United SttMi           OTOoi of PWfeida *nd Toife Sub«aM«
                 Envtronmonal PfOtMtton     Offie* of PojiwM* PreffrMV (TS-7MCI
                                       t. oc ao«n
v>ERV    Pesticide
                 Fact Sheet
540/FS-92-175
                 Name of Chemical:    prodiamine
                 Reason for Issuance:   Registration
                 Date Issued:   2/7/92
                 Fact Sheet Number 231 _.
  1.  DESCRIPTION OF CHhMICAL

     Generic Name: j*3,N3-Di-n-propyl-2,4-dinitro-b-
                   (trifluoroittethyl)-m-phenylenediamine
     Common Maine: Prodiamine
     Trade Names: Barricade"
     EPA Shaughnessy Code: 110201
     Chemical Abstracts  Service (CAS) Number:  29091-21-2
     Year of Initial Registration: 1991
     Pesticide Type: Herbicide
     Chemical Family: Dinitro-aniline
     U.S. Producer: Sandoz Crop Protection Corporation

  2.  USE PATTERNS AND FORMULATIONS

     Application sites:  Terrestrial non-food  sites.
        Preemergence for selective control of  annual grasses
        and broadleaf weeas in established lawns  and
        in landscape ornamentals.

     Types of formulations:  The two end-use products
        are water disperseable granular formulations of the active
        ingredient; with a nominal concentration  of 65.u%
        of the active ingredient.  One product is packaged
        in water soluble bags to reduce applicator exposure
        associated with  handling and applying  the product.

     Amount and Method of Application:  Application rates
        for 2-6 months control of weeds varies between
        0.325 and 1.5 Ibs. of active ingredient per acre,
        depending on the weeds to be controlled.  Maximum
        annual application rates varies between 0.5 and
        1.5 Ibs. of active ingredient per acre, per season;
        depending on the species of turf grass.   Ground
        spray application of aqueous suspensions  of the
        formulated product is the only method  of  application
        registered.

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                            -2-

   Carrier:   Water

3.  SCIENCE  FINDINGS

    Summary  Science Statements:

          Adequate toxicological, product  chemistry, ecological
      effects,  environmental fate and  ground water
      data have been submitted and reviewed to support the
      conditional registration of prodiamine for use as a
      preemergence  herbicide in the  culture of ornamental turf
      grasses and landscape ornamentals.  Technical prodiamine
      is classified as  a  Toxicity Category  III pesticide and  is
      labeled with  the  signal  word "CAUTION", based on a battery
      of 6 acute studies.

            Studies demonstrated that  prodiamine generally
      has a  negative mutagenic activity.  However, there
      was a  suggestive  activity in Salmonella strain TA 1538
      without activation  (Registrant claimed that material
      tested was from an  outdated manufacturing process)
      and in mouse  lymphoma cells without activation, but neg-
      ative  in  confirmatory testing.  Prodiamine was not a  develop-
      mental toxicant.  In a rat teratology study the developmental
      toxicity  NOEL was 300 mg/kg and  the LEL was 1,000 ing/kg
      based  on  the  total  number of fetuses/litter with malform-
      ations.  The  maternal toxicity NOEL was 300 mg/kg and the
      LEL was 1,000 mg/kg based on depressed body weight gain.
      In a rabbit teratology study there was no evidence of develop-
      mental toxicity at  500 mg/kg/day the  highest dose tested  (HDT).
      A two  gereration  reproduction  study in rats demonstrated
      a reproductive toxicity  NOEL of  200 ppm based on reduced pup
      weight and increased relative  liver weight at 2000 ppm.

          In a  rat  carcinogenicity study prodiamine at 3200 ppm  in
      the diet  increased  thyroid follicular cell neoplasia  in
      in both sexes. Positive dose-trends  in thyroid follicular
      cell adenomas and in combined  follicular cell tumors
      (adenomas and carcinomas) in both males and females
      were observed. In addition, a  statistically signific-
      ant positive  trend  in incidence  of pancreatic adenomas
      was observed  in female rats; although the dose trend  for
      the incidence of  carcinomoas and adenomas  (combined)  was
      not significant.

          In a  mouse carcinogenicity study  with prodiamine  there
      was found an  increase in subcutaneous fibrosarcomas  in  high
      level  male mice related  to fighting.

          Based on a "weight-of-evidence"  analysis, prodiamine
      was determined to be a Group C carcinogen.  EPA health  Effects
      Division's Peer Review Committee recommended  that a
      Reference Dose Approach  should be used  for quantification
      of risk to humans.

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                        -3-
     Prodiamine appears to be metabolized rapidly by
 dealkylation reactions to N,N-didespropyl metabolites.
 Cyclization also occurs to form N-propyl benzimidazole
 A and N-propyl benzimidazole B found in feces.  The
 N-propyl benzimidazoles were metabolized further via
 nitro-reciuction, N-dealkylation, and ring hydroxylation
 to form hydroxy-benzimidazoles found in urine.

     Acute toxicology studies with technical prodiamine
and the two end-use products containing 65.0% active
prodiamine demonstrated that prodiamine is of low
acute toxicity to mammals.

     A 13-week subchronic feeding study in rats demon-
strated that the lowest effect level in rats was 4000 ppm,
The effect was reduced body weight gain, increased
cholesterol and increased urinary protein content.

     Prodiamine is very water-insoluble and is not
hydrolyzable.  Absorption, leaching and run-off studies
indicate that movement in soil is unlikely.  Volatility
is not significant.  Prodiamine is stable to hydro-
lysis and moderately bound to sediment.  Data demonstrate
that prodiamine is rapidly degraded in water exposed
to natural sunlignt.

     An avian single dose oral LD$Q study with bobwhite
quail demonstrated that prodiamine is accutely non-toxic
to boowhite quail. The no-observed-effect dosage was
> 2250 mg/kg/day.  In eight day dietary studies with
mallard duck and bobwhite quail the 1*050 level was
> 10,000 mg/kg/day, the highest concentration fed.

     Prodiamine is not expected to pose a significant
acute hazard to freshwater organisms at its limit of
solubility in water (13 ppb).

     Chemical analysis of both the manufacturing-use
and the end-use products demonstrated that nitrosoamine
would not be expected to be present in these products
at levels of toxicological concern.

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                            -4-
Chemical Characteristics:

      Physical State:           Solid,  powered
      Color:  Chemically Pure:   Yellow-orange
             Technical tirade:   Yellow-orange
      Odor:                     Halide  odor
      helting Point:            122.5-124.O'C
      Density:                 1.4107  gin/ml  (typical)
      holecular Weight         350.3
      Empirical Formula
      Solubility        Solvent
      Parts per Million:  Water

      Grams per 100 ml:   Acetone
                         n-octanol
                         Dimethyl
                          foriuamide
                         Xylene
                         Isopropanol
                         Heptane
          0.013
at *C

 25' C
22.600
0.962
32.100
3.540
0.852
0.100
25'
25*
20'
20'
20*
20'
C
C
C
C
C
C
     Vapor Pressure:

     Dissociation Constant:
 2.5 x 10~8 mm/Hg at 25*C

Data waived because of low
water solubility.
     Octanol/Water Partition Coefficient:   P * 1.3 x 104

     pH:  (in non-aqueous solvent):   6.878  at 25*C

     Stability:   Thermally stable.   Moderately stable to
                 light.   Decomposes at 240 C

     Oxidizing or Reducing Action:   Slight oxidizing potential

     Explodability:  Non-explosive

     Storage Stability:   Stable for 84 days at 54"c and
                         168 days at 40 ,  and 1 year at
                         ambient temperature

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                            -b-



Toxicology Characteristics:

  Acute Toxicity  (  93.0%, Technical)

     Acute oral toxicity in  rats:  LD^Q  >  5000 rag/kg
          Toxicity Category  IV.

     Acute dermal toxicity  (rat):   LD$Q > 2,000 mg/kg  (M&F)
          Toxicity Category  III.

     Primary dermal  irritation (rabbit)i  Non-irritating  to
          skin of rabbits
          Toxicity Category  IV.

     Primary eye irritation  (rabbit): No cornea1 opacity;
          minimally  irritating to  eyes  of rabbits
          Toxicity Category  III.

     Acute inhalation toxicity (rat): LC50 > 0.256 mg/m3 for
          males and  females
          Toxicity Category  III.

     Dermal sensitization (guinea  pig): Not a dermal
          sensitizer.

  Acute Toxicity for Barracade* 65 WDG  Herbicide

     Acute oral toxicity (rats):   L&5Q  >  5000 mg/kg  (h&F)
          Toxicity Category  IV.

     Acute dermal toxicity  (rats):  No  deaths, LI>5o
          >2000 mg/Kg,  Category III.

     Primary dermal  irritation (rabbit):  Very slight erytheme
         in 1 of 6 rabbits
         Category IV.

     Primary eye irritation  (rabbit): 5/6 rabbits had  conjunctival
          redness and chemosis > score  1, but reaction
          vanished by 4th day.
          Category III.

     Acute inhalation toxicity (rat):   LCso > l.til mg/L  (M&F)
          Category III.

     Dermal sensitization (guinea  pig):   Positive for  dermal
          sensitization.

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                        -6-

 Subchronic and Chronic  Toxicity

     A 13-week feeding  study with  rats demonstrated
 a no observed effect level  (NOEL)  of 1200 ppm; a
 least  effect  level  (LEL) of 4000 ppm.  The observed
 effects seen  in both male and  females were a reduction
 of body weight gain and increased  cholesterol value.
 Increased urinary protein content  was seen only in
 males.
                                /

 In a rat developmental  toxicity study developmental
 effects (increased  incidence of omphalocele) were
 observed only at 300 mg/kg  (LEL).  The NOEL for this
 developmental effect was 100 mg/kg.  A maternal
 effect (depressed body  weight  gains) was also observed at
 at 1000 mg/kg (LEL).  The NOEL for this effect was 300 mg/kg.

 In a rabbit developmental toxicity study there were no develop-
 mental effects at 500 mg/kg/day (hDT).  A maternal effect
 (reduced body weight gain)  was observed at 300 mg/kg  (LEL)
 The NOEL for  this effect was 100 mg/kg/day.

 A 2-generation reproduction study  in the rat treated  with
 0, 50,  200, and 2,000 ppm prodiamine had a NOEL of 200 ppm
 (approximately 10 mg/Kg/day) based on reduced pup
 weight and increased relative  liver weight at 2,000 ppm.

 Mutagenicity

 The following mutagenicity  studies indicated that
 prodiamine is not generally mutagenic at doses tested:

 - Ames Assays for mutagenicity with TA1538 strain of
   Salmonella   were  found positive  for increased revert-
   ants in TA1538 at 5000 ug/plate  in the absence of activation.
   The  registrant states that the material tested was  from
   an outdated manufacturing process.

 - Ames Assays for mutagenicity with five tester
   strains of  Salmonella were negative for reverse gene mutation
   (his" to his'1') at 10,000  ug/plate with or without
   metabolic activation  up to 10,000 ug/plate with
   precipitation at  500  ug/plate and above.

-  Ames Assays for mutagenicity with Salmonella was negative
   at 0.3 - 100 vig/plate with or without metabolic activation.

-  A mutagenic-unscheduled DNA  synthesis  study demonstrated
   that prodiamine was non-matagenic.

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                            -6-
hechanism of Pesticidal Action;

     Prodiamine is a mitotic inhibitor of normal cell
division of susceptible plants.   The formation  and
function of microtubulin is inhibited.  Susceptible  plant
roots are stunted and fail to function in the presence
of prodiamine.  Plants do not grow and develop  through
their normal cycle of vegetative growth followed by
reproduction (flowering and seed setting;.   Susceptible
plants react to prodiamine in such a way as  to  be
less competitive.

Environmental Characteristics:
    Hydrolysis:    Prodiamine slowly hydrolyzes in the
        pH range of 5-9.  Mo significant degradation
        occurs after 30 days.  A hydrolysis study conducted
        at pH 5, 1 and 9 indicated that degradation by
        hydrolysis is greater than 6 months.

    Photodegradation:  The half-life of prodiamine is
        20 minutes in deionized water and 40 minutes
        in natural water.

    Aerobic Soil Metabolism:  The anerobic
        breakdown of prodiamine in soil is considerably
        more rapid than aerobic breakdown.  Different
        metabolites were observed for these conditions
        of metabolism.  The bound residue level was higher
        under anaerooic conditions.  Prodiamine had a
        half-life of 3^ days under anerobic conditions
        and 218  days under aerobic conditions.  The half-life
        of prodiamine under aerobic soil conditions is
        approximately 2 months.  The major soil degradate is
        6-amino-benzimidazole under aerobic soil conditions.

     Leaching:  Prodiamine or its degradates do not
        leach significantly.  Under field conditions
        prodiamine is immobile with regard to downward
        movement in soil.

     Runoff:  Runoff of prodiamine is unlikely to occur
        because  of its insolubility and immobility.

     Soil Adsorption/ Desorption:  Prodiamine is very
        strongly adsorbed to soil, more strongly than
        dinitramine.  Data demonstrate that prodiamine is
        extremely immobile.

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                            -7-

-  Mouse lynphoma foreward nutation assay with or without
   metabolic activation at concentrations of 0.5,
   1, 4, 6, 8, 10, 13. 16. 20,  and 50 ug/ml with
   activation was negative.  In a nonactivated study
   it was also negative at 1,  10, 40, 60, 80,  100,
   130, 160, 200 and 500 ug/ng.

     A 2-year feeding/oncogenic mouse study demonstrated
a significant increased incidence of subcutaneous fibro-
sarcoma in high dose Bales was related to fighting activity
caused by group caging.  Levels tested were 0, 50,  500,
and 5000 ppm (Ms 0, 6.2, 59.4  and 606.6 ug/kg/day;  F:
0, 6.8, 64.6 and 646.2 mg/kg/day).  Systemic effects
(reduced body weight gains and increased liver weight)
were observed at 5000 ppm (LEL).  The NOEL for this
effect was 500 ppm.

   A 2-year feeding/oncogenic rat study demonstrated
a significant increased incidence of follicular adenoma/
carcinoma in both males and females.  Levels tested were
0, 50, 200, 800 and 3200 ppm (M: 0, 1.8, 7.2 29.4,  and
115.2 mg/kg/day; Ft 0, 2.3 9.1, 37 and 151 mg/kg/day).
Systemic effects (increased liver weight and minor bio-
chemical disturbances) occurred at 800 ppm (LEL).  The
NOEL for this effect was 200 ppm.

    In a metabolism study with rats, prodiamine was absorbed
and readily eliminated after a single dose of 10 or 400
mg/kg of C^4-prodiamine or a single oral dose of 10 ing/kg
of the radioactive compound following 14 days of admin-
istration of 10 mg unlabeled prodiamine/kg/day.  All but
high-dose female rats had eliminated about 70% of the
C1* dose in the urine and feces within 24 hour (high-dose
females excreted about 38% of the dose).  Tissue radio-
activity levels were slightly higher in females than
those in males. C14 prodiamine and its metabolites did not
accumulate in the body to an appreciable extent.

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                               -10-


4.  Summary of Regulatory Postion and Rationale

    Available data provide adequate information to support
    the conditional registration of Barricade® T Herbicide,
    Barricade 65 WG Herbicide,  and Barricade 65 WG Herbicide
    in Water Soluble Packs,  that were first conditionally
    registered February 7, 1992  under Section 3 of the Federal
    Insecticide,  Fungicide and Rodenticide Act as amended.

    Use, Formulation, Manufacturing Process or
    Geographic Restrictions:
       o Aerial applications of prodiamine products are not  permitted.
         Probition against aerial applications must appear on labeling.
       o End-use products must bear the following precautions:
            "May cause an allergic skin reaction.  Wash thoroughly
             with soap and water after handling."
            "During mixing and loading wear chemical
             resistant gloves.   Wash non-disposable gloves
             thoroughly with soap and water before removing.
             Remove contaminated clothing and separately launder
             clothing before use.

       Conditional registration will expire on February 1, 1995.

5.  Summary of Data Requirements

   Toxicology Data:

      1.  Acute and 90-day neurotoxicity screening Battery
          in rats (EPA Guideline Numbers 81-S and 82-7) .
          Data are due February 1, 1994.

      3.  Study in rats to measure effects on TSH, T3
          and 14.
          Data are due April 1, 1993.

   Exposure Data:

      1. Worker Exposure Studies.  Reserved pending review
         of required toxicology data listed above.

      2. Reentry data: Subpart K (Foliar Dissipation (132-1),
         Soil Dissipation (132-2), Dermal Exposure (132-3),
         and Inhalation Exposure (132-4)).  Reserved pending
         review of required toxicology data listed above.

   Ecological Effects Data:

      1.  Avian Reproduction with a Waterfowl and Bobwhite
          guail,  EPA Ref. Guidelines 71-4.  Data are due
          May 1,  1994.

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                             -9-

Potential to Contaminate Ground Water:   The  low  solubility
     in water and its high tendency to  bind  to soil
     prevents prodiamine from being carried  downward
     through soil.  Prodiamine has a low potential for
     leaching into ground water.  Surface water  con-
     tamination from soil containing prodiamine  would
     be expected.

Ecological Characteristics

     Avian Studies:  Prodiamine is practically non-toxic
             to birds based on the following studies:

     Single Dose Acute Oral LD50:
             Bobwhite Quail with 96.3%  Technical:
                       > 2250 mg/Kg
     Eight Day Dietary Study:
             Mallard duck with 98.4 Technical:
                  LCso > 10,000 ppm
             Bobwhite quail with 98.4% Technical:
                       > 10,000 ppm
                          A study is required as  a condition
     Avian Reproduction:
       for registration.
Aquatic Organisms:   The following data indicate that
     prodiamine is  not toxic to freshwater fish and
     aquatic invertebrates:
Fish Acute Toxicity:
      Bluegill sunfish,
      Rainbow trout,
                             > 552.0 ppb
                          > 829.0 ppb

Freshwater Invertebrates:
      A 48-hour ECso in Daphnia was > 658 ppb

Honey Bee:
     Acute contact LDso > 10° ug/bee.

Endangered Species Hazards:

     Based on available data, the conditionally registered
     use-pattern of prodiamine is unlikely to pose a hazard to
     endangered aquatic and avian species.  There may
     be some hazard to endangered plant species from
     runoff and movement of the products from treated turf
     areas .

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                            -11-
   2.  Acute LC5Q Estuarine/Marine Organisms  Studies,
       EPA Ref.  Guidelines 72-3,  identified as:
        o 96-hour LCso for an estuarine marine fish
        o 96-hour LCso for a shrimp species
        o Either a 48-hour embryo larvae study or a
            96-hour shell deposition study with  oyster.
        Data are due February 1,  1993.

   3.  Fish Early Life Stage and Aquatic Invertebrate  Life-
       Cycle Studies,  EPA Ref. Guidelines 72-4.
       Data are  due May 1, 1993.

   4.  Target Area: Phytotoxicity (if end-use product  is
                    aerially applied).
       Tier II:   o Seed Germination/Seedling  Emergence,
                   10 species, EPA Ref. Guideline 123-1
                 o Vegetative vigor,  10 species, EPA Ref.  Guideline
                   123-1
                 o Aquatic plant growth (5 species), EPA Ref.  Guide-
                   lines 123-2

       Tier III: o Terrestrial Field1,  EPA Ref.  Guidelines
                   124-1
                 o Aquatic field2, EPA Ref. Guidelines 124-2

                    I/ Required if a 25 percent  or greater
                       detrimental effect was found in 1 or more
                       plant species in corresponding  test of
                       previous tier.
                    2/ Required if a 25 percent  or greater
                       detrimental effect was found on any
                       plant species in the corresponding  test
                       of the previous tier.
       Data are  due at the time of application to amend
         any registration of prodiamine to allow aerial
         application.

Environmental Fate and Ground Water Data:

    1.  Prodiamine Aged-Leaching Study, EPA Ref. Guide-
        lines 163-1.  Data are due June 31, 1992.

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6. Contact Person at £PA

      Joanne I. iniller
      Product Manager 23
      Fungiciae-Herbiciae Branch
      Registation Division (H-7505CJ
      Office of Pesticide Programs
      Environmental Protection Agency
      401 M Street SW
      Washington, DC  204oO

   Office Location and Telephone Number

      Room 237, Crystal Mall Building 12
      1921 Jefferson Davis Highway
      Arlington, VA  22202
      (703) 305-7630

   DISCLAIMER:  The information presented in this Pesticide Fact
   Sheet is for informational purposes only and may not be used
   to fulfill data requirements for pesticide registration and
   reregistration.

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