SEPA
United States       Prevention, Pesticides    EPA 738-R-05-002
Environmental Protection   and Toxic Substances    June 2005
Agency         (7508C)
Reregistration
Eligibility Decision for
2,4-D

-------
Reregistration Eligibility Decision

               for

              2,4-D
             List A
            Case 0073
                      Approved By:
                      Debra Edwards, Ph.D.
                      Director, Special Review and
                      Reregistration Division
                      Date

-------
Table of Contents

Glossary of Terms and Abbreviations
                                                                                        vn
2,4-D Reregistration Eligibility Decision Team	  x

Executive Summary  	xi

I. Introduction	1

n. Chemical Overview  	  3
     A. Regulatory History	  3
     B. Chemical Identification	  4
     C. Use Profile  	  8
     D. Estimated Usage of Pesticide  	  9

HI. Summary of 2,4-D Risk Assessment	  15
     A. Human Health Risk Assessment	  15
           1.  Toxicity of 2,4-D	15
              a.  Toxicity Profile	  15
              b.  Safety and Database Uncertainty Factors  	  18
              c.  Carcinogenicity	19
              d.  Cumulative Assessment	  20
              e.  Endocrine Effects	  20
           2. Dietary Exposure and Risk from Food 	  23
              a.  Exposure Assumptions	  23
              b.  Population Adjusted Dose	  24
              c.  Food Risk Estimates	  24
           3. Dietary Exposure and Risk from Drinking Water  	  24
              a.  Surface Water	  25
              b.  Ground Water	  26
              c.  EDWCs Selected for Risk Assessment	  27
           4. Residential and Other Non-occupational Exposure	  27
              a.  Toxicity  	28
              b.  Residential Handler  	  29
               1) Exposure Scenarios, Data, and Assumptions  	  29
               2) Residential Handler Risk Estimates	  31
                      	31
              c.  Residential Postapplication Risk	  32
               1) Exposure Scenarios, Data, and Assumptions  	  32
               2) Postapplication Risk Estimates	  33
              d.  Recreational  Swimmer Risk	  34
                                            in

-------
          1) Exposure Scenarios, Data, and Assumptions	35
          2) Recreational Swimmer Risk Estimates  	36
     5. Aggregate Exposure and Risk	38
         a. Acute Aggregate Risk Assessment	38
         b. Chronic Aggregate Risk Assessment	40
         c. Short-term Aggregate Risk Assessments	41
         d. Cancer Aggregate Risk	42
         e. Aggregate Risk Characterization	42
     6. Occupational Risk  	43
         a. Occupational Toxicity  	43
         b. Occupational Handler Exposure	44
         c. Occupational Handler Risk Summary	45
         d. Occupational Postapplication Risk	50
          1) Exposure Scenarios, Data, and Assumptions	50
          2) Occupational Postapplication Risk Estimates	51
     7. Human Incident Data	52
     8. Cancer Epidemiology Studies	52
B. Environmental Risk Assessment	53
     1. Environmental Exposure  	53
         a. Environmental Fate and  Transport 	53
         b. Aquatic Organism Exposure	55
          1) Exposure to 2,4-D Acid in Surface Water	56
          2) Surface Water Modeling of 2,4-D Esters	56
          3) Modeling of Direct Application of 2,4-D for Control of Aquatic Weeds  ....  56
          4) Modeling of 2,4-D Use on Rice	57
         c. Terrestrial Organism Exposure	57
          1) Birds and Mammals  	58
          a) Exposure to Nongranular (Liquid) Formulations 	58
          b) Exposure to Granular Formulations	58
          2) Non-target Terrestrial Plants  	58
     2. Environmental Effects (Toxicity)	59
         a. Toxicity to Aquatic Organisms	59
         b. Toxicity to Terrestrial Organisms	61
     3. Ecological Risk Estimation (RQs)  	62
         a. Risk to Aquatic Organisms	63
          1) Fish and Aquatic Invertebrates  	63
          2) Aquatic Plants	64
         b. Risk to Non-target Terrestrial Organisms	65
          1) Birds	65
          2) Mammals  	67
          3) Non-Target Insects  	69
          4) Non-target Terrestrial Plants  	69
     4. Ecological Incidents	72
     5. Endangered Species Concerns 	72
                                       IV

-------
           6. Risk Characterization	74
              a.  Characterization of risk to aquatic organisms from direct aquatic application .  . 74
              b.  Characterization of risk to mammals from terrestrial use  	75
              c.  Characterization of risk to birds from terrestrial use  	76
              d.  Characterization of risk to non-target plants from terrestrial use	77

IV. Risk Management, Reregistration, and Tolerance Reassessment Decision 	79
     A.  Determination of Reregistration Eligibility	79
     B.  Public Comments and Responses  	79
     C.  Regulatory Position	80
           1. Food Quality Protection Act Findings	80
              a.  "Risk Cup" Determination	80
              b.  Determination of Safety to U.S. Population 	80
           2. Endocrine Disrupter Effects	81
           3. Cumulative Risks	81
           4. Special Review Disposition  	82
           5. Dioxin Contaminants	82
     D.  Tolerance Reassessment Summary	84
           1. Tolerances Currently Listed Under 40 CFR §180.142  	84
           2. Tolerances to Be Proposed Under 40 CFR §180.142  	89
           3. Codex Harmonization	97
           4. Residue Analytical Methods - Plants and Livestock (GLN 860.1340)	97
     E. Regulatory Rationale	98
           1. Human Health Risk Management	98
              a.  Residential Risk	98
               1)  Residential risk summary  	98
               2)  Residential Post-application Mitigation	99
               3)  Residential Swimmer Mitigation	99
              b.  Aggregate Risk	100
               1)  Aggregate Risk Summary	100
               2)  Acute Aggregate Risk	100
               3)  Short-term Aggregate Risk 	101
               4)  Chronic (Non-Cancer) Aggregate Risk  	101
               5)  Aggregate Risk Mitigation 	102
              c. Occupational Risk Mitigation 	102
               1)  Handler Risk Mitigation 	102
               2)  Post-application Risk Mitigation	102
           2. Environmental Risk Mitigation	103
              a.  Birds	103
              b.  Mammals	104
              c.  Aquatic Organisms	105
              d.  Non-target Insects  	106
              e.  Non-target Terrestrial Plants	106
              f  Summary of Environmental Risk Mitigation	106

-------
     F. Other Labeling Requirements  	106
          1. Endangered Species Considerations	106
          2. Spray Drift Management  	107
          3. Consumer Labeling Initiative	107

V. What Registrants Need To Do  	108
     A. Manufacturing Use Products	109
          1. Additional Generic Data Requirements	109
     B. End-Use Products	Ill
          1. Additional Product-Specific Data Requirements	Ill
          2. Labeling for End-Use Products	Ill
     C. Existing Stocks	Ill
     D. Required Labeling Changes Summary Table  	113

VI. Appendicies	153
     Appendix A.  Table of 2,4-D Use Patterns Eligible for Reregistration (Case 0073)	154
     Appendix B.  Data Supporting Guideline Requirements for the Reregistration of 2,4-D  ... 169
     Appendix C.  Technical Support Documents  	184
     Appendix D.  Citations Considered to be Part of the Data Base Supporting the Reregistration
          Eligibility Decision (Bibliography) for 2,4-D 	187
     Appendix E.  Generic Data Call-In	292
     Appendix F.  Product Specific Data Call-In  	294
     Appendix G.  EPA's Batching of 2,4-D Products for Meeting Acute Toxicity Data
          Requirements for Reregistration  	296
     Appendix H.  List of Registrants Sent This Data Call-In	298
                                            VI

-------
Glossary of Terms and Abbreviations
A           Acre
AGDCI      Agricultural Data Call-In
ae           Acid Equivalent
ai           Active Ingredient
aPAD        Acute Population Adjusted Dose
AR          Anticipated Residue
BCF         Bioconcentration Factor
CFR         Code of Federal Regulations
cPAD        Chronic Population Adjusted Dose
CSF         Confidential Statement of Formula
CSFn USDA  Continuing Surveys for Food Intake by Individuals
DCI         Data Call-In
DEEM       Dietary Exposure Evaluation Model
DFR         Dislodgeable Foliar Residue
DWLOC     Drinking Water Level of Comparison.
EC          Emulsifiable Concentrate Formulation
EDSP        Endocrine Disruption Screening Program
EDWC       Estimated Drinking Water Concentration
EEC         Estimated Environmental Concentration
EPA         Environmental Protection Agency
EUP         End-Use Product
FDA         Food and Drug Administration
FIFRA       Federal Insecticide, Fungicide, and Rodenticide Act
FFDCA      Federal Food, Drug, and Cosmetic Act
FQPA       Food Quality Protection Act
FOB         Functional Observation Battery
G           Granular Formulation
GENEEC    Tier I Surface Water Computer Model
GLN         Guideline Number
HAFT       Highest Average Field Trial
HAT           Hour After Treatment
IR           Index Reservoir
LC50        Median Lethal Concentration. A statistically derived concentration of a substance that
             can be expected to cause death in 50% of test animals. It is usually expressed as the
             weight of substance per weight or volume of water, air or feed, e.g., mg/1, mg/kg or
             ppm.
LD50        Median Lethal Dose. A statistically derived single dose that can be expected to cause
             death in 50% of the test animals when administered by the route indicated (oral,
             dermal, inhalation). It is expressed as a weight of substance per unit weight of animal,
             e.g., mg/kg.
LOC         Level of Concern
LOD         Limit of Detection
LOAEL      Lowest Observed Adverse Effect Level
                                          vn

-------
MATC       Maximum Acceptable Toxicant Concentration
|ig/g         Micrograms Per Gram
|ig/L         Micrograms Per Liter
mg/kg/day    Milligram Per Kilogram Per Day
mg/L         Milligrams Per Liter
MOE         Margin of Exposure
MRID        Master Record Identification (number). EPA's system of recording and tracking
             studies submitted
MSWC       Maximum Swimming Water Concentration
MUP         Manufacturing-Use Product
NA          Not Applicable
NAWQA     USGS National Water Quality Assessment
NCOD       National Drinking Water Contaminant Occurrence Database
NPDES       National Pollutant Discharge Elimination System
NR          Not Required
NOAEL      No Observed Adverse Effect Level
OP          Organophosphate
OPP           EPA Office of Pesticide Programs
OPPTS       EPA Office of Prevention, Pesticides and Toxic Substances
ORETF       Outdoor Residential Exposure Task Force
PAD         Population Adjusted Dose
PCA         Percent Crop Area
PDIC         Product-Specific Data Call-In
POP         USDA Pesticide Data Program
PHED          Pesticide Handler's Exposure Data
PHI          Preharvest Interval
ppb          Parts Per Billion
PPE         Personal Protective Equipment
ppm         Parts Per Million
PRZM/
EXAMS      Tier II Surface Water Computer Model
Ql *          The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer Risk
             Model
RAC         Raw Agriculture Commodity
RED         Reregistration Eligibility Decision
REI          Restricted Entry Interval
RfD          Reference Dose
RQ          Risk Quotient
SCI-GROW  Tier I Ground Water Computer Model
SAP           Science Advisory Panel
SF           Safety Factor
SLC           Single Layer Clothing
SLN         Special Local Need (Registrations Under Section 24(c)) of FIFRA)
STORET     Storage and Retrieval Environmental Data System
                                         Vlll

-------
TGAI         Technical Grade Active Ingredient
TRR          Total Radioactive Residue
TWAM       Time Weighted Annual Mean
USDA        United States Department of Agriculture
USGS         United States Geological Survey
UF           Uncertainty Factor
UV           Ultraviolet
WPS          Worker Protection Standard
                                           IX

-------
2,4-D Reregistration Eligibility Decision Team

Office of Pesticide Programs:

Biological and Economic Analysis Assessment

Elisa Rim
Rafael Prieto
Steve Jarboe
Tim Kiely

Environmental Fate and Effects Risk Assessment

Mark Corbin
Bill Evans
James Hetrick
Sid Abel

Health Effects Risk Assessment

Bill Hazel
Timothy Dole
Linda Taylor
Felecia Fort
Toiya Jimerson
Michael Metzger
Whang Phang

Risk Management

Katie Hall
Mark Seaton
Moana Appleyard
Tom Myers
Margaret Rice

-------
Executive Summary

     EPA has completed its review of public comments on the preliminary risk assessments and is
issuing its risk management decision for 2,4-D. The revised risk assessments are based on review of
the required target data base supporting the use patterns of the currently registered products and
additional information received from the 2,4-D Task Force IE. After considering the risks identified
in the revised risk assessment and comments and mitigation suggestions from interested parties, EPA
developed its risk management decision for uses of 2,4-D that pose risks of concern. The decision is
discussed fully in this document.

     2,4-D is an herbicide in the phenoxy or phenoxyacetic acid family that is used post-emergence
for selective control of broadleaf weeds. 2,4-D is registered for use on a variety of food/feed sites
including field, fruit, and vegetable crops. 2,4-D is also registered for use on turf, lawns, rights-of-
way, aquatic and forestry applications. Residential homeowners may use 2,4-D on lawns.

     Based primarily on pesticide usage information from 1992 through 2000 for agriculture and
1993 through 1999 for non-agriculture,  total annual domestic usage of 2,4-D is approximately 46
million pounds, with 30 million pounds (66%) used for agriculture and 16 million pounds (34%) used
for non-agriculture. In terms of pounds, total 2,4-D usage is allocated mainly to pasture/rangeland
(24%), lawn by homeowners with fertilizer (12%), spring wheat (8%), winter wheat (7%),
lawn/garden by lawn care operators/landscape maintenance contractors (7%), lawn by homeowners
alone (without fertilizer) (6%), field corn (6%), soybeans (4%), summer fallow (3%), hay other than
alfalfa (3%) and roadways (3%). Agricultural sites with at least 10% of U.S. acreage treated include
spring wheat (51%), filberts (49%), sugarcane (36%), barley (36%), seed crops (29%), apples (20%),
rye (16%), winter wheat (15%), cherries (15%), oats (15%), millet (15%), rice (13%), soybeans
(12%), and pears (10%). For 2,4-D, rates per application and rates per year are generally less than
1.50 pounds acid equivalent (a.e.) per acre and 2.00 pounds a.e. per acre (Ibs ae/A),  respectively. 2,4-
D is used predominantly in the Midwest, Great Plains, and Northwestern United States.

     The Food Quality Protection Act (FQPA) requires that, when considering whether to establish,
modify, or revoke a tolerance, 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." 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 as to 2,4-D and any other substances. For the purposes of this tolerance action,
therefore, EPA has not assumed that 2,4-D  has a common mechanism of toxicity with other
substances. 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 (OPP) 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/.

Dietary Risk
                                            XI

-------
     Acute and chronic dietary exposures for food and drinking water do not exceed the Agency's
level of concern; therefore, no mitigation is warranted at this time for any dietary exposure to 2,4-D.

     The maximum contaminant level (MCL) established by EPA's Office of Water (OW) for 2,4-D
is 70 micrograms/liter (ug/1; ppb).  Further, it is important to note that an MCL is an enforceable limit
under the Safe Drinking Water Act (SDWA). To minimize the possibility that aquatic applications
will result in drinking water concentrations in excess of the MCL, registrants and the Agency have
developed label language for the direct aquatic use of 2,4-D to control aquatic weeds.

Residential Risk

     Potential exposures are anticipated as a result of homeowner and commercial applications in
residential areas.  Applications can be made to lawns.  In addition to residential areas, there are also
potential postapplication exposure scenarios that may occur in public areas such as parks, recreational
areas, and golf courses.  The Agency evaluated 2,4-D exposures to residential handlers during
mixing, loading and application to turf/ornamentals and 2,4-D postapplication exposure to residues by
adults and children on treated turf.

     In preliminary versions of the risk assessment, when considered alone, acute and short-term
residential risks posed by the use of 2,4-D were not of concern to the Agency; however, when
considered as part of an aggregate exposure with food and drinking water, exposures did exceed the
Agency's level of concern. As a result, 2,4-D registrants agreed to reduce the maximum application
rate to turf and residential lawns from 2.0 Ibs ae/A to 1.5 Ibs ae/A.  Chronic residential exposures to
2,4-D are not expected due to its use pattern.

Aggregate Risk

     An aggregate risk assessment looks at the combined risk from dietary exposure (food and
drinking water pathways), as well as exposures from non-occupational sources (e.g., residential uses).
In the preliminary and revised risk assessments, the estimated acute and short-term exposures
exceeded the Agency's level of concern. As a result, 2,4-D registrants agreed to reduce the maximum
application rate to turf and residential lawns from 2.0 pounds acid equivalent per acre (Ibs ae/A) to
1.5 Ibs ae/A.  The current risk assessment considers exposures from the reduced application rate for
residential turf.

     Two methods of aggregate risk calculations were employed in assessing the aggregate risk of
2,4-D. The first method is the drinking water level of concern (DWLOC) method.  OPP (Office of
Pesticide Programs) has traditionally compared estimates of concentrations of a pesticide in drinking
water to DWLOCs.  A DWLOC is the portion of the acute population adjusted dose (aPAD)  or
chronic population adjusted dose (cPAD) remaining after estimated dietary (food only) exposures
have been subtracted and the remaining  exposure has been converted to a concentration (ug/liter or
ppb).  This concentration value (DWLOC) represents the available or allowable exposure through
drinking water. The second method is the forward calculation method. In this approach, food,
drinking water, and residential exposures are aggregated and compared to an appropriate endpoint. A
                                             xn

-------
population adjusted dose, or PAD, is the reference dose (RfD) adjusted for the FQPA safety factor. A
risk estimate that is less than 100% of the acute PAD (aPAD), the dose at which an individual could
be exposed over the course of a single day and no adverse health effects would be expected, does not
exceed EPA's level of concern. Likewise, risk estimate that is less than 100% of the chronic PAD
(cPAD), the dose at which an individual could be exposed over the course of a lifetime and no
adverse health effects would be expected, does not exceed EPA's level of concern.

     In the case of 2,4-D, the DWLOCs were calculated for comparison to the MCL established by
the EPA Office of Water and aggregate risks were calculated using the forward calculation approach
for comparison to the appropriate endpoint. The  respective DWLOCs and aggregate risks are shown
for acute, chronic and short term exposures in the following sections.

     Acute aggregate risk. The acute aggregate risk assessments address exposure to 2,4-D
residues in food and water using both the DWLOC and forward calculation approach. Acute
residential exposures from swimming in treated water bodies or playing on treated turf were not
included because exposures are unlikely to co-occur with acute dietary exposures. The acute
DWLOCs are 432 ppb or greater with the most sensitive population being females 13-49 years old.
The estimated drinking water concentrations (EDWCs) of 118 ug/liter for surface water and 15
ug/liter for groundwater are substantially less than the DWLOCs which means that the risks are not of
concern.

     Acute aggregate risks were also assessed by aggregating acute food exposures and acute water
exposures using Lifeline. The acute aggregate risks are not of concern because they are less than 100
percent of the aPAD.  The highest risks (58 percent of the aPAD) are for females 13-49 years old
because these risks are based upon the lower no-observed adverse effect level (NOAEL) of 25
mg/kg/day from a developmental  study in rats.

     Short-term aggregate risk. Short term aggregate risk assessments were conducted by
calculating DWLOCs based upon short term turf  exposures, chronic food exposures and short term
endpoints. Short term exposures from swimming in treated water bodies were not included because
these exposures represent high-end unlikely scenarios.  The short term DWLOCs were calculated
only for females 13-49 and children 1-6 because these population subgroups have the highest
exposure and are protective of the other subgroups.  The DWLOCS range from 24 to 54 ug/liter.
These DWLOCs are all greater than the EDWCs, which range from 15 to 23 ug/liter,  and indicate that
short term risks  are not of concern.

     Short term aggregate risks were also assessed by aggregating short term turf exposures, chronic
food exposures and chronic water exposures using the forward calculation approach.  Short term
aggregate risks were calculated  only for females 13-49 and children 1-6 because these population
subgroups have the highest exposure and are protective of the other subgroups.  The short term
aggregate margins of exposure (MOEs) indicate that the short term risks are not of concern because
the MOEs equal or exceed the target MOE of 1000.
                                            Xlll

-------
     Chronic (non-cancer) aggregate risk.  Chronic DWLOCs were calculated based upon chronic
dietary exposures.  As there are no chronic residential exposures, residential exposures were not
included in the chronic DWLOC calculations.  The chronic DWLOCs are 47 ug/liter or greater with
the most sensitive populations being infants and children. The EDWCs, which range from 1.5 to 23
ug/liter, are less than the DWLOCs which means that the risks are not of concern.  It should be noted
that the master label indicates that potable water consumption from a treated water body cannot begin
until the 2,4-D concentration is 70 ug/liter or below, therefore an annual average exposure at the
MCL of 70 ug/liter would not occur because dissipation would reduce the initial concentration of 70
ug/liter to an annual average concentration of 11 ug/liter.

     Chronic aggregate risks were also assessed by aggregating chronic food exposures and chronic
water exposures using the forward calculation approach. The chronic aggregate risks are presented as
percent cPAD  are not of concern because they are less than 100 percent of the cPAD.  The highest
risks (38 percent of the cPAD) are for children 1-2 years old.

Occupational Risk

     Based on current use patterns, occupational handlers (mixers, loaders, and applicators) may be
exposed to 2,4-D during and after normal use.  The Agency identified 18 handler scenarios resulting
from mixing/loading and applying 2,4-D for crop and non-crop uses. For the occupational use of 2,4-
D, EPA is concerned about any Margin of Exposure (MOE) less than 100, which incorporates
uncertainty factors of lOx for interspecies variation and lOx for intraspecies variation.

     With the exception of mixing/loading wettable powder, all of the short-term and intermediate-
term MOEs exceed the target of 100 with baseline personal protective equipment (PPE) (i.e., long-
sleeved shirt, long pants, shoes plus socks, no respirator) or single layer PPE (i.e., long-sleeved shirt,
long pants, shoes plus  socks, gloves, no respirator) and are not of concern. The MOEs for handling
wettable powder are above 100 with engineering controls (i.e., water soluble bags).

Ecological Risk

     Fish and Aquatic Invertebrates: Estimated risk quotients (RQs) from use of 2,4-D acid and
amine salts in aquatic weed control through direct subsurface application to water bodies exceed the
restricted use LOCs for freshwater invertebrates.  There are no chronic LOG exceedances for this use.
Estimated RQs from use of 2,4-D BEE in weed control through direct subsurface application to water
bodies  exceed the acute risk level of concern (LOG) for freshwater fish and invertebrates and chronic
risk LOG for freshwater and estuarine fish and freshwater invertebrates when compared on an acid
equivalent basis. Estimated RQs from use of 2,4-D  acid and amine salts in rice paddies exceed the
acute endangered species LOCs for freshwater invertebrates.

     Non-Target Aquatic Plants:  For non-target aquatic plants, estimated RQs from the runoff/drift
of 2,4-D acid and amine salts from use on terrestrial crops exceed the aquatic vascular plant
endangered species LOCs for use of 2,4-D acid and amine salts on pasture and apples.  Consideration
of average application rates and assuming a proportional reduction in EECs results in RQs below the
                                             xiv

-------
endangered species LOG. Likewise, there are no LOG exceedances from the drift of the ester forms
to aquatic water bodies or from the runoff of the ester forms to water bodies from use on terrestrial
sites.
     Estimated RQs for the scenario of direct application to water for aquatic weed control for 2,4-D
acid and amine salts exceed the acute and endangered species LOCs for aquatic vascular and acute
the LOG for non-vascular plants, while estimated RQs from use of 2,4-D BEE (the only ester
registered for aquatic weed control) for direct application to water for weed control exceed all LOCs
for vascular and the acute LOG for non-vascular plants.
     Estimated RQs for use of 2,4-D acid and amine salts in rice paddies exceed the acute and
endangered species LOCs for aquatic vascular plants.  Consideration of average application rates
results in RQs below the endangered species LOCs.

     Birds: For non-granular spray applications of 2,4-D acid, amine salts, and esters, estimated RQs
exceed acute LOCs for most crop scenarios for short grass, tall grass, and broadleaf forage exposures.
For birds that eat fruit and large insects, acute endangered LOCs are exceeded for non-cropland,
forest, and cranberry  scenarios.  Chronic LOCs are exceeded for birds that forage on short grass when
the application rate of 2,4-D ranges from 2.0 to 4.0 Ibs ae/A such as with non-cropland areas,
cranberries, or asparagus. For granular broadcast applications, acute LOCs are exceeded for several
different crop scenarios and bird weights.  The chronic LOC is not exceeded for granular broadcast
applications.

     Mammals: For  non-granular formulations of 2,4-D, estimated RQs exceed acute LOCs for
mammals feeding on plants and insects for all uses assessed for  small and medium size mammals,
except potatoes and citrus.  There were no exceedances for granivores exposed to non-granular
formulations of 2,4-D.  LOCs for acute exposure to granular 2,4-D products are exceeded for all sites
with the following exceptions: 1000 g mammals in turf, aquatic  areas, and cranberries.  Mammalian
chronic RQs range from 0.05 to 200 and chronic LOCs were exceeded in all cases with the exception
of potatoes and citrus (large insects, seeds).  Consideration of average application rates results in
acute RQs below the LOCs for non-granular and granular applications.  However, consideration of
average application rates for non-granular and granular applications did not result in RQs below the
chronic LOC.

     Insects: Since study results show that 2,4-D DMAS and 2,4-D EHE are practically non-toxic to
honey bees, the potential for 2,4-D and its salts and esters is predicted to pose minimal risk to
pollinators and other  beneficial insects.

     Non-Target Terrestrial Plants: Estimated RQs exceed acute LOCs for both non-endangered
and endangered plants for non-granular and granular uses at many use sites.  Consideration of average
application rates did not result in RQs below LOCs.

     In summary, some ecological risks are of concern on some sites for some species. The
Agency's characterization of its assessment of ecological risk is  provided in section m.B.3 of this
document.  The mitigation measures of (1) reducing maximum application rates, and (2) specifying a
                                             xv

-------
required spray droplet size of "Medium to Coarse" or coarser (i.e., prohibiting "fine" sprays) are
expected to lessen, but not eliminate, the risk of 2,4-D to wildlife and plants.

Summary of Mitigation Measures

     EPA has determined that 2,4-D is eligible for reregistration provided the mitigation outlined in
this document is implemented.

Dietary Risk

•    Acute and chronic dietary exposures for food and drinking water do not exceed the Agency's
     level of concern; therefore, no mitigation is warranted at this time for any dietary exposure to
     2,4-D.

Residential Risk

•    Maximum turf rate is reduced from 2.0 Ibs ae/A to 1.5 Ibs ae/A.
•    At the agreed-upon maximum application rate of 1.5 Ibs ae/A for residential turf, acute and
     short-term residential risks posed by the use of 2,4-D are not of concern to the Agency.  Due to
     its use pattern, chronic residential exposures to 2,4-D are not expected.

Occupational Risk

     Risks from handling wettable-powder products will be mitigated by requiring wettable powder
     products to be packaged in water-soluble packaging.
•    Personal protective equipment (PPE) prescribed in the exposure reduction plan set forth in 1992
     will be replaced with the PPE requirements outlined in this document.

Ecological Risk

     The measures to control spray drift are expected to reduce the risk of 2,4-D to non-target plants.
•    Maximum turf rate is reduced from 2.0 Ibs ae/A to 1.5 Ibs ae/A.
     Implementation of the application rates set forth in the Master Label will reduce rates (as
     compared to current rates on existing labels) for field corn, popcorn, sweet corn, small grains,
     fallowland/stubble, non-cropland, turf, aquatic applications (surface), pasture, and soybean.
                                             xvi

-------
I. Introduction

     The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended in 1988 to
accelerate the reregistration of products with active ingredients registered prior to November 1, 1984.
The amended Act calls for the development and submission of data to support the reregistration of an
active ingredient, as well as a review of all submitted data by the U.S. Environmental Protection
Agency (referred to as EPA or "the Agency"). Reregistration 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 and the Federal Food Drug and Cosmetic Act (FFDCA) to require reassessment
of all existing tolerances for pesticides in food.  FQPA also requires EPA to review all tolerances in
effect on August 3, 1996 by August 3, 2006. In reassessing these tolerances, the Agency must
consider, among other things, aggregate risks from non-occupational sources of pesticide exposure,
whether there is increased susceptibility to infants and children, and the cumulative effects of
pesticides with a common mechanism of toxicity. When a safely finding has been made that
aggregate risks are not of concern and the Agency concludes that there is a reasonable certainty of no
harm from aggregate exposure, the tolerances are considered reassessed.  EPA decided that, for those
chemicals that have tolerances and are undergoing reregistration, tolerance reassessment will be
accomplished through the reregistration process.

     As mentioned above, FQPA requires EPA to consider "available information" concerning the
cumulative effects of a particular pesticide's residues and "other substances that have a common
mechanism of toxicity" when considering whether to establish, modify, or revoke a tolerance.
Potential cumulative effects of chemicals with a common mechanism of toxicity are considered
because low-level exposures to multiple chemicals causing a common toxic effect by a common
mechanism could lead to the same adverse health effect as would a higher level of exposure to any
one of these individual chemicals. 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 the 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/.

     Unlike other pesticides for which EPA has considered cumulative risk based on a common
mechanism of toxicity, EPA has not made a common mechanism of toxicity finding for 2,4-
dichlorophenoxyacetic acid (2,4-D). Therefore, for the purposes of tolerance reassessment and a
decision on reregistration eligibility, EPA is assuming that 2,4-D does not share a common
mechanism of toxicity with other compounds. In the future, if information suggests 2,4-D shares a
common mechanism of toxicity with other compounds, additional testing may be required and a
cumulative assessment may be necessary.
                                       Page 1 of 304

-------
     This document presents summaries of EPA's revised human health and ecological risk
assessments, tolerance reregistration decision, and the reregistration eligibility decision for 2,4-D.
The document consists of six sections. Section I contains the regulatory framework for
reregistration/tolerance reassessment.  Section II provides a profile of the use and usage of the
chemical.  Section in gives an overview of the revised human health and environmental effects risk
assessments based on data, public comments, and other information received in response to the
preliminary risk assessments. Section IV presents the Agency's reregistration eligibility and risk
management decisions. Section V summarizes label changes necessary to implement the risk
mitigation measures outlined in Section IV.  Finally, the Appendices list related information,
supporting documents.  The preliminary and revised risk assessments for 2,4-D are available in the
Public Docket, under docket  number OPP-2004-0167 and on the Agency's web page,
http: //www. epa. gov/edockets.
                                       Page 2 of 304

-------
n. Chemical Overview

     A. Regulatory History

     2,4-D has been used as an herbicide since the mid-1940s.  Currently over 600 end-use products
are registered for use on over 300 distinct agricultural and residential sites, and there are over 100
tolerances for 2,4-D listed in the Code of Federal Regulations.  2,4-D was the subject of a
Registration Standard and a Registration Standard Guidance Document dated February 16, 1988 and
September 9, 1988, respectively.  These documents summarized the regulatory conclusions based on
available data,  and specified the additional data required for reregistration purposes.  Numerous data
submissions have been received and evaluated since the Registration Standard Guidance Document
was published.

Special Review

     2,4-D has been in pre-Special Review status since September 22, 1986, because of
carcinogenicity concerns.  More specifically, there were concerns for epidemiological links of 2,4-D
to non-Hodgkin's lymphoma from both occupational and residential exposure. A proposed decision
not to initiate Special Review was published (53 FR 9590) on March 23, 1988 based on findings that
such a link could not be established. The final decision was deferred until reregistration. In part to
address these concerns,  the 2,4-D Task Force agreed to risk reduction measures in September 1992
that included an exposure reduction plan effected through modifications of technical and
manufacturing-use product labels and implementation of a user education program.

     A Science Advisory Board/Scientific Advisory Panel Special Joint Committee reviewed
available epidemiological and other data on 2,4-D in 1992 and concluded that "the data are not
sufficient to conclude that there is a cause and effect relationship between exposure to 2,4-D and non-
Hodgkin's lymphoma." 2,4-D was classified as a Group D, not classifiable as to human
carcinogenicity.  The Agency requested further histopathological examinations of rat brain tissues and
mouse spleen tissues in question.  These exams were submitted and reviewed, and on March 16,
1999, the Agency notified the 2,4-D Task Force that the Agency would continue to classify 2,4-D as
a Group D carcinogen.

     The  Agency has twice recently reviewed epidemiological studies linking cancer to 2,4-D. In
the first review, completed January 14, 2004, EPA concluded there is no additional evidence that
would implicate 2,4-D as a cause of cancer (EPA, 2004).  The second review of available
epidemiological studies occurred in response to comments received during the Phase 3 Public
Comment Period for the 2,4-D RED. EPA's report, dated December 8, 2004 and authored by EPA
Scientist Jerry Blondell, Ph.D., found that none of the more recent epidemiological studies
definitively linked human cancer cases to 2,4-D.

     Final notice of the Agency's decision not to initiate Special Review will be issued at the
completion of the reregistration process.
                                       Page 3 of 304

-------
Residue Tolerances

     Tolerances for residues of 2,4-D in/on plant and processed food/feed commodities, fish, and
potable water are expressed in terms of 2,4-D per se [40 CFR §180.142(a)(l-6 and 9-12) and (b)].
There are currently approximately 110 tolerances for 2,4-D.

     The Industry Task Force n on 2,4-D Research Data (Task Force n) is supporting the
reregistration of 2,4-D. The members of the Task Force currently include Agro-Gor Corp (jointly
owned by Atanor, S.A. and FBI-Gordon Corp.), Dow AgroSciences, and Nufarm USA. In addition,
USDA's Interregional Project No. 4 (IR-4) is supporting the reregistration of a number of minor crop
uses for 2,4-D, and the California Citrus Quality Council (CCQC) is supporting selected uses of 2,4-
D isopropyl ester (IPE) on citrus fruits.
     B.  Chemical Identification

     2,4-D [2,4-dichlorophenoxyacetic acid] is a List A pesticide active ingredient classified as an
herbicide, a plant growth regulator, and a fungicide. It is, however, mainly used as a selective
postemergence herbicide for the control of broadleaf weed species in a variety of food/feed sites
including field, fruit, and vegetable crops. In addition to the acid form, there are numerous salts and
esters of 2,4-D in Reregistration Case 0073, each with an assigned PC Code number, that are
presently registered as active ingredients in end-use products (EPs). Nine forms of 2,4-D are
currently supported; these forms are listed in Table 1 below.  With regards to analytical methodology,
the quantitative recovery of residues of concern are enhanced by the formation of the more polar acid
form of 2,4-D. Given that results of 2,4-D analyses are typically expressed in terms of the quantified
levels of the acid form, 2,4-D concentrations in product formulations are typically referred to in terms
of acid equivalents (ae).

     Chemical structures and information are presented in Tables  1 and 2 for 2,4-D acid and those
salts and esters with registered manufacturing-use and/or end-use products (MPs/EPs) being
supported by 2,4-D Task Force n and its member companies.

Table 1. Chemical Structures for Supported Forms of 2,4-D Acid, Amine Salts, and Esters
2,4-D active ingredients with registered MPs/EPs
2,4-D acid
Empirical Formula: C8H6C12O3
Molecular Weight: 221.0
CAS Registry No.: 94-75-7
PC Code: 030001

2,4-D sodium salt (Na)
Empirical Formula: C8H,Cl2NaO3
Molecular Weight: 243.03
CAS Registry No. : 2702-72-9
PC Code: 030004
                                       Page 4 of 304

-------
2,4-D active ingredients with registered MPs/EPs
                                    OH
                                O
                                                                          .Cl
                                                                                     O  Na
                                                                                  O
2,4-D diethanolamine salt (PEA)
Empirical Formula:  C17H17C19NO5
Molecular Weight:  326.18
CAS Registry No.:  5742-19-8
PC Code:        030016
                                   2,4-D dimethylamine salt (DMA)
                                   Empirical Formula:  C10H13C1,NO3
                                   Molecular Weight:  266.13
                                   CAS Registry No.:  2008-39-1
                                   PC Code:        030019
 Cl,
Cl
                           O"[NH (CH CH OH) ]
                        O
                                                              0~[NH2(CH3)J
2,4-D isopropvlamine salt (IPA)
Empirical Formula:  CUH15CLNO3
Molecular Weight:  280.04
CAS Registry No.:  5742-17-6
PC Code:        030025
                                   2,4-D triisopropanolamine salt (TIPA)
                                   Empirical Formula:  C17H,7C1,NO6
                                   Molecular Weight:   412.3~1
                                   CAS Registry No.:   32341-80-3
                                   PC Code:        030035
                 .Cl
                  O
                                    Cl
                             O'[NH3CH(CH3)2]
                                                  O
                                                             O ~ NH+(CH,CHOHCH3)3
                         O
                                                                          O
2,4-D 2-butoxyethyl ester (BEE)
Empirical Formula:  C14H18C12O4
Molecular Weight:  321.20
CAS Registry No.:  1929-73-3
PC Code:        030053
                                   2,4-D 2-ethylhexyl ester (2-EHE)'
                                   Empirical Formula:  C16H22C12O3
                                   Molecular Weight:  333.2~7
                                   CAS Registry No.:  1928-43-4
                                   PC Code:        030063
                                           Page 5 of 304

-------
 2,4-D active ingredients with registered MPs/EPs
  Cl .
               Cl
                     0
                                 O
                                              CH
                                                     Cl
    .Cl
                                                                  o
                                                                        0
                        ,CH,
                                                                                         /\    CH,
                                                                                       ^  ^
                              2,4-D isopropyl ester (IPE)
                              Empirical Formula:  CUH19C19O3
                              Molecular Weight:   263.12
                              CAS Registry No.:   94-11-1
                              PC Code:   030066
                                                      O
CH
1 Formerly identified as the isooctyl ester.

      Available data concerning identification of the active ingredients are summarized in Table 2 for
2,4-D acid, salts, and esters with registered MPs/EPs.
                                           Page 6 of 304

-------
Table 2. Available Data Concerning Identification of the Active Ingredient1
Active ingredient
(PC Code)
2,4-D acid
(030001)
2,4-D Na salt
(030004)
2,4-D DBA salt
(030016)
2,4-D DMA salt
(030019)
2,4-D IPA salt
(030025)
2,4-D TIPA salt
(030035)
2,4-D BEE
(030053)
2,4-D 2-EHE
(030063)
2,4-D IPE
(030066)
Color
white
white
cream
amber
amber
amber
dark
amber
dark
amber
pale
amber
Physical State
crystalline
solid
powder
powder
aqueous
liquid
aqueous
liquid
aqueous liquid
liquid
liquid
liquid
Melting Point/
Boiling Point
m.p. 138-141 C
m.p. 200 C
m.p. 83 C
m.p. 1 18-120 C
(PAI)
nip. 121 C
(PAI)
m.p, 87-1 IOC
(PAI)
b.p. 89 C
b.p. 300 C
b.p. 240 C
Density/Specific
Gravity
s.g=1.416
at25C
bulk = 42.2 lb/ft3
at25C
bulk = 0.762
g/cm3
at25C
s.g. = 1.23
at20C
s.g. = 1.15
at20C
s.g, = 1,21
at20C
s.g. = 1.225
at20C
s.g. = 1.152
at20C
s.g. = 1.252
at25C
Octanol/Water
Partition Coeff.
Log Knmf
0.001 Msol'n
pH5 2.14
pH 7 0.177
pH9 0.102
Vapor Pressure
1.4x 10'7mmHg
at25C
N/A 2; salt dissociates to acid in water
2.24 x ID'2
at25C
N/A; salt
dissociates to acid
in water
<1.33xlO-5Paat
25 C

-------
     C.  Use Profile

     2,4-D comes in multiple chemical forms and is found in numerous end-use products intended
for use in a wide range of use patterns. 2,4-D is an ingredient in approximately 660 agricultural and
home use products, as a sole active ingredient and in conjunction with other active ingredients. 2,4-D
is formulated primarily as an amine salt in an aqueous solution or as an ester in an emulsifiable
concentrate.  Chemical forms covered by this risk assessment are as 2,4-D acid, 2,4-D DMAS, 2,4-D
IPA, 2,4-D TIPA, 2,4-D EHE, 2,4-D BEE, 2,4-D DEA, 2,4-D IPE, and 2,4-D sodium salt. Copies of
all labels may be found at http://www.cdpr.ca.gov/docs/epa/m2.htm. The following is information on
the currently registered uses including an overview of use sites and application methods. A detailed
table of the uses of 2,4-D eligible for reregistration is contained in Appendix A.

 Type of Pesticide: Herbicide

Target organism(s): A wide variety of broadleaf weeds and aquatic weeds

Mode of action: 2,4-D is thought to increase cell-wall plasticity, biosynthesis of proteins and the
production of ethylene. The abnormal increase in these processes is thought to result in uncontrolled
cell division and growth which damages vascular tissue.

Use Sites: Table 3 presents a summary of the registered 2,4-D uses.

Use Classification: General use

Formulation Types: Formulation types registered include emulsifiable concentrate, granular, soluble
concentrate/solid, water dispersible granules, and wettable powder.

Application Methods: 2,4-D may be applied with a wide range of application equipment including
fixed-wing aircraft, backpack sprayer, band sprayer, boom sprayer, granule applicator, ground-
directed sprayers, hand held sprayer, helicopter, injection equipment, tractor-mounted granule
applicator, and tractor-mounted sprayers.
Application Rates: For 2,4-D, rates per application and rates per year are generally less than 1.5
pounds acid equivalent (ae) per acre per year and 2.0 pounds a.e. per acre per year (Ibs ae/A),
respectively.  Maximum rates are 4.0 Ibs ae/A per year for asparagus, forestry uses, and non-cropland
uses, among others. The maximum rate for aquatic uses is 10.8 Ibs ae/acre foot for submerged
aquatic plants.
Application Timing: Timing of 2,4-D application can include at emergence, before bud break,
during dormancy, to established plantings, foliar, post-emergence, pre-emergence, pre-harvest, and
pre-plant.
                                       Page 8 of  304

-------
Table 3. Registered 2,4-D Uses
Crop Grouping
Terrestrial food crop
Terrestrial food and feed
crop
Terrestrial feed crop
Terrestrial non-food crop
Terrestrial non-food and
outdoor residential
Aquatic food crop
Aquatic non-food
outdoor
Aquatic non-food
industrial
Forestry
Outdoor residential
Indoor non-food
Representative Crops
Pear, Pistachio, Stone fruits
Agricultural fallow/idleland; Agricultural rights-of-way/fencerows/hedgerows;
Agricultural uncultivated areas; Apple; Barley; Citrus fruits; Corn (unspecified);Corn,
field; Corn, pop; Corn, sweet; Fruits (unspecified), Grapefruit, Lemon, Oats, Orange, Pome
fruits, Rice, Rye, Small fruits, Soil, preplant/outdoor, Sorghum, Sorghum (unspecified),
Soybeans (unspecified), Sugarcane, Tangelo, Tree nuts, Wheat
Grass forage/fodder/hay, Pastures, Rangeland, Rye, Sorghum
Agricultural fallow/idleland, Agricultural rights-of-way/fencerows/hedgerows,
Agricultural uncultivated areas, Airports/landing fields, Christmas tree plantations,
Commercial/industrial lawns, Commercial/institutional/industrial, premises/equipment
(outdoor), Forest nursery plantings (for transplant purposes), Golf course turf, Grasses
grown for seed, Industrial areas (outdoor), Nonagricultural outdoor buildings/structures,
Nonagncultural rights-of-way/fencerows/hedgerows, Nonagricultural uncultivated
areas/soils, Ornamental and/or shade trees, Ornamental lawns and turf, Ornamental sod
farm (turf), Ornamental woody shrubs and vines, Paved areas (private roads/sidewalks),
Potting soil/topsoil, Recreation area lawns, Recreational areas, Soil, preplant/outdoor,
Urban areas
Fencerows/hedgerows, Nonagricultural rights-of-way/fencerows/hedgerows, Ornamental
and/or shade trees, Ornamental lawns and turf, Ornamental woody shrubs and vines,
Paths/patios, Paved areas (private roads/sidewalks), Urban areas
Agricultural drainage systems, Aquatic areas/water, Commercial fishery water systems,
Irrigation systems, Lakes/ponds/reservoirs (with human or wildlife use), Rice,
Streams/rivers/channeled water, Swamps/marshes/wetlands/stagnant water
Aquatic areas/water, Streams/rivers/channeled water,
Swamps/marshes/wetlands/stagnant water
Drainage systems, Industrial waste disposal systems, Lakes/ponds/reservoirs (without
human or wildlife use)
Conifer release, Forest plantings (reforestation programs)(tree farms, tree plantations,
etc.), Forest tree management/forest pest management, Forest trees (all or unspecified),
Forest trees (hardwoods, broadleaf trees), Pine (forest/shelterbelt)
Residential lawns
Commercial transportation facilities-nonfeed/nonfood
     D. Estimated Usage of Pesticide

     Based primarily on pesticide usage information from 1992 through 2000 for agriculture and
1993 through 1999 for non-agriculture, total annual domestic usage of 2,4-D is approximately 46
million pounds, with 30 million pounds (66%) used by agriculture and 16 million pounds (34%) used
by non-agriculture (see the OPP Biological and Economic Assessment Division [BEAD] quantitative
use analysis [QUA] which is available on EPA's Pesticide Docket OPP-2004-0167 located at:
                                      Page 9 of 304

-------
http://www.epa.gov/edockets). In terms of pounds, total 2,4-D usage is allocated mainly to
pasture/rangeland (24%), lawn by homeowners with fertilizer (12%), spring wheat (8%), winter
wheat (7%), lawn/garden by lawn care operators/landscape maintenance contractors (7%), lawn by
homeowners alone (without fertilizer) (6%), field corn (6%), soybeans (4%), summer fallow (3%),
hay other than alfalfa (3%), and roadways (3%).

     Agricultural sites with at least 10% of U.S. acreage treated include spring wheat (51%), filberts
(49%), sugarcane (36%), barley (36%), seed crops (29%), apples (20%), rye (16%), winter wheat
(15%), cherries (15%), oats (15%), millet (15%), rice (13%), soybeans (12%) and pears (10%). For
2,4-D, rates per application and rates per year are generally less than 1.5 Ibs ae/A per year and 2.0 Ibs
ae/A per year, respectively. 2,4-D is used predominantly in the Midwest, Great Plains, and
Northwestern United States (Figure 1).
                                     Page 10 of 304

-------
                       Total 2,4-D Usage on an Area-Weighted Basis
            Legend
       2,4-D Use(lbs/sq mile)
          00
          0.1 -5.0
          5.1 -10.0
       .-•;, 10.1 - 25.0
       mm 25.1 - BO.O
0    250   500
                                Source of 2,4-D Use Data: Thelin, G.P., and Gianessi, L.P., 2000.
                                         USGS Open File Report 00-250
Figure 1. Estimated 2,4-D usage (Ibs ae/square mile). The estimates are based on pesticide use rates compiled
by the National Center for Food and Agricultural Policy (NCFAP) and modified by Thelin, G.P. and Gianessi,
L.P., 2000 (USGS Open-File Report 00-250)

-------
Application Rates, Timing and Frequency of Applications
     The 2,4-D master label (available in EPA docket #OPP-2004-0167) has been developed by the
2,4-D Task Force and represents the maximum supported application rates for agricultural and non-
agricultural uses. All end-use product manufacturers obtain 2,4-D starting material from companies
represented by the 2,4-D Task Force. EPA used the master label rates in the 2,4-D human health and
ecological risk assessments.  Some master label rates are lower than the rates present on existing
labels.  The Agency and the task force have agreed that all  of the 2,4-D labels will be updated with
the new master label rates as part of the registration process. All of the registrants, including those
that are not in the 2,4-D task force, will have to conform to the master label rates.  The master label
agreement is discussed in an internal Agency memo (EPA, March 18, 2003), which is available on
EPA's Pesticide Docket OPP-2004-0167 located at: http://www.epa.gov/edockets.

     Typically, one to three applications are made per growing season.  Applications are made to the
target weeds prior to crop emergence, after crop emergence, prior to harvest, and in the dormant
season, depending upon the crop. The label required spray volumes for ground applications range
from 0.0375 Ibs ae/A for applications to low bush blueberries to 4.0 Ibs ae/A for brush control. 2,4-D
can be applied over the top to tolerant crops such as small grains and rice, but must be  directed or
shielded for the more sensitive crops such as fruits and berries.

     The application rates on the master label are included in Table 4 for non-crop areas and Table 5
for agricultural crops. The average  application rates from the 2,4-D QUA report (EPA BEAD 2001)
are shown for comparison. With the exception of filberts, the  QUA data indicate that only one
application is made to most crops. The National Agricultural Pesticide Impact Assessment Program
(NAPIAP) report on Phenoxy Herbicides indicates that on average one 2,4-D application is made
annually to turfgrass.

Table 4. 2,4-D Application Rates for Non-Crop Areas
Aquatic Areas, Forestry, Non-Crop Areas and
Turf
Aquatic Areas - Floating Weeds
Aquatic Areas - Submerged Weeds
Tree and Brush Control - Tree Injection
Forestry - Weed and Brush Control
Forestry - Conifer Release
Irrigation Ditch Banks
Rights of Way Areas
Rangeland, Pastures
Turf- Grass Grown for Seed or Sod
Acid Equivalent Ibs (ae) Application Rates
Per Application/Per crop or Year
Master Label
2.0/4.0 per acre
10.8 per acre foot
1 to 2 ml per inch of trunk diameter
4.0/4.0 per acre
4.0/4.0 per acre
2.0/4.0 per acre
2.0/4.0 per acre
2.0/4.0 per acre
2.0/4.0 per acre
Amount Used per QUA
Report
5 12,000 lbsA
136,000 Ibs

2.1 million Ibs

35 1,000 Ibs
                                      Page 12 of 304

-------
Aquatic Areas, Forestry, Non-Crop Areas and
Turf
Turf- Ornamental
Acid Equivalent Ibs (ae) Application Rates
Per Application/Per crop or Year
Master Label
2.0/4.0 per acre B
Amount Used per QUA
Report
11.6 million Ibs
A. According to the NAPIAP report about 98,000 acres were treated for floating weeds and about 5,000 acres were treated for
submerged weeds by state agencies in 1993.
B. The registrants have agreed to reduce the ornamental turf rate from 2.0 to 1.5 Ibs ae per acre. The new maximum yearly rate
will be 3.0 Ibs ae per acre.
Table 5. 2,4-D Application Rates for Agricultural Crops
Agricultural Crops
Asparagus
Blueberries - Low Bush Wiper Bar
Blueberries - High Bush
Citrus (Growth Regulator)
Conifer Plantations
Corn (sweet)
Corn (field and pop)
Cranberries - granular applications
Cranberries - liquid applications
Fallowland and Crop Stubble
Filberts
Grain Sorgum
Grapes
Orchard Floors (Pome and Stone Fruits,
Tree Nuts)
Potatoes
Rice
Soybeans (Preplant burndown)
Strawberries (Except CA or FL)
Sugarcane
Cereal Grains
(Wheat, Barley, Millet, Oats and Rye)
Acid Equivalent Ibs (ae) Application Rates per Acre
Per Application/Per crop or Year
Master Label
2.0/4.0
0.0375 Ib/GA
1.4/2.8
0.1
4.0/4.0
0.5 to 1.0/1.5
0.5 to 1.5/3.0
4.0/4.0 dormant season application
1.2/2.4 growing season application
2.0/4.0
1 .0 Ib per 100 Ga/4 Apps per year
0.5 to 1.0/1.0
1.36/1.36
2.0/4.0
0.07/0.14
1.0 or 1.5/1.5
0.5 or 1.0/1.0
1.5/1.5
2.0/4.0
0.5 or 1.25/1.75
Average Rate per QUA Report
1.1/1.3
0.46/0.51
No Data
No Data
0.48/0.51
0.44/0.46
1.8/2.0
0.69/0.89
0.64/1.7
0.46/0.50
0.73/0.87
Apples = 1.2/1.4
Pears = 1.1/1. 5
0.10/0.17
0.92/0.94
0.46/0.47
1.2/1.3
0.75/0.99
Wheat= 0.44/0.48
Barley =0.46/0.47
Oats = 0.46/0.46
Rye = 0.50/0.50
Millet= 0.44/0.44
                                    Page 13 of 304

-------
Agricultural Crops
Wild Rice (MN only)
Acid Equivalent Ibs (ae) Application Rates per Acre
Per Application/Per crop or Year
Master Label
0.25/0.25
Average Rate per QUA Report
0.20/0.20
Page 14 of 304

-------
HE. Summary of 2,4-D Risk Assessment

     The following is a summary of EPA's human health and ecological risk findings and
conclusions for 2,4-D, as presented fully in the documents "2,4-D.  HED's Revised Human Health
Risk Assessment for the Reregistration Eligibility Decision (RED) Revised to Reflect Public
Comments" dated May 12, 2005, and the "Environmental Fate and Effects Division's Risk
Assessment for the Reregistration Eligibility Decision for 2,4-D," dated October 28, 2004.

     The purpose of this section is to summarize the key features and findings of the risk assessment
in order to help the reader better understand the risk management decisions reached by the Agency.
While the risk assessments and related addenda are not included in this document, they are available
in the public docket OPP-2004-0167, and on the Agency's website at
http: //www. epa. gov/pesticides/reregistration/status. htm
     A. Human Health Risk Assessment

     EPA released its preliminary risk assessments for 2,4-D for public comment on June 23, 2004,
thereby starting Phase 3 of a six phase public participation process. In response to comments
received during Phase 3, the human health risk assessment was updated. EPA issued the revised risk
assessments for 2,4-D for a second public comment period on January 12, 2005 (Phase 5 of the public
participation process). The risk assessments were revised again in response to Phase 5 public
comments, and are available for review.

     The 2,4-D degradates detected in the various laboratory environmental fate studies were 1,2,4-
benzenetriol, 2,4-dichlorophenol (2,4-DCP), 2,4-dichloroanisole (2,4-DCA), 4-chlorophenol,
chlorohydroquinone (CHQ), volatile organics, bound residues, and carbon dioxide.  The OPP
Metabolism Assessment Review Committee (MARC)  determined that all residues other than 2,4-D
are not of risk concern due to low occurrence under environmental conditions, comparatively low
toxicity, or a combination thereof.  Therefore, the Agency assessed risks from 2,4-D per se.

           1.  Toxicity of 2,4-D

     With very few exceptions, the effects and relative toxicities of the salt and ester forms of 2,4-D
are quite similar to those of the acid form.  Thus, the acid form was selected as  being representative of
all members of the 2,4-D reregistration case (Case No.  0073).  The member chemicals in the 2,4-D
case exhibit low to slight acute toxicity with the exception of the acid and salt forms being severe eye
irritants.  The Agency has reviewed all toxicity studies submitted for 2,4-D and has  determined that
the toxicological database is sufficient for reregistration. Further details on the  toxicity of 2,4-D can
be found in the technical support documents cited in Appendix C.

              a. Toxicity Profile

     Major features of the toxicology profile are presented below. In acute studies, 2,4-D generally
has low acute toxicity (Toxicity Category HI or IV) via the oral, dermal and inhalation routes of


                                       Page 15  of  304

-------
exposure. 2,4-D is not a skin irritant (Toxicity Category HI or IV), nor a skin sensitizer.  Although
the 2,4-D ester forms are not eye irritants (Toxicity Category in or IV), the acid and salt forms are
considered to be severe eye irritants (Toxicity Category I). The acute toxicity of all 2,4-D forms is
listed in Table 6.

Table 6. Acute Toxicity Data for 2,4-D acid, 2,4-D ester forms, and 2,4-D aniine salts1.
Guideline
No
870.1100








870.1200








870.1300








870.2400








870.2500








Study Type

Acute Oral
2,4-D acid
DEA salt
DMA salt
IPA salt
IPE ester
UFA salt
BEE ester
EHE ester
Acute Dermal
2,4-D acid
DEA salt
DMA salt
IPA salt
IPE ester
UFA salt
BEE ester
EHE ester
Acute Inhalation
2,4-D acid
DEA salt
DMA salt
IPA salt
IPE ester
UFA salt
BEE ester
EHE ester
Primary Eye Irritation
2,4-D acid
DEA salt
DMA salt
IPA salt
IP ester
UFA salt
BEE ester
EHE ester
Primary Skin Irritation
2,4-D acid
DEA salt
DMA salt
IPA salt
IPE ester
UFA salt
BEE ester
EHE ester
MRID Numbers


00101605
41920901
00157512
00252291
41709901
41413501
40629801
41209001

00101596
41920911
00157513
00252291
41709902
41413502
40629802
41209002

00161660
41986601
00157514
40085501
40352701
41957601
40629803
42605202

41125302
41920902
00157515
00252291
40352702
41413504
40629804
44725303

42232701
41920903
00157516
00252291
40352703
41413505
40629805
41413505
Results


rat LD50 = 639 mg/kg
rat LD50 = 735 mg/kg
rat LD50 = 949 mg/kg
rat LD50 = 1646 mg/kg
rat LD50 = 1250 mg/kg
rat LD50 = 1074 mg/kg
rat LD50 = 866 mg/kg
rat LD50 = 896 mg/kg

rabbits LD50 >2000 mg/kg
rabbits LD50 >2000 mg/kg
rabbit LD50 1829 mg/kg
rabbits LD50 >2000 mg/kg
rabbits LD50 >2000 mg/kg
rabbits LD50 >2000 mg/kg
rabbits LD50 >2000 mg/kg
rabbits LD50 >2000 mg/kg

ratLC50>1.79mg/L
rat LC50 >3.5 mg/L
rat LC50 >3.5 mg/L
ratLCso =3.1 mg/L
rat LC50 >4.97 mg/L
rat LC50 =0.78 mg/L
rat LC50 =4.6 mg/L
ratLC50>5.4mg/L

severe eye irritant
severe eye irritant
severe eye irritant
severe eye irritant
not an eye irritant
severe eye irritant
not an eye irritant
not an eye irritant

unacceptable
slight skin irritant
slight skin irritant
slight skin irritant
slight skin irritant
slight skin irritant
very mild irritant
not a skin irritant
Toxicity Category


in
IE
in
IE
IE
IE
IE
IE

IE
IE
IE
IE
IE
IE
IE
IE

IE
IV
IV
IV
IV
IE
IV
IV

I
I
I
I
IV
I
IE
IE

N/A
IE
IV
IV
IV
IV
IV
IV
                                       Page 16 of 304

-------
Guideline
Nn
870.2600





Study Type
Dermal Sensitization
2,4-D acid
DBA salt
DMA salt
IPA salt
IPE ester
UFA salt
BEE ester
EHE ester
MRID Numbers

00161659
41920904
41642805
41233701
40352704
41413506
40629806
41209006
Results

not a dermal sensitizer
not a dermal sensitizer
unacceptable
unacceptable
not a dermal sensitizer
not a dermal sensitizer
not a dermal sensitizer
unacceptable
Toxicity Category

N/A




1. The technical acute toxicity values included in this document are for informational purposes only. The data supporting these values
will be evaluated during reregistration and may or may not meet the current Agency acceptance criteria.

     The mechanisms responsible for renal clearance of 2,4-D have been investigated in several
species. 2,4-D is actively secreted by the proximal tubules. This mechanism of renal clearance is
consistent with results seen with other phenoxy acids. It has been suggested that observed dose-
dependent, non-linear, pharmacokinetics of 2,4-D are primarily due to the saturation of this renal
secretory transport system.  Due to a limited capacity to excrete organic acids, the dog is more
sensitive to the effects of 2,4-D than the rat with respect to repeated dosing.

     In laboratory animals, following subchronic, oral exposure at dose levels of 2,4-D above the
threshold of saturation for renal clearance, the primary target organs are the eye, thyroid, kidney,
adrenals, and ovaries/testes. Changes in these organs are also observed following exposure to the
amine salts and esters of 2,4-D.  Systemic toxicity was not observed following repeated dermal
exposure to 2,4-D, EHE, and TIPA at or above the limit dose or following repeated dermal exposure
to BEE and IPA at the highest dose tested.  Liver toxicity was observed following repeated high-dose
dermal exposure to DEA, and one death occurred following repeated high-dose dermal exposure to
DMA.

     There are no repeat-dose inhalation exposure data available on 2,4-D. The most reliable way to
characterize inhalation toxicity and to quantify inhalation risk is through the use of inhalation toxicity
studies. In general, chemicals tend to be more toxic by the inhalation route than by the oral route due
to rapid absorption and distribution, bypassing of the liver's metabolic protection (portal circulation),
and potentially serious portal-of-entry effects, such as irritation, edema, cellular transformation,
degeneration, and necrosis. An inhalation risk assessment that is based on oral data generally
underestimates the inhalation risk because it cannot account for these factors.  However, in the case of
2,4-D, based on the limited metabolism of 2,4-D via the oral route, the moiety to which the body
would be exposed would be the same for both routes of exposure. With regard to portal-of-entry
effects, these can only be assessed in an inhalation study. Therefore, a subchronic (28-day) inhalation
study is required for 2,4-D.

     Developmental toxicity, characterized mainly as an increased incidence of skeletal
abnormalities in the rat, was observed following exposure to 2,4-D and its amine salts and esters at
dose levels that were at or above the threshold of saturation of renal clearance. Similarly,
developmental toxicity was observed in the rabbit only following exposure to 2,4-D (abortions) and
DEA (increased number of litters with fetuses having 7th cervical ribs) at or above the threshold of
                                        Page 17 of 304

-------
renal clearance.

     Reproductive toxicity, characterized as an increase in gestation length, was observed following
exposure to 2,4-D at a dose level above the threshold of saturation of renal clearance. A repeat 2-
generation reproduction study (using the revised EPA protocol) is required to address concerns for
endocrine disruption.

     Neurotoxicity was demonstrated following exposure to 2,4-D at relatively high dose levels.
Clinical signs of neurotoxicity (ataxia, decreased motor activity, myotonia, prostration, lateral
recumbency, impaired/loss of the righting reflex, and skin cold to the touch) were observed in
pregnant rabbits following exposure to 2,4-D and its amine salts and esters. Neuropathology (retinal
degeneration) was  observed following 2,4-D exposure in several studies in female rats.
Incoordination and slight gait abnormalities  (forepaw flexing or knuckling) were observed following
acute dosing and increased forelimb grip strength was observed following chronic exposure to 2,4-D
at dose levels that exceeded the threshold of saturation of renal clearance.  A developmental
neurotoxicity study in the rat is required for  2,4-D.

     2,4-D is classified as a Group D  chemical (not classifiable as to human carcinogenicity). Based
on the overall pattern of responses observed in both in vitro and in vivo genotoxicity tests, 2,4-D was
not mutagenic, although some cytogenic effects were observed. 2,4-D acid is currently considered to
be representative of all nine member chemicals of the 2,4-D case.

     The toxicological endpoints that were  used to complete the risk assessments  are summarized in
Table 7.  These endpoints were selected by the Agency from animal studies. With respect to dermal
exposures, the Agency previously selected a dermal absorption factor of 5.8 percent based on the
average absorbed dose value from a human  dermal absorption study. That factor (5.8 percent) was
used in previous versions of the human health risk assessment. Based on comments received during
the Phase 5 comment period, the  dermal absorption study and resulting absorption factor were
reconsidered. In order to account for the variability observed in the dermal absorption study, the
dermal absorption factor was changed from  5.8 percent to 10 percent.  In their "Re-evaluation of the
Lawn and Turf Uses of 2,4-D," which was made available to the public for review, Health Canada
also selected a factor of 10 percent based upon the weight of evidence from several published studies,
taking into account the variability in the data and the limitations of the various studies.  These studies
include the Feldman and Maibach study discussed above and  studies from Harris and Solomon 1992,
Moody et. al. 1990, Wester et. al. 1996, and Pelletier et al. 1988.

              b.  Safety and Database Uncertainty Factors

     The Food Quality Protection Act (FQPA) directs the Agency to use an additional tenfold (10X)
safety factor to protect for special sensitivity of infants and children to specific pesticide residues in
food, drinking water, or residential exposures,  or to compensate for an incomplete database. FQPA
authorizes the Agency to modify the tenfold safety factor only if reliable data demonstrate that
another factor would be appropriate.

     FQPA Special Safety Factor.  After evaluating hazard and exposure data for 2,4-D, EPA


                                       Page 18 of 304

-------
removed the default 10X FQPA special safety factor.  The toxicity database for 2,4-D includes
acceptable developmental and reproductive toxicity studies.  Developmental toxicity studies were
conducted in both rats and rabbits for most 2,4-D forms.  There is qualitative evidence of
susceptibility in the rat developmental toxicity study with 2,4-D acid and DEA salt where fetal effects
(skeletal abnormalities) were observed at a dose level that produced less severe maternal toxicity
(decreased body-weight gain and food consumption).  There is no evidence of increased (quantitative
or qualitative) susceptibility in the prenatal developmental toxicity study in rabbits or in the 2-
generation reproduction study in rats on 2,4-D. Regarding the 2,4-D amine salt and ester forms, no
evidence of increased susceptibility (quantitative or qualitative) was observed in the prenatal
developmental toxicity study in rats and rabbits (except for 2,4-D DEA) dosed with any of the amine
salts or esters of 2,4-D.  There is evidence of increased susceptibility (qualitative) in the prenatal
developmental study in rabbits for 2,4-D DEA salt.

     After establishing developmental toxicity endpoints to be used in the risk assessment with
traditional uncertainty factors (lOx for interspecies variability and lOx for intraspecies variability), the
Agency has no residual concerns for the  effects seen in the developmental toxicity studies. Therefore,
the 10X FQPA special safety factor was  reduced to IX.

     Database Uncertainty Factor.   On April 8, 2003, based on the weight of evidence presented,
the Agency reaffirmed the previous conclusion that a developmental neurotoxicity (DNT) study in
rats is required for 2,4-D because there is a concern for developmental neurotoxicity resulting from
exposure to 2,4-D. There is evidence of neurotoxicity, including clinical signs such as ataxia and
decreased motor activity in pregnant rabbits following dosing during gestation days 6-15 in studies on
2,4-D itself and 2,4-D amine salts and esters, and tremors in dogs that died on test following repeat
exposure to 2,4-D. Incoordination and slight gait abnormalities (forepaw flexing or knuckling) were
also observed following dosing in the acute neurotoxicity study with 2,4-D. There is also evidence of
developmental toxicity, as discussed above in the FQPA  Special Safety Factor section.  In addition,
the Agency determined that a repeat 2-generation reproduction study using the new protocol is
required to address specific concerns for endocrine disruption (thyroid and immunotoxicity
measures). Therefore, the Agency determined that a 10X database uncertainty factor (UFDB) is
needed to account for the lack of these studies.

              c. Carcinogenicity

     A Science Advisory Board/Scientific Advisory Panel Special Joint Committee reviewed
available epidemiological and other data on 2,4-D in 1992 and concluded that "the data are not
sufficient to conclude that there is a cause and effect relationship between exposure to 2,4-D and non-
Hodgkin's lymphoma." 2,4-D has been classified as a Category D chemical (i.e., not classifiable as to
human carcinogenicity), by the EPA/OPP Cancer Peer Review Committee in 1996. The Agency
requested further histopathological examinations of rat brain tissues and mouse spleen tissues in
question.  These exams were submitted and reviewed and on March 16, 1999, the Agency notified the
2,4-D Task Force that the Agency would continue to classify 2,4-D as a Group D carcinogen.

     The Agency has twice recently reviewed epidemiological studies linking cancer to 2,4-D. In
the first review, completed January 14, 2004, EPA concluded there is no additional evidence that


                                       Page 19 of 304

-------
would implicate 2,4-D as a cause of cancer (EPA, 2004).  The second review of available
epidemiological studies occurred in response to comments received during the Phase 3 Public
Comment Period for the 2,4-D RED. This report, dated December 8, 2004 and authored by EPA
Scientist Jerry Blondell, Ph.D., found that none of the more recent epidemiological studies
definitively linked human cancer cases to 2,4-D.

     2,4-D Diethanolamine (PEA).   The Agency recently reviewed the available toxicology data
on diethanolamine (DEA) and related compounds. The Agency concluded that it was not likely that
exposure to the DEA salt of 2,4-D resulting from occupational use would pose a carcinogenic risk to
humans. While liver tumors were observed in mice following dermal exposure to DEA, there was no
evidence of carcinogenicity in rats following dermal exposure, and there was no evidence of a
genotoxic or mutagenic concern. Although no formal assessment has been performed on the proposed
mode of action (choline deficiency), this mode of action was considered plausible for the mouse
hepatocellular tumors observed following dermal exposure to DEA, as were other confounding
factors, including the use of ethanol as a vehicle for dose administration and the fact that humans are
generally refractive to choline deficiency. Additionally, the low use pattern for 2,4-D DEA  indicates
that there is no potential long-term  dermal exposure to the diethanolamine salt of 2,4-D in agricultural
uses. The Agency also determined that, at this time, no carcinogenicity studies are required for the
DEA salt of 2,4-D.

              d.  Cumulative Assessment

     FQPA requires EPA to consider "available information" concerning the cumulative effects of a
particular pesticide's residues and "other substances that have a common mechanism of toxicity"
when considering whether to establish, modify,  or revoke a tolerance. Potential cumulative  effects of
chemicals with a common mechanism of toxicity are considered because low-level exposures to
multiple chemicals causing a common toxic effect by a common mechanism could lead to the same
adverse health effect as would a higher level of exposure to any one of these individual chemicals.
2,4-D is a member of the alkylphenoxy herbicide class of pesticides.  A cumulative risk assessment
has not been performed as part of this human health risk assessment because the Agency has not yet
made a determination whether or not phenoxy herbicides have a common mechanism of toxicity. 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 the 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/

              e. Endocrine Effects

     EPA is required under the Federal Food, Drug, and Cosmetic Act (FDCA), as amended by the
Food Quality Protection Act (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."
                                      Page 20 of 304

-------
     When the appropriate screening and/or testing protocols being considered under the Agency's
Endocrine Disruption Screening Program (EDSP) have been developed, 2,4-D may be subject to
additional screening and/or testing to better characterize effects related to endocrine disruption.

     Based on currently available toxicity data, which demonstrate effects on the thyroid and gonads
following exposure to 2,4-D, there is concern regarding its endocrine disruption potential. There have
been no studies on 2,4-D that specifically assess its endocrine disruption potential. The Agency has
determined that a repeat 2-generation reproduction study using the most recent protocol is required to
address both the concern for thyroid effects (comparative assessment between the young and adult
animals) and immunotoxicity, as well as a more thorough assessment of the gonads and
reproductive/developmental endpoints.

              f. Toxicological Endpoints for Risk Assessment

     The toxicological endpoints used in the human health risk assessment for 2,4-D are listed in
Table 7.  The safety factors used to account for interspecies extrapolation, intraspecies variability,
special susceptibility of infants and children, and database uncertainties are also described in Table 7
below. This table also describes any absorption factors used to extrapolate from one route of
exposure to another (e.g., oral to dermal).

Table 7. Toxicity Endpoints for Human Health Risk Assessment for 2,4-D
Exposure
Scenario
Dose Used in Risk
Assessment, UF
Special FQPA SF and Level of
Concern for Risk Assessment
Study and Toxicological Effects
Dietary Exposures
Acute Dietary
(Females 13-49
years of age)
MRID 00130407,
00130408
Acute Dietary
(General
population
including infants
and children)
MRID 431 15201
Chronic Dietary
(All populations)
MRID 436 12001
NOAEL = 25 mg/kg/day
UF = 1000
Acute RID = 0.025
mg/kg/day
NOAEL = 67 mg/kg/day
UF = 1000
Acute RID = 0.067
mg/kg/day
NOAEL= 5 mg/kg/day
UF = 1000
Chronic RID =
0.005 mg/kg/day
FQPA SF = IX
aPAD = acute RfD(0.025)
FQPA SF (1)
= 0.025 mg/kg/day
FQPA SF = IX
aPAD = acute RfD (0.067)
FQPA SF (1)
= 0.067mg/kg/day
FQPA SF = IX
cPAD = chronic RfD (0.005)
FQPA SF (1)
= 0.005 mg/kg/day
Rat Developmental Toxicity Study,
LOAEL = 75 mg/kg/day based on skeletal
abnormalities
Acute Neurotoxicity Study in Rats
LOAEL = 227 mg/kg/day based on gait
abnormalities
Rat Chronic Toxicity Study
LOAEL = 75 mg/kg/day based on
decreased body-weight gain (females) and
food consumption (females), alterations in
hematology , and clinical chemistry
parameters, decreased T4 (both sexes),
glucose (females), cholesterol (both sexes),
and triglycerides (females).
Occupational and Residential Non- Dietary Exposures
                                       Page 21 of 304

-------
Exposure
Scenario
Short- Term
Incidental Oral (1-
30 days)
MRID 00130407,
00130408
Intermediate-
Term
Incidental Oral (1-
6 months)
MRID 41991501
Short- Term
Dermal*
MRID
00130407,
00130408
Intermediate-
Term
Dermal*
MRID 00130407,
00130408
Long- Term
Dermal*
MRID 436 12001
Short- Term
Inhalation*
MRID
00130407,
00130408
Intermediate-
Term Inhalation*
MRID 00130407,
00130408
Long- Term
Inhalation*
MRID 436 12001
Cancer
Dose Used in Risk
Assessment, UF
NOAEL= 25 mg/kg/day
NOAEL = 15 mg/kg/day
Oral study NOAEL= 25
mg/kg/day
Oral study NOAEL =15
mg/kg/day
Oral study NOAEL= 5
mg/kg/day
Oral study NOAEL= 25
mg/kg/day
Oral study NOAEL = 15
mg/kg/day
Oral study NOAEL= 5
mg/kg/day
Special FQPA SF and Level of
Concern for Risk Assessment
Residential LOC for MOE
=1000
Occupational = NA
Residential LOC for MOE =
1000
Occupational = NA
Residential LOC for MOE
= 1000
Occupational LOC for MOE =
100
Study and Toxicological Effects
Rat developmental toxicity study
LOAEL = 75 mg/kg/day based on
decreased maternal body-weight gain
Rat Subchronic Oral Toxicity
LOAEL = 100 mg/kg/day based on
decreased body weight/body-weight gain,
alterations in some hematology, and
clinical chemistry parameters, and cataract
formation.
Rat Developmental Toxicity Study
LOAEL = 75 mg/kg/day based on
decreased maternal body-weight gain and
skeletal abnormalities
Rat Subchronic Oral Toxicity (same as for
intermediate-term incidental oral)
Rat Chronic Toxicity Study (same as for
chronic dietary)
Rat Developmental Toxicity Study (same
as for short-term dermal)
Rat Subchronic Oral Toxicity (same as
intermediate-term incidental oral)
Rat Chronic Toxicity Study (same as for
chronic dietary)
Classification: Group D [not classifiable as to human carcinogenicity]
The dermal absorption factor is 10 percent and the inhalation absorption factor is 100 percent.
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, LOC = level of concern, NA = Not Applicable
     Dermal Absorption.  A dermal absorption study utilizing human volunteers is available.
Excretion following dermal application was 5.8 ± 2.4 percent (mean ± S.D.) of the administered dose
and after intravenous administration was 100 ± 2.5 percent. The Agency previously selected a dermal
                                      Page 22 of 304

-------
absorption factor of 5.8 percent based on the human dermal absorption study.  This factor was used in
previous versions of this risk assessment. Based on comments received during the Phase 5 comment
period, this dermal absorption study and factor were reconsidered. In order to account for the
variability observed in the dermal absorption study, the dermal absorption factor was changed from
5.8 percent to 10 percent. In their "Re-evaluation of the Lawn and Turf Uses of 2,4-D," which was
made available to the public, Health Canada also selected a factor of 10 percent based upon the
weight of evidence from several published studies, taking into account the variability in the data and
the limitations of the various studies. These studies include the Feldman and Maibach study
discussed above and studies from Harris and Solomon 1992, Moody et. al.  1990, Wester et. al. 1996,
and Pelletier et al. 1988.

           2. Dietary Exposure and Risk from Food

              a. Exposure Assumptions

     Acute and chronic dietary exposure and risk analyses for 2,4-D were conducted using the
Lifeline ™ Model Version 2.0 and Dietary Exposure Evaluation Model software with the Food
Commodity Intake Database (DEEM-FCID™, Version 1.33). DEEM incorporates consumption data
from USDA's Continuing Surveys of Food Intakes by Individuals (CSFH), 1994-1996 and 1998.
Lifeline ™ uses  food consumption data from the United States Department of Agriculture's
(USDA's) Continuing Surveys of Food Intakes by Individuals (CSFII) from 1994-1996 and 1998.
Lifeline™ uses recipe files contained within the program to relate raw agricultural commodities
(RACs) to foods  "as-eaten." Lifeline™ converts the RAC residues into food residues by randomly
selecting a RAC residue value from the "user defined" residue distribution (created from the residue,
percent crop treated, and processing factors data), and calculating a net residue for that food based on
the ingredients' mass contribution to that food item.

     Lifeline™ models the  individual's dietary exposures over a season by selecting a new CSFII
diary each day from a set of similar individuals based on age and season attributes.  Lifeline™ groups
CSFII diaries based on the respondent's age and the season during which the food diary was
recorded. Based on analysis of the 1994-96, and 1998 CSFII consumption data, which took into
account dietary patterns and survey respondents, the Agency concluded that it is most appropriate to
report risk for the following  population subgroups: the general U.S. population, all infants (<1 year
old), children 1-2, children 3-5, children 6-12, youths 13-19, adults 20-49, females 13-49, and adults
50+ years old. The most highly exposed population subgroup for 2,4-D using both DEEM and
Lifeline was children 1-2 years of age.

     The acute dietary assessment was only slightly refined as the following assumptions were
made:  tolerance-level exposure values for most commodities, the highest field trial residue value for
citrus commodities, and 100% crop treated (%CT).  Note that half of the average level of detection
(LOD) from the United States Department of Agriculture (USD A) Pesticide Data Program (POP)
monitoring data was used as the milk residue value because no milk  sample contained detectable 2,4-
D residues over several years of PDF sampling.
                                      Page 23 of 304

-------
     The chronic dietary assessment was moderately refined, making use of the following
assumptions:  tolerance-level exposure values for most commodities; averages of field trial data and
processing study factors for small grains, citrus, and sugarcane sugar and molasses; %CT information
for all commodities; and the MCL (70 ppb) as well as the highest observed groundwater monitoring
concentration (15 ppb) for drinking water in a forward calculation.  As in the case of the acute
assessment, half of the average LOD from PDF monitoring data was used for milk.

              b. Population Adjusted Dose

     A population adjusted dose, or PAD, is the reference dose (RfD) adjusted for the FQPA safety
factor.  A risk estimate that is less than 100% of the acute PAD (aPAD), the dose at which an
individual could be exposed over the course of a single day and no adverse health effects would be
expected, does not exceed EPA's level of concern. Likewise, a risk estimate that is less than 100% of
the chronic PAD (cPAD), the dose at which an individual could be exposed over the course of a
lifetime and no adverse health effects would be expected, does not exceed EPA's level of concern.

     In the case of 2,4-D , the FQPA SF has been removed (equivalent to a factor of Ix), so the acute
or chronic RfD is identical to the respective aPAD or cPAD. In addition, an uncertainty factor is
determined for each chemical. In the acute and chronic dietary risk assessments for 2,4-D, the total
uncertainty factor (UF) is lOOOx; lOx for interspecies variability, lOx for intraspecies variability, and
lOx for database uncertainty.

              c. Food Risk Estimates

     Acute: Risk to the general U.S. population was 18% and 17% of the aPAD using both DEEM
and Lifeline, respectively. The most highly exposed population subgroup using both DEEM and
Lifeline was children 1-2 years of age; risks were 33% and 32% of the aPAD, respectively.  Risk to
females 13-49 years of age was 31% of the aPAD using DEEM and 42% of the aPAD using Lifeline;
these higher calculated risks for women of child-bearing age are due to the 2.7x lower toxicological
point of departure for developmental effects applicable to Females 13-49 years of age.  These acute
dietary (food) risks are all less than the Agency's level of concern (100% of the aPAD).

     Chronic:  Risk to the general U.S. population was 4.1% and 3.8% of the cPAD, using DEEM
and Lifeline, respectively. Risk to children 1-2 years of age, the most highly exposed population
subgroup, was 8.5% of the cPAD using DEEM and Lifeline.

          3. Dietary Exposure and Risk from Drinking Water

     Drinking water exposure to pesticides can occur through surface and ground water
contamination.  EPA considers acute (one day) and chronic (lifetime) drinking water risks and uses
either modeling or monitoring data, if available and of sufficient quality, to estimate those exposures.
In assessing drinking water risks, EPA compares model results to concentrations that would be
acceptable in drinking water from a human health perspective (e.g., DWLOCs). If the estimated
drinking water concentrations (EDWCs) in water are less than the DWLOCs, EPA does not have


                                      Page 24 of 304

-------
concern from consuming drinking water. If the EDWCs are greater than DWLOCs, EPA will
conduct further analysis to characterize the potential dietary risk from drinking water.  Risks from
exposure to 2,4-D in drinking water are further discussed in the section m.A.5.

     2,4-D is an herbicide used in a wide variety of environments. As the major route of degradation
is aerobic microbial metabolism, 2,4-D is non-persistent (t1/2=6.2 days) in terrestrial (aerobic)
environments, moderately persistent (t1/2=45 days) in aerobic aquatic environments, and highly
persistent (t1/2= 231 days) in anaerobic terrestrial and aquatic environments. Because 2,4-D will be
anionic (X-COO" EF) under most environmental conditions, it is expected to be mobile (Koc=61.7) in
soil and aquatic environments.

     The 2,4-D degradates detected in the various laboratory environmental fate studies were 1,2,4-
benzenetriol, 2,4-dichlorophenol (2,4-DCP), 2,4-dichloroanisole (2,4-DCA), 4-chlorophenol,
chlorohydroquinone (CHQ), volatile organics, bound residues, and carbon dioxide. The Agency has
determined that residues other than 2,4-D are  not of risk concern due to low occurrence under
environmental conditions, comparatively low toxicity,  or a combination thereof.

     Estimated Environmental Concentrations (EEC)  were derived through an evaluation of
monitoring data and modeling. A number of different  scenarios were assessed and EECs provided
for each. Scenarios evaluated included the direct application of 2,4-D to water bodies for aquatic
weed control, a rice use scenario, and  terrestrial uses including food and nonfood uses.

              a. Surface Water

     Modeling: The Tier n screening models, Pesticide Root Zone Model and Exposure Analysis
Modeling System (PRZM-EXAMS),with the Index Reservoir and Percent Crop Area adjustment (IR-
PCA PRZM/EXAMS) were used to estimate  2,4-D residues in surface  water used for drinking water.

     The Index Reservoir represents a watershed that  is more vulnerable than most watersheds used
as drinking water sources.  It was developed from a watershed in western Illinois that has been used
for drinking water purposes.  The Index Reservoir is used as a standard watershed that, in
combination with local soils types, weather conditions, and cropping practices, represents a
vulnerable watershed that could support a drinking water supply.

     For terrestrial uses of 2,4-D, EECs were calculated from aquatic exposure modeling using
PRZM/EXAMS with the Index Reservoir and a percent crop area treated (PCA) adjustment (Tier II).
Fifteen scenarios were chosen for aquatic exposure modeling,  including sugarcane in Florida; turf in
Florida and Pennsylvania; spring wheat in North Dakota; winter wheat in Oregon; corn in Illinois and
California; sorghum in Kansas and Texas; soybean in Mississippi; pasture in North Carolina; apples
in North Carolina, Oregon, and Pennsylvania; and filberts in Oregon. Although this only represents a
portion of the crops for which 2,4-D has a labeled use, it does represent crops with higher application
rates and crops which have a large percentage of their total acreage treated with 2,4-D.

     Surface water concentrations were modeled using PRZM version 3.12 and EXAMS version


                                      Page 25 of 304

-------
2.98.04. Ground water concentrations were modeled using SCIGROW version 2.2. The 15 crop
scenarios listed above were modeled using PRZM/EXAMS. Based on the maximum modeled
values, (more specifically, the North Carolina apple model scenario), the model-estimated, surface-
water-derived drinking water concentrations for the use of 2,4-D are:

     118 ug/L for the 1 in 10 year annual peak concentration (acute)
      64 ug/L for the 1 in 10 year 90-day average
      23 ug/L for the 1 in 10 year annual mean concentration (chronic)

     Monitoring: Monitoring data considered  in the assessment were the United States Geological
Survey's (USGS) National Water Quality Assessment Program (NAWQA) groundwater and surface
water database, USGS/EPA reservoir monitoring database, National Drinking Water Contaminant
Occurrence Database (NCOD), and US EPA's  Storage and Retrieval environmental data system
(STORET).  Review of these databases was conducted to provide peak and median concentrations.
Additionally, the quality of data was evaluated for targeting pesticide use areas, detection limits, and
analytical recoveries.  The monitoring data indicate that 2,4-D is detected in groundwater and surface
water.  Also, 2,4-D is detected in finished drinking water. Maximum concentrations of 2,4-D in
surface source water and ambient groundwater are 58 ug/L and 14.8 ug/L, respectively. The highest
median 2,4-D concentration of 1.18 ug/L was derived from finished water samples in the NCOD
database. The highest time weighted annual mean (TWAM) concentration was 1.45 ug/L from the
NAWQA database containing nontargeted data reflecting pesticide concentrations in flowing water as
opposed to more stationary bodies of water such as ponds, lakes, and reservoirs.

     The PRZM/EXAMS surface water-derived drinking water model estimate that would be
appropriate for acute exposure (118 ug/L) is approximately two times the peak concentration of 58
ug/L detected in the surface water monitoring data evaluated as part of this assessment.  However,
since 70 ug/1 is the current maximum contaminant level (MCL) established under the Safe Drinking
Water Act, and is the label-prescribed 2,4-D concentration in treated water to be used for drinking
water, this MCL limit is a reasonable and practical value to be used for the surface water
concentration of 2,4-D for acute risk assessment purposes.

     Note that the peak surface water concentration of 58 ug/L is consistent with the 70-ppb label
instruction (also the MCL). Although the surface water monitoring was not specifically targeted to
known 2,4-D- treated sites or even areas of high 2,4-D usage, this agreement suggests that,  from a
practical standpoint, the MCL is a reasonable regulatory limit.

     Although of high quality, the available monitoring data is not targeted to 2,4-D use. However,
the data provide context to model results and indicate that there is little evidence that concentrations
are likely to be found exceeding these levels.

              b. Ground Water

     Monitoring: The maximum 2,4-D concentration detected in ground water is 14.89 ug/L based
on the USGS NAWQA program and 8 ug/L based on the NCOD monitoring data. The next highest


                                      Page 26 of 304

-------
concentration detected in the NAWQA groundwater data is 4.54 ug/L which is consistent with the
NCOD-reported concentration.  Therefore, the Agency is using 15 ug/L based on monitoring for the
groundwater EDWC.

              c. EDWCs Selected for Risk Assessment

     The EDWCs for 2,4-D in surface and ground water are listed in Table 8 below. The EDWCs
were selected from both modeling calculations and monitoring data.

Table 8.  Surface and Ground Water Estimated Drinking Water Concentrations (EDWCs)
Drinking Water Source
Surface Water
Ground Water
Duration
Acute (Peak)
Short and Intermediate
Chronic
All Duration
EDWC (ppb)
(ppb = ug/liter)
70 ug/liter (aquatic
applications)
118 ug/liter (terrestrial
applications)
70 ug/liter (aquatic
applications)
64 ug/liter (terrestrial
applications)
1 1 ug/liter (aquatic
application)
23 ug/liter (terrestrial
application)
1 .5 ug/liter (terrestrial
application)
15 ug/liter
Data Source
Maximum Contaminant
Level (MCL)
Modeling - PRZM-
EXAMS (NC apple
scenario)
Maximum Contaminant
Level (MCL)
Modeling - PRZM-
EXAMS (NC apple 1 in
10 year annual average)
Modeling - Dissipation
modeling of aquatic
application
Modeling - PRZM-
EXAMS worst case
terrestrial use (NC apple
scenario)
Monitoring - Maximum
time weighted annual
mean from NAWQA
database
Monitoring - Highest
monitored value from
NAWQA database
          4. Residential and Other Non-occupational Exposure

      Residential exposure assessment considers all potential pesticide exposure, other than exposure
due to residues in foods or in drinking water.  Exposure may occur during and after application on
lawns and turf, golf courses, parks, cemeteries, and other grass areas.  Exposure may also occur to
recreational swimmers while swimming in waters treated with 2,4-D for aquatic weeds. Each route
                                      Page 27 of 304

-------
of exposure (oral, dermal, inhalation) is assessed, where appropriate, and risk is expressed as a
Margin of Exposure (MOE), which is the ratio of estimated exposure to an appropriate NOAEL. 2,4-
D products are marketed for homeowner use on residential lawns and turf. 2,4-D containing products
are also marketed for use by professional applicators on residential turf, golf courses, and on other
turf such as recreational or commercial areas.  Based on these uses, 2,4-D has been assessed for the
residential mixing/loading/applicator (or "handler") exposure for applications by homeowners to
home lawns.  For post-application exposure, 2,4-D has been assessed for toddlers playing on treated
turf, adults performing yardwork on treated turf, adults playing golf on treated turf, and children and
adults swimming in bodies of water treated with 2,4-D for aquatic weed control.

              a. Toxicity

     The toxicological endpoints, and associated uncertainty factors used for assessing the non-
dietary risks for 2,4-D are listed in Table 9.

     In a dermal absorption study utilizing human volunteers, excretion following dermal application
was 5.8 ± 2.4% and after i.v. administration was 100 ± 2.5%. In previous risk assessments, the
Agency selected a dermal absorption factor of 5.8 percent based on the human dermal absorption
study.  Based on comments received during the Phase 5 comment period, this dermal absorption
study and factor were reconsidered. In order to account for the variability observed in the dermal
absorption study, the dermal absorption factor was changed from 5.8 percent to 10 percent.  In their
"Re-evaluation of the Lawn and Turf Uses of 2,4-D," which was made available to the public, Health
Canada also selected a factor of 10 percent based upon the weight of evidence from several published
studies, taking into account the variability in the data and the limitations of the various studies.  These
studies include the Feldman and Maibach study discussed above and studies from Harris and
Solomon 1992, Moody et. al. 1990, Wester et. al. 1996, and Pelletier et al. 1988.

     Chronic endpoints were not used in the residential assessment because chronic occupational and
residential exposures to 2,4-D are not expected to occur. Per the 2,4-D Master Label, the maximum
label frequency for application  of 2,4-D to turf is two times per year. 2,4-D also rapidly dissipates
from foliage and is readily excreted from the human body.

     A MOE greater than or equal to 1000 is considered adequately protective for the residential
exposure assessment.  The MOE of 1000 includes lOx for interspecies extrapolation, lOx for
intraspecies variation,  and lOx for a database uncertainty factor. Table 9 lists the toxicity endpoints
selected for assessing residential risk for 2,4-D.

Table 9.  Toxicity Endpoints Selected for Assessing Residential Risk for 2,4-D
Exposure
Scenario
Dose Used in Risk
Assessment, UF
Level of Concern for
Risk Assessment
Study and Toxicological Effects
Occupational and Residential Non- Dietary Exposures
                                       Page 28 of 304

-------
Exposure
Scenario
Short- Term
Incidental Oral (1-30
days)
MRID 00130407,
00130408
Intermediate-Term
Incidental Oral (1-6
months)
MRID 41991501
Short- Term Dermal*
MRID 00130407,
00130408
Intermediate-Term
Dermal*
MRID 00130407,
00130408
Long-Term Dermal*
MRID 436 12001
Short- Term Inhalation*
MRID 00130407,
00130408
Intermediate-Term
Inhalation*
MRID 00130407,
00130408
Long-Term Inhalation*
MRID 436 12001
Cancer
Dose Used in Risk
Assessment, UF
NOAEL= 25 mg/kg/day
UFDB = 10
NOAEL = 15 mg/kg/day
Oral study NOAEL= 25
mg/kg/day
Oral study NOAEL = 15
mg/kg/day
Oral study NOAEL= 5
mg/kg/day
Oral study NOAEL= 25
mg/kg/day
Oral study NOAEL =15
mg/kg/day
Oral study NOAEL= 5
mg/kg/day
Level of Concern for
Risk Assessment
Residential LOG for
MOE =1000
Occupational = NA
Residential LOG for
MOE = 1000
Occupational = NA
Residential LOG for
MOE
= 1000
Occupational LOG for
MOE = 100
Study and Toxicological Effects
rat developmental toxicity study
LOAEL = 75 mg/kg/day based on
decreased maternal body-weight gain
subchronic oral toxicity - rat
LOAEL = 100 mg/kg/day based on
decreased body weight/body-weight gain,
alterations in some hematology, and
clinical chemistry parameters, and
cataract formation.
rat developmental toxicity study
LOAEL = 75 mg/kg/day based on
decreased maternal body-weight gain and
skeletal abnormalities
subchronic oral toxicity - rat (same as for
incidental oral)
rat chronic toxicity study (same as for
chronic dietary)
rat developmental toxicity study (same as
for short-term dermal)
subchronic oral toxicity - rat (same as
incidental oral)
rat chronic toxicity study (same as for
chronic dietary)
Classification: Group D [not classifiable as to human carcinogenicity]
*The dermal absorption factor is 10 percent and the inhalation absorption factor is 100 percent.
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, LOG = level of concern, NA = Not Applicable
              b.  Residential Handler

               1) Exposure Scenarios, Data, and Assumptions

     Homeowners (or others) may be exposed to 2,4-D while treating their lawns.  All homeowner-
use products are available in liquid or granular form. 2,4-D is applied using hose-end sprayers, pump
sprayers, ready-to-use sprayers, broadcast spreaders, bellygrinders, and hand application, either
before or after seasonal weed  emergence, at a rate up to 1.5 Ibs ae/A. A number of assumptions, or
                                      Page 29 of 304

-------
estimates, such as adult body weight and area treated per application, are made by the Agency for
residential risk assessment. Also, note that residential handlers are addressed somewhat differently
than occupational handlers in that homeowners are assumed to complete all elements of an
application (mix/load/apply) without use of personal protective equipment (assessments are based on
an assumption that individuals will be wearing short pants and short-sleeved shirts).

     The quantitative exposure/risk assessment developed for residential handlers is based on these
scenarios:
     1) Hand application of granules
     2) Belly grinder application
     3) Load/apply granules with a broadcast spreader
     4) Mix/load/apply with a hose-end sprayer (mix your own)
     5) Mix/load/apply with a hose-end sprayer (ready-to-use)
     6) Mix/load/apply with hand held pump sprayer
     7) Mix/load/apply with ready-to-use sprayer

     Exposure estimates for these scenarios are taken from the Pesticide Handlers Exposure
Database (PHED, Version 1.1 August 1998) which is used to assess handler exposures when
chemical-specific monitoring data are not available. In addition to PHED data, the residential risk
assessment relies on data from the Outdoor Residential Exposure Task Force (ORETF) and
proprietary studies. Three turf transferable residue studies submitted by the Broadleaf Turf Herbicide
Turf Transferable Residue (TTR) Task Force. These studies measured the dissipation of several
phenoxy herbicides,  including 2,4-D, using the ORETF roller technique. Scenarios #1 through #5 use
ORETF or PHED data; scenarios #6 and #7 use exposure data from the Carbaryl
Mixer/Loader/Applicator Exposure Study (EPA MRID 444598-01).

     The results of a biomonitoring study (Harris and Solomon 1992) were also used to calculate
dermal MOEs for post application exposure on turf.  The study was conducted with adult volunteers
who were exposed to 2,4-D while performing controlled activities for one hour on turf treated with
2,4-D.  The controlled activities were conducted at 1 hour after treatment (HAT) and at 24 HAT.  Ten
volunteers participated in the study.  Five volunteers wore long pants, a tee shirt, socks and closed
footwear. The other five wore shorts and a tee shirt and were barefoot. The volunteers walked on the
turf for a period of 5 minutes and then sat or lay on the area for 5 minutes and then continued in this
fashion for 50 more minutes.  Each volunteer collected all urine for the next  96 hours immediately
following the exposure. The MOEs for the DAT 1 volunteers who wore shorts and no shoes ranged
from 1000 to 26000 with the  lowest MOE corresponding to a volunteer who removed his shirt during
the exposure period.   The MOEs for the remaining volunteers ranged from 17000 to 27000.

     For more information, see "2,4-D.  HED's Revised Human Health Risk Assessment for the
Reregistration Eligibility Decision (RED) Revised to Reflect Public Comments.  PC Code 030001;
DP Barcode D316597" dated May 12, 2005, and the "2,4-D: 3rd Revised Occupational and
Residential Exposure and Risk Assessment and Response to Public Comments for the Registration
Eligibility Decision (RED) Document" dated May 4, 2005.
                                      Page 30 of 304

-------
  Assumptions Regarding Residential Handlers
•    Clothing would consist of a short-sleeved shirt, short pants and no gloves.
•    Broadcast spreaders and hose end sprayers would be used for broadcast treatments and the
     other application methods would be used for spot treatments only.
•    An area of 0.023 acre (1000 square feet) would be treated per application during spot treatments
     and an area of 0.5 acre would be treated during broadcast applications.
•    The application rate is 1.5 Ib ae/acre representing the most recent revision to the master label.
•    Average body weight of an adult handler is 70 kg.
•    The duration of exposure is expected to be short-term (1-30 days) for residential handlers of
     2,4-D. Intermediate- and long-term exposures of residential applicators are not anticipated
     based on 2,4-D 's residential use pattern.

                2) Residential Handler Risk Estimates

     Based on toxicological criteria and potential for exposure, the Agency has conducted both a
dermal and an inhalation exposure assessment.  Risk assessment for short-term inhalation exposure is
based on a rat developmental study.  An assumption is made that 100% of the estimated inhalation
dose will be absorbed. A dermal absorption factor of 10 percent was selected for converting dermal
exposures to oral equivalent doses.  An MOE greater than or equal to 1000 (lOx for interspecies
extrapolation, lOx for intraspecies variation, and lOx for database uncertainty) is considered
adequately protective for this assessment.  Since all residential handler MOEs are  greater than 1000,
risk to residential handlers is not of concern. The 2,4-D risk estimates are presented in Table 10
below.

     In preliminary versions of the risk assessment, when considered alone, acute and short-term
residential risks posed by the use of 2,4-D were not of concern to the Agency; however, when
considered as part of an aggregate exposure with food and drinking water, exposures did exceed the
Agency's level of concern.  As a result, 2,4-D registrants agreed to reduce the maximum application
rate to turf and residential lawns from 2.0 Ibs ae/A to 1.5 Ibs ae/A.  The revised application rate (1.5
Ibs ae/A) was used in the current risk assessment.

Table 10. 2,4-D Short Term Risk Estimates for Residential Handlers
Scenario
1 . Hand Application of Granules
2. Belly Gnnder Application
3. Load/Apply Granules with a Broadcast Spreader
4. Mix/Load/Apply with a Hose-end Sprayer (Mix your own)
5. Mix/Load/Apply with a Hose-end Sprayer (Ready to Use)
6. Mix/Load/Apply with Hand Held Pump Sprayer
Application Rate
(Ibs ae/acre)
1.5
1.5
1.5
1.5
1.5
1.5
Treated Area
(acres/day)
0.023
0.023
0.5
0.5
0.5
0.023
MOE
3,700
3,900
29,000
1,800
7,400
11,000
                                       Page 31 of 304

-------
Scenario
7. Mix/Load/Apply with Ready to Use Sprayer
Application Rate
(Ibs ae/acre)
1.5
Treated Area
(acres/day)
0.023
MOE
7,900
Note: 1000 square feet equals 0.023 acres
     For more information, see Appendix F of "2,4-D: 3rd Revised Occupational and Residential
Exposure and Risk Assessment and Response to Public Comments for the Reregistration Eligibility
Decision (RED) Document (PC Code 030001, DP Barcode D316596)" dated May 4, 2005.

              c.  Residential Postapplication Risk

               1) Exposure Scenarios, Data, and Assumptions

     2,4-D uses in the residential setting include applications to home lawns. The following
scenarios were assessed for residential post application risks:

     1) Toddlers playing on treated turf
     2) Adults performing yardwork on treated turf
     3) Adults playing golf on treated turf

     These scenarios chosen for risk assessment represent what the Agency considers the likely
upper-end estimates of possible exposure.  An MOE of 1000 (or more) is considered protective for
this assessment.

Assumptions Regarding Residential Postapplication Risk

•    An assumed initial turf transferable residue (TTR) value of 5.0% of the application rate is used
     for assessing hand to mouth exposures.
•    An assumed initial TTR value of 20% of the application is used for assessing object to mouth
     exposures.
•    Soil residues are contained in the top centimeter and soil density (i.e., the ratio of the mass of
     dry solids to the bulk volume of the soil occupied by those dry solids) is 0.67 gram/mL.
•    Three year old toddlers are expected to weigh 15 kg.
•    Hand-to-mouth exposures are based on a frequency of 20 events/hour and a surface area per
     event of 20 cm2 representing the palmar surfaces of three fingers.
•    Saliva extraction efficiency is 50 percent. Every time the hand goes in the mouth
     approximately half of the residues on the hand are removed.
•    Adults are assessed using a transfer coefficient of 14,500 cm /hour.
•    Toddlers are assessed using a transfer coefficient of 5,200 cm /hour.
•    Golfers are assessed using a transfer coefficient of 500 cm2/hour.
•    An exposure duration of 2 hours per day is assumed for toddlers playing on turf or adults
     performing heavy yardwork.
                                      Page 32 of 304

-------
     The following assumptions that are specific to 2,4-D are used for assessing residential post
application exposures.

•    The master label application rate of 1.5 Ibs ae/acre was used.
•    The exposure following the application of granular formulations was not assessed because there
     were no TTR data submitted for granular formulations. It was assumed this exposure would be
     less than or equal to the exposure from liquid formulations.

     Other residential exposure standard operating procedures (SOPs) may be viewed at the
following website: http: //www. epa. gov/oscpmont/sap/1997/september/sopindex.htm .

Calculation Method for Postapplication Exposure for Toddlers on Treated Turf

     MOEs were calculated for acute toddler exposures using the maximum TTR value along with
the acute dietary NOAEL of 67 mg/kg/day. This NOAEL was adapted to acute dermal exposures by
using the dermal absorption factor of 10 percent to account for route to route extrapolation. The
MOEs for toddler short term exposures were calculated using the seven day average TTR value
because the short term NOAEL was based upon decreased body weight gain which occurred after
several days of exposure.  MOEs for acute and adult short term exposures were calculated using the
maximum TTR value because the acute and short term NOAELs are the same and are based upon the
developmental effects which could have occurred following one day of exposure.

     The quantitative exposure/risk assessment for postapplication risk to children is based on these
scenarios:

     1)   Dermal activity from treated turf: Postapplication exposure to children from the dermal
           exposure of pesticide residues from activity on treated turf.
     2)   Hand-to-mouth activity from treated turf: Postapplication exposure to children from the
           "incidental" ingestion of pesticide residues on treated turf from hand-to-mouth transfer
           (i.e., those residues that end up in the mouth from children touching turf and then putting
           their hands in their mouths).
     3)    Object-to-mouth activity from treated turf: Postapplication exposure to children from
           incidental ingestion of pesticide residues on treated turf from object-to-mouth transfer
           (i.e., those residues that end up in the mouth from a child mouthing a handful of treated
           turf).
     4)    Soil ingestion activity: Postapplication exposure to children from incidental ingestion of
           soil in a treated area.

     For more information on formulas used for calculating occupational and residential exposures
to 2,4-D, see Appendix A of "2,4-D: 3rd Revised Occupational and Residential Exposure and Risk
Assessment and Response to Public Comments for the Reregistration Eligibility Decision (RED)
Document" dated May 4, 2005.

               2)  Postapplication Risk Estimates


                                       Page 33 of 304

-------
     Risk assessment for children's postapplication exposure is based on a NOAEL of 67 mg/kg/day
from an oral study of acute neurotoxicity study in rats.  A Margin of Exposure (MOE) of 1000 (lOx
for interspecies extrapolation, lOx for intraspecies variation, and lOx for database uncertainty) is
considered adequately protective for this assessment. Table 11 below presents the MOEs for Post-
Application Exposure in Children.  Since all MOEs meet or exceed 1000, postapplication exposure to
children is not of concern.
Table 11. Children Post-Application Exposure to Turf Treated with 2,4-D

Application Rate
(Ibs ae/acre)
Dermal
MOE
Hand-to Mouth
MOE
Object to
Mouth MOE
Soil Ingestion
MOE
Total
MOE
Acute Toddler Risks Using the Maximum TTR (North Carolina Tnal 1 using 2,4-D DMA)
DATO
1.5
1,900
3000
12,000
>100,000
1,100
Short Term Toddlers Risks Using California TTR Data (DMA Mix, No Ram)
DAT 0 to
DAT 6
1.5
3,900
2,100
8,500
> 100,000
1,200
Short Term Toddler Risks Using North Carolina TTR Data from Trial 1 (DMA and DMA Mix, No Rain)
DAT 0 to
DAT 6
1.5
5,100
4,400
18,000
> 100000
2,100
Short Term Toddler Risks Using North Carolina TTR Data from Trial 2 (DMA Mix, Some Rain)
DAT 0 to
DAT 6
1.5
12,000
7,000
28,000
> 100000
3,900
The acute NOAEL is 67 mg/kg/day for neurotoxic effects observed in the acute neurotoxicity study.
The short term NOAEL is 25 mg/kg/day for maternal effects observed in the developmental study.
     Table 12 below lists the adult acute/short term MOEs for exposure to turf treated with 2,4-D.
The acute/short term NOAEL is 25 mg/kg/day from the rat developmental toxicity study. The
LOAEL was 75 mg/kg/day based on skeletal abnormalities from a developmental toxicity study in
rats.  All MOEs meet or exceed 1000, so postapplication exposure to adults is not of concern.

Table 12.  Adult Acute/Short Term MOEs for Exposure to Turf Treated with 2,4-D
Exposure Scenario
Heavy Yardwork
Playing Golf
Application Rate
(Ibs ae/acre)
1.5
TTR (ug/cm2)
0.50
Acute/Short Term Dermal MOE1
on Day 0
1000
15000
1 The acute/short term NOAEL is 25 mg/kg/day for developmental effects observed in the developmental study.
              d. Recreational Swimmer Risk
                                      Page 34 of 304

-------
                1) Exposure Scenarios, Data, and Assumptions

     The master label indicates that 2,4-D can be used for aquatic weed control of surface weeds
such as water hyacinth and submersed weeds such as Eurasian milfoil.  Surface weeds are controlled
by foliar applications at a maximum rate of 4.0 Ib ae/acre. Submersed weeds are controlled by
subsurface injection of liquids to achieve a target concentration of 2 to 4 ppm in the water column
surrounding the weeds. This requires 5.4 to 10.8 Ib ae per acre foot of water depth (e.g., 5.4 Ibs ae
would be required to achieve 2 ppm in a one acre pond that has an average depth of 1 foot). Granular
formulations of BEE (Aquakleen and Navigate) are also used to control submersed weeds.  The
granular formulations resist rapid decomposition in water and release the herbicide into the root zone.

     Although many herbicide treatments are applied to aquatic areas where recreational swimming
is not likely to occur, some of the subsurface treatments are made at recreational lakes.  These
treatments are made because the Eurasian milfoil interferes with recreation and other activities. This
problem is particularly prevalent in the northern states such as Minnesota and Washington and in the
New England region.

     The following exposure scenarios are assessed for recreational swimmers:

     1) Adult Recreational Swimmer
     2) Child Recreational Swimmer

Assumptions Regarding Recreational Swimmer Risk

     The following assumptions were used for the assessment of swimmer risks.  Many of these
assumptions were taken from the Residential  SOPs and are also used in the SWIMODEL.
                                                               fj
     •    The skin surface area of adults is assumed to be 21,000 cm (Residential SOPs). This is
          the 95th percentile value for females (EPA Exposure Factors Handbook, 1997).
     •    The body weight for children is assumed to be 22 kg as cited in the Residential SOPs.
          This is a mean value for 6 year old children.
     •    The skin surface area for children is assumed to be 9,000 cm2 as cited in the Residential
          SOPs. This is the 90th percentile value for male and female children.
     •    The assumed mean ingestion rate is 0.05 liters per hour for both adults and children as
          cited  in the Residential SOP. This value may be greater for young children playing in
          water and accidentally ingesting a remarkable quantity of water (U.S.  EPA SAP, 1999).
     •    The exposure time is assumed to be 3 hours per day. This is the 90th percentile value for
          time spent swimming in a freshwater pool (EPA Child Specific Exposure Factors
          Handbook, 2002).
     •    The body weight for female adult acute exposures is assumed to be 60 kg.
     •    The body weight for male adult acute exposures is assumed to be 70 kg.
     •    The body weight for adult short term exposure is assumed to be 60 kg because the
          endpoint is gender specific.
     •    Risks were not calculated for foliar treatments because the application rate of 2.0 Ib
          ae/acre would result in water concentration of only 0.25 ppm in a three foot water column


                                      Page 3 5 of 304

-------
          even if all of the spray were to run off the leaves into the water.

Calculation Method for Recreational Swimmer Exposure

     The Agency used the Swimmer Exposure Assessment Model (SWIMODEL) to calculate
exposures to swimmers in water treated with 2,4-D for aquatic weed control. The SWIMODEL
estimates exposure for up to six exposure routes (i.e., oral ingestion, dermal absorption, inhalation,
buccal/sublingual, nasal/orbital, and aural routes), or calculates exposure as a function of any one of
the three major exposure routes (i.e., oral ingestion,  dermal absorption, or inhalation). Other factors
used in the SWIMODEL formulae for dermal and ingestion exposure which are described in
Appendix A of "2,4-D: 3rd Revised Occupational and Residential Exposure and Risk Assessment and
Response to Public Comments for the Reregistration Eligibility Decision (RED) Document" dated
May 4, 2005.

     The SWIMODEL formulas for the other dermal pathways  (aural, buccal/sublingual and
orbital/nasal) were not used in the 2,4-D human health risk assessment because these formulas are
based upon recreational swimmers in swimming pools who swim with their heads partially immersed.
It is anticipated that recreational swimmers in weed infested areas would be less likely to swim with
their heads immersed than recreational swimmers in weed- free swimming pools.  In addition, the
formulas for the buccal/sublingual and orbital/nasal pathways contain a default absorption factor of
0.01 which is based upon the absorption of nitroglycerin. This factor would greatly overestimate the
risk of 2,4-D exposure because 2,4-D is absorbed at a much  lower rate.

     Because the 2,4-D water concentrations can vary depending upon the application rate and site
conditions the Maximum Swimming Water Concentration (MSWC) was calculated.  The MSWC is
the water concentration at which the combined dermal and ingestion MOE meets or exceeds the
target MOE of 1000. The MSWCs were calculated for children's acute exposures using the acute
NOAEL of 67 mg/kg/day and the MSWCs for children's short term exposures were calculated using
the short term NOAEL of 25 mg/kg/day for maternal effects. The MSWCs for adult  acute/short term
exposures were calculated using a NOAEL of 25 mg/kg/day that is based upon developmental effects
which could have occurred following one day of exposure.

               2) Recreational Swimmer Risk Estimates

     The MSWCs are summarized in Table 13 and the detailed  calculations are included in
Appendix H of the 3rd Revised Occupational and Residential Exposure Assessment for 2,4-D.  The
acute MSWCs range from 1.2 ppm for 2,4-D BEE to 9.8 ppm for 2,4-D acid while the short term
MSWCs range from 0.9 ppm for 2,4-D BEE to 3.6 ppm for 2,4-D acid or amine.  The MSWCs for
2,4-D BEE are lower because based on its chemical  properties, 2,4-D BEE is expected to have a
much higher dermal absorption value.
                                      Page 36 of 304

-------
Table 13. Maximum Swimming Water Concentrations for 2,4-D Aquatic Applications
Exposure Duration
NOAEL
(mg/kg/day)
2,4-D Form
2,4-D MSWC*
(ppm)
Dermal
MOE
Ingestion
MOE
Combined
MOE
Adults
Acute/Short Term
25
25
Acid or Amine
BEE
9.8
1.2
97000
1200
1000
8300
1000
1000
Children
Acute
Acute
Short Term
Short Term
67
67
25
25
Acid or Amine
BEE
Acid or Amine
BEE
9.8
2.4
3.6
0.90
425000
1300
230000
1300
1000
4100
1000
4100
1000
1000
1000
1000
* The MS WC is the concentration below which the combined MOE would be above 1000 and the risks would not be of
concern.
     The Acute MSWC of 9.8 ppm for exposures to 2,4-D acid or amine is greater than the master
label application rate of 4.0 ppm, therefore, acute exposures to 2,4-D acid or amine are not of
concern. The MSWC of 3.6 ppm for short-term exposures to 2,4-D acid or amine is also not of
concern because some dissipation or dispersion is likely to occur which would cause the 7-day
average of 2,4-D concentrations to be less than 3.6 ppm.  Dissipation studies submitted to EFED
indicated that the half lives following pond and lake liquid treatments ranged from 3.2 days to 27.8
days which yield 7 day average concentrations of 1.9 ppm when the half life equals 3.2 days to 3.6
ppm when the half life equals 27.8 days.

     The MSWCs for 2,4-D BEE are less than the master label application rate of 4 ppm, but they
are unlikely to be of concern for the following reasons:

•    2,4-D BEE degrades rapidly by abiotic hydrolysis in sterile water to form 2,4-D acid
particularly when the pH is 7.5 or above.

•    2,4-D BEE degrades to 2,4-D acid by microbial hydrolysis with an average half life of 2.6 +
1.8 hours at a bacterial concentration of 5 x 10~8 organisms per liter.  Therefore, degradation of 2,4-D
BEE to 2,4-D under typical environmental conditions will be rapid leading to significantly lower risk
estimates because the 2,4-D acid has a lower rate of dermal absorption.

•    Modeling predicts direct water application of 2,4-D BEE will yield surface water concentrations
of 2,4-D BEE concentrations in the Agency standard pond of 624 ug/L for peak (24 hour average), 30
ug/L for the 21-day average,  and 10 ug/L for the 60-day average.

•    The existing label rates for 2,4-D BEE products are also  lower than the master label rate.
                                       Page 37 of 304

-------
              5.  Aggregate Exposure and Risk

     OPP has traditionally compared estimates of concentrations of a pesticide in drinking water to
DWLOCs.  A DWLOC is the portion of the acute PAD or chronic PAD remaining after estimated
dietary (food only) exposures have been subtracted and the remaining exposure has been converted to
a concentration (ug/L or ppb).  This concentration value (DWLOC) represents the available or
allowable exposure through drinking water. In an acute risk assessment, the remaining portion of the
aPAD is based on dietary exposures at the percentile of exposure appropriate for a given risk
assessment and depends on each relevant population subgroup considered. Estimated Drinking
Water Concentrations (EDWCs) of 2,4-D in ground and surface water that are less than the DWLOCs
do not exceed the Agency's level of concern. DWLOC values vary for population subgroups
depending on dietary exposure through foods for each subgroup, assumptions made about the volume
of drinking water consumed, and default body weights for each subgroup.

     More recently, OPP has adopted the forward calculation approach for the assessment of
aggregate risks.  In this approach, food, drinking water and residential exposures are aggregated and
compared to an appropriate endpoint.

     In the case of 2,4-D, the DWLOCs were calculated for comparison to the MCL established by
the EPA Office of Water and aggregate risks were calculated using the forward calculation approach
for comparison to the appropriate endpoint. The respective DWLOCs and aggregate risks are shown
for acute, chronic and short term exposures in the following sections.

              a.  Acute Aggregate Risk Assessment

DWLOC Approach

     Acute DWLOCs were calculated based upon acute dietary exposures. Acute residential
exposures from swimming in treated water bodies or playing on treated turf were not included
because exposures are unlikely to co-occur with acute dietary exposures. The acute DWLOCs are
summarized in Table 14 and are 432 ppb or greater with the most sensitive population being females
13-49 years old.  The EDWCs of 118 ug/liter for surface water and 15 ug/liter for groundwater are
substantially less than the DWLOCs which means that the risks are not of concern.
                                      Page 3 8 of 304

-------
Table 14.  Acute DWLOC Calculations
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
Females 13-49
years old
Body Weight
(kg)
70
10
10
10
10
60
Water
Consumption
(liters/day)
2.0
1.0
1.0
1.0
1.0
2.0
aPAD
(mg/kg/day)
0.067
0.025
Food Exp1
(mg/kg/day)
0.0118
0.0132
0.0221
0.0206
0.0147
0.0106
Max Water
Exposure
(mg/kg/day )
0.0552
0.0538
0.0449
0.0464
0.0523
0.0144
DWLOC
(^g/L)3
1932
538
449
464
523
432
1. Food exposure values are the maximum of the acute DEEM or Lifeline values.
2 . Maximum water exposure (mg/kg/day) = [(acute PAD - food exposure)]
3. DWLOC (ug/L) = [maximum water exposure x body weight] ^ [water consumption x 10"3 mg/ug].
Surface Water EDWC = 70 ug/liter (aquatic applications) or 1 18 ug/liter (terrestrial applications)
Ground Water EDWC = 15 ug/liter
Forward Calculation Approach

     Acute aggregate risks were assessed by aggregating acute food exposures and acute water
exposures.  The acute aggregate risks are presented in Table 15 and are not of concern because they
are less than 100 percent of the aPAD. The highest risks (58 percent of the aPAD) are for females 13-
49 years old because these risks are based upon the lower NOAEL of 25 mg/kg/day.

Table 15.  2,4-D Aggregate Acute MOEs
Population
Subgroup
General U.S.
Population
Females 13-49 yrs old
Body
Weight
(kg)
70
60
Water
Consumption
(liters/day)
2.0
2.0
Food
Exposure
(mg/kg/day)
0.0118
0.0106
Drinking
Water
Exposure"
(mg/kg/day)
0.00337
0.0039
Aggregate
Exposure
(mg/kg/day
)
0.0152
0.015
aPAD4
(mg/kg/day
)
0.067
0.025
Percent
aPAD5
23
58
Notes for Table X
1 . Food exposure values are the maximum of the DEEM or Lifeline acute values .
2. Drinking Water Exposure = (EDWC * daily water consumption) / (1000 ug/mg * Body Weight ); where the EDWC = 118 ug/liter
3. Aggregate Exposure = Food Exposure + Drinking Water Exposure
4. aPAD = NOAEL/1000; where the NOAEL is 25 mg/kg/day for females 13-49 and 67 nig/kg/day for all other population subgroups
5. Percent aPAD = (Aggregate Exposure/aPAD) * 100
                                     Page 39 of 304

-------
              b. Chronic Aggregate Risk Assessment

DWLOC Approach

     Chronic DWLOCs were calculated based upon chronic dietary exposures. As there are no
chronic residential exposures, residential exposures were not included in the chronic DWLOC
calculations. The chronic DWLOCs are summarized in Table 16 and are 46 ug/liter or greater with
the most sensitive population being children. The EDWCs, which range from 1.5 to 23 ug/liter, are
less than the DWLOCs which means that the risks are not of concern. It should be noted that the
master label indicates that potable water consumption from a treated water body cannot begin until
the 2,4-D concentration is 70 ug/liter or below, therefore an annual average exposure at the MCL of
70 ug/liter would not occur because dissipation would reduce the initial concentration of 70 ug/liter to
an annual average concentration of 11 ug/liter.

Table 16.  Chronic DWLOC  Calculations
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
Body
Weight
(kg)
70
10
10
10
10
60
70
70
60
Water
Consumption
(liters/day)
2.0
1.0
1.0
1.0
1.0
2.0
2.0
2.0
2.0
cPAD
(mg/kg/day)
0.005
Food Exp
(mg/kg/day)
0.00020
0.00016
0.00042
0.00037
0.00026
0.00019
0.00019
0.00018
0.00020
Max Water
Exposure
(mg/kg/day)
0.0048
0.00484
0.00458
0.00463
0.00474
0.00481
0.00481
0.00482
0.0048
DWLOC
(^g/L)3
168
48
46
46
47
144
168
169
144
1. Food exposure values are the maximum of the DEEM or Lifeline chronic dietary values.
2. Maximum water exposure (mg/kg/day) = [(chronic PAD - food exposure)]
3. DWLOC (ug/liter) = [maximum water exposure x body weight] - [water consumption x 10"3 mg/ug].
Surface Water EDWC (maximum time weighted annual mean from the NAWQA database) = 1.5 ug/liter
Surface Water EDWC (dissipation modeling of aquatic application when 70 ppb occurs at time zero) =11 ug/liter
Surface Water EDWC (worst case terrestrial use PRZM-EXAMs run) = 23 ug/liter
Ground Water EDWC (the highest monitored value from the NAWQA database) =15 ug/liter
Forward Calculation Approach

     Chronic aggregate risks were also assessed by aggregating chronic food exposures and chronic
water exposures in a forward calculation approach.  The chronic aggregate risks are presented as
percent cPAD in Table 17 and are not of concern because they are less than 100 percent of the cPAD.
The highest risks (38 percent of the cPAD) are for children 1-2 years old.

Table 17. 2,4-D Aggregate Chronic Risks
                                      Page 40 of 304

-------
Population Subgroup
General U.S. Population
Children 1-2 yrs old
Body
Weight
(kg)
70
10
Water
Consumption
(liters/day)
2.0
1.0
Food
Exposure
(mg/kg/day)
0.00020
0.00042
Drinking
Water
Exposure"
(mg/kg/day)
0.00043
0.0015
Aggregate
Exposure
(mg/kg/day
)
0.0006
0.002
cPAD4
(mg/kg/day
)
0.005
0.005
Percent
cPAD5
13
38
1. Food exposure values are from Table X and are the maximum of the DEEM or Lifeline chronic dietary values.
2. Drinking Water Exposure = (EDWC * daily water consumption)/ (1000 ug/mg * Body Weight ); where the EDWC = 15 ug/liter
3. Aggregate Exposure = Food Exposure + Drinking Water Exposure
4. cPAD = NOAEL of 5 mg/kg/day / 1000
5. Percent cPAD = (Aggregate Exposure/aPAD) * 100
              c.  Short-term Aggregate Risk Assessments

DWLOC Approach

     Short-term aggregate risks assessments were conducted by calculating DWLOCs based upon
short term turf exposures, chronic food exposures and short term endpoints. Short-term exposures
from swimming in treated water bodies were not included because these exposures represent episodic
scenarios that are unlikely to occur the same day as an acute dietary exposure.  The short-term
DWLOCs were calculated only for females 13-49 and children 1-6 because these population
subgroups have the highest exposure and are protective of the other subgroups.  The DWLOCS are
listed in Table 18 and range from 24 to 54 ug/liter. These DWLOCs are all greater than the EDWCs,
which range from 15 to 23 ug/liter, and indicate that short term risks are not of concern.

Table 18. Short-Term DWLOC Calculations for 2,4-D
Pop.
Subgroup
Children 1-6
Females 13-
49
Body
Weight
(kg)
15
60
Water
Consumption
(liters/day)
1.0
2.0
NOAEL/UF
(mg/kg/day)
0.025
0.025
Turf
Exposure
(mg/kg/day)
0.021
0.024
Food Exp1
(mg/kg/day)
0.00042
0.00020
Max Water
Exposure
(mg/kg/day)2
0.00358
0.00080
DWLOC
(^g/L)3
54
24
1. Food exposure values are the maximum of the DEEM or Lifeline chronic dietary values.
2 Maximum water exposure (mg/kg/day) = [(NOAEL/UF) - (Turf exposure + food exposure)]
3. DWLOC (ug/liter) = [maximum water exposure x body weight] — [water consumption x 10"3 mg/ug].
Surface Water EDWC (worst case terrestrial use PRZM-EXAMs run) = 23 ug/liter
Ground Water EDWC (based upon the highest monitored value) =15 ug/liter
Forward Calculation Approach

     Short-term aggregate risks were also assessed by directly aggregating short-term turf exposures,
chronic food exposures and chronic water exposures.  Short-term aggregate risks were calculated only
for females 13-49 and children 1-6 because these population subgroups have the highest exposure and
are protective of the other subgroups. The short term aggregate MOEs are presented in Table 19 and
indicate that the short term risks are not of concern because the MOEs equal or exceed the target
MOEof 1000.
                                      Page 41 of 304

-------
Table 19. 2,4-D Aggregate Short-Term MOEs Including Turf Exposures
Population
Subgroup
Females 13-49
Children 1 - 6
Females 13 -49
Children 1 - 6
Turf
Application
Rate
(Ibs ae/acre)
1.5
1.5
1.5
1.5
Chronic
Food
Exposure"
(mg/kg/day)
0.000195
0.000424
0.000195
0.000424
Short-Term
Turf
Exposure
(mg/kg/day)
0.024
0.021
0.024
0.021
Chronic
EDWC4
(ug/liter)
15
15
23
23
Drinking
Water
Exposure'
(mg/kg/day)
0.00050
0.0010
0.00077
0.0015
Aggregate
Exposure
(mg/kg/day)
0.0247
0.0224
0.0250
0.0230
Aggregate
MOE7
1000
1100
1000
1100
1. Body weights are 60 kg (females) and 15 kg (children). Water consumption values are 2 liter/day (females) and 1.0 liter/day (children).
2. The food exposure for females is from Lifeline. The food exposure for children is from DEEM and is for 1-2 year old children
3. Female's turf exposures are from the dermal route only. Children's turf exposures are from the dermal and incidental oral routes.
4. ED WC is 1 5 ug/liter for ground water and 23 ug/liter for surface water.
5. Drinking Water Exposure = (EDWC * daily water consumption) / (1000 ug/mg * Body Weight )
6. Aggregate Exposure = Turf Exposure + Food Exposure + Drinking Water Exposure
7. Aggregate MOE = NO AEL/ Aggregate Exposure where the NOAEL is 25 mg/kg/day.
              d. Cancer Aggregate Risk

     2,4-D was classified as a Category D chemical, i.e., not classifiable as to human
carcinogenicity, by the EPA/OPP Cancer Peer Review Committee in 1996. Thus, no aggregate
cancer assessment is warranted.

              e. Aggregate Risk Characterization

     The highest aggregate risks are the short term risks that include the turf exposure scenarios.
For the most sensitive subpopulation (females 13 -49), these risks j ust meet the target MOE of 1000
and the turf exposure is the risk driver as it contributes 96 percent of the risk. It is important to note,
however, that the turf exposure estimate is based upon modeling and is greater than exposure
measurements obtained from biomonitoring.  The results of a biomonitoring study (Harris and
Solomon 1992) were also used to calculate dermal MOEs for post application exposure on turf. The
study was conducted with adult volunteers who were exposed to 2,4-D while performing controlled
activities for one hour on turf treated with 2,4-D. The controlled activities were conducted at 1 hour
after treatment (HAT) and at 24 HAT. Ten volunteers participated in the study. Five volunteers wore
long pants, a tee shirt, socks and closed footwear. The other five wore shorts and a tee shirt and were
barefoot. The volunteers walked on the turf for a period of 5 minutes and then sat or lay on the area
for 5 minutes and then continued in this fashion for 50 more minutes.  Each volunteer collected all
urine for the next 96 hours immediately following the exposure. The MOEs for the DAT 1
volunteers who wore shorts and no shoes ranged from 1000 to 26000 with the lowest MOE
corresponding to a volunteer who removed his shirt during the exposure period. The MOEs for the
remaining volunteers ranged from 17000 to 27000. If the calculated MOE  of 1000 is considered in
conjunction with the biomonitoring results, it is clear that the short term risks are upper bound
estimates and not likely to be of concern.
                                      Page 42 of 304

-------
           6. 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-D include workers in agricultural areas,
workers in forest areas, workers in rights-of-way and non-cropland areas, workers in lawn and turf
areas (including turf grown for seed or sod), and workers applying 2,4-D for aquatic weed control.
Occupational risk for all of these potentially exposed populations is measured by an MOE which
determines how close the occupational exposure comes to a NOAEL. In the case of 2,4-D, MOEs
greater than 100 do not exceed the Agency's level of concern. 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 reenter.

     Occupational risk estimates are expressed as MOEs, which are the ratio of estimated exposure
to an established dose level (NOAEL). 2,4-D MOEs are determined by a comparison of specific
exposure scenario estimates to the NOAELs for short-term assessment and intermediate-term
assessment, respectively.  The NOAEL for short-term dermal and inhalation exposure is 25
mg/kg/day from a rat developmental toxicity study, and the NOAEL for intermediate-term dermal
and inhalation exposure is  15 mg/kg/day from a rat subchronic oral toxicity study. The dermal
absorption factor is 10 percent and the inhalation absorption factor is 100 percent.  For 2,4-D users an
MOE of 100 has been determined to be adequately protective (for both short- and intermediate-term
exposure) based on the standard uncertainty factors of lOx for interspecies extrapolation and lOx for
intraspecies variability. Long-term worker exposure is not expected for 2,4-D.

     Occupational risk is assessed for exposure at the time of application (termed "handler"
exposure) and assessed for exposure following application, or postapplication 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 activities such as
scouting, irrigating, pruning, and harvesting and is based primarily on dermal exposure estimates.

     Occupational risk estimates are calculated based on assumptions concerning acres treated per
day and the seasonal duration of exposure.  For more information on the assumptions and calculations
of potential risk of 2,4-D to workers, see the Occupational Exposure Assessment (Section 7.0) in
"2,4-D: 3rd Revised Occupational and Residential Exposure and Risk Assessment and Response to
Public Comments for the Reregistration Eligibility Decision (RED) Document," dated May  4, 2005.

              a. Occupational Toxicity

     Table 20 provides a listing of the toxicological endpoints used in the 2,4-D occupational risk
assessment.
                                       Page 43 of 304

-------
Table 20. Toxicological Endpoints for the Occupational Risk Assessment
Exposure
Scenario
Short- Term Dermal*
Intermediate-Term
Dermal*
Long- Term
Dermal*
Short- Term
Inhalation*
Intermediate-Term
Inhalation*
Long- Term
Inhalation*
Cancer
Dose Used in Risk
Assessment, UF
Oral study NOAEL=
25 mg/kg/day
Oral study NOAEL = 15
mg/kg/day
Oral study NOAEL=
5 mg/kg/day
Oral study NOAEL= 25
mg/kg/day
Oral study NOAEL = 15
mg/kg/day
Oral study NOAEL= 5
mg/kg/day
Level of Concern
for Risk
Assessment
Occupational
LOC for MOE -
100
Study and Toxicological Effects
Rat developmental toxicity study
LOAEL = 75 mg/kg/day based on decreased maternal
body-weight gain and skeletal abnormalities
Subchronic oral toxicity - rat
LOAEL =100 mg/kg/day based on decreased body
weight/body-weight gain, alterations in some
hematology, and clinical chemistry parameters, and
cataract formation.
Rat Chronic Toxicity Study
LOAEL = 75 mg/kg/day based on decreased body-
weight gain (females) and food consumption (females),
alterations in hematology , and clinical chemistry
parameters, decreased T4 (both sexes), glucose
(females), cholesterol (both sexes), and triglycerides
(females)].
Rat developmental toxicity study (same as for dermal)
Subchronic oral toxicity - rat (same as incidental oral)
Rat chronic toxicity study (same as for chronic dietary)
Classification: Group D [not classifiable as to human carcinogenicity]
*The dermal absorption factor is 10 percent and the inhalation absorption factor is 100 percent.
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, LOG = level of concern, NA
= Not Applicable
     For more occupational toxicity information, see "2,4-D: HED's Revised Human Health Risk
Assessment for the Reregistration Eligibility Decision (RED) Revised to Reflect Public Comments,"
dated January 4, 2005.

              b. Occupational Handler Exposure

     Occupational handler risk estimates have been assessed for both short- and intermediate-term
exposure durations. Because 2,4-D is typically applied only a few times per season and because the
agricultural scenarios occur for only a few months per year, it is anticipated that 2,4-D exposures
would primarily be short-term. Intermediate-term risk estimates are provided as an upper-bound
assessment.

     Occupational handler assessments are conducted using increasing levels of protection.  The
                                      Page 44 of 304

-------
Agency typically evaluates all exposures with minimal protection and then considers additional
protective measures using a tiered approach (going from minimal to maximum levels of protection).
The lowest tier is represented by the baseline clothing  scenario (i.e., single layer clothing, socks, and
shoes), followed by, if MOEs are of concern, increasing levels of risk mitigation such as personal
protective equipment (PPE) and engineering controls (EC). With the exception of mixing and
loading wettable powders, MOEs for most occupational exposure scenarios are above 100 at baseline
PPE (long-sleeved shirt, long pants, socks, and shoes) or single layer PPE (long-sleeved shirt, long
pants, socks, shoes, and gloves). The MOEs for handling wettable powder are acceptable with
engineering controls (i.e. water soluble bags).  While the generic assessment for 2,4-D as an active
ingredient does not indicate a need for additional PPE, evaluation of end-use product toxicity data
may.  End-use product PPE will be assessed on a product-by-product basis.

              c.  Occupational Handler Risk Summary

     The Agency has determined that there are potential exposures to individuals who mix, load,
apply, and otherwise handle 2,4-D during the usual use patterns associated with the pesticide's use.
Based on the use patterns, 18 major occupational handler exposure scenarios were identified as
follows:

Mixer/Loader
     (la) Mix/Load Wettable Powder for Aerial Application
     (Ib) Mix/Load Wettable Powder for Groundboom Application
     (Ic) Mix/Load Wettable Powder for Aquatic Subsurface Application
     (le) Mix/Load Wettable Powder for 10 Man Crew Backpack Application
     (If) Mix/Load Wettable Powder for Row Sprayer
     (Ig) Mix/Load Wettable Powder for Aquatic Foliar Application
     (Ih) Mix/Load Wettable Powder for Turfgun Application
     (2a) Mix/Load Liquids for Aerial Application
     (2b) Mix/Load Liquids for Groundboom
     (2c) Mix/Load Liquids for Aquatic Subsurface Application
     (2d) Mix/Load Liquids for Airblast Application
     (2e) Mix/Load Liquids for 10 Man Crew Backpack Application
     (2f) Mix/Load Liquids for Row Sprayer
     (2g) Mix/Load Liquids for Aquatic Foliar Application
     (2h) Mix/Load Liquids for Turfgun  Application
     (3) Load Granules for Broadcast Spreader

Applicator
     (4) Aerial Application
     (5) Groundboom Application
     (6) Subsurface Application of Liquids to Submersed Aquatic Weeds
     (7) Airblast Application
     (8) Backpack Application
     (9) Rights of Way (ROW) Application


                                      Page 45 of  304

-------
     (10) Foliar Application of Liquids to Floating Aquatic Weeds
     (11) Turfgun Application
     (12) Broadcast Spreader Application

Mixer/Loader/Applicator
     (13) Mix/Load/Apply Wettable Powder with a Turfgun
     (14) Mix/Load/Apply Liquids with a Turfgun
     (15) Mix/Load/Apply Water Dispersable Granules with a Turfgun
     (16) Mix/Load/Apply Liquids with a Backpack Sprayer
     (17) Load/Apply Granules with a Push Spreader
     (18) Flag Aerial Application
Occupational Handler Exposure Assumptions

     When possible, the assumptions for daily areas treated are taken from the Health Effects
Division Science Advisory Committee on Exposure Policy 9: Standard Values for Daily Acres
Treated in Agriculture (July 5, 2000). In other instances, the daily areas treated were defined for each
handler scenario by best scientific judgement, or the best information available, as footnoted below in
Table 21.

     Analyses were completed using acceptable surrogate exposure data for the scenario assessed.
Several handler assessments were completed using data from the Pesticide Handler Exposure
Database (PHED) (version 1.1). PHED data were used primarily for the large scale agricultural and
forestry scenarios. Some handler assessments (i.e., handheld handgun equipment, push-type spreader,
and other lawn care scenarios) were completed using data from the Outdoor Residential Exposure
Task Force (ORETF). California Department of Pesticide Regulation (CA DPR) data were used for
the backpack applicator forestry scenario where multiple applicators are supplied by a nurse tank.

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

     •     The average work day was 8 hours.
     •     A listing of application methods and amounts of acreage treated per 8 hour day is
           included in Table 22 and Table 23.
     •     The application rate for submerged aquatic weeds is based upon the master label rate of
           10.8 Ibs a.e. per acre foot times an average  lake depth of 5 feet.
     •     Maximum application rates and daily acreage were used to evaluate short term exposures.
     •     Average application rates were used to evaluate intermediate term exposures.
     •     A body weight of 60 kg was assumed for short-term exposures because the short-term
           endpoint relates to females 13-50 years of age.
     •     A body weight of 70 kg was assumed for intermediate-term exposures because the
                                      Page 46 of 304

-------
           intermediate-term endpoint is not gender-specific.
      •     The dermal absorption rate is 10%.
      •     The inhalation absorption rate is  100%.
      •     Baseline PPE includes long sleeve shirts, long pants and no gloves or respirator.
      •     Single Layer PPE includes baseline PPE with gloves.
      •     Double Layer PPE includes coveralls over single layer PPE.
      •     Double Layer PPE PF5 includes  above with a PF5 respirator (i.e. a dustmask).
      •     Double Layer PPE PF10 includes above with a PF10 cartridge respirator.
      •     Only closed cockpit airplanes are used for aerial application.
      •     There are very little exposure data to evaluate the exposure in helicopters; therefore, the
           exposure data for fixed-wing aircraft are used as a surrogate.
      •     Airplane and helicopter pilots do not wear chemical resistant gloves.

Table 21.  2,4-D Application Methods and Assumptions
Application Method
Aenal
Groundboom
Subsurface Application of Liquids
Airblast
Backpack Sprayer - Mix/Load/Apply
Backpack Sprayer - Apply Only
Right of Way (ROW) Sprayer
Foliar Application of Liquids
Broadcast Spreader - Tractor Drawn or Boat
Mounted
Turf gun
Broadcast Spreader - Push Type
Typical Crops Treated
Small Grain, Field Corn, Sugarcane
Citrus Growth Regulation
Small Grams, Field Com, Sugarcane
Orchard/Vineyard Floors
Strawbemes
Submersed Aquatic Weeds
Citrus Growth Regulation
Christmas Tree Plantations
Conifer Release
Weed Control - 20 gallons per acre
Brush Control - 400 gallons per acre
Floating Aquatic Weeds
Turf
Submersed Aquatic Weeds
Turf
Turf
Treated Area
1200
350
200
80
80
302
40
23
44
505
2.55
106
40
507
5
5
1. Except as noted, the acres treated per day values are from ExpoSAC Policy #9 "Standard Values for Daily Acres
Treated in Agriculture", Revised 7/5/2000.
2. The area treated for aquatic application of liquids to submersed aquatic weeds is based on information provided in an
email of 12/11/03 from Dr. Kurt Getsinger of the US Army Corps of Engineers to Timothy C. Dole of the US EPA Office
of Pesticide Programs.
3. The area treated for Backpack Sprayer (Mix/Load/Apply) is 40 gallons per day from ExpoSAC Policy #9 divided by the
label recommended spray volume of 20 gallons per acre.
4. The area treated for Backpack Sprayer (Apply Only) is 4 acres per day based upon the acreage treated in CA DPR HS-
1769 normalized to an 8 hour day.
5. The area treated for ROW sprayers was determined by the dividing the daily spray volume handled (1000 gallons per
                                         Page 47 of 304

-------
day) from ExpoSAC Policy #9 by the label recommended spray volume of 20 gallons per acre for weed control and 400
gallons per acre for woody brush control.
6.  The area treated for foliar application of liquids to floating aquatic weeds is based upon use information reported in the
HED Memorandum "Occupational and Residential Exposure Characterization/Risk Assessment for Tnclopyr
Tnethylamine for Aquatic Weed Control, DP Barcode D269448 of 7/22/2002.
7.  The area treated for application of granules to submersed aquatic weeds is based upon information provided in an email
of 11/22/2000 from Jim Kannenburg of Marine Biochemists/Applied Biochemists to Troy  Swackhammer of the US EPA
Office of Pesticide Programs.

Summary of Risk Concerns and Data Gaps for Handlers

      The MOEs for handlers are summarized in Tables 22 and 23 below.  With the exception of
mixing/loading wettable powder, all of the short-term and intermediate-term MOEs exceed the target
of 100 with baseline PPE (i.e., long-sleeved shirt, long pants, shoes plus socks, no respirator) or single
layer PPE (i.e., long-sleeved shirt, long pants, shoes plus socks, gloves, no  respirator) and are not of
concern.  The MOEs for handling wettable powder are adequate with engineering controls (i.e. water
soluble bags).
Exposure Scenario
Crop Type
Application
Rate
(\b ae/acre)
Acres/
Day
Base-line
Single
Layer
Eng.
Control
Mixer/Loader (M/L)
M/LWP
M/L Liquids
M/L Liquids
Load Granulars for Broadcast
Spreader
All Crops
All Crops
Submersed Weeds
Golf Courses and
Aquatic Areas
0.25 to 4
0.25 to 4
54
2 to 54
5 to 1200
5 to 1200
30
40 or 50
>1
>1
3.2
>220
>5
>89
260
>230
>260
>330
980
>1000
Applicator (APP)
Aerial Application
Groundboom Application
Subsurface Aquatic Application of
Liquids
Airblast Application
Backpack Application
ROW Application
Foliar Aquatic Application of
Liquids
Turfgun Application
Broadcast Spreader Application
All Crops
All Crops
Submersed Weeds
Citrus
Conifer Release
Weed Control
Floating Weeds
turf
Golf Courses and
Aquatic Areas
1.25 to 4.0
1.25 to 4
54
0.1
4
2
2
1.5
1.5 or 54
1200
40 to 200
30
40
4
50
10
5
40 or 50
ND
>1000
430
>1000
ND
110
280
ND
>250
ND
>1000
430
>1000
140
350
870
>1000
>290
>550
>1000
>1000
>1000
ND
ND
ND
>1000
>1000
Mixer/Loader/Applicator (M/L/A)
                                          Page 48 of 304

-------
Exposure Scenario
M/L/A Liquids with Backpack
Sprayer
M/L/A WD Granules with a Turfgun
M/L/A Wettable Powder with a Turf
Gun
M/L/A Liquid Flowables with a
Turfgun
Load/ Apply Granules with a Push
Spreader
Crop Type
Christmas Trees
turf
turf
turf
turf
Application
Rate
(Ib ae/acre)
4
1.5
1.5
1.5
1.5
Acres/
Day
2
5
5
5
5
Base-line
ND
ND
ND
ND
ND
Single
Layer
730
>1000
>1000
>1000
710
Eng.
Control
ND
ND
>1000
ND
ND
Flagger
Flag Aerial Liquid Application
All Crops
1.25 to 4.0
1200
>210
>200
>1000
MOEs in bold font do not exceed the target MOE of 100 and are of concern
ND not determined
Table 23. MOEs for Intermediate-Term Risk to Occupational Handlers
Exposure Scenario
Crop Type
Application
Rate
(\b ae/acre)
Acres/
Day
Base-line
Single
Layer
Eng.
Control
Mixer/Loader (M/L)
M/LWP
M/L Liquids
M/L Liquids
Load Granulars for Broadcast
Spreader
All Crops
All Crops
Submersed Weeds
Golf Courses or Aquatic
Areas
0.25 to 4
0.25 to 4
54
1.5 or 54
5 to 1200
5 to 1200
30
40 or 50
>1.1
>1.5
2.2
>150
>7.3
>130
190
>160
>360
>460
690
>1000
Applicator (APP)
Aerial Application
Groundboom Application
Subsurface Aquatic Application
Airblast Application
Backpack Application
ROW Application
Foliar Aquatic Application of
Liquids
Turfgun Application
Broadcast Spreader Application
All Crops
All Crops
Submersed Weeds
Citrus
Conifer Release
Weed Control
Floating Weeds and Wild
Rice
turf
Golf Courses and
Aquatic Areas
0.5 to 2.0
0.5 to 4
54
0.1
2
2
4 or 0.25
1.5
1.5 or 54
1200
40 to 200
30
40
4
50
10
5
40 or 50
ND
>1000
300
>1000
ND
78
>200
ND
>180
ND
>1000
300
>1000
200
240
>610
>1000
>200
>770
>1000
>1000
>1000
ND
ND
ND
ND
ND
Mixer/Loader/Applicator (M/L/A)
                                   Page 49 of 304

-------
Exposure Scenario
M/L/A Liquids with Backpack
Sprayer
M/L/A WD Granules with a
Turf gun
M/L/A Wettable Powder with a
Turf Gun
M/L/A Liquid Flowables with a
Turf gun
Load/ Apply Granules with a Push
Spreader
Crop Type
C onifer Plantations
turf
turf
turf
turf
Application
Rate
(Ib ae/acre)
4
1.5
1.5
1.5
1.5
Acres/
Day
2
5
5
5
5
Base-line
ND
ND
ND
ND
ND
Single
Layer
510
>1000
>1000
>1000
500
Eng.
Control
ND
ND
>1000
ND
ND
Flagger
Flag Aerial Liquid Application
All Crops
0.50 to 2.0
1200
>660
>610
>1000
MOEs in bold font do not exceed the target MOE of 100 and are of concern
              d. Occupational Postapplication Risk

     Post application 2,4-D exposures can occur in the agricultural environment when workers enter
fields recently treated with 2,4-D to conduct tasks such as scouting and irrigation. In the Worker
Protection Standard (WPS), a restricted entry interval (REI) is defined as the duration of time which
must elapse before residues decline to a level so entry into a previously treated area and engaging in a
specific task or activity would not result in exposures that are of concern.  The WPS REI for 2,4-D is
12 hours for the ester and sodium salt forms and is 48 hours for the acid and amine salt forms.

                1) Exposure Scenarios, Data, and Assumptions

     Postapplication dislodgeable foliar residue (DFR) data were submittted for 2,4-D as well as turf
transferable residue (TTR) data from treated turf. Three turf transferable residue (TTR) studies were
submitted by the Broadleaf Turf Herbicide TTR Task Force.  These studies are described in "2,4-D:
3rd Revised Occupational and Residential Exposure (ORE) and Risk Assessment and Response to
Public Comments for the Reregistration Eligibility Decision (RED) Document"dated May 4, 2005,
and in Appendix F of that document. These data were used in the human health risk assessment
along with standard transfer coefficients based on EPA Science Advisory Council guidance to assess
potential exposures to workers reentering treated sites.

     For all other postapplication activities, EPA used the EPA Science Advisory Council for
Exposure (Exposure SAC) policy on agricultural transfer coefficients.

     The following assumptions were made regarding postapplication occupational exposure:

•    Short term risks were assessed using master label rates.
•    Intermediate term risks were assessed using average application rates when available.
                                      Page 50 of 304

-------
•    The transfer coefficients are from an interim transfer coefficient policy developed by HED's
     Science Advisory Council for Exposure using proprietary data from the Agricultural Re-entry
     Task Force (ARTF) database (US EPA, August 7, 2001).  This policy will be periodically
     updated to incorporate additional information about agricultural practices in crops and new data
     on transfer coefficients.  Much of this information will originate from exposure studies currently
     being conducted by the ARTF, from further analysis of studies already submitted to the
     Agency, and from studies in the  published scientific literature.
•    The transfer coefficients for turf harvesting and maintenance are based upon recently conducted
     ARTF studies that are being reviewed by EPA.
•    In cases where applications would be made in such a way as to minimize contact with crop
     foliage postapplication exposures are expected to be negligible and are not assessed.  These
     cases are included in "2,4-D: 3rd  Revised Occupational and Residential Exposure and Risk
     Assessment and Response to Public Comments for the Reregistration Eligibility Decision
     (RED) Document (PC Code 030001, DP Barcode D316596)", dated May 4, 2005.
•    The initial percent of application rate as Dislodgeable Foliar Residue (DFR) was assumed to be
     20% for all crops except turf. This is the standard value used in the absence of chemical specific
     data.

               2) Occupational Postapplication Risk Estimates

     All short- and intermediate-term  MOEs are above 100 on day zero. All occupational
postapplication risk scenarios are not of concern.  Short-term and intermediate-term risk estimates are
shown in Tables 24 and 25 below.
Table 24. 2,4-D Postapplication Short-Term Worker Risks
Crop Group
Field/row crop, low/med (cereal grains)
Field/row crop, low/med (rice)
Field/row crop, tall (com)
Pre-harvest rate for field corn
Post-emergence rate for sweet corn
Field/row crop, tall (sorghum)
Sugarcane
Turf - California
Turf - North Carolina
ShortTerm MOE on Day 0
Application Rate
(Ib a.e./acre)
1.25
1.5
1.5
0.5
1.0
2.0
2.0
2.0
Low Exposure
Scenarios
6,700
5,600
5,600
17,000
8,400
NA
1,900
860
Medium
Exposure
Scenarios
450
370
1,400
4,200
2,100
420
NA
NA
High
Exposure
Scenarios
NA
NA
560
NA
NA
210
950
430
                                      Page 51 of 304

-------
Table 25. 2,4-D Postapplication Intermediate Term Worker Risks
Crop Group
Field/row crop, low/med (cereal grains)
Field/row crop, low/med (rice)
Field/row crop, tall (field com)
Field/row crop, tall (sweet corn)
Field/row crop, tall (sorghum)
Sugarcane
Turf -California
Turf - North Carolina
Intermediate Term MOE on Day 0
Application Rate+
(Ib a.e./acre)
0.5
0.92
0.44
0.48
0.46
0.75
2.0
2.0
Low Exposure
Scenarios
12,000
6,400
13,000
13,000
13,000
NA
1,600
610
Medium
Exposure
Scenarios
780
420
3,300
3,100
3,100
780
NA
NA
High
Exposure
Scenarios
NA
NA
1,300
NA
NA
390
810
300
+ Average application rates as reported in the QUA report or NASS report were used when available.
              7.  Human Incident Data

     In evaluating incidents to humans, the Agency reviewed reports from the National Poison
Control Centers, the EPA OPP's Incident Data System (IDS), the California Pesticide Illness
Surveillance Program, and the National Pesticide Telecommunications Network (NPTN).

     The Agency reviewed 2,4-D incident reports in January 2004. A total of 45 incidents were
reported in the OPP Incident Data System and many of these incidents involved irritant effects to the
eyes, skin and occasionally respiratory passages.  Poison Control Center Incident Data (1993 to!998)
indicated that 2,4-D is generally less likely than other pesticides to cause minor, moderate or life
threatening symptoms.   The most common symptoms were dermal irritation and ocular problems.
Incident data from the California Pesticide Illness Surveillance Program indicated that the number of
cases generally ranges from 0 to 3 per year and most of these cases were due to eye or skin effects.
Incident data from the National Pesticide Information Center for the years  1996 to 2002 indicated
that an average of 3 cases definitely or probably related to 2,4-D exposure  were reported per year.

              8.  Cancer Epidemiology Studies

     A Science Advisory Board/Scientific Advisory Panel Special Joint Committee reviewed
available epidemiological and other data on 2,4-D in 1992 and concluded that "the data are not
sufficient to conclude that there is a cause and effect relationship between exposure to 2,4-D and non-
Hodgkin's lymphoma" and 2,4-D was classified as a Group D, not classifiable as to human
carcinogenicity. The Agency has twice recently reviewed epidemiological studies linking cancer to
2,4-D.  In the first review, completed January 14, 2004, EPA concluded there is no additional
evidence that would implicate 2,4-D as a cause of cancer (EPA, 2004). The second recent review of
available epidemiological studies occurred in response to comments received during the Phase 3
Public  Comment Period during the reregistration process for 2,4-D. EPA's report, dated December 8,
                                      Page 52 of 304

-------
2004 and authored by Jerry Blondell, Ph.D., found that none of the more recent epidemiological
studies definitively linked human cancer cases to 2,4-D.

     B. Environmental Risk Assessment

     A summary of the Agency's environmental risk assessment for 2,4-D is presented below. The
Agency has conducted an assessment of potential risks to aquatic and terrestrial organisms resulting
from the use of 2,4-D and its associated chemical forms including 2,4-D dimethylamine salt (2,4-D
DMAS), 2,4-D isopropylamme salt (2,4-D IP A), 2,4-D tnisopropanolamme salt (2,4-D TIPA), 2,4-D
ethylhexyl ester (2,4-D EHE), 2,4-D butoxyethyl ester (2,4-D BEE), 2,4-D-diethanolamine salt (2,4-
D DEA), 2,4-D isopropyl ester (2,4-D IPE) and 2,4-D sodium salt.  In this document, the term
"chemical form" is used to refer to the supported technical formulations listed above, while the term
"formulation" refers to the physical nature (e.g. granular or emulsifiable concentrate) of the applied
product, and the term "end use product" is used to refer to any formulated product including mixtures
of pesticide sold in the United States.

     2,4-D has the following registered uses, which result in environmental exposures:
pasture/rangeland, turf, wheat, corn, soybeans, fallowland, hay other than alfalfa, noncropland
(roadways, rights-of-way, ditches, industrial sites, etc.),  forestry, rice, sugarcane, pome fruits, stone
fruits, nut orchards, filberts, grass grown for seed and sod, aquatic weed control, potatoes, asparagus,
strawberries, blueberries, grapes, cranberries, and citrus.

     This summary will present exposure estimates and hazard determinations associated with 2,4-D
and its various chemical forms.  In addition, risks of concern, as determined in the environmental
assessment, will be identified and characterized. More detailed information associated with the
potential environmental risk from the use of 2,4-D can be found in the Environmental Fate and
Effects Division's Risk Assessment for the Reregistration Eligibility Document for 2,4-
Dichlorphenoxyacetic Acid, (2,4-D), dated October 28,  2004. The complete environmental risk
assessment is not  included in this RED, but may be accessed in the OPP Public Docket (OPP-2004-
0167) and on the Agency's website at http://www.epa.gov/pesticides/reregistration/status.htm.

           1. Environmental Exposure

              a. Environmental Fate and Transport

     The environmental fate database is sufficient to characterize the environmental exposure
associated with 2,4-D use.  However, there are some studies that will be required as a result of the
reregistration process. An aerobic aquatic metabolism study for 2,4-D BEE in acidic aquatic
environments is required, along with several other dissipation studies. See section V.A. 1 of this
reregistration eligibility decision (RED) document for a complete list of all required studies. EPA
intends to issue a DCI as part of this RED to require submission of additional data to address areas of
uncertainty. These data are expected to confirm the conclusions of this environmental risk
assessment.
                                       Page 53 of 304

-------
Database
     A complete database has been assembled for 2,4-D acid. The dissipation of 2,4-D appears to be
dependent on oxidative microbial-mediated mineralization, photodegradation in water, and leaching.
2,4-D is stable to abiotic hydrolysis. Photodegradation of 2,4-D was observed [half life (t1/2) =12.9
calendar days or 7.57 days of constant light] in pH 5 buffer solution.  However, the 2,4-D
photodegradation half-life on soil was  68 days.

Degradation Summary
     The degradation of 2,4-D was rapid (t1/2= 6.2 days ) in aerobic mineral soils. The half-life of
2,4-D in aerobic aquatic environments was 15 days.  2,4-D was moderately persistent to persistent
(t1/2 = 41 to 333 days) in anaerobic aquatic laboratory studies.

     Several degradates were detected in the laboratory fate studies reviewed. The degradates
detected were 1,2,4-benzenetriol, 2,4-DCP, 2,4-DCA, chlorohydroquinone (CHQ), 4-chlorophenol,
volatile organics, bound residues, and carbon dioxide.  For a complete listing of 2,4-D degradates for
each route of degradation, please see the environmental risk assessment. No degradates were
considered for further analysis in water or the terrestrial ecological assessment.

Mobility
     2,4-D has a low binding affinity  (Kad < 3 and Kde < 1) in mineral soils and sediment.  The
mobility of 2,4-D in supplemental soil thin layer chromatography (TLC) studies was classified as
intermediately mobile (Rf=0.41) to very mobile (Rf=1.00) in "sieved" mineral soils. Aged
radiolabeled residues of 2,4-D appeared to be immobile in supplemental soil column studies.  2,4-D
was studied in sandy loam, sand, silty clay loam and loam soil.  Freundlich K^ values were 0.17 for
the sandy loam soil, 0.36 for the sand soil, 0.52 for the silty clay loam soil, and 0.28 for the loam soil.
Corresponding Koc values were 70, 76, 59 and 117 mL/g.

Bridging Strategy
     The 1988 2,4-D Registration Standard proposed an environmental fate strategy for bridging the
degradation of 2,4-D esters and 2,4-D amine salts to 2,4-D acid.  The bridging provides information
on the dissociation of 2,4-D amine salts and hydrolysis of 2,4-D esters is included in the ecological
risk assessment. The bridging data indicate esters of 2,4-D are rapidly hydrolyzed in alkaline aquatic
environments, soil/water slurries, and moist soils. The 2,4-D amine salts have been shown to
dissociate rapidly in water. However,  2,4-D esters may persist under sterile acidic aquatic conditions
and on dry  soil.  These bridging data indicate under most environmental conditions 2,4-D esters and
2,4-D amines will degrade rapidly to form 2,4-D acid.

2.4-D Amine Salts
     Additional data submitted subsequent to establishment of the environmental fate bridging
strategy generally support the strategy for the amine salts.  Direct evidence of the stability of 2,4-D
amine salts in soil and aquatic environments is difficult due to the lack of analytical methods.  Based
on maximum application rates for 2,4-D amine salts (at 4 Ibs ae/A), 2,4-D amine salts are expected to
fully dissociate in soil environments because their theoretical concentrations in soil solution does not
exceed water solubilities. Additionally, dissociation studies indicate the time for complete
                                       Page 54 of 304

-------
dissociation is rapid (less than 3 minutes).  Although the analytical methods in the field studies for
2,4-D DMAS were not capable of separating and identifying 2,4-D DMAS from 2,4-D acid, the most
conservative half-lives of 2,4-D DMAS would be equivalent to the 2,4-D acid half-lives in field
studies. Half-lives of 2,4-D in 2,4-DMAS field studies ranged from 1.1 days to 30.5 days with a
median half-life of 5.6 days.

2.4-D Esters
     The conversion of 2,4-D esters to the acid and an associated alcohol moiety is more difficult to
generalize.  Unlike the physical dissociation mechanism of 2,4-D amine salts, the de-esterification of
2,4-D esters is dependent on abiotic and microbial-mediated processes.  Any environmental variable
influencing microbial populations or microbial activity could theoretically influence the persistence  of
the 2,4-D ester. Soil properties including clay mineralogy, organic carbon content, temperature, and
moisture content are known to influence hydrolysis rates (Wolfe, et al, 1989 and Wolfe, 1990).

     Registrant-sponsored research indicates the 2,4-D esters (ethylhexyl, isopropyl, butoxyethyl)
degrade rapidly (half life  less than 24 hours) in soil slurries, aerobic aquatic environments, and
anaerobic, acidic aquatic  environments. In terrestrial field dissipation studies for 2,4-D EHE, the
half-lives for 2,4-D EHE  ranged from 1 to 14 days with median half-life of 2.9 days. 2,4-D BEE,
applied as a granule formulation, degraded rapidly in the water column in aquatic field dissipation
studies under alkaline conditions. However, the 2,4-D BEE residues were detected in sediment
samples from Day 0 (immediately posttreatment) to 186 days posttreatment.  It is unclear whether
2,4-D BEE persistence in sediment is due to the slow release of the granule formulation or to slow de-
esterification of sediment bound 2,4-D BEE.  Available open-literature and registrant sponsored
laboratory data would suggest slow granule dissolution prolonged the persistence of 2,4-D BEE. In
forest dissipation studies, the 2,4-D EHE ester degraded slowly on foliage and in leaf litter.

Persistance of 2,4-D Amine Salts and 2,4-D Esters
     The weight of evidence from open-literature and registrant sponsored data indicates that 2,4-D
amine salts and 2,4-D esters are not persistent under most environmental conditions including those
associated with most sustainable agricultural conditions. 2,4-D amine salt dissociation is expected to
be instantaneous (< 3 minutes) under most environmental conditions. Although the available data on
de-esterification of 2,4-D ester may not support instantaneous conversion from the 2,4-D ester  to 2,4-
D acid under all conditions, it does show 2,4-D esters in normal agriculture soil and natural water
conditions are short lived compounds (< 2.9 days). Under these conditions, the environmental
exposure from 2,4-D esters and 2,4-D amines is expected to be minimal in both terrestrial and aquatic
environments.

               b. Aquatic Organism Exposure

     For exposure to aquatic fish and invertebrates, EPA considers surface water exposure only,
since most aquatic organisms are not found in ground water. Surface water models are used to
estimate exposure to freshwater aquatic animals. Unlike the drinking water assessment described in
the human health risk assessment section of this document, the ecological water resource assessment
does not include the Index Reservoir (IR) and Percent-Crop Area (PCA) factor refinements. The IR


                                       Page 55 of 304

-------
and PCA factors represent a drinking water reservoir, not the variety of aquatic habitats, such as
ponds adjacent to treated fields, relevant to a risk assessment for aquatic animals.  Therefore, the EEC
values used to assess exposure to aquatic animals are not the same as the values used to assess human
dietary exposure from drinking water sources.

                1)  Exposure to 2,4-D Acid in Surface Water

     The aquatic exposure assessment for 2,4-D has relied on a combination of monitoring data and
modeling. Both Tier I (SCIGROW and screening level models for aquatic uses) and Tier n
(PRZM/EXAMS) models have been used to estimate exposure to 2,4-D and its various chemical
forms in a variety of exposure scenarios.  Concentrations used for ecological assessment are 62.8 ug
ae/L for peak, 55.1 ug ae/L for the 21-day average concentration, and 45.4 ug ae/L for the 60-day
average.  The predicted 2,4-D concentrations in surface water are slightly higher than reported
monitoring data. The modeling predictions are expected to indicate upper bound concentration
ranges for 2,4-D. Model input and output files for the ecological assessment may be found in the
ecological risk assessment for 2,4-D.

                2)  Surface Water Modeling of 2,4-D Esters

     The Agency's strategy for bridging the fate data requirements for the ester and amine salt forms
of 2,4-D to the acid form was supported by laboratory data which indicated rapid conversion of the
amine and ester forms of 2,4-D to the acid form. However, 2,4-D esters may persist under acidic
aquatic conditions.  In order to account for the potential impact of the spray application of 2,4-D
esters to aquatic environments, and to account for runoff during the time in which 2,4-D EHE may
remain in the field, the Agency conducted additional modeling with PRZM/EXAMS to assess the
potential for aquatic organisms to be exposed to 2,4-D EHE through spray drift or runoff. The peak
(acute) estimated environmental concentrations (EECs) for the 2,4-D esters were estimated for each
scenario and range from 0.6 ug ae/L (CA citrus) to 7.4 ug ae/L (NC pasture). A chronic EEC was not
provided in this scenario because the hydrolysis soil slurry data indicate that dissipation in a non-
sterile water body will occur at all pHs  and therefore long-term exposures are unlikely.

                3)  Modeling of Direct Application of 2,4-D for Control of Aquatic Weeds

     Because there are no aquatic herbicide model scenarios, a first approximation of an aquatic
ecological EEC was predicted assuming direct application to the standard pond.  For this assessment,
the Agency developed a simple spreadsheet model that incorporates degradation based on an
acceptable aerobic aquatic metabolism  study for the EFED standard pond with no flow.  In this
model, the 21-day average and 60-day average concentrations were calculated assuming first-order
dissipation from aerobic aquatic degradation, but does not assume dissipation.

     The interpretation of the label for aquatic weed control is that the target rate for 2,4-D amine
(2,4-D DMAS) and ester (2,4-D BEE) use is based on concentration and not application rate. In
order to account for this scenario it was assumed that 2,4-D would be applied at a rate to meet the
target concentration of 4000 ug/1. This assumption would be applicable across all water bodies since


                                       Page 56 of 304

-------
the target rate is based on a rate per acre foot of water (10.8 Ibs ae/acre-foot) and would be
independent of water body geometry/volume. This scenario included the assumption of uniform
application across the entire water body; however, this application scenario will over-predict actual
concentrations because 2,4-D is not applied to more than 50% of a water body in a single treatment.
Treating more than 50% of a water body will result in oxygen depletion due to decaying plant
material. Typically, 2,4-D is applied to control aquatic weeds in littoral zones that make up less than
50% of the water body.  Modeling the 2,4-D concentration that results when 100% of the water body
is treated predicts direct water application of 2,4-D will yield surface water concentrations of 2,4-D
concentrations in the EFED standard pond of 4000 ug ae/L for peak, 3417 ug ae/L for the 21-day
average, and 2610 ug ae/L for the 60-day average.  Actual concentrations are expected to be less
given the conservative treatment area assumption as described above, and the likely effects of
dispersion on 2,4-D concentrations.

     EFED evaluated the potential for exposure to 2,4-D BEE using a similar approach. Modeling
predicts direct water application of 2,4-D BEE will yield surface water concentrations of 2,4-D BEE
concentrations in the EFED standard pond of 624 ug/L for peak (24 hour average), 30 ug/L for the
21-day average, and 10 ug/L for the 60-day average.

                4)  Modeling of 2,4-D Use on Rice

     Finally, the use of 2,4-D on rice was evaluated using a screening level model. 2,4-D is
registered for use in rice  paddies for the acid and amine salt forms of 2,4-D (esters are not registered
for rice use) with a maximum seasonal application rate of 1.5 pounds ae per acre. Modeling of this
use rate results in an estimated acute 2,4-D concentration in the rice paddy of 1431 ug ae/L.  This
value is expected to represent upper percentile concentrations for edge of paddy concentrations
because of the lack of consideration for degradation, dilution and dispersion. EFED conducted a
preliminary evaluation of the effect of degradation and holding times on EECs for the use of 2,4-D on
rice.  As with the previous rice model, this refined model provides a single EEC which represents
both an acute and chronic exposure and is an approximation of the EEC at the point of release into a
receiving water body. Modeling with all three scenarios predict initial concentrations in the paddy
water between 678 ug ae/L (California) and 762 ug ae/L (Louisiana) and decreasing concentrations
with holding times based on degradation due to aerobic aquatic metabolism.

              c. Terrestrial Organism Exposure

     The Agency assessed exposure to terrestrial organisms by first predicting the amount of 2,4-D
residues found on animal food items and then by determining the amount of pesticide consumed by
using information on typical food consumption by various species of birds and mammals. The
amount of residues on animal feed items are based on the Fletcher nomogram (a model developed by
Fletcher, Hoerger, Kenaga, et al.)1 and the current maximum application rate as stated in the Master
Label for 2,4-D.  For terrestrial uses of 2,4-D, the Master Label allows a maximum single application
of 4 Ibs ae/A and up to two 2 Ibs ae/A applications per season for a total seasonal maximum rate of 4
                                      Page 57 of 304

-------
Ibs ae/A. Therefore, for terrestrial uses, EPA modeled the maximum and mean residues of 2,4-D in
various food items immediately after the 4 Ib Ibs ae/A application.  The Agency assumed no dilution
due to the growth of the plants or degradation of 2,4-D.  EPA's estimates of 2,4-D residues on various
wild animal food items are summarized in Table 26. EPA used these EECs and standard food
consumption values to estimate dietary exposure levels for 2,4-D to birds and mammals.

Table 26. Estimated Environmental Concentrations on Avian and Mammalian Food Items
(ppm) Following a Single Application at 1 Ib ae/A
Food Items
Short grass
Tall grass
Broadleaf/forage plants and small
insects
Fruits, pods, seeds, and laree insects
EEC (ppm)
Predicted Maximum Residue1
240
110
135
15
EEC (ppm)
Predicted Mean Residue1
85
36
45
7
 Predicted maximum and mean residues are for a 1 Ib ae/a application rate and are based on Hoerger and Kenaga (1972) as modified
by Fletcher etal. (1994).

                1) Birds and Mammals

     The Agency expects exposure to birds and mammals from residues of 2,4-D on food items.
Exposure is probable because 2,4-D is applied in many different environments that provide habitats
rich in food sources attractive to various avian and mammalian species.

                     a) Exposure to Nongranular (Liquid) Formulations

     Toxicant concentrations on food items following multiple applications are predicted based on a
first-order residue decline using the Agency's FATES model. The FATES model allows
determination of residue dissipation over time by incorporating degradation half-life. Predicted
maximum and mean EECs resulting from multiple applications are calculated by taking into account
the maximum or mean initial EEC from the first application, the total number of applications, the time
interval between applications, and a first-order foliar degradation rate of 8.8 days.

                     b) Exposure to Granular Formulations

     Birds and small mammals may be exposed to granular formulations through ingestion of
granules. The number of lethal doses (LD50) that are available within one square foot immediately
after application (LD50/ft2) is used as the risk quotient (RQ) for granular products.  RQs are calculated
for three separate weight classes of birds (1000 g, 180 g, and 20 g) and mammals (15 g, 35 g, and
1000g,35g,andl5g).

                2) Non-target Terrestrial Plants
                                      Page 58 of 304

-------
     Due to the differences in the solubilities of the acid and amine salts when compared to the
solubilities of the esters, risks for these two groups were calculated separately for the non-target
terrestrial plant risk assessment. The terrestrial plant toxicity data for the 2,4-D acid and amine salts
were bridged as one group, while that of the esters were bridged as another group.

     Terrestrial plants inhabiting dry and semi-aquatic areas may be exposed to pesticides from
runoff, spray  drift or volatilization.  EPA's runoff exposure estimate assumes a l-in-10 year rain event
and is based on a pesticide's water solubility and the amount of pesticide present on the soil surface
and its top one inch, characterized as "sheet runoff (one treated acre to an adjacent acre) for dry
areas, characterized as "channelized runoff (10 treated acres to a distant low-lying acre) for semi-
aquatic areas, and is based on percent runoff values of 0.01, 0.02, and 0.05 for water solubility of <10
ppm, 10-100 ppm, and >100 ppm, respectively.   The modeled runoff exposure estimates likely over-
estimate actual exposures from runoff, given the conservative l-in-10 year rain event assumption, and
also given that farming practices, intended to minimize soil loss from runoff, are not taken into
account.

     Spray drift exposure from ground and overhead chemigation applications is assumed to be 1%
of the application rate. Spray drift from aerial, airblast,  and forced-air applications is assumed to be
5% of the application rate with an application efficiency (i.e., the amount that lands on the target area)
of 60%.  The effects of multiple applications are addressed by summing the application rates from
individual applications.

     Applications of granular formulations may pose risks to terrestrial plants  inhabiting dry and
semi-aquatic areas. Exposure is assumed to be from runoff only, and drift is assumed not to occur
with granular applications of pesticides. Therefore, the Agency's runoff scenario  is essentially the
same as that used in the non-granular scenario described above, with the exception that the drift
component is removed.

     The EECs for the acid and amine salts as well as the esters to dry and semi-aquatic areas are
tabulated in Appendix F of the 2,4-D ecological risk assessment for single applications to the targeted
use sites. The percent runoff value based on water solubility is assumed to be 5% for the acid and
amines and 1% for the esters.

           2.  Environmental Effects (Toxicity)

               a. Toxicity to Aquatic Organisms

Freshwater and Estuarine/Marine Fish

     The available acute toxicity data on 2,4-D  indicate that the acid and amine salts are practically
non-toxic to freshwater or marine fish. The esters are highly to slightly toxic to marine or freshwater
fish.  Toxicities for the acid and amine salts range from a LC50 of >80.24 to 2244  milligrams acid
equivalent per liter (mg ae/L).  The ester toxicities range from a LC50  of >0.1564 to 14.5 mg ae/L.
                                       Page 59 of  304

-------
     Chronic toxicity, based on length and larval survival from the early life stage studies, range
from a NOEC of 14.2 to 63.4 mg ae/L for 2,4-D acid, 2,4-D DBA and 2,4-D DMAS. The NOEC
based on larval fish survival for the fish full life cycle studies ranged from 0.0555 to 0.0792 mg ae/L
for 2,4-D BEE and 2,4-D EHE.

Amphibians

     Although not currently required by the Agency, freshwater amphibian studies were conducted
on frog tadpoles (Rana pipiens). Tests were conducted using the ASTM (American Society for
Testing and Materials) Standard E729-88a.  Tests indicate that 2,4-D  acid, 2,4-D DMA, and 2,4-D
EHE are practically non-toxic to tadpoles.

Freshwater and Estuarine/Marine Invertebrates

     Acute toxicity of 2,4-D acid and amine salts to freshwater aquatic invertebrates ranges from a
LC50 of 25 to 642.8 mg ae/L (slightly toxic to practically non-toxic).  The freshwater toxicities of the
esters range from 2.2 mg ae/L for the 2,4-D IPE to 11.88 mg ae/L for the 2,4-D EHE (moderately
toxic to slightly toxic). Acute toxicity of 2,4-D acid and amine salts to marine invertebrates range
from an LC50 of 49.6  for 2,4-D IPA to 830 mg ae/L for 2,4-D DMA (slightly toxic to practically non-
toxic). The marine invertebrate LC50 s range from >0.092 to >66 mg ae/L for the 2,4-D esters (highly
toxic to practically non-toxic). These toxicities indicate that the esters are more toxic than the acid and
amine salts. Although acute data are missing for some of the amine salts, these studies will not be
required because none of the RQs exceed the aquatic levels of concern for the acid amine salts.

     Chronic toxicity tests for freshwater and estuarine/marine invertebrates were performed on 2,4-
D acid, 2,4-D DEA, 2,4-D DMAS, and 2,4-D BEE.  The toxicity ranged from a NOEC of 16.05 mg
ae/1 for 2,4-D DEA (survival and reproduction) and 79 mg ae/L for the 2,4-D acid (number of young).
The chronic freshwater NOEC is  0.20 mg ae/L for the 2,4-D BEE (survival and reproduction).  There
are no freshwater or marine chronic toxicity data for any of the other 2,4-D esters.

     Although an estuarine/marine invertebrate life-cycle toxicity test using the TGAI is required to
establish the toxicity of products containing the 2,4-D acid, salts, and amines, a chronic study will not
be required. The data from the freshwater invertebrate studies will be bridged to the estuarine/marine
invertebrates for the 2,4-D acid and amine salts.  The RQs for the freshwater chronic studies were
well below the levels of concern,  and the chronic risk for estuarine/marine invertebrates would be
expected to be low. However, there is a risk concern for for estuarine/marine invertebrates for the
2,4-D esters. A chronic study will be required for 2,4-D BEE to reduce the uncertainty to
estuarine/marine invertebrates.

Aquatic Plants

     The vascular plant ECso toxicity data for the acid and amine salts range from 0.29 mg ae/L for
2,4-D DEA to 1.28 mg ae/L for 2,4-D TTPA. The ECso toxicity data for the more toxic esters range
from 0.33 mg ae/L for 2,4-D EHE to 0.3974 mg ae/L for 2,4-D BEE. The same trend is shown for the
                                      Page 60 of 304

-------
non-vascular plant ECso. The nonvascular plant EC50 toxicity data range for the acid and amine salts is
3.88 to 156.5 mg ae/L for 2,4-D DMA. The range for the esters is 0.066 mg ae/L for 2,4-D EHE to
19.8 mg ae/L for 2,4-D EHE. In addition, based on the data available, it appears that the vascular
plants are more than two orders of magnitude more sensitive than the non-vascular plants.

              b. Toxicity to Terrestrial Organisms

     The bird and mammal toxicity values of the 2,4-D acid, salts, amine salts, and esters were
pooled because the toxicity values were within one to two orders of magnitude for all the chemical
forms.

Birds

     Toxicity ranges for birds do not show distinct differences between the acid, salts, amine salts,
and esters, as indicated for aquatic animals. All studies have been conducted with the active
ingredient, and have been converted to the acid equivalent since use rates on the master label are
given in pounds acid equivalent per acre.

     2,4-D is classified as moderately toxic to practically non-toxic to birds on an acute oral basis,
since the oral LD50 ranges from 500 mg ai/kg (415 mg ae/kg) for 2,4-D DMAS to >1000  mg ae/kg for
the 2,4-D acid.

     The chronic NOEC of 962 ppm is based on the endpoints of eggs cracked and a decreased
number of eggs laid for the 2,4-D acid. There is no comparable study for the mallard duck and no
other avian chronic study was performed on any of the other active ingredients.

Mammals

     The Agency expects exposure to mammals from residues of 2,4-D on food items, since 2,4-D is
used in many different mammalian habitats, including pasture and rangeland, and turf lawns.
Toxicity  ranges for mammals do not show distinct differences between the acid, salts, amine salts,
and esters as indicated for aquatic animals. All studies have been conducted with the active
ingredient, and have been converted to the acid equivalent since all use rates on the master label are
given in pounds acid equivalent per acre. The rat LD50 ranged from 579 to 1300 mg ae/kg.

     Mammalian chronic toxicity values are from rat and rabbit developmental toxicity studies for
the 2,4-D acid and all amine salts, and esters. In addition, the 2-generation rat study is also available
for the 2,4-D acid.  The NOAEL in the rat chronic toxicity study was 5 mg/kg/day, with a LOAEL of
75 mg/kg/day based on decreased body-weight gain and alterations in hematology.  The NOAEL in
the rabbit developmental toxicity study was 30 mg/kg/day, and the LOAEL was 90 mg/kg/day based
on clinical signs, loss of righting reflex, and abortions.
                                       Page 61 of 304

-------
Non-Target Insects

     Available data from a honey bee acute toxicity study indicated that technical 2,4-D is practically
non-toxic to the honey bee. The LD50 in the honey bee acute toxicity study is greater than 10
micrograms per bee; see MRID 445173-04 for 2,4-D DMA and MRID 445173-01 for 2,4-D EHE.
Minimal risk is expected to non-target insects from 2,4-D use.

Terrestrial Plants

     The terrestrial plant runoff exposure scenario is based on the solubility of the 2,4-D compound.
The water solubilities differ greatly between 2,4-D esters and 2,4-D acid and amine salts. The
terrestrial plant toxicity values for 2,4-D acid and amine salts is summarized in Table 27, and have
been listed as the acid equivalent.  The sensitivity ranges for the monocot and dicot species are listed
for the seedling emergence and vegetative vigor studies.

Table 27. Terrestrial Plant Toxicity Summary for 2,4-D Acid and amine salts
Study Type
Seedling Emergence
Vegetative Vigor
Monocot
Dicot
Monocot
Dicot
Most sensitive Crop /
Active Ingredient
Sorghum /2,4-D DMAS
Mustard /2,4-D DBA
Onion /2,4-D Acid
Tomato /2,4-D DBA
EC25/NOEC
(Ib ae/A)
0.026/0.015
0.045 / 0.045
0.0075/0.0075
0.003/0.002
     The terrestrial plant toxicity for the 2,4-D esters is summarized in Table 28. The sensitivity
ranges for the monocot and dicot species are listed for the seedling emergence and vegetative vigor
studies.

Table 28. Terrestrial Plant Toxicity Summary for 2,4-D Esters
Study Type
Seedling Emergence
Vegetative Vigor
Monocot
Dicot
Monocot
Dicot
Most sensitive Crop /
Active Ingredient
Onion/ 2,4-D WE
Lettuce / 2,4-D IPE
Com /2,4-D IPE
Lettuce /2,4-D IPE
EC25/NOEC
(Ib ae/A)
0.01/0.005628
0.00081/0.00047
0.2016/0.0252
0.00126/0.006132
           3.  Ecological Risk Estimation (RQs)

     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-D
                                       Page 62 of 304

-------
products, the Agency calculates a Risk Quotient (RQ), which is the ratio of the EEC to the most
sensitive toxicity endpoint values.  These RQ values are then compared to the Agency's levels of
concern (LOCs), given in Table 29, which indicate whether a pesticide, 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 (e.g., endangered species), the Agency presumes a risk of concern to that category.
These risks of concern may be addressed by further refinements of the risk assessment or by
mitigation.  Use, toxicity, fate, exposure, and incidents are considered when characterizing the risk,
as well as the levels of uncertainty in the assessment.

Table 29. EPA's Levels of Concern and Associated Risk Presumptions.

Risk Presumption
Acute Risk - there is potential for acute risk; regulatory action may be
warranted in addition to restricted use classification.
Acute Restricted Use - there is potential for acute risk, but may be
mitigated through restricted use classification.
Acute Endangered Species - endangered species may be adversely
affected; regulatory action may be warranted.
Chronic Risk - there is potential for chronic nsk; regulatory action
may be warranted.
LOC
terrestrial
animals
0.5
0.2
0.1
1
LOC
aquatic
animals
0.5
0.1
0.05
1
LOC Plants

1
N/A
1
N/A
     For a more detailed explanation of the ecological risks posed by the use of 2,4-D, refer to
Environmental Fate and Effects Division's Risk Assessment for the Reregistration Eligibility
Document for 2,4- Dichlorophenoxyacetic Acid (2,4-D), dated October 28, 2004.

              a. Risk to Aquatic Organisms

     The RQs for aquatic organisms are presented in detail in Appendix F of the ecological risk
assessment for 2,4-D.

                1) Fish and Aquatic Invertebrates

     There were no acute or chronic Level of Concern (LOC) exceedances for aquatic organisms
through use of 2,4-D acid and amine salts due to runoff/drift from use on terrestrial sites, no acute
LOC exceedances for aquatic organisms due to drift-only of 2,4-D esters to water bodies from use on
terrestrial  sites, and, there were no acute LOC exceedances for aquatic organisms due to the
runoff/drift of 2,4-D esters to water bodies from use on terrestrial sites.  Chronic concerns were not
evaluated  for terrestrial uses of 2,4-D esters.

     Estimated risk quotients (RQs) from use of 2,4-D acid and amine salts in aquatic weed control
through direct subsurface application to water bodies exceed the restricted use LOCs for freshwater
                                       Page 63 of 304

-------
invertebrates. There are no chronic LOG exceedances for this use.  Estimated RQs for use of 2,4-D
BEE in weed control through direct subsurface application to water bodies exceed the acute risk LOG
for freshwater fish and invertebrates and chronic risk LOG for freshwater and estuarine fish and
freshwater invertebrates when compared on an acid equivalent basis.

     Additional characterization of the potential risk associated with the direct application of 2,4-D
for aquatic weed control was completed by back-calculating the target concentration needed to reduce
EECs below LOCs.  This type of consideration provides context to the characterization of potential
risk and indicates that for all 2,4-D chemical forms target concentration reduction of up to 10-fold still
exceeds all LOCs for aquatic organisms.

     While noting the potential risks identified above, it is important to note the benefits gained
through the direct application of 2,4-D to aquatic bodies, for the control of invasive species.  The U.S
Army Corps of Engineers (USAGE), among others, has identified 2,4-D as an important tool for
protecting the nation's waters from the invasion and establishment of some of the world's worst
species of exotic nuisance vegetation.  2,4-D has a reputation as a selective and economical means to
remove invasive plants, enhance the growth and recovery of desirable native vegetation, restore water
quality, reduce sedimentation rates in reservoirs, and improve fish and wildlife habitat. 2,4-D
products are used to control invasive weeds, such as Eurasian watermilfoil (Myriophyllum spicatum)
in the northern tier states and water hyacinth (Eichhornia crassipes} in the Gulf Coast states. Effective
control of these plants  can benefit public health with respect to reducing levels of mosquito habitat. In
addition, according to USAGE, no other product (or alternative technique) can control these plants in
a more cost-effective manner (K. Getsinger, USAGE, Public Comment; Docket ID# OPP-2004-0167-
0053).

     Estimated RQs for use of 2,4-D  acid and amine salts in rice paddies exceed the acute
endangered species LOCs for freshwater invertebrates.  The rice model used to predict these EECs is
a screening level model which predicts concentration in tailwater at the point of release from the
paddy. It is anticipated that once released, the concentration will be reduced and subsequently is
expected to decrease away from the point of release. Additional characterization was conducted by
considering average application rates (average rates are presented in the quantitative usage analysis
dated August 9, 2001 prepared by the Biological and Economic Affairs Division of EPA/OPP) versus
maximum label rates and assuming a proportional reduction in EECs.  Consideration of average
application rates results in EECs below the endangered species LOG.

                2)  Aquatic Plants

     For non-target, aquatic plants, estimated RQs resulting from the runoff/drift of 2,4-D acid and
amine salts from use on terrestrial crops exceed the aquatic vascular plant endangered species LOCs
for use of 2,4-D acid and amine salts on pasture and apples.  Consideration of average application
rates and assuming a proportional reduction in EECs results in RQs below the endangered species
LOG.  Likewise, there are no LOG exceedances from the drift of the ester forms to aquatic water
bodies or from the runoff of the ester forms to water bodies from use on terrestrial sites.
                                       Page 64 of 304

-------
     Estimated RQs for the scenario of direct application to water for aquatic weed control for 2,4-D
acid and amine salts indicate acute and endangered species LOG exceedances for aquatic vascular
plants and acute LOG exceedances for non-vascular plants, while estimated RQs for the use of 2,4-D
BEE for direct application to water to control aquatic weeds exceed all LOCs for vascular and one
acute LOG exceedance for non-vascular plants. Risk to endangered non-vascular plants is not
evaluated because at this time there are no listed endangered nonvascular plant species. Additional
characterization of potential risk for the direct application of 2,4-D for aquatic weed control was
completed by back-calculating the target concentration needed to reduce the RQs below LOCs.  This
type of consideration provides context to the characterization of potential risk and indicates that for all
2,4-D chemical forms target concentration reduction of up to 100-fold still exceeds all LOCs for
aquatic plants.

     While noting the potential risks identified above, it is important to note the benefits gained
through the direct application of 2,4-D to aquatic bodies, for the control of invasive species.  The U.S
Army Corps of Engineers (USAGE), among others, has identified 2,4-D as an important tool for
protecting the nation's waters from the invasion and establishment of some of the world's worst
species of exotic nuisance vegetation. 2,4-D has a reputation as a selective and economical means to
remove invasive plants, enhance the growth and recovery of desirable native vegetation, restore water
quality, reduce sedimentation rates in reservoirs, and improve fish and wildlife habitat.  2,4-D
products are used to control invasive weeds, such as Eurasian watermilfoil (Myriophyllum spicatum)
in the northern tier states and water hyacinth (Eichhornia crassipes) in the Gulf Coast states. Effective
control of these plants can benefit public health with respect to reducing levels of mosquito habitat. In
addition, according to USAGE, no other product (or alternative technique) can control these plants in
a more cost-effective manner (K. Getsinger, USAGE, Public Comment; Docket ID# OPP-2004-0167-
0053).

     Estimated RQs for use of 2,4-D acid and amine salts in rice paddies exceed the acute and
endangered species LOCs for aquatic vascular plants.  Consideration of average application rates
results in RQs below the endangered species LOCs.

              b. Risk to Non-target Terrestrial Organisms

                1)  Birds

     The RQs for birds are presented in detail in Appendix F of the ecological risk assessment for
2,4-D. Potential risks were evaluated for non-granular and granular formulations applied both as
banded and broadcast applications.

     EPA has relied on risk estimates from oral gavage studies on birds (LD50 of 415 mg ae/kg-bw)
to assess risk because no definitive endpoint was determined from dietary studies. Therefore, it is
likely that the risk estimates associated with the gavage studies overestimate the actual exposure of
birds in the field. For predicted maximum exposures when compared with oral gavage data there are
exceedances of acute LOCs for all use sites except potatoes and citrus for most small birds and some
medium birds. There are also exceedances of acute restricted use and endangered species LOCs for
medium and large birds feeding on short grass, tall grass, and broadleaf forage/small insects at all use
sites except potatoes and citrus. However, comparison with the lowest dietary LC50 of >5620 mg


                                       Page 65 of 304

-------
ae/kg-diet would result in no acute LOG exceedances. As noted previously, no definitive endpoint
was available from the avian acute dietary studies and, hence, risk was not evaluated using this
endpoint.

     The RQs are presented below in Table 30 for the avian risk due to 2,4-D residues on various
food items.

Table 30. Avian Risk Quotient Summaries for Non-granular Spray Applications of 2,4-D acid,
amine salts and esters
Use Site (Acute &
Chronic Risk)
Scenario
Short Grass
Tall Grass
Broadleaf, forage,
small insects
Fruit, large insects,
Fallow areas and Crop Stubble; Turf (Golf courses, Residential Lawns, Grasses Grown for Seed, and Sod); Pastures,
Rangeland, Perennial Grassland; Sugarcane (2 Ibs ae/A/app, 2 app., ground/aerial, 30 day interval)
Acute RQ Exceedance
0.1* -1.91***
0.04-0.88***
0.04-0.78***
-
Non-Cropland (Fencerows, Hedgerows, Roadsides, Ditches, Rights-of-Way, Utility Power Lines, Railroads, Airports,
Industrial Sites, etc.); Forest Uses, Cranberry (4.0 Ibs ae/A/app, 1 app., ground/aerial,)
Acute RQ Exceedance
0.18* -3.5***
0.07-1.6***
0.07-1.43***
0.01-0.15*
Fruit, Small Grains (Except Corn), Asparagus (1.4 to 2.0 Ibs ae/A/app)
Acute RQ Exceedance
0.09-1.75***
0.04-0.81***
0.03 - 0.72***
-
Corn (1.5 Ibs ae/A/app, 2 app., 7 day interval, ground or aerial)
Acute RQ Exceedance
0.1* -2.07***
0.04-0.81***
0.03 - 0.72***
-
* indicates an exceedance of Endangered Species Level of Concern (LOC).
** indicates an exceedance of Acute Restricted Use LOC.
*** indicates an exceedance of Acute Risk LOC.

     Chronic risk calculations resulted in RQ's of 1.0 to 1.1 on birds which forage on short grass
when the application rate of 2,4-D ranges from 2.0 to 4.0 Ib ae/A such as seen with rights-of-way,
cranberries or asparagus. The chronic risk LOC is 1.0.

Non-granular Banded Applications - According to the Master Label for 2,4-D, products that allow
for banded applications of sprays to row crops require all formulators to adjust the application rates
according to a formula provided. Many current labels do not advise applicators to adjust the
application rates, and the resulting treatment can be interpreted to concentrate the per acre application
rate into a narrow band. Birds, at least in theory, could be exposed to the higher concentration of
toxicant by foraging or wandering into the treated  band. EPA/OPP evaluated the banded risk by
comparing the RQs from unadjusted band rates to  those using the adjusted band rates to illustrate the
increased risk. OPP assumed a 6 inch band and 30 inch row space as a typical banded application.
The RQs indicate that levels of concern are not exceeded for 1000 g birds for rates adjusted due to
band widths.  LOCs are also not exceeded  for these adjusted rates for potatoes  for all weight classes
of birds.  The unadjusted band width rate, however, exceeds LOCs for all weight classes of birds for
all uses with the exception of potatoes.

Granular Broadcast Applications - Acute RQs for granular products are calculated for three separate

                                        Page 66 of 304

-------
weight classes of birds using the LD50/ft2: 1000 g (e.g., waterfowl), 180 g (e.g., upland gamebird), and
20 g (e.g., songbird). The acute RQs for broadcast applications of granular products are tabulated
below for the use sites from the 2,4-D Master Label which support granular formulations.
Table 31: Avian Acute Risk Quotient Calculations for Granular Broadcast A

Von-Cropland (4.0 Ibs ae/A/app, 1 app., ground/aerial,)
Aquatic areas (4.0 Ib ae/A/app. 3 wks between apps)
Cranberry (4.0 Ibs ae/A/app, 1 app., ground)
Turf (2.0 Ibs ae/A/app, 2 app., ground/ aerial, 30 day interval)
Aquatic areas - Ditchbank applications (2.0 Ib ae/A/app., 2 app.,
ground)
Aquatic areas - Surface application or subsurface injection (10.8
Ib ae/acre-foot to an average pond depth of 5 feet)
Bird Body Weight (g)
20
180
1000
20
180
1000
20
180
1000
pplications
Acute RQ
(LD^perft2)"
5.02***
0.55***
0.1*
2 5***
0.3**
0.05
13.55***
1 5***
0.27**
aRQ = App. Rate (Ibs ae) x 453,590 mg x   Acre
        Acre            Lb      43,560 ft2
1
  	  x  1000 g x     Kg
Animal weight (g)     1 kg     LD50 mg
* indicates an exceedance of Endangered Species Level of Concern (LOC).
** indicates an exceedance of Acute Restricted Use LOC.
*** indicates an exceedance of Acute Risk LOC.
Granular Banded Applications - In addition to broadcast applications of granular formulations, a
number of labels instruct the applicators to apply unincorporated banded treatments of granular
products to crops.  As explained for banded spray treatments above, many labels adjust application
rates according to band width and row spaces, but many others do not.  If banded granular
applications were used at the same sites as banded spray applications, the risk would be similar.

                2) Mammals

     Acute LOCs for mammals feeding on plants and insects were exceeded when considering non-
granular formulations, for all uses assessed for small and medium size mammals, except potatoes and
citrus.  There were no exceedances for granivores. Banded applications result in exceedances of
acute LOCs at all use sites.

     Mammalian chronic RQs range from 0.05 to 200 and chronic LOCs were exceeded in all cases
with the exception of potatoes and citrus (large insects, seeds). Consideration of average application
rates results in EECs below the LOCs for non-granular, granular,  or banded applications. However,
consideration of average application rates for non-granular, granular and banded applications did not
result in exposure below the chronic LOC.
                                       Page 67 of 304

-------
Acute Exposure from Nongranular 2,4-D Products The acute RQs for broadcast applications of
nongranular products are tabulated for herbivores/insectivores and granivores in Appendix F of the
ecological risk assessment for 2,4-D.  When the LD50 of 1072 mg ai/kg (579 mg ae/kg) is used for in
herbivore/insectivore RQ calculations, endangered species LOCs are exceeded at many sites for
mammals foraging on short and tall grass, broadleaf plants, and small insects. The RQs range from
1.72 for asparagus to < 0.01 for potatoes. There are no LOG exceedances for granivorous mammals.

      As described above for avian risk, in addition to broadcast spray, a number of labels instruct the
applicators to apply unincorporated banded treatments of sprays to row crops. Using the same
assumptions as described above for birds, the RQs for mammals are presented in Table 32. Again,
for purposes of comparison, the unadjusted rates that appear on many of the current labels have been
included. Using the mammalian LD50 of 579 mg ae/kg, acute levels of concern are exceeded at all
use sites and for 15, 35, and 1000 g mammals when banded rates are not adjusted. When the banded
rates are adjusted, LOCs are not exceeded for 1000 g mammals. The results of these calculations are
tabulated in Appendix F of the ecological risk assessment for 2,4-D.

Acute Exposure to Granular 2,4-D Products - Mammalian species also may be exposed to granular
pesticides by ingesting granules. The number of lethal doses (LD50) that are available within one
square foot immediately after application can be used as a RQ (LD50/ft2)for the various types of
exposure to pesticides. RQs are calculated for three separate weight classes of mammals: 15 g, 35 g,
and 1000 g. The LOCs are exceeded for all sites with the following exceptions: no LOCs are
exceeded for 1000 g mammals in turf, aquatic areas (ditchbanks and surface applications), or
cranberries.

      The acute RQs for broadcast applications of granular products are tabulated below for the use
sites from the master label which support granular formulations.

Table 32; Mammalian Acute Risk Quotient Calculations for Granular Broadcast Applications
Animal Body Weight (g)
Non-Cropland (4.0 Ibs ae/A/app, 1 app., ground/aerial,)
Aquatic areas (4.0 Ib ae/acre/app. 3 weeks between
applications)
Cranberry (4.0 Ibs ae/A/app, 1 app., ground)
Turf (2.0 Ibs ae/A/app, 2 app., ground/aerial, 30 day interval)
Aquatic areas - Ditchbank applications (2.0 Ib ae/acre/app., 2
app., ground
Aquatic areas - Surface application or subsurface injection
(10.8 Ib ae/acre foot to an average pond depth of 5 feet)
15
35
1000
15
35
1000
15
35
1000
Acute RQ (LD50 per ft2) 1
4.8***
2 i ***
0.1*
24 ***
1.0***
??
12.9***
5.5***
0.2**
1 RQ = App. Rate (Ibs ae)  x 453,590 mg x  Acre
        Acre            Lb      43,560 ft2
s      1       x  1000 g  x    Kg
 Animal weight (g)      1 kg     LD50 mg
* indicates an exceedence of Endangered Species Level of Concern (LOC).
** indicates an exceedence of Acute Restricted Use LOC.
*** indicates an exceedence of Acute Risk LOC.
                                       Page 68 of 304

-------
Chronic Exposure to Mammals - The chronic RQs for broadcast applications of nongranular
products are tabulated in Appendix F of the 2,4-D ecological risk assessment for all classes of
mammals.  The parental toxicity NOAELs ranged from 5 mg/kg/day based on female body weight
gain and male renal tubule alteration for the 2,4-D acid. The FATE program was used to determine
the maximum and 56-day average residues that occur in a one year time period.  The application rate,
minimum number of applications, and the interval between applications were determined from the
2,4-D Master Label and represent the highest single application rates.  Levels of concern were
exceeded in all cases with the exception of potatoes and citrus (large insects, seeds) and RQs ranged
from 0.1 to 200.

                3) Non-Target Insects

     The Agency currently does not quantify risks to terrestrial non-target insects. RQs are therefore
not calculated for these organisms. Since the test results from one of the salts (2,4-D DMAS) and
2,4-D EHE was practically non-toxic to honey bees (LD50 of >100 jig/bee), the potential for 2,4-D
and its salts and esters is predicted to pose minimal risk to pollinators and other beneficial insects.

                4) Non-target Terrestrial Plants

     Acute LOCs for both non-endangered and endangered terrestrial plants were exceeded for non-
granular and granular uses at many use sites. Consideration of average application rates did not result
in exposure below LOCs.

     RQs for terrestrial plants in dry and semi-aquatic areas are calculated for multiple and single
spray applications for endangered and non-endangered species.  As  mentioned above in the exposure
section, the runoff scenarios are based on solubility, and as a consequence, the environmental
concentrations must be calculated separately for the esters and the acid and amine salts.  The
environmental concentrations for the esters were calculated separately at a percent runoff value of
0.01, while that of the acid and amine salts were calculated at a value of 0.05.  A 60% efficiency
factor is also included for aerial applications. In addition, banded applications granular and non-
granular formulations are also calculated.  The detailed calculations for terrestrial plants are tabulated
in Appendix F of the ecological risk assessment.

Risk Quotient (RQ) Calculations - To calculate the RQs for non-endangered plants the EC25 value of
the most sensitive species in the seedling emergence study is compared to runoff and drift exposure to
determine the RQ (EEC/toxicity value). The EC25 value of the most sensitive species in the
vegetative vigor study is compared to the drift exposure to determine the acute RQ.  RQs are
calculated for the most sensitive monocot and dicot species.

RQs for Endangered Plants - To calculate the RQs for endangered plants the NOEC or EC05 value of
the most sensitive species in the seedling emergence study is compared to runoff and drift exposure
(EEC/toxicity value).  The NOEC or EC05 value of the most sensitive species in  the vegetative vigor
study is compared to the drift exposure to determine the acute RQ.  RQs are calculated for the most
sensitive monocot and dicot species.  The RQ ranges for single and multiple applications are
summarized below for non-endangered and endangered plants for the acid and amine salts, and


                                      Page 69 of 304

-------
separately for the esters.
•    Single Spray Applications - Most use sites on the 2,4-D Master Label allow multiple
     applications. However, the following use sites are labeled for maximum application rate for a
     single application.

Table 33. 2,4-D Use Sites With Maximum Labeling for a Single Application
Use Site
Non-crop l, Forest Uses, Cranberry
Strawberry, Rice
Grapes
Sorghum, Soybean
Soybean
Citrus
Application Rate/Method
Ground & Aerial Applications (4.0 Ibs ae/A/app.,)
Ground & Aerial Applications (1.5 Ibs ae/ac/app.)
Ground Applications (1 .36 Ibs ae/A/app.)
Ground and Aerial Applications (1 .0 Ibs ae/A/app.)
Ground & Aerial Applications (1.0 Ibs ae/A/app.)
Ground or Aenal Applications (0. 1 Ibs ae/A/app.)
1 Woody plants in rights-of-way. Other non-crop sites may have up to 2 applications of 2 Ibs each.

     The detailed RQ calculations for single applications are tabulated in detail in Appendix F of the
ecological assessment for 2,4-D, and a summary is presented below.

Table 34. Terrestrial Plant Risk Quotients for Single Applications
Chemical Group (acid / ester)
2,4-D Acid and Amine Salt
2,4-D Ester
Plant Group (non-endangered /
endangered)
non-endangered
endangered
non-endangered
endangered
Risk Quotient Range
0.18-67
0.13-136
O.01 - 543.21
0.04-936.17
Multiple spray applications - Most of the 2,4-D products on the 2,4-D Master Label allow second
applications at prescribed intervals ranging from 7 to 30 days with the exception of pome fruit which
allows a 75 day interval. The RQs for multiple applications follow a linear pattern for changes in
application rates, and since a maximum of two applications is allowed, the RQ doubles for these
applications. The detailed calculations are tabulated in detail in Appendix F of the 2,4-D ecological
risk assessment, and a summary is presented below.

Table 35. Terrestrial Plant Risk Quotients for Multiple Applications	
   Chemical Group (acid / ester)
 Plant Group (non-endangered /
	endangered)	
Risk Quotient Range
      2,4-D Acid and Amine Salt
         non-endangered
     0.19-157
                                           endangered
                                          0.19-272
                                       Page 70 of 304

-------
Chemical Group (acid / ester)
2,4-D Ester
Plant Group (non-endangered /
endangered)
non-endangered
endangered
Risk Quotient Range
0.01 - 12
0.01 -33
Banded Spray Applications - Banded spray applications are allowed on a number of labels and
instruct the applicators to apply unincorporated banded treatments of sprays to row crops. Many
labels adjust application rates according to band width and row spaces, but others do not. For the
labels which do not adjust the application rates, the treatments could be more concentrated in the
bands. Since non-target plants do not migrate from treated to untreated bands as is the case with birds
and mammals, exposure to plants is characterized as "sheet runoff (one treated acre to an adjacent
acre) for dry areas and "channelized runoff (10 treated acres to a distant low-lying acre) for semi-
aquatic areas. Therefore, the higher per acre rates in the concentrated bands do not affect the
exposure to non-target plants when label rates are not adjusted.

     The 2,4-D Task Force proposal to require all formulators to adjust the application rates for
banded applications will reduce the exposure to non-target plants. If we assume use of the same 6
inch band and 30 inch row space that we used for the analysis  of birds and mammals, the per acre
banded application rate would be reduced by 1/5 of the broadcast application rate. The RQs are
detailed in Appendix F  of the ecological risk assessment for 2,4-D, and summarized for multiple and
single applications in the following table.

Table 36. Non-target Plant Risk Quotient Summary of Adjusted Band Applications to Selected
Row Crops.
Chemical Group (acid /
ester)
2,4-D Acid and Amrne Salt
2,4-D Ester
Plant Group (non-
endangered /
endangered)
non-endangered
endangered
non-endangered
endangered
Risk Quotient Range
(Single Applications)
0.02 - 60
0.02 - 439
O.01 - 27
O.01 - 47
Risk Quotient Range
(Multiple Applications)
0.04 - 120
0.04 - 878
O.01 - 54
O.01 - 94
Granular Applications - The only currently approved granular applications which are currently
allowed on the master label are on grass grown for seed or sod, turf, cranberries, non-crop land, and
aquatic weed control sites. The non-target terrestrial plant RQ summaries for the acid and amine salts
for the esters are presented below. Detailed RQs are presented in Appendix F of the ecological risk
assessment for 2,4-D.
                                       Page 71 of 304

-------
Table 37. Non-target Plant Risk Quotient Summary of Granular Applications to Selected Uses.
Chemical Group (acid /
ester)
2,4-D Acid and Amine Salt
2,4-D Ester
Plant Group (non-endangered /
endangered)
non-endangered
endangered
non-endangered
endangered
Risk Quotient Range
(Single Applications)
2.2 - 77
2.2-133
2.0- 494
3.57-851
Risk Quotient
Range (Multiple
Applications)1
4.4-154
4.4 - 266
4.0 - 987.62
7.14 -1702.12
1 Turf is only site for multiple applications of granular products.

              4. Ecological Incidents

Aquatic Incidents
     The EFED Ecological Incident Information System (EIIS) database reports pesticide incidents
that have been voluntarily submitted to EPA by state agencies. The report assigns a certainty index of
0 (unrelated), 1 (unlikely), 2 (possible) 3 (probable) or 4 (highly probable) to each incident. In
addition, a judgement of registered use, accidental misuse, intentional misuse, or undetermined is
assigned.  There were 227 incidents reported for 2,4-D, and 24 of these incidents were reported as
aquatic incidents under the 2,4-D acid only.
     The two "highly probable" registered use incidents occurred when 2,4-D was applied to corn
and a railroad right-of-way. The corn application resulted in bluegill and largemouth bass mortalities
in Missouri, while the right-of-way application resulted in a kill of 23,000 (presumably) fish.
     The corn incident affected bluegill, catfish, crappie, fox squirrel, greengill, largemouth bass,
silver minnow, smallmouth bass,  sunfish and watersnake.  This incident was determined to be "highly
probable" and was not listed as a misuse, however, no residue analysis was obtained. Another
incident was recorded as "possible" and the use was "undetermined." The species affected included
bass, catfish, crappie, grass carp, and perch.
     Results from these incidents should be regarded with caution since it is not clear exactly which
products or tank mixes might be involved.  In addition, residue analysis was not available in almost
all instances.

Terrestrial Incidents
      There were 227 terrestrial incidents reported for 2,4-D, and 155 of these incidents were
reported as plant incidents under the acid form only. Two incidents were reported as both terrestrial
and aquatic.
     Eighty-four incidents to plants were listed as registered uses and most were considered
"probable."  Crop damage was reported to have occurred on numerous crops, but most common non-
target plant damages occurred on grass and corn.  However, most of these incidents resulted from
applications to lawns/turf and corn, respectively.
     Results from the incident reports should be regarded with caution since it is not clear exactly
which products or tank mixes might be involved. In addition, residue analysis was not available in
almost all instances.

              5. Endangered Species Concerns
                                       Page 72 of 304

-------
     The Agency has developed the Endangered Species Protection Program to identify pesticides
whose use may cause adverse impacts on 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 to affect any
particular species, EPA puts basic toxicity and exposure data developed for REDs into context for
individual listed species and their locations by evaluating important ecological parameters, pesticide
use information, the geographic relationship between specific pesticide uses and species locations,
and biological requirements and behavioral aspects of the particular species.  This analysis will take
into consideration any regulatory changes recommended in the RED that are being implemented at
this time. 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.

     The Endangered Species Protection Program as described in a Federal Register notice (54 FR
27984-28008, July 3, 1989) is currently being implemented on an interim basis.  As part of the
interim program, the Agency has developed County Specific Pamphlets that articulate many of the
specific measures outlined in the Biological Opinions issued to date. The Pamphlets are available for
voluntary use by pesticide applicators on EPA's website at www.epa.gov/espp.

     The preliminary risk assessment for endangered species indicates that 2,4-D exceeds the
endangered species LOCs for the following combinations of analyzed uses and species:

•    Estimated risk quotients (RQs) from use of 2,4-D DMAS in weed control through direct
     subsurface application to water bodies exceed the endangered species LOG for freshwater and
     estuarine fish, and estuarine invertebrates. However, there are currently no endangered
     estuarine/marine invertebrates.
•    Estimated RQs from use of 2,4-D BEE in weed control through direct subsurface application to
     water bodies  exceed the endangered species LOG for freshwater fish and invertebrates and
     estuarine fish.
     Estimated RQs from use of 2,4-D acid and amine salts in rice paddies exceed endangered
     species LOCs for freshwater invertebrates. The rice model used to predict these EECs is a
     screening level model which predicts  concentration in tailwater at the point of release from the
     paddy.  It is anticipated that once released, the concentration will be reduced and subsequently,
     RQs will decrease.
•    The scenario of the  direct application to water for weed control for the acid and amine salts
     indicates a endangered species concern for aquatic vascular plants. Estimated RQs from use of
     2,4-D BEE for direct application to water for weed control exceed all LOCs for both vascular
     and non-vascular plants. Potential risk to endangered non-vascular plants is not evaluated
     because at this time there are no listed endangered non-vascular plant species.
•    Target acute RQs for birds and mammals were exceeded for endangered species risks for
     multiple crops and multiple animal weights. Banded and granular applications result in higher
     RQs at more use sites.
•    Target acute LOCs for both non-endangered and endangered plants were exceeded for non-
     granular and granular for multiple uses, based on predicted EECs.
                                       Page 73 of 304

-------
     In December 2004, EPA completed a refined assessment for 2,4-D's potential effects to 26
environmentally significant units (ESUs) of Pacific Salmonids (salmon and steelhead). That refined
assessment concluded that 2,4-D has "no effect" on these species when used according to label
directions on terrestrial sites.  Further, that assessment concluded that use of 2,4-D on rice "may affect
but is not likely to adversely affect" 4 ESU's and will have "no effect" on 22 ESU's. That same
analysis concluded that use of 2,4-D "may affect" each of the 26 ESU's when used for aquatic weed
control purposes. As a result of that assessment, EPA is currently engaged in consultation with the
National Marine Fisheries  Service regarding those scenarios that resulted in a determination that 2,4-
D "may affect but is not likely to adversely affect" the species, or "may affect" the species.

     The Agency's level of concern for endangered and threatened freshwater fish and invertebrates,
estuarine invertebrates, birds, mammals, aquatic vascular plants, and terrestrial non-target plants is
exceeded for the use of 2,4-D. The Agency recognizes that there are no  Federally listed
estuarine/marine invertebrates. The registrant must provide information  on the proximity of Federally
listed freshwater vascular plants, birds, mammals, and non-target terrestrial plants (there are no listed
estuarine/marine invertebrates) to the 2,4-D use sites. This requirement may be satisfied in one of
three ways: 1) having  membership in the FIFRA Endangered Species Task Force (Pesticide
Registration [PR] Notice 2000-2); 2) citing FIFRA Endangered Species Task Force data; or 3)
independently producing these data, provided the information is of sufficient quality to meet FIFRA
requirements. The information will be used by the OPP Endangered Species Protection Program to
develop recommendations  to avoid adverse effects to listed species.

              6. Risk Characterization

     The Agency has considered available information on 2,4-D's  toxicity, use areas, usage, fate
properties, and application methods and formulations in characterizing ecological risks related to
normal use.  Upon review and synthesis of this information, the Agency concludes use of 2,4-D for
aquatic weed control presents risk to aquatic organisms, while 2,4-D use  on terrestrial  sites presents
the greatest potential risks to small mammals, birds, and non-target  terrestrial plants.

                a.  Characterization of risk to aquatic organisms from direct aquatic
                application

     Whereas the maximum labeled target concentration for control of aquatic weeds is 4 ppm, the
typical target concentration is 2 ppm.  Moreover, the risks to aquatic organisms were estimated based
on a 2,4-D application that resulted in a whole-reservoir concentration of 4 ppm.  Treating 100% of
the water body would  result in a large amount of decaying plant life, thereby creating an oxygen-
depleted environment  that would most likely result in fish kills.  To avoid that scenario, the 2,4-D
label advises the applicator to avoid treating more than 50% of a water body in a single application.
In actual practice, aquatic weeds that 2,4-D controls tend to grow in littoral zones. As  a result,
generally a maximum  of 20-30% of a water body is treated in a single application.  Applying the
typical rate of 2 ppm, and taking into account a typical maximum treated area of 30% would decrease
calculated RQs by approximately 6-fold.
     While noting the potential risks to aquatic organisms from the direct application  of 2,4-D for the
control of aquatic weeds identified above, it is important to note the benefits gained through the direct
application of 2,4-D to aquatic bodies, for the control of invasive species. The U.S Army Corps of


                                       Page 74 of 304

-------
Engineers (USAGE), among others, has identified 2,4-D as an important tool for protecting the
nation's waters from the invasion and establishment of some of the world's worst species of exotic
nuisance vegetation.  2,4-D has a reputation as a selective and economical means to remove invasive
plants, enhance the growth and recovery of desirable native vegetation, restore water quality, reduce
sedimentation rates in reservoirs, and improve fish and wildlife habitat. 2,4-D products are used to
control invasive weeds, such as Eurasian watermilfoil (Myriophyllum spicatum) in the northern tier
states and water hyacinth (Eichhornia crassipes) in the Gulf Coast states. Effective control of these
plants can benefit public health with respect to reducing levels of mosquito habitat. In addition,
according to USAGE, no other product (or alternative technique) can control these plants in a more
cost-effective manner (K. Getsinger, USAGE, Public Comment; Docket ID# OPP-2004-0167-0053).

                b.  Characterization of risk to mammals from terrestrial use

     All of the calculated RQs for mammalian acute risk for the non-granular use of 2,4-D were
based on maximum labeled application rates. The QUA from BEAD (Quantitative Usage Analysis
for 2,4-D, Case Number: 0073, Date:  8-9-01, A. Halvorson) suggests that the average application
rates for many  crops are considerably less than the modeled maximum application rates. For non-
granular spray  application mammalian acute concerns, the highest RQ was 1.72 for use on asparagus
for small mammals feeding on short grass based on a maximum application rate of 4 Ibs ae/acre;
however, the average application rate was only 1.10 Ibs ae/acre (BEAD QUA). If the modeled
application rate was reduced to the reported average application rate of 1.10 Ibs ae/acre for asparagus,
the RQ would be 1.08 which is still above the acute LOG of 0.5.  However, asparagus is
representative of a minor 2,4-D use, and risk to mammals from use of 2,4-D  on asparagus would be
minimal, given that fact.
     To add context to the acute mammalian assessment, the effect of assuming an average
application rate was determined. Major 2,4-D crops include pasture/rangeland, turf, wheat, corn, and
soybeans.  For pasture/rangeland, the highest acute RQ was 0.86 for small mammals feeding on short
grass based on a maximum application rate of 4 Ibs ae/acre.  However, the average application rate
was only 0.62 Ibs ae/acre (BEAD QUA).  If the modeled application rate was reduced to 0.62 Ibs
ae/acre for pasture/rangeland, the resulting RQ is 0.31 which is below the acute LOG, but above the
restricted use LOG of 0.2. Similar trends are noted for other major use sites.
     Calculated  chronic risks to mammals were greatest for small herbivores/insectivores. For 15 g
mammalian herbivores/insectivores, chronic RQs based on maximum residues and mean residues
ranged from <1 to 200 and <1 to 70, respectively. For major use  sites, including rangeland/pasture,
RQs were approximately 100.  These chronic risk estimates are likely conservative as described
below.

Exposure
     The chronic RQs calculated for mammalian herbivores/insectivores are based on conservative
estimates of exposure that are not likely to occur in nature. In the example of pasture/rangeland, the
chronic RQ of approximately 100 for maximum residues (35 for mean residues) was calculated based
on an application rate of 4 Ibs ae/A. This maximum application rate was  determined based on the
knowledge that the maximum rate of 2 Ibs ae/A may be applied twice per year, at a 30 day interval.
However, the Biological and Economic Analysis Division within OPP has determined that the
average application rate on pasture/rangeland is only 0.62 Ibs ae/acre (BEAD QUA).  Moreover,
information from several state contacts indicate that a once per year application of less than 1 Ib ae/A


                                      Page 75 of 304

-------
is typical (personal communications). As the typical rate is approximately 25% of the assessed rate,
use of the typical rate would be expected to decrease the RQ for the pasture/rangeland scenario to
approximately 25 for maximum residues and 9 for mean residues.

     A second example of the conservative assumptions included in the assessment of exposure to
mammalian herbivores/insectivores is the assumption that 100% of the long term diet is limited to
single food types foraged only from treated fields. The assumption of 100% diet from a single food
type may be realistic for acute exposures, but diets are likely to be more variable over longer periods
of time. Moreover, currently Agency models do not account for the uptake of 2,4-D by plants and
therefore assume that all non-dissipated pesticide applied to the field is present for exposure to
organisms.  In fact, many pesticides, including 2,4-D, are systemic and are absorbed by  plants in the
field so that the current approach may overestimate the amount of 2,4-D available for exposure in
terrestrial systems.  Therefore, the percent of diet assumption is likely to be conservative and will tend
to overestimate potential risks for chronic exposure, especially for larger organisms that have larger
home ranges.

Hazard
     The mammalian chronic risk assessment utilized a toxicity endpoint from a rat two-generation
reproduction test.  This endpoint was the NO AEL of 5 mg/kg-bw/day for growth rate reductions in
Fib offspring. The agency considers that reduced growth (reductions in pup body weight gains
relative to controls) in offspring as a potentially important effect with implications for the
survivability of offspring and therefore a potential impact on fecundity.  Because the endpoint is the
no effect level for this  measured parameter, evaluations of the significance of any exposures above
this endpoint were conducted. From the same two-generation rat reproduction study, the LO AEL
associated with Fib pup growth rate reduction was 20 mg/kg-bw/day. This LOAEL corresponds
with body-weight gain reductions  of 15 to 17 % (males and females) relative to controls. The 20
mg/kg-bw/day dose level also represents a NO AEL for increased gestational length and  incidents of
skeletal anomalies and reduced ossification in Fib pups.  The LOAEL for these gestational  and
skeletal effects is 80 mg/kg-bw/day.

     In addition to the available rat two generation reproduction study, a number of developmental
toxicity studies are available in rats and rabbits for the acid, amine salts  and esters.  These data are
from studies involving short-term exposures during critical  periods of fetal development and are
useful to determine if long-term or short-term exposure events are necessary for the types of effects
observed in the two-generation reproduction study. MRID  41747601, developmental toxicity in
rabbits with the acid, shows a NO AEL of 30 mg/kg-bw/day for increased rate of fetal abortions, with
a LOAEL 90 mg/kg-day. Similar NO AEL and LOAEL thresholds were observed in studies in
rabbits with the amine salts and esters of 2,4-D. MRID 000251031, developmental toxicity in rats
with the acid, showed a NO AEL of 25 mg/kg-bw/day and a LOAEL of 75 mg/kg-bw/day for
increased incidence of skeletal malformations.  Similar results are reported in other studies with rats
involving the amine salt and esters of 2,4-D.

               c. Characterization of risk to birds from terrestrial use

     The assessment of risk to birds from exposure to 2,4-D is likely conservative as follows.
Currently, Agency models do  not account for the uptake  of 2,4-D by plants and therefore assume that


                                      Page 76 of 304

-------
all non-dissipated pesticide applied to the field is present for exposure to organisms.  In fact, many
pesticides, including 2,4-D, are systemic and are absorbed by plants in the field and therefore, the
current approach may overestimate the amount of 2,4-D available for exposure in terrestrial and
aquatic systems.
     For non-granular spray application, the highest acute avian RQ (3.50) was from the cranberry
scenario, for birds feeding on short grass. That assessment was based on a maximum application rate
of 4 Ibs ae/acre; however, the average application rate is 1.83 Ibs ae/acre (see the BEAD QUA). If the
modeled application rate was reduced to 1.83 Ibs ae/acre for cranberries, and an assumption made that
the resulting EEC will be reduced linearly, the RQ would be 1.60.
     To determine the hazard associated with acute exposures to birds, the assessment has
considered two types of data, a suite of dietary studies and  a suite of gavage studies. For avian acute
exposures, the dietary studies result in non-definitive endpoints which are not appropriate for
estimating risk. Therefore, the assessment has relied on the gavage studies to estimate avian acute
risks.  The Agency recognizes that this approach may overestimate risk to birds due to the fact that
birds would not typically be expected to consume 2,4-D in this manner.
     Given the conservative assumptions in both exposure scenarios and hazard determinations, the
Agency finds that the acute risk to birds from 2,4-D exposure does not exceed the Agency's level of
concern.
     Potential chronic risks to birds is limited to a few  use sites. These include non-cropland, forest,
asparagus, and cranberry.  The RQs for these sites range from 1 -1.09.  Further characterization of
these use sites by evaluating average application rates versus maximum application rates lower these
RQs to below the LOCs.

                d.  Characterization of risk to non-target plants from terrestrial use

     Acute LOCs for both non-endangered and endangered terrestrial plants were  exceeded for non-
granular and granular uses at many use sites.  Consideration of average application rates did not result
in exposure below LOCs.  However, the exposure estimates used to develop the RQs were likely
conservative, as follows.
     In the exposure calculation for non-target plants, the major contributor is run-off from the
application site. The runoff and leaching vulnerability schemes used in this assessment were adapted
from a vulnerability scheme developed by the USDA (Kellogg et al, 1998), and incorporate several
conservative assumptions. For example, a 1-in-10 year rain event  is modeled, resulting in 3 cm of
runoff water.  USDA identified several caveats to be considered when using this vulnerability scheme
which could contribute to the uncertainty associated with this assessment. Among  these are that
estimates of runoff and leaching vulnerability are estimated through the use of algorithms (i.e. they
represent estimates of vulnerability and not actual field  measurements), fate and transport processes
(i.e. dilution and recharge) are not included, farm management practices are not considered, and some
watershed estimates are based on major crops only.  The effect of these factors on the vulnerability
assessment is unknown, however, there is a low probability that a l-in-10 year rain event will
coincide with the first few days following a 2,4-D application at the maximum application rate. Also,
it is likely that farm management practices would be in  place to limit run-off, as run-off events are
detrimental to the farm as a whole for reasons other than pesticide  damage.
     Currently Agency models do not account for the uptake of 2,4-D by plants and therefore
assume that all non-dissipated pesticide applied to the field is present for  exposure to organisms. In
fact, many pesticides, including 2,4-D, are systemic and are absorbed by plants in the field and


                                      Page 77 of 304

-------
therefore, the current approach may overestimate the amount of 2,4-D available for exposure in
terrestrial and aquatic systems.
                                      Page 78 of  304

-------
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 to support reregistration of products containing 2,4-D as
an active ingredient. The Agency has completed its review of these generic data, and has determined
that the data are sufficient to support reregistration of all products containing 2,4-D .

     The Agency has completed its assessment of the dietary, occupational,  residential, and
ecological risk associated with the use of pesticide products containing the active ingredient 2,4-D .
Based on a review of these data and on public comments on the Agency's assessments for the active
ingredient 2,4-D , the Agency has sufficient information on the human health and ecological effects
of 2,4-D 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-D
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 implement these measures. Label changes are described in
Section V. Appendix A summarizes the uses of 2,4-D 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-D, 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-D, the Agency has determined that 2,4-D 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-D . If all
changes outlined in this document are incorporated into the product labels, then all current risks for
2,4-D will be adequately mitigated for the purposes of this determination.

     B.  Public Comments and Responses

     Through the Agency's public participation process, EPA worked extensively with stakeholders
and the public to reach the regulatory decisions for 2,4-D . During the public comment period on the
revised risk assessments, which closed on March 14, 2005, the Agency received comments from
numerous parties. These comments in their entirety are available in the public docket (OPP-2004-
0167) at http: //www. epa.gov/edockets. Individual responses to these comments are also available in
the public docket (OPP-2004-0167).

     The RED and technical supporting documents for 2,4-D are available to the public through
EPA's  electronic public docket and comment system, EPA Dockets, under docket identification
number OPP-2004-0167.  The public may access EPA Dockets at http://www.epa.gov/edockets. In


                                       Page 79 of 304

-------
addition, the 2,4-D RED may be downloaded or viewed through the Agency's website at
http: //www. epa. gov/pesticides/reregistration/status. htm.

     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
this pesticide. EPA has determined that risk from dietary (food sources only) exposure to 2,4-D is
within its own "risk cup." An aggregate assessment was conducted for exposures through food,
drinking water, and residential uses. The Agency has determined that the aggregate human health
risks from these combined exposures are within the risk cup. In other words, EPA has concluded that
the tolerances for 2,4-D meet FQPA safety standards. 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, water, and residential uses.

              b. Determination of Safety to U.S. Population

     The Agency has determined that the established tolerances for 2,4-D , 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 FFDCA, and that there is a reasonable certainty no harm will result to the
general population or any subgroup from the use of 2,4-D. 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-D . Both the acute dietary (food alone) and chronic dietary risk from
2,4-D are not of concern.

     Acute and chronic risks from drinking water exposures are not of concern.  Models have been
used to estimate surface water concentrations. The  surface water EECs are below the DWLOCs for
all population subgroups.  Drinking water monitoring data from the USGS NAWQA Program
confirm that concentrations of 2,4-D are less than modeled estimates for surface water.  The
maximum concentration detected in ground water monitoring (from USGS NAWQA) has been used
as the ground water EEC. The ground water EEC is below the DWLOCs for all populations
subgroups.

     EPA has determined that the established tolerances for 2,4-D, 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 safety determination for infants and children considers the factors  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-D residues in this population subgroup. FQPA directs EPA, in setting
pesticide tolerances, to use an additional tenfold margin of safety to protect infants and children,
taking into account the potential for pre- and postnatal toxicity and the completeness of the toxicology
and exposure databases. The statute authorizes EPA to replace this tenfold FQPA safety  factor with a


                                      Page 80 of 304

-------
different FQPA factor only if reliable data demonstrate that the resulting level of exposure would be
safe for infants and children.

FQPA Special Safety Factor

     EPA concludes that the toxicology database for 2,4-D is substantially complete since all
required studies have been submitted. After evaluating hazard and exposure data for 2,4-D, EPA
removed the default 10X FQPA special safety factor. The toxicity database for 2,4-D includes
acceptable developmental and reproductive toxicity studies. Developmental toxicity studies were
conducted in both rats and rabbits for most 2,4-D forms. There is qualitative evidence of
susceptibility in the rat developmental toxicity study with 2,4-D acid and DEA salt where fetal effects
(skeletal abnormalities) were observed at a dose level that produced less severe maternal toxicity
(decreased body-weight gain and food consumption). There is no evidence of increased (quantitative
or qualitative) susceptibility in the prenatal developmental toxicity study  in rabbits or in the 2-
generation reproduction study in rats on 2,4-D. Regarding the 2,4-D amine salt and ester forms, no
evidence of increased susceptibility (quantitative or qualitative) was observed in the prenatal
developmental toxicity study in rat and rabbits (except for 2,4-D DEA) dosed with any of the amine
salts or esters of 2,4-D. There is evidence of increased susceptibility (qualitative) in the prenatal
developmental study in rabbits for 2,4-D DEA salt.
     After establishing developmental toxicity endpoints to be used in the risk assessment with
traditional uncertainty factors (lOx for interspecies variability and lOx for intraspecies variability), the
Agency has no residual concerns for the effects seen in the developmental toxicity studies. Therefore,
the 10X FQPA special safety factor was reduced to IX.

Database  Uncertainty Factor

     The  EPA has concluded that there is a concern for developmental neurotoxicity resulting from
exposure to 2,4-D, and that a developmental neurotoxicity (DNT) study in rats is required for 2,4-D.
The Agency has also concluded that a 2-generation reproduction study is required to address both the
concern for thyroid effects and immunotoxicity, as well as a more thorough assessment of the gonads
and reproductive/developmental endpoints.  EPA has determined that a 10X database uncertainly
factor (UFDB) is needed to account for the lack of these studies. This Uncertainty Factor is applied
only to exposure scenarios that are expected for children or pregnant women, and thus is not applied
to occupational exposure scenarios.

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

              3. Cumulative Risks
                                       Page 81 of 304

-------
     The Food Quality Protection Act (FQPA) requires EPA to consider "available information"
concerning the cumulative effects of a particular pesticide's residues and "other substances that have a
common mechanism of toxicity" when considering whether to establish, modify, or revoke a
tolerance. Potential cumulative effects of chemicals with a common mechanism of toxicity are
considered because low-level exposures to multiple chemicals causing a common toxic effect by a
common mechanism could lead to the same adverse health effect as would a higher level of exposure
to any one of these individual chemicals. 2,4-D is a member of the alkylphenoxy herbicide class of
pesticides. A cumulative risk assessment has not been performed as part of this human health risk
assessment because the Agency has not yet made a determination of whether 2,4-D and other
alkylphenoxy compounds have a common mechanism of toxicity. 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 by the 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: //epa. gov/pesticides/cumulative/. 1

              4.  Special Review Disposition

     2,4-D has been in pre-Special Review status since September 22, 1986, because of
carcinogenicity concerns. In 1994 a Science Advisory Panel/Scientific Advisory Board classified
2,4-D as a Group D carcinogen (not classifiable to human carcinogenicity).  The Agency requested
further histopathological examinations of rat brain tissues and mouse spleen tissues in question.
These exams were submitted and reviewed, and on March 16,  1999, The Agency notified the 2,4-D
Task Force that the Agency would continue to classify 2,4-D as a Group D carcinogen. Also, in a
1994 review of all relevant epidemiological studies, EPA found that none of the more recent
epidemiological studies definitively linked human cancer cases to 2,4-D. A final notice of the
Agency's intent not to  initiate Special Review will be published in concert with the release of this
RED document.

              5.  Dioxin Contaminants

Exposure
     In 1987, a DCI titled "Data Call-In Notice for Product Chemistry Relating to Potential
Formation of Halogenated Dibenzo-p-dioxin  or Dibenzofuran Contaminants in Certain Active
Ingredients," was issued to  identify pesticides that may contain halogenated dibenzo-p-dioxin and
dibenzofuran contaminants. A second DCI in 1987, "Data Call-In for Analytical Chemistry Data on
Polyhalogenated Dibenzo-p-Dioxins/Dibenzofurans (HDDs and HDFs)," was issued, under which
registrants whose products did not qualify for an exemption or waiver were required to generate and
submit analytical methods and certification limits of dioxins and furans.
     The specific results of analysis of multiple 2,4-D technical products, submitted to EPA  in
response to both DCIs, are considered confidential business information (CBI) and cannot be released
by EPA to the public. In summary, two of eight technical products had concentrations of 2,3,7,8-
tetrachlorodibenzo-p-dioxin (TCDD; dioxin)  greater than the limit of quantitation (LOQ; LOQ = 0.1
ppb) and three of eight had concentrations of 1,2,3,7,8-pentachlorodibenzo-p-dioxin (PCDD) greater
than the LOQ (LOQ = 0.5 ppb).
     In 1991, the EPA's Office of Research and Development (EPA/ORD) began an assessment of


                                      Page 82 of 304

-------
the health risks of exposure to dioxins. The most recent revision of that assessment has recently been
submitted to the National Academies of Science (NAS) for review.  In that document and elsewhere,
a source inventory of dioxin was published.  As a result of the 1987 DCI data, and the amount of 2,4-
D applied to agricultural and residential settings (approximately 50 million pounds per year), the
current draft dioxin source inventory (see The Inventory of Sources and Environmental  Releases of
Dioxin-Like Compounds in the United States: The Year 2000 Update. EPA/600/P-03/002A, External
Review Draft, March 2005) identifies 2,4-D as a source of dioxin emissions (28.9 g TEQDF-
WHO98; TEQ = Toxic EQuivalent amount, or an amount of total dioxin equivalent to 28.9 g of the
most toxic dioxin congener, 2,3,7,8-TCDD). It should be noted that this estimate of dioxin release
assumes all products are contaminated and does not take into account manufacturing changes since
the DCI.  Moreover, that estimate is specific for the year 1995,  and therefore should not be considered
the current estimate of dioxin release.
     The 1995 estimate for dioxin emissions from 2,4-D, taken together with NAS estimates for
2002/2004 releases from other sources of dioxin in the U.S., suggest that 2,4-D applications to land
ranks seventh (2.6% of all  dioxin sources) behind backyard burning (57%), sewage sludge application
(6.9%), residential wood burning (5.7%), coal-fired utilities (5.4%), diesel trucks (3.2%), and
secondary aluminum smelting (2.6%) in terms of dioxin emissions (see The Inventory of Sources and
Environmental Releases of Dioxin-Like Compounds in the United States: The Year 2000 Update,
EPA/600/P-03/002A, External Review Draft, March 2005).  According to 2,4-D registrants, since the
1990's, the manufacturing  processes for 2,4-D and its chemical intermediate, dichlorophenol, have
been modified, and those modifications decrease the chance that TCDD and PCDD are  formed during
the manufacturing process. The following description of the current 2,4-D manufacturing process
summarizes information submitted by the 2,4-D Task Force II.
     A key chemical intermediate in the manufacture of 2,4-D is 2,4-dichlorophenol (2,4-DCP) and
the purity of this intermediate has a strong correlation to the purity of 2,4-D acid produced from it.  In
the manufacture of 2,4-DCP, multiple positions around the phenyl ring structure may be chlorinated.
The desired positions for chlorination are carbons two and four of the phenyl ring, but the reaction
may yield small quantities  of compounds chlorinated at different positions. Certain combinations of
these chlorinated structures may form precursors to the dioxin 2,3,7,8-TCDD.
     Manufacture of the 2,4-DCP intermediate has been optimized by controlling processing
conditions necessary to drive the chlorination reaction to the preferred two and four carbon positions,
thereby limiting the formation of impurities that can lead to dioxin formation. Controlled temperature
and residence time during the chlorination reaction, programmed addition of the chlorinating agent,
and efficient agitation in the reaction vessel are processing factors that contribute to the  purity of 2,4-
DCP. Additionally, distillation of 2,4-DCP is a technique that may be employed post-chlorination  to
increase purity. Moreover, quality control sampling and analytical procedures are also utilized to
verify product quality at various steps of the 2,4-DCP process.  According to Results of testing of
2,4-DCP, performed in response to the Toxic Substances Control Act (TSCA) Dioxin/Furan Test
Rule, showed no detectable concentrations of 2,3,7,8-substituted tetra- through hepta-CDD/CDFs.
     In the manufacture of 2,4-D acid per se, there are additional process  conditions and procedures
that must be controlled to maximize yield and purity. Details regarding these measures are dependent
on specific manufacturing methodologies and, as such, are protected under FIFRA Section 10 as
Confidential Business Information.

Anticipated Residues
                                      Page 83 of 304

-------
       The Agency's most recent evaluations of anticipated dioxin and furan residues resulting from
2,4-D applications are based on the concentrations of dioxins and furans present in technical grade
2,4-D as determined by review of analytical data submitted in response to the 1987 DCI. In those
evaluations, completed in the early 1990's, the ratios of individual chlorodibenzo-p-dioxin (CDD;
dioxin) or chlorodibenzo-p-furan (CDF; furan) contaminant concentrations to 2,4-D acid
concentrations were calculated, and those ratios were used with 2,4-D tolerance expressions to
calculate an anticipated residue in eggs, fruits, grains, kidney (hogs), meat (hogs), milk, nuts, poultry,
and sugarcane, for each detected dioxin or furan.  For each technical 2,4-D formulation for which the
Agency received data, calculation of an anticipated dietary exposure was based on a worst-case
scenario in which the highest anticipated residue was used, and an assumption was made that 100%
of the diet consisted of the food item with the highest anticipated residue.

Toxicological Significance
       Based on the calculation of dietary exposures, using the worst-case scenario described above,
both the cancer and non-cancer risks from dietary exposure to dioxins and furans as contaminants of
2,4-D acid were considered to be of no toxicological concern at the time of the assessment.

Risk Management
     Members of the 2,4-D Task Force n have submitted information about the current
manufacturing process for the 2,4-D intermediate, 2,4-DCP, as well as for 2,4-D acid itself, and have
included in their submissions explanatory text on how current manufacturing processes minimize the
chance of dioxin and furan formation.  To confirm that the changes to the manufacturing processes
since the time of the 1987 DCI have resulted in lower concentrations of dioxin congeners in technical
2,4-D products, the Agency is requiring that five recent batches of all technical products be analyzed
for 2,3,7,8-TCDD, 2,3,7,8-TCDF and their respective higher substituted chlorinated congeners  using
validated analytical methods.  The Agency is  specifying that the manufacturers use the most current
state-of-the art laboratory methods for measuring 2,3,7,8-TCDD and TCDF at levels less than 1 part
per trillion (EPA Method 1613, Tetra- through Octa-Chlorinated Dioxins and Furans by Isotope
Dilution HRGC/HRMS). Because 1,2,3,7,8-PeCDD is equi-potent to 2,3,7,8-TCDD in the TEF
scheme, the Agency is adding this compound to our testing requirements. The pentachloro-congener
was reported as present in 2,4-D in the 1987 Data Call-in.  Registrants are encouraged to submit their
analytical  methods and sampling  plans to the Agency for review prior to commencing these studies.

     D. Tolerance Reassessment Summary

           1. Tolerances Currently Listed Under 40 CFR §180.142

     Tolerances for residues of 2,4-D in/on plant RACs and processed commodities, fish, and
potable water are currently expressed in terms of 2,4-D per se  [40 CFR §180.142(a)(l-6 and 9-12)
and (b)]. Tolerances for residues  in livestock commodities are currently  expressed in terms of 2,4-D
and/or its metabolite 2,4-dichlorophenol (2,4-DCP) [40 CFR §180.142(a)(8)].  EPA has concluded
that 2,4-D is the residue of concern and that tolerances listed in 40 CFR § 180.142 are to be defined as
residues of 2,4-D, both free and conjugated, determined as the acid.

     The  listing for 2,4-D tolerances in 40 CFR §180.142 should be recodified into parts (a), (b), (c),
and (d).  Part (a) should be reserved for commodities with permanent tolerances reflecting at least a


                                      Page 84 of 304

-------
preharvest (field) or postharvest use, part (b) for Section 18 emergency exemptions, part (c) for
tolerances with regional use registrations, and part (d) for commodities bearing 2,4-D residues solely
inadvertently, including irrigated crops.  A summary of 2,4-D tolerance reassessments and
recommended recodifications is presented in Table 37 along with any recommended changes in
commodity definitions.

     Note that some commodities currently are the subject of two or more separate tolerances
depending on the use pattern, the 2,4-D form applied, timing of treatment (preharvest or postharvest),
or degree of intent to deposit residues (direct treatment or inadvertent). Direct treatment involves
intentional field treatment of crop sites or postharvest treatment of harvested commodities on
registered labels. Inadvertent deposition involves the incidental exposure of crops when water
passing through 2,4-D-treated irrigation ditchbanks or diverted from 2,4-D-treated bodies of water is
used to irrigate crops.  EPA is proposing to remove most such use-pattern or FIFRA-related language
at 180.142. Due to the complicated nature of the routes of residue deposition, we are proposing to
subsume the lower tolerances in the highest existing  or reassessed tolerance established in the same
commodity - even if that results in 180.142(a) containing some tolerances that reflect 2,4-D residues
that could potentially result from two or more exposure routes.  An example is citrus which has
tolerances for 2,4-D in the RAC resulting from preharvest use + postharvest use, irrigation ditchbank
treatment (inadvertent), and direct water body treatment (also inadvertent).  If there are no registered
uses on a given commodity and residues are likely to occur on that commodity solely inadvertently,
i.e., via irrigation, then the tolerance in that commodity will be located under 180.142(d). In most
cases, residues, and hence the tolerance, resulting from a direct, registered use are higher than the
residues (and the tolerance) resulting inadvertently. EPA proposes these revisions because we know
that an enforcement agency, having detected 2,4-D residues  in a commodity, would: (i) not be able to
distinguish which form of 2,4-D had been applied; (ii) rarely be able to determine who applied the
pesticide, when, or for what purpose; and (iii) not know whether a sample is violative if the 2,4-D
concentration falls between two tolerance levels.

Tolerances Listed Under 40 CFR §180.142(a)(l):
     Adequate data are available to reassess the established tolerances for the following
commodities:  apple, apricot,  citrus fruit, pear, potato and quince.
     The available apple and pear residue data will support a crop group tolerance at 0.05 ppm for
pome fruits under the redesignated section 180.142(a).  The  separate tolerances on apple, pear, and
quince should be revoked concomitant with establishing a new pome fruit crop group tolerance.
     The 5 ppm tolerance on citrus fruits should be reassessed to 3.0 ppm to reflect any combination
of the preharvest use on citrus, the postharvest use of 2,4-D on lemons in the U.S., a similar
postharvest use on oranges  imported into the U.S., and any inadvertent (irrigation) residues that may
be incurred as a result of 2,4-D use in aquatic sites. The tolerances in citrus fruit of 0.1 ppm at
180.142(a)(3) and 1.0 ppm at 180.142(a)(6), both reflecting inadvertent residues, should be revoked
as they will be subsumed by the reassessed tolerance of 3.0 ppm at 180.142(a).
     The tolerance for residues in/on apricots should be revoked as residues in/on apricots will be
covered by the tolerance in stone fruits.

Tolerances Listed Under 40 CFR $180.142(a¥2):


                                       Page 85 of 304

-------
     Adequate data are available to reassess all the tolerances listed under 180.142(a)(2).  All
reassessed tolerances should be recodified under the revised section 180.142(a).
     Based on the available residue data, the current tolerances on grass hay and tree nuts are
adequate.  However, tolerances can be lowered on the following commodities:  blueberry, sweet corn
(kernel plus cob with husks removed), corn forage and grain, cranberry, stone fruits, grape, grass
forage, pistachio, rice straw, sorghum forage, grain and stover, and sugarcane. Tolerances should be
increased  on the following commodities:  corn stover, rice grain, and wheat grain and forage.
     The available residue data for wheat commodities will be used to reassess tolerances on similar
commodities from barley, millet, oats, and rye.  Tolerances should be increased accordingly on:
barley grain; millet grain, forage and straw; oat forage and grain; and rye forage and grain.
     The tolerance for residues in  sugarcane forage should be revoked because it is no longer
considered a significant livestock feed item (OPPTS GLN 860.1000).

Tolerances Listed Under 40 CFR §180.142(a)(3):
     Tolerances listed in 40 CFR §180.142(a)(3) are established for negligible residues of 2,4-D in
irrigated crops from application of its dimethylamine salt to irrigation ditch banks in the Western
United States in programs of the Bureau of Reclamation, U.S. Department of Interior; cooperating
water user organizations; the Bureau of Sport Fisheries, U.S.  Department of Interior; Agricultural
Research Service, U.S. Department of Agriculture; and the Corps of Engineers, U.S. Department of
Defense.  Where tolerances are established at higher levels resulting from other uses of 2,4-D, the
higher tolerance applies also to residues in crops from the irrigation ditch bank use cited in this
paragraph.
     The tolerances in crops or crop groups listed under 40 CFR §180.142(a)(3) that do not have a
direct treatment tolerance under 180.142(a) should be recodified as 180.142(d), i.e., inadvertent
residue tolerances.
     The available irrigated crop data support tolerances for  inadvertent residues at 0.2  ppm in
foliage of legume vegetables (group 7) and non-grass animal feed (group 18) and at 0.05 ppm in/on
the following crops groups:  bulb vegetables (group 3),  legume vegetables (group 6), cucurbit
vegetables (group 9), and fruiting vegetables (group 8).
     In addition, tolerances resulting from the primary  use of 2,4-D on grasses, citrus fruits, and tree
nuts are high enough to cover any inadvertent residues in these crops that may result from the use of
2,4-D treated irrigation water.  Therefore, separate tolerances for inadvertent residues in/on these
crops are not required.
     Separate tolerances for inadvertent residues are unnecessary in pome fruits, stone fruits,
pistachios, grapes, blueberry, and strawberry as these crops all have tolerances resulting from the
direct use of 2,4-D. However, the tolerances in  all of these commodities have been reassessed at 0.05
ppm, the limit of quantitation of the enforcement method, to reflect only direct treatment at this time.
It is reasonably possible that inadvertent residues resulting from irrigation with treated water could
contribute concentrations of 2,4-D  in the commodities necessitating tolerances higher than 0.05 ppm.
Therefore, confirmatory irrigated crop residue data are required for a representative perennial crop
(strawberry). Also, additional residue data on sugar beets and tops irrigated with water containing
2,4-D at 0.1 ppm are required to permit reassessment of the tolerances in the Root and Tuber
Vegetables Group and the Leaves of Root and Tuber Vegetables Group resulting inadvertently due to
                                       Page 86 of 304

-------
irrigation with 2,4-D-treated water. These data may also be used to reassess inadvertent tolerances
established at 180.142(d) as a result of the 2,4-D RED.

Tolerance Listed Under 40 CFR § 180.142(a¥4):
     The established tolerance for residues in/on asparagus is reassessed at the current level under
the revised tolerance expression and is to be recodified as 40 CFR §180.142(a).

Tolerance Listed Under 40 CFR §180.142(a>(5)
     The established tolerance for residues in/on strawberry is reassessed at the current level under
the revised tolerance expression and is to be recodified as 40 CFR §180.142(a).

Tolerances Listed Under 40 CFR $180.142(a¥6):
     Tolerances listed in 40 CFR §180.142(a)(6) are established for residues of 2,4-D from
application of its dimethylamine salt for water hyacinth control in ponds, lakes, reservoirs, marshes,
bayous, drainage ditches, canals, rivers, and streams that are quiescent or slow moving in programs
conducted by the Army Corps of Engineers or other Federal, State, or local public agencies. Where
tolerances are established at higher levels from other uses of the dimethylamine salt of 2,4-D on crops
included within these commodity groups, the higher tolerances also apply to residues from the aquatic
uses cited in this paragraph.
     Based on the available residue data, the current tolerance in shellfish is adequate and the
tolerance in fish can be reduced to 0.1 ppm.  Both tolerances should be recodified under the revised
section 180.142(a).
     Tolerances for residues in/on the irrigated crops and crop groups at the current §180.142(a)(6)
are set at 1.0 ppm whereas the tolerances in/on the identical crops/crop groups at §180.142(a)(3) are
at 0.1 ppm for the irrigation ditchbank use. The recommended/reassessed tolerances from
§180.142(a)(3) to be recodified under sections §180.142(a) or §180.142(d) concomitantly address the
reassessments/recodifications  recommended for tolerances at §180.142(a)(6), depending on whether
residues are incurred directly and/or inadvertently, as explained above.

Tolerances Listed Under 40 CFR $180.142(a¥8V
     Tolerances listed in 40 CFR §180.142(a)(8) are established for residues of 2,4-D and/or its
metabolite 2,4-DCP in livestock commodities.  As indicated by the Agency, the regulated residue in
animal commodities is 2,4-D (free and conjugated). As a result of this residue definition change, all
reassessed livestock tolerances should be recodified to §180.142(a).
     Based upon the available livestock feeding study, the 0.1 ppm tolerance in milk is reassessed at
0.05 ppm and the tolerances in cattle, goat, horse, and sheep commodities are reassessed at:  0.3 ppm
in fat, meat, and meat byproducts except kidney and 4.0 ppm in kidney.
     The established tolerances for 2,4-D residues in hog commodities may be revoked. Based on
the MTDB for swine (1.6 ppm)  and the results  of the ruminant feeding study, there is no reasonable
expectation of finite 2,4-D residues occurring in hog commodities [Category 3 of 40 CFR
§180.6(a)(3)].
     In addition, the established tolerances for 2,4-D residues in eggs and poultry tissues may be
revoked. Based on the results of the 2,4-D poultry metabolism study, there is no reasonable
expectation of finite residues in poultry tissues and eggs [Category 3 of 40 CFR §180.6(a)(3)].
                                       Page 87 of 304

-------
Tolerance Listed Under 40 CFR §180.142(^(9):
     Tolerances listed in 40 CFR §180.142(a)(9) are established for residues of 2,4-D from
applications of its dimethylamine salt or its butoxyethanol ester for Eurasian water milfoil control in
programs conducted by the Tennessee Valley Authority in dams and reservoirs of the TVA system.
     The tolerance for 2,4-D residues in fish at 40 CFR §180.142(a)(9) should be revoked and this
section deleted. There is no need for two 2,4-D tolerances in fish.  It has already been recommended
that the  1.0 ppm tolerance in fish currently at §180.142(a)(6) be reassessed at 0.1 ppm and that this
reassessed tolerance be recodified at the new 40 CFR §180.142(a).

Tolerance Listed Under 40 CFR §180.142(a)(10V
     The tolerance listed in 40 CFR §180.142(a)(10) is a regional registration as defined in Sec.
180.1(n) and is established for the residues of 2,4-D in raspberries.  The tolerance includes residues
from the application of 2,4-D and its N-oleyl-l,3-propylenediamine salt.
     As the members of Task Force n are not supporting 2,4-D use on this commodity, the tolerance
for residues in/on raspberries should be revoked unless another party wishes to support a use on this
crop.  40 CFR §180.142(a)(10) should be deleted and any tolerances with regional use registration
should be established under the revised section 40 CFR §180.142(c).

Tolerance Listed Under 40 CFR §180.142(a)(l 1):
     A  time-limited tolerance of 0.02 ppm has been established for residues of 2,4-D resulting from
the preplant use of 2,4-D ester or amine in/on soybean seed  [40 CFR §180.142(a)(l 1)], expired on
December 31,  2004. Adequate residue data are available to support permanent tolerances on soybean
commodities.  Section 180.142(a)(l 1) should be deleted, and permanent tolerances for 2,4-D residues
in/on soybean  seed, forage, and hay are recommended to be established under the revised section
180.142(a).

Tolerances Listed Under 40 CFR $180.142(a¥12):
     Tolerances listed at 40 CFR §180.142(a)(12) are established for residues of 2,4-D in processed
feeds. Such residues may be present therein only as a result of application to the growing crop of the
herbicides identified in this section. Tolerances formerly listed at 40 CFR §180.1450 were moved to
40 CFR §180.142(a)(12) (63 FR 34829, 6/26/98).
     The tolerance for residues in sugarcane bagasse should be revoked because it is no longer
considered a significant livestock feed item and has been deleted from Table 1 (OPPTS GLN
860.1000).
     40 CFR  §180.142(a)(12) should be deleted.  The tolerance for 2,4-D residues in milled fractions
derived  from barley, oats, rye, and wheat should be revoked as the commodity definition will change
and the tolerances will be increased and recodified at the revised 40 CFR §180.142(a) for residues in
barley bran, rye bran, and wheat bran. No tolerances in other processed products of small grains are
necessary because concentration of residues does not occur in them.

Tolerances Listed Under 40 CFR §180.142(a)(13):
     Tolerances listed at CFR §180.142(a)(13) are established for residues of 2,4-D in processed
foods and potable water.
                                       Page 88 of 304

-------
     40 CFR §180.142(a)(13) should be deleted.  The tolerances for 2,4-D residues in sugarcane
molasses and in milled fractions derived from barley, oats, rye, and wheat should be revoked as
tolerances will be recodified under the revised 40 CFR §180.142(a) for residues in sugarcane
molasses, barley bran, rye bran, and wheat bran.
     The established tolerance for residues of 2,4-D in potable water should be revoked as
EPA/OPPTS/OPP no longer establishes pesticide tolerances in potable water.  Instead, the EPA
Office of Water establishes Maximum Contaminant Levels (MCLs).  An MCL of 0.07 ppm has been
established for 2,4-D in drinking water.

Tolerances Listed Under 40 CFR $180.142(¥):
     The tolerance listed in 40 CFR §180.142(b) is a time-limited tolerance established for 2,4-D
in/on wild rice in connection with use of 2,4-D in MN under a Section 18 emergency exemption
granted by EPA. The tolerance is set to expire on December 31, 2005.  As adequate residue data are
available on wild rice grown in MN, a permanent tolerance for rice, wild, grain should be established
at 0.05 ppm under 40 CFR §180.142(c).

              2.  Tolerances to Be Proposed Under 40 CFR §180.142

Tolerances Needed Under 40 CFR §180.142(a):
     The revised section will include all permanent tolerances for residues of 2,4-D, defined as
residues of 2,4-D, both free and conjugated, determined as the acid. The section will include all plant
commodities (excluding crop commodities exposed solely inadvertently), livestock commodities,
fish, and  shellfish at reassessed levels.
     In addition, the available residue data indicate that new tolerances should be established for 2,4-
D residues in/on the following commodities: almond hulls; aspirated grain fractions; barley bran and
straw; oat straw; rice hulls; rye bran and straw; soybean forage, hay, and seeds; and wheat bran and
straw.
     Once adequate residue data become available, new tolerances should also be established for
wheat hay.  Wheat hay data will be translated to barley hay, millet hay, and oat hay.

Tolerances Needed Under 40 CFR §180.142(c):
     Based on the available residue data, tolerances with regional use registrations should be
established for wild rice grain at 0.05 ppm, reflecting the use of 2,4-D on wild rice grown in MN.

Tolerances Needed Under 40 CFR §180.142(dV
     Tolerances for inadvertent 2,4-D residues in irrigated crops that have no registered, direct uses
will be moved from paragraph §180.142(a)(3) to paragraph §180.142(d) and the commodity and crop
group listings will be revised to the current EPA definitions.

Table 38.  Tolerance Reassessment Summary for 2,4-D.
Commodity
Tolerance Listed
Under 40 CFR
§180. 142 (ppm)
Reassessed
Tolerance (ppm)
Comment
[Corrected Commodity Definition]
Tolerances Listed Under 40 CFR §180.142 (a) (1) 2
                                      Page 89 of 304

-------
Commodity
Apple
Apricot
Fruit, citrus
Pear
Potato
Quince
Tolerance Listed
Under 40 CFR
§ 180.1 42 (ppm)
5
5
5
5
0.2
5
Reassessed
Tolerance (ppm)
Revoke
Revoke
3.0
Revoke
0.40
Revoke
Comment
[Corrected Commodity Definition]
A single tolerance should be established at 0.05
ppm under 180. 142(a) for direct and inadvertent
residues in/on the Fruit, pome, group 11.
Residues in/on apricots will be covered by the
tolerance for direct and inadvertent residues in stone
fruits at 180.1 42(a).
A tolerance should be established in Fruit, citrus,
group 10, recodified as 180.142(a), that will cover
the preharvest use on citrus, the postharvest use on
lemons in the U.S., the postharvest use on citrus
imported into the U.S., and the inadvertent residues
due to irrigation with treated water.
A single tolerance should be established at 0.05
ppm under 180. 142(a) for direct and inadvertent
residues in/on the Fruit, pome, group 11.
Includes direct and inadvertent (irrigation) residues.
Recodify as 180.142(a).
Residues in/on quince will be included under the
0.05 ppm tolerance at 180.142(a) for direct and
inadvertent residues in/on the Fruit, pome, group
11.
Tolerances Listed Under 40 CFR §180.142 (a) (2) 2
Barley, grain
Blueberry
Corn, fodder
Corn, forage
Corn, fresh, sweet,
kernel plus cob with
husks removed
Corn, grain
Cranberry
Fruit, stone
Grape
Grass, hay
0.5
0.1
20
20
0.5
0.5
0.5
0.2
0.5
300
2.0
Revoke
50.0
6.0
0.05
0.05
Revoke
0.05
0.05
300
The submitted data for wheat grain may be
translated to barley grain. Recodify as 180.142(a).
To be included under the 0.2 ppm Berries group 13
tolerance to be recodified as 1 80. 142(a).
Residue data from the 7-day PHI. Recodify as
180.142(a). Corn, stover
Residue data from the 7-day PHI. Recodify as
180,142(a),
Recodify as 180. 142(a).
Residue data from 7 -day PHI. Recodify as
180.142(a).
To be included under the 0.2 ppm Berries group 13
tolerance to be recodified as 1 80. 142(a).
Recodify as 180. 142(a). This tolerance will now
cover both direct and inadvertent residues. Fruit,
stone, group 12
Residue data on grape are available for the entire
U.S. Recodify as 1 80. 142(a).
Residue data from the 7-day posttreatment interval
(PTI) for Grass, hay. Recodify as 180.142(a).
Page 90 of 304

-------
Commodity
Grass, pasture
Grass, rangeland
Millet, forage
Millet, grain
Millet, straw
Nut
Oat, forage
Oat, grain
Pistachio
Rice
Rice, straw
Rye, forage
Rye, grain
Sorghum, fodder
Sorghum, forage
Sorghum, grain
Sugarcane
Sugarcane, forage
Tolerance Listed
Under 40 CFR
§ 180.1 42 (ppm)
1,000
1,000
20
0.5
20
0.2
20
0.5
0.2
0.1
20
20
0.5
20
20
0.5
2
20
Reassessed
Tolerance (ppm)
360
25
2.0
50
0.2
25
2.0
0.05
0.5
10
25
2.0
0.2
0.2
0.2
0.05
Revoke
Comment
[Corrected Commodity Definition]
Recodify as 180. 142(a). Residue data from the 0-
day PTI. This new tolerance will now cover both
direct and inadvertent residues. Grass, forage
The data for wheat forage, grain, and straw may be
translated to millet forage, grain, and straw. The
required wheat hay data will be translated to millet
hay. Recodify as 180. 142(a). This new tolerance
will now cover both direct and inadvertent residues.
Recodify as 180. 142(a). This new tolerance will
now cover both direct and inadvertent residues.
Nut, tree, group 14
The data for wheat forage may be translated to oat
forage. Recodify as 180. 142(a). This new tolerance
will now cover both direct and inadvertent residues.
The data for wheat grain may be translated to oat
grain. Recodify as 180. 142(a). This new tolerance
will now cover both direct and inadvertent residues.
Recodify as 180. 142(a). This new tolerance will
now cover both direct and inadvertent residues.
Recodify as 180. 142(a). This new tolerance will
now cover both direct and inadvertent residues.
Rice, grain
Recodify as 180. 142(a). This new tolerance will
now cover both direct and inadvertent residues.
Recodify as 180. 142(a). This new tolerance will
now cover both direct and inadvertent residues. The
data for wheat forage may be translated to rye
forage.
Recodify as 180. 142(a). This new tolerance will
now cover both direct and inadvertent residues. The
data for wheat grain may be translated to rye grain.
Recodify as 180. 142(a). This new tolerance will
now cover both direct and inadvertent residues.
Sorghum, stover
Recodify as 180. 142(a). This new tolerance will
now cover both direct and inadvertent residues.
Recodify as 180. 142(a). This new tolerance will
now cover both direct and inadvertent residues.
Recodify as 180.142(a). Sugarcane, cane
Sugarcane forage is no longer considered a
significant livestock feed item.
Page 91 of 304

-------
Commodity
Wheat, forage
Wheat, grain
Tolerance Listed
Under 40 CFR
§ 180.1 42 (ppm)
20
0.5
Reassessed
Tolerance (ppm)
25
2.0
Comment
[Corrected Commodity Definition]
Recodify as 180. 142(a). This new tolerance will
now cover both direct and inadvertent residues. The
14-day PHI residue data on wheat forage and grain
will be used to support tolerances for residues in/on
similar commodities of barley, millet, oats, and rye.
Tolerance Listed Under 40 CFR §180.142 (a)(3) 4
Avocado
Cottonseed
Cucurbits
Fruit, citrus
Fruit, pome
Fruit, stone
Grain, crop
Grass, forage
Hop
Leafy vegetables
Legume, forage
Nut
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.05
0.05
0.05
Revoke
Revoke
Revoke
Revoke
Revoke
0,2
0.4
Group 7 - 0.2
Group 18 -0.2
Revoke
Recodify as 180. 142(d).
Recodify as 180. 142(d). Cotton, iindelinted seed
Recodify as 180.142(d). Vegetable, cucurbit, group
9
Inadvertent residues will be covered by the crop
group tolerance on citrus fruit at 180. 142(a).
Inadvertent residues will be covered by the crop
group tolerance on pome fruit at 180.142(a).
Revocation of one strone fruit tolerance is
necessary to avoid duplication. Inadvertent residues
will be covered by the stone fruit group tolerance at
1 80. 1 42(a)(2) to be recodified as 1 80. 1 42(a).
Separate tolerances in RACs of each grain will be
individually established and recodified as
180. 142(a) in/on grain, forage, fodder, stover, or
hay, as applicable, to cover both direct and
inadvertent residues. Upon formal Agency
approval, a small grains subgroup tolerance may be
established.
Inadvertent residues will be covered by the grass
forage tolerance for direct residues to be recodified
as!80.142(a).
Inadvertent residues will be covered by the hop
tolerance for direct residues upon establishment at
180. 142(a) in response to PP#2E6352.
Establish separate tolerances for inadvertent
residues in the Vegetable, leafy, except brassica,
group 4 and Vegetable, brassica, leafy, group 5 at
0.4 ppm under the revised 1 80. 1 42(d)
Establish separate tolerances for the Vegetable,
foliage of legume, group 7 and Animal feed,
nongrass, group 18 for inadvertent residues under
180.142(d).
Inadvertent residues will be covered by the
tolerance in the tree nuts crop group at 180. 142(a)
Page 92 of 304

-------
Commodity
Root crop vegetables
Seed and pod
vegetables
Small fruit
Vegetable, fruiting
Tolerance Listed
Under 40 CFR
§ 180.1 42 (ppm)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
Reassessed
Tolerance (ppm)
Group 1 - TBD
Group 2 - TBD
Group 3 - 0.05
0.05
0.2
0.05
Comment
[Corrected Commodity Definition]
Additional data are required to determine
inadvertent residues in sugar beet roots and tops to
represent root and tuber vegetables. Establish
separate tolerances in the Vegetable, bulb, group 3.
When sugar beet data are received, establish
separate tolerances in the Vegetable, root and tuber,
group 1 and Vegetable, leaves of root and tuber,
group 2. Recodify as 180.142(a).
Establish tolerance for inadvertent residues at
180.142(d) in the Vegetable, legume, group 6.
The 0.2 ppm tolerance in the Berries group 13, to be
recodified at §180. 142(a), will also cover
inadvertent residues. Inadvertent residues in/on
blueberry and cranberry will also be covered by this
group tolerance. Inadvertent residues in/on grape
and strawberry will be covered by separate
tolerances for direct uses on these crops
§180.142(a).
Establish tolerance for inadvertent residues at 0.05
ppm in the Vegetable, fruiting, group 8 recodified
under §1 80. 142(d).
Tolerance Listed Under 40 CFR §180.142 (a)(4) 2
Asparagus
5
5.0
Recodify as §1 80. 142(a).
Tolerance Listed Under 40 CFR §180.142 (a)(5) 2
Strawberry
0.05
0.05
Recodify as § 1 80. 1 42(a). This tolerance will cover
direct and inadvertent residues.
Tolerance Listed Under 40 CFR §180.142 (a)(6) 2
Crops in paragraph
(c) of this section
Crop groupings in
paragraph (c) of this
section
Fish
Shellfish
1.0
1.0
1.0
1.0
Revoke
Revoke
0.10
1.0
The tolerances to be established under paragraphs
§ 1 80. 1 42(a) and § 1 80. 1 42(d) will be sufficient to
cover inadvertent residues in irrigated crops under
the recodified § 1 80. 1 42(a)(6).
The tolerances to be established under paragraphs
§ 1 80. 1 42(a) and § 1 80. 1 42(d) will be sufficient to
cover inadvertent residues in irrigated crops under
the recodified § 1 80. 1 42(a)(6).
Residue data for fish and shellfish are from recent
tests where fish and shellfish were exposed to 2,4-D
under static conditions at 6.0 ppm (1 ,5x). Recodify
to§180.142(a).
Tolerance Listed Under 40 CFR §180.142 (a)(8) 2
Cattle, fat
Cattle, kidney
Cattle, meat
0.2
2
0.2
0.3
4.0
0.3
Recodify as §1 80. 142(a).
Recodify as §1 80. 142(a).
Recodify as §180.1 42(a).
Page 93 of 304

-------
Commodity
Cattle, meat
byproducts, except
kidney
Egg
Goat, fat
Goat, kidney
Goat, meat
Goat, meat
byproducts, except
kidney
Hog, fat
Hog, kidney
Hog, meat
Hog, meat
byproducts, except
kidney
Horse, fat
Horse, kidney
Horse, meat
Horse, meat
byproducts, except
kidney
Milk
Poultry
Sheep, fat
Sheep, kidney
Sheep, meat
Sheep, meat
byproducts, except
kidney
Tolerance Listed
Under 40 CFR
§ 180.1 42 (ppm)
0.2
0.05
0.2
2
0.2
0.2
0.2
2
0.2
0.2
0.2
2
0.2
0.2
0.1
0.05
0.2
2
0.2
0.2
Reassessed
Tolerance (ppm)
0.3
Revoke
0.3
4.0
0.3
0.3
Revoke
0.3
4.0
0.3
0.3
0.05
Revoke
0.2
2.0
0.2
0.2
Comment
[Corrected Commodity Definition]
Recodify as §180.1 42(a).
Category 3 of 40 CFR §180.6(a)(3) applies.
Recodify as §1 80. 142(a).
Recodify as §1 80. 142(a).
Recodify as §180.1 42(a).
Recodify as §180.1 42(a).
Category 3 of 40 CFR §180.6(a)(3) applies.
Recodify as §180.1 42(a).
Recodify as §180.1 42(a).
Recodify as §180.1 42(a).
Recodify as §180.1 42(a).
Residues in milk increased linearly with dose;
therefore, the 0.05 ppm tolerance will be adequate
for the Ix dose level. Recodify as §180.142(a).
Category 3 of 40 CFR §180.6(a)(3) applies.
Recodify as §180.1 42(a).
Recodify as §1 80. 142(a).
Recodify as §180.1 42(a).
Recodify as §180.1 42(a).
Tolerance Listed Under 40 CFR §180.142 (a)(9) 2
Fish
1.0
Revoke
The reassessed tolerance of 0. 1 ppm at
§ 180. 142(a)(6) will be recodified as § 180. 142(a).
There is no need for duplication of tolerances.
Tolerance Listed Under 40 CFR §180.142 (a)(10) 2
Raspberry
1.0
Revoke
Although there is no indication that IR-4 or the Task
Force II is supporting a use on raspberries, it would
be covered by the 0.2 ppm tolerance in the Bemes
group!3at§180.142(a).
Page 94 of 304

-------
Commodity
Tolerance Listed
Under 40 CFR
§ 180.1 42 (ppm)
Reassessed
Tolerance (ppm)
Comment
[Corrected Commodity Definition]
Tolerance Listed Under 40 CFR §180.142 (a)(ll) 3
Soybean, seed
0.02
0.02
Tolerance expired on 12/31/04. Residue data
support a permanent tolerance. If established,
recodifyas§180.142(a).
Tolerance Listed Under 40 CFR §180.142 (a)(12) 2
Sugarcane bagasse
Sugarcane molasses
Milled fractions
denved from barley,
oats, rye, and wheat
to be ingested as
animal feed or
converted into animal
feed
5
5
2
Revoke
0.20
Revoke
Sugarcane bagasse is no longer considered a
significant livestock feed item.
Maximum residue value is based on HAFT residues
of 0.015 ppm in/on sugarcane and a 7x
concentration factor for molasses. Recodify as
§180.142(a). Sugarcane, molasses
Tolerances for direct and inadvertent residues of
2,4-D in barley, bran; rye, bran; and wheat, bran are
to be established under revised 40 CFR 1 80. 1 42(a).
Tolerances in other small grain processed products
are not necessary as residues do not concentrate
upon processing.
Tolerance Listed Under 40 CFR §180.142 (a)(13) 2
Sugarcane molasses
Milled fractions
derived from barley,
oats, rye, and wheat
to be ingested as
animal feed or
converted into animal
feed
Potable water
5
2
0.1 (N)
Revoke
Revoke
Revoke
The sugarcane molasses reassessed tolerance at
§ 180. 142(a)(12) will be recodifed as § 180. 142(a).
Duplication of tolerances is not necessary.
Tolerances for direct and inadvertent residues of
2,4-D in barley, bran; rye, bran; and wheat, bran are
to be established under revised 40 CFR 1 80. 1 42(a).
Tolerances in other small grain processed products
are not necessary as residues do not concentrate
upon processing.
OPP no longer establishes tolerances in drinking
water. EPA's Office of Water has established an
MCL for 2,4-D at 0.07 ppm.
Tolerances Needed Under 40 CFR §180.142 (a); this list does not include recodifications, etc. from above
Almond hulls
Aspirated grain
fractions
None
None
0.10
40
Almond, hulls
Based on FLAFT residues of 0.038 ppm for corn
grain and a 39x concentration factor, maximum
expected residues would be 1.48 ppm in aspirated
grain fractions (AGF) derived from com grain.
Based on FLAFT residues of 3.24 ppm for wheat
grain and a 1 1 ,2x concentration factor, maximum
expected residues would be 36.3 ppm in AGF
denved from wheat grain.
As sorghum and soybeans uses are early-season
uses, residue data on AGF were not generated for
these crops. Establish tolerance in AGF at 40 ppm.
Page 95 of 304

-------
Commodity
Barley, hay
Barley, straw
Barley, bran
Millet, hay
Oat, hay
Oat, straw
Rice, hulls
Rye, straw
Rye, bran
Soybean, forage
Soybean, hay
Soybean, seed
Wheat, hay
Wheat, straw
Wheat, bran
Tolerance Listed
Under 40 CFR
§ 180.1 42 (ppm)
None
None
None
None
None
--
None
None
None
None
None
None
None
None
None
Reassessed
Tolerance (ppm)
TBD
50
4.0
TBD
TBD
50
2.0
50
4.0
0.02
2.0
0.02
TBD
50
4.0
Comment
[Corrected Commodity Definition]
Data for wheat straw were translated to barley
straw. Required wheat wheat hay data will be
translated to barley hay.
Data for wheat bran were translated to barley bran.
Required wheat wheat hay data will be translated to
millet hay.
Data for wheat straw were translated to oat straw.
Required wheat wheat hay data will be translated to
oat hay.
Maximum residue value is based on HAFT residues
of 0.425 ppm in/on rice grain and a 3.3x
concentration factor for hulls.
Data for wheat straw were translated to rye straw.
Data for wheat bran were translated to rye bran.
Adequate residue data are available to support
permanent tolerances on soybean commodities.
Data are required on wheat hay

Maximum residue value is based on HAFT residues
of 1 .08 ppm in/on wheat grain (14-day PHI) and a
3.6x concentration factor for bran.
Tolerance Listed Under 40 CFR §180.142 (b) 5
Wild rice
0.1
0.05
Tolerance expires 12/31/05. Adequate data are
available to establish a permanent tolerance with a
regional registration to be recodified as § 180. 142(c)
for Rice, wild, grain at 0.05 ppm.
Tolerance Needed Under 40 CFR §180.142 (c) 6
Rice, wild, grain
None
0.05
regional tolerance with use restricted to MN
Tolerances Needed Under 40 CFR §180.142 (d) 7
Commodities and
crop groups currently
listed under paragraph
(a)(3)
0.1 (N)
NA
See comments listed under § 1 80. 142(a)(3)
Maximum residue of treated RAC sample(s) following application of 2,4-D formulations according to use patterns
the Task Force II registrants intend to support for reregistration.
This subparagraph will be deleted and tolerances recodified under revised paragraph (a).
TBD = To be determined. Reassessment of tolerances(s) cannot be made at this time because additional data are
required.
Tolerances listed under § 180.142 (a)(3) for inadvertent residues will be recodified as either § 180.142(a) or
§180.142(d).
This paragraph will be reserved for future time-limited tolerances under Section 18 Emergency Exemptions.
Tolerances with regional use registration.
                                         Page 96 of 304

-------
7     Paragraph (d) will contain tolerances for inadvertent residues (e.g., residues in irrigated crops) only, i.e., there is no
     registration for direct use in the U.S. If residues may result inadvertently as well as intentionally (direct, labeled
     treatment), the tolerance is codified at §180.142(a)

              3. Codex Harmonization

     The Codex Alimentarius Commission has established several maximum residue limits (MRLs)
for residues of 2,4-D in/on various plant and animal commodities.  The Codex MRLs are expressed in
terms of 2,4-D per se.  The expression of residues for Codex MRLs and U. S. tolerances is
harmonized.  A numerical comparison of the Codex MRLs and the corresponding reassessed U.S.
tolerances is presented in Table 39.

Table 39. Codex MRLs and applicable U.S. tolerances for 2,4-D.  Recommendations for
compatibility are based on conclusions following reassessment of U.S. tolerances
Codex
Commodity, As Defined
Barley
Blackberries
Citrus fruits
Eggs
Maize
Meat (from mammals other
than marine mammals)
Milk products
Milks
Oats
Potato
Raspberries, Red, Black
Rice
Rye
Sorghum
Vaccinium berries, including
Bearberry
Wheat
MRL
(mg/kg)
0.5
0.1
2.0
0.05 (*)
0.05 (*)
0.05 (*)
0.05 (*)
0.05 (*)
0.5
0.2
0.1
0.05 (*)
0.5
0.05 (*)
0.1
0.5
Reassessed U.S. Tolerance,
ppm
2.0
0.20
3.0
Revoked
0.05
0.30
4.0
0.05
0.05
2.0
0.40
0.20
0.50
2.0
0.20
0.20
2.0
Recommendation And Comments

U.S. tolerance for Berries group 13



Meat, fat, and mbyp except kidney
Kidney




U.S. tolerance for Berries group 13


Forage, grain, and stover=0.2
U.S. tolerance for Berries group 13

     (*) = At or about the limit of detection.

              4. Residue Analytical Methods - Plants and Livestock (GLN 860.1340)

     For the purpose of reregistration, adequate methods are available for data collection and the
enforcement of plant commodity tolerances.  The Pesticide Analytical Manual (PAM) Vol. II lists
three GC methods (designated as Methods A, B, and C) with microcoulometric detection and one GC
                                       Page 97 of 304

-------
method (designated as Method D) with electron capture detection (BCD). In a letter dated September
3, 1993 (CBRS No. 12270, DP Barcode D193335, 9/3/93, W. Smith), Task Force H indicated that the
enforcement methods currently listed in PAM Vol. n are unsuitable for determining residues of 2,4-D
in wheat and poultry commodities.

Plant Commodities: Task Force II submitted an adequate proposed GC/ECD enforcement method for
plants (designated as EN-CAS Method No. ENC-2/93) which has been independently validated.
Adequate radiovalidation data have been submitted and evaluated for the proposed enforcement
method using samples from the wheat metabolism study. The proposed enforcement method or
modifications of the enforcement method were used for data collection purposes.

Livestock Commodities:  Task Force II submitted two separate (but essentially comparable) proposed
enforcement methods (GC/ECD) for determination of 2,4-D in livestock commodities.  Adequate
radiovalidation data have been submitted for the method using samples of fat, kidney, and milk from
the goat metabolism study and samples of eggs from the poultry metabolism study.  The Agency
concluded that the methods are adequate provided the registrants satisfy the following requests: (i)
submit a revised method which combines the two methods into a single method; (ii) delete from the
method all references to the use of diazomethane as a derivatizing agent; and (iii) provide complete
raw data and sample calculations (including chromatograms showing peak areas, external standard
linearity curves and associated data, standard calculations, etc.). Once an adequate revised method is
submitted, the Agency will evaluate the tolerance method validation. Recently, it has been
determined that the technology to generate diazomethane has advanced such that it is no longer
considered to be a dangerous procedure; as a result, the use of diazomethane as a derivatizing agent is
now considered acceptable.

     E. Regulatory Rationale

     The following is a summary of the rationale for managing risks associated with the use of 2,4-
D. 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.  Residential Risk

               1) Residential risk summary

     A Margin of Exposure (MOE) of 1000 (1 Ox for interspecies extrapolation, lOx for intraspecies
variation, and lOx database uncertainty factor) is considered adequately protective for this assessment
of residential risks. Residential handler risks are not of concern. All MOEs for post-application, oral
exposure to children from playing on treated lawns meet or exceed 1000; therefore, post-application
exposure to children is not of concern.  Likewise, all adult acute/short term MOEs meet or exceed
1000, so post-application exposure is not of concern for adults.
                                      Page 98 of 304

-------
     As discussed below, potential risks were identified to individuals who swim in water treated
with 2,4-D.  Although the risk assessment is likely to be conservative, mitigation measures will be
required.

                2) Residential Post-application Mitigation

     For residential, post-application exposures, when the calculated MOE of 1000 based on
modeling is considered in conjunction with biomonitoring results, it is clear that the modeled short-
term risks from post-application exposure are upper bound estimates. At one day post-treatment, the
MOEs for the volunteers who wore shorts and no shoes ranged from 1400 to 35000 with the lowest
MOE corresponding to the volunteer who removed his shirt during the exposure period. The MOEs
for the remaining volunteers ranged from 24000 to 37000. The Agency has concluded that no
further mitigation is needed for residential post-application exposures.

                3) Residential Swimmer Mitigation

     The acute MSWC of 9.8 ppm for exposures to 2,4-D acid or amine is greater than the proposed
maximum application rate of 4.0 ppm, therefore, acute exposures to acid or amine are not of concern.
The MSWC of 3.6 ppm for short-term exposures to acid or amine is also not of concern because
some dissipation or dispersion is likely to occur which would cause the 7-day average of 2,4-D
concentrations to be less than 3.6 ppm.  Dissipation studies submitted to the Agency indicated that
the half lives following pond and lake liquid treatments  ranged from 3.2 days to 27.8 days which
yield 7 day average concentrations of 1.9 ppm when the half life equals 3.2 days, to 3.6 ppm when the
half life equals 27.8 days.

     The MSWCs for 2,4-D BEE are less than the master label application rate of 4 ppm, but they
are unlikely to be of concern for the following reasons:

•    2,4-D BEE degrades rapidly by abiotic hydrolysis in sterile water to form 2,4-D acid
particularly when the pH is 7.5 or above.

•    2,4-D BEE degrades to 2,4-D acid by microbial hydrolysis with an average half life of 2.6 +
1.8 hours at a bacterial concentration of 5 x 10"8 organisms per liter. Therefore, degradation of 2,4-D
BEE to 2,4-D under typical environmental conditions will be rapid leading to significantly lower risk
estimates because the 2,4-D acid has a lower rate of dermal absorption.

•    Modeling predicts direct water application of 2,4-D BEE will yield surface water concentrations
of 2,4-D BEE concentrations in the Agency standard pond of 624 ug/L for peak (24 hour average), 30
ug/L for the 21-day average, and 10 ug/L for the 60-day average.

•    The existing label rates for 2,4-D BEE products are also lower than the master label rate.
                                       Page 99 of 304

-------
     Although the risk characterization above suggests that the risk estimates are conservative, a 24
hour post-application restriction on swimming is necessary to ensure the safety of children swimming
in water treated with 2,4-D BEE.

              b. 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 is reliable information." Aggregate exposure will
typically include exposures from food, drinking water, residential uses of a pesticide, and other non-
occupational sources of exposure.

                1) Aggregate Risk Summary

     For 2,4-D, EPA conducted acute, short-term, and chronic aggregate risk assessments using the
reduced maximum application rate for residential turf (1.5 Ibs ae/A). The aggregate risk assessment
compares the Drinking Water Level of Comparison (DWLOC) for each scenario with the appropriate
Estimated Drinking Water Concentration (EDWC) for the pesticide. The DWLOC is the maximum
concentration in drinking water which, when considered together with food, and, if appropriate,
residential exposure, does not exceed EPA's level of concern. Generally, EDWCs that are less than
the corresponding DWLOC are not of concern to the Agency.
     It is important to note that the MCL for 2,4-D, established by EPA's Office of Water under the
Safe Drinking Water Act (SDWA), is 70 ug/L. To minimize the possibility that direct aquatic
applications will result in drinking water concentrations in excess of the MCL, the Agency has
worked with the 2,4-D Task Force and water quality specialists to  develop appropriate label
requirements for 2,4-D products registered for use to control aquatic weeds.

                2) Acute Aggregate Risk

DWLOC Approach
     Acute DWLOCs were calculated based upon acute dietary exposures.  Acute residential
exposures from swimming in treated water bodies or playing on treated turf were not included
because exposures  are unlikely to co-occur with acute dietary exposures.  The acute DWLOCs  are
range from 432 to 1932 with the most sensitive population being females 13 to 49 years old.  The
EDWCs  of 118 ug/liter for surface water and 15 ug/liter for groundwater are substantially less than
the DWLOCs which means that the risks are not of concern.

Forward Calculation Approach
     Acute aggregate risks were assessed by directly combining acute food exposures and estimates
of acute water  exposures. The acute aggregate risks and are not of concern because they are less than
100 percent of the aPAD. The highest risks (58 percent of the aPAD) are for females 13-49 years old
because these risks are based upon the lower NOAEL of 25 mg/kg/day from a developmental study in
                                      Page 100 of 304

-------
rats. Whereas, estimates of other population groups are based on a NOAEL of 67 mg/kg/day from an
acute neurotoxicity study in rats.

                3)  Short-term Aggregate Risk

DWLOC Approach
     Short-term aggregate risks assessments were conducted by calculating DWLOCs based upon
short-term turf exposures, chronic food exposures and short-term endpoints. Short-term exposures
from swimming in treated water bodies were not included because these exposures represent high-end
unlikely scenarios.  The short-term DWLOCs were calculated only for females 13-49 and children 1-
6 because these population subgroups have the highest exposure and estimates calculated for these
groups are protective of the other subgroups. The DWLOCs range from 24 to 36 ug/liter. The
EDWCs range from 15 to 23 ug/liter. Since the DWLOCs are all greater than the EDWCs, the short
term risks are not of concern.

Forward Calculation Approach
     Short-term aggregate risks were assessed by aggregating short-term turf exposures, chronic
food exposures and chronic water exposures. Short-term aggregate risk were calculated only for
females 13-49 and children 1-6 because these population subgroups have the highest exposure and
estimates calculated for these groups are protective of the other subgroups.  The short-term aggregate
MOEs indicate that the short term risks are not of concern because the MOEs equal or exceed the
target MOE of 1000.

                4)  Chronic (Non-Cancer) Aggregate Risk

DWLOC Approach
     Chronic DWLOCs were calculated based upon chronic dietary exposures.  As there are no
chronic residential exposures, residential exposures were not included in the chronic DWLOC
calculations. The chronic DWLOCs are 46 ug/L or greater with the most sensitive populations being
infants and children. The EDWCs, which range from 1.5 to 23 ug/L,  are less than the DWLOCs
which means that the risks are not of concern. It should be noted that the master label indicates that
potable water consumption from a  treated water body cannot begin until the 2,4-D concentration is 70
ug/L or below, therefore an annual average exposure at the MCL of 70 ug/L would not occur because
dissipation would reduce the initial concentration of 70 ug/L to an annual average concentration  of 11
ug/L.

Forward Calculation Approach
     Chronic aggregate risks were assessed by aggregating chronic food exposures and chronic
water exposures. The chronic aggregate risks are not of concern because they are less than 100
percent of the cPAD. The highest risks (38 percent of the cPAD) are  for children 1-2 years old.
                                      Page 101 of 304

-------
                5)  Aggregate Risk Mitigation

      Given the reduced maximum application rate to residential lawns (1.5 Ibs ae/A), the highest
aggregate risks are the risks from short-term exposures, which include the turf exposure scenarios.
For the most sensitive subpopulation (females 13-49) these risks meet the target MOE of 1000 and
the turf exposure is the risk driver as it contributes 96 percent of the risk.
     Whereas calculated risks just meet the Agency's target MOE, it is important to note that the turf
exposure estimate is based upon modeling and is greater than exposure measurements obtained from
biomonitoring.  As described in the human health assessment, the results of a biomonitoring study
were used to calculated MOEs by assuming that all of the urinary 2,4-D measured in the 96 hours
after the exposure period was the result of the turf exposure. This assumption is protective because
2,4-D exposures due to inhalation and due to food and water ingestion would be counted as dermal
exposure. The biomonitoring results were adjusted by a factor of two to account for the SOP
assumption of two hours of daily exposure vs one hour of exposure during the study, and a factor of
1.7 to account for an application rate of 1.5 Ibs ae/acre vs 0.88 Ib ae/acre applied during the study. At
one day post-treatment, the MOEs for the volunteers who wore shorts and no shoes ranged from 1400
to 35000 with the lowest MOE corresponding to the volunteer who removed his shirt during the
exposure period. The MOEs for the remaining volunteers ranged from 24000 to 37000. If the
calculated MOE of 1000 based on modeling is considered in conjunction with the MOE calculated
based on biomonitoring results, it is clear that the modeled short-term risks are upper bound
estimates. The Agency has concluded that aggregate risks from acute, short-term and chronic
exposures are not of concern. No further mitigation beyond reducing the maximum application rate
from 2.0 to 1.5 Ibs/ae per acre is needed.

              c. Occupational Risk Mitigation

                1)  Handler Risk Mitigation

     With the exception of mixing/loading wettable powder, the short-term and intermediate-term
Margin of Exposure estimates (MOEs) exceed 100 with baseline attire (i.e., long-sleeved shirt, long
pants, shoes plus socks) or single layer attire (i.e., long-sleeved shirt, long pants, shoes plus socks,
gloves) and are not of concern.   The MOEs for handling wettable powder are acceptable with
engineering controls (i.e. water soluble bags). Water soluble bags will be required for wettable
powder formulations.

                2)  Post-application Risk Mitigation

     All short-  and intermediate-term MOEs are above 100 on day zero.  All occupational
postapplication risk scenarios are below EPA's level of concern. Products containing 2,4-D salt and
ester forms as active ingredient with Worker Protection Standard (WPS) uses will require a re-entry
interval (REI) of 12 hours. Because of acute eye irritation concerns, products containing 2,4-D acid
and amine forms with WPS uses will require a REI of 48 hours and protective eyewear.  The
requirements for individual products will be finalized based on product-specific chemistry and acute


                                      Page 102 of 304

-------
toxicity review.  The exposure reduction program implemented in 1992 will be replaced with the
personal protective equipment described in section V.D. of this document.

           2.  Environmental Risk Mitigation

     The Agency has considered available information on 2,4-D's toxicity, use areas, usage, fate
properties, application methods, and formulations in calculating ecological risks.  The resulting
assessment suggests that the use of 2,4-D for aquatic weed control presents risk to aquatic organisms,
while 2,4-D use on terrestrial sites presents greater potential risks to  small mammals, birds, and non-
target terrestrial plants, than to other plants and animals.

              a. Birds

Acute Risk
     Whereas the assessment of risk to birds from the terrestrial use of 2,4-D suggests risks of
concern, the assessed exposures to 2,4-D are likely conservative in the following ways.  Currently,
Agency models do not account for the uptake of 2,4-D by plants and therefore assume that all non-
dissipated pesticide applied to the field is present for exposure to organisms.  In fact, many pesticides,
including 2,4-D, are systemic and are absorbed by plants in the field and therefore, the current
approach may overestimate the amount of 2,4-D available for exposure in terrestrial and aquatic
systems.
     For non-granular spray application, the highest acute avian RQ (3.5) was from the cranberry
use-site scenario, for birds feeding on short grass. That assessment was based on a maximum
application rate of 4 Ibs ae/acre; however, the average application rate is 1.83 Ibs ae/acre (see the
Agency's quantitative use assessment). If the modeled application rate was reduced to 1.83 Ibs
ae/acre for cranberries, and an assumption made that the resulting  EEC will be reduced linearly, the
RQ would be 1.6.
     To determine the hazard associated with acute exposures to birds, the assessment has relied on
two types of data, a suite of dietary studies and a suite of gavage studies. For avian acute exposures,
the dietary studies result in non-definitive endpoints which are not appropriate for estimating risk.
Therefore, the assessment has relied on the gavage studies to estimate avian acute risks. The Agency
recognizes that this approach may overestimate risk to birds due to the fact that birds would not
typically be expected to consume 2,4-D in this manner.

Chronic Risk
     Potential chronic risks to birds is limited to the following use sites: non-cropland, forest,
asparagus, and cranberry.  The RQs for these sites range from one to slightly above one.  Further
characterization of these use sites by evaluating average application  rates versus maximum
application rates lower these RQs to below the LOCs.
     Given the conservative assumptions in both exposure scenarios and hazard determinations, the
Agency finds that the acute and chronic risks to birds from 2,4-D exposure are not of concern.
                                       Page 103 of 304

-------
                b. Mammals
Acute risk
     All of the calculated RQs for mammalian acute risk for the non-granular use of 2,4-D were
based on maximum labeled application rates. The EPA's quantitative use assessment (EPA QUA)
suggests that the average application rates for many crops are considerably less than the modeled
maximum application rates. For non-granular spray application mammalian acute concerns, the
highest RQ was 1.72 for use on asparagus for small mammals feeding on short grass based on a
maximum application rate of 2 Ibs ae/A applied two times a year; however, the average application
rate was only 1.10 Ibs ae/A (EPA QUA). If the modeled application rate was reduced to the reported
average application rate of 1.10 Ibs ae/A for asparagus, the RQ would be 1.08 which is still above the
acute LOG of 0.5. However, asparagus is representative of a minor 2,4-D use, and risk to mammals
from use of 2,4-D on asparagus would be minimal, given that fact.
     To add context to the acute mammalian assessment, the effect of assuming an average
application rate was determined.  Major 2,4-D crops include pasture/rangeland, turf, wheat, corn, and
soybeans. For pasture/rangeland, the highest acute RQ was 0.86 for small mammals feeding on short
grass based on a maximum application rate of 4 Ibs ae/A. However, the average application rate was
only 0.62 Ibs ae/A (BEAD QUA). If the modeled application rate was reduced to 0.62 Ibs ae/A for
pasture/rangeland, the resulting RQ is 0.31 which is below the acute LOG, but above the restricted
use LOG of 0.2.  Similar trends are noted for other major use sites.
     Although the calculated RQ values still exceed the Agency's level of concern when average
applications rates are considered, the Agency has concluded that the benefits from 2,4-D use
(including control of invasive and noxious weed species), taken together with the low toxicity of 2,4-
D to humans, outweigh the concerns of toxicity to small mammals. No additional mitigation steps
will be taken.

 Chronic risk
     Calculated chronic risks to mammals were greatest for small herbivores/insectivores.  For 15 g
mammalian herbivores/insectivores, chronic RQs based on maximum residues and mean residues
ranged from <1 to 200 and <1 to 70, respectively. For major use sites, including rangeland/pasture,
RQs were approximately 100.  These chronic risk estimates are likely conservative as described
below.
     The chronic RQs calculated for mammalian herbivores/insectivores are based on conservative
estimates of exposure that are not likely to occur in nature. In the example of pasture/rangeland, the
chronic  RQ of approximately 100 for maximum residues (35 for mean residues) was calculated based
on an application rate of 2 Ibs ae/A applied twice per year, at a 30 day interval. However, the EPA
has determined that the average application rate on pasture/rangeland is only 0.62 Ibs ae/A (EPA
QUA).  Moreover, information from several of the Agency's state contacts indicate that a once per
year application of less than 1 Ib ae/A is typical (personal communications).  As the typical rate is
approximately 25% of the assessed rate, use of the typical rate would be expected to decrease the RQ
for the pasture/rangeland scenario approximately four-fold, to approximately 25 for maximum
residues and 9 for mean residues.
     A  second example of the conservative assumptions included in the assessment of exposure to
mammalian herbivores/insectivores is the assumption that 100% of the long term diet is relegated to


                                     Page 104 of 304

-------
single food types foraged only from treated fields. The assumption of 100% diet from a single food
type may be realistic for acute exposures, but diets are likely to be more variable over longer periods
of time. The risk assessment assumed that 100% of the small mammals' diet consists of short
grasses. Several published reports suggest that actual diets of small mammals are more varied, and
would likely include invertebrates, worms, fungi, and seeds, in addition to plant matter.
     Given the conservative assumptions in the  exposure scenarios, the Agency finds that the risks
identified in the risk assessment are likely to overestimate actual risks to mammals from 2,4-D
applications. Based on information about average application rates and dietary patterns as described
above, the Agency has concluded that actual 2,4-D exposures to mammals are likely to be
significantly lower than those assessed but may still be above the chronic LOG for this screening
level assessment.  However, the Agency has concluded that the benefits from 2,4-D use (including
control of invasive and noxious weed species), taken together with the low toxicity of 2,4-D to
humans, outweigh the concerns of toxicity to small mammals. No additional mitigation is being
required at this time.

                c. Aquatic Organisms

     Whereas the assessment of risk to  aquatic organisms suggests risks of concern, the assessed
exposures to 2,4-D are likely conservative as follows.  Whereas the maximum labeled target
concentration for control of aquatic weeds is 4 ppm, the typical target concentration is 2 ppm. A rate
of 4 ppm is reserved for spot-treating new aquatic weed stands and hybrid weed species that tend to
be less susceptible to 2,4-D. Per the product label, re-application of 2,4-D can occur after 21 days.
     In the current assessment, the risks to aquatic organisms were estimated based on a 2,4-D
application that resulted in a whole-reservoir concentration of 4 ppm.  Treating 100% of the water
body would likely result in a large amount of decaying plant life, thereby creating an oxygen-depleted
environment that would most likely result in fish kills. To avoid that scenario, the current 2,4-D label
advises that the applicator avoid treating more than 50% of a water body in a 21-day period. In actual
practice, aquatic weeds that 2,4-D controls tend to grow near the shore of lakes, ponds, and
reservoirs. As a result, generally a maximum of 20-30% of a water body is treated in a single
application.  Applying the typical rate of 2 ppm, and taking into account a typical maximum treated
area of 30%, would decrease calculated  RQs by approximately 6-fold.
     While noting the potential risks to aquatic organisms from the direct application of 2,4-D for the
control of aquatic weeds identified above, it is important to note the benefits  gained through the direct
application of 2,4-D to aquatic bodies, for the control of invasive species. The U.S Army Corps of
Engineers (USAGE) and state agencies have identified 2,4-D as an important tool for protecting water
bodies from the invasion and establishment of some species of exotic nuisance vegetation.  2,4-D has
a reputation as a selective and economical means to remove invasive plants,  enhance the growth and
recovery of desirable native vegetation,  restore water quality, reduce sedimentation rates in reservoirs,
and improve fish and wildlife habitat.  2,4-D products are used to control invasive weeds, such as
Eurasian water milfoil (Myriophyllum spicatuni)  in the northern tier states and water hyacinth
(Eichhornia crassipes) in the Gulf Coast states. Effective control of these plants can benefit public
health with respect to reducing levels of mosquito habitat. In addition, according to USAGE, no other
product (or alternative technique) can control these plants in a more cost-effective manner (K.
Getsmger, USAGE, Public Comment; Docket ID# OPP-2004-0167-0053).


                                      Page 105 of 304

-------
     Given the typical application rates and treatment areas, and considering the beneficial aspects of
using 2,4-D to control invasive plant species, the Agency concludes that the benefits from direct
aquatic use of 2,4-D outweigh the risk concerns for aquatic organisms. No additional mitigation
measures will be required at this time to address risk to aquatic organisms.

              d. Non-target Insects

     Risk to non-target insects do not exceed the Agency's level of concern. Available data from a
honey bee acute toxicity study indicated that technical 2,4-D is practically non-toxic to the honey bee.
The potential for 2,4-D and its salts and esters to pose risk to pollinators and other beneficial insects is
expected to be minimal.

              e. Non-target Terrestrial Plants

     Estimated RQs exceeded acute LOCs for both non-endangered and endangered terrestrial plants
for non-granular and granular uses  at many use sites. Consideration of average application rates did
not result in exposure below LOCs. However, the exposure estimates used to develop the RQs were
likely conservative, as follows.
     In the exposure calculation for non-target aquatic plants and terrestrial plants in intermittently
flooded areas, the major contributor is run-off from the application site. The run-off and leaching
vulnerability  schemes used in this assessment incorporate several conservative assumptions  which are
fully discussed in the ecological risk assessment.  Also, it is likely that farm management practices
would be in place to limit run-off, as run-off events are detrimental to the farm as a whole for reasons
other than pesticide damage.
     Whereas the risk assessments are likely conservative as described above, the Agency is
concerned about the risk to non-target terrestrial plants  from drift of 2,4-D during application.  To
address that concern, the Agency is implementing spray drift controls that will decrease the risk that
2,4-D will drift onto non-target plants.

              f.  Summary of Environmental Risk Mitigation

     Characterization of the risks identified in the Agency's screening level risk assessment suggests
that risks from drift onto non-target plants exceeds the Agency's level of concern.  The Agency is
implementing spray drift  controls that will decrease the risk that 2,4-D will drift onto non-target
plants.

     F. 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-D. For the specific labeling statements and a  list of
outstanding data, refer to  Section V of this RED document.

           1. Endangered Species Considerations
                                       Page 106 of 304

-------
     The Agency has developed the Endangered Species Protection Program to identify pesticides
whose use may cause adverse impacts on 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 and 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. Based on
EPA's screening level assessment for 2,4-D, RQs exceed levels of concern for mammals, birds,
aquatic plants, and terrestrial plants. However, these findings are based solely on EPA's screening
level assessment and do not constitute "may affect" findings under the ESA. The Agency is requiring
additional data to further characterize and refine its ecological and endangered species risk
assessments.  The 2,4-D Task Force has submitted a limited endangered species assessment on
several crops for the Agency's consideration. This assessment was generated using the FIFRA
Endangered Species Task Force (FESTF) integrated management system (IMS).

           2.  Spray Drift Management

     The Agency has been working closely with stakeholders to develop improved approaches for
mitigating risks to human health and the environment from  pesticide spray and dust drift. As part of
the reregistration process, we will continue to work with all interested parties on this important issue.
     From its assessment of 2,4-D, as summarized in this document, the Agency concludes that
certain drift mitigation measures are needed to address the risks from off-target drift for 2,4-D. Label
statements implementing these measures are listed in the "spray drift management" section of the
Labeling Changes Summary Table in section V.D. of this RED document.  In the future, 2,4-D
product labels may need to be revised to include additional  or different drift label statements.

           3. Consumer Labeling Initiative

     The Consumer Labeling Initiative  (CLI) is an effort among federal, state, and local government
agencies, industry, environmental groups, and other interested parties working to improve product
labels on residential  pesticides in order to improve consumer understanding and compliance of
consumer labels. The CLI Work Group  of the Pesticide Program Dialogue Committee (PPDC) is
working to revise consumer labels.  In addition to the labeling changes presented in this RED, the
Agency will leave open the possibility that changes to residential product labeling may occur as the
result of the PPDC CLI.
                                      Page 107 of 304

-------
V. What Registrants Need To Do

          For 2,4-D technical grade active ingredient products, registrants need
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 Katie Hall at (703) 308-0166 with questions regarding generic reregistration
and/or the DCI. All materials submitted in response to the generic DCI should be addressed:

By US mail:                                     By express or courier service:
Document Processing Desk (DCI/SRRD)           Document Processing Desk (DCI/SRRD)
Katie Hall                                       Katie Hall
US EPA (7508C)                                 Office of Pesticide Programs (7508C)
1200 Pennsylvania Ave., NW                      Room 604, Crystal Mall 2
Washington, DC 20460                           1801 S. Bell Street
                                                Arlington, VA 22202 -4501

              For products containing the active ingredient 2,4-D registrants need 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);
                                     Page 108 of  304

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

              (3)     five copies of the draft label incorporating all label amendments outlined in
                     Table 40 of this document;

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

              (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 Moana Appleyard at (703) 308-8175 with questions regarding product
reregistration and/or the PDCI. All materials submitted in response to the PDCI should be addressed:
By US mail:
Document Processing Desk (PDCI/PRB)
Moana Appleyard
US EPA (7508C)
1200 Pennsylvania Ave., NW
Washington, DC 20460
By express or courier service only:
Document Processing Desk (PDCI/PRB)
Moana Appleyard
Office of Pesticide Programs (7508C)
Room 266A, Crystal Mall 2
1801 Bell Street
Arlington, VA 22202
       A. Manufacturing Use Products

              1. Additional Generic Data Requirements

       The generic data base supporting the reregistration of 2,4-D for eligible uses has been
reviewed and determined to be substantially complete. However the following data requirements are
necessary to confirm the reregistration eligibility decision documented in this RED.

Table 40. Data Requirements for the Reregistration Eligibility Decision for 2,4-D
Guideline Study Name
New OPPTS
Guideline No.
Old
Guideline
No.
Environmental Fate and Effects Data Requirements
Aquatic field dissipation studies (Behavior of 2,4-D BEE under acidic to neutral
aquatic conditions in a water/sediment system)
Laboratory volatility study (2,4-D IPE)
Terrestrial field dissipation studies (2,4-D IPA, 2,4-D TIPA, 2,4-D DBA, 2,4-D
BEE)
835.6200
835.1410
835.6100
164-2
163-2
164-1
                                     Page 109 of 304

-------
Guideline Study Name
Aquatic field dissipation studies in a rice use scenario (2,4-D IP A, 2,4-D TIP A, 2-
4-D DBA)
Aquatic field dissipation studies in an aquatic weed control scenario (2,4-D IP A,
2,4-D TIPA, 2-4-D DBA)
Forest field dissipation studies (2,4-D IPA, 2,4-D Iff A, 2,4-D BEE, and 2,4-D
DBA)
Fish acute toxicity test, freshwater and marine with typical end-use product (TEP)
(2,4-D BEE)
Oyster acute toxicity test with TEP (2,4-D BEE)
Mysid acute toxicity test with TEP (2,4-D BEE)
Penaid acute toxicity test with TEP (2,4-D BEE)
Sediment and soil adsorption/desorption (2,4-D BEE granular formulation)
Seedling Germination/Seedling Emergence
Vegetative Vigor
Non-target terrestrial plants - TEP representative testing from the acid and amine
salts group, and representative testing from the ester group. The test products
should include the most common and most active surfactants and adjuvants which
affect the toxicity of the product. The registrants should consult with the Agency
before finalizing which products to test.
The registrant must provide information on the proximity of Federally listed
freshwater vascular plants, birds, mammals, and non-target terrestrial plants (there
are no listed estuarine/marine invertebrates) to the 2,4-D use sites. This
requirement may be satisfied in one of three ways: 1) having membership in the
FIFRA Endangered Species Task Force (Pesticide Registration [PR] Notice 2000-
2); 2) citing FIFRA Endangered Species Task Force data; or 3) independently
producing these data, provided the information is of sufficient quality to meet
FIFRA requirements. Registrants should consult with the Agency prior to
fulfilling this data requirement.
New OPPTS
Guideline No.
835.6200
835.6200
835.6300
850.1075
850,1025
850.1035
850.1045
835.1230
850.4225
850.4250

Old
Guideline
No.
164-2
164-2
164-3
72-1
72-3
72-3
72-3
163-1
123-l(a)
123-l(b)

Human Health Effects Data Requirements
Developmental neurotoxicity study
Subchronic inhalation toxicity study (28-day)
Repeat two-generation reproduction study (using the most recent Agency
protocol) addressing concerns for endocrine disruption (thyroid and
immunotoxicity measures)
870.6300
870.3465
870.3800
83-6
82-4
83-4
Product and Residue Chemistry Data Requirements
Crop field trials - wheat hay
860.1500
171-4k
Page 110 of 304

-------
Guideline Study Name
Water, fish, and irrigated crops - irrigated crop studies in strawberries and sugar
beet roots and tops
Residue analytical method - revised enforcement method for determination of 2,4-
D in livestock commodities
Directions for Use
New OPPTS
Guideline No.
860.1400
860.1340
860.1200
Old
Guideline
No.
171 -4f
171-4c
171-3
Other Data Requirements
UV/Visible Absorption
Droplet Size Spectrum
Drift Field Evaluation
The Agency is requiring that five recent batches of all technical products be
analyzed for 2,3,7,8-TCDD, 2,3,7,8-TCDF and their respective higher substituted
chlorinated congeners using validated analytical methods. The Agency specifies
that the manufacturers use the most current state-of-the art laboratory methods for
measuring 2,3,7,8-TCDD and TCDF at levels less than 1 part per trillion (EPA
Method 1613, Tetra- through Octa-Chlorinated Dioxins and Furans by Isotope
Dilution HRGC/HRMS). Because 1,2,3,7,8-PeCDD is eqm-potent to 2,3,7,8-
TCDD in the TEF scheme, the Agency is adding this compound to our testing
requirements.
830.7050
840.1100
840.1200

None
201-1
202-1

       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. Registrants 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.

              2. Labeling for End-Use Products

       Labeling changes are necessary to implement the mitigation measures outlined in Section IV
above. Specific language to incorporate these changes is specified in Table 40.

       C. Existing Stocks

       Registrants may generally distribute and sell products bearing old labels/labeling for 12
months from the date of the issuance of this Reregistration Eligibility Decision document. Persons
                                      Page 111 of  304

-------
other than the registrant may generally distribute or sell such products for 24 months from the date of
the issuance of this RED. However, existing stocks time frames will be established case-by-case,
depending on the number of products involved, the number of label changes, and other factors.  Refer
to "Existing Stocks of Pesticide Products; Statement of Policy"; Federal Register, Volume 56, No.
123, June 26,  1991.
                                     Page 112 of  304

-------
D.  Required Labeling Changes Summary Table

In order to be eligible for reregistration, all product labels must be amended to incorporate the risk mitigation measures outlined in Section
IV. The following table describes how language on the labels should be amended.
                                            Table 41: Summary of Labeling Changes for 2,4-D
          Description •
                                            Language'
 Macement 0n Label
 For all Manufacturing Use
 Products
"Only for formulation into an herbicide or plant growth regulator for the following use(s)
[fill blank only with those uses that are being supported by MP registrant]."

"Wettable powder formulations must be packaged in water-soluble packages."
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
 formulator 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
"This chemical is toxic to fish and aquatic invertebrates. 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
                                                                       fO^
                                                          Page 113 of  304

-------
PPE Requirements
Established by the RED1
for liquids, wettable powders
formulated in water-soluble
packages, and water-
dispersible granules
"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, flaggers, and other handlers must wear:
- long-sleeved shirt and long pants,
- shoes and socks, plus
- chemical resistant gloves, when applying postharvest dips or sprays to citrus, applying
with any handheld nozzle or equipment, mixing or loading, cleaning up spills or
equipment, or otherwise exposed to the concentrate.
- chemical resistant apron when applying postharvest dips or sprays to citrus, mixing or
loading, cleaning up spills or equipment, or otherwise exposed to the concentrate.

See engineering controls for additional requirements."
Immediately
following/below
Precautionary
Statements: Hazards
to Humans and
Domestic Animals
PPE Requirements
Established by the RED1
for granular
formulations
"Personal Protective Equipment (PPE)

All loaders, applicators, and other handlers must wear:
- long-sleeved shirt and long pants,
- shoes plus socks."
Immediately
following/below
Precautionary
Statements: Hazards
to Humans and
Domestic Animals
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 from other
laundry."
 Precautionary
Statements:  Hazards
to Humans and
Domestic Animals
immediately
following the PPE
requirements
                                                           Page 114 of 304

-------
Engineering Controls
for aerial applications
Enclosed Cockpits

"Engineering Controls:

Pilots must use an enclosed cockpit that meets the requirements listed in the WPS for
agricultural pesticides [40 CFR 170.240(d)(6)]"
Precautionary
Statements: Hazards
to Humans and
Domestic Animals
(Immediately
following PPE and
User Safety
Requirements.)
Engineering Controls
for wettable powder
formulations packaged in
water-soluble packages
"Engineering Controls"

"Water-soluble packets when used correctly qualify as a closed loading system under the
WPS. Mixers and loaders using water-soluble packets (1) must wear the PPE specified
above for mixers and loaders and (2) must be provided, have immediately available for use
in an emergency, such as a broken package, spill, or equipment breakdown a NIOSH-
approved dust mist filtering respirator with MSHA/NIOSH approval number prefix TC-
21C or a NIOSH-approved respirator with any N 2, R, P, or HE filter."
Precautionary
Statements: Hazards
to Humans and
Domestic Animals
(Immediately
following PPE and
User Safety
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.  If pesticide gets on skin, wash immediately with
soap and water.

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.)
                                                         Page 115 of 304

-------
Environmental Hazard
Statement for Terrestrial Uses
"This pesticide may be toxic to fish and aquatic invertebrates. Do not apply directly to
water, to areas where surface water is present, or to intertidal areas below the mean high
water mark except as noted on appropriate labels. Drift and runoff may be hazardous to
aquatic organisms in water adjacent to treated areas. Do not contaminate water when
disposing of equipment wash waters or rinsate.

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
Safety
Recommendations
Environmental Hazard
Statement for products used
for aquatic weed control
"Fish breathe dissolved oxygen in the water and decaying weeds also use oxygen.  When
treating continuous, dense weed masses, it may be appropriate to treat only part of the
infestation at a time.  For example, apply the product in lanes separated by untreated strips
that can be treated after vegetation in treated lanes has disintegrated.  During the growing
season, weeds decompose in a 2 to 3 week period following treatment. Begin treatment
along the shore and proceed outwards in bands to allow fish to move into untreated areas.
Waters having limited and less dense weed infestations may not require partial treatments."
Precautionary
Statements
immediately
following the User
Safety
Recommendations
Restricted-Entry Interval for
products containing with
directions for use within the
scope of the WPS and
containing 2,4-D acid or amine
forms
"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
Restricted-Entry Interval for
products containing with
directions for use within the
scope of the WPS and
containing 2,4-D salt or ester
forms
"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
                                                            Page 116 of 304

-------
Early Entry Personal
Protective Equipment
established by the RED for
products containing 2,4-D acid
or amine forms and with WPS
uses
"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,
- chemical-resistant gloves made of any water-proof material,
- shoes plus socks,
- protective eyewear."
Directions for Use,
Agricultural Use
Requirements Box
Early Entry Personal
Protective Equipment
established by the RED for
products containing 2,4-D salt
or ester forms and with WPS
uses
"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,
- chemical-resistant gloves made of any water-proof material,
- shoes plus socks."
Directions for Use,
Agricultural Use
Requirements Box
Entry Restrictions for Granular
Formulations with directions
for use outside the scope of the
WPS
"Do not enter or allow people (or pets) to enter the treated area until dusts have settled."
If no WPS uses on the
product, place the
appropriate statement
in the Directions for
Use Under General
Precautions and
Restrictions.  If the
product also contains
WPS uses, then create
a NonAgricultural Use
Requirements box as
directed in PR Notice
93-7 and place the
appropriate statement
inside that box.
                                                            Page 117 of 304

-------
Entry Restrictions for liquids,
water-dispersible granules, and
wettable powders formulated
in water-soluble packages with
directions for use outside the
scope of the WPS
"Do not enter or allow people (or pets) to enter the treated area until sprays have dried."
If no WPS uses on the
product, place the
appropriate statement
in the Directions for
Use Under General
Precautions and
Restrictions.  If the
product also contains
WPS uses, then create
a NonAgricultural Use
Requirements box as
directed in PR Notice
93-7 and place the
appropriate statement
inside that box.
General Application
Restrictions for products
primarily intended for
occupational (professional) use
"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.'
Directions for Use
under General
Precautions and
Restrictions
                                                            Page 118 of  304

-------
Use-Specific Application
Restrictions
(Note: The maximum
allowable application rate must
be listed as pounds or gallons
of formulated product per
surface acre, not just as pounds
acid equivalent per surface
acre.)
"Aquatic weed control"
For all acids, salts, amines, and butoxyethanol ester forms used for aquatic weed control,
the following statements must appear on the product label:

> "Ditchbank application
Postemergence:
Limited to 2 applications per season.
Maximum of 2.0 Ibs ae/acre per application.
Minimum of 30 days between applications.
Spot treatment permitted.
Do not use on small canals with a flow rate less than  10 cubic feet per second (CFS) where
water will be used for drinking purposes. CFS may be estimated by using the formula
below. The approximate velocity needed for the calculation can be determined by
observing the length of time that it takes a floating object to travel a defined distance.
Divide the distance (ft.) by the time (sec.) to estimate velocity (ft. per sec.). Repeat 3 times
and use the average to calculate CFS.

  Average Width (ft.) x Average Depth (ft.) x Average Velocity (ft. per sec.) = CFS

For ditchbank weeds:
Do not allow boom spray to be directed onto water surface.
Do not spray across stream to opposite bank.
Directions for Use
Associated with the
Specific Use Pattern
                                                          Page 119 of 304

-------
Use-Specific Application
Restrictions

(Note: The maximum
allowable application rate must
be listed as pounds or gallons
of formulated product per
surface acre, not just as pounds
acid equivalent per surface
acre.)
For shoreline weeds:
Allow no more than 2 foot overspray onto water."

> "Floating and Emergent Weeds
Maximum of 4.0 Ibs ae/surface acre per application.
Limited to 2 applications per season.
Minimum of 21 days between applications.
Spot treatments are permitted.
Apply to emergent aquatic weeds in ponds, lakes, reservoirs, marshes, bayous, drainage
ditches, non-irrigation canals, rivers, and streams that are quiescent or slow moving.
Coordination and approval of local and state authorities may be required, either by letter of
agreement or issuance of special permits for aquatic applications.
                               Water Use
                               1. Water for irrigation or sprays:

                               A. If treated water is intended to be used only for crops or non-crop areas that are labled for
                               direct treatment with 2,4-D such as pastures, turf, or cereal grains, the treated water may be
                               used to irrigate and/or mix sprays for these sites at anytime after the 2,4-D aquatic
                               application.
Directions for Use
Associated with the
Specific Use Pattern
                                                            Page 120 of 304

-------
Use-Specific Application
Restrictions
B. Due to potential phytotoxicity considerations, the following restrictions are applicable:
If treated water is intended to be used to irrigate or mix sprays for plants grown in
commercial nurseries and greenhouses; and other plants or crops that are not labeled for
direct treatment with 2,4-D, the water must not be used unless one of the following
restrictions has been observed:

i. A setback distance from functional water intake(s) of greater than or equal to 600 ft. was
used for the application, or,

ii. A waiting period of 7 days from the time of application has elapsed, or,

iii. An approved assay indicates that the 2,4-D concentration is 100 ppb (0.1 ppm) or less at
the water intake. Wait at least 3 days after application before initial sampling at water
intake.

2. Drinking water (potable water):
A. Consult with appropriate state or local water authorities before applying this     product
to public waters. State or local agencies may require permits. The potable water use
restrictions on this label are to ensure that consumption of water by the public is allowed
only when the concentration of 2,4-D in the water is less than the MCL (Maximum
Contaminant Level) of 70 ppb.  Applicators should consider the unique characteristics of the
treated waters to assure that 2,4-D concentrations in potable water do not exceed 70 ppb at
the time of consumption.
Directions for Use
Associated with the
Specific Use Pattern
                                                            Page 121 of  304

-------
Use-Specific Application
Restrictions
B. For floating and emergent weed applications, the drinking water setback
distance from functioning potable water intakes is greater than or equal to 600 ft.

C. If no setback distance of greater than or equal to 600 ft. is used for application,
applicators or the authorizing organization must provide a drinking water notification prior
to a 2,4-D application to the party responsible for public water supply or to individual
private water uses. Notification to the party responsible  for a public water supply or to
individual private water users must be done in a manner to assure that the party is aware of
the water use restrictions when this product is applied to potable water.

The following is an example of a notification via posting, but other methods of notification
which convey the above restrictions may be used and may be required in some cases under
state or local law or as a condition of a permit.

Example:
Posting notification should be located every 250 feet including the shoreline of the  treated
area and up to 250 feet of shoreline past the application site to include  immediate public
access points.  Posting must include the day and time of application. Posting may be
removed if analysis of a sample collected at the intake 3  or more days following application
shows that the concentration in the water is less than 70 ppb (100 ppb for irrigation or
sprays), or after 7 days following application, whichever occurs first.
Directions for Use
Associated with the
Specific Use Pattern
                                                            Page 122 of 304

-------
Use-Specific Application
Restrictions
Text of notification: Wait 7 days before diverting functioning surface water        intakes
from the treated aquatic site to use as drinking water, irrigation, or sprays,  unless water at
functioning drinking water intakes is tested at least 3 days after    application and is
demonstrated by assay to contain not more than 70 ppb 2,4-D     (100 ppb for irrigation or
sprays). Application Date:	Time:	

D. Following each application of this product, treated water must not be used for
drinking water unless one of the following restrictions has been observed:

i. A setback distance from functional water intake(s) of greater than or equal to 600 ft. was
used for the application, or,
ii. A waiting period of at least 7 days from the time of application has elapsed, or,
iii. An approved assay indicates that the 2,4-D concentration is 70 ppb (0.07 ppm) or less at
the water intake.  Sampling for drinking water analysis should occur no sooner than 3 days
after 2,4-D application. Analysis of samples must be completed by a laboratory that is
certified under the Safe Drinking Water Act to perform drinking water analysis using a
currently approved version of analytical Method Number 515, 555, other methods for 2,4-
D as may be listed in Title 40 CFR, Part 141.24, or Method Number 4015 (immunoassay
of 2,4-D) from U.S. EPA Test Methods for Evaluating Solid Waste SW-846.

E. Note: Existing potable water intakes that are no longer in use, such as those    replaced
by a connection to a municipal water system or a potable water well, are      not
considered to be functioning potable water intakes.
Directions for Use
Associated with the
Specific Use Pattern
                                                            Page 123 of 304

-------
Use-Specific Application
Restrictions
F. Drinking water setback distances do not apply to terrestrial applications of 2,4-D
adjacent to water bodies with potable water intakes.

3. Swimming (2,4-D butoxyethanol ester only):
A. Do not swim in treated water for a minimum of 24 hours after application.

B. Users must provide notification prior to performing a 2,4-D BEE application.
Notification to the party responsible for the public swimming area or to individual private
users must be done in a manner to assure that the party is aware of the water use swimming
restrictions when this product is applied to water. The following is an example of a
notification via posting, but other methods of notification which convey the above
restrictions may be used and may be required in some cases under state or local law or as a
condition of a permit.

Example:
Posting notification should be located every 250 feet including the shoreline of the treated
area and up to 250 feet of shoreline past the application site to include immediate public
access points.

Text of Notification: Do not swim in treated water for a minimum of 24 hours after
application. Application Date:	Time:	.

4. Except as stated above, there are no restrictions on using water from treated areas for
swimming, fishing, watering livestock or domestic purposes."
Directions for Use
Associated with the
Specific Use Pattern
                                                            Page 124 of  304

-------
Use-Specific Application
Restrictions

(Note: The maximum
allowable application rate must
be listed as pounds or gallons
of formulated product per acre-
foot, not just as pounds acid
equivalent per acre-foot.)















> "Submersed Weeds
Maximum of 10.8 Ibs ae/per acre-foot per application.
Limited to 2 applications per season.
Apply to aquatic weeds in ponds, lakes, reservoirs, marshes, bayous, drainage ditches, non-
irrigation canals, rivers, and streams that are quiescent or slow moving.
Do not apply within 21 days of previous application.
When treating moving bodies of water, applications must be made while traveling
upstream to prevent concentration of 2,4-D downstream from the application.
Coordination and approval of local and state authorities may be required, either by letter of
agreement or issuance of special permits for such use.
Table 1. Amount of 2,4-D to Apply for a Target Subsurface Concentration
Surface Area









Average Depth



1ft.
2ft.

3ft.
4ft.
5ft.
For typical
conditions - 2 ppm
2,4-D ae/acre-foot

5.4 Ibs
10.8 Ibs

16.2 Ibs
21.6 Ibs
27.0 Ibs
For difficult
conditions* - 4
ppm 2,4-D ae/acre-
foot
10.8 Ibs
21.6 Ibs

32.4 Ibs
43.2 Ibs
54.0 Ibs
* Examples include spot treatment of pioneer colonies of Eurasian Water Milfoil and
certain difficult to control aquatic species.
Directions for Use
Associated with the
Specific Use Pattern


















Page 125 of 304

-------
Use-Specific Application
Restrictions
Water Use:
1. Water for irrigation or sprays:
A. If treated water is intended to be used only for crops or non-crop areas that are labeled
for direct treatment with 2,4-D such as pastures, turf, or cereal grains, the treated water may
be used to irrigate and/or mix sprays for these sites at anytime after the 2,4-D aquatic
application.

B. Due to potential phytotoxicity and/or residue considerations, the following restrictions
are applicable:
If treated water is intended to be used to irrigate or mix sprays for unlabeled crops, non-
crop areas or other plants not labeled for direct treatment with 2,4-D, the water must not be
used unless one of the following restrictions has been observed:

i. A setback distance described in the Drinking Water Setback Table was used for the
application, or,
ii. A waiting period of 21 days from the time of application has elapsed, or,
iii. An approved assay indicates that the 2,4-D concentration is 100 ppb (0.1 ppm) or less at
the water intake. See Table 3 for the waiting period after application but before taking the
initial sampling at water intake.

2. Drinking water (potable water):
A. Consult with appropriate state or local water authorities before applying this product to
public waters. State or local agencies may require permits.
Directions for Use
Associated with the
Specific Use Pattern
                                                             Page 126 of 304

-------
Use-Specific Application
Restrictions
The potable water use restrictions on this label are to ensure that consumption of water by
the public is allowed only when the concentration of 2,4-D in the water is less than the
MCL (Maximum Contaminant Level) of 70 ppb. Applicators should consider the unique
characteristics of the treated waters to assure that 2,4-D concentrations in potable water do
not exceed 70 ppb at the time of consumption.

B. For submersed weed applications, the drinking water setback distances from
functioning potable water intakes are provided in Table 2. Drinking Water Setback
Distance (below).

C. If no setback distance from the Drinking Water Setback Table (Table 2) is to be used for
the application, applicators or the authorizing organization must provide a drinking water
notification and an advisory to shut off all potable water intakes prior to a 2,4-D
application. Notification to the party responsible for a public water supply or to individual
private water users must be done in a manner to assure that the party is aware of the water
use restrictions when this product is applied to potable water. The following is an example
of a notification via posting, but other methods of notification which convey the above
restrictions may be used and may be required in some cases under state or local law or as a
condition of a permit.
Directions for Use
Associated with the
Specific Use Pattern
                                                            Page 127 of  304

-------
Use-Specific Application
Restrictions
Example:
Posting notification should be located every 250 feet including the shoreline of the treated
area and up to 250 feet of shoreline past the application site to include immediate public
access points. Posting should include the day and time of application. Posting may be
removed if analysis of a sample collected at the intake no sooner than stated in Table 3
(below) shows that the concentration in the water is less than 70 ppb (100 ppb for irrigation
or sprays), or after 21 days following application, whichever occurs first.

Text of notification: Wait 21 days before diverting functioning surface water intakes from
the treated aquatic site to use as drinking water, irrigation, or sprays, unless water at
functioning drinking water intakes is tested no sooner than (insert days from Table 3) and is
demonstrated by assay to contain not more than 70 ppb 2,4-D (100 ppb for irrigation or
sprays).
Application Date:	Time:	.

D. Following each application of this product, treated water must not be used for drinking
water unless one of the following restrictions has been observed:
i. A setback distance described in the Drinking Water Setback Distance Table was used for
the application, or,

ii. A waiting period of at least 21 days from the time of application has elapsed, or,
Directions for Use
Associated with the
Specific Use Pattern
                                                            Page 128 of 304

-------
Use-Specific Application
Restrictions
iii. An approved assay indicates that the 2,4-D concentration is 70 ppb (0.07 ppm) or less at
the water intake. Sampling for drinking water analysis should occur no sooner than stated
in Table 3. Analysis of samples must be completed by a laboratory that is certified under
the Safe Drinking Water Act to perform drinking water analysis using a currently approved
version of analytical Method Number 515, 555, other methods for 2,4-D as may be listed in
Title 40 CFR, Part  141.24, or Method Number 4015 (immunoassay of 2,4-D) from U.S.
EPA Test Methods for Evaluating Solid Waste SW-846.

E. Note: Existing potable water intakes that are no longer in use, such as those replaced by
a connection to a municipal water system or a potable water well, are not considered to be
functioning potable water intakes.

F. Drinking water setback distances do not apply to terrestrial applications of 2,4-D
adjacent to water bodies with potable water intakes.
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 129 of  304

-------
Use-Specific Application
Restrictions
Use-Specific Application
Restrictions
3. Swimming (2,4-D butoxyethanol ester only):
A. Do not swim in treated water for a minimum of 24 hours after application.
B. Users must provide the following notification prior to performing a 2,4-D BEE
application. Notification to the party responsible for the public swimming area or to
individual private users must be done in a manner to assure that the party is aware of the
water use swimming restrictions when this product is applied to water. The following is an
example of a notification via posting, but other methods of notification which convey the
above restrictions may be used and may be required in some cases under state or local law
or as a condition of a permit.
Example:
Posting notification should be located every 250 feet including the shoreline of the treated
area and up to 250 feet of shoreline past the application site to include immediate public
access points.
Text of Notification: Do not swim in treated water for a minimum of 24 hours after
application. Application Date: Time:
4. Except as stated above, there are no restrictions on using water from treated areas for
swimming, fishing, watering livestock or domestic purposes."
Table 2. Drinking Water Setback Distance
for Submersed Weed Applications
Application Rate and Minimum Setback Distance (feet) From Functioning Potable Water
Intake
Directions for Use
Associated with the
Specific Use Pattern
Directions for Use
Associated with the
Specific Use Pattern
Page 130 of 304

-------

1 ppm*
600
2 ppm*
1200
3 ppm*
1800
4 ppm*
2400
* ppm acid equivalent target water concentration

Table 3. Sampling for Drinking Water Analysis After 2,4-D Application for
Submersed Weed Applications
Minimum Days After Application Before Initial Water Sampling at the Functioning
Potable Water Intake
1 ppm*
5
2 ppm*
10
3 ppm*
10
4 ppm*
14
* ppm acid equivalent target water concentration"

Page 131 of 304

-------
Use-Specific Application
Restrictions
(Note: The maximum
allowable application rate must
be listed as pounds or gallons
of formulated product per acre,
not just as pounds acid
equivalent per acre.
"Asparagus"
Permitted forms of 2,4-D include acid, salts, and amines.
"The preharvest interval (PHI) is 3 days.
Limited to 2 applications per crop cycle.
Maximum of 2.0 Ib ae/acre per application
Minimum of 30 days between applications."

"Blueberry, low bush"
Permitted forms of 2,4-D include acid, salts, and amines.
"Postemergence:
Limited to one postemergence application per year.
Maximum of 0.0375 Ibs ae/gallons of spray solution per application.

Postharvest:
Limited to one postharvest application per year.
Maximum of 1.0 Ibs ae/gallon spray solution per application.
For spot or directed wipe treatment only.
Apply only in non-bearing years."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 132 of 304

-------
Use-Specific Application
Restrictions

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Blueberry, high bush"
Permitted forms of 2,4-D include acid, salts, and amines.
"The preharvest interval (PHI) is 30 days.
Postemergence and postharvest:
Limited to 2 applications per year.
Maximum of 1.4 Ibs ae/acre per application."

"Cereal Grains (wheat, barley, millet, oats, and rye)"
Permitted forms of 2,4-D include acid, salts, amines, and esters.
"The preharvest interval (PHI) is 14 days.

Postemergence:
Limited to one postemergence application per crop cycle.
Maximum of 1.25 Ibs ae/acre per application.

Preharvest:
Limited to one preharvest application per crop cycle.
Maximum of 0.5 Ibs ae/acre per application.

Limited to 1.75 Ibs ae/acre per crop cycle."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 133 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Citrus (growing fruit)
Permitted form of 2,4-D is isopropyl ester.

"The preharvest interval (PHI) is 7 days.

-To increase fruit size on growing Navel oranges, Valencia oranges, and grapefruit:
Limited to one application per crop cycle.
Maximum of 45 grams ae per acre (0.1 Ibs ae/acre).

-To reduce pre-harvest fruit drop on growing Navel oranges, Valencia oranges, and
grapefruit:
Limited to one application per crop cycle.
Maximum rate of 200 ppm per application.

-To prevent pre-harvest drop of mature fruit and leaves on lemons. Navel oranges. Valencia
oranges, and Tangelos:
Limited to one application per crop cycle.
Maximum rate of 24 ppm per application."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 134 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
Postharvest Citrus Treatment
Permitted form of 2,4-D is isopropyl ester.
"Permitted application methods include dip or spray.

Postharvest packing house application to lemons:
Limited to one application per crop.
Maximum rate of 500 ppm per application."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 135 of  304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Corn, field and pop"
Permitted forms of 2,4-D include acid, salts, amines, and esters.
"Do not use treated crop as fodder for 7 days following application.
The preharvest interval (PHI) is 7 days.
Maximum of 3 Ibs ae/acre per crop cycle.

Preplant or preemergence:
Limited to one preplant or preemergence application per crop cycle.
Maximum of 1.0 Ib ae/acre per application.

Postemergence:
Limited to one postemergence application per crop cycle.
Maximum of 0.5 Ib ae/acre per application.

Preharvest:
Limited to one preharvest application per crop cycle.
Maximum of 1.5 Ibs ae/acre per application."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 136 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Corn, sweet"
Permitted forms of 2,4-D include acid, salts, amines, and esters.
"Do not use treated crop as fodder for 7 days following application.
The preharvest interval (PHI) is 45 days.
Minimum of 21 days between applications.
Maximum of 1.5 Ibs ae/acre per crop cycle.

Preplant or preemergence:
Limited to one preplant or preemergence application per crop cycle.
Maximim of 1.0 Ib ae/acre per application.

Postemergence:
Limited to one postemergence application per crop cycle.
Maximum of to 0.5 Ib ae/acre per application."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 137 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Cranberries"
Permitted forms of 2,4-D include acid, salts, amines, and esters.
"The preharvest interval (PHI) is 30 days.

Dormant Season:
Limited to one application per crop cycle.
Maximum of 4.0 Ibs ae/acre per dormant season

Postemergence:
Limited to 2 applications per crop cycle.
Maximum of 1.2 Ibs ae/acre per postemergence application."

"Filberts"
Permitted forms of 2,4-D include acid, salts, and amines.
"The preharvest interval (PHI) is 45 days.
Minimum of 30 days between applications.
Limited to 4 applications per year.
Maximum of 1.0 Ibs ae per 100 gallons of spray solution per application.

"Fallowland (crop stubble on idle land, or postharvest to crops, or between crops)"
Permitted forms of 2,4-D include acid, salts, amines, and esters.
"Plant only labeled crops within 29 days following application.
Limited to 2 applications per year.
Maximum of 2.0 Ibs ae/acre per application.
Minimum of 30 days between applications."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 138 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds  acid equivalent per
acre.)
"Forestry (forest site preparation, forest roadsides, brush control, established conifer
release, Chrismas trees, reforestation areas)"
Permitted forms of 2,4-D include acid, salts, amines, and esters.

Broadcast application:
Limited to 1 broadcast application per year.
Maximum of 4.0 Ibs ae/acre per broadcast application.

Basal spray, Cut Surface - Stumps, and Frill:
Limit of one basal spray or cut surface application per year.
Maximum of 8.0 Ibs ae per 100 gallons of spray solution.

Injection:
Limit to one injection application per year.
Maximum of 2 ml of 4.0 Ibs ae formulation per injection site."

"Grapes"
Permitted forms of 2,4-D include acid, salts, and amines.
"For use only in California.
The preharvest interval (PHI) is 100 days.
Limited to 1 application per crop cycle.
Maximum of 1.36 Ibs ae/acre per application."
Directions for Use
Associated with the
Specific Use Pattern
                                                            Page 139 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Grasses (pastures and rangeland not in agricultural production)"
Permitted forms of 2.4-D include acid, salts, amines, and esters.
"The preharvest interval (PHI) is 7 days (cut forage for hay).

Postemergence:
Limited to 2 applications per year.
Maximum of 2.0 Ibs ae/acre per application.
Minimum of 30 days between applications.
If grass is to be cut for hay, Agricultural Use Requirements for the Worker Protection
Standard are applicable.
For program lands, such as Conservation Reserve Program, consult program rules to
determine whether grass or hay may be used.  The more restrictive requirements of the
program rules or this label must be followed."
                               "Hops"
                               Permitted forms of 2,4-D include acid and amines.
                               "The preharvest interval (PHI) is 28 days.
                               Postemergence:
                               Limited to 3 applications per crop cycle.
                               Maximum of 0.5 Ib ae/acre per application.
                               Maximum of 1.5 Ibs ae/acre per crop cycle.
                               Minimum of 30 days between applications."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 140 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Non-Cropland (fencerows, hedgerows, roadsides, ditches, rights-of-way, utility
power lines, railroads, airports, and industrial sites)"
Permitted forms of 2,4-D include acid, salts, amines, and esters.

"Postemergence (annual and perennial weeds):
Limited to 2 applications per year.
Maximum of 2.0 Ibs ae/acre per application.
Minimum of 30 days between applications.

Postemergence (woody plants):
Limited to 1 application per year.
Maximum of 4.0 Ibs ae/acre per year.

Applications to non-cropland areas are not applicable to treatment of commercial timber or
other plants being grown for sale or other commercial use, or for commercial seed
production, or for research purposes."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 141 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Pasture and Rangeland (established grass pastures, rangeland, and perennial
grasslands not in agricultural production)"
Permitted forms of 2,4-D include acid, salt, amines, and esters.
"Do not cut forage for hay within 7 days of application.

Postemergence:
For susceptible annual and biennial broadleaf weeds: Use 1.0 Ibs ae/acre per application.
For moderately susceptible biennial and perennial broadleaf weeds: Use 1.0 to 2.0 Ibs
ae/acre per application.
For difficult to control weeds and woody plants: Use 2.0 Ibs ae/acre per application.
Spot treatment: Use 2.0 Ibs ae/acre.
Maximum of two applications per year.
Maximum of 4.0 Ibs ae/acre per year.
Minimum of 30 days between applications.
If grass is to be cut for hay, Agricultural Use Requirements for the Worker Protection
Standard are applicable."
                               "Pistachios"
                               Permitted forms of 2,4-D include acid, salts, and amines.
                               "Do not cut orchard floor forage for hay within 7 days of application.
                               The preharvest interval (PHI) is 60 days.

                               Postemergence:
                               Limited to 2 applications per year.
                               Maximum of 2.0 Ibs ae/acre per application.
                               Minimum of 30 days between applications."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 142 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Pome Fruits"
Permitted forms of 2,4-D include acid, salts, and amines.
"The preharvest interval (PHI) is 14 days.
Do not cut orchard floor forage for hay within 7 days of application.

Postemergence:
Limited to 2 applications per crop cycle.
Maximum of 2.0 Ibs ae/acre per application.
Minimum of 75 days between applications."

"Potatoes"
Permitted forms of 2,4-D include acid, salts, amines, and esters.
"Only for use on potatoes intended for fresh market.
The preharvest interval (PHI) is 45 days.

Postemergence:
Limited to 2 applications per crop cycle.
Maximum of 0.07 Ib ae/acre per application.
Minimum of 10 days between applications."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 143 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Rice"
Permitted forms of 2,4-D include acid, salts, and amines.
"The preharvest interval (PHI) is 60 days.
Maximum of 1.5 Ibs ae/acre per crop cycle."

Preplant:
Limited to one preplant application per crop cycle.
Maximum of 1.0 Ibs ae/acre per preplant application..

Postemergence:
Limited to one postemergence application per crop cycle.
Maximum of 1.5 Ibs ae/acre per postemergence application.
                               "Rice, wild"
                               Permitted forms of 2,4-D include acid, salts, and amines.
                               "For use in Minnesota only.
                               The preharvest interval (PHI) is 60 days.

                               Postemergence:
                               Limited to 1 application per crop cycle .
                               Maximum of 0.25 Ib ae/acre per application."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 144 of  304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Sorghum"
Permitted forms of 2,4-D include acid, salts, amines, and esters.
"The preharvest interval (PHI) is 30 days.
Do not permit meat or dairy animals to consume treated crop as fodder or forage for 30
days following application.

Postemergence (acid, salts, and amines):
Limited to 1 application per crop cycle.
Maximum of 1.0 Ib ae/acre per application.

Postemergence (esters):
Limited to 1 application per crop cycle.
Maximum of 0.5 Ib ae/acre per application."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 145 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds  acid equivalent per
acre.)
"Soybeans"
Permitted forms of 2,4-D include acid, salts, amines, and esters.
"The maximum rate per crop cycle is 1.0 Ib ae/acre.
Preplant:
Limited to 2 preplant applications per crop cycle.
Maximum of 0.5 Ib ae/acre per preplant application.
> Esters: Apply not less than 7 days prior to planting soybeans.
>Amines, acid, salts: Apply not less than 15 days prior to planting soybeans.'
 or
"Preplant:
Limited to 1 application per crop cycle.
Maximum of 1.0 ae/acre per preplant application.
>Esters: Apply not less than 15 days prior to planting soybeans.
>Amines, acid, salts: Apply not less than 30 days prior to planting soybeans.'

"Stone Fruits"
Permitted forms of 2,4-D include acid, salts, and amines.
"The preharvest interval (PHI) is 40 days.
Do not cut orchard floor forage for hay within 7 days of application.

Postemergence:
Limited to 2 applications per crop cycle.
Maximum of 2.0 Ib ae/acre per application.
Minimum of 75 days between applications."
Directions for Use
Associated with the
Specific Use Pattern
                                                            Page 146 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Strawberry"
Permitted forms of 2,4-D include acid, salts, and amines.
"Do not apply in California or Florida.
Dormant or after last picking:
Limited to 1 application per crop cycle.
Maximum of 1.5 Ibs ae/acre per application."

"Sugarcane"
Permitted forms of 2,4-D include acid, salts, and amines.
"Do not harvest cane prior to crop maturity.
Do not apply more than 4 Ibs ae/acre per crop cycle.

Preemergence:
Limited to one application per crop cycle.
Maximum of 2.0 Ibs ae/acre per application.

Postemergence:
Limited to one application per crop cycle.
Maximum of 2.0 Ibs ae/acre per application.."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 147 of 304

-------
Other Application Restrictions
(Risk Mitigation)

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds acid equivalent per
acre.)
"Tree Nuts"
Permitted forms of 2,4-D include acid, salts, and amines.
"The preharvest interval (PHI) is 60 days.
Do not cut orchard floor forage for harvest within 7 days of application.

Postemergence:
Limited to 2 applications per crop cycle
Maximum of 2.0 Ibs ae/acre per application.
Minimum of 30 days between applications."

"Turf, ornamental (golf courses, cemetaries, parks, sports fields, turfgrass, lawns and
other grass areas)"
Permitted forms of 2,4-D include acid, salts, amines, and esters.

"Postemergence:
Limited to 2 applications per year.
Maximum of 1.5 Ibs ae/acre per application.
The maximum seasonal rate is 3.0 Ibs ae/acre, excluding spot treatments."

"Turf, grown for seed or sod"
Permitted forms of 2,4-d include acid, salts, amines, and esters.

"Limited to 2 applications per year.
Maximum of 2.0 Ibs ae/acre per application.
Minimum of 21 days between applications."
Directions for Use
Associated with the
Specific Use Pattern
                                                           Page 148 of 304

-------
Spray Drift
"SPRAY DRIFT MANAGEMENT"

 "A variety of factors including weather conditions (e.g., wind direction, wind speed,
temperature, relative humidity) and method of application (e.g., ground, aerial, airblast,
chemigation) can influence pesticide drift.  The applicator must evaluate all factors and
make appropriate adjustments when applying this product."

Droplet Size
 "When applying sprays that contain 2,4-D as the sole active ingredient, or when applying
sprays that contain 2,4-D mixed with active ingredients that require a Coarse or coarser
spray, apply only as a Coarse or coarser spray (ASAE standard 572) or a volume mean
diameter of 385 microns or greater for spinning atomizer nozzles."

 "When applying sprays that contain 2,4-D mixed with other active ingredients that require
a Medium or more fine spray, apply only as a Medium or coarser spray (ASAE standard
572) or a volume mean diameter of 300 microns or greater for spinning atomizer nozzles."

Wind Speed
 "Do not apply at wind speeds greater than 15 mph. Only apply this product if the wind
direction favors on-target deposition and there are not sensitive areas (including, but not
limited to, residential areas, bodies of water, known habitat for nontarget species, nontarget
crops) within 250 feet downwind.  If applying a Medium spray, leave one swath unsprayed
at the downwind edge of the treated field."
Directions for Use
                                                           Page 149 of  304

-------
Temperature Inversions
 "If applying at wind speeds less than 3 mph, the applicator must determine if: a)
conditions of temperature inversion exist, or b) stable atmospheric conditions exist at or
below nozzle height. Do not make applications into areas of temperature inversions or
stable atmospheric conditions."

Susceptible Plants
 "Do not apply under circumstances where spray drift may occur to food, forage, or other
plantings that might be damaged or crops thereof rendered unfit for sale, use or
consumption. Susceptible crops include, but are not limited to, cotton, okra, flowers,
grapes (in growing stage), fruit trees (foliage), soybeans (vegetative stage), ornamentals,
sunflowers, tomatoes, beans, and other vegetables, or tobacco. Small amounts of spray
drift that might not be visible may  injure susceptible broadleaf plants."

Other State and Local Requirements
 "Applicators must follow all state and local pesticide drift requirements regarding
application of 2,4-D herbicides.  Where  states have more stringent regulations, they must be
observed."

Equipment
 "All aerial and ground application equipment must be properly maintained and calibrated
using appropriate carriers or surrogates."

Additional requirements for aerial applications:

 "The boom length must not exceed 75% of the wingspan or 90% of the rotor blade
diameter."
                            Page 150 of 304

-------
                                 "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 unless a greater height
                               is required for aircraft safety. This requirement does not apply to forestry or rights-of-way
                               applications."

                                 "When applications are made with a crosswind, the swath will be displaced downwind.
                               The applicator must compensate for this by adjusting the path  of the aircraft upwind."
                               Additional requirements for ground boom application:
                                 "Do not apply with a nozzle height greater than 4 feet above the crop canopy."
                               Additional requirements for liquid products applied as a spray and containing an ester
                               form of2,4-D (e.g. 2,4-D butoxyethyl ester, 2,4-D ethylhexyl ester, 2,4-D isopropyl ester):

                                 "2,4-D esters may volatilize during conditions of low humidity and high temperatures.
                               Do not apply during conditions of low humidity and high temperatures."

Application Restrictions
"Do not apply this product in a way that will contact any person or pet, either directly or
through drift.  Keep people and pets out of the area during application."
Directions for Use
under General
Precautions and
Restrictions
Entry Restrictions for liquids,
water-dispersible granules, and
wettable powders formulated
in water-soluble packages
"Do not allow people or pets to enter the treated area until sprays have dried."
Directions for use
under General
Precautions and
Restrictions
                                                            Page 151  of 304

-------
 Entry Restrictions for granular
 formulations
"Do not allow people or pets to enter the treated area until dusts have settled."
Directions for use
under General
Precautions and
Restrictions
 Environmental Hazard
 Statement for Residential Use
 labels
"This pesticide is toxic to fish and aquatic invertebrates. Do not apply directly to water, to
areas where surface water is present, or to intertidal areas below the mean high water mark
except as noted on appropriate labels.  Drift and runoff may be hazardous to aquatic
organisms in water adjacent to treated areas.  Do not contaminate water when disposing of
equipment wash waters or rinsate.2

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
Safety
Recommendations
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.
2 May be deleted for ready-to-use products.
                                                            Page 152 of 304

-------
VL Appendicies
                                 Page 153 of 304

-------
Appendix A.  Table of 2,4-D Use Patterns Eligible for Reregistration (Case 0073)
                                    Page 154 of 304

-------
Appendix A. Use Patterns Subject to Reregistration for 2,4-D (Case 0073)
Use Site





Aquatic
weed control
- Ditchbank
application






Aquatic
weed control
- floating
and

emergent
weeds







Formulation





Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid,
Soluble
concentrate -
solid,
Granular
Wettable powder,
Emulsifiable
concentrate,

Soluble
concentrate -
liquid,
Soluble
concentrate -
solid,
Granular



Max.
Single
App.
Rate


2.0









4.0













Unit





Lbs ae/acre









Lbs
ae/surface
acre











Max. #
App. Per
Crop
Cycle/Yea


2 per season









2 per season













Max. App.
Rate Per
Crop
Cycle/Year


4.0 Ibs
ae/acre








8.0 Ibs
ae/surface
acre











Min.
Retreatm
ent
Interval
(days)

30









21













Reentry
Interval (REI)




NA









NA













Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
NA









NA













Restrictions/Comments





See Label Changes Summary Table
in 2,4-D RED.








Apply to aquatic weeds in ponds,
lakes, reservoirs, marshes, bayous,
drainage ditches, non-irrigation
canals, rivers, and streams that are

quiescent or slow moving.

Coordination and approval of local
and state authorities may be required,
either by letter of agreement or
issuance of special permits for such
use.
See Label Changes Summary Table
in 2,4-D RED.
                                                    Page 155 of 304

-------
Use Site




Aquatic
weed control
- submersed
weeds














Asparagus






Formulation




Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid,
Soluble
concentrate -
solid,
Granular








Wettable powder,
Emulsifiable
concentrate,
soluble
concentrate -
liquid, soluble
concentrate - solid
Max.
Single
App,
Rate

10.8

















2.0






Unit




Lbs ae per
acre-foot
















Lbs ae/acre






Max. #
App. Per
Crop
Cycle/Yea
r

2 per season

















2 per crop
cycle





Max. App.
Rate Per
Crop
Cycle/Year

21.61bsae
per acre-foot
per season















4.0 Ibs
ae/acre





Min.
Retreatm
ent
Interval
(days)

21

















30






Reentry
Interval (REI)



24 hour
swimming
restriction for
2,4-D BEE form














2,4-D acid and
amines -48
hours;
2,4-D salt and
esters - 12 hours


Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
NA

















NA






Restrictions/Comments




Apply to aquatic weeds in ponds,
lakes, reservoirs, marshes, bayous,
drainage ditches, non-irrigation
canals, rivers, and streams that are
quiescent or slow moving.

When treating moving bodies of
water, applications must be made
while traveling upstream to prevent
concentration of 2,4-D downstream
of the application.
Coordination and approval of local
and state authorities may be required,
either by letter of agreement or
issuance of special permits for such
use.
See Label Changes Summary Table
in 2,4-D RED.
See Label Changes Summary Table
in 2,4-D RED.





Page 156 of 304

-------
Use Site




Blueberry,
low bush





Blueberry,
high bush





Formulation




Wettable powder,
Emulsifiable
concentrate,
soluble
concentrate -
liquid, soluble
concentrate - solid

Wettable powder,
Emulsifiable
concentrate,
soluble
concentrate -
liquid, soluble
concentrate - solid
Max.
Single
App,
Rate

Postemerg
ence:
0.0375

Postharves
t:
1.0
1.4






Unit




Ibs ae per
gallon spray
solution per
application



Lbs ae/acre






Max. #
App. Per
Crop
Cycle/Yea
r

Postemergen
ce: 1

Postharvest:
1


2 per year






Max. App.
Rate Per
Crop
Cycle/Year

0.0375 Ibs ae
per gallon
spray
solution



2.8 Ibs
ae/acre





Min.
Retreatm
ent
Interval
(days)

NA






NS






Reentry
Interval (REI)



2,4-D acid and
amines -48
hours;
2,4-D salt and
esters - 12 hours


2,4-D acid and
amines -48
hours;
2,4-D salt and
esters - 12 hours


Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
NA






PHI - 30 days






Restrictions/Comments




Postharvest: For spot or directed wipe
treatment only.
Apply only in non-bearing years.

See Label Changes Summary Table
in 2,4-D RED.

See Label Changes Summary Table
in 2,4-D RED





Page 157 of 304

-------
Use Site



Citrus,
growing fruit
























Formulation



Emulsifiable
concentrate
























Max.
Single
App,
Rate

To
increase
fruit size
on
growing
Navel
oranges,
Valencia
oranges,
and
grapefruit:
0,1

To reduce
pre-
harvest
fruit drop
on
growing
Navel
oranges,
Valencia
oranges,
and
grapefruit:
200
Unit



To increase
fruit size on
growing
Navel
oranges,
Valencia
oranges, and
grapefruit:
Ibs ae/acre

To reduce
pre-harvest
fruit drop on
growing
Navel
oranges,
Valencia
oranges, and
grapefruit:
ppm






Max. #
App. Per
Crop
Cycle/Yea
r

1 per crop
cycle
























Max. App.
Rate Per
Crop
Cycle/Year

same as
max. single
app. rate























Min.
Retreatm
ent
Interval
(days)

NA

























Reentry
Interval (REI)


12 hours

























Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
PHI - 7 days

























Restrictions/Comments



See Label Changes Summary Table
in 2,4-D RED
























Page 158 of 304

-------
Use Site




















Citrus,
postharvest
treatement


Corn, field
and pop







Formulation




















Emulsifiable
concentrate



Wettable powder,
Emulsifiable
concentrate,
Granular, Soluble
concentrate -
liquid, Soluble
concentrate - solid




Max.
Single
App.
Rate

To
prevent
pre-
harvest
drop of
mature
fruit and
leaves on
lemons,
Navel
oranges,
Valencia
oranges,
and
Tangelos:
24
500




Preplant
or
preemerge
nee: 1.0
Postemerg
ence: 0.5

Preharvest
: 1.5
Unit




To prevent
pre-harvest
drop of
mature fruit
and leaves
on lemons,
Navel
oranges,
Valencia
oranges, and
Tangelos:
ppm




ppm




Lbs ae/acre








Max. #
App. Per
Crop
Cycle/Yea
r

1















l




Preplant or
preemergenc
e: 1

Postemergen
ce: 1

Preharvest: 1


Max. App.
Rate Per
Crop
Cycle/Year

same as
max. single
app. rate













500 ppm




3.0 Ibs
ae/acre







Min.
Retreatm
ent
Interval
(days)

















NA




NA








Reentry
Interval (REI)



















NA




2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours




Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
















NA




PHI - 7 days
PGI - 7 days







Restrictions/Comments




















Application methods include dip or
spray

See Label Changes Summary Table
in 2,4-D RED
See Label Changes Summary Table
in 2,4-D RED







Page 159 of 304

-------
Use Site




Corn, sweet





Cranberries











Filberts






Formulation




Wettable powder,
Emulsifiable
concentrate,
Granular, Soluble
concentrate -
liquid, Soluble
concentrate - solid
Wettable powder,
Emulsifiable
concentrate,
Granular, Soluble
concentrate -
liquid, Soluble
concentrate - solid





Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid
Max.
Single
App.
Rate

Preplant
or
preemerge
nee: 1.0
Postemerg
ence: 0.5
Dormant
season:
4.0

Postemerg
ence: 1.2






1.0






Unit




Lbs ae/acre





Dormant
season: Ibs
ae/acre per
dormant
season

Postemergen
ce: Ibs
ae/acre per
postemergen
ce
application
Ibs ae per
100 gallons
of spray
solution



Max. #
App. Per
Crop
Cycle/Yea
r

Preplant or
preemergenc
e: 1

Postemergen
ce: 1

Dormant
season: 1

Postemergen
ce:2







4






Max. App.
Rate Per
Crop
Cycle/Year

1.5 Ibs
ae/acre per
crop cycle



Dormant
season: 4 Ibs
ae/acre per
dormant
season

Postemergen
ce: 2.4 Ibs
ae/acre per
postemergen
ce
application
4.0 Ibs ae per
100 gallons
of spray
solution per
year


Min.
Retreatm
ent
Interval
(days)

21





NS











30






Reentry
Interval (REI)



2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours

2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours







2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours


Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
PHI - 45 days
PGI - 7 days




PHI - 30 days











PHI - 45 days






Restrictions/Comments




See Label Changes Summary Table
in 2,4-D RED




See Label Changes Summary Table
in 2,4-D RED










See Label Changes Summary Table
in 2,4-D RED





Page 160 of 304

-------
Use Site




Fallowland
(crop stubble
on idle land,
or
postharvest
to crops, or
between
crops)
Forestry
(forest site
preparation,
forest
roadsides,
brush
control,
established
conifer
release,
Christmas
trees,
reforestation
areas)





Grapes







Formulation




Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid

Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid











Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid

Max.
Single
App,
Rate

2.0





Broadcast:
4.0

Basal
spray, cut
surface -
stumps,
frill: 8.0

Injection:
2







1.36







Unit




Lbs ae/acre





Broadcast:
Ibs ae/acre

Basal spray,
cut surface -
stumps, frill:
Ibs ae per
100 gallons
of spray
solution

Injection: ml
of 4.0 Ibs ae
formulation
per injection
site


Ibs ae/acre







Max. #
App. Per
Crop
Cycle/Yea
r

2 per year





1 per year














1 per crop
cycle






Max. App.
Rate Per
Crop
Cycle/Year

4.0 Ibs
ae/acre per
year



Broadcast:
4.0 Ibs
ae/acre per
year
Basal spray,
cut surface -
stumps, frill:
Ibs ae per
100 gallons
of spray
solution


Injection: ml
of 4.0 Ibs ae
formulation
per injection
site
1.36 Ibs
ae/acre per
year





Min.
Retreatm
ent
Interval
(days)

30





NA














NA







Reentry
Interval (REI)



2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours


2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours











2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours



Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
NS





NA














PHI - 100 days







Restrictions/Comments




Plant only label crops within 29 days
following application.

See Label Changes Summary Table
in 2,4-D RED


See Label Changes Summary Table
in 2,4-D RED













For use in California only.

Do not apply to grape foliage, shoots,
or stems.


See Label Changes Summary Table
in 2,4-D RED
Page 161 of 304

-------
Use Site




Grasses
(pastures and
rangeland
not in
agricultural
production)









Hops






Formulation




Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid








Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid
Max.
Single
App,
Rate

2.0














0.5






Unit




Lbs ae/acre














Lbs ae/acre






Max. #
App. Per
Crop
Cycle/Yea
r

2 per year














3 per crop
cycle





Max. App.
Rate Per
Crop
Cycle/Year

4.0 Ibs
ae/acre per
year












1.5 Ibs
ae/acre per
crop cycle




Min.
Retreatm
ent
Interval
(days)

30














NS






Reentry
Interval (REI)



2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours










2,4-D acid and
amines - 48
hours




Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
PHI - 7 days














PHI - 28 days






Restrictions/Comments




Do not cut forage for hay within 7
days of application.
If grass is to be cut for hay,
Agricultural Use Requirements for
the Worker Protection Standard are
applicable.
For program lands, such as
Conservation Reserve Program,
consult program rules to determine
whether grass or hay may be used.
The more restrictive requirements of
the program rules or this label must
be followed.
See Label Changes Summary Table
in 2,4-D RED
See Label Changes Summary Table
in 2,4-D RED





Page 162 of 304

-------
Use Site




Non-
Cropland
(fenecrows,
hedgerows,
roadsides,
ditches,
rights-of-
way, utility
power lines,
Fell ironic! s ;
airports, and
industrial
sites)
Nut
Orchards





Formulation




Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate -
solid, Granular



Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid
Max.
Single
App,
Rate

Postemerg
ence
(annual
and
perennial
plants): 2
Postemerg
ence
(woody
plants): 4
2.0






Unit




Ibs ae/acre









Lbs ae/acre






Max. #
App. Per
Crop
Cycle/Yea
r

Postemergen
ce (annual
and
perennial
plants): 2

Postemergen
ce (woody
plants): 1


2 per year






Max. App.
Rate Per
Crop
Cycle/Year

4.0 Ibs
ae/acre








4.0 Ibs
ae/acre per
year




Min.
Retreatm
ent
Interval
(days)

Postemerg
ence
(annual
and
perennial
plants): 30
days
Postemerg
ence
(woody
plants):
NA
30






Reentry
Interval (REI)



2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours





2,4-D acid and
amines - 48
hours;
2,4-D salt - 12
hours


Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
NA









NS






Restrictions/Comments




Applications to non-cropland areas
are not applicable to treatment of
commercial timber or other plants
being grown for sale or other
commercial use, or for commercial
seed production, or for research
purposes.
See Label Changes Summary Table
in 2,4-D RED.

Do not cut forage for hay within 7
days of application.

See Label Changes Summary Table
in 2,4-D RED.


Page 163 of 304

-------
Use Site




Pasture and
Rangeland
(established
grass
pastures,
rangeland,
and
perennial
grasslands
not in
agricultural
production)














Pome fruits





Formulation




Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid
















Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid
Max.
Single
App,
Rate

Susceptibl
e annual
and
biennial
broadleaf
weeds: 1.0
Moderate!
y
susceptibi
e biennial

and
perennial
broadleaf

weeus. i .u
to 2.0

Difficult
to control
weeds and
woody
plants: 2.0
Spot
treatment:
2.0
2.0





Unit




Lbs ae/acre




















Lbs ae/acre





Max. #
App. Per
Crop
Cycle/Yea
r

2 per year




















2 per crop
cycle




Max. App.
Rate Per
Crop
Cycle/Year

4.0 Ibs
ae/acre



















4.0 Ibs
ae/acre




Min.
Retreatm
ent
Interval
(days)

30




















75





Reentry
Interval (REI)



2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours

















2,4-D acid and
amines - 48
hours;
2,4-D salt - 12
hours


Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)





















PHI - 14 days





Restrictions/Comments




Do not forage for hay within 7 days
of application.

For program lands, such as
Conservation Reserve Program,
consult program rules to determine
whether grass or hay may be used.
The more restrictive requirements of
the program rules or this label must
be followed.

If grass is to be cut for hay,
Agricultural Use Requirements for
the Worker Protection Standard are

applicable.
See Label Changes Summary Table
in 2,4-D RED.







Do not cut orchard floor forage for
hay within 7 days of application.

See Label Changes Summary Table
in 2,4-D RED.


Page 164 of 304

-------
Use Site




Potatoes






Rice






Rice, wild






Formulation




Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid
Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid

Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid
Max.
Single
App,
Rate

0.07






Preplant:
1.0

Postemerg
ence:
1.5


0.25






Unit




Lbs ae/acre






Lbs ae/acre






Lbs ae/acre






Max. #
App. Per
Crop
Cycle/Yea
r

2 per crop
cycle





Preplant: 1
per crop
cycle

Postemergen
ce: 1 per

crop cycle
1 per crop
cycle





Max. App.
Rate Per
Crop
Cycle/Year

0.14 per crop
cycle





1.5 Ibs
ae/acre per
crop cycle




0.25 Ibs
ae/acre per
crop cycle




Min.
Retreatm
ent
Interval
(days)

10






NA






NA






Reentry
Interval (REI)



2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours


2,4-D acid and
amines - 48
hours;
2,4-D salt - 12
hours


2,4-D acid and
amines - 48
hours;
2,4-D salt - 12
hours


Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
PHI - 45 days






PHI - 60 days






PHI - 60 days






Restrictions/Comments




Only for use on potatoes intended for
fresh market.

See Label Changes Summary Table
in 2,4-D RED.


See Label Changes Summary Table
in 2,4-D RED.





For use in Minnesota only.

See Label Changes Summary Table
in 2,4-D RED.



Page 165 of 304

-------
Use Site




Sorghum











Soybean













Formulation




Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid






Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid








Max.
Single
App,
Rate

Postemerg
ence
(acid,
salts, and
amines):
1.0
Postemerg
ence
(esters):
0.5


1.0













Unit




Lbs ae/acre











Lbs ae/acre













Max. #
App. Per
Crop
Cycle/Yea
r

1 per crop
cycle










1 app. of 1.0
Ibs ae/acre
per crop
cycle
OR

2 apps. Of
0.5 Ibs
ae/acre per
crop cycle




Max. App.
Rate Per
Crop
Cycle/Year

Postemergen
ce (acid,
salts, and
amines): 1.0
Ibs ae/acre
per crop
cycle

Postemergen
ce (esters):
0.5 Ibs
ae/acre per
crop cycle
1.0 Ibs
ae/acre per
crop cycle











Min.
Retreatm
ent
Interval
(days)

NA











NS













Reentry
Interval (REI)



2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours







2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours









Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
PHI - 30 days











_













Restrictions/Comments




Do not permit meat or dairy animals
to consume treated crop as fodder or
forage for 30 days following
application.

See Label Changes Summary Table
in 2,4-D RED.






0.5 Ibs ae/acre rate:
>Esters: Apply not less than 7 days
prior to planting soybeans.
>Amines, acid, salts: Apply not less
than 15 days prior to planting
soybeans.

1.0 Ib ae/acre rate:
>Esters: Apply not less than 15 days
prior to planting soybeans.
>Amines, acid, salts: Apply not less
than 30 days prior to planting
soybeans.
See Label Changes Summary Table
in 2,4-D RED.
Page 166 of 304

-------
Use Site




Stone fruits






Strawberry







Sugarcane






Formulation




Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid
Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid

Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate - solid
Max.
Single
App,
Rate

2.0






1.5







Preemerge
nee: 2.0

Postemerg
ence: 2.0


Unit




Lbs ae/acre






Lbs ae/acre







Lbs ae/acre






Max. #
App. Per
Crop
Cycle/Yea
r

2






1







Preemergenc
e: 1

Postemergen
ce: 1


Max. App.
Rate Per
Crop
Cycle/Year

4.0 Ibs
ae/acre per
crop cycle




1.5 Ibs
ae/acre per
cop cycle





4 Ibs ae/acre
per crop
cycle




Min.
Retreatm
ent
Interval
(days)

75






NA







NS






Reentry
Interval (REI)



2,4-D acid and
amines - 48
hours;
2,4-D salt - 12
hours


2,4-D acid and
amines - 48
hours;
2,4-D salt - 12
hours



2,4-D acid and
amines - 48
hours;
2,4-D salt - 12
hours


Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
PHI - 40 days






-







_






Restrictions/Comments




Do not cut orchard floor forage for
hay within 7 days of application.

See Label Changes Summary Table
in 2,4-D RED.


Do not apply in California or Florida.

Apply in dormant stage or after last
picking.


See Label Changes Summary Table
in 2,4-D RED.
Do not harvest cane prior to crop
maturity.

See Label Changes Summary Table
in 2,4-D RED.


Page 167 of 304

-------
Use Site




Turf,
ornamental
(golf
courses,
cemetaries,
parks, sports
fields,
turfgrass,
lawns, and
other grass
areas)
Turf, grown
for seed or
sod





Formulation




Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate -
solid, Granular



Wettable powder,
Emulsifiable
concentrate,
Soluble
concentrate -
liquid, Soluble
concentrate -
solid, Granular
Max.
Single
App,
Rate

1.5










2.0







Unit




Lbs ae/acre










Lbs ae/acre







Max. #
App. Per
Crop
Cycle/Yea
r

2










2







Max. App.
Rate Per
Crop
Cycle/Year

3.0 Ibs
ae/acre per
year,
excluding
spot
treatments





4.0 Ibs
ae/acre per
crop cycle





Min.
Retreatm
ent
Interval
(days)

NS










21







Reentry
Interval (REI)



NS










2,4-D acid and
amines - 48
hours;
2,4-D salt and
esters - 12 hours



Preharvest
Interval (PHI)
Pre grazing
Interval (PGI)
Preslaughtering
Interval (PSI)
_










_







Restrictions/Comments




See Label Changes Summary Table
in 2,4-D RED.









See Label Changes Summary Table
in 2,4-D RED.






Page 168 of 304

-------
Appendix B. Data Supporting Guideline Requirements for the Reregistration of 2,4-D
                                   Page 169 of 304

-------
                                                 Appendix B
                         Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
Use Patterns
crrATioN(S)
PRODUCT CHEMISTRY
New
Guideline
Number
830.1550
830.1600
830.1620
Old
Guideline
Number
61-1
61-2A
61-2B

Product Identity and Composition
Description of materials used to
produce the product
Description of production process

All
All


41219701, 41223801, 41926201, 43516401, 43516402,
43981801, 40808301, 41219601, 41055804, 41055805,
41220101, 41973501, 41055801, 41055802, 41220101,
41973501, 41067001, 41203301, 41123601, 41055809,
41055810, 41964401, 41055815, 41055816, 41978001,
44807001, 41055818, 41055819, 41055812, 41055813,
41961301, 41055806, 41055807, 41968301, 41015001,
42188601, 42786501, 40443301, 41224201
41223801, 41637501, 41790601, 44149301, 44547901,
43516401, 40808301, 41246701, 41681901, 41796201,
41055804, 41496701, 41055801, 41496701, 41973501,
41067001, 41599401, 42537501, 44184201, 41055809,
41055815, 41055818, 41055812, 44584501, 44963803,
41055806, 44982101, 41015001, 42188601, 41376701,
40443301, 41224201
41223801, 41790601, 44149301, 44547901, 43516401,
40808301, 41246701, 41796201, 41496701, 41055801,
41973501, 41067001, 41599401, 41789901, 42537501,
44184201, 41055809, 41055815, 44727101, 44807001,
41055818, 44228301, 41055812, 44584501, 44963803,
41055806, 44982101, 41015001, 42188601, 41376701,
40443301, 41224201
                                                Page 170 of 304

-------
                         Appendix B
Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
830.1670
830.1700
830.1750
61-2B
62-1
62-2
Formation of Impurities
Preliminary Analysis
Certification of limits
Use Patterns
All
All
All
crrATioN(S)
41223801, 41790601, 44149301, 44547901, 43516401,
40808301, 41246701, 41496701, 41055801, 41973501,
41067001, 41599401, 41789901, 41789902, 41 123601,
42537501, 44184201, 41055809, 41964401, 42798101,
41055815, 41978001, 42798301, 44727101, 44807001,
41055818, 42798201, 44228301, 41055812, 41961301,
44584501, 44963803, 41055806, 41968301, 44982101,
41015001, 42188601, 42786501, 40443301
41219701, 41926201, 41790602, 44149302, 44543502,
44543503, 44932701, 43516401, 43516402, 43981801,
40808301, 41724201, 41724202, 41349001, 41796201,
41796202, 41219601, 41796202, 41055805, 41220101,
41496701, 41973501, 43777501, 44287101, 41055802,
41220101, 41496701, 41973501, 43777502, 44228601,
41067001, 41203301, 41735701, 41123601, 41055810,
41964401, 43314701, 41055816, 41055819, 44620501,
41055813, 44963801, 41349002, 41724201, 41724203,
41055807, 45014801, 41015002, 42188601, 40443301,
41206901
41219701, 41223801, 41926201, 43516401, 43516402,
43981801, 40808301, 41219601, 41055804, 41055805,
41220101, 41496701, 41973501, 41055801, 41055802,
41220101, 41496701, 41973501, 41067001, 41203301,
41599401, 41123601, 41055809, 41055810, 41964401,
41055815, 41055816, 41978001, 44807001, 41055818,
41055819, 41055812, 41055813, 41961301, 44963804,
41055806, 41055807, 41968301, 41015001, 42188601,
40443301, 41206901
                        Page 171 of 304

-------
                         Appendix B
Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
830.1800
830.6302
830.6303
830.6304
830.6313
830.6314
62-3
63-2
63-3
63-4
63-13

Analytical Method
Color
Physical State
Odor
Stability to normal and elevated
temperatures, metals, and metal ions
Oxidation/Reduction: Chemical
Incompatibility
Use Patterns
All
All
All
All
All
All
crrATioN(S)
41219701, 41223801, 41637501, 41926201, 44543502,
44543503, 43516401, 43516402, 43981801, 40808301,
41219601, 41796202, 41055802, 41220101, 41496701,
41055802, 41220101, 41496701, 41067001, 41203301,
41599401, 41789902, 41 123601, 41055810, 41055816,
41055819, 41055813, 449638034, 44963804, 41055807,
44982102, 41015002, 42188601, 42786501, 40443301,
41206901
41223801, 44543504, 43516403, 43516404, 40808301,
41055803, 41067001, 41123601, 42857203, 41055811,
41055817, 41055820, 41055814, 44963802, 41055808,
41015003, 40443301, 41224201
41223801, 44543504, 43516403, 43516404, 40808301,
41055803, 41067001, 41123601, 42857203, 41055811,
41055817, 41055820, 41055814, 44963802, 41055808,
41015003, 40443301, 41224201
41223801, 44543504, 43516403, 43516404, 40808301,
41055803, 41067001, 41123601, 42857203, 41055811,
41055817, 41055820, 41055814, 44963802, 41055808,
41015003, 40443301, 41224201
41223801, 41745301, 42023601, 44543504, 41055803,
41855701, 42023601, 42795401, 43516403, 43516404,
40808301, 41055803, 41855701, 42023601, 42795401,
41055803, 42795401, 41973502, 41067001, 41855701,
42857209, 41978002, 42487901, 41968303, 44963802,
41015003, 42116702, 42786501, 40443301, 41224201
42023601, 43516403, 43516404, 40808301, 41973501,
41067001, 4105581 1, 41055817, 41055820, 41055814,
41968303, 44963802, 41055808, 40443301, 41224201
                        Page 172 of 304

-------
                         Appendix B
Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
830.6315
830.6316
830.6317
830.6319
830.6320
830.7000
830.7050
830.7100
830.7200
830.7220





63-12
None

63-5
63-6
Flammability
Explodability
Storage stability
Miscibility
Corrosion characteristics
PH
TJV/Visable Absorption
Viscosity
Melting Point
Boiling Point
Use Patterns
All
All
All
All

All
All
All
All
All
crrATioN(S)
4105581 1, 41055817, 41055820, 41055814, 41055808,
41015003, 40443301, 41224201
41745302, 43516403, 43516404, 40808301, 41973501,
41067001, 42537501, 4105581 1, 41055817, 41055820,
41055814, 41055808, 41015003, 40443301, 41224201
41745301, 41926203, 43516403, 43516404, 40808301,
43260501, 41067001, 41123601, 42227501, 41055811,
45642701, 41055817, 43874601, 41055820, 41055814,
41055808, 41015003, 42786501, 40443301, 41224201
40443301, 41224201
42023601, 43516403, 43516404, 40808301, 43260501,
41973501, 41067001, 41123601, 42227501, 41055811,
45642701, 41055817, 41055820, 41055814, 41055808,
41015003, 40443301, 41224201
41926202, 44543504, 43516403, 43516404, 40808301,
41 123601, 42857208, 4105581 1, 41055817, 41055820,
41015003, 40443301, 41224201
44543504, Datagap
4105581 1, 41055817, 41055820, 41055814, 41055808,
41015003, 40443301, 41224201
41223801, 44543504, 41055803, 41067001, 41223801,
43516403, 43516404, 40808301, 41055803, 41067001,
42537501, 42857209, 42829901, 42831001, 43325003,
43325001, 42830901, 43325001, 44963802, 43325002,
44963802, 42831 101, 41015003, 40443301, 41224201
                        Page 173 of 304

-------
                                                Appendix B
                        Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT

830.7300


830.7370


830 7550





830.7840





830.7950



63-7


63-10


63-11





63-8





63-9



Density


Dissociation constants in water


Partition coefficient, shake flask
method




Solubility





Vapor Pressure


Use Patterns

All


All


All





All





All


crrATioN(S)
41223801, 44543504, 43516403, 43516404, 40808301,
41055803, 41973501, 41067001, 41855701, 41 123601,
42857204, 41055811, 41055817, 41055820, 41055814,
44963802, 41055808, 41015003, 40443301, 41224201
41223801, 41308901, 44543504, 41055803, 41067001,
41972501, 44543504, 43516403, 43516404, 40808301,
41055803, 41067001, 41332009, 41015003, 41224201
41332004, 44543504, 41332004, 43516403, 43516404,
40808301, 41055803, 41067001, 42537501, 42857207,
41647001, 44963802, 41055808, 44963802, 41055808,
41015003, 42116702, 40443301, 41224201
41223801, 42023601, 41332002, 44543504, 45692501,
41055803, 45692501, 43516403, 43516404, 40808301,
45692501, 41055803, 41067001, 41332002, 41880601,
42537501, 42857205, 43358801, 41055811, 42021002,
41978001, 43358802, 41669501, 42830901, 42831101,
44963802, 41055808, 41968302, 41015003, 42116702 3,
42786501, 43302001, 40443301, 41224201
41223801, 44543504, 41055803, 41067001, 44543504,
43516403, 43516404, 40808301, 41055803, 41067001,
42537501, 42857206, 42021001, 41431 101, 41431301,
44963802, 41055808, 44963802, 41055808, 41015003,
40443301, 41224201
ECOLOGICAL FATE AND EFFECTS
835.2120
835.2240
835.2410
161-1
161-2
161-3
Hydrolysis
Photodegradation in Water
Photodegradation on Soil
A,B
A,B
A,B
410073-01,413537-01,414831-01,413496-01
427354-01, 427705-02, 427705-01
434412-01,
41 1253-06, 414831-02, 427497-02
411253-05,427497-02
                                               Page 174 of 304

-------
                         Appendix B
Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
835.2370
835.4100
835.4200
835.4400
835.4300
835.1230
835.1410
835.8100
835.6100
835.6200
835.6300
840.1100
840.1200
850.2100
161-4
162-1
162-2
162-3
162-4
163-1
163-2
163-3
164-1
164-2
164-3
201-1
202-1
71-1A
Photodegradation in Air
Aerobic Soil Metabolism
Anaerobic Soil Metabolism
Anaerobic Aquatic Metabolism
Aerobic Aquatic Metabolism
Leaching-Adsorption/Desorption
Laboratory Volatility
Field Volatility
Terrestrial Field Dissipation
Aquatic Field Dissipation
Forestry Dissipation
Droplet Size Spectrum
Drift Field Evaluation
Avian Acute Oral Toxicity
Use Patterns
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
CITATION(S)
414831-03
431675-01, 437991-01, 431496-01, 434159-01, 436859-01,
437991-02,438215-01
433560-01,434159-01,
415579-01,433560-01,425747-01,437991-03,436063-01,
438829-01, 439083-01, 437991-05, 437991-04
420453-01, 429792-01, 441886-01, 437991-06, 431496-01,
436910-01, 436859-02, 444394-01, 437796-01, 437991-08,
437991-07
420253-02, 441179-01, 441585-01, 441052-01, Datgap
417180-01, 420596-01, Datagap

435146-01, 435334-01, 435428-01, 436406-01, 437052-02,
437624-04, 437624-03, 437624-01, 438317-02, 438317-01,
438491-02, 438640-01, 439147-01, 438727-03, 437634-02
446031-01, 434704-01, 436697-02, 435003-01, 436697-01,
435928-02, 436121-01, 436768-03, 437052-01, 437979-02,
438107-01, 438317-03, 438343-01, 438491-01, 438640-02,
438727-02, 438727-01, 438724-01, 446031-02, Datagap
445250-01,439083-02,439547-01,434916-01,458971-01,
439083-02, 439547-01, Datagap
439083-03,439271-01, 439547-02, Datagap
Datagap
Datagap
415462-02, 419751-01, 415462-01, 233351, 00138871, 416444-01,
414541-01, 41 1583-03, 72472, 226397, 439350-01
                        Page 175 of 304

-------
                         Appendix B
Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
850.2200
850.2300
850.1075
850.1010
850.1075
850.1025
850.1035
850.1045
850.1300
850.1350
850.1400
850.1500
850.4100
71-2A
71-2B
71-4A
71-4B
72-1
72-2A
72-3A
72-3B
72-3C
72-3
72-4A
72-4B
72-4C
72-5
122-1A
Avian Dietary Toxicity
Avian Reproduction
Fish Toxicity Bluegill
Invertebrate Toxicity
Estuarine/Marine Toxicity - Fish
Estuarine/Marine Toxicity - Mollusk
Estuarine/Marine Toxicity - Shrimp
Estuarine/Marine Toxicity - Penaid
Fish Early Life Stage - Daphnid
Estuarine/Marine Invertebrate Life
Cycle
Freshwater Fish- Acute Toxicity
Life Cycle Fish
Terrestrial Plant Toxicity, Seedling
Emergence
Use Patterns
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
CITATION(S)
415861-01, 415462-02, 419751-02, 419751-03, 417495-01,
233351, 417495-02, 00138870, 00138872, 416444-02, 416444-03,
414484-01, 414290-07, 41 1583-05, 45070, 41 1583-04, 226397,
439349-01,439352-01
453364-01
411583-01, 53986, 419751-05, 419751-04, 0073-091-01, 233350,
411583-11,419751-04,234027,419751-04,01338869,413538-03,
413538-04, 413538-01, 00050674, 00053988, 417373-03, 45068,
45069, 439331-01, 439332-01, 439307-01
439103-01, Datagap
41 1583-01, 419751-06, 232630, 413538-03, 413538-01, 67328
429797-01, 417373-06, 420183-02, 419751-07, 411583-10,
419734-01, 41 1583-1 1, 418252-08, 232630, 414290-03, 414290-02,
414290-06,411583-10,418352-04,418352-01,411583-11,
418352-06,418352-03
429797-01, 420183-02, 41 1583-1 1, 419734-01, 414290-03,
414290-06,411583-10,418352-04, 418352-01, Datagap
417373-06, 419751-07, 41 1583-1 1, 419252-08, 232630, 414290-02,
414290-05, 418352-06, 418352-03, Datagap
Datagap
417373-04, 420183-04, 417677-01
418352-11,420183-03,418352-10,413583-02

413457-01,417373-05

                        Page 176 of 304

-------
                                                 Appendix B
                         Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
850.5400
850.4225
850.4250


850.4400


850.3020
122-2
123-1A
123-1B


123-2


141-1
Aquatic Plant Growth
Seedling Germination and Seedling
Emergence
Vegetative Vigor


Aquatic Plant Growth


Honey Bee Acute Contact
Use Patterns
A,B
A,B
A,B


A,B


A,B
crrATioN(S)

424168-02, 426091-1, 442756-01, 430167-02, 423895-01, 431970-
03, 431970-02, 431970-01, 424492-01, 439821-01, Datagap
424168-01, 426091-02, 423439-02, 437882-01, 426693-04,
43982 1-01, Datagap
442951-01, 427122-04, 427122-05, 427122-01, 427122-02,
427122-03, 415059-04, 414200-02, 415059-01, 415059-03,
415059-02, 417321-02, 434886-02, 417321-01, 434886-03,
434886-04, 434886-01, 420684-04, 417321-02, 420684-04,
420684-03, 417352-03, 417352-06, 417352-04, 417352-05,
417352-02
445173-04,445173-01
TOXICOLOGY
870.1100
870.1200
870.1300
870.2400
870.2500
870.2600
870.3100
81-1
81-2
81-3
81-4
81-5
81-6
82-1A
Acute Oral Toxicity-Rat
Acute Dermal Toxicity-Rabbit/Rat
Acute Inhalation Toxicity-Rat
Primary Eye Irritation-Rabbit
Primary Skin Irritation
Dermal Sensitization
Subchronic Oral Toxicity: 90-Day
Study Rodent
A,B
A,B
A,B
A,B
A,B
A,B
A,B
00101605, 41920901, 00157512, 00252291, 41709901, 41413501,
40629801,41209001
00101596, 4192091 1, 00157513, 00252291, 41709902, 41413502,
40629802,41209002
00161660, 41986601, 00157514, 40085501, 40352701, 41957601,
40629803, 42605202
41 125302, 41920902, 00157515, 00252291, 40352702, 41413504,
40629804, 44725303
42232701, 41920903, 00157516, 00252291, 40352703, 41413505,
40629805,41413505
00161659, 41920904, 41642805, 41233701, 40352704, 41413506,
40629806,41209006
41991501, 41928101, 41994001, 41896701, 41896702, 42021401,
43515901,42021402
                                                Page 177 of 304

-------
                         Appendix B
Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
870.3150
870.3200
870.3465
870.4100
870.3700
870.3700
870.3800
870.4300
870.4200
870.5265
870.5300
870.5375
870.5385
870.5395
82-1B
82-2
82-4
83-1B
83-3A
83-3B
83-4
83-5
83-2B
84-2
84-2
84-2
84-2B
84-2
Subchronic Oral Toxicity: 90-Day
Study Non-rodent
21-Day Dermal - Rabbit/Rat
90-Day Inhalation-Rat
Chronic Feeding Toxicity
Developmental Toxicity - Rat
Developmental Toxicity - Rabbit
2-Generation Reproduction - Rat
Combined Chronic Toxicity/
Carcinogenicity: Rats
Carcinogenicity Mice
Gene Mutation
In vitro Mammalian Cell Gene
Mutation Test
In vitro Chromosome Aberration
In vivo chromosome aberration
Micronucleus Assay
Use Patterns
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
CITATION(S)
41737301, 42780001, 42780003, 43515501, 42780002
41735304, 41735301, 41407901, 41920905, 41735303,41735306,
41735302, 41735305, 41407903, 41407902
Datagap
43612001,430490001
00130407, 00130408, 41527101, 41527104, 41920906, 41986602,
41735201, 42304601, 42304602, 43523101, 43523001, 41527103;
41527106, 41527102; 41527105
41747601, 42158703, 42158706, 42055501, 42013501, 42224001,
42304603, 42304604, 42158702; 42158704, 42158701, 42158705
00150557, 00163996, Repeat Study Required
43879801,43597201
43612001
41409801, 41388204, 41797903, 41409802, 41409803,
41388203, 41797902, 42015701, 43935101, 41388202,
41797901
43394201, 43327304, 43327302
43327305, 43327303, 43327301
Mustonen, etal, 41478301, 42015704, 42015701, 42015707,
41409805, 41870102, 41409806, 41870103, 41478303,
42015701, 42015703, 42015706, 43930801, 41478302,
42015701, 42015702, 42015705
41409804, 41870101
                        Page 178 of 304

-------
                                             Appendix B
                       Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
870.5450
870.6200
870.6300
870.7485
870.7600
84-2
81-8, 82-7,
83-1
83-6
85-1
85-3
Rodent Dominant Lethal Assay
Neurotoxicity Screening Battery
Developmental Neurotoxicity
General Metabolism
Dermal Penetration and Absorption
Use Patterns
A,B
A,B
A,B
A,B
A,B
crrATioN(S)
41409807, 41498101, 41409808, 41409809, 41498103,
43930501, 41498102
43115201,43293901
Datagap
41737302
Feldman. R. I And Maibach, H. I. (1974)
OCCUPATIONAL/RESIDENTIAL EXPOSURE
875.1100
875.1300
875.2200
231
232
132-lb
Estimation of Dermal Exposure at
Outdoor Sites
Estimation of Inhalation Exposure at
Outdoor Sites
Soil Residue Dissipation
A,B
A,B
A,B
449722-01, 444598-01
449722-01,444598-01
446557-01,446557-04,
446557-03,450331-01
RESIDUE CHEMISTRY
860.1200



860.1300

860.1300




171-4A

171-4B
Directions for Use



Plant Metabolism

Livestock Metabolism
A,B



A,B

A,B
Datagap
00004666, 00004667, 00004669, 00004675, 00004676,
00004677, 00004680, 00004681, 00004682, 00004683,
00004689, 00004693, 00004698, 00004699, 00004715,
00004723, 00004960, 00004996, 00074214, 00074215,
00074216, 00074217, 00102675, 00102676, 00102679
00102717, 00123973, Blacktop and Linscott. (1968),
Feung, etal. (1972), 41991503, 42423101, 42439701
42615601, 43290501, 43496101
00004705, 00068891, 42605201, 42749701, 43160201
                                            Page 179 of 304

-------
                         Appendix B
Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
860.1340
860.1340
860.1340
860.1380
860.1380
860.1380
860.1400
171-4C
171-4C
171-4C
17ME
171-4E
17ME
171-4F
Residue Analytical Method - Plant
commodities
Residue Analytical Method - Livestock
commodities
Residue Analytical Method - Water
Storage Stability - Plant commodities
Storage Stability - Livestock
commodities
Storage Stability - Water
Water, Fish, and Irrigated Crops -
Irrigated Crops
Use Patterns
A,B
A,B
A,B
A,B
A,B
A,B
A,B
crrATioN(S)
00004720, 00033119, 00036171, 00037169, 00042288,
00045364, 00045365, 00046125, 00059025, 00059026,
00059027, 00059033, 000601 13, 00060120, 00060870,
00060872, 00060880, 00061012, 00061014, 00061016,
00061017, 00061018, 00061645, 00074219, 00075198,
00075715, 00075716, 00075719, 00088176, 00102605,
00102710, 00102717, 00102719, 00102737, 00102815,
00102862, 00102865, 00109535, 00115499, 00115509,
00120057, 00121733, 00123269, 00126684, 00127273,
00133938, 00136845, 00138635, 0013951 1, 00139951,
00140092, 00156264, PP#6E2606 (1979), Aly and Faust
(1964), Bontoyan (1985), Freed (1948), 43289301,
43691101,43893701
00004701, 00004707, 00004719, 00037169, 00043759,
00055485, 00066156, 00068011, 00068892, 00068893,
00071787, 00078237, 00102713, 00102714, 00102760,
00102816, 00102821, 00115509, 00115515, 00120057
Otto et al (1982), 44016501, 44016502, Datagap
00035913, 001 15509, 0012171 1, 00136848, 00140032, Otto
et aid 982)
00136845, 00140092, 00145248, 43809901, 43870301,
43879901, 43879902, 43879903, 43879904, 43879905,
43886401, 43886402, 43886403, 43886404, 43886405,
43886406, 43943101, 43963801, 43963802, 44211901,
45245601
44024801,44967401
00035913,00139511
00052597, 00139511, Datagap
                        Page 180 of 304

-------
                         Appendix B
Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
860.1400
860.1400
860.1480
860.1480
860.1500
860.1500
860.1500
860.1500
860.1500
860.1500
860.1500
171-4F
171-4F
171-4J
171-4J
171-4K
171-4K
171-4K
171-4K
171-4K
171-4K
171-4K
Water, Fish, and Irrigated Crops -
Fish and Shellfish
Water, Fish, and Irrigated Crops -
Water
Meat, Milk, Poultry, Eggs - Milk and
the Fat, Meat, and Meat Byproducts of
Cattle, Goats, Hogs, Horses, and Sheep
Meat, Milk, Poultry, Eggs - Eggs and
the Fat, Meat, and Meat Byproducts of
Poultry
Crop Field Trials (Root and Tuber
Vegetables Group - Potatoes)
Crop Field Trials (Legume Vegetables
(Succulent or Dried) Group - Soybean
seed)
Crop Field Trials (Foliage of Legume
Vegetables Group - Soybean forage
and hay)
Crop Field Trials (Citrus -
Grapefruits, Lemons, Oranges)
Crop Field Trials (Pome Fruits Group
- Apples, Pears, Quinces)
Crop Field Trials (Stone Fruits Group
- Cherry, Peach, Plum/Fresh Prune)
Crop Field Trials (Berries Group -
Blueberries, Raspberries)
Use Patterns
A,B
A,B
A,B
A,B
A,B
A,B
A,B
A,B
A,B
A,B
A,B
CLTATION(S)
00028443, 00035913, 00043759, 00052597, 00102760,
00115741, 43378801, 44135201, 44577801
00035913, 00038429, 00052597, 00102788, 00115741,
00118549, 42968501, 42968502
00004701, 00004707, 00004719, 00059034, 00068892,
00068893, 00102714, 44024801
00102719
00060876, 00102814, 00102862, 00136845, 43886401
43356301, 43356302, 43356303, 43669801
43356301, 43356302, 43356303, 43669801
00102605, 43870303, 00102879, 00115509, 43870303,
45462201, 00042526, 00102605, 00102737, 00139059,
00163903, 43870303, 45462201, 45672201
00102824, 43943101, 00102824, 43886405
00088176, 43879902, 43879901, 43879903
00061010, 00061012, 43886403, 44268501, 40881401
                        Page 181 of 304

-------
                         Appendix B
Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
860.1500
860.1500
860.1500
860.1500
171-4K
171-4K
171-4K
171-4K
Crop Field Trials (Tree Nut Group -
Almond, Filbert, Pecan, Walnut)
Crop Field Trials (Cereal Grains
Group - Barley, grain; Corn, Held,
grain; Corn, sweet (K+CWHR);
Millet, grain; Oats, grain; Rice, grain;
Rice, wild, grain; Rye, grain;
Sorghum, grain; Wheat, grain)
Crop Field Trials (Forage, Fodder, and
Straw of Cereal Grains Group -
Barley, haw and straw; Corn, field,
forage, and stover; Corn, sweet, forage
and stover; Millet, forage, hay, and
straw; Oat, forage, hay, and straw;
Rice, straw; Rye, forage and straw;
Sorghum, forage and stover; Wheat,
forage, hay, and straw)
Crop Field Trials (Grass Forage,
Fodder, and Hay Group - Grass
(pastures and rangeland) forage and
hay)
Use Patterns
A,B
A,B
A,B
A,B
CITATION(S)
00088176, 44211901, 43963801, 43963802, 00115509
00004610, 00036168, 00036169, 00036171, 00036169,
00059025, 00059027, 00059029, 00060117, 00061010,
00021755, 00022329, 00025383, 00028385, 00030697,
43676801, 43686001, 43693702, 00102865, 43886406,
00025330, 00161 187, 00036169, 00059028, 00102816,
00004594, 00120057, 43747901, 43785901, 43853601,
00102719, 00102889, 00120057, 43697801, 43718001,
43718002, 00022622, 00036168, 00036170, 00036171,
00045369, 00046127, 00059029, 00060111, 00061010,
00078482, 00090361, 00127226, 00128778, 43665201,
43665202, 43676802, 43797901, 43797903, 44190301,
44190302, Datagap
00036168, 00036171, 00059025, 00059027, 00021755,
00022622, 00025383, 00028385, 00030697, 00073273,
00075715, 00075724, 00102865, 00127273, 00139511,
43676801, 43686001, 43693702, 00059028, 00120057,
43747901, 43785901, 00102719, 00102889, 00120057,
43697801, 43718001, 43718002, 00004485, 00028173,
00028200, 00042288, 00061010, 00063507, 00090360,
00102712, 00120057, 00138635, 00144791, 00147047,
43665201, 43665202, 43676802, 43797901, 43797903,
44190301, 44190302, Datagap
00004485, 00028173, 00028200, 00042288, 00061010,
00063507, 00090360, 00102712, 00120057, 00138635,
00144791, 00147047, 43592101, 43610801, 43610802,
43665203, 43665204, 43665205, 43779501, 43779502,
43779503, 43779504
                        Page 182 of 304

-------
                                                 Appendix B
                         Data Supporting Guideline Requirements for the Reregistration of 2,4-D
REQUIREMENT
860.1500
860.1520
860.1850
171-4K
171-4L
165-1
Crop Field Trials (Miscellaneous
Commodities - Asparagus; Aspirated
Grain Fractions; Cranberries; Grapes;
Hops; Pistachios; Strawberries;
Sugarcane)
Processed Food/Feed (Apples; Barley;
Citrus; Corn, Held; Grape; Oats;
Potato; Prunes; Rice; Rye; Sorghum;
Soybean; Sugarcane; Wheat)
Confined Rotational Crops
Use Patterns
A,B
A,B
A,B
CITATION(S)
00025338, 00060870, 43879905, 43693701, 43709701,
00061010, 00061012, 43886402, 00061012, 00102833,
43947901, 45245601, 45647101, 45665801, 45512701,
43879904, 00102717, 00102812, 43886404, 00030701,
00079738, 00102640, 00102794, 001 15793, 00127823,
43736101,43736102
43943101, 43870302, 43709701, 45245601, 45647101,
43879903, 43755402, 43709702, 00030701, 00068889,
43755401, 43693701
43356002
OTHER
840.1100
840.1200
201-1
202-1
Droplet Size Spectrum
Drift Field Deposition Evaluation
A,B
A,B
Reserved
Reserved
                                                Page 183 of 304

-------
Appendix C. Technical Support Documents
                                 Page 184 of 304

-------
       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 South Bell Street, Arlington, VA. It is open Monday through
Friday, excluding legal holidays, from 8:30 am to 4 pm.

       The docket initially contained preliminary risk assessments and related documents as of
June 23, 2004. Sixty days later the first public comment period closed. The EPA then considered
comments, revised the risk assessment, and added the response to comments documents,
preliminary mitigation strategies, and the revised risk assessments to the docket on January 12,
2005.  The second sixty day public comment period closed on March 14, 2005.  The 2,4-D
Reregistration Eligibility Decision (RED), revised risk assessments, and response to comments
documents were made available in the summer of 2005.

       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:

              www. epa. gov/pesticides/reregistration

These documents include:

       HED Documents:
       1. 2,4-D. HED's Revised Human Health Risk Assessment for the Reregistration Eligibility
Decision (RED) Revised to Reflect Public Comments. PC Code 030001; DP Barcode D316597.
May 12, 2005.

       2. 2,4-D. Revised Acute and Chronic Dietary Exposure Assessments Including Proposed
New Uses Hops and Potatoes for the Reregistration Eligibility Decision.  April 18, 2005.

       3. 2,4-D: 3rd Revised Occupational and Residential Exposure and Risk Assessment and
Response to Public Comments for the Registration Eligibility Decision (RED) Document (PC Code
030001, DP Barcode D316596). May 4, 2005.

       4. 2,4-D: Response to Phase 5 Public Comments (PC Code 030001, DP Barcode D315562).
June 7, 2005.

       5. 2,4-D. Revised Acute and Chronic Dietary Exposure Assessments for the Reregisration
Eligibility Decision. October 13, 2004.
       6. 2,4-D: Health Effects Division (HED) Metabolism Assessment Review Committee
(MARC) Decision Document-Revised.  DP Barcodes D309452 Chemical ID.  No. 030001. Case No.
0073.  Meeting date 9/3/03. October 13. 2004.

       7. 2,4-D. Revisions to the Product and Residue Chemistry Chatpers of the Reregistration
Eligibility Decision; Reregistration Case no. 0073.  Chemical I. D. No. 030001; DP Barcode No.
D309450 and D309451. October 12, 2004.
       8. 2,4-D PC Code 030001, Case No. 0073  DP Barcode D309450 Reregistration Eligibility
Decision Revised Chemistry Considerations.  October 12, 2004.
                                    Page 185 of 304

-------
       9.  2,4-D Case 0073 Reregistration Eligibility Decision: Revised Product Chemistry
Considerations (DP Barcode D309451). October 12, 2004.

       10.  2,4-D - Phase 3 Toxicology Chapter Revision. December 9, 2004.

       11.  2,4-D: Response to Public Comments [PC Code 030001, DP Barcode D307717].
December 16, 2004.
       EFED Documents:

       1.  Revised Environmental Fate and Effects Division Revised Preliminary Risk Assessment
for the 2,4-Dichlorophenoxyacetic acid (2,4-D) Reregistration Eligibility Decision Document.
October 28, 2004.

       2. Revised EFED Revised Preliminary Risk Assesssment for the 2,4-D Reregistration
Eligibility Document. October 28, 2004.

       3.  2,4-D -  Response to Public Comments on the Revised EFED Science Chapter for the
Reregistration Eligibility Decision Document. October 28, 2004.

       4.  2,4-D -  Response to Public Comments from the San Francisco Department of the
Environment on the EFED Science Chapter for the Reregistration Eligibility Decision Document.
November 1, 2004.
                                    Page 186 of 304

-------
Appendix D.  Citations Considered to be Part of the Data Base Supporting the Reregistration
Eligibility Decision (Bibliography) for 2,4-D
                                    Page 187 of 304

-------
                                   2,4-D Bibliography

Toxicology References
Arbuckle, T. E., Schrader, S. M., Cole, D., etal. (1999). 2,4-Dichlorophenoxyacetic Acid Residues in
Semen of Ontario Farmers. Reproductive Toxicology 13: 421-429].
Bortolozzi, A. A.; Duffard, R. O.; and Evangelista De Duffard, A. M. (1999). Behavioral Alterations
Induced in Rats by a Pre- and Postnatal Exposure to 2,4-Dichlorophenoxyacetic Acid.
Neurotoxicology and Teratology, 2J_ (4): 451-465
Brusco, A.; Saavedra, J. P.; Garcia, G; etal. (1997). 2,4-Dichlorophenoxyacetic Acid Through
Lactation Induces Astrogliosis in Rat Brain.Mol. Chem. Neuropathol. 30, 175-185
Cavieres, M. F. Jaeger, J. and Porter, W.  (2002). Developmental Toxicity of a Commercial Herbicide
Mixture in Mice: I. Effects on Embryo Implantation and Litter Size. Environmental Hlth Perspectives
HO (11), 1081-1085.

Duffard, R; Garcia, G.; Rosso, S.; et al. (1996). Central Nervous System Myelin Deficit in Rats
Exposed to 2,4-Dichlorophenoxyacetic Acid Throughout Lactation. Neurotoxicology and Teratology,
18 (6): 691-696

Evangelista de Duffard, A. M., N. De Aldrete, M., and Duffard, R. (1990)]. Changes in brain
serotonin and 5-hydroxyindoleacetic acid levels induced by 2,4-dichlorophenoxyacetic acid butyl
ester. Toxicol. 64, 265-270.

Faustini, A., Settimi, L., Pacifici, R., etal. (1996). Immunological changes among farmers exposed to
phenoxy herbicides:  preliminary  observations. Occupational and Environmental Medicine 5^, 583-
585.

Garabrant, D. H.  and Philbert, M. A. (2002). Review of 2,4-Dichlorophenoxyacetic Acid (2,4-D)
Epidemiology and Toxicology. CritRev Toxicol 32 (4): 233-57.
Garry, V. F.; Tarone, R. E.; Kirsch, I. R; etal. (2001). Biomarker Correlations  of Urinary 2,4-D
Levels in Foresters: Genomic Instability  and Endocrine Disruption. Environmental Health
Perspectives (2001). 109 (5): 495-500.

Griffin, R. J. ; Godfrey, V. B.; Kim, Y-C ; etal. (1997). Sex-Dependent Differences in the
Disposition of 2,4-Dichlorophenoxyacetic Acid in Sprague-Dawley Rats, B6C3F1 Mice, and Syrian
Hamsters. Drug Metabolism and Disposition. The American Society for Pharmacology and
Experimental Therapeutics, Vol.  25, No. 9.
Lee, K., Johnson, V., and Blakley, B.  (2001). The Effect of Exposure to a Commercial 2,4-D
Formulation During Gestation on the  Immune Response in CD-I Mice. Toxicology: 165 (1): 39-49.

Sandberg, J.  A. (1996). Distribution of 2,4-Dichlorophenoxyacetic Acid (2,4-D) in Maternal and Fetal
Rabbits. J. Toxicology and Environmental Health. 49:  497-509.
Arias, E (2003).  Sister chromatid exchange induction  by the herbicide 2,4-dichlorophenoxyacetic
acid in chick embryos. Ecotox and Environ Safety 55:338-343.
                                     Page 188 of 304

-------
                                  2,4-D Bibliography

Amer, SM and Aly, FAE (2001). Genotoxic effect of 2,4-dichlorophenoxyacetic acid and its
metabolite 2,4-dichlorophenol in mouse. Mutat Res 494:1-12.
Charles, JM, Cifone, MA, Lawlor, T, Murli, H, Young, RR, Leeming, NM (2000).  Evaluation of the
in vitro genetic toxicity of 4-(2,4-dichlorophenoxy) butyric acid. Mutat Res 472: 75-83.
Galloway, SM, Armstrong, MJ, Reuben, C, Colman, S, Brown, B, Cannon, C, etal. (1987).
Chromosome aberrations and sister chromatid exchanges in Chinese hamster ovary cells: evaluation
of 108 chemicals.  Environ Mol Mutagen 10:1-175, Suppl. 10.
Holland, NT, Duramad, P, Rothman, N, Figgs, LW, Blair, A, Hubbard, A, Smith, MT. (2002).
Micronucleus frequency and proliferation in human lymphocytes after exposure to herbicide 2,4-
dichlorophenoxyacetic acid in vitro and in vivo. Mutat Res 512:165-178.
Madrigal-Bujaidar, E, Hernandez-Ceruelos, A, Chamorro, G (2001). Induction of sister chromatid
exchanges by 2,4-dichlorophenoxyacetic acid in somatic nd germ cells of mice exposed in vivo.
Food and Chem Toxicol 39:941-946.

Mustonen, R, Kangas, J, Vuojolahti, P and Linnainmaa, K (1986). Effects of phenoxyacetic acid on
the induction of chromosome aberrations in vitro and in vivo.  Mutagenesis, 4:241-245.

Venkov, P, Topashka-Ancheva, M, Georgieva, M, Alexieva, V, Karanov, E (2000). Genotoxic
effects of substituted phenoxyacetic acids.  Arch Toxicol 74:560-566.

Waters, MD, Sandhu, SS , Simmons, VF, Mortelmans, KE Mitchell, AD,  Jorgenson, Jones, DCL,
Valencia, R, Garrett, NE. (1982).  Study of pesticide genotoxicity,  in RFleck, A Hollaender (Eds),
Genetic Toxicology - An Agricultural Perspective, Plenum Press, New York,  pp. 275-326.

Zeljezic, D and Garaj-Vrhovac,V (2004). Chromosomal  aberrations, micronuclei and nuclear buds
induced in human lymphocytes by 2,4-dichlorophenoxyacetic acid pesticide formulation. Toxicol
200:39-47.
Occupational and Residential References
2,4-D Smart Meeting , March 6, 2001, Industry Task Force E on 2,4-D Research Data and the USDA
Office of Pest Management Policy.
2,4-D Master Label, September 24, 2004, Industry Task Force II on 2,4-D Research Data and the
USDA Office of Pest Management Policy.

Abbott, et al., 1987 "Worker Exposure to a Herbicide Applied with Ground Sprayers in the United
Kingdom", AIHA Journal 48 (2): 167-175

Bothwell, Max L. and Daley, Ralph J. "Selected Observations on the Persistence and Transport of
Residues from Aqua-Kleen 20 (2,4-D) Treatments in Wood and Kalamalka Lakes, B.C."  The
National Water Research Institute, Inland Waters Directorate, Pacific and Yukon Region, West
Vancouver, B.C. August, 1981.

Burnside, Oliver C. et al, Biologic and Economic Assessment of Benefits from Use of Phenoxy
Herbicides in the United States. NAPIAP Report Number l-PA-96, November 1996
                                     Page 189 of 304

-------
                                  2,4-D Bibliography

Crowell, Wendy J., November 1999, "Minnesota DNR Tests the Use of 2,4-D in Managing Eurasian
Watermilfoil." Aquatic Nuisance Species Digest, Volume 3, No. 4, pp 42-43.
Feldmann and Maibach, "Percutaneous Penetration of Pesticides and Herbicides in Man", Toxicology
and Applied Pharmacology 28, 126-132 (1974)
Harris and Solomon, 1992, "Human Exposure to 2,4-D Following Controlled Activities on Recently
Sprayed Turf," Journal of Environmental Science and Health, B27 (1), 9-22 (1992).
Industry Task Force H on 2,4-D Research Data, "EPA/SRRD and 2,4-D Task Force Lawn and Turf
Application Rate", May  2, 2005.

Maroni et al./Chapter 6 -Phenoxyacetate Herbicides, Toxicology 143 (2000), 77-83.
Paris et. al. "Second Order Model to Predict Microbial Degradation of Organic Compounds in
Natural Waters", Applied and Environmental Microbiology, Vol. 41, No. 3, March 1981, p. 603-609
USFS, September 20, 1998, 2,4-Dichlorophenoxyacetic acid Formulation - Human Health and
Ecological Risk Assessment Final Report, Prepared for the USFS by Syracuse Environmental
Research Associates, Inc.

U.S. EPA, August, 1997 Exposure Factors Handbook Volume I - General Factors. U.S.
Environmental Protection Agency, Office of Research and Development, EPA/600/P-95/002Fa.

U.S. EPA, February 10,  1998 Draft Standard Operating Procedures for Residential Exposure
Assessments.  U.S. Environmental Protection Agency, Office of Pesticide Programs.
U.S. EPA, 1998. PHED Surrogate Exposure Guide. VI. 1.  U.S. Environmental Protection Agency,
Office of Pesticide Programs, August 1998.
U.S. EPA SAP, "Exposure Data Requirement for Assessing Risks from Pesticide Exposure of
Children", SAP Meeting of March 8, 1999, page 60.

U.S. EPA, 1999, "Use of Values from the PHED Surrogate Table and Chemical-Specific Data."
Science Advisory Council for Exposure, Policy.007, U.S. Environmental Protection Agency,  Office
of Pesticide Programs.

U.S. EPA, August 7, 2000,  "Agricultural Default Transfer Coefficients" Science Advisory Council
for Exposure,  SOP 003.1, .U.S. Environmental Protection Agency, Office of Pesticide Programs.

U.S. EPA, July 5,  2000, "Standard Values for Daily Acres Treated in Agriculture" HED Science
Advisory Council for Exposure, Policy.009, U.S. Environmental Protection Agency, Office of
Pesticide Programs.

U.S. EPA, 8/9/2001,  Quantitative Usage Analysis for 2,4-D.
U.S. EPA, December 5,  2001 "A Pilot Study to Determine the Water Volume Ingested by
Recreational Swimmers", Paper Presented at the 2001 Annual Meeting of the Society of Risk
Analysis by Otis Evans et. al. of the U.S. EPA Office of Research and Development, National
Exposure Research Laboratory.
U.S. EPA, August 23, 2002, Master Label for the Reregistration of 2,4-Dichlorophenoxyacetic Acid
Uses Supported by the 2,4-D Industry and IR-4

                                    Page 190 of 304

-------
                                  2,4-D Bibliography

U.S. EPA, March 18, 2003, Maximum Application Rates for 2,4-D Risk Assessments

U.S. EPA, May 1, 2003, 2,4-D Report of Hazard Identification And Review Committee: Author:
Linda Taylor, Ph.D., TXRNO. 0051866

U.S. EPA, January 14, 2004, Review of 2,4-D Incident Reports: Authors: Jerome Blondell, Ph.D. and
Monica Hawkins, M.P.H., DP Barcode D297233.

Washington State Dept. of Ecology, Feb. 2001,  Herbicide Risk Assessment for the Aquatic Plant
Management Final Supplemental Environmental Impact Statement Appendix C. Volume 3: 2.4-D.
Pub. No. 00-109-043


Incident Report References

Bradberry SM, Watt BE, Proudfoot AT, Vale JA. 2000.  Mechanisms of toxicity, clinical features,
and management of acute chlorophenoxy herbicide poisoning: a review.  J Toxicol Clin Toxicol.
38(2): 111-22.

Burns CJ, Beard KK, Cartmill JB. 2001. Mortality in chemical workers potentially exposed to 2,4-
dichlorophenoxyacetic acid (2,4-D) 1945-94: an update. Occup Environ Med. 58(1):24-30.

Durakovic Z, Durakovic A, Durakovic S, Ivanovic D. 1992.  Poisoning with 2,4-
dichlorophenoxyacetic acid treated by hemodialysis. Arch Toxicol.66(7):518-21.

EPA (U.S. Environmental Protection Agency).  1994. An SAB Report: Assessment of Potential 2,4-
D Carcinogencity. Review of the Epidemiological and Other Data on Potential Carcinogencity of
2,4-D.  U.S. Environmental Protection Agency Science Advisory Board (SAB), Washington, D.C.

Faustini A, Settimi L, Pacifici R, Fano V, Zuccaro  P, Forastiere F. 1996.  Immunological changes
among farmers exposed to phenoxy herbicides: preliminary observations. Occup Environ Med.
53(9):583-5.

Flanagan RJ, Meredith TJ, Ruprah M, Onyon LJ, Liddle A. 1990.  Alkaline diuresis for acute
poisoning with chlorophenoxy herbicides and ioxynil. Lancet. Feb 24;335(8687):454-8.

Fontana A, Picoco C, Masala G, Prastaro C, Vineis P. 1998.  Incidence rates of lymphomas and
environmental measurements of phenoxy herbicides: ecological analysis and case-control study.
Archives of Environmental Health 53:384-387.

Friesen EG, Jones GR, Vaughan D. 1990.  Clinical presentation and management of acute 2,4_D oral
ingestion.  Drug Saf 5(2): 155-9.

Garabrant DH, Philbert MA. 2002. Review of 2,4-dichlorophenoxyacetic acid (2,4-D) epidemiology
and toxicology. Critical Reviews in Toxicology 32(4):233-257.

Hardell L, Eriksson M.  1999. A case control study of non-Hodgkin's lymphoma and exposure to
pesticides. Cancer 85:1353-1360.
                                     Page 191 of 304

-------
                                  2,4-D Bibliography

Jorens PG, Heytens L, De Paep RJ, Bossaert L, Selala MI, Schepens PJ. 1995. A 2,4-
dichlorophenoxyacetic acid induced fatality.  Eur J Emerg Med. 2(l):52-5.

Keller T, Skopp G, Wu M, Aderjan R.  1994. Fatal overdose of 2,4-dichlorophenoxyacetic acid (2,4-
D). Forensic Scilnt. 65(l):13-8.

Kogevinas M, Becher H, Benn T, Bertazzi PA, Boffetta P. 1997. Cancer mortality in workers
exposed to phenoxy herbicides, chlorophenols, and dioxins. Am J Epidemiol. 145:1061-1075.

Leonard C, Burke CM, OKeane C, Doyle JS. 1997. "Golf ball liver": agent orange hepatitis. Gut.
40(5):687-8. and comment in: Gut. 42(1): 143, 1998.

Lynge E. 1998.  Cancer incidence in Danish phenoxy herbicide workers, 1947-1993.  Environ Health
Perspect. 106:683-688.

Reigart JR, Roberts JR.  1999. Recognition and Management of Pesticide Poisonings, Fifth Edition.
EPA 735-R-98-003.  U.S. Environmental Protection Agency, Washington, D.C.

Schreinemachers DM.  2000.  Cancer mortality in four northern wheat-producing states.  Environ
Health Perspect. 108:873-881.

Schreinemachers DM.  2003.  Birth malformations and other adverse perinatal outcomes in four
wheat-producing states.  Environ Health Perspect. 111:1259-1264. (and two comments and response
by Kirby RS and Salihu HM and by Burns CJ and Leonard RC.  2003. Environ Health Perspect.
111:A868-A870).

World Health Organization (WHO) 1984.  2,4-Dichlorophenoxyacetic acid (2,4-D). Environmental
Health Criteria 29: 83-101.

Zahm SH. 1997. Mortality study of pesticide applicators and other employees of a lawn service
company.  JOEM 39:1055-1067.
Cancer Epidemiology Review References

Waterhouse D, Carman WJ, Schottenfeld D, Gridley G, McLean S. Cancer incidence in the rural
community of Tecumseh, Michigan: A pattern of increased lymphopoietic neoplasms. Cancer
77:763-770, 1996.

Zahm SH, Babbit PA, Weisenburger DD, Blair A, Saal RC, Vaught JB. The role of agricultural
pesticide use in the development of non-Hodgkin's lymphoma in women. Archives of Environmental
Health 48:353-358,  1993.

Morrison HI, Semenciw RM, Wilkins K, Mao Y, Wigle DT.  Non-Hodgkin's lymphoma and
agricultural practices in the prairie provinces of Canada.  Scandinavian Journal of Work, Environment
and Health 20:42-47, 1994.

Persson B, Fredriksson M, Olsen K, Beoryd B, Axelson O. Some occupational exposures as risk
factors for malignant lymphomas. Cancer 72:1173-1778, 1993.
                                    Page 192 of  304

-------
                                  2,4-D Bibliography

Kogevinas M, Kauppinen T, Winkelmann R, et al.  Soft tissue sarcoma and non-Hodgkin's
lymphoma in workers exposed to phenoxy herbicides, chlorophenols, and dioxins: two nested case-
control studies. Epidemiology 6:396-402, 1995.
Hardell L, Eriksson M. 2003. Is the decline of the increasing incidence of non-Hodgkin's lymphoma
in Sweden and other countries a result of cancer preventive measures? Environmental Health
Perspective 111:1704-6.
McDuffie HH, Pahwa P, McLaughlin JR, Spinelli JJ, Fincham S. et al.  2001. Non-Hodgkin's
lymphoma and specific pesticide exposures in men: cross-Canada study of Pesticides and Health.
Cancer Epidemiology, Biomarkers & Prevention 10:1155-1163.
Swaen GMH, van Amelsvoort LGPM,  Slangen JJM, Mohren DCL.  2004. Cancer mortality in a
cohort of licensed herbicide applicators. International Archives of Occupational and Environmental
Health 77:293-295.
Gavazza A, Presciuttini S, Barale R, Lubas  G, Gugliucci B. 2001. Journal of Veterinary Internal
Medicine 15:190-195.
Glickman LT, Raghavan M, Knapp DW, Bonney PL, Dawson MH1. 2004. Herbicide exposure and
the risk of transitional cell carcinoma of the urinary bladder in Scottish Terriers.  Journal of the
American Veterinary Medical Association 224:1290-1297.
Hayes HH, Tarone RE, Cantor KP. 1995. On the association between canine malignant lymphoma
and opportunity for exposure to 2,4-dichlorophenoxyacetic acid. Environmental Research 70:119-
125.

O'Brien DJ,  Kaneene JB, Getis A, Lloyd JW, Swanson GM, Leader RW.  2000. Spatial and temporal
comparison of selected cancers in dogs and humans, Michigan, USA, 1964-1994.  Preventive
Veterinary Medicine 47:187-204.

Burns CJ, Beard KK, Cartmill JB. 2001.  Mortality in chemical workers potentially exposed to 2,4-
dichlorophenoxyacetic acid (2,4-D) 1945-94: an update. Occup Environ Med.  58(1):24-30.
EPA (U.S. Environmental Protection Agency). 1994. An SAB Report: Assessment of Potential 2,4-
D Carcinogencity. Review of the Epidemiological and Other Data on Potential Carcinogencity of
2,4-D. U.S. Environmental Protection Agency Science Advisory Board (SAB), Washington, D.C.
Fontana A, Picoco C, Masala G, Prastaro C, Vineis P. 1998.  Incidence rates of lymphomas and
environmental measurements of phenoxy herbicides: ecological analysis and case-control study.
Archives  of Environmental Health 53:384-387.
Garabrant DH, Philbert MA. 2002. Review of 2,4-dichlorophenoxyacetic acid (2,4-D) epidemiology
and toxicology.  Critical Reviews in Toxicology 32(4):233-257.
Hardell L, Eriksson M. 1999. A case control study of non-Hodgkin's lymphoma and exposure  to
pesticides. Cancer 85:1353-1360.
Kogevinas M, Becher H, Benn T, Bertazzi PA, Boffetta P. 1997.  Cancer mortality in workers
exposed to phenoxy herbicides, chlorophenols, and dioxins. Am J Epidemiol. 145:1061-1075.
                                     Page 193 of 304

-------
                                  2,4-D Bibliography

Lynge E. 1998.  Cancer incidence in Danish phenoxy herbicide workers, 1947-1993. Environ Health
Perspect. 106:683-688.
Schreinemachers DM.  2000.  Cancer mortality in four northern wheat-producing states.  Environ
Health Perspect. 108:873-881.
Zahm SH. 1997. Mortality study of pesticide applicators and other employees of a lawn service
company.  JOEM 39:1055-1067.
Human Health References
Re-evaluation of the Lawn and Turf Uses of (2,4-Dichlorophenoxy) acetic acid [2,4-D], Pest
Management Regulatory Agency, Health Canada, 21 February 2005.
Environmental Fate and Effects References

2,4-D Task Force, 2003. Master Label for Reregistration of 2,4-Dichlorophenoxy Acetic Acid Uses
dated March 17, 2003.

Anderson, A.M, Byrtus, G., Thompson I, Humphries, D., Hill, B., and Bilyk, M., 2002. Baseline
       Pesticide Data for Semi-Permanent Wetlands in the Aspen Parkland of Alberta. Albeta
       Environment, Publication No. T/673.

Blomquist, J.D., 2003. Personal Communication.

Blomquist, ID., Denis, J.M., Cowles, J.L., Hetrick, J.A., Jones, R.D., and Birchfield, N.B. 2001.
       Pesticides in Selected Water-Supply Reservoirs and Finished Drinking Water 1999-2000:
       Summary of Results from a Pilot Monitoring Program. USGS Open-File Report 01-456.
       Baltimore, Maryland 2001.

Bradbury, Steven. Policy for Estimating Aqueous Concentrations from Pesticides Labeled for Use on
       Rice. EFED Memorandum dated October 29, 2002.

Chapra, S. C. (1997). Surface Water Quality Modeling. McGrawHill, New York, p. 149

Dubberly, Dale., Florida Department of Agriculture and Consumer Services (FDOACS), 2003.
       Personal Communication.

ECOFRAM. 1999. ECOFRAM Terrestrial Draft Report. Ecological Committee on FIFRA Risk
       Assessment Methods. USEPA, Washington, DC.

Fetter, C.W. 1992. Contaminant Hydrogeology. Prentice-Hall, Inc.  Upper Saddle River, New
       Jersey.

Feitshans, T.A., 1999. An Analysis of State Pesticide Drift Laws, San Joaquin Agric. L. Rev. 1,37
       (Spring 1999).

Fletcher, J.S., J.E. Nellsen, and T.G. Pfieeger. 1994. Literature review and evaluation of the EPA
       food-chain (Kenaga) nomogram, an instrument for estimating pesticide residues on plants.
       Env. Toxicol. Chem. 13:1381-1391.

                                     Page 194 of  304

-------
                                  2,4-D Bibliography

Furlong, E.T., Anderson, B.D., Werner, S.L., Soliven, P.P., Coffey, L.J., and Burkhardt, M.R., 2001.
       Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory -
       Determination of Pesticides in Water by Graphitized Carbon-Based Solid-Phase Extraction
       and High-Performance Liquid Chromotography/Mass Spectormetry. USGS Water-Resources
       Investigations Report 01-4134.  Denver, Colorado, 2001.

Gibson, L. R. and M. Liebman. 2002. Course Material for Principles of Weed Science, Agronomy
       317, Iowa State University. Website accessed 15 July 2003,
       http: //www. agron. iastate. edu/courses/Agron317/Herbicide_mode_of_action. htm.

Harrison, S.A., Watschke, T.L., Mumma, R.O., Jarrett, A.R, and Hamilton, G.W. Jr.  1993. Nutrient
       and pesticide concentrations in water from chemically treated turfgrass. in K.  Racke and A.
       Leslie (editors), Pesticides in urban environments: Fate and significance. American Chemical
       Society (ACS) Symposium Series 1993, #522, p. 191-207.

Hoerger, F. and E. E. Kenaga.  1972. Pesticide residues on plants: correlation of representative data as
       a basis for estimation of their magnitude in the environment, in: F.  Coulston and F. Corte
       (editors), Environmental Quality and Safety: Chemistry, Toxicology, and Technology. Vol I.
       Georg Thieme Publishers, Stuttgart, West Germany, pp. 9-28.

Howard, P.H., RS. Boethling,  W.F. Jarvis, W.M. Meylan and E.M. Michalenko. 1991.
       Handbook of Environmental Degradation Rates. Lewis Publishers, Ann Arbor, MI.
Jones, R. D., Breithaupt, J., Carleton, J., Libelo, L., Lin, J., Matzner. R, Parker, R., and Birchfield, N.
       Guidance for Use of the Index Reservoir in Drinking Water Exposure Assessments,
       November 16, 1999. United States Environmental Protection Agency (USEPA) Office of
       Pesticide Programs (OPP).
Kellogg, R.L., Wallace, S., Alt, K., and Goss, D.W.  1998. Potential Priority Watersheds for
       Protection of Water Quality from Nonpoint Sources Related to Agriculture. United States
       Department of Agriculture, Natural Resources Conservation Service (NRCS).
Kennedy, I. and Mahoney, M. Revised  Tier 1 Estimates for Drinking Water Concentrations Resulting
       from Triclopyr Use for Aquatic Weed Control. EFED Memorandum dated June 17, 2002.
Majewski, M.S. and Capel, P.O. 1995.  Pesticides in the Atmosphere: Distribution, Trends, and
       Governing Factors. USGS Series: Pesticides in the Hydrologic System, Volume One in the
       Series. Ann Arbor, Michigan.
Mayer, F. L. and M.R. Ellersieck. 1986. Manual  of acute toxicity: Interpretation and data base for 410
       chemicals and 66 species of freshwater animals. United States Department of the Interior,
       U.S. Fish and Wildlife  Service,  Resource Publication 160.
McCall, P.J., Swann, R.L., and Laskowski, D.A.  1983.  Partition Models for Equilibrium Distribution
       of Chemicals in Environmental  Compartments.  In Fate of Chemicals in the Environment, ed.
       R.L. Swann and A. Eschenroder, 105-23. American Chemical Society.
Mineau, P., B. T. Collins, and A. Baril.  1996. On the use of scaling factors to improve interspecies
       extrapolation of acute toxicity in birds. Regulatory Toxicology and Pharmacology. 24:24-29.


Nagy, K. A. 1987. Field metabolic rate  and food requirement scaling  in mammals and birds.
       Ecological Monographs 57:111-128.
                                     Page 195 of 304

-------
                                  2,4-D Bibliography

Pans, D.F., Steen, W.C., Baughman, G.L., and Barrnett, J.T. Jr, 1981. Second-Order Model to
       Predict Microbial Degradation of Organic Compounds in Natural Waters. Applied and
       Environmental Microbiology, vol. 41, No. 3, p 603-609.
Paris, D.F., Wolfe, N.L., and Steen, W.C.,  1983. Microbial Transformations of Esters of Chlorinated
       Carboxylic Acids. Applied and Environmental Microbiology, vol. 47, No. 1, p 7-11.
Rawn, D.F.K., Halldorson, T. H. J.., Lawson, B.D. and Muir, C.G. 1999.  A Multi-Year Study of
       Four Herbicides in Air and Precipitation from a Small Prairie Watershed.  J. Environ. Qual.
       28:898-906.
Smith, A.E. and Hayden,  B.J. 1980.  Hydrolysis of MCPA Esters and the Persistence of MCPA in
       Saskatchewan Soils. Bull. Environm. Contam. Toxicol., 25, 369-373.
Steen, W.C. 1991. Microbial Transformation Rate Constants of Structurally Diverse Man-made
       Chemicals.  U.S. Environmental Protection Agency, Athens GA. EPA/600/3-91/016.
Swarzenbach, R.P., Gschwend, P.M., and Imboden, D.M., 1993.  Environmental Organic Chemistry.
       John Wiley  and Sons, Inc.  New York.
Thelin, GP. and Gianessi, L.P. 2000. Method for Estimating Pesticide Use for County Areas of the
       Conterminous United States. USGS Open-File Report 00-250, Sacramento, California 2000.
Toride, N, F.  J.  Leij, and M. Th. van Genuchten, 1995. The CXTFIT Code for Estimating Transport
       Parameters from Laboratory or Field Tracer Experiments. USDA-ARS, U.S. Salinity
       Laboratory Research Report No. 137.
USEPA, 2002. Guidance for Selecting Input Parameters in Modeling the Environmental Fate and
       Transport of Pesticides Input Parameter Guidance. Version n February 28, 2002. U.S.
       Environmental Protection Agency, Office of Pesticide Programs, Environmental Fate and
       Effects Division.
USEPA. 2000. Wildlife Exposure Factors Handbook.  Office of Research and Development,
       Washington, D.C. EPA/600/R-93/187. December 1993.
USEPA, 1999. Applying a Percent Crop Area Adjustment to  Tier 2 Surface Water Model Estimates
       for Pesticide Drinking Water Exposure Assessments. U.S. Environmental Protection Agency,
       Office of Pesticide Programs, Environmental Fate and Effects Division.
USEPA, 1992. Pesticides in Ground Water Database: A Compilation Of Monitoring Studies: 1971-
       1991, National Summary. EPA 734-12-92-001.  Washington, D.C. September 1992.
Willis, GH. and McDowell,  L.L., 1987. Pesticide persistence on foliage. Reviews of Environmental
       Contamination and Toxicology, vol. 100. New York, New York.
Wolfe, N.L. 1990. Abiotic Transformations of Toxic Organic Chemicals in the Liquid Phase  and
       Sediments. In: Toxic Organic Chemicals in Porous Media. Z. Gerstl, Y. Chen, U. Mingelgrin
       andB. Yaron. (Eds.). Springer-Verlag, New York. p. 136-147.
Wolfe, N.L., M.E-S. Metwally and A.E. Moftah. 1989. Hydrolytic Transformations of Organic
       Chemicals in the Environment. In:  Reactions and Movement of Organic Chemicals in Soils.
       B.L. Sawhney and K. Brown, (Eds), Soil Science Society of America and American Society
       of Agronomy, Madison, WI. p. 229-242.
Yin D., Jin, H., Yu, L, and Hu S.. 2003. Deriving freshwater quality  criteria for 2,4-dichlorophenol
       for protection of aquatic life in China. Environmental Pollution, 122 (2003) 217-222.
                                     Page 196 of 304

-------
                                 2,4-D Bibliography
Residue Chemistry MRID References
00004485
00004594
00004610
00004666
00004667
00004669
00004675
00004676
Leng, M.L.; Gentry, W.M. (1970) Residue Data for 2,4-D 2,4,5-T and Silvex in
Grass from Treatments with Various Formulations of the Herbicides.
(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-B)

Rhodia, Incorporated (1971) Phenoxy Herbicides on Stubble Crop Rice.
(Unpublished study received Nov 21, 1973 under 359-170; submitted by Rhone-
Poulenc, Inc., Monmouth Junction, N.J.; CDL: 230485-B)

Feeny, R.W.; Higham, J.W.; Snyder, E.H.; Colbert, D.R; Agamahan, H (1975)
Avenge(R) (CL 84,777): Determination of CL 84,777 (1,2-Dimethyl pyrazolium
methyl sulfate) and Bromoxynil (3,5- Dibromo-4-hydroxylbenzonitrile)
Residues in Barley Straw and Grain Following Ground Application (California):
Report No. C- 592. (Unpublished study received Jan 8, 1975 under 241-EX-64;
prepared in cooperation with Lake Ontario Environmental Laboratory,
submitted by American Cyanamid Co., Princeton, N.J.; CDL: 224170-R)

Andreae, W.A.; Good, N.E. (1957) Studies on 3-Indoleacetic acid metabolism:
IV. Conjugation with Aspartic acid and Ammonia as processes in the
metabolism of Carboxylic acids. Plant Physiology 32(? ): 566-572. (Also in
unpublished submission received Sep 16, 1968 under 8F0676; submitted by
Dow Chemical U.S.A., Midland, Mich.; CDL:092090-F)

Bach, M.K. (1961) Metabolites of 2,4-D ichlorophenoxyacetic acid from bean
stems. Plant Physiology 36(? ):558-565. (Also in unpublished submission
received Sep 16, 1968 under 8F0676; submitted by Dow Chemical U.S.A.,
Midland, Mich.; CDL:092090-G)

Easier, E. (1964) The  decarboxylation of Phenoxyacetic acid herbi- cides by
excised leaves of woody plants. Weeds 12(? ):14-16. (Also in unpublished
submission received Sep 16, 1968 under 8F0676; submitted by Dow Chemical
U.S.A., Midland, Mich.; CDL: 092090-K)

Fang, S.C. (1958) Absorption, translocation and metabolism of 2, 4-D-l-CA14I
in pea and tomato plants. Weeds 6(? ): 179-186. (Also in unpublished
submission received Sep 16, 1968 under 8F0676; submitted by Dow Chemical
U.S.A.; Midland, Mich.; CDL: 092090-S)

Fang, S.C.; Butts, J.S.  (1954) Studies in plant metabolism: in. Absorption,
translocation and metabolism of radioactive 2,4-D in corn and wheat plants.
Plant Physiology 29(? ): 56-60. (Also in unpublished submission received Sep
16, 1968 under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.;
CDL: 092090-T)
                                   Page 197 of 304

-------
                                 2,4-D Bibliography
00004677
00004680
00004681
00004682
00004683
00004689
00004693
00004698
Fites, R.C.; Slife, F.W.; Hanson, IB. (1964) Translocation and metabolism of
radioactive 2,4-D in jimsonweed. Weeds 12(? ): 180-183. (Also in unpublished
submission received Sep 16, 1968 under 8F0676; submitted by Dow Chemical
U.S.A., Midland, Mich.; CDL:092090-U)

Holley, R.W. (1952) Studies of the fate of radioactive 2,4-Dichlo-
rophenoxyacetic acid in bean plants: II. A water-soluble transformation product
of 2,4-D. Archives of Biochemistry and Biophysics 35(? ):171-175.  (Also in
unpublished submission received Sep 16, 1968 under 8F0676; submitted by
Dow Chemical U.S.A., Midland, Mich.; CDL:092090-X)

Holley, R.W.; Boyle, F.P.; Hand, D.B. (1950) Studies of the fate of radioactive
2,4-Dichlorophenoxyacetic acid in bean plants. Ar- chives of Biochemistry and
Biophysics 27(? ):143-151. (Also in unpublished submission received Sep 16,
1968 under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.;
CDL: 092090-Y)

Jaworski, E.G.; Butts, IS. (1952) Studies in plant metabolism: H The
metabolism of CA14I-Labeled 2,4-Dichlorophenoxyacetic acid in bean plants.
Archives of Biochemistry and Biophysics 38 (? ):207-218. (Also in unpublished
submission received Sep 16, 1968 under 8F0676; submitted by Dow Chemical
U.S.A., Midland, Mich.; CDL:092090-Z)

Jaworski, E.G.; Fang,  S.C.; Freed, V.H. (1955) Studies  in plant metabolism: V.
The metabolism of radioactive 2,4-D in etiolated bean plants. Plant Physiology
30(? ):272-275. (Also in unpublished submission received Sep 16, 1968 under
8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092090-
AA)

Morgan, P.W.; Hall, W.C.  (1963) Metabolism of 2,4-D by cotton and grain
sorghum. Weeds  11 (?):130-135. (Also in unpublished submission received Sep
12, 1968 under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.;
CDL:092980-C)

Slife, F.W.; Key, J.L.; Yamaguchi, S.; Crafts, A.S. (1962) Penetration,
translocation, and metabolism of 2,4-D and 2,4,5-T in wild and cultivated
cucumber plants.  Weeds 10(? ):29-35. (Also in unpublished submission received
Sep 12, 1968 under 8F0676; submitted by Dow Chemical U.S.A., Midland,
Mich.; CDL:092980-G)

Weintraub, R.L.;  Yeatman, IN.; Lockhart, I A.; Reinhart, J.H.; Fields, M.
(1952) Metabolism of 2,4-Dichlorophenoxyacetic acid:  II.  Metabolism of the
side chain by bean plants. Archives of Biochemistry and Biophysics 40(? ):277-
285.  (Also in unpublished submission received Sep 12,  1968 under 8F0676;
submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092980-L)
                                   Page 198 of 304

-------
                                 2,4-D Bibliography
00004699
00004701
00004705
00004707
00004715
00004719
00004720
00004723
Weintraub, R.L.; Reinhart, J.H.; Scherff, R.A.; Schisler, L.C. (1954) Metabolism
of 2,4-Dichlorophenoxyacetic acid: III. Meta- bolism and persistence in dormant
plant tissue. Plant Physiology 29(? ):303-304. (Also in unpublished submission
received Sep 12, 1968 under 8F0676, submitted by Dow Chemical U.S.A.,
Midland, Mich.; CDL:092980-M)

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)

Clark, D.E.; Young, I.E.; Younger, R.L.; Hunt, L.M.; McLaran, J.K. (1964) The
fate of 2,4-Dichlorophenoxyacetic acid in sheep. Journal of Agricultural and
Food Chemistry 12(l):43-45. (Also In unpublished submission received Sep 12,
1968 under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.;
CDL:092980-S)

Gutenmann, W.H; Hardee, D.D.; Holland, R.F.; Lisk, D.J. (1963) Residue
studies with 2,4-Dichlorophenoxyacetic acid herbicide in the dairy cow and in a
natural and artificial rumen. Journal of Dairy Science XLVT(ll): 1287-1288.
(Also In unpublished submission received Sep 12, 1968 under 8F0676;
submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092980-V)

Erickson, L.C.; Brannaman, B.L.; Coggins, C.W., Jr. (1963) Residues in stored
lemons treated with various formulations of 2,4-D. Journal of Agricultural and
Food Chemistry 11(5):437-440. (Also in unpublished submission  received Sep
12, 1968 under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.;
CDL: 092980-AG)

Klmgman, D.L.; Gordon, C.H.; Yip, G; Burchfield, HP. (1966) Res- idues in
the forage and in milk from cows grazing forage treated with esters of 2,4-D.
Weeds 14(? ): 164-167. (Also in unpublished submission received Sep 12, 1968
under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.;
CDL: 092980-AK)

Lee, Y.N.; Luh, B.S. (1968) Effect of Chlorophenoxyacetic acid growth-
regulator sprays on residues in canned apricots and grapes.  Journal of Food
Science 33(? ):104-108. (Also in unpublished submission received Sep 12, 1968
under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.;
CDL: 092980-AL)

Morton, H.L.; Robison, E.D.; Meyer, RE. (1967) Persistence of 2,4-D, 2,4,5-T,
and Dicamba in range forage grasses. Weeds 15 (? ):268-271.
(Also~In~unpublished submission received Sep 12, 1968 under 8F0676;
submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092980-AO)
                                   Page 199 of 304

-------
                                2,4-D Bibliography
00004960
00004996
00021755
00022329
00022622
00025330
00025338
00025383
00028173
00028200
Primer, P.E. (1965) Investigations into the Fate of Some 14C Labeled Growth
Regulators of the Phenoxy and Naphthalenic Type in Apple Tissue. Doctoral
dissertation, Cornell Univ., Dept. of Pomology. (Unpublished study received
Dec 4, 1970 under 1E1094; submitted by Interregional Research Project No. 4,
New Brunswick, N.J.; CDL:090854-1)

Corbett, J.R; Miller, C.S. (1966) The persistence of 2,4-D in cot- ton when
applied with desiccants. Weeds 14(? ):34-37. (Also in unpublished submission
received Sep 16, 1968 under 8F0676; submitted by Dow Chemical U.S.A.,
Midland, Mich.; CDL:092090-O)

Burnside, I. (1975) Crop Residue Report: FSDS No. A-8647. (Unpub- lished
study received May 2, 1975 under 476-2156; prepared by Univ. of Nebraska,
submitted by Stauffer Chemical Co., Richmond,  Calif;  CDL:009609-K)

Grage, D.; Dietz, B.; Dietze, R.; et al. (1976) Sequential Appli- cations of
Eradicane 6.7-E (PPI) and 2,4-D (POES): Summary of Crop Residue Data on
Corn. (Unpublished study received Apr 20, 1976 under 476-2157; prepared in
cooperation with Morse Laboratories, Inc., submitted by Stauffer Chemical Co.,
Richmond, Calif; CDL:224614-E)

Woofter, D.; Appleby, A.P.; Watson, V.H.; et al. (1972) ?Chemical Sprays on
Corn, Sorghum and Wheat). (Unpublished study received Jan 3, 1973 under
876-25; prepared in cooperation with Oregon State Univ. and others, submitted
by Velsicol Chemical Corp., Chicago, 111.; CDL:005052-C)

Suzuki, H.K.; Fenster, C.R (1976) Dicamba: Residue Tolerance Peti- tion-
Proso Millet. (Unpublished study received Jan 24, 1979 under 9E2166; prepared
in cooperation with Univ. of Nebraska, submitted by Velsicol Chemical Corp.,
Chicago, 111.; CDL: 097773-A)

Klausen-Rogers, G; Renfrew, J.; Slater, L.;  et al. (1970) Residue Results:
?Dicamba|. (Unpublished study received Jun 15,  1973 under 1F1131; prepared
in cooperation with Del Monte Corp. and others, submitted by Velsicol
Chemical Corp., Chicago, 111.; CDL:090907-F)

Suzuki, H.K.; Behrens, R; Kilmer, D. (1975) Residue Chemistry: ?Dicamba|.
(Unpublished study including report no. 404000, nos. 174, 176 and 179,
received Nov 18, 1976 under 876-255; prepared in cooperation with
International Research and Development Corp. and Univ. of Wisconsin,
submitted by Velsicol Chemical Corp., Chicago,  111.; CDL:226930-A)

Hoffman, C.; Haas, R; Cnswell, T.; etal. (1970) Grass: Project No. 404000.
(Unpublished study received Jun 15, 1970 under 876- 25; submitted by Velsicol
Chemical Corp., Chicago, 111.; CDL: 004524-D)

Tullos, B.; Martin, L.; Morse, R; et al. (1975) Weedmaster Herbi- cide Residue
Data. (Unpublished study received Oct 2, 1975 un- der 876-203; prepared in
cooperation with Kerr Foundation and others, submitted by Velsicol Chemical
Corp., Chicago, 111.; CDL: 195015-A)
                                   Page 200 of 304

-------
                                 2,4-D Bibliography
00030692
00028443
00030697
00030701
00033119
00035913
00036168
00036169
Suzuki, H.K.; Whitacre, D.M.; Wellman, I; et al. (1978) Residue Data: Banvel|.
(Unpublished study received Sep 14, 1979 under SD79-13; prepared in
cooperation with Craven Laboratories and others, submitted by state of South
Dakota for Velsicol Chemical Corp., Chicago, 111.; CDL:241007-E)

Duke, T. (1971) Technical Report on the Effect of 2,4-D Formula- tions on
Estuarine Organisms. (Unpublished study received Jul 13, 1971 under 1E1046;
prepared by U.S. Environmental Protection Agency, Gulf Breeze Laboratory,
submitted by U.S. Dept. of the Army, Office of the Chief of Engineers,
Washington, D.C.; CDL: 091865-H)

Suzuki, H.K.; Whitacre, D.M.; Anderson, R.F.; et al. (1976) Resi- due Project
75-1-D, BanvelA(R)I: Corn-Harvest Aid. (Unpublished study received Aug 30,
1979 under 876-25; prepared in cooperation with International Research and
Development Corp. and ABC Laboratories, submitted by Velsicol Chemical
Corp., Chicago, 111.; CDL:240896-A)

Suzuki, H.K.; Whitacre, D.M.; Boudreaux, H.; et al. (1980) Weed-
masterA(R)IHerbicide on Sugarcane: Residue Data and Processing Studies.
(Unpublished study received Apr 12, 1980 under 876- 203; prepared in
cooperation with International Research & Development Corp. and T. Lanaux &
Sons, submitted by Velsicol Chemical Corp., Chicago, 111.; CDL:242414-B)

Washington State University (1963) ?Residues of 2,4D in Apples and Pears|.
(Unpublished study received Dec 24, 1963 under 264-37; submitted by Union
Carbide Agricultural Products Co., Ambler, Pa.; CDL:001835-B)

Gangstad, E.O.; Zimmerman, P.W.; Hitchcock, A.E.; et al. (1974) Aquatic-Use
Patterns for 2,4-D Dimethylamine and Integrated Control. By U.S. Dept. of the
Army, Office of the Chief of Engineers, Aquatic Plant Control Program.
Vicksburg, Miss.: U.S.  Army Engineer, Waterways Experiment Station. (APCP
technical report 7; published study; CDL:096474-C)

Bjerke, E.L.; Ervick, O.K.; Stymiest, C.; et al. (1973) A Residue Study of the
Disappearance of Picloram and 2,4-Dichlorophenoxy- acetic acid in Small Grain
following Application of Tordon Herbicide: GH-C 683. (Unpublished study
received Jul 3, 1975 under 6F1653; prepared in cooperation with South Dakota
State Univ. and others,  submitted by Dow  Chemical Co., Indianapolis, Ind.;
CDL:094498-C)

Southwick, L.; Hartman, G.P.; Stritzke, 1; et al. (1975) A Residue Study of
Picloram and 2,4-D in Oats and Barley following Post- emergence Application
of TordonA(R)I 202 Herbicide: GHP-912. (Unpublished study received Jul 3,
1975 under 6F1653; prepared in cooperation with Univ. of Montana and others,
submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:094498-D)
                                   Page 201 of 304

-------
                                 2,4-D Bibliography
00036170
00036171
00037169
00038429
00042288
00042526
00043280
00043759
Southwick, L.; Behrens, R; Hartman, G.P. (1975) A Residue Study of Picloram
and 2,4-Dichlorophenoxyacetic acid in Wheat follow- ing One, Two and Three
Years Use of Picloram and 2,4-D (Tor- donA(R)I 202 Mixture): GHP-913.
(Unpublished study received Jul 3, 1975 under 6F1653; prepared in cooperation
with Univ. of Minnesota and Univ. of Montana, submitted by Dow Chemical
Co., Indianapolis, Ind.; CDL:094498-E)

Bjerke, E.L.; Dietrich, I; Baker, L.O.; et al. (1975) A Residue Study of Picloram
and 2,4-D in Wheat and Barley following Post- emergence Application of
Tordon 22K Weed Killer plus Formula 40 Herbicide: GH-C 821. (Unpublished
study received Jul 3, 1975 under 6F1653; prepared in cooperation with Univ. of
Montana and Montana State Univ., submitted by Dow Chemical Co.,
Indianapolis, Ind.; CDL:094498-F)

Marquardt, R.P.; Luce, E.N (1961) A new basic procedure for determining
phenoxy acid herbicides in agricultural products. Journal of Agricultural and
Food Chemistry 9(4):266-270. (Also In unpublished submission received Dec 6,
1972 under 3G1339; submitted by Interregional Research Project No.  4, New
Brunswick, N.J.; CDL:093578-A)

Smith, G.E.; Isom, B.G  (1967) Investigation of effects of large- scale
applications of 2,4-D on aquatic fauna and water quality. Pesticides Monitoring
Journal 1(3):16-21. (Also in unpublished submission received Jul 11, 1971
under 1E1046; submitted by U.S. Dept. of the Army, Washington,  D.C.;
CDL:093359-Y)

Grigsby, B.H.; Farwell, E.D. (1950) Some Effects of Herbicides on Pasture and
on Grazing Livestock. Michigan Agricultural Experiment Station Quarterly
Bulletin 32(3): 378-385. (Submitter ACD file no. HF-19; also in unpublished
submission received Oct 3, 1966 under unknown admin, no.; submitted by Dow
Chemical U.S.A., Midland, Mich.; CDL:106349-A)

Meagher, W.G; Phillips, RL. (1966) Physiological Effects and Chemical
Residues Resulting from 2,4-TP and 2,4,5-TP Sprays used for Control of
Preharvest Fruit Drop in Pineapple Oranges. Progress rept, Jun 30, 1966.
(Unpublished study received Mar 4, 1974 under 4E1476; prepared by Univ. of
Florida,  Citrus Experiment Station, submitted by Interregional Research Project
No. 4, New Brunswick, N.J.; CDL:093925-D)

Whitney, E.W.; Montgomery, A.B.; Martin, E.C.; et al. (1968) The effects of a
2,4-D application on the biota and water quality in Currituck Sound, North
Carolina. Without title| ? (? ):13- 17. (Also in unpublished submission received
Aug 4, 1976 under 876-222; submitted by Velsicol Chemical Corp., Chicago,
111.; CDL:242936-D)

Sikka, H.C. (1976) Fate  of 2,4-D in Fish and Blue Crabs:  Contract No.
DACW39-74-C-0068. (Syracuse Research Corp. for U.S. Army, Office of the
Chief of Engineers, Environmental Characterization Branch, MESL, Waterways
Experiment Station, unpublished study; CDL: 099544-D)
                                   Page 202 of  304

-------
                                 2,4-D Bibliography
00045364
00045365
00045369
00046125
00046127
00052597
00055485
00055755
Swann, R.L.; Pettyjohn, M.A.; Bjerke, E.L. (1972) Determination of Residues of
2,4-D in Wheat, Barley and Oat Green Forage, Grain and Straw by Gas
Chromatography. Method ACR 72.8 dated May 12, 1972. (Unpublished study
received Jul 3, 1975 under 6F1653; prepared in cooperation with International
Research and Development Corp., submitted by Dow Chemical U.S.A.,
Midland, Mich.; CDL:094500-B)

Bjerke, E.L. (1973) A Study of Extraction of Picloram and 2,4-D from Small
Cereal Grains: GH-C 680. (Unpublished study received Jul 3, 1975 under
6F1653; submitted by Dow Chemical U.S.A., Mid- land, Mich.; CDL:094500-
C)

Bjerke, E.L.; Ervick, O.K. (1975) A Residue Study of Picloram and 2,4-D in
Milled Wheat Fractions: GH-C 798. (Unpublished study received Jul 3, 1975
under 6F1653; submitted by Dow Chemical U.S.A., Midland, Mich.;
CDL:094501-B)

Yip, G (1964) Herbicides and plant growth regulators: Determina- tion of
herbicides in oils. Journal of the Association of Official Analytical Chemists
47(6): 1116-1119. (Also in unpublished submission received on unknown date
under 6F0459; submitted by U.S. Dept. of Agriculture, Agricultural Research
Service, unknown location; CDL:098165-I)

Phillips, W.M.; Yip, G; Finney, K.F.; et al. (1964) The Effects and Residue
Status of Applications of Amine and Ester; Applica- tions of 2,4-D at Three
Preharvest Growth Stages on Hard Red Winter Wheat. (Unpublished study
received on unknown date under 6F0459; prepared in cooperation with Kansas
State Univ., Agricultural Experiment Station, Dept. of Flour and Feed Milling
Industries and others, submitted by U.S. Dept. of Agriculture, Agricultural
Research Service, unknown location; CDL:098165-L)

Frank, P. A. (1969) Residues of 2,4-D in Irrigation Water and Ir- rigated Crops.
(U.S. Dept. of Agriculture, Crops Protection Branch, unpublished study;
CDL: 091863-D)

Khajeh-Noon, K. (19??) Method for Analysis of Residues of N,N- Dimethyl-
2,4-dichlorophenoxyacetamide on Whole Fish. Undated method. (Unpublished
study received Nov 22, 1971 under 16133-1; prepared by Thornton
Laboratories, Inc., submitted by Clearwater Chemical Corp., Ft. Myers, Fla.;
CDL:015056-K)

Whitney, E.W.; Montgomery, A.B.; Martin, E.C.; et al. (19??) The effects of a
2,4-D application on the biota and water quality in Currituck Sound, North
Carolina. ?Without Title]  ? (? ):13-17. (Also in unpublished submission received
May 19, 1975 under 2E1221;  submitted by U.S. Dept. of the Army,
Washington, D.C.; CDL:094080-J)
                                   Page 203 of  304

-------
                                2,4-D Bibliography
00059025
00059026
00059027
00059028
00059029
00059033
00059034
00060111
00060113
00060117
Glas, R.D. (1975) Residues of Dowco 290 and 2,4-D in Wheat and Barley
following Postemergence Application of Lontrel 205 Herbicide: GH-C 836.
(Unpublished study received Nov 12, 1980 under 464-563; submitted by Dow
Chemical U.S.A., Midland, Mich.; CDL:099735-D)

Gardner, R.C.; Bjerke, E.L. (1975) Residues of Dowco 290, 2,4-D and MCPA
in Green Forage, Straw and Grain of Wheat and Barley after Postemergence
Treatment with Lontrel Herbicides: GH-C 850. (Unpublished study received
Nov 12, 1980 under 464-563; submit- ted by Dow Chemical U.S.A., Midland,
Mich.; CDL:099735-E)

Kutschinski, A.H. (1979) Residues of Dowco 290 and 2,4-D in Barley and
Wheat following Postemergence Application of Lontrel 205 Herbicide by
Ground vs Aerial Sprayer: GH-C 1208. (Unpublished study received Nov 12,
1980 under 464-563; submitted by Dow Chemical U.S.A., Midland, Mich.;
CDL: 09973 5-F)

Kutschinski, A.H. (1979) Residues of Dowco 290 and 2,4-D in Oats following
Postemergence Application of Lontrel 205 Herbicide: GH-C 1217.
(Unpublished study received Nov 12, 1980 under 464- 563; submitted by Dow
Chemical U.S.A., Midland, Mich.; CDL: 099735-G)

Glas, RD. (1978) Residues of 3,6-Dichloropicolinic acid and 2,4-D in Milling
and Malting Fractions following Postemergence Application of Lontrel 205
Herbicide to Wheat and Barley: GH-C 977. (Unpublished study received Nov
12,  1980 under 464-563; sub- mitted by Dow Chemical U.S.A., Midland,
Mich.; CDL:099735-H)

Kutschinski, A.H. (1979) Determination of Residues of 3,6-Dichloro- picolinic
acid and 2,4-D in Barley and Wheat by Gas Chromatography. Method ACR
79.5 dated Apr 18, 1979. (Unpublished study received Nov 12, 1980 under 464-
563; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:099735-L)

Miller, P.W. (1975) Residues of 2,4-D and 2,4-Dichlorophenol in Milk from
Cows Fed 2,4-D in Conjunction with Dowco 290: GH-C 804. (Unpublished
study received Nov 12, 1980 under 464-563; submitted by Dow Chemical
U.S.A., Midland, Mich.;  CDL:099736-A)

American Cyanamid Company (1977) General Summary: Avenge in Wheat
Grain and Straw). (Compilation; unpublished study received Apr 26, 1977 under
241-250; CDL:229617-A)

Peterson, RP. (1976) CL 84,777 Combination: Gas Chromatographic
Procedure for the Determination of 2,4-D Residues in Wheat. Method M-733
dated Oct 8, 1976. (Unpublished study received Apr 26,  1977 under 241-250;
submitted by American Cyanamid Co., Princeton, N.J.; CDL:229617-D)

American Cyanamid Company (1975) General Summary: ?Studies to De-
termine Avenge and 2,4-D Residues in Barley Grain and Straw).  (Compilation;
unpublished study received Apr 26, 1977 under 241- 250; CDL:229616-A)
                                  Page 204 of 304

-------
                                2,4-D Bibliography
00060120
00060870
00060872
00060876
00060880
00061010
00061012
00061014
00061016
00061017
Peterson, R.P. (1976) CL 84,777 Combination: Gas Chromatographic
Procedure for the Determination of 2,4-D Residues in Barley. Method M-738
dated Oct 8, 1976. (Unpublished study received Apr 26, 1977 under 241-250;
submitted by American Cyanamid Co., Princeton, N.J.; CDL:229616-D)

Dow Chemical U.S.A. (1956) Residue Study on Samples from Washington and
California Trials: 2,4-D for Weed Control in Asparagus Cul- ture. (Unpublished
study received Jan 2, 1958 under PP0162; CDL:090188-K)

Dow Chemical U.S.A. (1955?) Method of Analysis for 2,4-D on Treated
Asparagus. (Unpublished study received Jan 2, 1958 under PP0162;
CDL:092439-C)

Florida Fruit & Vegetable Association (1960) The Results of Tests on the
Amount of Residue Remaining, Including a Description of the Analytical
Method Used: (2,4-D). (Unpublished study received Oct 12, 1963 under
PP0272; CDL:090295-B)

University of California—Davis (19??) Analysis for Combined 2,4-D esters in
Potatoes. Undated method. (Unpublished study received Oct 12, 1963 under
PP0272; prepared by Agricultural Extension Service, Dept of Agronomy,
submitted by Florida Fruit & Vegetable Association, Orlando, Fla.;
CDL:090295-G)

National Agricultural Chemical Association (1965?) The Results of Tests on the
Amount of Residue Remaining, Including a Description of the Analytical
Method Used: (2,4-Dichlorophenoxyacetic acid). (Compilation; unpublished
study received May 15, 1967 under 8F0670; CDL:091172-AL)

National Agricultural Chemical Association (1967) Summary of Residues.
(Compilation; unpublished study received May  15, 1967 un- der 8F0670;
CDL:091172-AN)

Dow Chemical Company (1959) Analytical Method: Determination of Trace
Amounts of 2,4-Dichlorophenoxyacetic acid in Sugar Cane Juice. Method no.
MLE.59.4 dated Apr 23, 1959. (Unpublished study received May 15, 1967
under 8F0670; submitted by National Agricultual Chemical Association,
unknown location; CDL: 091172-AR)

Dow Chemical Company (1964) Determination of 2,4-Dichlorophenoxya-  cetic
acid in Peanut Hay and Immature Peanut Vines. Method no. MLE.64.16 dated
Aug 20, 1964. (Unpublished study received May 15, 1967 under 8F0670;
submitted by National Agricultural Chemical Association, unknown location;
CDL: 091172-AT)

Dow Chemical Company (1964) Analytical Method: Determination of 2,4-
Dichlorophenoxyacetic acid in Peanuts. Method no. MLE.64.21 dated Apr 17,
1964. (Unpublished study received May 15,  1967 under 8F0670; submitted by
National Agricultural Chemical Association, unknown location; CDL: 091172-
AU)
                                   Page 205 of 304

-------
                                 2,4-D Bibliography
00061018
00061645
00063507
00066156
00068011
00068889
00068891
00068892
Marquardt, R.P.; Luce, E.N (1955) Determination of 2,4-Dichloro-
phenoxyacetic acid (2,4-D) in grain and seed. Agricultural and Food Chemistry
3(l):51-53. (Also In unpublished submission received May 15, 1967 under
8F0670; submitted by National Agricultural Chemical Association, unknown
location; CDL:091172-AV)

Munro, H.E. (1972) Determination of 2,4-Dichlorophenoxyacetic acid and
2,4,5-Trichlorophenoxyacetic acid in tomato plants and other commercial crops
by microcoulometric gas chromatography. Pesti- cide Science 3(4):371-377;
taken from Weed Abstracts, 1973 22(2):38.  (Abstract no. 376).
(Also~In~unpublished submission received Dec 9, 1974 under 33652-1;
submitted by Chemie Linz AG, Chemie, Austria; CDL:230516-U)

Colorado. Department of Agriculture (1979) Residue Test No. 1734: Range
Grass from York, Nebraska. (Unpublished study; CDL: 244533-J)

Duffy, J.R.; Shelfoon, P. (1967) Determination of 2,4-D and its butoxyethanol
ester in oysters by gas chromatography. Journal of the Association of Official
Analytical Chemists 50(5): 1098- 1102. (Also~In~unpublished submission
received Aug 4, 1976 under 876-222; submitted by Velsicol Chemical Corp.,
Chicago, 111.; CDL:229171-E)

Diamond Shamrock Agricultural Chemicals (1975) Residue Studies in Grass
and Hay. (Compilation; unpublished study, including published data, received
Nov 19, 1980 under unknown admin, no.; CDL:244821-A)

Kutschinski, A.H.; Bates, T.W.; Swann, RL. (1971)  Residues of 2,4-D in
Sugarcane and Its Factory Products Resulting from Applications of Amine or
Ester Formulations of the Herbicides. Final rept. (Unpublished study received
Oct 9, 1971 under 8F0670; prepared by Dow Chemical Co. in cooperation with
International Research and Development  Corp., submitted by National
Agricultural Chemicals Association, Industry Task Force on Phenoxy Herbicide
Tolerances, Washington, D.C.; CDL:091173-D)

Miller, P.W.; Jensen, D.J. (1971) Identification of 2,4,6-Tri- chlorophenol and
2,6-Dichlorophenol Residues in Milk from Cows Fed 2,4-
Dichlorophenoxyacetic acid. (Unpublished study re-  ceived Oct 9, 1971 under
8F0670; prepared by Dow Chemical Co., submitted by National Agricultural
Chemicals Association, Industry Task Force on Phenoxy Herbicide Tolerances,
Washington, D.C.; CDL:091173-G)

Miller, P.W.; Jensen, D.J.; Gentry, W.M.  (1971) Residues of 2,4-
Dichlorophenoxyacetic acid and 2,4-Dichlorophenol  in Tissues of Beef Calves
Fed 2,4-D. Final rept. (Unpublished study received Oct 9, 1971 under 8F0670;
prepared by Dow Chemical Co., submitted by National Agricultural Chemicals
Association, Industry Task Force on Phenoxy Herbicide Tolerances,
Washington, D.C.; CDL:091173-H)
                                   Page 206 of 304

-------
                                 2,4-D Bibliography
00068893
00071787
00073273
00074214
00074215
00074216
00074217
00074219
Jensen, D.J.; Miller, P.W.; Palmer, IS. (1971) Residues of 2,4-
Dichlorophenoxyacetic acid and 2,4-Dichlorophenol in Tissues of Sheep Fed
2,4-D. (Unpublished study received Oct 9, 1971 under 8F0670; prepared by
Dow Chemical Co. in cooperation with U.S. Agricultural Research Service,
Animal Disease and Parasite Research Div., submitted by National Agricultural
Chemicals Association, Industry Task Force on Phenoxy  Herbicide Toler-
ances, Washington, D.C.; CDL:091173-1)

Toetz, D. (1976) Residues of 2,4-D in Flesh of Selected Fish Species in Lake
Fort Cobb as a Result of Herbicide Use on Eurasian
Watermilfoil-Myriophyllum spicatum. (Oklahoma State Univ., School of
Biological Sciences, Research Foundation for U.S. Dept.  of the Interior, Bureau
of Reclamation; unpublished study; CDL:099179-D)

Anon. (1979) A Comparison of Dicamba Dimethylamine Salt Emulsifiable
Concentrate with Dicamba Acid Granules in Terms of Stand Reduction and
Residues. (Reports by various sources; unpublished study received Nov 3, 1980
under OK 80/13; submitted by Oklahoma, Dept. of Agriculture, Oklahoma City,
Okla.; CDL: 243 740-A)

Feung, C.; Hamilton, R.H.; Mumma, RO. (1975) Metabolism of 2,4-
dichlorophenoxyacetic acid. VII. Comparison of metabolites  from five species
of plant callus tissue cultures. Journal of Agri- cultural and Food Chemistry
23(3):373-376. (Also in unpublished submission received Apr 14, 1981 under
OF2404; submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:070006-D)

Feung, C.; Hamilton, R.H.; Mumma, RO. (1973) Metabolism of 2,4-di-
chlorophenoxyacetic acid. V. Identification  of metabolites in soybean  callus
tissue cultures. Journal of Agricultural and Food Chemistry 21 (4):637-640.
(Also in unpublished submission received Apr  14, 1981 under OF2404;
submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:070006-E)

Feung, C.; Hamilton, R.H.; Witham,  F.H (1971) Metabolism of 2,4-
dichlorophenoxyacetic acid by soybean cotyledon callus tissue cultures. Journal
of Agricultural and Food Chemistry 19(3):475, 479. (Also in unpublished
submission received Apr 14,  1981 under OF2404; submitted by Dow Chemical
Co., Indianapolis, Ind.; CDL:070006-F)

Hamilton, RH; Hurter, I; Hall, J.K.; et al.  (1971) Metabolism of 2,4-
dichlorophenoxyacetic acid and 2,4,5-trichlorophenoxyacetic acid by bean
plants. Journal of Agricultural and Food Chemistry 19(3):480-483.
(Also~In~unpublished submission received Apr 14, 1981 under OF2404;
submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:070006-G)

Lokke, H. (1975) Analysis of free and bound chlorophenoxy acids in cereals.
Bulletin of Environmental Contamination & Toxicology 13 (6): 73 0-73 6.
(Also~In~unpublished submission received Apr 14, 1981 under OF2404;
submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:070006-J)
                                   Page 207 of 304

-------
                                2,4-D Bibliography
00075198
00075715
00075716
00075719
00075724
00078237
00078482
00079738
00088176
00090360
00090361
Carlile, B.L. (1968) Degradation and Depletion of Herbicides in Drainage
Waters and Accumulation of Residues in Crops Irrigated with Treated Water:
Annual Report-2,4-D and Silvex. (Battelle Memorial Institute for U.S. Dept. of
Agriculture; unpublished study; CDL:090913-D)

Velsicol Chemical Corporation (1981) ?Residues in Corn|. Includes undated
method AM-0691. (Compilation, unpublished study received Jun 12,  1981
under 876-25; CDL:245471-B)

Velsicol Chemical Corporation (1981) ?Residues in Wheat). In- eludes undated
method AM-0691. (Compilation; unpublished study received Jun 12,  1981
under 876-25; CDL:245471-C)

Velsicol Chemical Corporation (1981) ?Determination of Banvel and Dicamba
in Sorghum|. (Compilation; unpublished study received Jun 12, 1981 under 876-
25; CDL:245471-F)

Velsicol (1981) (Determination of Banvel and Dicamba in Various Crops).
Includes method AM-0691 dated Jul 25, 1979. (Compila- tion; unpublished
study received Jun 22, 1981 under CO 81/11; CDL:245581-A)

Bjerke, E.L.; Herman, J.L.; Miller, P.W.; et al. (1971) A Residue Study of
Phenoxy Herbicides in Milk and Cream. (Unpublished study received on
unknown date under 1 El 123; prepared by Dow Chemical U.S.A., submitted by
Interregional Research Project No. 4, New Brunswick, N.J.; CDL:098798-A)

Montana, Department of Agriculture (1974) ?Residue Tests for Picloram in
Grains). (Compilation; unpublished study received on unknown date under
4E1489; CDL:093948-F)

Velsicol Chemical Corporation (1981) Sugarcane Residue Studies.
(Compilation; unpublished study received Sep 11, 1981 under 876- 25;
CDL: 070319-D)

Interregional Research Project Number 4 (1978) ?Residues Study of Envy 2,4-D
on Stone Fruit|. (Compilation;  unpublished study re- ceived Nov 18, 1981 under
2E2606; CDL:070506-A)

Klingman, D.L.; Gordon, C.H.; Yip, G;  et al. (1966) Residues in the forage and
in milk from cows grazing forage treated with esters of 2,4-D. Weeds 14(2): 164-
167.  (Also~In~unpublished submission received May 31, 1966 under 6F0459;
submitted by U.S. Dept. of Agriculture, Agricultural Research Service, un-
known address; CDL:090505-A)

Hilton, J.L.; Phillips, W.M.; Shaw, W.C. (1960) A Summary of the Effects of
Amine and Ester Formulations of 2,4-Dichlorophenoxy- acetic Acid ?2,4-D  on
Small Grains, Including the Status of Residues When 2,4-D is Applied to the
Crop at Various Stage of Growth: Line Project No. CR FL-16. (U.S.
Agricultural Research Service, Crops Research Div.; unpublished study;
CDL:090505-C)
                                   Page 208 of 304

-------
                                 2,4-D Bibliography
00102605
00102640
00102675
00102676
00102679
00102710
00102712
00102713
00102714
Phillips, R. (1970) 2,4-D-Oranges and Grapefruit-CES (Lake Alfred) 1969.
(Unpublished study received Sep 28, 1970 under 359-177; prepared by Univ. of
Florida, Dept. of Food Science, Pesticide Research Laboratory, submitted by
Rhone-Poulenc, Inc., Monmouth Junction, NJ; CDL:026724-A)

National Agricultural Chemicals Assoc. (1970) (2,4-D: Residues in Sugarcane).
(Compilation; unpublished study received Jan 18, 1971 under 8F0670;
CDL:091176-A)

Canny, M.; Markus, K. (1960) The breakdown of 2,4-dichlorophenoxy- acetic
acid in shoots and roots. Australian J. Biol. Sci. 13 (4):486-502.  (Also In
unpublished submission received Sep 12, 1968 under 8F0670; submitted by
National Agricultural Chemicals Assoc., Industry Task Force on Phenoxy
Herbicide Tolerances, Washington, DC; CDL:092089-L)

National Agricultural Chemicals Assoc. (1968) (Phenoxy Herbicides: Residues
in Various Crops). (Compilation; unpublished study received Sep 12, 1968
under 8F0670;  CDL:092089-O)

Luckwill, L.; Lloyd-Jones, C. (1960) Metabolism of plant growth regulators I.
2,4-dichlorophenoxy acetic acid in leaves of red and of black currant. U.
Decarboxylation of 2,4-dichlorophen- oxyacetic acid in leaves of apple and
strawberry. Ann. Appl. Biol. 48(3):613-636. (Also In unpublished submission
received Sep 12, 1968 under 8F0670; submitted by National Agricultural
Chemicals Assoc., Industry Task Force on Phenoxy Herbicide Tol- erances,
Washington, DC; CDL:092089-AC)

Florida Fruit & Vegetable Assoc. (1960) (Analyses for 2,4-D Residue in
Potatoes). (Compilation; unpublished study received Sep 26, 1960 under
PP0272; CDL:092551-D)

Gentry, W. (1971) Residues of 2,4-Dichlorophenoxyacetic Acid, 2,4,5-
Trichlorophenoxyacetic Acid, and 2-(2,4,5-Trichloro- phenoxy)propionic Acid
in Grass Treated with Phenoxy Herbicides. (Unpublished study received Sep 7,
1973 under 8F0670; prepared by Dow Chemical Co., submitted by National
Agricultural Chemicals Assoc., Industry Task Force on Phenoxy Herbicide
Tolerances, Washington, DC; CDL:092965-C)

National Agricultural Chemicals Assoc. (1973) Discussion of Anal- yses for
Residues of 2,4-D and 2,4-Dichlorophenol in Animal Tissues, July 1973.
Summary of study 092142-AD. (Compilation; unpublished study received Sep
7, 1973 under 8F0670; CDL: 092965-D)

National Agricultural Chemicals Assoc. (1973) Discussion of Anal- yses for
Residues of 2,4-D and 2,4-Dichlorophenol in Milk, July 1973. (Compilation;
unpublished study received Sep 7, 1973 under 8F0670; CDL:092965-F)
                                   Page 209 of  304

-------
                                 2,4-D Bibliography
00102717
00102719
00102737
00102760
00102788
00102794
00102812
00102814
00102815
Crabtree, G.; Sheets, W.; Montgomery, M; et al. (1974) Residue Study: 2,4-D
for Control of Broadleaf Weeds in Strawberries. (Unpublished study received on
unknown date under 5E1544; pre- pared by Oregon State Univ., submitted by
Interregional Research Project No. 4, New Brunswick, NJ; CDL:094206-A)

National Agricultural Chemicals Assoc. (1975) Summary of Additional Residue
Data for 2,4-D in Sorghum, Poultry and Eggs, and Discussion on Residues in/on
Forage Grasses.  (Compilation; unpublished study received Jul 16, 1975 under
8F0670; CDL: 094530-A)

Honse, C.; Yoh, I; Moye, H.; et al. (1973) (Alkanolamme Salt of 2,4-D:
Residues in Organs). (Unpublished study received Sep 25, 1975 under 6E1678;
prepared by Univ. of Florida, Pesticide Research Laboratory, submitted by
Interregional Research Project No. 4, New Brunswick, NJ; CDL:097352-B)

Rawls, C. (1968) The Accumulation and Loss of Field-applied Butoxy- ethanol
Ester of 2,4-dichlorophenoxyacetic Acid in Eastern Oysters, ... and Soft-shelled
Clams, Mya arenaria. (Unpublished study received Jan 5, 1972 under 2E1221;
prepared by Univ. of Maryland, Natural Resources Institute, Chesapeake
Biological Laboratory, submitted by U.S. Dept. of the Army, Washington, DC;
CDL:097882-Z)

Bartley, T.; Gangstad, E. (1975) Dissipation of Residues of 2,4-D in Irrigation
Canals. (U.S. Dept.  of the Interior, Bureau of Reclamation, Office of the Chief
Engineer, Division of Research and U.S. Dept. of the Army, Office of the Chief
of Engineers, Directorate of Civil Works, Planning Div.; unpublished study;
CDL:097921-A)

Kutschinski, A. (1972) Residues of 2,4-D in Louisiana Sugarcane Resulting
from Multiple Applications of Amine Formulations In- eluding a Late Summer
Treatment: GH-C 512. (Unpublished study received Dec 6, 1973 under 464-1;
submitted by Dow Chemical U.S.A., Midland, MI; CDL:101303-A)

Reasor Hill Corp. (1960) ?Residues of 2,4-D in Strawberries and Cranberries |.
(Compilation; unpublished study received Feb 27, 1961 under 347-136;
CDL: 120079-A)

Zweig, G. (1962) Letter sent to J. McLean dated Nov 27, 1962 ?Re- port of
analysis for 2,4-D in potatoes|. (Unpublished study received Dec 17, 1962 under
unknown admin, no.; prepared by Univ. of California-Davis, Presticide Residue
Research, sub- mitted by Chemical Machines, Winnipeg, Canada; CDL: 120204-
A)

Brannock, D.; Freed, V. (1965) Analysis of Pears and Apples for Residues of
2,4-D from Dacamine-D. (Unpublished study received May 18, 1965 under
677-200;  prepared by Oregon State Univ.,  Dept. of Agricultural Chemistry,
submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, OH;
CDL: 120205-A)
                                   Page 21 Oof 304

-------
                                2,4-D Bibliography
00102816
00102821
00102824
00102833
00102862
00102865
00102879
00102889
00109535
00115499
00115509
Dow Chemical Co. (1955?) Studies on Raw Agricultural Commodities for
Residues of 2,4-Dichloropnenoxyacetic Acid (2,4-D). (Un- published study
received on unknown date under unknown admin, no.; CDL: 120208-A)

Boyce Thompson Institute for Plant Research, Inc. (1962) Residues of 2,4-D in
Milk from Cows Grazing on Sprague Pastures. (Un- published study received
Mar 22, 1962 under unknown admin, no.; submitted by Rhone-Poulenc, Inc.,
Monmouth Junction, NJ; CDL:  122170-A)

Legault, R.; Benson, N.; Reynolds, D.; et al. (1963) Pesticide Res- idue
Analysis. (Unpublished study received 1964 under 264-37; prepared by
Washington State Univ., Dept. of Agricultural Chem- istry, submitted by Union
Carbide Agricultural Products Co., Inc., Research Triangle Park, NC;
CDL: 122187-A)

Rhone-Poulenc, Inc. (1964) Use of Weedez Bar (2,4-D) in Grape Vineyards--
Application to USDA for Registration on no Residue Basis. (Unpublished study
received Mar 23, 1964 under 359- EX-42; CDL:125194-B)

Chemical Machines (1964) ?2,4-D: Residues in Potatoes]. (Compi- lation;
unpublished study received Mar 24, 1964 under 3462-8; CDL:221908-B)

Leng, M; Jensen, D.; Miller, P. (1973) Residues of 2,4-D in Field Corn and
Sweet Corn from Preemergence or Postemergence Treatments with the
Herbicide. (Unpublished study received Mar 4, 1976 under 464-201; submitted
by Dow Chemical U.S.A., Midland, MI; CDL:223616-A)

Bice, J. (1961) Physiological Effect of 2,4-D on Lemons. (Unpub- lished study
received Jun 15, 1967 under 5202-18; submitted by Brogdex Co., Pomona, CA;
CDL:230582-A)

Wisconsin Alumni Research Foundation (1969) Assay Report: W.A.R.F. No.
8110601-630. (Unpublished study received Oct 5, 1976 under 11275-2;
submitted by Guth Corp., Naperville, IL;  CDL:235811-A)

Velsicol Chemical Corp. (1982) ?Dicamba: Residues in Cows & Other
Subjects). (Compilation; unpublished  study received Aug 6,  1982 under 876-
168; CDL:248024-A)

Dow Chemical Co. (1972) Amendment to PP IF 1102 Requesting Toler- ances
for Residues of... (2,4,5-T). (Compilation; unpublished study received Jul 21,
1972 under 1F1102; CDL:090864-A)

National Agricultural Chemicals Assoc. (1967) (Study: 2,4-D Resi- due in
Crops, Animal Tissue of Animal Products). (Compilation; unpublished study
received Sep 16, 1968 under 8F0669; CDL: 092964-Q)
                                   Page 211 of  304

-------
                                2,4-D Bibliography
00115515
00115741
00115793
00118549
00120057
00121711
00121733
00123269
00123973
00126684
00127226
00127273
Dow Chemical Co. (1971) Study: 2,4,5-T Residues in Animals and Se- lected
Crops). (Compilation; unpublished study received Sep 29, 1971 under 1F1102;
CDL:093415-A)

Otto, N. (1982) Letter sent to Chief, Applied Sciences Branch dated Sep 8,
1982: Herbicidal residues and environmental effects re- suiting from the
experimental application of two 2,4-D formula- tions to control eurasian
watermilfoil. (U.S. Bureau of Recla- mation, Engineering and Research Center;
unpublished study; CDL: 248613-B)

Ciba-Geigy Corp. (1977) Residues of Ametryn and 2,4-D Amine in or on
Sugarcane from Single and Multiple Applications—Louisiana. (Compilation;
unpublished study received Jan 16, 1978 under 100- 473; CDL:232676-A)

Amchem Products, Inc. (1971) Fenac Residue Data-Total Water Treat- ment.
(Compilation; unpublished study received Jul 7, 1972 under 2F1213;
CDL:091039-T)

National Agricultural Chemicals Assoc. (1970) The Results of Tests on the
Amount of Residue Remaining, Including a Description of the Analytical
Method Used: (2,4-Dichlorophenoxyacetic  Acid). (Compilation; unpublished
study received Jan 18, 1971 under 8F0670; CDL:091174-A)

Washington, Dept. of Game (1967) ?DDT:  Residues in Seafood]. (Compilation;
unpublished study received 1967 under 4F0419; CDL: 092706-A)

Thompson Chemicals Corp. (19??) Method: ?Residues of Phenoxyacids and
Their Amine Salts in Apples and Other Crops). (Unpublished study received Apr
3, 1967 under 7F0589; CDL:092877-A)

Interregional Research Project No. 4 (1973) ?2,4-D Residues in Asparagus and
Other Subjects). (Compilation; unpublished study received Mar 1, 1974 under
4E1475; CDL:093923-A)

U.S. Fish and Wildlife Service (1972) Metabolism of Pesticides: ?2,4-D|.
(Unpublished study received  1972 under 4G1487; CDL: 093950-A)

FBI-Gordon Corp. (1982) ?Ultra-Sulv (2,4-D) Residues in Wheat and Corn and
Rate of Decline in Soil|. (Compilation; unpublished study received Apr 1, 1983
under 2217-703; CDL:249863-G)

U.A. Agricultural Research Service (1961)  ?Residues: 2,4-D . (Compilation;
unpublished study received Mar 16, 1964 under 6F0459; CDL:092748-A)

PBI-Gordon Corp. (1982) Residues: (MCPP-Soil and Other Subjects).
(Compilation; unpublished study received Apr 1, 1983 under 2271-EX-3;
CDL:071501-Z)
                                   Page 212 of 304

-------
                                2,4-D Bibliography
00127823
00128778
00133938
00136845
00136848
00138635
00139059
00139511
00139951
00140032
00140092
00144791
Velsicol Chemical Co. (1981) Hawaiian Sugarcane Residue Data: ?Banvel|.
(Compilation; unpublished study received Apr 15, 1983 under 876-25;
CDL:249983-A)

Uniroyal Chemical (1981) Residue: ?2,4-D Amine|. (Compilation; unpublished
study received Jun 27, 1983 under 400-390; CDL: 250616-A)

Stauffer Chemical Co. (1976) Residue Chemistry Data: ?Eradicane 6.7-E and
Other Chemicals in Corn|. (Compilation; unpublished study received Apr 20,
1976 under 476-2157; CDL:224095-A)

Interregional Research Project No. 4 (1974) ?Residue Levels of 2,4-
Dichlorophenoxyacetic Acid and 2,4-Dichlorophenol in Red Potato Tubers).
(Compilation; unpublished study received 1974 under 1E1122; CDL:093432-A)

U.S. Dept. of the Interior (1962?) Residues: Method of Analysis of 2,4-D in
Water and Crop Plants. (Compilation; unpublished study received Jan 22, 1971
under 1E1136; CDL:093444-A)

Velsicol Chemical Corp. (1983) The Results of Tests on the Amount of Residue
Remaining, Including a Description of the Analytical Method Used: ?Dicamba
and 5-Hydroxy Dicamba Residue in Vege- tables, Forage Crops, Legumes,
Cottonseed and Cottonseed Frac- tions and Grains). (Compilation; unpublished
study received Feb 2, 1984 under 876-449; CDL:072332-A)

California. (1975) ?Residue of 2,4-Dichlorophenoxyacetic Acid Iso- propyl
Ester in Oranges). (Compilation; unpublished study re- ceived Feb 29, 1984
under CA 83/69; CDL:252533-A)

U.S. Dept. of the Interior (1973) ?Residue Studies: 2,4-D: Crops). (Compilation;
unpublished study received Apr 21, 1983 under 3E2876; CDL:071564-F)

International Research and Development Corporation (19??) Determi- nation of
Residues of 2,4 Dichlorophenoxyacetic Acid (2,4-D) in Asparagus-gas
Chromatography. Undated method IRDC 6. (Un- published study received Jan
11, 1971 under 1F1131; submitted by Velsicol Chemical Corp., Chicago, 111.;
CDL:091953-P)

Union Carbide Agricultural Products Company, Incorporated (1965?)
Analytical Methods. (Unpublished study received Apr 19,  1968 under 264-EX-
30G;CDL:123220-E)

National Agricultural Chemicals Assoc. (1970) Residue Studies on Sugarcane.
(Compilation; unpublished study received Jul 19, 1973 under 8F0670;
CDL: 092966-A)

Uniroyal Chemical (1985) DED-WEED SULV Residues in Pasture Grass and
Wheat Forage. Unpublished study. 14 p.
                                   Page 213 of 304

-------
                                 2,4-D Bibliography
00145248



00147047

00156264



00161187



00163903


40881401



41991503



42423101



42439701



42605201



42615601
42749701
42968501
Velsicol Chemical Corp. (1984) Foliar Absorption, Metabolism and
Translocation of Dicamba; [Residue of Banvel Herbicide in Cotton and Grain
Crops; Toxicology of Contaminants]. Unpublished com- pilation. 367 p.

FBI Gordon Corp. (1984) Residue Analysis. Unpublished study. 25 p.

Interregional Research Project No. 4 (1985) The Results of Tests on the Amount
of 2,4-D Residues Remaining in or on Soybeans Includ- ing a Description of the
Analytical Method Used. Unpublished compilation. 62 p.

Interregional Research Project No. 4 (1977) The Results of Tests on the Amount
of Residues 2,4-D and its Metabolite Remaining in or on Millet Including a
Description of the Analytical Method Used. Unpublished compilation. 10 p.

FMC Corp. (1986) Freshgard 26 Product Data: Residue Chemistry Data.
Unpublished compilation. 17 p.

Baron, J. (1988) 2,4-D~Magnitude of Residue on Rasberry: Laborato- ry
Project ID IR-4 PR 2844/3718. Unpublished study prepared by North Dakota
State University. 34 p.

Smith, G. (1991) Metabolism of 14 Carbon-(2,4-Dichlorophenoxy) Acetic Acid,
Dimethylamine Salt in Apples: Lab Project Number: 38072. Unpublished study
prepared by ABC Laboratories, Inc. 37 p.

Pughs, I; Smith, G (1992) Metabolism of Uniformly Ring Labeled ?carbon 14|
2,4-Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester in Potatoes: Lab Project
Number: 38075. Unpublished study prepared by ABC Labs, Inc. 49 p.

Puvanesarajah, V. (1992) Metabolism of Uniformly ?carbon 14|-Ring Labeled
2,4-Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester in Wheat: Lab Project
Number: 38076. Unpublished study prepared by ABC Laboratories, Inc. 121 p.

Puvanesarajah, V.; Bliss, M. (1992) Metabolism of Uniformly Ring Labeled
(carbon  14)2,4-Dichlorophenoxyacetic Acid in Poultry: Lab Project Number:
38077. Unpublished study  prepared by ABC Labs Inc. 91 p.

Puvanesarajah, V.; Ilkka, D. (1992) Metabolism  of Uniformly (carbon 14)-Ring
Labeled 2,4-Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester in Wheat: A
Supplement: Lab Project Number: 38076-01. Unpublished study prepared by
ABC Labs, Inc. 57 p.

Guo, M.; Stewart, S. (1993) Metabolism of Uniformly (carbon 14)-Ring
Labeled 2,4-Dichlorophenoxyacetic Acid in Lactating Goats: Lab Project
Number: 40630. Unpublished study prepared by ABC Labs, Inc. 110 p.

U.S.  Army Corps of Engineers (1993) 2,4-D Residue Data Provided by the U.S.
Army Corps of Engineers.  Unpublished study prepared by Rhone-Poulenc Ag
Co. 297 p.
                                   Page 214 of 304

-------
                                2,4-D Bibliography
42968502
43160201
43289301
43290501
43356002
43356301
43356302
43356303
43378801
Rhone-Poulenc Ag Co. (1993) Miscellaneous Data on Residues and Persistence
of 2,4-D in Aquatic Environments. Unpublished study prepared by Rhone-
Poulenc Ag Co.  160 p.

Guo, M;  Stewart, S. (1994) Supplemental Data for the Study, Metab- olism of
Uniformly (Carbon 14)-Ring Labeled 2, 4-Dichlorophen- oxyacetic Acid in
Lactating Goats: Final Report: Lab Project Nos. 40630-01; 40630. Unpublished
study prepared by ABC Labs, Inc. 26 p.

James, J.  (1994) Radiovahdation of EN-CAS Method ENC-2/93 for the
Determination of 2,4-Dichlorophenoxyacetic Acid (2,4-D) in/on Wheat Forage,
Straw, and Grain Treated with (Phenyl (U)(carbon 14))-2,4-Dichlorophenoxy
Acetic Acid: Final Report: Lab Project Number: 93-0018: ENC-2/93.
Unpublished study prepared by EN-CAS Analytical Labs. 211 p.

Wu, D. (1994) Metabolism of (carbon 14)-2,4-D IPE in Stored Lemons-Nature
of the Residue in Plants: Lab Project Number: XBL 93012: RPT00166.
Unpublished study prepared by XenoBiotic Labs,  Inc. 246 p.

Burnett, T.; Ling, K. (1994) Confined Rotational Crop Study on Uniformly
(carbon 14)-Ring-Labeled 2,4-Dichlorophenoxyacetic Acid (2,4-D): Lab Project
Number:  92155. Unpublished study prepared by Pan-Agricultural Labs, Inc. 184
P-

Carringer, R (1994) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Soybeans Following Ground Application with
2,4-D Acid: Lab Project Number: 93-0022-0227: AA930227. Unpublished
study prepared by American Agricultural Services, Inc. and EN-CAS Analytical
Labs. 368 p.

Carringer, R. (1994) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Soybeans Following Ground Application with
2,4-D 2-Ethylhexyl Ester: Lab Project Number: 93-0022-0226: AA930226.
Unpublished study prepared by American Agricultural Services, Inc. and EN-
CAS Analytical Labs. 450 p.

Carringer, R. (1994) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Soybeans Following Ground Application with
2,4-D Dimethylamine Salt: Lab Project Number: 93-0022-0225: AA930225.
Unpublished study prepared by American Agricultural Services, Inc. and EN-
CAS Analytical Labs. 370 p.

Premkumar, N;  Stewart, S. (1994) Uniformly (carbon 14)-Ring Labeled 2,4-
Dichlorophenoxyacetic Acid: A Metabolism Study in Bluegill Sunfish: Final
Report: Lab Project Number: 41116. Unpublished study prepared by ABC
Laboratories, Inc. 128 p.
                                   Page 215 of 304

-------
                                 2,4-D Bibliography
43496101
43592101
43610801
43610802
43665201
43665202
43665203
43665204
Premkumar, N.; Vengurlekar, S. (1994) Uniformly (carbon 14)- Ring Labeled
2,4-Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester: Nature of the Residue in
Potato: Final Report: Lab Project Number: 41256: M-9149. Unpublished study
prepared by ABC Labs, Inc. 203 p.

Rosemond, I (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Rangelands Following Ground Applications
with 2,4-D 2-Ethylhexyl Ester: (Final Report): Lab Project Number: AA930220:
93-0025-0220.  Unpublished study prepared by American Agricultural Services,
Inc. and EN-CAS Analytical labs. 409 p.

Rosemond, I (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxyacetic Acid) in Rangelands Following Ground Applications
with 2,4-D Dimethylamine Salt: Lab Project Number: 93-0025-0219:
AA930219. Unpublished study prepared by American Agricultural Services and
EN-CAS Analytical Laboratories. 417 p.

Rosemond, I (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxyacetic Acid) in Grass Pastures Following Ground Applications
with 2,4-D 2-Ethylhexyl Ester: Lab Project Number: AA930217: 93-0026-0217.
Unpublished study prepared by American Agricultural Services and EN-CAS
Analytical Labs. 484 p.

Carringer,  S. (1995) Magnitude of the Residue of 2,4-D (2,4-Dichlorophenoxy
Acetic Acid) in/on Wheat (Winter and Spring) Following Ground Applications
with 2,4-D 2-Ethylhexyl Ester: Lab Project Number: AA930204: 93-0019-1054:
47509. Unpublished study prepared by American Agricultural Services, Inc. and
En-Cas Analytical Labs. 705 p.

Carringer,  S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in/on Wheat (Winter and Spring) Following
Ground Applications with 2,4-D Acid: Lab Project Number: AA930205: 93-
0019-0205: ENC-2/93. Unpublished  study prepared by American Agricultural
Services, Inc. and En-Cas Analytical Labs. 403 p.

Carringer,  S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Grass Pastures Following Ground
Applications with 2,4-D Dimethylamine Salt: Lab Project Number: AA930216:
93-0026-0216:  ENC-2/93. Unpublished study prepared by American
Agricultural Services, Inc. and En-Cas Analytical Labs. 488 p.

Carringer,  S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Grass Pastures Following Ground
Applications with 2,4-D Acid: Lab Project Number: AA930218: 93-0026-0218:
ENC-2/93. Unpublished study prepared by American Agricultural  Services, Inc.
and En-Cas Analytical Labs. 352 p.
                                   Page 216 of  304

-------
                                 2,4-D Bibliography
43665205
43669801
43676801
43676802
43686001
43691101
43693701
43693702
Carrmger, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Rangelands Following Ground Applications
with 2,4-D Acid: Lab Project Number: AA930221: 93-0025-0221: ENC-2/93.
Unpublished study prepared by American Agricultural Services, Inc. and En-
Cas Analytical Labs. 368 p.

Carringer, R. (1994) Magnitude of the Residue of 2,4-D (2,4-Dichlorophenoxy
Acetic Acid) in Soybeans Following Ground Applications with 2,4-D
Ethylhexyl Ester: Amendment to Final Report: Lab Project Number:
AA930226: 60635: 60636. Unpublished study prepared by American
Agricultural Services, Inc. 55 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Field Corn Following Ground Applications
with 2,4-D-Ethlhexyl Ester: Lab Project Number: AA930209: ENC-2/93: 93-
0020-0209. Unpublished study prepared by American Agricultural Services and
EN-CAS Analytical Labs. 708 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Wheat (Winter and Spring) Following Ground
Applications with 2,4-D Dimethylamine Salt: Lab Project Number: AA930207:
93-0019-0207: ENC-2/93. Unpublished study prepared by American
Agricultural Services, Inc. and EN-CAS Analytical Labs. 569 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Field Corn Following Ground Applications
with 2,4-D Dimethylamine Salt: Lab Project Number: AA930208: 93-0020-
0208.  Unpublished study prepared by American Agricultural Services, Inc. and
EN-CAS Analytical Labs. 709 p.

Zheng, S. (1995) Independent Laboratory Validation of EN-CAS Method No.
ENC-2/93, the Determination of 2,4-Dichlorophenoxy Acetic Acid (2,4-D)
in/on Various Raw Agricultural Commodities and Their Processed Fractions:
Lab Project Number: 011-03: 94P-011-03. Unpublished study prepared by
Centre Analytical Labs, Inc. 95 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid, 2-Ethylhexyl
Ester in Processed Wheat (Winter and Spring) Fractions (Bran, Flour,
Middlings, and Shorts) Following Ground Applications with 2,4-D 2-Ethylhexyl
Ester:  Lab Project Number:  AA930206: 93-0019-0206. Unpublished study
prepared by American Agricultural Services, Inc.; Texas A&M Univ.; and EN-
CAS Analytical Labs. 700 p.

Carrmger, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Field Corn Following Applications with 2,4-D
Acid:  Lab Project Number: AA930210: 93-0020-0210. Unpublished study
prepared by American Agricultural Services, Inc. and EN-CAS Analytical Labs.
584 p.
                                   Page 217 of 304

-------
                                 2,4-D Bibliography
43697801
43709701
43709702
43718001
43718002
43736101
43736102
43747901
Carrmger, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Grain Sorghum Following Ground
Applications with 2,4-D 2-Ethylhexyl Ester: Lab Project Number: AA930214:
93-0021-0214: F93196531. Unpublished study prepared by American
Agricultural Services, Inc. and EN-CAS Analytical Labs. 554 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D 2-Ethylhexyl Ester, 2,4-
D Acid in Processed Field Corn Fractions Following Ground Applications with
2,4-D 2-Ethylhexyl Ester: Lab Project Number: AA930211: 93-0020-0211:
ENC-2/93. Unpublished study prepared by American Agricultural Services, Inc.
and EN-CAS Analytical Labs. 658 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Processed Grain Sorghum Fractions (Starch
and Flour) Following Ground Applications with 2,4-D Dimethylamine Salt: Lab
Project Number: AA930213: 93-0021-0213: ENC-2/93. Unpublished study
prepared by American Agricultural Services, Inc.  and EN-CAS Analytical Labs.
539 p.


Carrmger, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Grain Sorghum Following Ground
Applications with 2,4-D Dimethylamine Salt: Lab Project Number: AA930212:
93-0021-0212. Unpublished study prepared by American Agricultural Services,
Inc. and EN-CAS Analytical Labs. 567 p.

Carrmger, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Grain Sorghum Following Ground
Applications with 2,4-D Acid: Lab Project Number: AA930215: 93-0021-0215.
Unpublished study prepared by American Agricultural Services, Inc. and EN-
CAS Analytical Labs. 518 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Sugarcane Following Ground Application
with 2,4-D Dimethylamine Salt: (Final Report): Lab Project Number: 93-0023-
0201: AA930201. Unpublished study prepared by American Agricultural
Services, Inc. and EN-CAS Analytical Lab. 760 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Sugarcane Following Ground Application
with 2,4-D Acid: (Final Report): Lab Project Number: 93-0023-0202:
AA930202. Unpublished study prepared by American Agricultural Services,
Inc. and EN-CAS Analytical Lab. 642 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Rice Following Ground Applications with
2,4-D Acid: (Final Report): Lab Project Number:  AA930224: 93-0024-0224:
ENC-2/93. Unpublished study prepared by American Agricultural Services, Inc.
495 p.
                                   Page 218 of 304

-------
                                 2,4-D Bibliography
43755401
43755402
43779501
43779502
43779503
43779504
43785901
43797901
Carrmger, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Processed Fractions of Sugarcane Following
Ground Application with 2,4-D Dimethylamine Salt: Lab Project Number:
AA930203: 93-0023-0203: 5450. Unpublished study prepared by American
Agricultural Services, Inc. and Hawaiian Sugar Planters Association. 575 p.

Carrmger, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Processed Rice Fractions (Hulls, Bran, and
White Milled Rice) Following Ground Application with 2,4-D Dimethylamine
Salt: Lab Project Number: AA930223: 93-0024-0223: ENC-2/93. Unpublished
study prepared by American Agricultural Services, Inc. and South Texas Ag
Research. 548 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid in Grass Pastures
Following Ground Applications with 2,4-D 2-Ethylhexyl Ester: (Final Report):
Lab Project Numbers: AA940503: 6397-154. Unpublished study prepared by
American Agricultural Services, Inc. and Hazleton Wisconsin, Inc. 383 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid in Grass Pastures
Following Ground Applications with 2,4-D Dimethylamine Salt: (Final Report):
Lab Project Numbers: AA940504: 6397-155. Unpublished study prepared by
American Agricultural Services, Inc. and Hazleton Wisconsin, Inc. 383 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid in Rangelands
Following Ground Applications with 2,4-D 2-Ethylhexyl Ester: (Final Report):
Lab Project Numbers: AA940505: 6397-156. Unpublished study prepared by
American Agricultural Services, Inc. and Hazleton Wisconsin, Inc. 360 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid in Rangelands
Following Ground Applications with 2,4-D Dimethylamine Salt: (Final Report):
Lab Project Number: AA940506: 6397-157: HWI 6397-157. Unpublished study
prepared by American Agricultural  Services, Inc. and Hazleton Wisconsin, Inc.
360 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4-
Dichlorophenoxy Acetic Acid) in Rice Following Ground Application with 2,4-
D Dimethylamine Salt: Lab Project Number: AA930222: 93-0024-0222: ENC-
2/93. Unpublished study prepared by American Agricultural Services, Inc. and
EN-CAS Analytical Labs. 582 p.

Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid in Wheat (Winter
and Spring) Following Ground Applications with 2,4-D 2-Ethylhexyl Ester:
(Final Report): Lab Project Number: AA940501: HWI 6397-151. Unpublished
study prepared by American Agricultural Services, Inc. and Hazleton
Wisconsin, Inc. 630 p.
                                    Page 219 of 304

-------
                                 2,4-D Bibliography
43797903
43809901
43853601
43870301
43870302
43870303
43879901
43879902
43879903
Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid in Wheat (Winter
and Spring) Following Ground Applications with 2,4-D Dimethylamine Salt:
(Final Report): Lab Project Number: AA940502: HWI 6397-152. Unpublished
study prepared by American Agricultural Services, Inc. and Hazleton
Wisconsin, Inc. 607 p.

Barker, W. (1995) Determination of Frozen Storage Stability for 2,4-
Dichlorophenoxy Acetic Acid (2,4-D) in/on Crops: Final Report: Lab Project
Number:  93-0044: ENC-2/93: 93-0044ITFH. Unpublished study prepared by
EN-CAS  Analytical Labs. 793 p.

Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Wild Rice (Zizania palustris
L.): Lab Project Number: 1015.92-MN01: 1015.92-NDR09: PR 1015.
Unpublished study prepared by IR-4. 246 p.

Johnson,  G; Strickland, M. (1995) Storage Stability of (2,4-
Dichlorophenoxy)Acetic Acid Residues in/on Raw Orange, Grapefruit, Lemon
Fruit and  Processed Lemon Products: Final Report: Lab Project Number: 101-
006: R289408: CCQC 94-03. Unpublished study prepared by Western
EcoSystems Technology; Research for Hire; and Corning Hazleton. 205 p.

Johnson,  G; Strickland, M. (1995) Magnitude of Residues in/on Products
Processed from Lemons Treated with (2,4-Dichlorophenoxy)Acetic Acid
Isopropyl Ester: Final Report: Lab Project Number: 101-005: R289407:
R289409. Unpublished study prepared by Western EcoSystems Technology;
Research for Hire; and Corning Hazleton. 267 p.

Johnson,  G; Strickland, M. (1995) Magnitude of Residues in/on California
Citrus Fruit after Growth Regulator Treatments with (2,4-
Dichlorophenoxy)Acetic Acid Isopropyl Ester: Final Report: Lab Project
Number:  101-004: R289401: R289402. Unpublished study prepared by Western
EcoSystems Technology; Research for Hire; and Corning Hazleton. 337 p.

Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Peach: Lab
Project Number: 4255.93-CAR05: 4255.93-GA08: 4255.93-NJ01. Unpublished
study prepared by Environmental Technologies Institute, Inc. and Interregional
Research Project No. 4. 282 p.

Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Cherry: Lab
Project Number: 4254.92-NDR03: 4254.94-CA49: 4254.92-MHO.
Unpublished study prepared by Environmental Technologies Institute, Inc. and
Interregional Research Project No. 4. 264 p.

Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Plum: Lab
Project Number: 4257.93-CAR06: 4257.93-WA01: 4257.93-MI04.
Unpublished study prepared by Environmental Technologies Institute, Inc. and
Interregional Research Project No. 4. 348 p.
                                   Page 220 of 304

-------
                                2,4-D Bibliography
43879904
43879905
43886401
43886402
43886403
43886404
43886405
43886406
43893701
43943101
Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Pistachios:
Lab Project Number: 4301.94-CAR10: 4301.94-CA99: 4301.94-CA08.
Unpublished study prepared by Environmental Technologies Institute, Inc. and
Interregional Research Project No. 4. 215 p.

Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Asparagus: Lab Project
Number: 04090.94-YAR14: 04090.92-YAR01: 4090.92-WA12. Unpublished
study prepared by Interregional Research Project No. 4. 348 p.

Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Potato
(Reregistration): Lab Project Number: 04302: .92-ND04: .92-CA24.
Unpublished study prepared by University of Idaho; University of Maine; and
University of Wisconsin. 783 p.

Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Cranberry
(Reregistration): Lab Project Number: 4297.92-NDR08: 4297.92-MA01:
4297.92-WI07. Unpublished study prepared by University of Massachusetts and
University of Wisconsin. 303 p.

Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Blueberry (Lowbush): Lab
Project Number: 4295.94-CAR26: 94-CAR96: R&R 520.XLS. Unpublished
study prepared by University of California and University of Maine. 166 p.

Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Strawberry (Reregistration):
Lab Project Number: 04179.95-CAR03:  4179.95-WA13: 4179.95-WA14.
Unpublished study prepared by Washington State University and University of
Wisconsin. 422 p.

Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Pear (Reregistration): Lab
Project Number: 04256.92-WA16: 4256.92-NY18: 4256.92-CA94.
Unpublished study prepared by Cornell University; Collins Ag Consultant, Inc.;
and University of California. 515 p.

Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Corn (Sweet): Lab Project
Number: 4183.95-WA29: 4183.95-SC11: 4183.95-WI07. Unpublished study
prepared by University of Wisconsin; University of Florida; and Oregon State
University. 628 p.

Siirila, A. (1995) Method Validation for  the Determination of (2,4-
Dichlorophenoxy)Acetic Acid in/on California Citrus Fruit and Lemon
Processed Products: Revised Final Report: Lab Project Number: HWI 6578-
101A: MP-CCO1-MA: HWI 6179-100A. Unpublished study prepared by
Hazleton Wisconsin, Inc. 149 p.

Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Apple: Lab
Project Number: PR 4182: 4182.94-CAR25: 4182.92-NYP06. Unpublished
study prepared by Environmental  Technologies Institute, Inc. 347 p.
                                   Page 221 of 304

-------
                                 2,4-D Bibliography
43947901
43963801
43963802
44016501
44016502
44024801
44135201
44190301
44190302
44211901
44268501
Kunkel, D. (1996) 2,4-D: Magnitude of the Residue on Grape: Lab Project
Number: 04298.94-CAR24: 04298.94-CA70: 04298.94-CA71. Unpublished
study prepared by Interregional Research Project No. 4. 242 p.

Kunkel, D. (1996) 2,4-D: Magnitude of the Residue on Filberts (Reregistration):
Lab Project Number: 6106.95-CAR06: 6106.95-OR16: 6106.95-OR17.
Unpublished study prepared by Interregional Research Project No. 4. 323 p.

Kunkel, D. (1996) 2,4-D: Magnitude of the Residue on Pecan (Reregistration):
Lab Project Number: 6125.95-CAR18: 6125.95-NC11: 6125.95-NC12.
Unpublished study prepared by Interregional Research Project No. 4. 382 p.

Howard, J. (1996) Development, Validation and Radiovalidation of Analytical
Methodology for the Quantitation of Residues of 2,4-Dichlorophenoxyacetic
Acid (2,4-D) in Poultry Muscle, Liver, Fat and Eggs: Lab Project Number: 949:
1874. Unpublished study prepared by PTRL East, Inc. 80 p.

Howard, J. (1996) Development and Validation of Analytical Methodology for
the Quantitation of Residues of 2,4-Dichlorophenoxyacetic Acid (2,4-D) in Beef
Muscle, Liver, Kidney, Fat and Milk: Lab Project Number: 912:  1848.
Unpublished study prepared by PTRL East, Inc. 127 p.

Krautter, G.; Downs, J. (1996) 2,4-D: Magnitude of Residues in Meat and Milk
of Lactating Dairy Cows: Lab Project Number: 886: 1889: 912. Unpublished
study prepared by PTRL East, Inc. 608 p.

Biever, R. (1996) A Freshwater Fish and Shellfish Magnitude of Residues Study
in a Static Aquatic System: Amine 400 2,4-D Weed Killer: Lab Project Number:
3140.0796.6106.395: 96-9-6660: 1064. Unpublished study prepared by
Springborn Labs, Inc. and PTRL East, Inc. 167 p.

Carringer, S. (1996) Magnitude of the Residue of 2,4-D Acid in Wheat (Winter
and Spring) Following Ground Applications with 2,4-D 2-Ethylhexyl Ester:
(Final Report): Lab Project Number: AA960501: CHW 6397-164: 6397-164.
Unpublished study prepared by American Agricultural Services, Inc. and
Corning Hazleton, Inc. 498 p.

Carringer, S. (1996) Magnitude of the Residue of 2,4-D Acid in Wheat (Winter
and Spring) Following Ground Applications with 2,4-D Dimethylamine Salt:
(Final Report): Lab Project Number: AA960502: CHW 6397-163: 6397-163.
Unpublished study prepared by American Agricultural Services, Inc. and
Corning Hazleton, Inc. 498 p.

Kunkel, D. (1997) 2,4-D: Magnitude of the Residue on Almond: (Draft Report):
Lab Project Number: 4306.96-CAR08: 4306.96-CA16: 4306.96-CA17.
Unpublished study prepared by Interregional Research Project No. 4. 539 p.

Kunkel, D. (1997) 2,4-D: Magnitude of the Residue on Blueberry (High Bush):
Lab Project Number: 3085.93-NDR03: 3085.93-OR18: 3085.93-NC04.
Unpublished study prepared by Interregional Research Project No. 4. 454 p.
                                   Page 222 of 304

-------
                                2,4-D Bibliography
44577801
44967401
45245601
45462201
45512701
45647101
45665801
45672201
Biever, R. (1998) A Freshwater Shellfish Magnitude of Residue Study in a
Static Aquatic System with 2,4-D Dimethylamine Salt: Lab Project Number:
3140.1196.6107.395:1081. Unpublished study prepared by Springborn
Laboratories, Inc. andPTRL, Inc. 133 p.  {860.1400}

Howard, J. (1999) Determination of the Stability of 2,4-Dichlorophenoxyacetic
Acid (2,4-D) in Frozen Clam Tissue:  Lab Project Number: 1135: 2062.
Unpublished study prepared by PTRL East, Inc. 44 p.

Mester, T.; Fischer, E. (2000) Magnitude of the Residue of 2,4-D on Grape Raw
Agricultural Products and Processed Commodities:  Final Study Report: Lab
Project Number: 97677: 44086: 97677-A. Unpublished study prepared by ABC
Laboratories California. 181 p. {OPPTS 860.1500}

Johnson, G.; Stickland, M. (2001) Magnitude of Residues in/on Citrus Fruit
After Post Harvest Treatments with (2,4-Dichlorophenoxy) acetic Acid
Isopropyl Ester: Final Report: Lab Project Number: CCQC 00-01: 6578-708:
101-014. Unpublished study prepared by Western EcoSystems Technology
(WEST, Inc.) and Covance Laboratories. 176 p.

Arsenovic, M. (2001) 2,4-D:  Magnitude of the Residue on Hops: Lab Project
Number: A5024: A5024.99-CAR22:  A5024.99-WA48. Unpublished study
prepared by IR-4 Western Region Leader Laboratory; WSU, FEQL; Western
Biochemical Consulting, Inc. and University of Idaho.  124 p.

Kunkel, D. (1996) 2,4-D: Magnitude  of the Residue on Grape: Lab Project
Number: 04298: ENC-2/93: 4298.94-CA70. Unpublished study prepared by
Rutgers University. 242 p.

Tieu, H. (2001) Magnitude of Weedaxe (2,4-D) Residues in Grapes: Lab Project
Number: ERS21075: CA01: 21-075.  Unpublished study prepared by Primus
Labs. 110 p.  {OPPTS 860.1500, 860.1000}

Tieu, H. (2002) Magnitude of Weedaxe (2,4-D) Residue in Citrus: Lab Project
Number: R270206. Unpublished study prepared by Primus Labs. 95 p. {OPPTS
860.1000,860.1500}
Product Chemistry MRID References
40443301
41067001
41015001
Collins, R. (1987) Product Chemistry: 2,4-D Isopropyl Ester: Labo- ratory
Project ID: 2,4-D ISOPROPYL ESTER. Unpublished study prepared by
Gilmore, Inc. lip.

May & Baker Ltd. (1988) Product Chemistry Data Requirements under EPA
Pesticide Assessment Guidelines dated Oct 1982 (2,4-Dichlor- ophenoxy)acetic
Acid 2,4-D Technical Acid. Unpublished study. 138 p.

Braden, G; Feiler, W. (1989) Technical Isopropyl Ester of 2,4-D: Product
Chemistry Ingredients Identification. Unpublished study prepared by Amvac
Chemical Corporation. 39 p.
                                   Page 223 of 304

-------
                                 2,4-D Bibliography
4105002
4105003
40911901
40911902
40911903
41055801
41055802
41055803
41055804
41055805
41055806
41055807
41055808
41055809
41055810
41055811
Braden, G.; Feiler, W. (1989) Technical Isoproryl Ester of 2,4-D: Product
Chemistry Analysis. Unpublished study prepared by Amvac Chemical Corp.  10
P-

Feiler, W.; Braden, G. (1989) Technical Isopropyl Ester of 2,4-D: Produst
Chemistry: Physical and Chemical Properties. Unpublish- ed study prepared by
Amvac Chemical Corp. 15 p.

Gegel, B. (1987) 2,4-D Isooctyl (2-Ethylhaxel) Ester: Product Identity and
Composition. Unpublished study prepared by Dow Chemical Co. 20 p.

Gegel, B. (1987) 2,4-D Butoxyethyl Ester: Product Identity and Composition.
Unpublished study prepared by Dow Chemical Co. 20 p.

Gegel, B. (1987) 2,4,-D Butyl Esters: Product Identity and Composi- tion.
Unpublished study prepared by Dow Chemical Co. 20 p.

Dow Chemical Co. (1989) 2,4-D Acid: Product Identity and Composi- tion.
Unpublished study. 40 p.

Dow Chemical Co. (1989) 2,4-D Acid: Analysis and Certification of Product
Ingredients. Unpublished study. 32 p.

Dow Chemical Co. (1989) 2,4-D Acid: Physical and Chemical Charac- teristics.
Unpublished study. 6 p.

Dow Chemical Co. (1989) 2,4-D Acid, Flake: Product Identity and
Composition. Unpublished study. 14 p.

Dow Chemical Co. (1989) 2,4-D Acid, Flake: Analysis and Certifica- tion of
Product Ingredients. Unpublished study. 12 p.

Dow Chemical Co. (1989) 2,4-D Isooctyl (2-Ethylhexyl) Ester: Product Identity
and Composition. Unpublished study. 26 p.

Dow Chemical Co. (1989) 2,4-D Isooctyl (2-Ethylhexyl) Ester: Analy- sis and
Certification of Product Ingredients. Unpublished stu- dy. 35  p.

Dow Chemical Co. (1989) 2,4-D Isooctyl (2-Ethylhexyl) Ester: Physi- cal and
Chemical Characteristics. Unpublished study. 6 p.

Dow Chemical Co. (1989) 2,4,-D DMA-6 Unsequestered Weedkiller:  Pro- duct
Identity and Composition. Unpublished study. 23 p.

Dow Chemical Co. (1989) 2,4-D-6 Unsequestered Weedkiller: Analysis and
Certification of Product Ingredients. Unpublished study. 22 p.

Dow Chemical Co. (1989) 2,4-D DMA-6 Unseqestered Weedkiller: Physical
and Chemical Characteristics. Unpublished study. 6 p.
                                   Page 224 of 304

-------
                                 2,4-D Bibliography
41055812
41055813
41055814
41055815
41055816
41055817
41055818
41055819
41055820
41206901
41224201
41203301
41219601
41220101
41219701
Dow Chemical Co. (1989) 2,4-D Butoxyethyl Ester: Product Identity and
Composition. Unpublished study. 27 p.

Dow Chemical Co. (1989) 2,4-D Butoxy ethyl Ester: Analysis and Certification
of Product Ingredients. Unpublished study. 34 p.

Dow Chemical Co. (1989) 2,4-D Butoxy ethyl Ester: Physical and Chem- ical
Characteristics. Unpublished study. 6 p.

Dow Chemical Co. (1989) 2,4-D Isopropylamine Salt: Product Identity and
Composition. Unpublished study. 22 p.

Dow Chemical Co. (1989) 2,4-D Isopropylamine Salt: Analysis and
Certification of Product Ingredients. Unpublished study. 26 p.

Dow Chemical Co. (1989) 2,4-D Isopropylamine Salt: Physical and Chemical
Characteristics. Unpublished study. 6 p.

Dow Chemical Co. (1989) 2,4-D Triisopropanolamine Salt-4: Product Identity
and Composition. Unpublished study. 23 p.

Dow Chemical Co. (1989) 2,4-D Triisopropanolamine Salt-4: Analysis and
Certification of Product Ingredients. Unpublished study. 22 p.

Dow Chemical Co. (1989) 2,4-D Triisopropanolamine Salt-4: Physical and
Chemical Characteristics. Unpublished study. 6 p.

Fisher, J. (1989) Product Chemistry: Agrolinz Isopropyl 2,4-D Ester Technical:
Analytical Methods. Unpublished study prepared by Agrolinz, Inc.  17 p.

Fisher, J. (1989) Product Chemistry Data Requirements for Isopropyl 2,4-D
Ester Technical: Proj. ID P-890824. Unpublished study prepared  by Agrolinz,
Inc. 61 p.

Silvestre, D. (1989) 2,4-D Determination of Poly chlorinated Diben- zo-p-
dioxins and Dibenzofurans by GC/MS: Laboratory ID:  89-10. Unpublished
study prepared by Rhone-Poulenc Industrialisation.  133 p.

Armbruster, J. (1989) EPA Reg. No. 61649-001 - Certification of Limits for
Dibenzo-p-Dioxins/Dibenzofurans. Unpublished study prepared by  AGRO-
GORCorp. 179 p.

Berry, D. (1989) Final Report of the Determination of Halogenated Dibenzo-p-
dioxins and Dibenzofurans in 2,4-Dichlorophenoxyacetic Acid: Proj. ID AL 89-
030290. Unpublished study prepared by Dow Chemical Co., Analytical
Sciences Laboratories. 168 p.

Ambruster, J. (1989) Certification of Limits for Dibenzo-p-Dioxins/
Dibenzofurans. Unpublished study prepared by FBI/Gordon Corp. 179 p.
                                   Page 225 of  304

-------
                                2,4-D Bibliography
41223801
41349001
41349002
41376701
41203301
41332004
41332009
41496701
41599401
41246701
41223801
41647001
Armbruster, J. (1989) EPA Reg. No. 2217-455 - Product Chemistry ?of 2,4-
Dichlorophenoxyacetic Acid|. Unpublished study prepared by Agro-Gor Corp.
30 p.

Fiene, J.; Mahlburg, W. (1990) Determination of Halogenated Dibenzo -p-
Dioxins and Dibenzofurans in 2,4-D Acid: Lab Project Number: 90-1.
Unpublished study prepared by Chemserv Industries Service Ges.m.b.H. 323 p.

Fiene, J.; Mahlburg, W. (1989) Determination of Halogenated Dibenzo -p-
Dioxins and Dibenzofurans in 2,4-D Isooctyl Ester Technical: Lab Project
Number: 90/2. Unpublished study prepared by Chem- serve Industries Service
Ges.m.b.H. 325 p.

Fisher, J. (1989) Manufacturing Process for the Production of Esters of 2,4-
Dichlorophenoxyacetic Acid: Lab Project ID: P89030L. Unpublished study
prepared by Agrolinz, Inc. 15 p.

Silvestre, D. (1989) 2,4-D Determination of Poly chlorinated Diben- zo-p-
dioxins and Dibenzofurans by GC/MS: Laboratory ID: 89-10. Unpublished
study prepared by Rhone-Poulenc Industrialisation. 133 p.

Bailey, R; Hopkins, D. (1987) 2,4-Dichlorophenoxyacetic Acid: Determination
of Octanol/Water Partition Coefficient: Lab Project Number:
ES/DR/0002/2297/9. Unpublished study prepared by the Dow Chemical Co. 12
P-

Helmer, D. (1987) Determination of the Octanol/Water Partition Coefficient for
2,4- Dichlorophenoxy Acetic Acid, 2-Ethylhexyl Ester: Lab Project Number:
ML/AL/87/70819. Unpublished study prepared by Dow Chemical Co. 14 p.

DowElanco (1990) 2,4-D Acid: Product Identity and Composition:
"Amendment". Unpublished study prepared by The Dow Chemical Co. 51 p.

Buddie, G (1990) 2,4-D Technical Acid Product Chemistry: Supple- mental
Information: Lab Project Number: ACD/GCB/MS/8364. Unpub- lished study
prepared by Rhone-Poulenc Ag Co. 10 p.

Armbruster, J. (1989) Product Chemistry:  AUS  90 Technical. Unpub- lished
study prepared by AGRO-GOR Corp. 30  p.

Armbruster, J. (1989) EPA Reg. No. 2217-455 - Product Chemistry ?of 2,4-
Dichlorophenoxyacetic Acid|. Unpublished study prepared by Agro-Gor Corp.
30 p.

Heimerl, J. (1990) Determination of the Octanol/Water Partition Coefficient of
2,4-D Butoxyethyl Ester (2,4-D BEE): Lab Project Number: ML-AL 90-
080378. Unpublished study prepared by Dow Chemical USA. 22 p.
                                   Page 226 of 304

-------
                                 2,4-D Bibliography
41669501
41755701
41637501
41745301
41745302
41735701
41789901
41789902
41926201
41926202
41926203
41724201
Moore, R. (1990) 2,4-Dichlorophenoxyacetic acid, butoxyethyl ester: Aqueous
Solubility: Lab Project Number: 9585/F/02. Unpublished study prepared by
Midwest Research Institute. 17 p.

Schriber, C. (1990) Chemical Stability of 2,4-D Dimethyl Salt Solution: Lab
Project Number: GH-C 24428. Unpublished study prepared by DowElanco. 17
P-

Armbruster, J. (1990) Revised Partial Product Chemistry. Unpub- lished study
prepared by PBI/GORDON Corp. 18 p.

Etchepareborda, I;  Sancrica, J. (1990) Storage Stability of Tech- nical 2,4
Dichlorophenoxyacetic Acid.  Unpublished study pre- pared by Atanor S.A./
Laboratories de Estudios Analiticos. 8 p.

Castaneda, J. (1990) 2,4 Dichlorophenoxyacetic Acid Explodability:
Unpublished study prepared by Institute de Desarrollo Tecnolo- gico/para la
Industna Quimica (INTEC). 8 p.

Silvestre, D. (1990) Determination of Polychorinated Dibenzo-p- Dioxins and
Dibenzofurans In 2,4-D: Complementary Analytical Raw Data Relative to
Study 89-10: Lab Project Number: 343-484.  Unp- ublished study prepared by
Rhone-Poulenc Industrialisation. 100 p.

Rajoharison, G. (1991) Responses to EPA Queries on 2,4-D Product Chemistry:
Lab Project Number: GR/BC/91-189/PTC211. Unpublished study prepared by
Rhone-Poulenc Chimie. 9 p.

Buddie, G; Patel, P. (1991) 2,4-dichlorophenoxyacetic acid (2,4- D): Analysis
and Certification of Product Ingredients, Provision of Supplementary Analytical
Method Validation: Lab Project Num- ber: P-91-016. Unpublished study
prepared by Rhone-Poulenc Agriculture Ltd. 20 p.

Etchepareborda, I.;  Sancricca, J. (1991) Preliminary Analysis  of 2,4
Dichlorophenoxyacetic acid 97%.  Unpublished study prepared by Atanor S. A.
17 p.

Etchepareborda, I. (1991) pH of 2,4-Dichlorophenoxyacetic acid 97%.
Unpublished study prepared by Atanor S. A. 5 p.

Etchepareborda, I;  Sancricca, J. (1991) Storage Stability (1 year in commercial
packaging) of 2,4 Dichlorophenoxyacetic acid 97%.  Unpublished study
prepared by Atanor S. A. 7 p.

Landvoight, W. ; Mahlburg, W. (1990) Quality Assurance Project Plan for
Determination of Halogenated Dibenzo-p-Dioxins and Dibenzo- furans... in 2,4-
D...: Lab Project Number: 90-3. Unpublished study prepared by Chemserve
Industries  Service Ges.m.b.H. 43 p.
                                    Page 227 of 304

-------
                                2,4-D Bibliography
41724202
41724203
41796201
41796202
41790602
41790601
41123601
40808301
41978001
41978002
41308901
41332004
Landvoight, W.; Mahlburg, W. (1990) Determination of Halogenated Dibenzo-
p-Dioxins and Dibenzofurans in 2,4-D Acid by Method of Analysis 50288: Lab
Project Number: 90-4. Unpublished study prepared by Chemserve Industries
Service Ges.m.b.H. 561 p.

Landvoight, W.; Mahlburg, W. (1990) Determination of Halogenated Dibenzo-
p-Dioxins and Dibenzofurans in 2,4-D Isooctyl Ester by Method of Analysis
50288: Lab Project Number: 90-5. Unpublished study prepared by Chemserve
Industries Service Ges.m.b.H. 423 p.

Armbruster, I (1989) EPA Reg No. 61469-001-Product Chemistry.
Unpublished study prepared by Agro-Gor Corp. 8 p.

Armbruster, J. (1989) Certification of Limits for Dibenzo-p-Dioxin-
s/Dibenzofurans. Unpublished study prepared by PBI/Gordon Corp. 489 p.

Armbruster, J. (1989) Certification of Limits for Dibenzo-p-Dioxin-
s/Dibenzofurans. Unpublished study prepared by PBI/Gordon Corp. 489 p.

Armbruster, J. (1991) Product Chemistry: 61 & 63 Series: (2,4-D Acid, Reg.
No. 2217-455). Unpublished study prepared by PBI Gordon Corp. 8 p.

Sawyer, R. (1989) Riverdale Sodium Salt of 2,4-D: Product Chemi- stry: Project
ID: Sodium Salt of 2,4-D. Unpublished study pre- pared by Riverdale Chemical
Co. 18 p.

Allen, W.; Mahlburg, W.  (1988) Clean Crop 2,4-D Acid: Product Chemistry
Data: Study No. 88-9A. Unpublished study prepared by Transbas, Inc.
Laboratory. 64 p.

DowElanco (1991) 2,4-D Isopropylamine Salt: Response to 2,4-D Task 4:
Registrant's Response to Product Chemistry Data Requirements DEB Nos.
5454.5455, 5439, 5440-5544 Dated September 22, 1989. Unpublished study
prepared by DowElanco. 16 p.

Schriber, C. (1991) Chemical Stability of 2,4-D Isopropylamine Salt Solution:
Lab Project Number: 90088. Unpublished study prepared by DowElanco 17 p.

Reim, R. (1989) Dissociation of 2,4-Dichlorophenoxyacetic Acid (2,4-D) and
2,4-D Dimethylamine Salt in Water: Lab Project Number: ML AL 89 041014.
Unpublished study prepared by Dow Chemical U.S.A. 25  p.

Bailey, R.; Hopkins, D. (1987) 2,4-Dichlorophenoxyacetic Acid: Determination
of Octanol/Water Partition Coefficient: Lab Project Number:
ES/DR/0002/2297/9. Unpublished study prepared by the Dow Chemical Co. 12
P-
                                   Page 228 of 304

-------
                                2,4-D Bibliography
42023601
41431301
41964401
42021000
42021001
42021002
42227501
41973501
41973502
41968301
41968302
41968303
Desai, L. (1991) Technical 2,4-D Acid: Physical and Chemical Char- acteristics:
Lab Project Number: 91-GR-0004. Unpublished study prepared by Toxicon
Corp. 120 p.

Chadrabarti, A. (1989) Vapor Pressure of the Butoxyethyl Ester of (2,4-
Dichlorophenoxy) Acetic Acid Measured by the Knudsen-Effu- sion/Weight
Loss Method: Lab Project Number: ML-AL-89-020197. Unpublished study
prepared by Dow Chemical U.S.A. 12 p.

DowElanco (1991) Response to 2,4-D Task 4: Registrant's Response to Product
Chemistry Data Requirements DEB No. 5454-5455, 5440-5544 Dated Sep. 22,
1989 (Tinsworth Letter Dated January 23, 1990) 2,4-Dimethylamine Salt.
Unpublished study prepared by DowElanco .  17

DowElanco (1991) Submission of product chemistry data in support of
reregistration of 2,4-D.  Transmittal of 2 studies.

MacDaniel, R; Weiler, D.  (1987) Vapor Pressure Determination of 2,4-
Dichlorophenoxyacetic Acid: Dimethylamine Salt: Lab Project Number: 41023.
Unpublished study prepared by Rhone-Poulenc Inc. 9 p.

Hopkins, D. (1987) 2,4-Dichlorophenoxyacetic Acid Dimethylamine Salt:
Determination of the Water Solubility: Lab Project Number: ES-DR-0008-
3556-3. Unpublished study prepared by The Dow Chemi- cal Company. 15 p.

Sawyer, R. (1990) Product Chemistry: Riverdale Sodium Salt of 2,4-D.
Unpublished study prepared by Riverdale Chemical Co. 8 p.

DowElanco (1991) 2,4-D Acid and 2,4-D Acid Flake: Response to 2,4-D Task
4: Registrant's Response of Product Chemistry Data Require- ments Deb. No.
5454.5455,  5439, 5440-5544 Dated September 22, 1989. Unpublished study. 57
P-

Schriber, C. (1991) Chemical Stability of 2,4-Dichlorophenoxyacetic Acid: Lab
Project Number: 90089. Unpublished study prepared by DowElanco. 17 p.

DowElanco. (1991) 2,4,D Isooctyl  Ester (2-ethylhexyl ester): Response to 2,4-D
Task 4: Registrant's Response to Product Chemistry Data Requirements DEB
No. 5454-5455, 5489, 5440-5544 dated September 22, 1989. Unpublished
study, lip.

Helmer, D. (1987) Determination of the Water Solubility of 2,4-
dichlorophenoxy Acetic Acid, 2-ethylhexyl Ester: Lab Project No: ML-AL-87-
70817. Unpublished study  prepared by Dow Chemical USA. 13 p.

Schriber, C.; Tiszai, N.  (1991) Chemical Stability of 2,4-D 2-Ethyl hexyl Ester:
Lab Project Number: 90086. Unpublished study pre- pared by DowElanco. 17
P-
                                   Page 229 of 304

-------
                                2,4-D Bibliography
41961301
42116702
42188601
42537501
42487901
41332002
41972501
42795401
42798201
42798101
42831001
41431101
DowElanco (1991) 2,4-D Butoxyethyl Ester: Response to 2,4-D Task 4:
Registrants Response to Product Chemistry Data Requirements DEB No. 5454-
5455, 5440-5544 Dated September 22, 1989. Unpublished study. 11 p.

Feiler, W. (1991) Technical Isopropyl Ester of 2,4-D~Product Chemistry:
Physical and Chemical Properties. Unpublished study prepared by Amvac
Chemical Co. 4 p.

Feiler, W. (1991) Technical Isopropyl Ester of 2,4-D: Product Chemistry
Ingredients Identification. Unpublished study prepared by Amvac Chemical
Corp. 41 p.

Sawyer, R. (1992) Product Chemistry-Addendum: Riverdale Sodium Salt of
2,4-D. Unpublished study prepared by Riverdale Chemical Co. 14 p.

Schriber, C. (1992) Chemical Stability of 2, 4-Dichlorophenoxyacetic Acid,
Butoxy ethyl Ester Solution: Lab Project Number: 90090. Unpublished study
prepared by DowElanco. 16 p.

Hopkins, D. (1987) 2,4-Dichlorophenoxyacetic Acid: Determination of the
Water Solubility: Lab Project Number: ES/DR/0002/2297/8. Unpublished study
prepared by The Dow Chemical Co. 14 p.

Gallacher, A. (1991) Dissociation of 2,4-Dichlorophenoxyacetic Acid (2,4-D)
and 2,4-D Diethanolamine Salt in Water: Lab Project Num- ber: 4102-90-0304-
AS: 4102-90-03 04-AS-001. Unpublished study prepared by Ricerca, Inc. 231 p.

Murphy, J. (1993) Determination of Stability of 2,4-Dichlorophenoxyacetic
Acid (2,4-D) Technical Grade of Active Ingredient (TGAI): Lab Project
Number: FOR93058. Unpublished study prepared by Formulation Science and
Technology Lab. 9 p.

Murphy, G. (1993) Product Chemistry Review for DowElanco 2,4-D TIPA FI:
Lab Project Number: GM052993A. Unpublished study prepared by
DowElanco. 4 p.

Murphy, G. (1993) Response to the Letter Written by Lois A. Rossi (10/05/02):
Subject: Product Chemistry Review for DowElanco 2,4-D DMA FI: Lab Project
Number: GM052793A. Unpublished  study prepared by DowElanco. 7 p.

Murphy, G. (1993) Determination of Melting Point of 2,4-
Dichlorophenoxyacetic Acid Isopropylamine Salt (2,4-D IP A) Technical Grade
of Active Ingredient (TGAI): Lab Project Number: FOR93054. Unpublished
study prepared by Formulation Science and Technology Lab. DowElanco. 9 p.

Chakrabarti, A. (1990) Vapor Pressure of the Isopropyl Amine Salt of 2,4-
Dichlorophenoxy Acetic Acid Measured by the Knudsen-Effu- sion/Weight
Loss Method: Lab Project Number: ML-AL 89-020235. Unpublished study
prepared by Dow Chemical U.S.A. lip.
                                   Page 230 of 304

-------
                                2,4-D Bibliography
42798301
42831101
42829901
42830901
42857201
42857202
42857203
42857204
42857205
42857206
42857207
Murphy, G. (1993) Response to Letter Written by Lois A. Rossi (1/08/93):
Subject: Product Chemistry Review for DowElanco 2,4-D IPA FI: Lab Project
Number: GM052793B. Unpublished study prepared by DowElanco. 7 p.

Murphy, G. (1993) Determination of Boiling Point and Solubility of 2,4-
Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester (2,4-D 2-EHE) Technical
Grade of Active Ingredient (TGAI): Lab Project Number: FOR93055.
Unpublished study prepared by Formulation Science and Technology Lab,
DowElanco. 17 p.

Murphy, G. (1993) Determination of Melting Point of 2,4-
Dichlorophenoxyacetic Acid Dimethylamine Salt (2,4-D DMA) Technical
Grade of Active Ingredient (TGAI): Lab Project Number: FOR93053.
Unpublished study prepared by Formulation Science and Technology Lab.
DowElanco. 9 p.

Murphy, G. (1993) Determination of Boiling Point and Solubility of 2,4-
Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) Technical Grade
Active Ingredient (TGAI): Lab Project Number: FOR93057. Unpublished study
prepared by Formulation Science and Technology Lab. DowElanco. 17 p.

Malone, S. (1992) Characterization of Technical Diethanolamine Salt of (2,4-
Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0055-AS: 4102-
92-0055-AS-001. Unpublished study prepared by Ricerca, Inc. 47 p.

Malone, S. (1992) Characterization of Purified Diethanolamine Salt of (2,4-
Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0056-AS: 4102-
92-0056-AS-001. Unpublished study prepared by Ricerca, Inc. 73 p.

Wojcieck, B. (1992) Color, Physical State, Odor of the Diethanolamine Salt of
(2,4-Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0082-AS:
4102-92-0082-AS-001. Unpublished study prepared by Ricerca, Inc. 24 p.

Wojcieck, B. (1992) Bulk Density of the Diethanolamine Salt of (2,4-
Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0083-AS: 4102-
92-0083-AS-001. Unpublished study prepared by Ricerca, Inc. 22 p.

Douglass, M. (1993) Technical Diethanolamine Salt of (2,4-Dichlorophenoxy)
Acetic Acid-Solubility: Lab Project Number: 4102-92-0057-AS: 4102-92-
0057-AS-001. Unpublished study prepared by Ricerca, Inc. 92 p.

Douglass, M. (1993) Purified Diethanolamine Salt of (2,4-Dichlorophenoxy)
Acetic Acid-Vapor Pressure: Lab Project Number: 4102-92-0058-AS: 4102-
92-0058-AS-001. Unpublished study prepared by Ricerca, Inc. 68 p.

Douglass, M. (1993) Purified Diethanolamine Salt of (2,4-Dichlorophenoxy)
Acetic Acid-Octanol/Water Partition Coefficient: Lab Project Number:  4102-
92-0059-AS: 4102-92-0059-AS-001. Unpublished study prepared by Ricerca,
Inc. 55 p.
                                   Page 231 of 304

-------
                                2,4-D Bibliography
42857208
42857209
41961301
42786501
43260501
43325001
43325002
43325003
43302001
43516401
43516402
Furlong, K. (1992) pH of the Diethanolamine Salt of (2,4-Dichlorophenoxy)
Acetic Acid: Lab Project Number: 4102-92-0088-AS: 4102-92-0088-AS-001.
Unpublished study prepared by Ricerca, Inc. 27 p.

Malone, S. (1993) Technical Diethanolamine Salt of (2,4-Dichlorophenoxy)
Acetic Acid-Stability: Lab Project Number: 4102-92-0085-AS: 4102-92-0085-
AS-001. Unpublished study prepared by Ricerca, Inc. 51 p.

DowElanco (1991) 2,4-D Butoxy ethyl Ester: Response to 2,4-D Task 4:
Registrants Response to Product Chemistry Data Requirements DEB No. 5454-
5455? 5440-5544 Dated September 22, 1989. Unpublished study. 11 p.

Feiler, W. (1993) Technical Isopropyl Ester of 2,4-D: Product Chemistry.
Unpublished study prepared by Amvac Chemical Corp. 14 p.

Krause, R.; Jones-Jefferson, T.; Wallace, T. (1994) Storage Stability of 2,4-D
Acid: One Year Ambient Temperature Storage Study Results: Lab Project
Number: FOR93069. Unpublished study prepared by DowElanco, Formulation
Science & Technology. 14 p.

Kinnunen, C. (1994) Series 63: Determination of the Boiling Point of 2,4-
Dichlorophenoxyacetic Acid Butoxy ethyl Ester (2,4-D BEE) TGAI: Lab Project
Number: FOR94079. Unpublished study prepared by DowElanco. 9 p.

Kinnunen, C. (1994) Series 63: Determination of the Boiling Point of 2,4-
Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester (2,4-D 2-EHE) TGAI: Lab
Project Number: FOR94080. Unpublished study prepared by DowElanco. 9 p.

Kinnunen, C. (1994) Series 63: Determination of the Melting Point of 2,4-
Dichlorophenoxyacetic Acid Triisopropanolamine Salt (2,4-D) TGAI: Lab
Project Number: FOR93132. Unpublished study prepared by DowElanco. 9 p.

Braden, G (1994) Solubility of Isopropyl Ester of 2,4-D in Selected Organic
Solvents: Lab Project Number: SOL/018.  Unpublished study prepared by
Amvac Chemical Corp. R & D Labs. 16 p.

Haefele, L. (1995) Identity and Composition for Albaugh 2,4-D Technical Acid:
Final Report: Lab Project Number: 95-ALBG-012. Unpublished study prepared
by AC RN Labs. 37 p.

Willis, C. (1994) Preliminary Analysis and Precision and Accuracy of
Analytical Method Used to Validate Certified Limits: (2,4-Dichlorophenoxy)
Acetic Acid: Final Report: Lab Project Number: 810-17. Unpublished study
prepared by Case Consulting Labs., Inc. 114 p.
                                   Page 232 of 304

-------
                                 2,4-D Bibliography
43516403
43516404
43314701
43516401
43516402
43358801
43358802
43981801
44149301
44149302
43777501
Willis, C. (1994) 2,4-D (2,4-Dichlorophenoxyacetic acid): Physical and
Chemical Characteristics of 2,4-D: Color, Physical State, Odor, Melting Point,
Bulk Density, Solubility, Vapor Pressure, Dissociation Constant, Octanol/Water
Partition Coefficient, pH, Stability, Oxidizing or Reducing and Explodability:
Final Report: Lab Project Number: 810-18. Unpublished study prepared by Case
Consulting Labs., Inc. 25 p.

Willis, C. (1994) 2,4-D (2,4-Dichlorophenoxyacetic acid): Physical and
Chemical Characteristics of 2,4-D: Storage Stability and Corrosion
Characteristics: Interim Report: Lab Project Number: 810-19. Unpublished
study prepared by Case Consulting Labs., Inc. 14 p.

Kinnunen, C. (1994) Series 62-1: Preliminary Analysis of Product Sample of
2,4-Dichlorophenoxy Acetic Acid, Dimethylamine-6 (2,4-D DMA-6)
Sequestered for Dimethyl Nitrosamine: Lab Project Number: FOR93133.
Unpublished study prepared by DowElanco.  19 p.

Haefele, L. (1995) Identity and Composition for Albaugh 2,4-D Technical Acid:
Final Report: Lab Project Number: 95-ALBG-012. Unpublished study prepared
by AC RN Labs. 37 p.

Willis, C. (1994) Preliminary Analysis and Precision and Accuracy of
Analytical Method Used to Validate Certified Limits: (2,4-Dichlorophenoxy)
Acetic Acid: Final Report: Lab Project Number: 810-17.  Unpublished study
prepared by Case Consulting Labs., Inc. 114 p.

Kinnunen, C. (1994) Determination of Solubility of 2,4-Dichlorophenoxyacetic
Acid, Dimethylamine Salt: Lab Project Number: FOR94078. Unpublished study
prepared by DowElanco. 25 p.

Kinnunen, C. (1994) Determination of Solubility of 2,4-Dichlorophenoxyacetic
Acid, Isopropylamme Salt: Lab Project Number: FOR94081: GH-C 3356.
Unpublished study prepared by DowElanco.  24 p.

Willis, C. (1996) 2,4-D:  Analyses for Tetra- Through Octa-Chlorinated Dioxins
and Furans: Final Report: Lab Project Number: 810-24. Unpublished study
prepared by Case Consulting Labs, Inc. 1053 p.

Armbruster, J. (1996) Product Identity and Manufacturing Process: (2,4-D).
Unpublished study prepared by FBI/Gordon  Corp. 59 p.

Morrissey, M. (1996) Preliminary Analysis of 2,4-Dichlorophenoxyacetic Acid:
Final Report: Lab Project Number: CHW 6747-100. Unpublished study
prepared by Corning Hazleton Inc. 176 p.

Kinnunen, C. (1995) Preliminary Analysis of Product Sample of Flake 2,4-
Dichlorophenoxyacetic Acid: Lab Project Number: FOR95091. Unpublished
study prepared by DowElanco. 39 p.
                                    Page 233 of 304

-------
                                2,4-D Bibliography
43777502
43874601
44184201
44543502
44543503
44543504
44547901
44584501
44228601
44807001
Kinnunen, C. (1995) Preliminary Analysis of Product Sample of Molten 2,4-
Dichlorophenoxyacetic Acid: Lab Project Number: FOR95090. Unpublished
study prepared by DowElanco. 39 p.

Krause, R.; Jones-Jefferson, T. (1995) Storage Stability of 2,4-D; IPA Salt
Manufacturing-Use-Concentrate One Year Ambient Temperature Storage Study
Results: Lab Project Number: FOR94149. Unpublished study prepared by
DowElanco. 14 p.

Sanson, D. (1996) Product Identity and Composition of EH1330 Herbicide.
Unpublished study prepared by PBI/Gordon Corp. 8 p.

Pryce, A. (1998) 2,4-D Acid: Product Chemistry: Analysis Methods: Final
Report: Lab Project Number: AHM/EPA/98/AP/05: 97/0014. Unpublished
study prepared by A H Marks and Company Limited. 41 p. {OPPTS 830.1800}

Pryce, A. (1998) 2,4-D Acid: Product Chemistry: 5 Batch Analysis: Final
Report: Lab Project Number: AHM/EPA/98/AP/06. Unpublished study
prepared by A H Marks and Co. Limited. 154 p. {OPPTS 830.1700}

Hutchinson, N. (1998) 2,4-D TGAI:  Product Chemistry: Physical/Chemical
Properties: Final Report: Lab Project Number: AHM/EPA/98/NDH/Ol:
94/0010. Unpublished study prepared by A H Marks and Company Limited. 69
p. {OPPTS 830.6302,  830.6303, 830.6304,  830/6313, 830.7000, 830.7050,
830.7200, 830.7300, 830.7370, 830.7550, 830.7840, 830.7950}

Pryce, A. (1998) 2,4-D Acid: Product Chemistry: Existing Manufacturing
Process: Final Report:  Lab Project Number: AHM/EPA/98/AP/02. Unpublished
study prepared by A H Marks and Co., Ltd. 29 p. {OPPTS 830.1550, 830.1600,
830.1670, 830.1700, 830.1750}

Hamilton, T. (1998) Group A: Product Identity and Composition of 2,4-D
Butoxyethyl Ester Technical: Lab Project Number: GH-C 4680. Unpublished
study prepared by Dow AgroSciences LLC. 58 p. {OPPTS 830.1550, 830.1600,
830.1620, 830.1670, 830.1750}

Pruitt, P. (1996) Series 62-1, Preliminary Analysis and Series 62-2, Certified
Limits for 2,4-D Acid  Molten: Lab Project Number: GH-C 4238. Unpublished
study prepared by DowElanco. 40 p.

Madsen, S. (1999)  Group  A: Product Identity and Composition of 2,4-D
Isopropylamine Salt Technical—High pH Manufacturing Use Product
Containing 2,4-D Isopropylamine Salt: Lab Project Number: NAFST055.
Unpublished study prepared by Dow Agrosciences, LLC.  50 p. {OPPTS
830.1550, 830.1600, 830.1620, 830.1670, 830.1750}
                                   Page 234 of 304

-------
                                2,4-D Bibliography
44982101
44982102
45014801
44932701
45642701
44287101
45692501
40443301
40808301
41015001
Madsen, S.; Cobb, !; Hackett, B. et al. (1999) Group A: Product Identity and
Composition of 2,4-D 2-Ethylhexyl Ester Technical Grade Active Ingredient
and Manufacturing Use Product Containing 2,4-D 2-Ethylhexyl Ester Technical:
Lab Project Number: NAFST018. Unpublished study prepared by Dow
AgroSciences LLC. 54 p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670,
830.1750}

Hamilton, T. (1999) Ester Specific Analytical Method for Determination of
Esters of 2,4-Dichlorophenoxyacetic Acid (2,4-D) and Related Impurities: Lab
Project Number: DECO GL-AL 99-000252. Unpublished study prepared by
The Dow Chemical Company. 74 p. {OPPTS 830.1800}

VanderKamp, I; Kastl, P. (1999) Five Batch Analysis of 2,4-D 2-Ethyl-l-Hexyl
Ester Technical: Lab Project Number: DECO GL-AL 99-002231. Unpublished
study prepared by The Dow Chemical Co. 42 p. {OPPTS 830.1700}

Hutchinson, N. (1999) Preliminary Analysis of 5 Batches of 2,4-
dichlorophenoxyacetic Acid Technical Grade Active Ingredient: Final Report:
Lab Project Number: 98/0057. Unpublished study prepared by AH Marks and
Company Limited. 188 p. {OPPTS 830.1700}

Sarff, P. (2002) Determination of the Storage Stability and Corrosion
Characteristics for DMA-6 Sequestered (2,4-D Dimethylamine-6 Sequestered
Herbicide): Lab Project Number: 46237: NAFST494: NAF-190. Unpublished
study prepared by ABC Laboratories, Inc. 30 p. {OPPTS 830.6317, 830.6320}

Cramer, P. (1996) 2,4-Dichlorophenoxyacetic Acid: Analysis for
Poly chlorinated Dibenzo-p-dioxins and Dibenzofurans in Acid, Salt, and/or
Ester Technical Material: Final Report: Lab Project Number: 4199-A: MRI-
A\R4199-01: 4199. Unpublished study prepared by Midwest Research Institute.
811 p.

Lezotte, F.; Van Hoven, R; Nixon, W. (2002) Determination of Water
Solubility of 2,4-D Acid by the Shake Flask Method: Lab Project Number:
467C-103: 467/121801/7840/SUB467. Unpublished study prepared by Wildlife
International, Ltd. 43 p. {OPPTS 830.7840}

Collins, R. (1987) Product Chemistry: 2,4-D Isopropyl Ester: Labo- ratory
Project ID: 2,4-D ISOPROPYL ESTER. Unpublished study prepared by
Gilmore, Inc. lip.

Allen, W.; Mahlburg, W. (1988) Clean Crop 2,4-D Acid: Product Chemistry
Data: Study No. 88-9A. Unpublished study prepared by Transbas, Inc.
Laboratory. 64 p.

Braden, G.; Feiler, W. (1989) Technical Isopropyl Ester of 2,4-D: Product
Chemistry Ingredients Identification. Unpublished study prepared by Amvac
Chemical Corporation. 39 p.
                                   Page 235 of 304

-------
                                 2,4-D Bibliography
41015002
41015003
41055801
41055802
41055803
41055804
41055805
41055806
41055807
41055808
41055809
41055810
41055811
41055812
41055813
41055814
Braden, G.; Feiler, W. (1989) Technical Isoproryl Ester of 2,4-D: Product
Chemistry Analysis. Unpublished study prepared by Amvac Chemical Corp. 10
P-

Feiler, W.; Braden, G. (1989) Technical Isopropyl Ester of 2,4-D: Produst
Chemistry: Physical and Chemical Properties. Unpublish- ed study prepared by
Amvac Chemical Corp. 15 p.

Dow Chemical Co. (1989) 2,4-D Acid: Product Identity and Composi- tion.
Unpublished study. 40 p.

Dow Chemical Co. (1989) 2,4-D Acid: Analysis and Certification of Product
Ingredients. Unpublished study.  32 p.

Dow Chemical Co. (1989) 2,4-D Acid: Physical and Chemical Charac- teristics.
Unpublished study. 6 p.

Dow Chemical Co. (1989) 2,4-D Acid, Flake: Product Identity and
Composition. Unpublished study. 14 p.

Dow Chemical Co. (1989) 2,4-D Acid, Flake: Analysis and Certifica- tion of
Product Ingredients. Unpublished study. 12 p.

Dow Chemical Co. (1989) 2,4-D Isooctyl (2-Ethylhexyl) Ester: Product Identity
and Composition. Unpublished study.  26 p.

Dow Chemical Co. (1989) 2,4-D Isooctyl (2-Ethylhexyl) Ester: Analy-  sis and
Certification of Product Ingredients. Unpublished stu- dy. 35  p.

Dow Chemical Co. (1989) 2,4-D Isooctyl (2-Ethylhexyl) Ester: Physi- cal and
Chemical Characteristics. Unpublished study. 6 p.

Dow Chemical Co. (1989) 2,4,-D DMA-6 Unsequestered Weedkiller: Pro- duct
Identity and Composition. Unpublished study. 23 p.

Dow Chemical Co. (1989) 2,4-D-6 Unsequestered Weedkiller: Analysis and
Certification of Product Ingredients. Unpublished study. 22 p.

Dow Chemical Co. (1989) 2,4-D DMA-6 Unseqestered Weedkiller: Physical
and Chemical Characteristics. Unpublished study. 6 p.

Dow Chemical Co. (1989) 2,4-D Butoxyethyl Ester: Product Identity and
Composition. Unpublished study. 27 p.

Dow Chemical Co. (1989) 2,4-D Butoxy ethyl Ester: Analysis and Certification
of Product Ingredients. Unpublished study. 34 p.

Dow Chemical Co. (1989) 2,4-D Butoxy ethyl Ester: Physical and Chem- ical
Characteristics. Unpublished study. 6 p.
                                   Page 236 of 304

-------
                                 2,4-D Bibliography
41055815
41055816
41055817
41055818
41055819
41055820
41067001
41203301
41206901
41219601
41219701
41220101
41223801
41224201
Dow Chemical Co. (1989) 2,4-D Isopropylamine Salt: Product Identity and
Composition. Unpublished study. 22 p.

Dow Chemical Co. (1989) 2,4-D Isopropylamine Salt: Analysis and
Certification of Product Ingredients. Unpublished study. 26 p.

Dow Chemical Co. (1989) 2,4-D Isopropylamine Salt: Physical and Chemical
Characteristics. Unpublished study. 6 p.

Dow Chemical Co. (1989) 2,4-D Triisopropanolamine Salt-4: Product Identity
and Composition. Unpublished study. 23 p.

Dow Chemical Co. (1989) 2,4-D Triisopropanolamine Salt-4: Analysis and
Certification of Product Ingredients. Unpublished study. 22 p.

Dow Chemical Co. (1989) 2,4-D Triisopropanolamine Salt-4: Physical and
Chemical Characteristics. Unpublished study. 6 p.

May & Baker Ltd. (1988) Product Chemistry Data Requirements under EPA
Pesticide Assessment Guidelines dated Oct 1982 (2,4-Dichlor- ophenoxy)acetic
Acid 2,4-D Technical Acid. Unpublished study.  138 p.

Silvestre, D. (1989) 2,4-D Determination of Poly chlorinated Diben- zo-p-
dioxins and Dibenzofurans by GC/MS: Laboratory ID:  89-10. Unpublished
study prepared by Rhone-Poulenc Industrialisation.  133 p.

Fisher, J. (1989) Product Chemistry:  Agrolinz Isopropyl 2,4-D Ester Technical:
Analytical Methods. Unpublished study prepared by Agrolinz, Inc. 17 p.

Armbruster, J. (1989) EPA Reg. No.  61649-001  - Certification of Limits for
Dibenzo-p-Dioxins/Dibenzofurans. Unpublished study prepared by AGRO-
GORCorp. 179 p.

Ambruster, J. (1989) Certification of Limits for Dibenzo-p-Dioxins/
Dibenzofurans. Unpublished study prepared by PBI/Gordon Corp. 179 p.

Berry, D. (1989) Final Report of the Determination of Halogenated Dibenzo-p-
dioxins and Dibenzofurans in 2,4-Dichlorophenoxyacetic Acid: Proj. ID AL 89-
030290. Unpublished study prepared by Dow Chemical Co., Analytical
Sciences Laboratories.  168 p.

Armbruster, J. (1989) EPA Reg. No.  2217-455 - Product Chemistry ?of 2,4-
Dichlorophenoxyacetic Acid|. Unpublished study prepared by Agro-Gor Corp.
30 p.

Fisher, J. (1989) Product Chemistry Data Requirements for Isopropyl 2,4-D
Ester Technical: Proj. ID P-890824. Unpublished study prepared by Agrolinz,
Inc. 61 p.
                                   Page 237 of  304

-------
                                2,4-D Bibliography
41246701
41308901
41332002
41332004
41332009
41349001
41349002
41376701
41431101
41431301
41496701
41599401
Armbruster, J. (1989) Product Chemistry: AUS 90 Technical. Unpub- lished
study prepared by AGRO-GOR Corp. 30 p.

Reim, R (1989) Dissociation of 2,4-Dichlorophenoxyacetic Acid (2,4-D) and
2,4-D Dimethylamine Salt in Water: Lab Project Number: ML AL 89 041014.
Unpublished study prepared by Dow Chemical U.S.A. 25 p.

Hopkins, D. (1987) 2,4-Dichlorophenoxyacetic Acid: Determination of the
Water Solubility: Lab Project Number: ES/DR/0002/2297/8. Unpublished study
prepared by The Dow Chemical Co. 14 p.

Bailey, R.; Hopkins, D. (1987) 2,4-Dichlorophenoxyacetic Acid: Determination
of Octanol/Water Partition Coefficient: Lab Project Number:
ES/DR/0002/2297/9. Unpublished study prepared by the Dow Chemical Co. 12
P-

Helmer, D. (1987) Determination of the Octanol/Water Partition Coefficient for
2,4- Dichlorophenoxy Acetic Acid, 2-Ethylhexyl Ester: Lab Project Number:
ML/AL/87/70819. Unpublished study prepared by Dow Chemical Co. 14 p.

Fiene, J.; Mahlburg, W. (1990) Determination of Halogenated Dibenzo -p-
Dioxins and Dibenzofurans in 2,4-D Acid: Lab Project Number: 90-1.
Unpublished study prepared by Chemserv Industries Service Ges.m.b.H. 323 p.

Fiene, J.; Mahlburg, W. (1989) Determination of Halogenated Dibenzo -p-
Dioxins and Dibenzofurans in 2,4-D Isooctyl Ester Technical: Lab Project
Number: 90/2. Unpublished study prepared by Chem- serve Industries Service
Ges.m.b.H. 325 p.

Fisher, J. (1989) Manufacturing Process for the Production of Esters of 2,4-
Dichlorophenoxyacetic Acid: Lab Project ID: P89030L. Unpublished study
prepared by Agrolinz, Inc. 15 p.

Chakrabarti, A. (1990) Vapor Pressure of the Isopropyl Amine Salt of 2,4-
Dichlorophenoxy Acetic Acid Measured by the Knudsen-Effu- sion/Weight
Loss Method: Lab Project Number: ML-AL 89-020235. Unpublished study
prepared by Dow Chemical U.S.A. lip.

Chadrabarti, A. (1989) Vapor Pressure of the Butoxyethyl Ester of (2,4-
Dichlorophenoxy) Acetic Acid Measured by the Knudsen-Effu- sion/Weight
Loss Method: Lab Project Number: ML-AL-89-020197. Unpublished study
prepared by Dow Chemical U.S.A. 12 p.

DowElanco (1990) 2,4-D Acid: Product Identity and Composition:
"Amendment". Unpublished study prepared by The Dow Chemical Co. 51 p.

Buddie, G (1990) 2,4-D Technical Acid Product Chemistry: Supple- mental
Information: Lab Project Number: ACD/GCB/MS/8364. Unpub- lished study
prepared by Rhone-Poulenc Ag Co.  10 p.
                                   Page 238 of 304

-------
                                 2,4-D Bibliography
41637501
41647001
41669501
41681901
41724201
41724202
41724203
41735701
41745301
41745302
41755701
41789901
Armbruster, J. (1990) Revised Partial Product Chemistry. Unpub- lished study
prepared by PBI/GORDON Corp. 18 p.

Heimerl, J. (1990) Determination of the Octanol/Water Partition Coefficient of
2,4-D Butoxyethyl Ester (2,4-D BEE): Lab Project Number: ML-AL 90-
080378. Unpublished study prepared by Dow Chemical USA. 22 p.


Moore, R. (1990) 2,4-Dichlorophenoxyacetic acid, butoxyethyl ester: Aqueous
Solubility: Lab Project Number: 9585/F/02. Unpublished study prepared by
Midwest Research Institute. 17 p.

Armbruster, J. (1990) Revised Partial Product Chemistry. Unpub- lished study
prepared by AGRO/GOR Corp. 20 p.

Landvoight, W. ; Mahlburg, W. (1990) Quality Assurance Project Plan for
Determination of Halogenated Dibenzo-p-Dioxins and Dibenzo- furans... in 2,4-
D...: Lab Project Number: 90-3. Unpublished study prepared by Chemserve
Industries Service Ges.m.b.H. 43 p.

Landvoight, W.; Mahlburg, W. (1990) Determination of Halogenated Dibenzo-
p-Dioxins and Dibenzofurans in 2,4-D Acid by Method of Analysis 50288: Lab
Project Number: 90-4. Unpublished study prepared by Chemserve Industries
Service Ges.m.b.H. 561 p.

Landvoight, W.; Mahlburg, W. (1990) Determination of Halogenated Dibenzo-
p-Dioxins and Dibenzofurans in 2,4-D Isooctyl Ester by Method of Analysis
50288: Lab Project Number:  90-5. Unpublished study prepared by Chemserve
Industries Service Ges.m.b.H. 423 p.

Silvestre, D. (1990) Determination of Polychorinated Dibenzo-p- Dioxins and
Dibenzofurans In 2,4-D: Complementary Analytical Raw Data Relative to
Study 89-10: Lab Project Number: 343-484. Unp- ublished study prepared by
Rhone-Poulenc Industrialisation. 100 p.

Etchepareborda, I; Sancrica, J. (1990) Storage Stability of Tech- nical 2,4
Dichlorophenoxyacetic Acid. Unpublished study pre- pared by Atanor S.A./
Laboratories de Estudios Analiticos. 8 p.

Castaneda, J. (1990) 2,4 Dichlorophenoxyacetic Acid Explodability:
Unpublished study prepared by Institute de Desarrollo Tecnolo- gico/para la
Industna Quimica (INTEC). 8 p.

Schriber, C. (1990) Chemical Stability of 2,4-D Dimethyl Salt Solution: Lab
Project Number: GH-C 24428. Unpublished study prepared by DowElanco. 17
P-

Rajoharison, G (1991) Responses to EPA Queries on 2,4-D Product Chemistry:
Lab Project Number: GR/BC/91-189/PTC211. Unpublished study prepared by
Rhone-Poulenc Chimie. 9 p.
                                   Page 239 of 304

-------
                                 2,4-D Bibliography
41789902
41790601
41790602
41796201
41796202
41855701
41880601
41926201
41926202
41926203
41961301
41964401
Buddie, G.; Patel, P. (1991) 2,4-dichlorophenoxyacetic acid (2,4- D): Analysis
and Certification of Product Ingredients, Provision of Supplementary Analytical
Method Validation: Lab Project Num- ber: P-91-016. Unpublished study
prepared by Rhone-Poulenc Agriculture Ltd. 20 p.

Armbruster, J. (1991) Product Chemistry: 61 & 63 Series: (2,4-D Acid, Reg.
No. 2217-455). Unpublished study prepared by PBI Gordon Corp. 8 p.

Armbruster, J. (1989) Certification of Limits for Dibenzo-p-Dioxin-
s/Dibenzofurans. Unpublished study prepared by PBI/Gordon Corp. 489 p.

Armbruster, J. (1989) EPA Reg No. 61469-001-Product Chemistry.
Unpublished study prepared by Agro-Gor Corp. 8 p.

Armbruster, J. (1989) EPA REG No. 6149-001-Certification of Limits for
Dibenzo-p-Dioxins/Dibenzofurans. Unpublished study prepar- ed by Agro-Gor
Corp. 489 p.

Buddie, G; Mills, E. (1991) 2,4-Dichlorophenoxyacetic Acid (2,4-D) Physical
and Chemical Characteristics: Density and Stability (Supplement to MRID
41599401): Lab Project Number:  P-91-016. Unpublished study prepared by
Rhone-Poulenc Ag., Ltd. 27 p.

Cicotti, M. (1991) Determination of the Solubility of 2,4-D in Organic Solvents
in accordance with EPA 63-8 and BBA Guidelines: Lab Project Number:
BE/P/1/91/01/BG Unpublished study prepared by Battelle Europe. 15 p.

Etchepareborda, I.; Sancricca, J. (1991) Preliminary Analysis of 2,4
Dichlorophenoxyacetic acid 97%. Unpublished study prepared by Atanor S. A.
17 p.

Etchepareborda, I. (1991) pH of 2,4-Dichlorophenoxyacetic acid 97%.
Unpublished study prepared by Atanor S. A. 5 p.

Etchepareborda, I; Sancricca, J. (1991) Storage Stability (1 year in commercial
packaging) of 2,4 Dichlorophenoxyacetic acid 97%. Unpublished study
prepared by Atanor S. A. 7 p.

DowElanco (1991) 2,4-D Butoxyethyl Ester: Response to 2,4-D Task 4:
Registrants Response to Product Chemistry Data Requirements DEB No. 5454-
5455, 5440-5544 Dated September 22,  1989. Unpublished study. 11 p.

DowElanco (1991) Response to 2,4-D Task 4: Registrant's Response to Product
Chemistry Data Requirements DEB No. 5454-5455, 5440-5544 Dated Sep. 22,
1989 (Tinsworth Letter Dated January 23,  1990) 2,4-Dimethylamine Salt.
Unpublished study prepared by DowElanco . 17 p.
                                   Page 240 of 304

-------
                                2,4-D Bibliography
41968301
41968302
41968303
41972501
41973501
41973502
41978001
41978002
42021001
42021002
42023601
42116702
DowElanco. (1991) 2,4,D Isooctyl Ester (2-ethylhexyl ester): Response to 2,4-D
Task 4: Registrant's Response to Product Chemistry Data Requirements DEB
No. 5454-5455, 5489, 5440-5544 dated September 22, 1989. Unpublished
study, lip.

Helmer, D. (1987) Determination of the Water Solubility of 2,4-
dichlorophenoxy Acetic Acid, 2-ethylhexyl Ester: Lab Project No: ML-AL-87-
70817. Unpublished study prepared by Dow Chemical USA. 13 p.

Schriber, C.; Tiszai, N. (1991) Chemical Stability of 2,4-D 2-Ethyl hexyl Ester:
Lab Project Number: 90086. Unpublished study pre- pared by DowElanco.  17
P-

Gallacher, A. (1991) Dissociation of 2,4-Dichlorophenoxyacetic Acid (2,4-D)
and 2,4-D Diethanolamine Salt in Water: Lab Project Num-  ber: 4102-90-0304-
AS: 4102-90-03 04-AS-001. Unpublished study prepared by  Ricerca, Inc. 231 p.

DowElanco (1991) 2,4-D Acid and 2,4-D Acid Flake: Response to 2,4-D Task
4: Registrant's Response of Product Chemistry Data Require- ments Deb. No.
5454.5455, 5439, 5440-5544 Dated September 22, 1989. Unpublished study. 57
P-

Schriber, C. (1991) Chemical Stability of 2,4-Dichlorophenoxyacetic Acid:  Lab
Project Number: 90089. Unpublished study prepared by DowElanco. 17 p.

DowElanco (1991) 2,4-D Isopropylamine Salt: Response to  2,4-D Task 4:
Registrant's Response to Product Chemistry Data Requirements DEB Nos.
5454-5455, 5489, 5440-5544 Dated September 22, 1989. Unpublished study
prepared by DowElanco. 16 p.

Schriber, C. (1991) Chemical Stability of 2,4-D Isopropylamine Salt Solution:
Lab Project Number: 90088. Unpublished study prepared by DowElanco 17 p.

MacDaniel, R; Weiler, D. (1987) Vapor Pressure Determination of 2,4-
Dichlorophenoxyacetic Acid: Dimethylamine Salt: Lab Project Number: 41023.
Unpublished study prepared by Rhone-Poulenc Inc. 9 p.

Hopkins, D. (1987) 2,4-Dichlorophenoxyacetic Acid Dimethylamine Salt:
Determination of the Water Solubility: Lab Project Number: ES-DR-0008-
3556-3. Unpublished study prepared by The Dow Chemi- cal Company. 15 p.

Desai, L. (1991) Technical 2,4-D Acid: Physical and Chemical Char- acteristics:
Lab Project Number: 91-GR-0004. Unpublished study prepared by Toxicon
Corp. 120 p.

Feiler, W. (1991) Technical Isopropyl Ester of 2,4-D~Product Chemistry:
Physical and Chemical Properties. Unpublished study prepared by Amvac
Chemical Co. 4 p.
                                   Page 241 of 304

-------
                                2,4-D Bibliography
42188601
42227501
42487901
42537501
42786501
42795401
42798101
42798201
42798301
42829901
42830901
42831001
Feiler, W. (1991) Technical Isopropyl Ester of 2,4-D: Product Chemistry
Ingredients Identification. Unpublished study prepared by Amvac Chemical
Corp. 41 p.

Sawyer, R. (1990) Product Chemistry: Riverdale Sodium Salt of 2,4-D.
Unpublished study prepared by Riverdale Chemical Co. 8 p.

Schriber, C. (1992) Chemical Stability of 2, 4-Dichlorophenoxyacetic Acid,
Butoxyethyl Ester Solution: Lab Project Number: 90090. Unpublished study
prepared by DowElanco. 16 p.

Sawyer, R. (1992) Product Chemistry-Addendum: Riverdale Sodium Salt of
2,4-D. Unpublished study prepared by Riverdale Chemical Co. 14 p.

Feiler, W. (1993) Technical Isopropyl Ester of 2,4-D: Product Chemistry.
Unpublished study prepared by Amvac Chemical Corp.  14 p.

Murphy, J. (1993) Determination of Stability of 2,4-Dichlorophenoxyacetic
Acid (2,4-D) Technical Grade of Active Ingredient (TGAI): Lab Project
Number: FOR93058. Unpublished study prepared by Formulation Science and
Technology Lab. 9 p.

Murphy, G. (1993) Response to the Letter Written by Lois A. Rossi (10/05/02):
Subject: Product Chemistry Review for DowElanco 2,4-D DMA FI: Lab Project
Number: GM052793A. Unpublished study prepared by DowElanco. 7 p.

Murphy, G. (1993) Product Chemistry Review for DowElanco 2,4-D TIPA FI:
Lab Project Number: GM052993A.  Unpublished study prepared by
DowElanco. 4 p.

Murphy, G. (1993) Response to Letter Written by Lois A. Rossi (1/08/93):
Subject: Product Chemistry Review for DowElanco 2,4-D IPA FI: Lab Project
Number: GM052793B. Unpublished study prepared by DowElanco. 7 p.

Murphy, G. (1993) Determination of Melting Point of 2,4-
Dichlorophenoxyacetic Acid Dimethylamine Salt (2,4-D DMA) Technical
Grade of Active Ingredient (TGAI):  Lab Project Number: FOR93053.
Unpublished study prepared by Formulation Science and Technology Lab.
DowElanco. 9 p.

Murphy, G. (1993) Determination of Boiling Point and Solubility of 2,4-
Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) Technical Grade
Active Ingredient (TGAI): Lab Project Number: FOR93057. Unpublished study
prepared by Formulation Science and Technology Lab. DowElanco. 17 p.

Murphy, G. (1993) Determination of Melting Point of 2,4-
Dichlorophenoxyacetic Acid Isopropylamine Salt (2,4-D IPA) Technical Grade
of Active Ingredient (TGAI): Lab Project Number: FOR93054. Unpublished
study prepared by Formulation Science and Technology Lab. DowElanco. 9 p.
                                   Page 242 of 304

-------
                                 2,4-D Bibliography
42831101
42857201
42857202
42857203
42857204
42857205
42857206
42857207
42857208
42857209
43260501
Murphy, G. (1993) Determination of Boiling Point and Solubility of 2,4-
Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester (2,4-D 2-EHE) Technical
Grade of Active Ingredient (TGAI): Lab Project Number: FOR93055.
Unpublished study prepared by Formulation Science and Technology Lab,
DowElanco. 17 p.

Malone, S. (1992) Characterization of Technical Diethanolamine Salt of (2,4-
Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0055-AS: 4102-
92-0055-AS-001. Unpublished study prepared by Ricerca, Inc. 47 p.

Malone, S. (1992) Characterization of Purified Diethanolamine Salt of (2,4-
Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0056-AS: 4102-
92-0056-AS-001. Unpublished study prepared by Ricerca, Inc. 73 p.

Wojcieck, B. (1992) Color, Physical State, Odor of the Diethanolamine Salt of
(2,4-Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0082-AS:
4102-92-0082-AS-001. Unpublished study prepared by Ricerca, Inc. 24 p.

Wojcieck, B. (1992) Bulk Density of the Diethanolamine Salt of (2,4-
Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0083-AS: 4102-
92-0083-AS-001. Unpublished study prepared by Ricerca, Inc. 22 p.

Douglass, M. (1993) Technical Diethanolamine Salt of (2,4-Dichlorophenoxy)
Acetic Acid-Solubility: Lab Project Number: 4102-92-0057-AS: 4102-92-
0057-AS-001. Unpublished study prepared by Ricerca, Inc. 92 p.

Douglass, M. (1993) Purified Diethanolamine Salt  of (2,4-Dichlorophenoxy)
Acetic Acid-Vapor Pressure: Lab Project Number: 4102-92-0058-AS: 4102-
92-0058-AS-001. Unpublished study prepared by Ricerca, Inc. 68 p.

Douglass, M. (1993) Purified Diethanolamine Salt  of (2,4-Dichlorophenoxy)
Acetic Acid-OctanolAVater Partition Coefficient: Lab Project Number: 4102-
92-0059-AS: 4102-92-0059-AS-001. Unpublished  study prepared by Ricerca,
Inc. 55 p.

Furlong, K. (1992) pH of the Diethanolamine Salt of (2,4-Dichlorophenoxy)
Acetic Acid: Lab Project Number: 4102-92-0088-AS: 4102-92-0088-AS-001.
Unpublished study prepared by Ricerca, Inc. 27 p.

Malone, S. (1993) Technical Diethanolamine Salt of (2,4-Dichlorophenoxy)
Acetic Acid-Stability: Lab Project Number: 4102-92-0085-AS: 4102-92-0085-
AS-001. Unpublished study prepared by Ricerca, Inc. 51 p.

Krause, R; Jones-Jefferson, T.; Wallace, T. (1994) Storage Stability of 2,4-D
Acid: One Year Ambient Temperature Storage Study Results: Lab Project
Number: FOR93069. Unpublished study prepared by DowElanco, Formulation
Science & Technology. 14 p.
                                   Page 243 of 304

-------
                                 2,4-D Bibliography
43302001
43314701
43325001
43325002
43325003
43358801
43358802
43516401
43516402
43516403
43516404
Braden, G. (1994) Solubility of Isopropyl Ester of 2,4-D in Selected Organic
Solvents: Lab Project Number: SOL/018. Unpublished study prepared by
Amvac Chemical Corp. R & D Labs. 16 p.

Kinnunen, C.  (1994) Series 62-1: Preliminary Analysis of Product Sample of
2,4-Dichlorophenoxy Acetic Acid, Dimethylamine-6 (2,4-D DMA-6)
Sequestered for Dimethyl Nitrosamine: Lab Project Number: FOR93133.
Unpublished study prepared by DowElanco. 19 p.

Kinnunen, C.  (1994) Series 63: Determination of the Boiling Point of 2,4-
Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) TGAI: Lab Project
Number: FOR94079. Unpublished study prepared by DowElanco. 9 p.

Kinnunen, C.  (1994) Series 63: Determination of the Boiling Point of 2,4-
Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester (2,4-D 2-EHE) TGAI: Lab
Project Number: FOR94080. Unpublished study prepared by DowElanco. 9 p.

Kinnunen, C.  (1994) Series 63: Determination of the Melting Point of 2,4-
Dichlorophenoxyacetic Acid Triisopropanolamine Salt (2,4-D) TGAI: Lab
Project Number: FOR93132. Unpublished study prepared by DowElanco. 9 p.

Kinnunen, C.  (1994) Determination of Solubility of 2,4-Dichlorophenoxyacetic
Acid, Dimethylamine Salt: Lab Project Number: FOR94078. Unpublished study
prepared by DowElanco. 25 p.

Kinnunen, C.  (1994) Determination of Solubility of 2,4-Dichlorophenoxyacetic
Acid, Isopropylamine Salt: Lab Project Number: FOR94081: GH-C 3356.
Unpublished study prepared by DowElanco. 24 p.

Haefele, L. (1995) Identity and Composition for Albaugh 2,4-D Technical Acid:
Final Report: Lab Project Number: 95-ALBG-012. Unpublished study prepared
by AC RN Labs. 37 p.

Willis, C. (1994) Preliminary Analysis and Precision and Accuracy of
Analytical Method Used to Validate Certified Limits: (2,4-Dichlorophenoxy)
Acetic Acid: Final Report: Lab Project Number: 810-17. Unpublished study
prepared by Case Consulting Labs., Inc. 114 p.

Willis, C. (1994) 2,4-D (2,4-Dichlorophenoxyacetic acid): Physical and
Chemical Characteristics of 2,4-D: Color, Physical State, Odor, Melting Point,
Bulk Density, Solubility, Vapor Pressure, Dissociation Constant, Octanol/Water
Partition Coefficient, pH, Stability, Oxidizing or Reducing and Explodability:
Final Report: Lab Project Number: 810-18.  Unpublished study prepared by Case
Consulting Labs., Inc. 25 p.

Willis, C. (1994) 2,4-D (2,4-Dichlorophenoxyacetic acid): Physical and
Chemical Characteristics of 2,4-D: Storage Stability and Corrosion
Characteristics: Interim Report: Lab Project Number: 810-19. Unpublished
study prepared by  Case Consulting Labs., Inc. 14 p.
                                   Page 244 of  304

-------
                                2,4-D Bibliography
43777501
43777502
43874601
43981801
44149301
44149302
44184201
44228301
44228601
44287101
44543502
44543503
Kinnunen, C. (1995) Preliminary Analysis of Product Sample of Flake 2,4-
Dichlorophenoxyacetic Acid: Lab Project Number: FOR95091. Unpublished
study prepared by DowElanco. 39 p.

Kinnunen, C. (1995) Preliminary Analysis of Product Sample of Molten 2,4-
Dichlorophenoxyacetic Acid: Lab Project Number: FOR95090. Unpublished
study prepared by DowElanco. 39 p.

Krause, R.; Jones-Jefferson, T. (1995) Storage Stability of 2,4-D; IPA Salt
Manufacturing-Use-Concentrate One Year Ambient Temperature Storage Study
Results: Lab Project Number:  FOR94149. Unpublished study prepared by
DowElanco. 14 p.

Willis, C. (1996) 2,4-D: Analyses for Terra- Through Octa-Chlorinated Dioxins
and Furans: Final Report: Lab Project Number: 810-24. Unpublished study
prepared by Case Consulting Labs, Inc. 1053 p.

Armbruster, J. (1996) Product Identity and Manufacturing Process: (2,4-D).
Unpublished study prepared by PBI/Gordon Corp. 59 p.

Morrissey, M. (1996) Preliminary Analysis of 2,4-Dichlorophenoxyacetic Acid:
Final Report: Lab Project Number: CHW 6747-100. Unpublished study
prepared by Corning Hazleton Inc. 176 p.

Sanson, D. (1996) Product Identity and Composition of EH1330 Herbicide.
Unpublished study prepared by PBI/Gordon Corp. 8 p.

Cobb, J. (1997) Product Identity and Composition of TIPA-4: Manufacturing
Use Product Containing 2,4-D Triisopropanolamine Salt: Lab Project Number:
GH-C 4321. Unpublished study prepared by DowElanco. 76 p.

Pruitt, P. (1996) Series  62-1, Preliminary Analysis and Series 62-2, Certified
Limits for 2,4-D Acid Molten: Lab Project Number: GH-C 4238. Unpublished
study prepared by DowElanco. 40 p.

Cramer, P. (1996) 2,4-Dichlorophenoxyacetic Acid: Analysis for
Poly chlorinated Dibenzo-p-dioxins and Dibenzofurans in Acid, Salt, and/or
Ester Technical Material: Final Report: Lab Project Number: 4199-A: MRI-
A\R4199-01: 4199. Unpublished study prepared by Midwest Research Institute.
811 p.

Pryce, A. (1998) 2,4-D Acid: Product Chemistry: Analysis Methods: Final
Report: Lab Project Number: AHM/EPA/98/AP/05: 97/0014. Unpublished
study prepared by A H Marks and Company Limited. 41  p. {OPPTS 830.1800}

Pryce, A. (1998) 2,4-D Acid: Product Chemistry: 5 Batch Analysis: Final
Report: Lab Project Number: AHM/EPA/98/AP/06. Unpublished study
prepared by A H Marks and Co. Limited. 154 p. {OPPTS 830.1700}
                                   Page 245 of 304

-------
                                2,4-D Bibliography
44543504
44547901
44584501
44620501
44727101
44807001
44932701
44963801
44963802
Hutchinson, N. (1998) 2,4-D TGAI: Product Chemistry: Physical/Chemical
Properties: Final Report: Lab Project Number: AHM/EPA/98/NDH/Ol:
94/0010. Unpublished study prepared by A H Marks and Company Limited. 69
p. {OPPTS 830.6302, 830.6303, 830.6304, 830/6313, 830.7000, 830.7050,
830.7200, 830.7300, 830.7370, 830.7550,  830.7840, 830.7950}

Pryce, A. (1998) 2,4-D Acid: Product Chemistry: Existing Manufacturing
Process: Final Report: Lab Project Number: AHM/EPA/98/AP/02. Unpublished
study prepared by A H Marks and Co., Ltd. 29 p. {OPPTS 830.1550, 830.1600,
830.1670, 830.1700, 830.1750}

Hamilton, T. (1998) Group A:  Product Identity and Composition of 2,4-D
Butoxyethyl Ester Technical: Lab Project Number: GH-C 4680. Unpublished
study prepared by Dow AgroSciences LLC. 58 p. {OPPTS 830.1550, 830.1600,
830.1620, 830.1670, 830.1750}

Hamilton, T. (1998) Group A:  Product Identity and Composition of TIPA-4
Herbicide,  a Manufacturing Use Product: Lab Project Number: GH-C 4743.
Unpublished study prepared by Dow Agrosciences LLC. 13 p.  {OPPTS
830.1550, 830.1750, 830.1700}

Cobb, J. (1998) Group A: Product Identity and Composition of 2,4-D
Isopropylamine Technical Manufacturing Use Product Containing 2,4-D
Isopropylamine Technical: Lab Project Number: NAFST017. Unpublished
study prepared by Dow AgroSciences LLC 47 p. {OPPTS 830.1550, 830.1600,
830.1620, 830.1670, 830.1750}

Madsen, S. (1999) Group A: Product Identity and Composition of 2,4-D
Isopropylamine Salt Technical—High pH Manufacturing Use Product
Containing 2,4-D Isopropylamine Salt: Lab Project Number: NAFST055.
Unpublished study prepared by Dow Agrosciences, LLC. 50 p. {OPPTS
830.1550, 830.1600, 830.1620, 830.1670,  830.1750}

Hutchinson, N. (1999) Preliminary Analysis of 5 Batches of 2,4-
dichlorophenoxyacetic Acid Technical Grade Active Ingredient: Final Report:
Lab Project Number: 98/0057. Unpublished study prepared by AH Marks and
Company Limited. 188 p. {OPPTS 830.1700}

Sanson, D. (1999) Preliminary Analysis of Technical 2,4-
Dichlorophenoxyacetic 2-Ethylhexyl Ester: Lab Project Number: 98-019.
Unpublished study prepared by Ricerca, Inc. and University of Missouri
Biochemistry Department. 153 p. {OPPTS 830.1700}

Hughes, D. (1999) Determination of Physico-Chemical Properties of 2,4-D IOE
Technical Grade Active Ingredient (TGAI) and 2,4-D IOE Purified Active
Ingredient  (PAI) (Color, Physical State, Odor, Boiling Point, Density, Solubility,
Vapor Pressure, Octanol/Water Partition Coefficient, pH, Stability): Lab Project
Number: 6993-100. Unpublished study prepared by Covance Laboratories Inc.
12 p.
                                   Page 246 of  304

-------
                                2,4-D Bibliography
44963803
44963804
44982101
44982102
45014801
45642701
45692501
Sanson, D. (1999) Product Identity, Composition and Analysis of Technical 2,4-
Dichlorophenoxyacetic Acid, 2-Ethylhexyl Ester. Unpublished study prepared
by FBI/Gordon Corporation. 35 p. {OPPTS 830.1550, 830.1600, 830.1620,
830.1670}

Sanson, D. (1999) Certified Limits of Technical 2,4-Dichlorophenoxyacetic
Acid, 2-Ethylhexyl Ester and Enforcement Analytical Method of Technical 2,4-
Dichlorophenoxyacetic Acid, 2-Ethylhexyl Ester. Unpublished study prepared
by PBI/Gordon Corporation. 6 p. {OPPTS 830.1750 and 830.1800}

Madsen, S.; Cobb, I; Hackett, B. et al. (1999) Group A: Product Identity and
Composition of 2,4-D 2-Ethylhexyl Ester Technical Grade Active Ingredient
and Manufacturing Use Product Containing 2,4-D 2-Ethylhexyl  Ester Technical:
Lab Project Number: NAFST018. Unpublished study prepared by Dow
AgroSciences LLC. 54  p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670,
830.1750}

Hamilton, T. (1999) Ester Specific Analytical Method for Determination of
Esters of 2,4-Dichlorophenoxyacetic Acid (2,4-D) and Related Impurities: Lab
Project Number: DECO GL-AL 99-000252. Unpublished study  prepared by
The Dow Chemical Company. 74 p. {OPPTS 830.1800}

VanderKamp, I; Kastl, P. (1999) Five Batch Analysis of 2,4-D 2-Ethyl-l-Hexyl
Ester Technical: Lab Project Number: DECO GL-AL 99-002231. Unpublished
study prepared by The Dow Chemical Co. 42 p. {OPPTS 830.1700}

Sarff, P. (2002) Determination of the Storage Stability and Corrosion
Characteristics for DMA-6 Sequestered (2,4-D Dimethylamine-6 Sequestered
Herbicide): Lab Project Number: 46237: NAFST494: NAF-190. Unpublished
study prepared by ABC Laboratories, Inc. 30 p. {OPPTS 830.6317, 830.6320}

Lezotte, F.; Van Hoven, R; Nixon, W. (2002) Determination of Water
Solubility of 2,4-D Acid by the Shake Flask Method: Lab Project Number:
467C-103: 467/121801/7840/SUB467. Unpublished study prepared by Wildlife
International, Ltd. 43 p. {OPPTS 830.7840}
Toxicology MRID References
00031050
00101596
Feldmann, R.J.; Maibach, H.I. (1974) Percutaneous penetration of some
pesticides and herbicides in man. Toxicology and Applied Pharmacology 28(?
):126-132. (Also In unpublished submission received Apr 23, 1980 under
10279-7; submitted by Purdue Freder- ick Co., Norwalk, Conn.; CDL:242321-
R)

May hew, D.; Johnson, Y.; Kingery, A. (1981) Acute Dermal Toxicity Study in
Albino Rabbits with ITF-5; 2, 4-Dichlorophenoxyacetic Acid, Sodium Salt:
Project No. WIL-81233. (Unpublished study received Jul 23, 1981 under
unknown admin, no.; prepared by WIL Research Laboratories, Inc., submitted
by Dow Chemical U.S.A., Midland, MI; CDL:247496-F)
                                   Page 247 of 304

-------
                                 2,4-D Bibliography
00101602
00101603
00101605
00130407
00130408
00131303
00131304
00138868
00149377
Johnson, D.; Myer, J.; Marroquin, F.; et al. (1981) Determination of Acute
Dermal LD50 in Rabbits: IRDC Study No. 490-006. (Un- published study
received Dec 21, 1981 under unknown admin, no.; prepared by International
Research and Development Corp., sub- mitted by Dow Chemical U.S.A.,
Midland, MI; CDL:247498-C)

Johnson, D.; Myer, J.; Moxon, P.; et al. (1981) Determination of Acute Oral
LD50 in Fischer 344 Rats: 2,4-Dichlorophenoxyacetic acid, dimethylamine salt:
490-003. Rev. (Unpublished study received Dec 21, 1981 under unknown
admin, no.; prepared by International Research and Development Corp.,
submitted by Dow Chemical U.S.A., Midland, MI; CDL:247499-A)

Johnson, D.; Myer, J.; Moxon, P.; et al. (1981) Determination of Acute Oral
LD50 in Fischer 344 Rats: 2,4-Dichlorophenoxyacetic Acid, Technical: 490-
001. Rev. (Unpublished study received Dec 21, 1981 under unknown admin.
no.; prepared by International Research and Development Corp., submitted by
Dow Chemical U.S.A., Midland, MI; CDL:247499-C)

Rodwell, D.; Werchowski, K.; Mercieca, M.; et al. (1983) A Teratol- ogy Study
in Fischer 344 Rats with 2,4-Dichlorophenoxyacetic Acid: Project No. WIL-
81135. Final rept. (Unpublished study received Jun 1, 1983 under unknown
admin, no.; prepared by WIL Research Laboratories, Inc., submitted by 2-4 D
Task Force, Washington, DC; CDL:251031-A)

Nemec, M.; Kopp, S.; Leist, P.; et al. (1983) A Range-finding Tera- tology
Study in Fischer 344 Rats with 2,4-Dichlorophenoxyacetic Acid: Project No.
WIL-22002. Final rept. (Unpublished study received Jun 1, 1983 under
unknown admin, no.; prepared by WIL Research Laboratories, Inc., submitted
by 2-4 D Task Force, Washington, DC; CDL:251032-A)

Serota, D.; Colpean, B.; Burdock, G.; et al. (1983) Subchronic Tox- icity Study
in Mice: 2,4-Dichlorophenoxy Acetic Acid (2,4-D): Project No. 2184-100. Final
rept. (Unpublished study received Oct 14, 1983 under unknown admin, no.;
prepared by Hazle- ton Laboratories America, Inc., submitted by 2,4-D Task
Force, Washington, DC; CDL:251473-A)

Serota, D.; Burns, C.; Burdock, G.;  et al. (1983)  Subchronic Toxi- city Study  in
Rats~2,4-Dichlorophenoxyacetic Acid (2,4-D): Project No. 2184-102. Final
rept. (Unpublished study received Oct 14, 1983 under unknown admin, no.;
prepared by Hazleton Laboratories America, Inc., submitted by 2,4-D Task
Force, Wash- ington, DC; CDL:251474-A)

Streeter, C.; Young, J. (1983)  XRM-4725: An Acute Aerosol Inhala- tion Study
with Rats. (Unpublished study received Jan 18, 1984 under 464-596; submitted
by Dow Chemical U.S.A., Midland, MI; CDL:252291-C)

Eiseman, J. (1984) The Pharmacokinetic Evaluation of [Carbon 14]- 2,4-
Dichlorophenoxyacetic Acid (2,4-D) in the Mouse: Final Re- port: Project No.
2184-104. Unpublished study prepared by Hazleton Laboratories America, Inc.
148 p.
                                   Page 248 of 304

-------
                                 2,4-D Bibliography
00150557
00157512
00157513
00157514
00157515
00157516
00157517
00160876
00161659
00161660
00163996
40061801
Tasker, E. (1985) A Dietary Two-Generation Reproduction Study in Fischer
344 Rats with 2,4-Dichlorophenoxyacetic Acid: Final Report: Project No. WIL-
81137. Unpublished study prepared by Wil Research Laboratories, Inc. 1402 p.

Jeffrey, M; Battjes, I; Eisenbrandt, D. (1986) DMA 6 Weed Killer: Acute Oral
Toxicity Study in Fischer 344 Rats. Unpublished study prepared by Dow
Chemical U.S.A. 15 p.

Carreon, R.; Schuetz, D.; Lomax, L. (1986) DMA 6: Acute Dermal Toxicity
Study in New Zealand White Rabbits: Study No. M-003637- 001. Unpublished
study prepared by Dow Chemical U.S.A. 20 p.

Streeter, C.; Battjes, I; Lomax, L.  (1985) DMA-6 Sequestered Weed Killer:
Acute Aerosol Inhalation Study with Rats. Unpublished study prepared by Dow
Chemical U.S.A. 13 p.

Carreon, R. (1986) DMA 6: Primary Eye Irritation Study in New Zea- land
White Rabbits. Unpublished study prepared by Dow Chemical U.S.A. 9 p.

Jeffrey, M. (1986) DMA 6 Weed Killer: Primary Dermal Irritation Study in
New Zealand White Rabbits. Unpublished study prepared by Dow Chemical
U.S.A. 9 p.

Carreon, R. (1985) DMA 6: Dermal Sensitization Potential in the Guinea Pig.
Unpublished study prepared by Dow Chemical U.S.A. 9 p.

Serota, D. (1986) Combined Toxicity and Oncogenicity Study in Rats: 2,4-
Dichlorophenoxyacetic Acid: Final Report: Project No. 2184- 103. Unpublished
study prepared by Hazleton Laboratories Ameri- ca, Inc. 2049 p.

Gargus, J. (1986) Dermal Sensitization Study in Guinea Pigs: 2,4-
Dichlorophenoxyacetic Acid: Final Report: Project No. 2184-105. Unpublished
study prepared by Hazleton Laboratories, Inc. 10 p.

Auletta,  C.; Daly, I. (1986) An Acute Inhalation Toxicity Study of 2,4-
Dichlorophenoxyacetic Acid in the Rat: Final Report: Proj- ect No. 86-7893.
Unpublished study prepared by Bio/dynamics Inc. 39  p.

Brown, R. (1986) A Dietary Two-generation Reproduction Study in Fischer 344
Rats with 2,4-Dichlorophenoxyacetic Acid: Addendum to the Final Report:
[Microscopic Evaluation of the Kidneys of the FO, Fl and Fib Male Rats]:
Project No. WIL-81137. Unpub- lished study prepared by WIL Research
Laboratories, Inc. 19 p.

Serota, D. (1986) Oncogenicity Study in Mice with 2,4-Dichlorophe- noxyacetic
Acid (2,4-D): Final Report: HLA Project No. 2184-101. Unpublished study
prepared by Hazleton Laboratories America, Inc. 1797 p.
                                    Page 249 of 304

-------
                                 2,4-D Bibliography
40085501
40352701
40352702
40352703
40352704
40629801
40629802
40629803
40629804
40629805
40629806
41125302
41209001
Hey dens, W. (1986) Acute Toxicity of Landmaster n Administered by
Inhalation to Male and Female Sprage-Dawley Rats: Monsanto Refe- rence No.
EHL 86125. Unpublished study prepared by Monsanto Co., Environmental
Health Laboratory. 45 p.

Maedgen, J. (1986) Rat Acute Inhalation Toxicity: Tech. Isopropyl Ester of 2,4-
D: Proj. No. 4377-86. Unpublished study prepared by Stillmeadow, Inc. 15 p.

Maedgen, J. (1986) Rabbit Eye Irritation: Tech. Isopropyl Ester of 2,4-D: Proj.
No. 4374-86. Unpublished study prepared by Still- meadow, Inc. 16 p.

Maedgen, J. (1986) Rabbit Skin Irritation: Tech. Isopropyl Ester of 2,4-D: Proj.
No. 4375-86. Unpublished study prepared by Still- meadow, Inc. lip.

Maedgen, J. (1986) Guinea Pig Skin Sensitization: Tech. Isopropyl Ester of 2,4-
D: Proj. No. 4376-86. Unpublished study prepared by Stillmeadow, Inc. 15 p.

Jeffrey, M; Battjes, J.; Lomax. L. (1987) 2,4-D Butoxyethyl Ester, Technical:
Acute Oral  Toxicity Study in Fischer 344 Rats: Lab. Proj. ID K-007722-006A.
Unpublished study prepared by Dow Chemical Co. 30 p.

Jeffrey, M.; Battjes, J.; Zimmer, M. (1987) 2,4-D Butoxyethyl Ester Technical:
Acute Dermal Toxicity Study in New Zealand White Rab- bits: Lab. Proj. ID K-
007722-006D. Unpublished study prepared by Dow Chemical Co.  27 p.

Streeter, C.; Battjes, I; Yano, B. (1987) 2,4-D Butoxyethyl Ester, Technical:  An
Acute Aerosol Inhalation Study in Fischer 344 Rats: Lab. Proj. ID  K-007722-
007. Unpublished study prepared by Dow Chemical Co. 22 p.

Jeffrey, M.  (1987) 2,4-D Butoxyethyl Ester, Technical: Primary Eye Irritation
Study in New Zealand White Rabbits: Lab.  Proj. ID K-007722-006C.
Unpublished study prepared by Dow Chemical Co. lip.

Jeffrey, M.  (1987) 2,4-D Butoxyethyl Ester, Technical: Primary Der- mal
Irritation  Study in New Zealand White Rabbits: Lab. Proj. ID K-007722-006B.
Unpublished study prepared by Dow Chemical Co. 10 p.

Jeffrey, M.  (1986) Butoxy Ethyl 2,4-Dichlorophenoxyacetate: Dermal
Sensitization Potential in the Hartley Albino Guinea Pig: Lab. Proj. ID K-
007722-005. Unpublished study prepared by Dow Chemi- cal Co.  10 p.

Kirsch, P. (1983) Report on the Study of the Irritation to the Eye of the White
Rabbit Based on Draize of 2,4-D: Doc. No.  BASF: 837 0192. Unpublished study
prepared by BASF Aktiengesellschaft. 10 p.

Mahlburg, W. (1988) Acute Oral Toxicity Study of DPD Ester in Sprague-
Dawley Rats: Project ID: 88.3505.002; Study No. 89-19A. Unpublished study
prepared by Food & Drug Research Laboratories. 95 p.
                                   Page 250 of  304

-------
                                2,4-D Bibliography
41209002
41209003
41209005
41209006
41232304
41232305
41388202
41388203
41388204
41407901
41407902
Mahlburg, W. (1988) Acute Dermal Toxicity Study of DPD Ester in New
Zealand White Rabbits: Project ID: 88.3505.003; Study No. 89-19A.
Unpublished study prepared by Food & Drug Research Laboratories. 39 p.

Mahlburg, W. (1988) Acute Inhalation Limit Test of DPD Ester in Sprague-
Dawley Rats: Project ID: 88.3505.013; Study No. 89-19A. Unpublished study
prepared by Food & Drug Research Laboratories. 90 p.

Mahlburg, W. (1988) Primary Dermal Irritation Study of DPD Ester in New
Zealand White Rabbits: Project ID: 88.3505.005; Study No. 89-19A.
Unpublished study prepared by Food & Drug Research Laboratories. 34 p.

Mahlburg, W. (1988) Dermal Sensitization Study in Guinea Pigs with DPD
Ester: Project ID: 88.3505.006; Study No. 89-19A. Unpu- blished study
prepared by Food & Drug Research Laboratories. 38 p.

Lilja, H. (1988) Primary Dermal Irritation Study: Isopropyl: Pro-jectID: 88G-
0273. Unpublished study prepared by Toxikon Corp. 14 p.

Lilja, H. (1989) Epicutaneous skin Sensitization Test (Buehler Topical Closed
Patch Technique): FflVOL-44. Unpublished study prepared by Toxikon Corp.
23 p.

Samson, Y.; Gollapudi, B. (1989) Evaluation of 2,4-D Triisopropan- olamine
Salt in the Ames Salmonella/Mammalian-Microsome Bacteri- al Mutagenicity
Assay:  Lab Project Number: TXT:M-008866-007. Unpublished study prepared
by The Dow Chemical Co. 26 p.

Samson, Y.; Gollapudi, B. (1989) Evaluation of 2,4-D Isopropylamine Salt in
the Ames Salmonella/Mammalian-Microsome Bacterial Muta- genicity Assay:
Lab Project Number: TXT:M-004725-007. Unpub- lished study prepared by  the
Dow Chemical Co. 26 p.

Samson, Y.; Gollapudi, B. (1989) Evaluation of 2,4-D Butoxyethyl Ester in the
Ames Salmonella/Mammalian-Microsome Bacterial Muta- genicity Assay: Lab
Project Number: TXT:K-007722-011. Unpub- lished study prepared by The
Dow Chemical Co. 27 p.

Mizell, M.; Atkin, L.; Crissman, J. (1990) 2,4-Dichlorophenoxyace- tic Acid
Butoxy ethyl Ester: 21-Day Dermal Toxicity Study in New Zealand White
Rabbits: Final Report: Study ID: HET K-007722-008. Unpublished study
prepared by Dow Chemical Co., Toxicology Research Laboratory. 167 p.

Mizell, M.; Atkin, L.; Haut, K.; et al. (1990) 2,4-D Triisopropan- olamine Salt:
21-Day Dermal Toxicity Study in New Zealand White Rabbits: Final Report:
Study ID: K-008866-004. Unpublished study prepared by Dow Chemical Co.,
Toxicology Research Labora- tory. 168 p.
                                   Page 251 of 304

-------
                                 2,4-D Bibliography
41407903
41409801
41409802
41409803
41409804
41409805
41409806
41409807
41409808
41409809
Mizell, M; Atkm, L.; Haut, K.; et al. (1990) 2,4-D Isopropyla- mine Salt: 21-
Day Dermal Toxicity Study in New Zealand White Rabbits: Lab Project
Number: M-004725-004. Unpublished study prepared by Dow Chemical Co.,
Toxicology Research Laboratory.  166 p.

Lawlor, T.; Valentine, D. (1990) Mutagenicity Test on 2,4-Dichlor-
ophenoxyacetic Acid (2,4-D) in the Salmonella-Microsome Reverse Mutation
Assay (Ames Test): Rev. Final Rept: Lab Study No.  10979-0-401. Unpublished
study prepared by Hazleton Laborator- ies America, Inc. 34 p.

Lawlor, T.; Valentine, D. (1990) Mutagenicity Test on 2,4-D-Di- methylamine
Salt in the Salmonella/Mammalian-Microsome Reverse Mutation Assay (Ames
Test): Revised Final Report: Lab Project No. 10981-0-401. Unpublished study
prepared by Hazleton Labora- tories America, Inc. 34 p.

Lawlor, T.; Valentine, D. (1990) Mutagenicity Test on 2,4-D-2- Ethylhexyl
Ester in the Salmonella/Mammalian-Microsome Reverse Mutation Assay
(Ames  Test): Revised Final Report: Lab Project No. 10980-0-401. Unpublished
study prepared by Hazleton Labora- tories America, Inc. 34 p.

Ivett, J. (1990) Mutagenicity Test on 2,4-D-2-Dichlorophenoxyacetic Acid in
vivo Mouse Micronucleus Assay: Revised Final Report: Lab Project No. 10979-
0-455. Unpublished study prepared by Hazleton Laboratories America, Inc. 39
P-

Ivett, J. (1990) Mutagenicity Test on 2,4-D Dimethylamine Salt in vivo Mouse
Micronucleus Assay: Revised Final Report: Lab Project Number: 10981-0-455.
Unpublished study prepared by Hazleton Laboratories America, Inc. 40 p.

Ivett, J. (1990) Mutagenicity Test on 2,4-D-2-Ethylhexyl Ester in vivo Mouse
Micronucleus Assay: Revised Final Report: Lab Project No. 10980-0-455.
Unpublished study prepared by Hazleton Labora- tories, Inc. 39 p.

Cifone, M. (1990) Mutagenicity Test on 2,4-Dichlorophenoxyacetic Acid (2,4-
D) in the in vitro Rat Primary Hepatocyte Unscheduled DNA Synthesis Assay:
Revised Final Report: Lab Project No.  10979-0-447. Unpublished study
prepared by Hazleton Labora- tories America, Inc. 43 p.

Cifone, M. (1990) Mutagenicity Test on 2,4-D Dimethylamine Salt in the in
vitro Rat Primary Hepatocyte Unscheduled DNA Synthesis Assay: Revised
Final Report: Lab Project Number: 10981-0-447. Unpublished study prepared
by Hazleton Laboratories America, Inc. 44 p.

Cifone, M. (1990) Mutagenicity Test on 2,4-D-2-Ethylhexyl Ester in the in vitro
Rat Primary Hepatocyte Unscheduled DNA Synthesis Assay: Revised Final
Report: Lab Project Number: 10980-0-447. Unpublished study prepared by
Hazleton Laboratories America, Inc. 44 p.
                                    Page 252 of 304

-------
                                2,4-D Bibliography
41413501
41413502
41413503
41413504
41413505
41413506
41420004
41420005
41478301
41478302
Berdasco, N.; Schuetz, D.; Jersey, G. etal. (1989) 2,4-Dichloro- phenoxyacetic
Acid Triisopropanolamine Salt: Acute Oral Toxicity Study in Fischer 344 Rats:
Lab Project Number: K-008866-002A. Unpublished study prepared by The
Dow Chemical Co. 33 p.

Berdasco, N.; Schuetz, B.; Yano, B. etal. (1989) 2,4-Dichlorophe- noxyacetic
Acid Triisopropanolamine Salt: Acute Dermal Toxicity Study in New Zealand
White Rabbits:  Lab Project Number: K-008866 -002D. Unpublished study
prepared by The Dow Chemical Co. 19 p.

Nitschke, K.; Lomax, L. (1990) 2,4-D Triisopropanolamine: Acute Ae- rosol
LC50 Study in  Fischer 344 Rats: Lab Project Number: HET K- 008866-010.
Unpublished study prepared by The Dow Chemical Co. 30 p.

Berdasco, N.; Mizell, M. (1989) 2,4-Dichorophenoxyacetic Acid Tri-
isopropanolamine Salt: Primary Eye Irritation Study in New Zea- land White
Rabbits: Lab Project  Number: K-008866-002C. Unpub- lished study prepared
by The Dow Chmemical Co. 14 p.

Mizell, M. (1989) 2,4-Dichlorophenoxyacetic Acid, Triisopropanol- amine Salt:
Primary Dermal Irritation Study in New Zealand White Rabbits: Lab Project
Number: K-008866-002B. Unpublished study prepared by The Dow Chemical
Co. 13 p.

Berdasco, N. (1989) 2,4-Dichlorophenoxyacetic Acid Triisopropanol- amine
Salt: Dermal Sensitization Potential in the Hartley Albino Guinea Pig: Lab
Project Number: K-008866-002E. Unpublished study prepared by The Dow
Chemical Co. 14 p.

Ivett, J. (1989)  Single Acute Exposure Dose Selection Study on 2,4- D
Dimethylamine Salt:  Lab Project Number: 10981-0-459-PO. Un- published
study prepared  by Hazleton Laboratories America, Inc. 15 p.

Ivett, J. (1989)  Single Acute Exposure Dose Selection Study on 2,4- D-2-
Ethylhexyl Ester: Lab Project Number: 10980-0-459-PO. Un- published study
prepared by Hazleton Laboratories America, Inc. 15 p.

Gollapudi, B. ;  Samson, Y. ; McClmtock, M. (1990) Evaluation of 2,4-
Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) in the Mouse Bone
Marrow Micronucleus Test: Lab Project Number: K-O07722-012. Unpublished
study prepared  by Dow Chemical Co., Lake Jackson Research Ctr. 29 p.

Gollapudi, B.; Samson, Y.; McClintock, M. (1990) Evaluation of a Formulation
Containing 2,4-Dichlorophenoxyacetic Acid Triisopro- panolamine Salt (2,4-D
TIP A) in the Mouse Bone Marrow Micronu- cleus Test: Lab Project Number:
K-008866-009. Unpublished study prepared by Dow Chemical Co., Lake
Jackson Research Center. 30 p.
                                   Page 253 of 304

-------
                                2,4-D Bibliography
41478303
41498101
41498102
41498103
41527102
41527103
41527104
41527105
41527106
41642803
Gollapudi, B.; Samson, Y.; McClintock, M. (1990) Evaluation of a Formulation
Containing 2,4-Dichlorophenoxyacetic Acid Isopropyl- amine Salt (2,4-D IP A)
in the Mouse Bone Marrow Micronucleus Test: Lab Project Number: M-
004725-009. Unpublished study pre- pared by Dow Chemical Co., Lake
Jackson Research Ctr. 30 p.

McClintock, M.; Gollapudi, B. (1990) Evaluation of 2,4-Dichlorophe-
noxyacetic Acid Butoxyethyl Ester (2,4-D BEE) in the Rat Hepato- cyte:
Unscheduled DNA Synthesis (UDS) Assay: Lab Project Number:  TXT:K-
007722-013. Unpublished study prepared by The Dow Chem- ical Co. 46 p.

McClintock, M.; Gollapudi, B. (1990) Evaluation of a Formulation Containing
2,4-Dichlorophenoxyacetic Acid Triisopropylamine Salt (2,4-D TIP A) in the
Rat Hepatocyte Unscheduled DNA Synthesis (UDS) Assay: Lab Project
Number: TXT:K-008866-008. Unpublished study prepared by The Dow
Chemical Co. 46 p.

McClintock, M.; Gollapudi, B. (1990) Evaluation of a Formulation Containing
2,4-Dichlorophenoxyacetic Acid Isopropylamine Salt (2,4-D IP A) in the Rat
Hepatocyte: Unscheduled DNA Synthesis (UDS) Assay: Lab Project Number:
TXT:M-004725-008. Unpublished study prepared by The Dow Chemical Co.
46 p.

Schroeder, R (1990) A Teratogenicity Study in Rats with 2,4-D Tri-
isopropanolamine: Lab Project Number: HETK0008866-012: 89-3463.
Unpublished study prepared by Bio/dynamics, Inc.  478 p.

Schroeder, R. (1990) A Teratogenicity Study in Rats with 2,4-D Iso-
propylamine Salt: Lab Project Number: HETK-004725-011:  89-3465.
Unpublished study prepared by Bio/dynamics, Inc.  441 p.

Schroeder, R. (1990) A Range-Finding  Study to Evaluate the Toxicity of 2-
Butoxyethyl Ester of 2,4-D in the Pregnant Rat: Lab Project Number: HET K-
007722-016: 89-3468. Unpublished study prepared by Bio/dynamics, Inc. 154
P-

Schroeder, R. (1990) A Range-Finding  Study to Evaluate the Toxicity of 2,4-D
Triisopropanolamine Salt in the Pregnant Rat: Lab Pro- ject Number: HET K-
008866-011: 89-3464. Unpublished study pre- pared by Bio/dynamics, Inc. 246
P-

Schroeder, R. (1990) A Range-Finding  Study to Evaluate the Toxicity of 2,4-D
Isopropylamine Salt in the Pregnant Rat: Lab Project Number: HET K-004725-
010: 89-3466. Unpublished study prepared by Bio/dynamics,  Inc.  141 p.

Robbins, G (1989) Primary Eye Irritation Study in Rabbits: Dri-D Amine: Lab
Project Number: D2013. Unpublished study prepared by Cosmopolitan Safety
Evaluation, Inc. (C.S.E.) 19 p.
                                   Page 254 of 304

-------
                                 2,4-D Bibliography
41642804
41642805
41709901
41709902
41735201
41735304
41735301
41735302
41735303
41735304
41735305
Robbins, G. (1989) Primary Dermal Irritation Study in Rabbits: Dri- D Amine:
Lab Project Number: E2013. Unpublished study prepared by Cosmopolitan
Safety Evaluation, Inc. 14 p.

Robbins, G. (1989) Guinea Pig Sensitization Study (Buehler): Dri-D Amine:
Lab Project Number: F2013. Unpublished study prepared by Cosmopolitan
Safety Evaluation, Inc. (C.S.E.) 17 p.

Lilja, H. (1990) Acute Oral Toxicity Study (LD50): Hivol-44: Amended Report:
Lab Project Number: 88G-0274. Unpublished study prepared by Toxikon Corp.
17 p.

Lilja, H. (1990) Single Dose Dermal Toxicity: Hivol-44: Amended Report:
Project Number: 88G-0272. Unpublished study prepared by Toxikon Corp. 14
P-

Lochry, E. (1990) Developmental Toxicity (Embryo-Fetal Toxicity and
Teratogenic Potential) Study of 2,4-Dimethylamine Salt (2,4-D- DMA
Administered Orally via Gavage to CRL: CD BR VAF/Plus Pre- sumed
Pregnant Rats: Final Report: Lab Project Number: 320-001. Unpublished study
prepared by Argus Research Labs. 436 p.

Schulze, G. (1990) 21-Day Dermal Irritation and Dermal Toxicity Study in
Rabbits with 2,4 Dichlorophenoxyacetic Acid: Lab Pro- ject Number: 2184-109.
Unpublished study prepared by Hazleton Labs America, Inc. 186 p.

Schulze, G. (1990) 21-Day Dermal Irritation and Range-finding Study in
Rabbits with 2,4-Dichlorophenoxyacetic Acid: Final RepoitLab Project
Number: 2184-106. Unpublished study prepared by Hazle- ton Labs America,
Inc. 39 p.

Schulze, G. (1990) 21-Day Dermal Irritation and Dermal Range- finding Study
in Rabbits with 2,4-Dichlorophenoxyacetic Acid-2- Ethylhexyl  Ester: Lab
Project Number: 2184-107. Unpublished study prepared by Hazleton Labs
America, Inc. 44 p.

Schulze, G. (1990) 21-Day Dermal Irritation and Dermal Range-find- ing Study
in Rabbits with Dimethylamine Salt of 2,4-Dichloro- phenoxyacetic Acid: Lab
Project Number: 2184-108. Unpublished study prepared by Hazleton Labs
America, Inc. 46 p.

Schulze, G. (1990) 21-Day Dermal Irritation and Dermal Toxicity Study in
Rabbits with 2,4 Dichlorophenoxyacetic Acid: Lab Pro- ject Number: 2184-109.
Unpublished study prepared by Hazleton Labs America, Inc. 186 p.

Schulze, G. (1990) 21-Day Dermal Irritation and Dermal Toxicity Study in
Rabbits with 2,4-Dichlorophenoxyacetic Acid-2-ethyl- hexyl Ester: Lab Project
Number: 2182-110. Unpublished study prepared by Hazleton Labs America,
Inc. 200 p.
                                   Page 255 of 304

-------
                                2,4-D Bibliography
41735306
41737301
41737302
41747601
41797901
41797902
41797903
41870101
41870102
Schulze, G. (1990) 21-Day Dermal Irritation and Dermal Toxicity Study in
Rabbits with the Dimethylamine Salt of 2,4-Dichloro- phenoxyacetic Acid: Lab
Project Number: 2184-111. Unpublished study prepared by Hazleton Labs
America, Inc. 212 p.

Schulze, G. (1990) Subchronic Toxicity Study in Dogs with 2,4-
Dichlorophenoxyacetic Acid: Final Report: Lab Project Number: 2184-115.
Unpublished study prepared by Hazleton Laboratories America, Inc. 332 p.

Timchalk,  C.; Dryzga, M; Brzak, K. (1990) 2,4-Dichlorophenoxy- acetic,
Tissue Distribution and Metabolism of (Carbon 14)- Labeled, 2,4-
Dichlorophenoxyacetic Acid in Fischer 344 Rats: Final Report: Lab Project
Number: K-2372-47. Unpublished study prepared by the Dow Chemical Co. 70
P-

Hoberman, A. (1990) Development Toxicity (Embryo-Fetal Toxicity and
Teratogenic Potential) Study of 2,4-Dichlorophenoxyacetic Acid (2,4-D Acid)
Administered Orally  via Stomach Tube to New Zealand White Rabbits: Lab
Project Number: 320-003. Unpublished study prepared by Argus Research
Laboratories, Inc. 478 p.

Samson, Y.; Gollapudi, B. (1990) Response to the Comments by the U. S. EPA
on the Study Entitled: Evaluation of 2,4-D Triisopropa-  nolamine Salt in the
Ames Salmonella/Mammalian-Microsome Bacte- rial Mutagenicity Assay: Lab
Project Number: TXT:K-008866-007. Unpublished study prepared by The Dow
Chemical Co. 12 p.

Samson, Y.; Gollapudi, B. (1990) Response to the Comments by the U. S. EPA
on the Study Entitled: Evaluation of 2,4-D Isopropylamine Salt in the Ames
Salmonella/Mammalian-Microsome Bacterial Muta- genicity Assay: Lab
Project Number: TXT:K-004725-007. Unpub- lished study prepared by The
Dow Chemical Co. 12 p.

Samson, Y.; Gollapudi, B. (1990) Response to the Comments by the U. S. EPA
on the Study Entitled: Evaluation of 2,4-D Butoxyethyl  Ester in the Ames
Salmonella/Mammalian-Microsome Bacterial Muta- genicity Assay: Lab
Project Number: TXT:K-007722-011. Unpub- lished study prepared by The
Dow Chemical Co. lip.

Ivett, J. (1990) Mutagenicity Test on 2,4-Dichlorophenoxyacetic Acid in vivo
Mouse Assay: Lab Project Number: 10979-0-455. Un- published study
prepared by Hazleton Laboratories America, Inc. 6 p.

Ivett, J. (1990) Mutagenicity Test on 2,4-Dimethylamine Salt in vivo Mouse
Micronucleus Assay: Supplement to 41409805: Proj. No. 10981-0-455.  Rev.
Final Report. Unpublished study prepared by Hazleton Laboratories America,
Inc. 6 p.
                                   Page 256 of 304

-------
                                 2,4-D Bibliography
41870103
41896701
41896702
41920901
41920902
41920903
Ivett, J. (1990) Mutagenicity Test on 2,4-D-2-Ethylhexyl Ester in vivo Mouse
Micronucleus Assay: Lab Project Number: 10980/0/455. Supplement to
41409806. Rev. Final Report. Unpublished study prepared by Hazleton
Laboratories America, Inc. 6 p.

Schulze, G. (1991) Subchronic Toxicity Study in Rats with 2,4-Di-
chlorophenoxyacetate Acid-2-Ethylhexyl Ester: Final Report: Lab Project
Number: 2184-112. Unpublished study prepared by Hazle- ton Laboratories
America, Inc. 484 p.

Schulze, G. (1991) Subchronic Toxicity Study in Rats with the Di- methylamine
Salt of 2,4-Dichlorophenoxyacetic Acid: Final Report: Lab Project Number:
2184/113. Unpublished study pre- pared by Hazleton Laboratories America, Inc.
481 p.

Shults, S.; Brock, A.; Killeen, J. (1990) Acute Oral Toxicity (LD50) Study in
Rats with Diethanolamine Salt of 2,4-D: Lab Pro-jectNumber:90-0161: 3592-
90-0161-TX-001. Unpublished study prepared by Ricerca, Inc. 37 p.

Shults, S.; Brock,A.; Killeen, J. (1990) Primary Eye Irritation Study in Albino
Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number 90-0164: 3592-
90-0164-TX-001. Unpublished study prepared by Ricerca, Inc. 30 p.

Shults, S.; Brock, A.; Killeen, J. (1990) Primary Dermal Irritation Study in
Albino Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number: 90-
0165: 3592-90-0165-TX-001. Unpublished study prepared by Ricerca, Inc. 18  p.
41920904
41920905
41920906
41920907
41920908
Shults, S.; Brock, A.; Killeen, J. (1990) Dermal Sensitization Study (Closed
Patch Repeated Insult) in Guinea Pigs with Di- ethanolamine Salt of 2,4-D: Lab
Project Number: 90-0166: 3592- 90-0166-TX-001. Unpublished study prepared
by Ricerca, Inc. 37 p.

Siglm, J. (1991) 21-DAy Dermal Toxicity Study in Rabbits with Di-
ethanolamine Salt of 2,4-D DEA: Final Report: Lab Project Num- ber: 3229.1.
Unpublished study prepared by Springborn Labs, Inc. 412 p.

Siglin, J. (1990) Teratology Study in Rats with Diethanolamine Salt of 2,4-D:
Final Report: Lab Project Number: 3229.3. Unpublished study prepared by
Springborn Labs, Inc. 257 p.

Ivett, J. (1990) Single Acute Exposure Dose Selection Study on Di-
ethanolamine Salt of 2,4-D: Final Report: Lab Project Number: 12216-0-459-
PO. Unpublished study prepared by Hazleton Labs America, Inc. 15 p.

Ivett, J. (1990) Mutagenicity Test on Diethanolamine Salt of 2,4-D Acid in vivo
Mouse Micronucleus Assay: Final Report: Lab Project Number 12216-0-455.
Unpublished study prepared by Hazleton Labs America, Inc. 38 p.
                                    Page 257 of 304

-------
                                2,4-D Bibliography
41920909
41920910
41920911
41928101
41986601
41986602
41991501
41994001
42013501
42015701
42015702
McKeon, M. (1990) Mutagenicity Test on Diethanolamine Salt of 2,4-D in the
In vitro Rat Primary Hepatocyte Unscheduled DNA Synthesis Assay: Final
Report: Lab Project Number: HLA 12216-0-447. Un- published study prepared
by Hazleton Labs America, Inc. 45 p.

Lawlor, T.; Holloway, P. (1990) Mutagenicity Test on Diethanolamine Salt of
2,4-D in the Salmonella Mammalian-Microsome Reverse Mu- tation Assay
(Ames Test): Final Report: Lab Project Number: HLA 12216-0-401.
Unpublished study prepared by Hazleton Labs America, Inc. 51 p.

Shults, S.; Brock, A.; Killeen, J. (1991) Acute Dermal Toxicity Study in Albino
Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number: 90-0162:
3592-90-0162-TX-001. Unpublished study prepared by Ricerca, Inc. 25 p.

Szabo, I; Rachunek, B. (1991) 2,4-D, Butoxyethyl Ester: 13-Week Dietary
Toxicity Study in Fischer 344 Rats: Lab Project Number: DECO-TXT: K-
007722-015. Unpublished study prepared by Dow Chem- ical Co. 258 p.

Jackson, G.; Hardy, C. (1991) Diethanolamine Salt of 2,4-D: Acute Inhalation
Toxicity in Rats/4-Hour Exposure: Lab Project Number RIC 15/901290: 90-
0163. Unpublished study prepared by Huntingdon Research Centre Ltd. 26 p.

Siglin, J. (1991) Range-Finding Teratology Study in Rats with Diethanolamine
Salt of 2,4-D: Final RepoitLab Project Number 3229.2. Unpublished study
prepared by Springborn Labs, Inc. 136 p.

Schulze, G. (1991) Subchronic Toxicity Study in Rats with 2,4-Di-
chlorophenoxyacetic Acid: Lab Project Number: 2184-116. Unpubl- ished study
prepared by Hazleton Laboratories America. 529 p.

Serrone, D.; Killeen, I; Benz, G. (1991) A Subchronic Toxicity Study in Rats
with the Diethanolamine Salt of 2,4-Dichloropheno- xyacetic Acid: Lab Project
Number: 3579-90-0186-TX-003. Unpubl- ished study prepared by Ricerca, Inc.
798 p.

Rodwell, D. (1991) Range Finding Teratology Study in Rabbits with
Diethanolamine Salt of 2,4-D: Lab Project Number: 3229.12. Un- published
study prepared by Springborn Labs, Inc. 134 p.

Gollapudi, B. (1991) Response to Comments by U.S. EPA: Evaluation of  2,4-D
BEE, 2,4-D IPA and 2,4-D TIPA in the Ames Salmonella/ Mammalian-
Microsome Bacterial Mutagenicity Assay. Unpublished study prepared by The
Dow Chemical Co. 10 p.

Gollapudi, B. (1991) Response to Comments by U. S. EPA: Evaluation of 2,4-
Dichlorophenoxyacetic Acid Triisopropanolamine Salt (2,4- D TIPA) in the
Mouse Bone Marrow Micronuleus Test: Lab Project Number:  TXT:K-008866-
009.  Unpublished study prepared by The Dow Chemical Co. 9 p.
                                   Page 258 of 304

-------
                                2,4-D Bibliography
42015703
42015704
42015705
42015706
42015707
42021401
42021402
42055501
42158701
42158702
Gollapudi, B. (1991) Response to Comments by U. S. EPA: Evaluation of 2,4-
Dichlorophenoxyacetic Acid Isopropylamine Salt (2,4-D IP A) in the Mouse
Bone Marrow Micronuleus Test: Lab Project Num- ber: TXT:M-004725-009.
Unpublished study prepared by The Dow Chemical Co. 9 p.

Gollapudi, B. (1991) Response to Comments by U. S. EPA: Evaluation of 2,4-
Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) in the Mouse Bone
Marrow Micronuleus Test: Lab Project Number: TXT:K-007722-012.
Unpublished study prepared by The Dow Chemi- cal Co. 9 p.

Gollapudi, B. (1991) Response to Comments by U. S. EPA: Evaluation of 2,4-
Dichlorophenoxyacetic Acid Triisopropanolamine Salt (2,4- D TIP A) in the
Mouse Bone Marrow Micronuleus Test: Lab Project Number: TXT:K-008866-
008. Unpublished study prepared by The Dow Chemical Co. 30 p.

Gollapudi, B. (1991) Response to Comments by US. EPA: Evaluation of 2,4-
Dichlorophenoxyacetic Acid Isopropylamine Salt (2,4-D IP A) in the Mouse
Bone Marrow Micronuleus Test: Lab Project Num- ber: TXT:M-004725-008.
Unpublished study prepared by The Dow Chemical Co. 30 p.

Gollapudi, B. (1991) Response to Comments by US. EPA: Evaluation of 2,4-
Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) in the Mouse Bone
Marrow Micronuleus Test: Lab Project Number: TXT:K-007722-013.
Unpublished study prepared by The Dow Chemi- cal Co. 30 p.

Yano, B.; Cosse, P.; Corley, R. (1991) 2,4-D Isopropylamine Salt (2,4-D IPA):
A 13-Week Dietary Toxicity Study in Fischer 344 Rats: Lab Project Number:
HET M-004725-006. Unpublished study prepared by The Dow Chemical Co.
321 p.

Yano, B.; Cosse, P.; Markham, D. (1991) 2,4-D Tnisopropylamme Salt (2,4-D
TIPA): A 13-Week Dietary Toxicity Study in Fischer 344 Rats: Lab Project
Number: K-008866-006. Unpublished study prepared by The Dow Chemical
Co. 322 p.

Rodwell, D. (1991) Teratology Study in Rabbits with Diethanolamine Salt of
2,4-D: Final Report: Lab Project Number:  3229.13. Unpu- blished study
prepared by Springborn Labs, Inc. 228 p.

Liberacki, A.; Breslin, W.; Yano, B. (1991) Triisopropanolam- ine Salt of 2,4-D:
Oral Gavage Teratology Probe Study in New Zealand White Rabbits: Lab
Project Number: K-008866-014. Un- published study prepared by Dow
Chemical Co. 78 p.

Liberacki, A.; Breslin, W.; Yano, B. (1991) Isopropylamine Salt of 2,4-D: Oral
Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project
Number: M-004725-012. Unpublished study prepared by Dow Chemical Co. 74
P-
                                   Page 259 of 304

-------
                                 2,4-D Bibliography
42158703
42158704
42158705
42158706
42220301
42224001
42232701
42261801
42304601
Breslm, W.; Zablotny, C.; Yano, B. (1991) 2,4-D 2-Butoxyethyl Ester: Oral
Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project
Number: K-007722-020. Unpublished study prepared by Dow Chemical Co. 93
P-

Breslin, W.; Liberacki, A.; Yano, B. (1991) Isopropylamine Salt of 2,4-D: Oral
Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project
Number: M-004725-013. Unpublished study prepared by Dow Chemical Co.
270 p.

Breslin, W.; Liberacki, A.; Yano, B. (1991) Triisopropanolamine Salt of 2,4-D:
Oral Gavage Teratology Probe Study in New Zeal- and White Rabbits: Lab
Project Number: K-008866-016. Unpubli- shed study prepared by Dow
Chemical Co. 253 p.


Zablotny, C.; Yano, B.; Breslin, W. (1991) 2,4-D 2-Butoxyethyl Ester: Oral
Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project
Number: K-007722-021. Unpublished study prepared by Dow Chemical Co.
320 p.

Dryzga, M.; Bormett, G.; Nolan, R. (1992) 2,4-Dichlorophenoxyacetate,
Triisopropanolamine Salt: Dissociation and Metabolism in Male Fischer 344
Rats: Lab Project Number: K-008866-013. Unpublished study prepared by Dow
Chemical Co., Tox Res. Lab. 41 p.

Martin, T. (1991) Developmental Toxicity (Embryo-Fetal Toxicity and
Teratogenic Potential) Study of 2,4-D Dimethylamine Salt (2,4-D-DMA)
Administered Orally via Stomach Tube to New Zealand White Rabbits: Lab
Project Number: 320-004. Unpublished study prepared by Argus Research
Labs., Inc. 502 p.

Berdasco, N. (1992) 2,4-Dichlorophenoxyacetic Acid: Primary Dermal Irritation
Study in New Zealand White Rabbits: Lab Project Number: K-002372-060.
Unpublished study prepared by Dow Chemical Co. 14 p.

Dryzga, M.; Brzak, K.; Nolan, R. (1992) 2,4-Dichlorophenoxyacetate 2-
Ethylhexyl Ester: Metabolism in Fischer 344 Rats: Lab  Project Number: K-
020054-009. Unpublished study prepared by The Dow Chemical Co. 47 p.

Martin, T. (1992) Developmental Toxicity (Embryo-Fetal Toxicity and
Teratogenic Potential) Study of 2,4-D 2-Ethylhexyl Ester (2,4-D Isooctyl Ester)
Administered Orally Via Gavage to Crl:CD BR VAF/Plus Presumed Pregnant
Rats: Lab Project Number: 320-005. Unpublished study prepared by Argus
Research Laboratories, Inc. 469 p.
                                   Page 260 of 304

-------
                                 2,4-D Bibliography
42304602
42304603
42304604
42579701
42605202
42780001
42780002
42780003
42780004
42780005
42780006
Martin, T. (1992) Dosage-Range Developmental Toxicity (Embryo-Fetal
Toxicity and Teratogenic Potential) Study of 2,4-D 2-Ethylhexyl Ester (2,4-D
Isooctyl Ester) Administered Orally Via Gavage to Crl:CD BR VAF/Plus
Presumed Pregnant Rats: Lab Project Number: 320-005P. Unpublished study
prepared by Argus Research Laboratories, Inc. 111 p.

Martin, T. (1992) Developmental Toxicity (Embryo-Fetal Toxicity and
Teratogenic Potential) Study of 2,4-D 2-Ethylhexyl Ester (2,4-D Isooctyl Ester)
Administered Orally (Stomach Tube) to New Zealand White Rabbits: Lab
Project Number: 320-006. Unpublished study prepared by Argus Research
Laboratories, Inc. 503 p.

Martin, T. (1992) Dose-Range Developmental Toxicity (Embryo-Fetal Toxicity
and Teratogenic Potential) Study of 2,4-D 2-Ethylhexyl Ester (2,4-D Isooctyl
Ester) Administered Orally (Stomach Tube) to New Zealand White Rabbits:
Lab Project Number: 320-006P. Unpublished study prepared by Argus Research
Laboratories, Inc. 112 p.

Dryzga, M.; Bormett, G.; Stewart, H.; et al. (1992) 2,4-Dichlorophenoxyacetate,
Butoxyethyl Ester: Hydrolysis In vitro and In vivo in Fischer 344 Rats: Lab
Project Number: K-007722-018. Unpublished study prepared by The Dow
Chemical Co. 59 p.

Cieszlak, F. (1992) 2,4-Dichlorophenoxyacetic Acid, 2-Ethylhexyl Ester: Acute
Aerosol Inhalation Toxicity Study with Fischer 344 Rats: Lab Project Number:
K-020054-015. Unpublished study prepared by Dow Chemical Co. 37 p.

Dalgard, D. (1993) 13-Week Dietary Toxicity Study  of 2,4-D mDogs: Final
Report: Lab Project Number: HWA 2184-125. Unpublished study prepared by
Hazleton Washington, Inc. 302 p.

Dalgard, D. (1993) 13-Week Dietary Toxicity Study  with the Dimethylamine
Salt of 2,4-D in Dogs: Final Report: Lab Project Number: HWA 2184-126.
Unpublished study prepared by Hazleton Washington, Inc. 267 p.

Dalgard, D. (1993) 13-Week Dietary Toxicity Study  with the 2-Ethylhexyl Ester
of 2,4-D in Dogs: Final Report: Lab Project Number: HWA 2184-127.
Unpublished study prepared by Hazleton Washington, Inc. 271 p.

Dalgard, D. (1992) 4-Week Exploratory Rangefinding Study in Dogs with 2,4-
D: Final Report: Lab Project Number: HWA 2184-121. Unpublished study
prepared by Hazleton Washington, Inc. 85 p.

Dalgard, D. (1992) 4-Week Exploratory Rangefinding Study in Dogs with 2-
Ethylhexyl Ester of 2,4-D: Final Report: Lab Project Number: HWA 2184-122.
Unpublished study prepared by Hazleton Washington, Inc. 99 p.

Dalgard, D. (1992) 4-Week Exploratory Rangefinding Study in Dogs with the
Dimethylamine Salt of 2,4-D: Final Report: Lab Project Number: HWA 2184-
123. Unpublished study prepared by Hazleton Washington, Inc. 98 p.
                                   Page 261 of  304

-------
                                2,4-D Bibliography
42865301
43049001
43115201
43327301
43327302
43327303
43327304
43327305
43394201
43515501
Dryzga, M; Freshour, N.; Nolan, R. (1993) 2,4-Dichlorophenoxy- acetate,
Isopropylamine Salt: Dissociation and Metabolism in Male Fischer 344 Rats:
Lab Project Number: M-004725-014. Unpub- lished study prepared by The
Toxicology Research Lab., Dow Chemical Co. 64 p.

Dalgard, D. (1993) 52-Week Dietary Toxicity Study with 2,4-D in Dogs: Final
Report: Lab Project Number: HWA 2184-124: 2184124. Unpublished study
prepared by Hazleton Washington, Inc. 447 p.

Mattsson, I; McGuirk, R.; Yano, B. (1994) 2,4-Dichlorophenoxyacetic Acid
(2,4-D): Acute Neurotoxicity Study in Fischer 344 Rats: Lab Project Number:
K-002372-066. Unpublished study prepared by The Dow Chemical Co. 451 p.

Linscombe, V.; Lick, S. (1994) Evaluation of 2,4-D Triisopropanolamine Salt in
an In vitro Chromosomal Aberration Assay Utilizing Rat Lymphocytes:
Amended Final Report: Lab Project Number: K-008866-017: 10233.
Unpublished study prepared by Dow Chemical Co. 46 p.

Linscombe, V.; Lick, S. (1994) Evaluation of 2,4-D Triisopropanolamine Salt in
the Chinese Hamster Ovary Cell/Hypoxanthine-Guanine-Phosphoribosyl
Transferase (CHO/HGPRT) Forward Mutation Assay: Amended Final Report:
Lab Project Number: K-008866-018: 10233. Unpublished study prepared by
Dow Chemical Co. 43 p.

Linscombe, V.; Lick, S. (1994) Evaluation of 2,4-Dichlorophenoxyacetic Acid
Isopropylamine Salt in an In vitro Chromosomal Aberration Assay Utilizing Rat
Lymphocytes: Lab Project Number: M-004725-016: 10233. Unpublished study
prepared by Dow Chemical Co. 45 p.

Linscombe, V.; Lick, S. (1994) Evaluation of 2,4-Dichlorophenoxyacetic Acid
Isopropylamine Salt in the Chinese Hamster Ovary Cell/Hypoxanthine-
Guanine-Phosphoribosyl Transferase (CHO/HGPRT) Forward Mutation Assay:
Lab Project Number: M-004725-017: 10233. Unpublished study prepared by
Dow Chemical Co. 43 p.

Linscombe, V.; Lick, S. (1994) Evaluation of the 2,4-Dichlorophenoxyacetic
Acid Butoxyethyl Ester in an In vitro Chromosomal Aberration Assay Utilizing
Rat Lymphocytes: Lab Project Number: K-007722-022: 10233. Unpublished
study prepared by Dow Chemical Co. 45 p.

Linscombe, V.; Lick, S. (1994) Evaluation of 2,4-Dichlorophenoxyacetic Acid
Butoxyethyl Ester in the Chinese Hamster Ovary Cell/Hypoxanthine-Guanine-
Phosphoribosyl Transferase (CHO/HGPRT) Forward Mutation Assay: Lab
Project Number:  K-007722-023. Unpublished study prepared by Dow Chemical
Co. 44 p.

Tompkms, E. (1994) A 90-Day Oral (Capsule) Toxicity Study of 2,4-D
Isopropyl Ester in Dogs: Final Report: Lab Project Number: WIL-233001.
Unpublished study prepared by WIL Research Labs, Inc. 572 p.
                                   Page 262 of 304

-------
                                2,4-D Bibliography
43515901
43523001
43523101
43597201
43612001
43879801
43930501
43930801
43935101
44284501
Tompkms, E. (1995) A 90-Day Dietary Subchronic Toxicity Study of 2,4-D
Isopropyl Ester in Rats: Final Report: Lab Project Numbers: WIL-233002.
Unpublished study prepared by WIL Research Labs, Inc. 597 p.

Nemec, M. (1994) A Dose Range-finding Developmental Toxicity Study of 2,4-
D Isopropyl Ester in Rats: Final Report: Lab Project Number: WIL-233003.
Unpublished study prepared by WIL Research Labs, Inc. 279 p.

Nemec, M. (1995) A Developmental Toxicity Study of 2,4-D Isopropyl Ester in
Rats: Final Report: Lab Project Number: WIL/233004. Unpublished study
prepared by WIL Research Labs., Inc. 321 p.

Stott, W.; Johnson, K.; Gilbert, K.; etal. (1995) 2,4-Dichlorophenoxyacetic
Acid: Dietary Oncogenicity Study in B6C3F1 Mice—Two Year Final Report:
Lab Project No. K-002372- 063F. Unpublished study prepared by the Dow
Chemical Co. 724 p.

Jeffries, T.; Yano, B.; Ormand, J. etal. (1995) 2,4-Dichlorophenoxyacetic Acid:
Chronic Toxicity/Oncogenicity Study in Fischer 344 Rats: Final Report: Lab
Project Number: K/002372/064. Unpublished study prepared by The Dow
Chemical Co., Health and Environmental Sciences. 2020 p.


Stott, W.; Johnson, K.; Gilbert, K.; etal. (1995) 2,4-Dichlorophenoxyacetic
Acid: Dietary Oncogenicity Study in Male B6C3F1 Mice-Two Year Final
Report: Lab Project Number: K-002372-063M: 33475: 913. Unpublished study
prepared by Dow Chemical Co. 704 p.

Ham, A. (1996) Genotoxicity Test on Isopropyl Ester of 2,4-Dichloro-
Phenoxyacetic Acid in the Assay for Unscheduled DNA Synthesis in Rat Liver
Primary Cell Cultures: Lab Project Number: 16692-0-447: 2731-100: 615.
Unpublished study prepared by Corning Hazleton (CHV). 39 p.

Murli, H. (1996) Mutagenicity Test on Isopropyl Ester of 2,4-Dichloro Phenoxy
Acetic Acid in an in vivo Mouse Micronucleus Assay: Lab Project Number:
16692-0-455: 616. Unpublished study prepared by Hazleton Washington, Inc.
40 p.

Lawlor, T. (1996) Mutagenicity Test on Isopropyl Ester of 2,4-Dichlorophenoxy
Acetic Acid in the Salmonella/Mammalian-Microsome Reverse Mutation
Assay:  (Ames Test): Final Report: Lab Project Number: 16692-0-401.
Unpublished study prepared by Corning Hazleton Inc. 46 p.

Yano, B. (1997) 2,4-Dichlorophenoxyacetic Acid: Chronic
Toxicity/Oncogenicity Study in Fischer 344 Rats: Supplemental
Histopathology—Brains from Low- and Mid-Dose Level Rats Sacrificed for the
2-Year Necropsy: Revised (Final Report): Lab Project Number: K-002372-
064FR: K-0023 72-064. Unpublished study prepared by The Dow Chemical Co.
14 p.
                                   Page 263 of 304

-------
44725303
45761201
45761204
45761208
45761209
45761210
45761211
45761213
45761214
45761215
45840901
45897102
                                 2,4-D Bibliography
Cieszlak, F.; Brooks, K. (1998) Esteron 6E: Acute Primary Eye Irritation Study
in New Zealand White Rabbits: Lab Project Number: 971165. Unpublished
study prepared by The Dow Chemical Company. 16 p.

Garabrant, D.; Philbert, M. (2002) Review of 2,4-Dichlorophenoxyacetic Acid
(2,4-D) Epidemiology and Toxicology. Critical Reviews in Toxicology 32(4):
233-257.

Charles, J.; Hanley, T.; Wilson, R;  et al. (2001) Developmental Toxicity Studies
in Rats and Rabbits on 2,4-Dichlorophenoxyacetic Acid and Its Forms.
Toxicological Sciences 60:121-131.

Charles, J.; Cunny, H.; Wilson, R;  et al. (1999) Ames Assays and Unscheduled
DNA Synthesis  Assays on 2,4-Dichlorophenoxyacetic Acid and Its Derivatives.
Mutation Research 444:207-216.

Charles, J.; Cunny, H.; Wilson, R.;  et al. (1999) In Vivo Micronucleus Assays
on 2,4-Dichlorophenoxyacetic Acid and Its Derivatives. Mutation Research
444:227-234.

Gollapudi, B.; Charles, I; Linscombe, V.; et al.  (1999) Evaluation of the
Genotoxicity of 2,4-Dichlorophenoxyacetic Acid And Its Derivatives in
Mammalian Cell Cultures. Mutation Research 444:217-225.

Mattsson, I; Charles, I; Yano, B.; et al. (1997)  Single-Dose and Chronic
Dietary Neurotoxicity Screening Studies on 2,4-Dichlorophenoxyacetic Acid in
Rats. Fundamental and Applied Toxicology 40:111-119.

Charles, I; Cunny, H.; Wilson, R;  etal. (1996) Comparative Subchronic
Studies on 2,4-Dichlorophenoxyacetic Acid, Amine and Ester in Rats.
Fundamental and Applied Toxicology 33:161-165.

Charles, I; Bond, D.; Jeffries, T.; et al. (1996) Chronic Dietary
Toxicity/Oncogenicity Studies on 2,4-Dichlorophenoxyacetic Acid in Rodents.
Fundamental and Applied Toxicology 33:166-172.

Charles, J.; Dalgard, D.; Cunny, H.; et al. (1996) Comparative Subchronic and
Chronic Dietary Toxicity Studies on 2,4-Dichlorophenoxyacetic Acid, Amine,
and Ester in the  Dog. Fundamental  and Applied Toxicology 29:78-85.

Hardwick, T. (2002) The Pharmacokinetics of (Carbon-14)-2,4-D in the Rat and
Dog: Lab Project Number: 1149/40: 1149/40-D1145. Unpublished study
prepared by Covance Laboratories Ltd. 364 p. {OPPTS 870.7485}

Hardwick, T. (2003) (Carbon 14)-2,4-D: Metabolite Identification in the Rat and
Dog: Final Report: Lab Project Number: 1149/042: 1149/042-D 1145.
Unpublished study prepared by Covance Laboratories Ltd. 74 p. {OPPTS
870.7485}
Occupational and Residential MRD) References
                                   Page 264 of  304

-------
                                2,4-D Bibliography
44972201
44655701
44655704
44655703
45033101
44459801
Klonne, D. (1999) Integrated Report for Evaluation of Potential Exposures to
Homeowners and Professional Lawn Care Operators Mixing, Loading, and
Applying Granular and Liquid Pesticides to Residential Lawns: Lab Project
Number: OMAOO5: OMAOO1: OMAOO2. Unpublished study prepared by
Ricerca, Inc., and Morse Laboratories. 2213 p.

Wilson, R. (1998) Comparison of Transferable Turf Residues from the
Application of Various Forms of Phenoxy Herbicides and the Effects from the
Application of Various Spray Volumes Per Acre: Lab Project Number:
RDW98-0903. Unpublished study prepared by Broadleaf Turf Herbicide TFR
Task Force LLC. 40 p. {OPPTS 875.2100}

Hughes, D.; Read, S. (1998) Validation of a Method for the Determination of
2,4-D 2-EHE (2,4-dichlorophenoxyacetic acid 2-ethylhexyl ester); 2,4-DP 2-
EHE ?2-(2,4-dichlorophenoxy) propionic acid 2-ethylhexyl ester|; MCPA 2-
EHE (4-chloro-2-methylphenoxyacetic acid 2-ethylhexyl ester); 2,4-D (2,4-
dichlorophenoxyacetic acid), MCPP ?(RS)-2-(4-chloro-methylphenoxy)
propionic acid|, and Dicamba (3,6-dichloro-2-methoxybenzoic  acid)(In
Combination); and MCPA (4-chloro-2-methylphenoxyacetic acid),  MCPP
?(RS)-2-(4-chloro-2-methylphenoxy) propionic acid|, and 2,4-DP ?(RS)-2-(2,4-
dichlorophenoxy) propionic acid| (In Combination on Percale Cloth: Lab Project
Number: 6926-102.  Unpublished study prepared by Covance Laboratories. 236
P-

Barney, W. (1998) Determination of Transferable Turf Residues on Turf
Treated with 2,4-D DMA + MCPP-p DMA + Dicamba DMA  in Various Spray
Volumes: Lab Project Number: 98-314: 6956-104: BTH TFR TF 002.
Unpublished study prepared by Grayson Research, LCC. and Covance
Laboratories Inc. 235 p. {OPPTS 875.2100}

Hughes, D.; Bomkamp, D. (2000) Determination of Transferable Turf Residues
on Turf Treated with 2,4-D, MCPA DMA, 2,4-D DMA + MCPP-p DMA +
Dicamba DMA and MCPA DMA + MCPP-p DMA + 2,4-DP-p DMA: Lab
Project Number: BTH TFR TF 003: 6926-105. Unpublished study prepared by
Covance Laboratories. 394 p. {OPPTS 875.2100}

Merricks, D. (1997) Carbaryl Mixer/Loader/Applicator Exposure Study During
Application of RP-2 Liquid (21%), Sevin Ready to Use Insect  Spray or Sevin 10
Dust to Home Garden Vegetables: Lab Project Number:  1519:  10564: ML97-
0676-RHP. Unpublished study prepared by Agrisearch Inc., Rhone-Poulenc Ag
Co. and Morse Labs., Inc. 358 p.
Hazard Identification MRID References
46147201
                Hammond, L. (2003) Error Review of 2,4-D-Report of the Hazard Identification
                Assessment Review Committee. Project Number: 0051866. Unpublished study
                prepared by Industry Task Force n on 2,4-D Research Data. 5 p
                                   Page 265 of 304

-------
                                 2,4-D Bibliography
43115201
43293901
41527101
41920906
41735201
42304601
41527103
41527102
41747601
42055501
Mattsson, I; McGuirk, R; Yano, B. (1994) 2,4-Dichlorophenoxyacetic Acid
(2,4-D): Acute Neurotoxicity Study in Fischer 344 Rats: Lab Project Number:
K-002372-066. Unpublished study prepared by The Dow Chemical Co. 451 p.

Mattsson, I; Jeffries, T.; Yano, B. (1994) 2,4-Dichlorophenoxyacetic Acid:
Chronic Neurotoxicity Study in Fischer 344 Rats: Lab Project Number: K-
002372-064N: K-002372-064. Unpublished study prepared by The Dow
Chemical Co. 1091 p.

Schroeder, R. (1990) A Teratogenicity Study in Rats with 2-Butoxy- ethyl Ester
of 2,4-D: Lab Project Number: HETK-007722-017: 89- 34677. Unpublished
study prepared by Bio/dynamics, Inc. 452 p.

Siglin, J. (1990) Teratology Study in Rats with Diethanolamine Salt of 2,4-D:
Final Report: Lab Project Number: 3229.3. Unpublished study prepared by
Springborn Labs, Inc. 257 p.

Lochry, E. (1990) Developmental Toxicity (Embryo-Fetal Toxicity and
Teratogenic Potential) Study of 2,4-Dimethylamine  Salt (2,4-D- DMA
Administered Orally via Gavage to CRL: CD BR VAF/Plus Pre- sumed
Pregnant Rats: Final Report: Lab Project Number: 320-001. Unpublished study
prepared by Argus Research Labs. 436 p.

Martin, T.  (1992) Developmental Toxicity (Embryo-Fetal Toxicity and
Teratogenic Potential) Study of 2,4-D 2-Ethylhexyl  Ester (2,4-D Isooctyl Ester)
Administered Orally Via Gavage to Crl:CD BR VAF/Plus Presumed Pregnant
Rats: Lab Project Number: 320-005. Unpublished study prepared by Argus
Research Laboratories, Inc.  469 p.

Schroeder, R. (1990) A Teratogenicity Study in Rats with 2,4-D Iso-
propylamine Salt: Lab Project Number: HETK-004725-011: 89-3465.
Unpublished study prepared by Bio/dynamics, Inc. 441 p.

Schroeder, R. (1990) A Teratogenicity Study in Rats with 2,4-D Tri-
isopropanolamine:  Lab Project Number: HETK0008866-012: 89-3463.
Unpublished study prepared by Bio/dynamics, Inc. 478 p.

Hoberman, A. (1990) Development Toxicity (Embryo-Fetal Toxicity and
Teratogenic Potential) Study of 2,4-Dichlorophenoxyacetic Acid (2,4-D Acid)
Administered Orally via Stomach Tube to New Zealand White Rabbits: Lab
Project Number: 320-003. Unpublished study prepared by Argus Research
Laboratories, Inc. 478 p.

Rodwell, D. (1991) Teratology Study in Rabbits with Diethanolamine Salt of
2,4-D: Final Report: Lab Project Number: 3229.13.  Unpu- blished study
prepared by Springborn Labs, Inc. 228 p.
                                   Page 266 of 304

-------
                                 2,4-D Bibliography
42224001
42304603
42158704
42158705
43225201
43612001
41991501
43049001
43879801
43597201
Martin, T. (1991) Developmental Toxicity (Embryo-Fetal Toxicity and
Teratogenic Potential) Study of 2,4-D Dimethylamine Salt (2,4-D-DMA)
Administered Orally via Stomach Tube to New Zealand White Rabbits: Lab
Project Number: 320-004. Unpublished study prepared by Argus Research
Labs., Inc. 502 p.

Martin, T. (1992) Developmental Toxicity (Embryo-Fetal Toxicity and
Teratogenic Potential) Study of 2,4-D 2-Ethylhexyl Ester (2,4-D Isooctyl Ester)
Administered Orally (Stomach Tube) to New Zealand White Rabbits: Lab
Project Number: 320-006. Unpublished study prepared by Argus Research
Laboratories, Inc. 503 p.

Breslin, W.; Liberacki, A.; Yano, B. (1991) Isopropylamine Salt of 2,4-D: Oral
Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project
Number: M-004725-013. Unpublished study prepared by Dow Chemical Co.
270 p.

Breslin, W.; Liberacki, A.; Yano, B. (1991) Triisopropanolamine Salt of 2,4-D:
Oral Gavage Teratology Probe Study in New Zeal- and White Rabbits: Lab
Project Number: K-008866-016. Unpubli- shed study prepared by Dow
Chemical Co. 253 p.

Biever, R. (1994) (Carbon 14)-Acrolein (Magnacide H): Nature and Magnitude
of Residues Study Using Freshwater Fish and Shellfish: Final Report: Lab
Project Number: 93-3-4701:  12167-0691-6102-145. Unpublished study
prepared by Springborn Labs., Inc. 389 p.

Jeffries, T.; Yano, B.; Ormand, J. etal. (1995) 2,4-Dichlorophenoxyacetic Acid:
Chronic Toxicity/Oncogenicity Study in Fischer 344 Rats: Final Report: Lab
Project Number: K/002372/064. Unpublished study prepared by The Dow
Chemical Co., Health and Environmental Sciences. 2020 p.

Schulze, G. (1991) Subchronic Toxicity Study in Rats with 2,4-Di-
chlorophenoxyacetic Acid: Lab Project Number: 2184-116. Unpubl- ished study
prepared by Hazleton Laboratories America.  529 p.

Dalgard, D. (1993) 52-Week Dietary Toxicity Study with 2,4-D in Dogs: Final
Report: Lab Project Number: HWA 2184-124: 2184124. Unpublished study
prepared by Hazleton Washington, Inc. 447 p.

Stott, W; Johnson, K.; Gilbert, K.; etal. (1995) 2,4-Dichlorophenoxyacetic
Acid: Dietary Oncogenicity Study in Male B6C3F1 Mice-Two Year Final
Report: Lab Project Number: K-002372-063M: 33475: 913. Unpublished study
prepared by Dow Chemical Co. 704 p.

Stott, W.; Johnson, K.; Gilbert, K.; etal. (1995) 2,4-Dichlorophenoxyacetic
Acid: Dietary Oncogenicity Study in B6C3F1 Mice—Two Year Final Report:
Lab Project No. K-002372- 063F. Unpublished study prepared by the Dow
Chemical Co. 724 p.
                                   Page 267 of 304

-------
                                 2,4-D Bibliography
00101605
00101596
00161660
41125302
42232701
00161659
41920901
41642801
41413501
40629801
41209001
Johnson, D.; Myer, I; Moxon, P.; et al. (1981) Determination of Acute Oral
LD50 in Fischer 344 Rats: 2,4-Dichlorophenoxyacetic Acid, Technical: 490-
001. Rev. (Unpublished study received Dec 21, 1981 under unknown admin.
no.; prepared by International Research and Development Corp., submitted by
Dow Chemical U.S.A., Midland, MI; CDL:247499-C)

May hew, D.; Johnson, Y.; Kingery, A. (1981) Acute Dermal Toxicity Study in
Albino Rabbits with ITF-5; 2, 4-Dichlorophenoxyacetic Acid, Sodium Salt:
Project No. WIL-81233. (Unpublished study received Jul 23, 1981 under
unknown admin, no.; prepared by WIL Research Laboratories, Inc., submitted
by Dow Chemical U.S.A., Midland, MI; CDL:247496-F)

Auletta, C.; Daly, I. (1986) An Acute Inhalation Toxicity Study of 2,4-
Dichlorophenoxyacetic Acid in the Rat: Final Report: Proj- ect No. 86-7893.
Unpublished study prepared by Bio/dynamics Inc. 39 p.

Kirsch, P. (1983) Report on the Study of the Irritation to the Eye of the White
Rabbit Based on Draize of 2,4-D: Doc. No. BASF: 837 0192. Unpublished study
prepared by BASF Aktiengesellschaft. 10 p.

Berdasco, N. (1992) 2,4-Dichlorophenoxyacetic Acid: Primary Dermal Irritation
Study in New Zealand White Rabbits: Lab Project Number: K-002372-060.
Unpublished study prepared by Dow Chemical Co. 14 p.

Gargus, J. (1986) Dermal Sensitization Study in Guinea Pigs: 2,4-
Dichlorophenoxyacetic Acid: Final Report: Project No. 2184-105. Unpublished
study prepared by Hazleton Laboratories, Inc.  10 p.

Shults, S.; Brock, A.; Killeen, J. (1990) Acute Oral Toxicity (LD50) Study in
Rats with Diethanolamine Salt of 2,4-D: Lab Pro-jectNumber:90-0161: 3592-
90-0161-TX-001. Unpublished study prepared by Ricerca, Inc. 37 p.

Robbins, G. (1989) Acute Oral Toxicity Study in Rats:  Dri-D Amine: Lab
Proj ect Number: A2013. Unpublished study prepared by Cosmo- politan Safety
Evaluation, Inc. (C.S.E.) 36 p.

Berdasco, N; Schuetz, D.; Jersey, G. etal. (1989) 2,4-Dichloro- phenoxyacetic
Acid Triisopropanolamine Salt: Acute Oral Toxicity  Study in Fischer 344 Rats:
Lab Project Number: K-008866-002A. Unpublished  study prepared by The
Dow Chemical Co. 33 p.

Jeffrey, M; Battjes, J.; Lomax. L. (1987) 2,4-D Butoxyethyl Ester, Technical:
Acute Oral  Toxicity Study in Fischer 344 Rats: Lab.  Proj. ID K-007722-006A.
Unpublished study prepared by Dow Chemical Co. 30 p.

Mahlburg, W. (1988) Acute Oral Toxicity Study of DPD Ester in Sprague-
Dawley Rats: Project ID: 88.3505.002; Study No. 89-19A. Unpublished study
prepared by Food & Drug Research Laboratories. 95 p.
                                   Page 268 of 304

-------
                                 2,4-D Bibliography
41920911
41413502
40629802
41209002
41986601
40085501
41957601
40629803
42605202
41920902
41642803
41920902
Shults, S.; Brock, A.; Killeen, J. (1991) Acute Dermal Toxicity Study in Albino
Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number: 90-0162:
3592-90-0162-TX-001. Unpublished study prepared by Ricerca, Inc. 25 p.

Berdasco, N.; Schuetz, B.; Yano, B. etal. (1989) 2,4-Dichlorophe- noxyacetic
Acid Triisopropanolamine Salt: Acute Dermal Toxicity Study in New Zealand
White Rabbits: Lab Project Number: K-008866 -002D. Unpublished study
prepared by The Dow Chemical Co. 19 p.

Jeffrey, M; Battjes, J.; Zimmer, M. (1987) 2,4-D Butoxyethyl Ester Technical:
Acute Dermal Toxicity Study in New Zealand White Rab- bits: Lab. Proj. ID K-
007722-006D. Unpublished study prepared by Dow Chemical Co.  27 p.

Mahlburg, W. (1988) Acute Dermal Toxicity Study of DPD Ester in New
Zealand White Rabbits: Project ID: 88.3505.003; Study No. 89-19A.
Unpublished study prepared by Food & Drug Research Laboratories. 39 p.

Jackson, G.; Hardy, C. (1991) Diethanolamine Salt of 2,4-D: Acute Inhalation
Toxicity in Rats/4-Hour Exposure: Lab Project Number RIC 15/901290: 90-
0163. Unpublished study prepared by Huntingdon Research Centre Ltd. 26 p.

Hey dens, W. (1986) Acute Toxicity of Landmaster U Administered by
Inhalation to Male and Female Sprage-Dawley Rats: Monsanto Refe- rence No.
EHL 86125. Unpublished study prepared by Monsanto Co., Environmental
Health Laboratory. 45 p.

Nitschke, K.; Stebbins, K.  (1991) 2,4-D TTPA: Acute Inhalation Tox- icity
Study with Fischer 344 Rats: Lab Project Number: K-008866- 015.
Unpublished study prepared by Dow Chemical Co. 33 p.

Streeter, C.; Battjes, I; Yano, B. (1987) 2,4-D Butoxyethyl Ester, Technical: An
Acute Aerosol Inhalation Study in  Fischer 344 Rats: Lab. Proj. ID  K-007722-
007. Unpublished study prepared by Dow Chemical Co. 22 p.

Cieszlak, F. (1992) 2,4-Dichlorophenoxyacetic Acid, 2-Ethylhexyl Ester: Acute
Aerosol Inhalation Toxicity Study  with Fischer 344 Rats: Lab Project Number:
K-020054-015. Unpublished study prepared by Dow Chemical Co. 37 p.

Shults, S.; Brock,A.; Killeen, J. (1990) Primary Eye Irritation Study in Albino
Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number 90-0164: 3592-
90-0164-TX-001. Unpublished study prepared by Ricerca, Inc. 30 p.

Robbins,  G. (1989) Primary Eye Irritation Study in Rabbits: Dri-D  Amine: Lab
Project Number: D2013. Unpublished study prepared by Cosmopolitan Safety
Evaluation, Inc. (C.S.E.) 19 p.

Shults, S.; Brock,A.; Killeen, J. (1990) Primary Eye Irritation Study in Albino
Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number 90-0164: 3592-
90-0164-TX-001. Unpublished study prepared by Ricerca, Inc. 30 p.
                                   Page 269 of 304

-------
                                 2,4-D Bibliography
41413504
41125302
41920903
Berdasco, N.; Mizell, M. (1989) 2,4-Dichorophenoxyacetic Acid Tri-
isopropanolamine Salt: Primary Eye Irritation Study in New Zea- land White
Rabbits: Lab Project Number: K-008866-002C. Unpub- lished study prepared
by The Dow Chmemical Co. 14 p.

Kirsch, P. (1983) Report on the Study of the Irritation to the Eye of the White
Rabbit Based on Draize of 2,4-D: Doc. No. BASF: 83/ 0192. Unpublished study
prepared by BASF Aktiengesellschaft.  10 p.

Shults, S.; Brock, A.; Killeen, J. (1990) Primary Dermal Irritation Study in
Albino Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number: 90-
0165: 3592-90-0165-TX-001. Unpublished study prepared by Ricerca, Inc. 18 p.
41642804
41413505
40629805
41920904
41642805
41413506
40629806
41233701
Robbins, G. (1989) Primary Dermal Irritation Study in Rabbits: Dri- D Amine:
Lab Project Number: E2013. Unpublished study prepared by Cosmopolitan
Safety Evaluation, Inc. 14 p.

Mizell, M. (1989) 2,4-Dichlorophenoxyacetic Acid, Triisopropanol- amine Salt:
Primary Dermal Irritation Study in New Zealand White Rabbits: Lab Project
Number: K-008866-002B. Unpublished study prepared by The Dow Chemical
Co. 13  p.

Jeffrey, M. (1987) 2,4-D Butoxyethyl Ester, Technical: Primary Der- mal
Irritation Study in New Zealand White Rabbits: Lab. Proj. ID K-007722-006B.
Unpublished study prepared by Dow Chemical Co. 10 p.

Shults,  S.; Brock, A.; Killeen, J. (1990) Dermal Sensitization Study (Closed
Patch Repeated Insult) in Guinea Pigs with Di- ethanolamine Salt of 2,4-D: Lab
Project Number: 90-0166: 3592- 90-0166-TX-001. Unpublished study prepared
by Ricerca, Inc. 37 p.

Robbins, G. (1989) Guinea Pig Sensitization Study (Buehler): Dri-D Amine:
Lab Project Number: F2013. Unpublished study prepared by Cosmopolitan
Safety Evaluation, Inc. (C.S.E.)  17 p.

Berdasco, N. (1989) 2,4-Dichlorophenoxyacetic Acid Triisopropanol- amine
Salt: Dermal Sensitization Potential in the Hartley Albino Guinea Pig: Lab
Project Number: K-008866-002E. Unpublished study prepared by The Dow
Chemical Co. 14 p.

Jeffrey, M. (1986) Butoxy Ethyl 2,4-Dichlorophenoxyacetate: Dermal
Sensitization Potential in the Hartley Albino Guinea Pig: Lab. Proj. ID K-
007722-005. Unpublished study prepared by Dow Chemi- cal Co.  10 p.

Carreon, R.; Wall, J. (1984) XRM-4725 Herbicide Formulation:  Dermal
Sensitization Potential in the Guinea Pig:  Project Study ID: HET M-004725-
003. Unpublished study prepared by Dow Chemical U.S.A. lip.
Environmental Fate and Effects MRID References
                                   Page 270 of 304

-------
                                 2,4-D Bibliography
42059601
42749702
42735401
43914701
43762402
43705201
43849101
43872702
Doyle, R. (1991) Laboratory Volatility of the 2-Ethylhexyl Ester of 2,4-
Dichloro-phenoxyacetic Acid: Lab Project Number: T08037T601. Unpublished
study prepared by IIT Research Institute. 257 p.

Concha, M; Shepler, K. (1993) Photodegradation of (carbon 14)2,4-D 2-
Ethylhexyl Ester in a Buffered Aqueous Solution at pH 5 by Natural Sunlight:
Lab Project Number: 390W-1: 390W. Unpublished study prepared by PTRL
West, Inc. 104 p.

Concha, M.; Shepler, K.; Erhardt-Zabik, S. (1993) Hydrolysis of (carbon 14)2,4-
D Ethylhexyl ester at pH 5, 7, and 9: Lab Project Number: 387W-1: 387W.
Unpublished study prepared by PTRL-West, Inc. 95 p.

Hatfield, M. (1995) Field Soil Dissipation of the 2-Ethylhexyl Ester of 2,4-D in
Bare Ground in California: Final Report: Lab Project Number: AA940021:
RES94006: HWI 6397-144. Unpublished study prepared by American
Agricultural Services, Inc.; Agvise Labs and Hazleton Wisconsin,  Inc.  584 p.

Hatfield, M. (1995) Field Soil Dissipation of the 2-Ethylhexyl Ester of 2,4-D in
Turf in California: Final Report: Lab Project Number: AA940019: 6397-142:
HWI 6397-142. Unpublished study prepared by American Agricultural
Services, Inc.; Agvise Labs; and Hazleton Wisconsin, Inc. 614 p.

Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamme Salt of 2,4-D
on Turf in California: Final Report: Lab Project Number: AA940018: 6397-141:
RES94003. Unpublished study prepared by American Agricultural Services,
Inc.; Agvise, Inc.; and Hazleton Wisconsin, Inc. 593 p.

Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D
on Bare Soil in a Corn Use Pattern in Nebraska: Final Report: Lab Project
Number: AA940010: HWI 6397-133: RES94007. Unpublished study prepared
by American Agricultural Services, Inc.; Agvise Labs and Hazleton Wisconsin,
Inc. 576 p.

Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D
Granules in Bare Soil in North Dakota: Final Report: Lab Project Number:
RES94024: HWI 6397-146: AA940023. Unpublished study prepared by Agvise
Labs; Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc.  393 p.
00116625
43167501
McCall, P.; Vrona, S.; Kelley, S. (1981) Fate of uniformly carbon- 14 ring
labeled 2,4,5-trichlorophenoxyacetic acid and 2,4-Di- chlorophenoxyacetic acid.
?Source unknown). (Also In unpub- lished submission received Oct 21, 1982
under 11683-EX-2; sub- mitted by U.S. Dept. of the Interior, Washington, DC;
CDL: 248614-U)

Concha, M.; Shepler, K. (1994)  Aerobic Soil Metabolism of (carbon 14)2,4-
Dichlorophenoxyacetic Acid: Lab Project Number: 391W: 391 W-l.
Unpublished study prepared by PTRL West, Inc.  95 p.
                                    Page 271 of 304

-------
                                 2,4-D Bibliography
42045301
42979201
43356001
41125306
41007301
42045302
00112937
44117901
43908302
43954701
43491601
Cohen, S. (1991) Aerobic Aquatic Metabolism of 2,4-Dichlorophenoxy- acetic
Acid: Lab Project Number: C28-306-01: 002/011/008/89: 6197A Unpublished
study prepared by Center for Hazardous Mate- rials Research. 159 p.

Concha, M.; Shepler, K. (1993) Aerobic Aquatic Metabolism of (carbon 14)2,4-
D Acid: Lab Project Number: 393W-1: 393W. Unpublished study prepared by
PTRL West, Inc. 112 p.

Concha, M.; Shepler, K. (1994) Anaerobic Aquatic Metabolism of (carbon 14)-
2,4-D Acid: Lab Project Number: 394W-1: P394W. Unpublished study
prepared by PTRL West, Inc. 162 p.

Center for Hazardous Materials Research (1989) Aqueous Photodegra- dation of
2,4-Dichlorophenoxyacetic Acid in ph 7 Buffered Solu- tion: Rept. No. 5488A.
Unpublished study. 128 p.

Center for Hazardous Materials Research (1989) Hydrolysis of 2,4-D in
Aqueous Solutions Buffered  at pH 5, 7, and 9: Project ID: 002/001/001/88.
Unpublished study. 197 p.

Cohen, S. (1991) Mobility of Unaged 2,4-Dichlorophenoxyacetic Acid Using
Batch Equilibrium Technique: Lab Project Number: 012/011/ 006/89:  6224A:
C28-306-1. Unpublished study prepared by Center for Hazardous Materials
Research. 76 p.

Brandau, E.; Goertler, M.; Otsa, H; et al.  (1975) Carbofuran, FMC 33297, FMC
25213 and Endosulfan Soil Adsorption/Desorption Studies: Analytical Report
M-3785. (Unpublished study received Jan 3, 1978 under 279-3013; submitted
by FMC Corp., Philadel- phia, PA; CDL:096699-T)

Fathulla, R (1996) The Adsorption and Desorption of (carbon 14)-2,4-D on
Representative Agricultural Soils: Final Report: Lab Project Number: CHW
6397-166. Unpublished study prepared by Corning Hazleton Inc. 84 p.

Hatfield, M. (1995) Aquatic Dissipation of the Dimethylamine Salt of 2,4-D in a
Small Pond in North Dakota: Final Report: Lab Project Number: AA940027:
RES94027: HWI 6397-150. Unpublished study prepared by Agvise Labs;
American Agricultural Services, Inc.; and Hazleton Wisconsin, Inc. 719 p.

Hatfield, M. (1995) Aquatic Dissipation of the Dimethylamine Salt of 2,4-D in a
Small Pond in North Carolina: Final Report: Lab Project Number: RES94026:
RES944226: HWI6397-149.  Unpublished study prepared by Agvise Labs;
Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc. 713 p.

Barney, W. (1994) Aquatic Field Dissipation Study of 2,4-D DMAS in
Louisiana: Lab Project Number: 2001RI: F93154-032: F93309-517.
Unpublished study prepared by Environmental Technologies Institute, Inc.  580
P-
                                   Page 272 of 304

-------
                                 2,4-D Bibliography
45897101
45931801
43491601
43908302
43954701
43491601
45897101
45931801
44525001
43864002
Jacobson, B. (2003) Dispersion and Dissipation of the Herbicide 2,4-D in Lake
Woodruff, Florida: (Final Report): Lab Project Number: 243.01: 445S01:
RES944226. Unpublished study prepared by Waterborne Environmental, Inc.
and EPL Bio-Analytical Services. 423 p.

Jacobson, B. (2003) Dispersion and Dissipation of the Herbicide 2,4-D in Green
Lake, Minnesota: Lab Project Number: 243.03: 467C-105: RES944226.
Unpublished study prepared by Waterborne Environmental, Inc. and Wildlife
International, Ltd. 469 p.

Barney, W. (1994) Aquatic Field Dissipation Study of 2,4-D DMAS in
Louisiana: Lab Project Number: 2001RI: F93154-032: F93309-517.
Unpublished study prepared by Environmental Technologies Institute, Inc. 580
P-

Hatfield, M. (1995) Aquatic Dissipation of the Dimethylamine Salt of 2,4-D in a
Small Pond in North Dakota: Final Report: Lab Project Number: AA940027:
RES94027: HWI 6397-150. Unpublished study prepared by Agvise Labs;
American Agricultural Services, Inc.; and Hazleton Wisconsin, Inc. 719  p.

Hatfield, M. (1995) Aquatic Dissipation of the Dimethylamine Salt of 2,4-D in a
Small Pond in North Carolina: Final Report: Lab Project Number:  RES94026:
RES944226: HWI6397-149. Unpublished study prepared by Agvise Labs;
Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc. 713  p.

Barney, W. (1994) Aquatic Field Dissipation Study of 2,4-D DMAS in
Louisiana: Lab Project Number: 2001RI: F93154-032: F93309-517.
Unpublished study prepared by Environmental Technologies Institute, Inc. 580
P-

Jacobson, B. (2003) Dispersion and Dissipation of the Herbicide 2,4-D in Lake
Woodruff, Florida: (Final Report): Lab Project Number: 243.01: 445S01:
RES944226. Unpublished study prepared by Waterborne Environmental, Inc.
and EPL Bio-Analytical Services. 423 p.

Jacobson, B. (2003) Dispersion and Dissipation of the Herbicide 2,4-D in Green
Lake, Minnesota: Lab Project Number: 243.03: 467C-105: RES944226.
Unpublished study prepared by Waterborne Environmental, Inc. and Wildlife
International, Ltd. 469 p.

Norris, F. (1998) 2,4-D:  Dissipation After Application of the Granular Ester
Formulation to Farm Ponds: Final Study Report: Lab Project Number:
96P10380: 45503: 10380-02. Unpublished study prepared by Rhone-Poulenc
Ag Co., Covance Labs.,  Inc. and Agvise Labs., Inc. 1488 p.

Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D in
Pasture in California: Final  Report: Lab Project Number: AA940016: RAM
8862-93-001: AASI11/95.  Unpublished study prepared by Agvise Labs;
American Agricultural Services, Inc.; and Hazleton Wisconsin, Inc. 463  p.
                                   Page 273 of 304

-------
                                 2,4-D Bibliography
43831703
43500301
43470401
43612101
43592802
43810701
43797902
43872401
43676803
43872701
Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D
on Turf in California: Final Report: Lab Project Number: AA940018: 6397-141:
RES94003. Unpublished study prepared by American Agricultural Services,
Inc.; Agvise, Inc.; and Hazleton Wisconsin, Inc. 593 p.

Silvoy, J. (1994) Terrestrial Field Dissipation Study of 2,4-D DMAS on Bare
Soil in Colorado Conducted According to a Wheat Use Pattern: Lab Project
Number: 2000WH01: F93286/526. Unpublished study prepared by
Environmental Technologies Institute, Inc. and Agvise Labs. 717 p.

Silvoy, J. (1994) Terrestrial Field Dissipation Study of 2,4-D DMAS on Wheat
in Colorado: Lab Project Number: 2000WH05. Unpublished study prepared by
Environmental Technologies, Inc.; AGVISE; and A&L Lab., Inc. 703 p.

Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D DMAS on Bare
Soil in North Carolina, Conducted According to a Wheat Use Pattern: Lab
Project Number: 2000WH02: SC930170. Unpublished study prepared by
Environmental Technologies Institute, Inc., Agvise Laboratories, Inc., and other
facilities. 707 p.

Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D DMAS on
Wheat in North Carolina: Lab Project Numbers: 2000WH06: SC930174:
RES.07.05.01. Unpublished study prepared by Environmental Technologies
Institute (ETI), Inc. 713 p.

Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D DMAS on Bare
Soil in North Carolina Conducted According to a Turf Use Pattern: Lab Project
Number: 6397-127: 6397-128:  2000BS02. Unpublished study prepared by
Hazleton Wisconsin and Environmental Technologies Institute, Inc. 600 p.

Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D DMAS on Turf
in North Carolina: Lab Project Number: 2000TF02: HWI 6397-128.
Unpublished study prepared by Environmental Technologies Institute, Inc. 708
P-

Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D
on a Bare Soil in a Wheat Use  Pattern in North Dakota: Final Report: Lab
Project Number: AA940014: AASI12/95: HWI6397-137. Unpublished study
prepared by Agvise Labs; Hazleton Wisconsin, Inc.; and American Agricultural
Services, Inc. 426 p.

Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D DMAS on
Pasture in Texas: Lab Project Number: 2000PA02: 10-9305-02. Unpublished
study prepared by ETI Inc. and AGVISE Labs, Inc. 590 p.

Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D
Granules on Turf in North Dakota: Final Report: Lab Project Number:
RES94023: HWI 6397-145: AA940022. Unpublished study prepared by Agvise
Labs; Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc.  463 p.
                                    Page 274 of 304

-------
                                2,4-D Bibliography
43872702
                Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D
                Granules in Bare Soil in North Dakota: Final Report: Lab Project Number:
                RES94024: HWI 6397-146: AA940023. Unpublished study prepared by Agvise
                Labs; Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc.  393 p.
43834301
43954702
43779601
43908301
41353702
43821501
43799107
43799104
43799102
Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D
on Bare Soil in a Corn Use Pattern in Ohio: Final Report: Lab Project Number:
AA940012: HWI 6397-135: RES94009. Unpublished study prepared by
American Agricultural Services, Inc.; Hazleton Wisconsin, Inc.; and Agvise
Labs. 552 p.

Barney, W. (1995) Forest Field Dissipation of 2,4-Dichlorophenoxyacetic Acid,
Dimethylamine Salt in Oregon: Lab Project Number: 2002FO01: F9331-523: F-
9331-527. Unpublished study prepared by Collins Ag Consultants; Agvise Labs;
and Environmental Technologies Institute, Inc. 1309 p.

Reynolds, J. (1995) Aerobic Aquatic Metabolism of (Carbon-14)-
Dimethylamine: Lab Project Number: XBL95031: RPT00231: 8437.
Unpublished study prepared by XenoBiotic Labs, Inc. 118 p.

Reynolds, J. (1995) Anaerobic Aquatic Metabolism of (Carbon 14)-
Dimethylamine: Lab Report No. RPT00246; Study No. XBL95032.
Unpublished study prepared by XenoBiotic Labs., Inc. 128 p.

Reim, R. (1989) Dissociation of 2,4-Dichlorophenoxyacetic Acid (2,4-D), 2,4-D
Isopropylamine Salt (IPA) and 2,4-D Triisopropa- nolamine (TIPA) Salt in
Water: Lab Project Number: ML/AL/89/ 041189. Unpublished study prepared
by Dow Chemical U.S.A. 31 p

Hawes, K. (1995) The Aerobic Soil Metabolism of Isopropylamine: Lab Project
Number: ENV94100. Unpublished study prepared by DowElanco North
American Environmental Chemistry Lab. 47 p.

Hawes, K. (1995) The Aerobic Aquatic Metabolism of Isopropylamine: Lab
Project Number: ENV94101. Unpublished study prepared by DowElanco North
American Environmental Chemistry Lab. 78 p.

Hawes, K. (1995) The Anaerobic Aquatic Metabolism of Isopropylamine: Lab
Project Number: ENV94099. Unpublished study prepared by DowElanco North
American Environmental Chemistry Lab. 67 p.

Cleveland, C.; Ulmer, J.  (1995) Aerobic Soil Metabolism Study for
Triisopropanolamine (TIPA): a 2,4-D Requested Moiety Study: Lab Project
Number: ENV94142. Unpublished study prepared by DowElanco North
American Environmental Chemistry Lab. 70 p.
                                   Page 275 of  304

-------
                                2,4-D Bibliography
43799108
43799105
43685901
43685902
44439401
43882901
42770502
42770501
43514601
43533401
43846001
Krieger, M. (1995) Aerobic Aquatic Metabolism of (Carbon 14)-
Triisopropanolamine (TIPA): Lab Project Number: ENV94123. Unpublished
study prepared by DowElanco North American Environmental Chemistry Lab.
75 p.

Cleveland, C.; Ulmer, J. (1995) Anaerobic Aquatic Metabolism Study for
Triisopropanolamine (TIPA): Requested 2,4-D Moiety Study: Lab Project
Number: ENV94144. Unpublished study prepared by DowElanco North
American Environmental Chemistry Lab. 62 p.

Reynolds, J. (1995) Aerobic Soil Metabolism of (carbon 14) (inert ingredient):
Lab Project Number: XBL94082: RPT00214. Unpublished study prepared by
XenoBiotic Lab., Inc. 118 p.

Reynolds, J. (1995) Aerobic Aquatic Metabolism of (carbon 14) (inert
ingredient): Lab Project Number: XBL94084: RPT00216. Unpublished study
prepared by XenoBiotic Lab., Inc. 120 p.

Reynolds, J. (1996) Anaerobic Aquatic Metabolism of (carbon 14)-
Diethanolamine: Lab Project Number:  XBL94083: RPT00215: 94083.
Unpublished study prepared by XenoBiotic Labs., Inc. 151 p.

Reynold, J. (1995) Anaerobic Aquatic  Metabolism of (carbon 14)-(Inert
Ingredient): Lab Project Number: XBL94083: RPT00215:  SR940016-8.
Unpublished study prepared by XenoBiotic Labs, Inc. 141  p.

Concha, M.; Shepler, K.; Erhardt-Zabik, S.  (1993) Hydrolysis of (carbon 14)
2,4-D Ethylhexyl Ester in Natural Water: Lab Project Number: 395W-1: 395W.
Unpublished study prepared by PTRL  West, Inc. 69 p.

Concha, M.; Shepler, K.; Erhardt-Zabik, S.  (1993) Hydrolysis of (carbon 14)
2,4-D Ethylhexyl Ester in Soil Slurries: Lab Project Number: 403W-1: 403W.
Unpublished study prepared by PTRL  West, Inc. 79 p.

Silvoy, J. (1995) Terrestrial Field Dissipation Study of 2,4-D 2-EHE on Bare
Soil in Colorado: Lab Project Number: 2000WH03-COLORADO: SC930169:
RAM 8862-93-001. Unpublished study prepared by EH; Agvise; and A&L
Labs, Inc. 780 p.

Silvoy, J. (1995) Terrestrial Field Dissipation Study of 2,4-D 2-EHE on Wheat
in Colorado: Lab Project Number: 2000WH07-COLORADO: 2000WH07.
Unpublished study prepared by Agvise; A&L Labs, Inc.; and Battelle. 733 p.

Walter, J. (1995) WRC-AP-1 Nontarget Plant Data: Lab Project  Number:  4695-
GL21-NTP. Unpublished study prepared by Grace Biopesticides. 164 p.
                                   Page 276 of  304

-------
                                 2,4-D Bibliography
43592801
43762403
43762404
43640601
43831702
43872703
43849102
43831701
43705202
43762401
Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D 2-EHE on Bare
Soil in North Carolina: Conducted According to a Wheat Use Pattern: Lab
Project Numbers: 2000WH04: SC930172: F93076-050. Unpublished study
prepared by Environmental Technologies Institute (ETI), Inc. 749 p.

Barney, W. (1995) Terrestrial Field Soil Dissipation Study of 2,4-D 2-EHE on
Bare Soil in North Carolina Conducted According to a Turf Use Pattern: Lab
Project Number: 2000BS04. Unpublished study prepared by Environmental
Technologies, Inc. 748 p.

Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D 2-EHE on Turf
in North Carolina: Lab Project Number: 2000TF04. Unpublished study prepared
by Environmental Technologies, Inc. 865 p.

Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D 2-EHE on
Wheat in North Carolina: Lab Project Number: SC930176:  2000WH08.
Unpublished study prepared by Environmental Technologies Institute, Inc.;
Agvise Labs, Inc.; and DowElanco. 744 p.

Hatfield, M. (1995) Field Soil Dissipation of the 2-Ethylhexyl Ester of 2,4-D on
Bare Soil in a Wheat Use Pattern in North Dakota: Final Report: Lab Project
Number: AA940015: 6397-138: RES94022. Unpublished study prepared by
American Agricultural Services, Inc.; Agvise, Inc.; and Hazleton Wisconsin,
Inc. 445 p.

Hatfield, M. (1995) Field Soil Dissipation of the 2-Ethylhexyl Ester of 2,4-D
Granules in Bare Soil in Ohio: Final Report: Lab Project Number: RES94012:
HWI 6397-148: AA940025. Unpublished study prepared by Agvise Labs;
Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc. 404 p.

Hatfield, M. (1995) Field Soil Dissipation of the 2-Ethylhexyl Ester of 2,4-D on
Bare Soil in a Corn Use Pattern in Ohio: Final Report: Lab  Project Number:
AA940013: HWI 6397-136: RES94010. Unpublished study prepared by
American Agricultural Services, Inc.; Agvise Labs and Hazleton Wisconsin, Inc.
570 p.

Hatfield, M. (1995) Field Soil Dissipation of the 2-Ethylhexyl Ester of 2,4-D
Granules on Turf in Ohio: Final Report: Lab Project Number: AA940024: 6397-
147: RES 94011. Unpublished study prepared by American  Agricultural
Services, Inc.; Agvise, Inc.; and Hazleton Wisconsin, Inc. 513 p.

Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D 2-EHE on
Pasture in Texas: Lab Project Numbers: 2000PA04: 10-9305-04:  F93351-525.
Unpublished study prepared by Environmental Technologies Institute (ETI),
Inc. and Minnesota Valley Testing Labs. 692 p.

Hatfield, M. (1995) Field Soil Dissipation of the 2-Ethylhexyl Ester of 2,4-D in
Pasture in California: Final Report: Lab Project Number: AA940017: 6397-140:
HWI 6397-140. Unpublished study prepared by American Agricultural
Services, Inc.; Agvise Labs; and Hazleton Wisconsin, Inc. 507 p.
                                    Page 277 of 304

-------
                                2,4-D Bibliography
43762402
43908303
43927101
43415901
43691001
41353701
41483101
41483103
42574701
43799101
43799106
Hatfield, M. (1995) Field Soil Dissipation of the 2-Ethylhexyl Ester of 2,4-D in
Turf in California: Final Report: Lab Project Number: AA940019: 6397-142:
HWI 6397-142. Unpublished study prepared by American Agricultural
Services, Inc.; Agvise Labs; and Hazleton Wisconsin, Inc. 614 p.

Barney, W. (1995) Forest Field Dissipation of 2,4-Dichlorophenoxyacetic Acid
Isooctyl (2-Ethylhexyl) Ester in Georgia: Interim Report: Lab Project Number:
2002FO02: 6397-162: 011-02. Unpublished study prepared by Environmental
Technologies Institute, Inc. 152 p.

Barney, W. (1996) Forest Field Dissipation Study of 2,4-Dichlorophenoxyacetic
Acid, Isooctyl (2-Ethylhexyl) Ester in Georgia: Lab Project Number:
2002FO02: F93356-533: F93312-510. Unpublished study prepared by
Environmental Technologies Institute, Inc. 1355 p.

Reynolds, J. (1994) Aerobic Soil Metabolism of (carbon 14)-2-Ethylhexanol:
Lab Project Numbers: XBL93131: RPT00177. Unpublished study prepared by
XenoBiotic Labs, Inc. 111 p.

Reynolds, J. (1995) Anaerobic Aquatic Metabolism of (carbon 14)-2-
Ethylhexanol: Lab Project Number: XBL 93132: RPT00182. Unpublished study
prepared by XenoBiotic Labs, Inc. 115 p.

Racke, K. (1989) Hydrolysis of 2,4-Dichlorophenoxyacetic Acid-2- Butoxyethyl
Ester to 2,4-Dichlorophenoxyacetic Acid in a Soil/ Water System: Lab Project
Number: GH/C/2198. Unpublished study prepared by Dow Chemical U.S.A. 29
P-

Shepler, K.; Estigoy, L.; Ruzo, L. (1990) Hydrolysis of ?Carbon 14 2,4 D-
butoxyethyl Ester (2,4 D-BEE) at pH 5,7, and 9: Lab Project No.:  193W-
1;PTRL Project No. 193W. Unpublished study prepared by Pharmacology and
Toxicology Research Laboratory, West. 75 p.

Marx, M.;  Shepler, K. (1990) Vapor Phase Photolysis of (Carbon 14)-Phenyl}
2,4-Dichlorophenoxyacetic Acid, Butoxyethyl Ester (2D-BEE): PTRL Report
No. 195W-1: PTRL Project No. 195W. Unpublished study prepared by
Pharmacology & Toxicology Research Laboratories, West. 92 p.

Lawrence, B.; Mobley, S.; Kesterson, A. (1992) Anaerobic Aquatic Metabolism
of (carbon 14)2,4-D-2-Butoxyethyl Ester: Re-Issue: Lab Project Number: 453:
1428:  1623-90-43-06-28G-01. Unpublished  study prepared by PTRL East, Inc.
78 p.

Batzer, F. (1995) Aerobic Soil Metabolism of (Carbon 14)-2- Butoxyethanol:
Lab Project Number: ENV94094. Unpublished study prepared by DowElanco
North American Environmental Chemistry Lab. 117 p.

Batzer, F. (1995) Aerobic Aquatic Metabolism of (Carbon 14)-2-
Butoxyethanol: Lab Project Number: ENV94096. Unpublished study prepared
by DowElanco North American Environmental Chemistry Lab. 88 p.
                                   Page 278 of 304

-------
                                 2,4-D Bibliography
43799103
41349601
43441201
43149601
43606301
41125305
44188601
41557901
44105201
44158501
41158301
Batzer, F. (1995) Anaerobic Aquatic Metabolism of (Carbon 14)- 2-
Butoxyethanol: Lab Project Number: ENV94095. Unpublished study prepared
by DowElanco North American Environmental Chemistry Lab. 89 p.

Simoneaux, B. (1989) Uptake and Metabolism of 2?Delta|-?Carbon 14|-
Diazinon in Field Grown Apples: Lab Project Number: ABR-89058.
Unpublished study prepared by Ciba-Geigy Corp. 104 p.

Burke, B. (1994) Hydrolysis of (Ring-(carbon 14)) (2,4-Dichlorophenoxy)acetic
Acid Isopropyl Ester: Lab Project Number: PRT/22/4WNA/02:
PRT/22/4WNA/02/003. Unpublished study prepared by Plant Research
Technologies, Inc. 118 p.

Burke, B. (1994) Rate of De-esterification of (Ring-(carbon 14)) (2,4-
Dichlorophenoxy)acetic Acid Isopropyl Ester: Lab Project Number:
PRT/22/3WNA/01: PRT/22/3WNA/01/008. Unpublished study prepared by
Plant Research Technologies, Inc. 122 p.

Reynolds, J. (1995) Anaerobic Aquatic Metabolism of 2-(carbon 14)-
Isopropanol: Lab Project Number: XBL 94081: RPT00196. Unpublished study
prepared by XenoBiotic Labs, Inc. 100 p.

Center for Hazardous Materials Research (1989) Photodegradation of 2,4-
Dichlorophenoxyacetic Acid on Soil: Rept. No. 5485A. Un- published study.
127 p.

Fathulla, R (1996) Aerobic Aquatic Metabolism of (carbon 14)-2,4-D: Final
Report: Lab Project Number: CHW 6397-172. Unpublished study prepared by
Corning Hazleton, Inc. 83 p.

Levine, A. (1990) Anaerobic Aquatic Metabolism of 2,4-Dichloro-
phenoxyacetic Acid: Lab Project Number: 002/001/007/88. Unpub- lished study
prepared by Center for Hazardous Materials Research. Transmittal of 1  study.

Fathulla, R. (1996) The Adsorption and Desorption of (carbon 14)-2,4-DCP on
Representative Agricultural Soils: Lab Project Number: CHW 6397-168.
Unpublished study prepared by Corning Hazleton Inc. 82 p.

Fathulla, R. (1996) The Adsorption and Desorption of (carbon 14)-2,4-DCA on
Representative Agricultural Soils: Final Report: Lab Project Number: CHW
6397-170. Unpublished study prepared by Corning Hazleton, Inc. 84 p.

Alexander, H; Mayes, M.; Gersich, F. (1983) The Acute Toxicity of (2,4 -
Dichlorophenoxy)acetic Acid to Representative Aquatic Organisms: Project
Study ID: ES-DR-0002-2297-4. Unpublished study prepared by Dow Chemical
U.S.A. 26 p.
                                   Page 279 of 304

-------
                                 2,4-D Bibliography
53986
41975105
41975104
41158311
41353803
41353804
41353801
50674
40098001
45068
McCann, J.A.; Pitcher, F. (1973) Aquacide: Rainbow Trout (-Salrno
?~gairdneri~): Test No. 546. (U.S. Environmental Protection Agency, Pesticides
Regulation Div., Animal Biology Laboratory, unpublished study; CDL: 128584-
A)

Graves, W.; Peters, G. (1991) Diethanolamine Salt of 2,4-D: A 96- Hour Flow-
Through Acute Toxicity Test With the Rainbow Trout (Oncorhynchus mykiss):
Final Report: Lab Project Number: 281 A- 101 A. Unpublished study prepared by
Wildlife International. 37 p.

Graves, W.; Peters, G. (1991) Diethanolamine Salt of 2,4-D: A 96- Hour Flow-
Through Acute Toxicity Test With the Bluegill (Lepomis macrochirus): Final
Report: Lab Project Number: 281 A-105A. Unp- ublished study prepared by
Wildlife International. 37 p.

Alexander, H; Mayes, M; Gersich, F.; et al. (1983) The Acute Toxicity of (2,4-
Dichlorophenoxy) Acetic Acid Dimethylamine Salt to Representative Aquatic
Organisms: Project Study ID: ES-DR-0008-3556-2. Unpublished study
prepared by Dow Chemical U.S.A. 24 p.

Mayes, M.; Barren, M.; Hopkins, D.  (1989) 2,4-Dichlorophenoxyacetic Acid,
Trisopropanolamine Salt: Evaluation of the Toxicity to the Rainbow Trout,
Oncorhynchus mykiss: Final Report:  Project ES-DR- 0100-2400-1 A.
Unpublished study prepared by The Dow Chemical Co. 16 p.

Mayes, M.; Barren, M.; Hopkins, D.  (1989) 2,4-Dichlorophenoxyacetic Acid,
Trisopropanolamine Salt: Evaluation of the Toxicity to the Bluegill, Lepomis
macrochirus: Final Report: Project No. ES-DR- 2400/1B. Unpublished study
prepared by The Dow Chemical Co.  16 p.

Alexander, H.; Gersich, F.; Mayes, M. et al. (1983) The Acute Toxi-  city of 2-
Butoxyethyl (2,4-Dichlorophenoxy) Acetate to Represen- tative Aquatic
Organisms: Final Report: Lab Project Number:  ES - 586. Unpublished study
prepared by Dow Chemical U.S.A. 23 p.

Pitcher, F.G (1974) Weed-Rhap LV  OXY 6D:  Rainbow Trout (~Salmo~
?~gairdneri~): Test No. 683. (U.S. Environmental Protection Agency, Pesticides
Regulation Div., Animal Biology Laboratory, unpublished study; CDL: 128512-
A)

Mayer, F.; Ellersieck, M. (1986) Manual of Acute Toxicity: Inter- pretation and
Data Base for 410 Chemicals and 66 Species of Freshwater Animals. US Fish &
Wildlife Service, Resource Pub- lication 160. 579 p.

Buccafusco, R.J. (1976) Acute Toxicity of the Iso-octyl ester of 2,4-D D #
10498 to Rainbow Trout (?~Salmo gairdneri-?). (Unpub- lished study received
Oct 28, 1976 under 400-134; prepared by EG&G Bionomics, submitted by
Uniroyal Chemical, Bethany, Conn.;  CDL:226397-C)
                                   Page 280 of 304

-------
                                 2,4-D Bibliography
45069
43933101
43933201
43930701
43910301
41737307
42018301
41835209
41429001
Buccafusco, RJ. (1976) Acute Toxicity of the Iso-octyl ester of 2,4-D D #
10498 to Bluegill (?~Lepomis macrochirus-?). (Unpub- lished study received
Oct 28, 1976 under 400-134; prepared by EG&G Bionomics, submitted by
Uniroyal Chemical, Bethany, Conn.; CDL:226397-D)

Drottar, K.; Swigert, J.  (1996) 2,4-D Isopropyl Ester: A 96-Hour Flow-Through
Acute Toxicity Test with the Rainbow Trout (Oncorhynchus mykiss): Final
Report: Lab Project Number: 435A-103A: 435/100295/RBT-96H2A/CHP105.
Unpublished study prepared by Wildlife International Ltd. 69 p.

Drottar, K.; Swigert, J.  (1996) 2,4-D Isopropyl Ester End Use Product: A 96-
Hour Flow-Through Acute Toxicity Test with the Rainbow Trout
(Oncorhynchus mykiss): Final Report: Lab Project Number: 435A-101:
435/100295/RBT-96H2B/CHP105. Unpublished study prepared by Wildlife
Intl. Ltd. 68 p.

Drottar, K.; Swigert, J.  (1996) 2,4-D Isopropyl Ester: A 96-Hour Flow-Through
Acute Toxicity Test with the Bluegill (Lepomis macrochirus): Final Report: Lab
Project Number: 435A-105: 435/100295/BLU-96H2A/CHP105. Unpublished
study prepared by Wildlife International Ltd. 67 p.

Drottar, K.; Swigert, J.  (1996) 2,4-D Isopropyl Ester End Use Product: A 96-
Hour Flow Through Acute Toxicity Test with the Bluegill (Lepomis
macrochirus): Final Report: Lab Project Number: 435A-102: 435/100295/BLU-
96H2B/CHP 105. Unpublished study prepared by Wildlife International Ltd. 66
P-

Vaishnav, D.; Yurk, J.; Wade, B. (1990) 2,4-Dichlorophenoxyacetic Acid:
Acute Toxicity to Tidewater Silverside (Menidia Beryllina) Under Flow-
through Conditions: Lab Project Number: 3903008000- 0210-3140.
Unpublished study prepared by Environmental Science and Engineering Inc. 37
P-

Graves, W.; Peters, G (1991) Diethanolamme Salt of 2,4-D: A 96- Hour Flow-
through Acute Toxicity Test with the Atlantic Silver- side (Menidia  menidia):
Final Report: Lab Project Number: 281 A/ 102A. Unpublished study prepared by
Wildlife International Ltd. 37 p.

Ward, G. (1991) 2,4-D, Dimethylamine Salt: Acute Toxicity to the Tidewater
Silverside, Menidia beryllina, Under Flow-through Test Conditions: Lab Project
Number: J9002003B. Unpublished study prepared by Toxikon Environmental
Sciences. 41 p.

Sousa, J. (1990) Acute  Toxicity to  Tidewater Silversides (Menidia Beryllina)
Under Flow-Through Conditions: (2,4-D IP A): Lab Pro- ject Number: 89-11-
3140:  236.0689.6101.506: ES-2231. Unpublish- ed study prepared by
Springborn Laboratories, Inc. 35 p.
                                   Page 281 of 304

-------
                                 2,4-D Bibliography
41429004
41835205
41835202
41737304
42018304
41767701
41345701
41737305
44517307
Sousa, J. (1990) Acute Toxicity to Tidewater Silversides (Menidia beryllina)
under Flow-through Conditions: (2,4-D TIP A): Lab Pro- ject Number: 89-11-
3141: 236.0689.6100.506: ES-2230. Unpublished study prepared by Springborn
Laboratories, Inc. 38 p.

Ward, T.; Boeri, R. (1991) Acute Flow-through Toxicity of 2,4-D, 2- Ethylhexyl
Ester to the Tidewater Silverside, Menidia beryllina: Lab Project Number: 9035-
D. Unpublished study prepared by Re- source Analysts, Inc./EnviroSystems Inc.
25 p.

Ward, T.; Boeri, R. (1991) Acute Flow-through Toxicity of Esteron 99
Herbicide to the Tidewater Silverside, Menidia beryllina: Lab Project Number:
9038-D. Unpublished study prepared by Resource Analysts, Inc./EnviroSystems
Div.  25 p.

Mayes, M.; Gorzinski, S.; Potter, R.; et al. (1990) 2,4-Dichloro- phenoxyacetic
Acid: Evaluation of the Toxicity to Early Life Stages of the Fathead Minnow,
Pimephales promelas Rafinesque: Lab Project Number: ES-DR-0002-2297-10.
Unpublished study pre- pared by The Dow Chemical Co. 48 p.

Graves, W.; Peters, G (1991) Diethanolamine Salt of 2,4-D: An Early Life-
Stage Toxicity Test with the Fathead Minnow (Pime- phale promelas): Final
Report: Lab Project Number: 281 A/103 A. Unpublished study prepared by
Wildlife International Ltd. 55 p.

Dill,  C.; Gorzinski, S.; Potter, R; et al. (1990) 2,4-Dichloro- phenoxyacetic Acid
Dimethylamine Salt: Evaluation of the Toxi- city to Early Life Stages of the
Fathead Minnow, Pimephales promelas Rafinesque:  Lab Project Number: ES-
DR-0008-3556-4. Un- published study prepared by Dow Chemical Co.,
Environmental Tox. and Chem. Research. 39 p.

Mayes, M.; Gorzinski, S.; Harms, D.; et al. (1989) 2,4-Dichloro- phenoxyacetic
Acid,2-Butoxyethyl Ester: Evaluation of the Toxi- city to Early Life Stages of
the Fathead Minnow, Pimephales promelas Rafinesque: Lab Project Number:
ES/DR/0131/3037/1. Un- published study prepared by  Dow Chemical Co. 53 p.

Mayes, M.; Gorzinski, S.; Potter, R.; et al. (1990) 2,4-Dichloro- phenoxyacetic
Acid (2-Ethylhexyl Ester): Evaluation of the Toxi- city to Early Life Stages of
the Fathead Minnow, Pimephales promelas Rafinesque: Lab Project Number:
ES-DR-0019-1208-7. Un- published study prepared by The Dow Chemical Co.
51 p.

Palmer, S.; Krueger, H. (1997) 2,4-D (2,4-Dichlorophenoxyacetic Acid): A 96-
Hour Static Acute Toxicity Test with the Leopard Frog Tadpoles (Rana
pipiens): Final Report: Lab Project Number:  467A-102: 467/060297/LF-
96H1A/SUB467. Unpublished study prepared by Wildlife International Ltd. 57
P-
                                    Page 282 of 304

-------
                                 2,4-D Bibliography
44517306
44517305
41975106
138869
41353805
67328
41158306
43930601
41835211
42018303
Palmer, S.; Krueger, H. (1997) 2,4-D Dimethylamine Salt: A 96-Hour Static
Acute Toxicity Test with the Leopard Frog Tadpoles (Rana pipiens): Final
Report: Lab Project Number: 467A-103: 467/060297/LF-96H1B/SUB467.
Unpublished study prepared by Wildlife International Ltd. 57 p.

Palmer, S.; Krueger, H. (1997) 2,4-D 2-Ethylhexyl Ester:  A 96-Hour Static
Acute Toxicity Test with the Leopard Frog Tadpoles (Rana pipiens): Final
Report: Lab Project Number: 467A-101: 467/060297/LF-96H1C/SUB467.
Unpublished study prepared by Wildlife International Ltd. 70 p.

Graves, W.; Peters, G. (1991) Diethanolamine Salt of 2,4-D: A 48- Hour Flow-
Through Acute Toxicity Test With the Cladoceran (Daph- nia magna): Final
Report: Lab Project Number: 281 A-107. Unpubl- ished study prepared by
Wildlife International. 37 p.

Alexander, H; Mayes, M.; Gersich, F.; et al. (1983) The Acute Tox- icity of
(2,4-Dichlorophenoxy) Acetic Acid Isopropylamine Salt to Representative
Aquatic Organisms: ES-626. (Unpublished study received Jan 18, 1984 under
464-596; submitted by Dow Chemical U.S.A., Midland, MI; CDL:252291-D)

Mayes, M. (1989) 2,4-Dichlorophenoxyacetic Acid, Trisopropanolamine Salt:
Evaluation of the Toxicity to the Water Flea, Daphnia magna Straus: Final
Report: Lab Project Number: ES/DR/0100/2400/1C. Unpublished study
prepared by The Dow Chem- ical Co. 17 p.

Kuc, W.J. (1977) The Acute Toxicity of 2,4-D Isooctyl Ester Tech D-10498 to
the Water Flea-Daphnia magna-Straus: UCES Proj. # 11506-29-07.
(Unpublished study received Aug 19, 1977 under 400-134; prepared by Union
Carbide Corp., submitted by Uniroyal Chemical, Bethany, Conn.; CDL:231359-
A)

Alexander, H; Gersich, F.; Mayes, M.; et al. (1983) The Acute Toxicity of (2,4-
Dichlorophenoxy) Acetic Acid Isooctyl Ester to Representative Aquatic
Organisms: Project Study ID: ES-DR-0019- 1208-3. Unpublished study
prepared by Dow Chemical U.S.A. 15 p.

Drottar, K.;  Swigert, J. (1996) 2,4-D Isopropyl Ester: A 48-Hour Flow-Through
Acute Toxicity Test with the Cladoceran (Daphnia magna): Final Report: Lab
Project Number: 435A-104A. Unpublished study prepared by Wildlife
International Ltd. 68 p.

Ward, T.; Boeri, R. (1991) Chronic Toxicity of 2,4-D to the Daphnid Daphnia
magna: Lab Project Number: 9040-D. Unpublished study  prepared by Resource
Analysts, Inc./EnviroSystems Div. 38 p.

Holmes, C.; Peters, G. (1991) Diethanolamine Salt 2,4-D: A Flow- through
Life-Cycle Toxicity Test with the Cladoceran (Daphnia magna):  Final Report:
Lab Project Number: 281 A/106. Unpublished study prepared by  Wildlife
International Ltd. 51 p.
                                   Page 283 of 304

-------
                                 2,4-D Bibliography
41835210
41353802
42979701
41737306
42018302
41975107
41158310
41973401
41429003
41429002
Ward, G. (1991) 2,4-D, Dimethylamine Salt: Chronic Toxicity to the Water
Flea, Daphnia magna, Under Flow-through Test Conditions: Lab Project
Number: J9002003D. Unpublished study prepared by Toxikon Environmental
Sciences. 45 p.

Gersich, F.; Gorzinski, S.; Harms, D.; et al. (1989) 2,4-Dichloro- phenoxy
Acetic Acid (2-Butoxyethyl Ester): Evaluation of the Chronic Toxicity to
Daphnia magna Straus: Final Report: Project No. ES-DR-0131-3037-2.
Unpublished study prepared by The Dow Chemical Co. 36 p.

Ward, T.; Magazu, I; Boen, R. (1993) 2,4-D: Acute Flow-Through Mollusc
Shell Deposition Test: Lab Project Number: 286-DE. Unpublished study
prepared by T.R Wilbury Labs, Inc. 38 p.

Vaishnav, D.;  Yurk, I; Wade, B. (1990) 2,4-Dichlorophenoxyacetic Acid:
Acute Toxicity to Pink Shrimp (Penaeus Duorarum) Under Flow-through
Conditions: Lab Project Number: 3903008000-0200- 3140. Unpublished study
prepared by Environmental Science and Engineering Inc. 37 p.

Graves,  W.; Peters, G. (1991) Diethanolamine Salt of 2,4-D: A 96- Hour Shell
Deposition  Test with the Eastern Oyster (Crassostrea virginica):  Lab Project
Number: 281 A/115. Unpublished study prepared by Wildlife International Ltd.
39 p.

Graves,  W.; Peters, G. (1991) Diethanolamine Salt of 2,4-D: A 96- Hour Flow-
Through Acute Toxicity Test With the Pink Shrimp (Pen- aeus Duorarum):
Final Report: Lab Project Number: 281 A-104A. Unpublished study prepared by
Wildlife International. 37 p.

Heitmuller, T. (1975) Acute Toxicity of DMA-4 to Larvae of the Eastern Oyster
(Crassostrea virginica), Pink Shrimp (Penaeus duorarum), and Fiddler Crabs
(UCA pugilator): Project Study ID: GH-RC-10. Unpublished study prepared by
Bionomics—EG&G, Inc. 12 p.

Ward, G. (1991) 2,4-D, Dimethylamine Salt: Acute Effect on New Shell Growth
of, the Eastern Oyster, Crassostrea virginica, Under Floow-through Conditions:
Lab Project Number: J9002003C. Unpublished study prepared by Toxikon
Environmental Sciences. 41 p.

Dionne, E. (1990) Acute Toxicity to Eastern Oyster (Crassostrea virginica)
under Flow-through Conditions: (2,4-D IP A): Lab Proj- ject Number: 89-11-
3134: 236.0689.6101.504: ES-2227. Unpublish- ed study prepared by
Springborn Laboratories, Inc. 39 p.

Sousa, J. (1990) Acute Toxicity to Pink Shrimp (Penaeus duorarum) Under
Flow-through  Conditions: (2,4-D IPA): Lab Project Number: 89-11-3154: 236.
0689. 6101. 516: ES-2229. Unpublished study prepared by Springborn
Laboratories, Inc. 40 p.
                                   Page 284 of 304

-------
                                 2,4-D Bibliography
41429006
41429005
41835204
41835201
41835206
41835203
41420001
43307901
43307902
43307903
43768001
Dionne, E. (1990) Acute Toxicity to Eastern Oyster (Crassostrea virginica)
under Flow-through Conditions: (2,4-D TIP A): Lab Pro-ject Number: 89-9-
3092: 236.0689.6100.504: ES-2226. Unpublished study prepared by Springborn
Laboratories, Inc. 37 p.

Sousa, J. (1990) Acute Toxicity to Pink Shrimp (Penaeus duorarum) Under
Flow-through Conditions:  (2,4-D TIPA): Lab Project Number: 89-12-3169:
236.0689.6100.516: ES-2228. Unpublished study pre- pared by Springborn
Laboratories, Inc. 37 p.

Ward, T.; Boeri, R. (1991) Acute Flow-through Mollusc Shell Deposi- tion Test
with 2,4-D, 2-Ethylhexyl Ester: Lab Project Number: 9034-D. Unpublished
study prepared by Resource Analysts, Inc./ EnviroSystems Div. 25 p.

Ward, T.; Boeri, R. (1991) Acute Flow-through Mollusc shell Deposi- tion Test
with Esteron 99 Herbicide: Lab Project Number:  9037-D. Unpublished study
prepared by Resource Analysts, Inc./Enviro- Systems Div. 25 p.

Ward, T.; Boeri, R. (1991) Acute Flow-through Toxicity of 2,4-D, 2- Ehtylhexyl
Ester to the Grass Shrimp, Palaemonetes pugio: Lab Project Number: 9036-D.
Unpublished study prepared by Resource Analysts, Inc. 25 p.

Ward, T.; Boeri, R. (1991) Acute Flow-through Toxicity of Esteron 99
Herbicide to the Grass Shrimp, Palaemonetes pugio: Lab Pro-ject Number:
9039-D. Unpublished study prepared by Resource Analysts, Inc./EnviroSystems
Div. 25  p.

Hughes, J. (1989) The Toxicity of 2,4-D to Selenastrum Capricorn- utum: Lab
Project Number: 0460-05-1100-1. Unpublished study prepared by Malcolm
Pirnie, Inc. 33 p.

Hughes, J.; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D to Anabaena
flos-aquae: Lab Project Number:  10/01/1. Unpublished study prepared by
Carolina Ecotox, Inc.  57 p.

Hughes, J.; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D to Navicula
pelliculosa: Lab Project  Number: 10/01/2.  Unpublished study prepared by
Carolina Ecotox, Inc.  55 p.

Hughes, J.; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D to
Skeletonema costatum: Lab Project Number: 10/01/3. Unpublished study
prepared by Carolina Ecotox, Inc. 57 p.

Hughes, J.; Williams, T.; Alexander, M. (1995) The Toxicity of Isopropyl Ester
of 2,4-Dichlorophenoxyacetic Acid to Selenastrum capricornutum: Lab Project
Number: 17-01-1. Unpublished study prepared by Carolina Ecotox, Inc. 56 p.
                                    Page 285 of 304

-------
                                 2,4-D Bibliography
44295101
42712204
42712205
42712201
42712202
42712203
41505904
41420002
41505901
41505903
41505902
Hughes, !; Williams, T.; Conder, L. (1997) Effect of 2,4-
Dichlorophenoxyacetic Acid on the Growth and Reproduction of Lemna gibba
G3: (Final Report): Lab Project Number: 10-05-1. Unpublished study prepared
by Carolina Ecotox, Inc. 72 p.

Thompson, S.; Swigert, J. (1993) Diethanolamine Salt of 2,4-D: A 14-Day
Toxicity Test with Duckweed (Lemna gibba G3): Final Report: Lab Project
Number: 281 A-116. Unpublished study prepared by Wildlife International, Ltd.
45 p.

Thompson, S.; Swigert, J. (1993) Diethanolamine Salt of 2,4-D: A 5-Day
Toxicity Test with the Freshwater Alga (Selenastrum capricornurum): Final
Report: Lab Project Number: 281A-117A.  Unpublished study prepared by
Wildlife International, Ltd. 39 p.

Thompson, S.; Swigert, J. (1993) Diethanolamine Salt of 2,4-D: A 5-Day
Toxicity Test with the Marine Diatom (Skeletonema costatum): Final Report:
Lab Project Number: 281 A-119. Unpublished study prepared by Wildlife
International, Ltd. 38 p.

Thompson, S.; Swigert, J. (1993) Diethanolamine Salt of 2,4-D: A 5-Day
Toxicity Test with the Freshwater Diatom (Navicula pelliculosa): Final Report:
Lab Project Number: 281 A-120. Unpublished study prepared by Wildlife
International, Ltd. 39 p.

Thompson, S.; Swigert, J. (1993) Diethanolamine Salt of 2,4-D: A 5-Day
Toxicity Test with the Freshwater Alga (Anabaena flos-aquae): Final Report:
Lab Project Number: 281A-118. Unpublished study prepared by Wildlife
International, Ltd. 39 p.

Hughes, J. (1989) The Toxicity of 2,4-D, Dimethylamine Salt to Lemna gibba:
Lab Project Number: 0460-05-1100-7. Unpublished prepared by Malcolm
Pirnie, Inc. 33 p.

Hughes, J. (1989) The Toxicity of 2,4-D, Dimethylamine Salt to Selenastrum
capricornutum: Lab Project Number: 0460-05-1100-3. Unpublished study
prepared by Malcolm Pirnie, Inc. 33 p.

Hughes, J. (1990) The Toxicity of 2,4-D, Dimethylamine Salt to Skeletonema
costatum: Lab Project Number: 0460-05-1100-6. Un- published study prepared
by Malcolm Pirnie, Inc. 34 p.

Hughes, J. (1990) The Toxicity of 2,4-D, Dimethylamine Salt to Navicula
pelliculosa: Lab Project Number: 0460-05-1100-5. Unpub- lished study
prepared by Malcolm Pirnie, Inc. 32 p.

Hughes, J. (1989) The Toxicity of 2,4-D, Dimethtylamine Salt to Anabaena flos-
aquae: Lab Project Number: 0460-05-1100-4.  Unpub- lished study prepared by
Malcolm Pirnie, Inc.  33 p.
                                   Page 286 of 304

-------
                                 2,4-D Bibliography
41732102
43488602
41732101
43488603
43488601
43488604
43188201
42068403
41735203
41735206
41735204
41735205
Hughes, J. (1990) The Toxicity of 2,4-D, Isopropylamine Salt to Selenastrum
capricornutum: Lab Project Number: B460-10-1. Un- published study prepared
by Malcolm Pirnie, Inc. 34 p.

Hughes, I; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D TIPA to
Lemna gibba: Lab Project Number: 10-02-4: ES-2838. Unpublished study
prepared by Carolina Ecotox, Inc. 66 p.

Hughes, J. (1990) The Toxicity of 2,4-D, Triisopropanolamine Salt to
Selenastrum capricornutum: Lab Project Number: B460-09-1. Unpublished
study prepared by Malcolm Pirnie, Inc. 34 p.

Hughes, L; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D TIPA to
Skeletonema costatum: Lab Project Number: 10-02-3: ES-2837. Unpublished
study prepared by Carolina Ecotox, Inc. 65 p.

Hughes, L; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D TIPA to
Navicula pelliculosa: Lab Project Number: 10-02-2: ES-2836. Unpublished
study prepared by Carolina Ecotox, Inc. 66 p.

Hughes, L; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D TIPA to
Anabaena  flos-aquae: Lab Project Number: 10-02-1: ES-2807. Unpublished
study prepared by Carolina Ecotox, Inc. 64 p.

Selim, S. (1994) Hydrolysis of Pyrethrin 1 as a Function of pH at 25 degrees C:
Lab Project Number: P1092011: 93-1147.BTC. Unpublished study prepared by
Biological Test Center. 83 p.

Hughes, J. (1990) The Toxicity of 2,4-D, Butoxyethyl Ester to Navi- cula
pelliculosa: Lab Project Number: B460-08-2. Unpublished study prepared by
Malcolm Pirnie, Inc. 35 p.

Hughes, J. (1990) The Toxicity of 2,4-D,2-Ethylhexyl Ester to Lemna gibba:
Lab Project Number: B460-07-4. Unpublished study pre- pared by Malcolm
Pirnie, Inc. 36 p.

Hughes, J. (1990) The Toxicity of 2,4-D,2-Ethylhexyl Ester to Sele- nastrum
capricornutum: Lab Project Number: 0460-05-1100-2. Un- published study
prepared by Malcolm Pirnie, Inc. 38 p.

Hughes, J. (1990) The Toxicity of 2,4-D,2-Ethylhexyl to Skeletonema costatum:
Lab Project Number: B460-07-3. Unpublished study pre- pared by Malcolm
Pirnie, Inc. 38 p.

Hughes, J. (1990) The Toxicity of 2,4-D,2-Ethylhexyl Ester to Navi- cula
pelliculosa: Lab Project Number: B460-07-2. Unpublished study prepared by
Malcolm Pirnie, Inc. 38 p.
                                   Page 287 of 304

-------
                                 2,4-D Bibliography
41735202
0016000
41975101
41546201
00138871
41644401
41454101
41158303
72472
43935001
Hughes, J. (1990) The Toxicity of 2,4-D,2-Ethylhexyl Ester to Ana- baena flos-
aquae: Lab Project Number: B460-07-1. Unpublished study prepared by
Malcolm Pirnie, Inc. 37 p.

Shell Chemical Company (1975) Data Supporting the Use of Nudrin 1.8
Insecticide Solution for the Control of Insect Pests on Squash. Summary of
studies 232410-T through 232410-V.  (Unpublished study received Jun 29, 1976
under 201-347; CDL:232410-B)

Campbell, S.; Grimes, I; Smith, G. (1991) Diethanolamine Salt of 2,4-D: An
Acute Toxicity Study with the Northern Bobwhite: Lab Project Number: 281-
109. Unpublished study prepared by Wildlife International. 29 p.

Hoxter, K.; Culotta, J.; Jaber, M.  (1990) An Acute Oral Toxicity Study with the
Northern Bobwhite: Final Report: Lab Project Num- ber: 103-310. Unpublished
study prepared by Wildlife Inter- national Ltd. 21 p.

Beavers, J.; Jaber, M.; Joiner, G; et al. (1983) An Acute Oral Toxicity Study in
the Mallard with 2,4-D Isopropylamine Salt: Project No. 103-226. Final rept.
(Unpublished study received Jan  18, 1984 under 464-596; prepared by Wildlife
International Ltd., submitted by Dow  Chemical U.S.A., Midland, MI; CDL:
252291-F)

Culotta, J.; Campbell, S.; Hoxter, K. etal. (1990) 2,4-Dichloro- phenoxyacetic
Acid, Triisopropanolamine Salt: An Acute Oral Toxicity Study with the
Northern Bobwhite: Lab Project Number: 103/329. Unpublished study prepared
by Wildlife International Ltd.  19 p.

Lloyd, D.; Grimes, J.; Hoxter, K. (1990) 2, 4-Dichlorophenoxy- acetic Acid,
Butoxyethyl  Ester: An Acute Oral Toxicity Study with the Northern Bobwhite:
Final Report: Lab Project Number:  103-318. Unpublished study prepared by
Wildlife International Ltd. 20 p.

Beavers, J. (1984) (2,4-Dichlorophenoxy) Acetic Acid Isooctyl Ester: An Acute
Oral Toxicity Study with the Mallard: Project Study ID: 103-229. Unpublished
study prepared by Wildlife International Ltd. 20 p.

Gleich, J.; Wei?ss|e, G; Unkelbach, H.D.; et al. (1981) Teratogen- icity Study in
Himalayan Rabbits after Oral Administration: Experiment No. T 9127.
(Translation; unpublished study re-  ceived Mar 31, 1981 under 21137-4;
prepared by E. Merck, W. Germany, submitted by EM Laboratories, Inc.,
Elmsford, N.Y.; CDL:244977-A)

Palmer, S.; Beavers, J. (1996) 2,4-D Isopropyl Ester: An Acute Oral Toxicity
Study with the Northern Bobwhite:  Lab Project Number: 435-103:
435/100295/QLD.NC/CHP105. Unpublished study prepared by Wildlife
International Ltd. 50 p.
                                    Page 288 of 304

-------
                                 2,4-D Bibliography
41586101
41546202
41975102
41975103
41749501
41749502
00138870
00138872
41644402
41644403
41448401
Culotta, J.; Hoxter, K.; Foster, I; et al. (1990) 2,4-D (2,4-Dich- loroxyacetic
Acid): A Dietary LC50 Study with the Northern Bob- white. Lab Project
Number: 103-306. Unpublished study prepared by Wildlife International Ltd. 55
P-

Culotta, J.; Foster, J.; Grimes, J. et al. (1990) A Dietary LC50 Study with the
Mallard: Lab Project Number: 103-307. Unpub- lished study prepared by
Wildlife International Ltd. 42 p.

Hoxter, K.; Grimes, I; Smith, G ; et al. (1991) Diethanolamine Salt of 2,4-D: A
Dietary LC50 Study with the Northhern Bobwhite: Lab Project Number: 281-
107. Unpublished study prepared by Wil- dlife International. 32 p.

Hoxter, K.; Grimes, I; Smith, G; et al. (1991) Diethanolamine Salt of 2,4-D: A
Dietary LC50 Study with the Northern Bobwhite: Lab Project Number: 281-
108. Unpublished study prepared by Wil- dlife International. 32 p.

Long, R; Foster, J.; Hoxter, K.; et al. (1990) 2,4-D Dimethylamme Salt: A
Dietary LC50 Study with the Northern Bobwhite: Lab Pro- ject Number: 103-
308. Unpublished study prepared by Wildlife International Ltd. 42 p.

Long, R; Foster, J.; Hoxter, K.; et al. (1990) 2,4-D Dimethylamine Salt: A
Dietary LC50 Study with the Northern Bobwhite: Lab Pro- ject Number: 103-
309. Unpublished study prepared by Wildlife International Ltd. 42 p.

Beavers, I; Jaber, M; Joiner, G; et al. (1983) A Dietary LC50 in the Bobwhite
with 2,4-D Isopropylamine Salt: Project No. 103- 224. Final rept (Unpublished
study received Jan 18, 1984 un- der 464-596; prepared by Wildlife International
Ltd., submitted by Dow Chemical U.S.A., Midland, MI;  CDL:252291-E)

Beavers, I; Jaber, M.; Joiner, G; et al. (1983) A Dietary LC50 in the Mallard
with 2,4-D Isopropylamine Salt: Project No. 103-225. Final rept. (Unpublished
study received Jan 18, 1984 under 464- 596; prepared by Wildlife International
Ltd., submitted by Dow Chemical U.S.A., Midland, MI;  CDL:252291-G)

Driscoll, C.; Foster, I; Hoxter, K. etal. (1990) 2,4-Dichlorophe- noxyacetic
Acid, Triisopropanolamine Salt: A Dietary LC50 Study with the Northern
Bobwhite: Lab Project Number: 103/327. Unpub- lished study prepared by
WildLife International Ltd. 17 p.

Driscoll, C.; Foster, J.; Hoxter, K. etal. (1990) 2,4-Dichlorophe- noxyacetic
Acid, Triisopropanolamine Salt: A Dietary LC50 Study with the Mallard: Lab
Project Number: 103/328.  Unpublished study prepared by Wildlife International
Ltd. 17 p.

Grimes, J.; Culotta, J.; Hoxter, K.; etal. (1990)  2,4-Dichloro- phenoxyacetate
Acid, Butoxyethyl Ester: A Dietary LC50 Study with the Northern Bobwhite:
Lab Project Number: 103-316. Unpub- lished study prepared by Wildlife
International Ltd. 20 p.
                                    Page 289 of 304

-------
                                 2,4-D Bibliography
41429007
41158305
45070
41158304
43934901
43935201
45336401
44517304
44517301
42416802
42416801
Grimes, J.; Culotta, I; Hoxter, K. et al. (1990) 2,4-Dichlorophe- noxyacetic
Acid, Butoxyethyl Ester: A Dietary LC50 Study with the Mallard: Lab Project
Number: 103-317. Unpublished study prepared by Wildlife International Ltd. 20
P-

Beavers, J. (1984) (2,4-Dichlorophenoxy) Acetic Acid Isooctyl Ester: A Dietary
LC50 Study with the Bobwhite Quail: Project Study ID: 103-227. Unpublished
study prepared by Wildlife International Ltd. 16 p.

Fink, R. (1976) Final Report: Eight-Day Dietary LC50~Mallard Duck: Project
No. 117-114. (Unpublished study received Oct 28, 1976 under 400-134;
prepared by Wildlife International, Ltd., sub- mitted by Uniroyal Chemical,
Bethany, Conn.; CDL:226397-E)

Beavers, J. (1984) (2,4-Dichlorophenoxy) Acetic Acid Isooctyl Ester: A Dietary
LC50 Study with the Mallard: Project Study ID: 103-228. Unpublished study
prepared by Wildlife International Ltd. 17 p.

Palmer, S.; Beavers, J. (1996) 2,4-D Isopropyl Ester: A Dietary LC50 Study
with the Northern Bobwhite: Lab Project Number: 435-101: WIL-233002:
435/100292/QLCSDT.WC/CHP105. Unpublished study prepared by Wildlife
International Ltd. 68 p.

Palmer, S.; Beavers, J. (1996) 2,4-D Isopropyl Ester: A Dietary LC50 Study
with the Mallard: Lab Project Number: 435-102:
435/100295/MLCSDT.WC/CHP105. Unpublished study prepared by Wildlife
International Ltd. 68 p.

Mitchell, L.; Beavers, J.; Martin, K. et al. (1999) 2,4-D Acid: A Reproduction
Study with the Northern Bobwhite: Final Report: Lab Project Number: 467-106.
Unpublished study prepared by Wildlife International, Ltd. 181 p.

Palmer, S.; Krueger, H. (1997) 2,4-D Dimethylamine Salt: An Acute Contact
Toxicity Study with the Honey Bee: Lab Project Number: 467-102:
467/052297/BLDNC.EFA/SUB467. Unpublished study prepared by Wildlife
International Ltd. 32 p. {OPPTS 850.3020}

Palmer, S.; Krueger, H. (1997) 2,4-D 2-Ethylhexyl Ester: An Acute Contact
Toxicity Study with the Honey Bee: Lab Project Number: 467-104.
Unpublished study prepared by Wildlife International Ltd. 34 p._{OPPTS
850.3020}

Backus, P. (1992) Effect of 2,4-D Acid on Seed Germination/Seedling
Emergence: Tier II: Lab Project Number: 5097-91-0389-BE-001: 91-0389.
Unpublished study prepared by Ricerca, Inc. 223 p.

Backus, P. (1992) Effect of 2,4-D Acid on Vegetative Vigor of Plants: Tier E:
Lab Project Number: 91-0390: 5097-91-0390-BE-001. Unpublished study
prepared by Ricerca, Inc. 124 p.
                                   Page 290 of  304

-------
                                2,4-D Bibliography


42609101        Backus, P. (1992) Effect of 2,4-D DEAS on Seed Germination/Seedling
                Emergence (Tier II): Lab Project Number: 5283-92-0155-BE-001: 92-0155.
                Unpublished study prepared by Ricerca, Inc. 210 p.
                                  Page 291 of 304

-------
Appendix E. Generic Data Call-In
                                  Page 292 of 304

-------
Appendk E.



The generic data call-in will be posted at a later date.
                                     Page 293 of 304

-------
Appendix F. Product Specific Data Call-In
                                  Page 294 of 304

-------
Appendk F.



The product specific data call-in will be posted at a later date.
                                     Page 295 of 304

-------
Appendix G. EPA's Batching of 2,4-D Products for Meeting Acute Toxicity Data
Requirements for Reregistration
                                   Page 296 of 304

-------
Appendk G.

The batching of 2,4-D products for meeting acute toxicity data requirements for reregistration will be
posted at a later date.
                                      Page 297 of 304

-------
Appendix H. List of Registrants Sent This Data Call-In
                                   Page 298 of 304

-------
Appendk H.



A list of registrants sent this data call-in will be posted at a later date.
                                       Page 299 of 304

-------
Appendix I.   List Of Available Related Documents And Electronically Available Forms
                                  Page 300 of 304

-------
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/opprdOO 1 /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@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
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 (PR Notice 98-5)
http: //www. epa. aov/opprdOO 1 /forms/85 70- 1 . pdf

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

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

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

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

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

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

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

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

http://www. epa. aov/opppmsd 1 /PR Notices/pr98-
5.pdf
                                    Page 301 of 304

-------
8570-35
8570-36
8570-37
Data Matrix (PR Notice 98-5)
Summary of the Physical/Chemical
Properties (PR Notice 98-1)
Self-Certification Statement for the
Physical/Chemical Properties (PR
Notice 98-1)
http://www. epa. gov/opppmsd 1 /PR Notices/pr98-
5.pdf
http://www. epa. gov/opppmsd 1 /PR Notices/pr98-
l.pdf
http://www. epa. gov/opppmsd 1 /PR Notices/pr98-
l.pdf
Pesticide Registration Kit

Dear Registrant:
www. epa. gov/pesticides/registrationkit/
       For your convenience, we have assembled an online registration kit which 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.      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.

       2.      Pesticide Registration (PR) Notices


              a.      83-3 Label Improvement Program—Storage and Disposal Statements
              b.      84-1 Clarification of Label Improvement Program
              c.      86-5 Standard Format for Data Submitted under FIFRA
              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
                     §95-2 Notifications, Non-notifications, and Minor Formulation Amendments
                     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 Registration/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
              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 1 $6, 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)
                                     Page 302 of 304

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

       1.      The Office of Pesticide Programs' website.

       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.

       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 website.

       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 website:
              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 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; and
                     •       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 chemical abstract system (CAS)
              number if one has been assigned.

Documents Associated with this RED

       The following documents are part of the Administrative Record for this RED document and
may be included in the EPA's Office of Pesticide Programs Public Docket.  Copies of these
documents are not available electronically, but may be obtained by contacting the person listed on the
respective Chemical Status Sheet.

       1.      Detailed Label Usage Information System (LUIS) Report.


                                     Page 303 of 304

-------
Page 304 of 304

-------