820K89
101
                                      DALAPON

                                  Health  Advisory           -«•
                              Office  of Drinking Water       r  *
                        U.S.  Environmental  Protection Agency~_
I. INTRODUCTION
                                                                  -re
        The Health  Advisory  (HA)  Program,  sponsored  by  the  Office of  Breaking
   Water (ODW), provides  information on  the health effects,  analytical aethod-
   ology and treatment technology that would be useful  in dealing with tehe
   contamination of drinking water.   Health Advisories  describe  nonregulatory
   concentrations of drinking water  contaminants at  which adverse health effects
   would not be anticipated  to  occur over  specific exposure  durations* ^Health
   Advisories contain a margin  of safety to protect  sensitive  members ^ofi the
   population.                                                       .-. (r
                                                                 :  -f dŁ
        Health Advisories serve as informal technical guidance to assist Federal,
   State and local  officials responsible for protecting public health -wjten
   emergency spills or contamination situations occur.   They are not  torbe
   construed as legally enforceable  Federal standards.   The  HAs  are subject to
   change as new information becomes available.                   -    ^rr

        Health Advisories are developed  for one-day, ten-day,  long-er-tefcm
   (approximately 7 years, or 10% of an  individual's lifetime) and 1-ifeftime
   exposures based  on data describing noncarcinogenic end points of tojfeicity.
   Health Advisories do not  quantitatively incorporate  any potential  carcinogenic
   risk from such exposure.   For  those substances that  are known ojr probable
   human carcinogens, according to the Agency classification schenfe  fcGr<5up A or
   B), Lifetime HAs are not  recommended.  The chemical  concentration  values for
   Group A or B carcinogens  are correlated with carcinogenic'risk estimates by
   employing a cancer potency (unit  risk)  value together with  assumptions for
   lifetime exposure and  the consumption of drinking water.  The cancer unit
   risk is usually  derived from the  linear multistage model  with 95%  upper
   confidence limits.  This  provides a low-dose estimate of  cancer risk to
   humans that is considered unlikely to pose a carcinogenic risk, im.easess
   of the stated values.   Excess  cancer  risk estimates  may  also  be calculated
   using the One-hit, Weibull,  Logit or  Probit models.   There  Is no atiEcent
   understanding of the biological mechanisms involved  in cancer to suggest that
   any one of these models is able to predict risk more accurately than another.
   Because each model is  based  on differing assumptions, the estimatesEthat are
   derived can differ by  several  orders  of magnitude.
                                                                -c

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    Dalapon




II. GENERAL INFORMATION AND PROPERTIES

    CAS No.  75-99-0

    Structural Formula
                            August, 1987
-2-
                                 CH,CCI2COOH
                             (2,2-Dichloropropionic  acid)
    Synonyms
            Dalapon (ANSI,  BSI, WSSA), DPA,  Basfapon and Basfapon B  (discontinued
            by BASF Wyandotte); Basfapon/Basfapon N, BH Dalapon and Crisapon
            (Crystal Chemical  Inter-America);  Dalapon  85, Dalapon-Na, Ded-Weed
            and Devipon (Devidayal); Dowpon, Dowpon M, Gramevin and Radapon  (discon-
            tinued by Dow);  Revenge  (Hopkins);  Unipon  (Heister, 1984).
    Uses
         9  Dalapon (2,2-dichloropropionic  acid)  is  used  as a herbicide  in  the
            form of its sodium  and/or  magnesium salts  to  control grasses in crops,'
            drainage ditches, along  railroads and in industrial areas  (U.S. EPA,
            1984).

    Properties  (U.S. EPA,  1984)
            Chemical Formula
            Molecular Weight
            Physical State (room temp.)
            Boiling Point
            Melting Point
            Density (°C)
            Vapor Pressure
            Specific Gravity
            Water Solubility (25°C)
            Log Octanol/Water Partition
              Coefficient
            Taste Threshold
            Odor Threshold
            Conversion Factor
    Occurrence
   C3H4C1202
   143  (acid form)
   liquid
   185  to 190°C
   20°C
    >800 mg/L
            Dalapon has been found in none of the surface water  or ground water
            samples analyzed from 14 samples taken at 14 locations (STORET,  1987)

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Dalapon                                                          August, 1987

                                     -3-


Environmental Fate

     0  The sodium salt of  dalapon has been shown to hydrolize slowly in
        water to produce pyruvic acid, and the rate of hydrolysis increases
        with increasing temperature.   After 175 hours, the extent of hydrolysis
        at 25°C for 1%, 5%  and 18% dalapon solutions was 0.41%,  0.61% and 0.8%,
        respectively (Brust,  1953).

     0  Hydrolysis of solutions of either dalapon or dalapon sodium salt is
        accelerated at alkaline pH values.  For example, hydrolysis of dalapon
        sodium salt at 60°C was 20% complete in 30 hours at which time the
        equilibrium pH was  2.3.  In contrast,  hydrolysis was 50% complete
        in 30 hours when the pH was maintained at 12 during the  experiment
        (Tracey and Bellinger, 1958).

     0  Based on reaction rate studies,  Kenaga (1974) concluded  that both
        dalapon salt and dalapon would have chemical hydrolysis  half-lives of
        several months at temperatures less than 25°C and at initial solution
        concentrations of less than 1%.   Considering the more rapid rate of
        microbial degradation, those authors concluded that it does not appear
        that chemical hydrolysis of dalapon is a particularly significant
        degradative pathway in soils.

     0  Because of its high water solubility and lack of affinity for soil
        particles, appreciable adsorption of dalapon on suspended or bottom
        sediments is not expected in natural waters.  Chemical degradation
        and volatilization  probably occur too slowly to account  for substantial
        loss of dalapon from water.  Aquarium studies conducted  by Smith et al.
        (1972) provide evidence that volatility is not a route for significant
        loss of dalapon from water.

     0  Microbial degradation is by far  the most important process affecting
        the fate of dalapon in soil.   Other processes which are  of lesser
        importance are adsorption, leaching and runoff, chemical degradation
        and volatilization.  Based on the light absorption characteristics of
        aqueous solutions of sodium salts of dalapon, it has been concluded
        that photodecomposition of dalapon in field applications is improbable
        (Kearney et al., 1965).

     0  Although dalapon is subject to hydrolysis under field conditions,
        chemical degradation is considered to be very slow and is unlikely
        to be an important  factor in the dissipation of dalapon  from soil.
        Smith et al. (1957) and Brust (1953) demonstrated that dalapon and
        its sodium salt can undergo hydrolysis to pyruvate and HC1.

     0  Although the laboratory studies  indicate that dalapon is a highly
        mobile compound (Warren,  1954; Helling,  1971; Kenaga,  1974)  and should
        be readily leachable from soils,  field data show that under many
        practical conditions dalapon does not move beyond the first six-inch
        depth of soil.   This is probably because microbial action proceeds at
        a faster rate than  leaching under favorable conditions (Kenaga,  1974).

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     Dalapon                                                          August,  1987

                                          -4-


          *  The microbia]  degradation of  dalapon  in  soil  has  been  well  established<
             Thiegs (1955)  compared  the rates of degradation of dalapon  in  autoclaved
             and non-autoclaved  soils.  The concentration  of dalapon  (59 ppm)  in
             the autoclaved soil did not change after incubation  at 100°F for  1 week
             while in the unsterilized soil, dalapon  disappeared  in 4  to 5  weeks
             after one application and in  1 week after the second application  of
             50 ppm.   Based on the observations that  dalapon decomposition  is
             adversely affected  by low soil moisture,  low  pH,  temperatures  below
             20° to 25°C, and large  additions of organic matter,  Holstun and
             Loomis (1956)  concluded that  dalapon  degradation  was a function of
             microbiological activity.


III. PHARMACOKINETICS

     Absorption

          0  In both dogs and humans, orally administered  dalapon is  quickly excreted
             in the urine.   Dogs administered a single oral dose  of 500  mg/kg
             dalapon sodium salt excreted  65 to 70% of the administered  dose in
             48 hours (Hoerger,  1969).  In a 60-day feeding study,  dogs  receiving
             50 and 100 mg/kg of dalapon sodium salt  excreted  25  to 53%  of  the
             administered dose in  the urine  (Hoerger, 1969).  'Human subjects
             consuming five successive daily oral  doses of 0.5 mg of  dalapon
             sodium salt excreted  approximately 50% of the administered  dose over
             an 18-day period  (Hoerger, 1969).  These data suggest  that  dalapon
             is well absorbed from the gastrointestinal tract.

     Distribution

          0  Chronic oral administration of dalapon did not result  in significant
             bioaccumulation in  either rats or dogs (Paynter et al.,  1960). In both
             rats and dogs, the  highest levels of  dalapon  were found  in  the kidneys,
             followed by the muscle and the fat  (Paynter et al.,  1960).

     Metabolism

          0  Although inadequate data are  available to characterize dalapon
             metabolism in  humans,  data in cattle  (Redemann and Hanaker, 1959)
             suggest that dechlorination may be involved in the metabolism  of
             dalapon.
     Excretion
             Available information suga^sts that at least 50% of orally admini-
             stered dalapon is eliminated  via the kidneys in dogs and humans
             {Hoerger, 1969).

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    Dalapon                                                          August,  1987

                                         -5-


IV. HEALTH EFFECTS

    Humans

       Short-term Exposure

         0  No information on the short-term  health effects of dalapon in humans
            was found in the available literature.

       Long-term Exposure

         0  No information on the long-term health  effects of dalapon in humans
            was found in the available literature.

    Animals^

       Short-term Exposure

         0  The sodium salt of dalapon is relatively nontoxic, with an oral V^Q
            ranging from 3,860 mg/kg in the  female  rabbit to 7,570 mg/kg in the
            female rat (Paynter et al., 1960).

       Dermal/Ocular Effects

         0  Concentrated .sodium dalapon solutions have been found to be irritating
            to the skin and eyes of rabbits  (Paynter et al., 1960).

       Long-term Exposure

         0  In a 90-day dietary study by Paynter et al. (1960), male and female
            rats were exposed to sodium dalapon (65% pure) at levels of 0, 11.5,
            34.6, 115, 346 or 1,150 mg/kg/day.   Increases in kidney and liver
            weight were observed in both sexes  at 346 and 1,150 mg/kg/day.  The
            No-Observed-Adverse-Effect-Level  (NOAEL) in this study was identified
            as 11.5 mg/kg/day base! on increases in kidney weight at higher
            doses.  (See discussion under Longer-term Health Advisory below.)

         0  In a 1-year study, sodium dalapon (65%  pure) was administered to
            dogs by capsule at level's of 0,  15,  50  or 100 mg/kg/day.  Based on
            increases in kidney weight at 100 mg/kg/day, the NOAEL was identified
            as 50 mg/kg/day (Paynter et a.'.,  1960).

         0  With the exception of an increase in kidney weight in male rats,
            sodium dalapon (65% pure) was without effrt,-;t in a 2-year dietary study
            (Paynter et al., 1960); the NOAEL in this study was 15 mg/kg/day.
            (See discussion under Longer-tern Health Advisory below.)

       Reproductive Effects

         0  Administered in the diet, sodium  dalapon (65% pure) had no effects on
            reproduction in the rat at dose levels  of approximately 30, 100 or
            300 mg/kg/day (Paynter et al.,  1960).

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   Dalapon                                                           August,  1987

                                        -6-


      Developmental  Effects

        0   Sodium  dalapon  (purity  not  specified) was  not  teratogenic in the rat
           at doses  as  high  as  2,000 mg/kg/day  (Emerson et al.,  1971;  Thompson
           et al.,  1971).   (See Ten-day  Health  Advisory below.)

      Mutagenicity

        0   Dalapon was  not mutagenic in  a  variety  of  organisms  including Salmonella
           typhimurium, Escherichia coli,  T4 bacteriophage, Streptomyces coelicolor
           and Aspergillus nidulans (U.S.  EPA,  1984).  Although Kurinnyi et al.
           (1982)  reported that dalapon  increased  chromosome aberrations in mice,
           the inadequate  technical detail presented  precluded  an evaluation of
           this study.

      Carcinogenicity

        0   No evidence  of  a  carcinogenic response  was observed  in a 2-year
           chronic feeding study in which  sodium dalapon  (65% pure) was
           administered to rats at levels  as high  as  50 mg/kg/day for a period
           of 2 years (Paynter  et al., 1960).


V. QUANTIFICATION  OF TOXICOLOGICAL EFFECTS

        Health Advisories  (HAs) are generally determined  for one-day,  ten-day,
   longer-term (approximately 7 years) and lifetime exposures if adequate data
   are available that identify  a sensitive noncarcinogenic end point of toxicity.
   The HAs for noncarcinogenic  toxicants are derived  using the following formula:
                 HA = .(NOAEL or LOAEL) x (BW) = 	   /L (	   /L,
                        (UF) x (	 L/day)

   where:

           NOAEL or LOAEL = No- or Lowest-Observed-Adverse-Effect-Level
                            in mg/kg bw/day.

                       BW = assumed body weight of a child  (10 kg) or
                            an adult (70 kg).

                       UF = uncertainty factor (10, 100 or  1,000), in
                            accordance with NAS/ODW guidelines.

                	 L/day = assumed daily water consumption of a child
                            (1 L/day) or an adult  (2 L/day).

   One-day Health Advisory

        No data were found in the available literature that were suitable for
   determination of the One-day HA value for dalapon.  It is, therefore,
   recommended that the Ten-day HA value for a 10-kg child  (4.3 mg/L, calculated
   below) be used at this time as. a conservative estimate of the One-day HA value.

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Dalapon                                                          August, 1987

                                     -7-


Ten-day Health Advisory

     The rat teratology study by Emerson et al.  (1971) has been selected to
serve as the basis for determination of the Ten-day HA for a 1 0-kg child.
In this study, sodium dalapon (purity not specified;  assumed to be 100%) was
orally administered to pregnant rats over a 10-day period (days 6 through
15 of gestation) at doses of 0, 500, 1,000 or 1,500 mg/kg/day.   Although no
compound-related teratogenic response was seen,  there was a decreased in
weight gain in the dams at the lowest level tested, 500 mg/kg/day.  Decreased
weight gain was also observed in the pups, but only at higher levels (1,000
and 1,500 mg/kg/day).  Standards for dalapon are commonly expressed in terms
of the acid rather than the salt.   Thus, it is necessary to convert the LOAEL
for the sodium salt, 500 mg/kg/day, to the equivalent value for the acid.

    The LOAEL for dalapon as acid  = (500 mg/kg/day) (143) = 430 mg/kg/day
                                             1 65

where:

        500 mg/kg/day = LOAEL for sodium dalapon.

                  143 = molecular weight of dalapon as acid in g/MWt.

                  1 65 = molecular weight sodium dalapon in g/MWt.

     The Ten-day HA for a 10-kg child is calculated as follows:

         Ten-day HA = (430 mg/kg/day) (10 kg) z 4.3   /: (4 300   /L)
                         (1,000) (1 L/day)

where:

        430 mg/kg/day = LOAEL for dalapon as acid based on body weight
                        decreases  in dams.

                10 kg = assumed body weight of a child.

                1,000 = uncertainty factor, chosen in accordance with NAS/ODW
                        guidelines for use with a LOAEL from an animal study.

              1 L/day = assumed daily water consumption of a child.

Longer-term Health Advisory

     The results of Paynter et al.  (1960) suggest that the subchronic and
chronic toxicity of dalapon are much the same.  Specifically,  in a 97-day rat
subchronic dietary study, sodium dalapon (65% sodium  dalapon;  16% sodium salts
of related chloropropionic acids;  2% sodium pyruvate;  5% sodium chloride; 5%
water; 7% undetermined) produced an increase in kidney weight in female rats
at 34.6 mg/kg/day and higher exposure levels but not at 11.5 mg/kg/day (NOAEL).
Similarly, in a two-year rat chronic dietary study, sodium dalapon exposure
(65% pure) resulted in an increase in male kidney weight at 50  mg/kg/day but
not at 15 mg/kg/day (NOAEL).  Considering both Paynter et al.  (1960) rat

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Dalapon                                                          August, 1987
                                                                    I
                                     -8-


dietary studies together,  the 15 mg/kg/day NOAEL for sodium dalapon is
appropriate to calculate both a Longer-term HA and a Lifetime HA.

     It is customary to express dalapon standards in terms of the acid rather
than the salt.  The NOAEL used to derive the Longer-term HA is based on
studies (Paynter et al., 1960) in which rats were exposed to sodium dalapon
that was 65% pure.  Thus,  a NOAEL for dalapon as the pure acid must be
calculated:

The NOAEL for dalapon as pure acid = (15 mg/kg/day) (0.65) (143) , g mg/kg/day
                                                 165

where:

        15 mg/kg/day « NOAEL for 65% pure sodium dalapon.

                0.65 » purity of sodium dalapon used in determining NOAEL.

                  143 = molecular weight of dalapon as acid.

                  165 - molecular weight of sodium dalapon.

     The Longer-term HA for a 1 0-kg child is calculated as follows:

              Longer-term HA = (8 mg/kg/day ) (10 kg) = 0.8 mg/L  (800 Ug/L )
                                  (100) (1 L/day)

where:

         8 mg/kg/day = NOAEL based  on kidney weight increases in male rats.

                1 0 kg =  assumed body weight of a child.

                  1 00 =  uncertainty  factor, chosen  in accordance  with NAS/ODW
                        guidelines for use with  a NOAEL from  animal  study.

              1  L/day =  assumed daily water consumption of  a  child.

      The Longer-term HA for  a  70-kg adult is calculated as follows:
         Lor jer-term  HA  =  (8  "»g/*g/day)  (70 kg)  ,  2.8 mg/L  (2,800 ug/L)
                             (100)  (2 L/day)

 where all factors  are the  same  except:

                70  kg =  assumed  body weight of an  adult.

              2 L/day =  assumed  daily water consumption of  an  adult.

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Dalapon                                                          August, 1987

                                     -9-


Lifetime Health Advisory

     The Lifetime HA represents that portion of an individual's total exposure
that is attributed to drinking water and is considered protective of noncar-
cinogenic adverse health effects over a lifetime exposure.  The Lifetime HA
is derived in a three-step process.  Step 1 determines the Reference Dose
(RfD), formerly called the Acceptable Daily Intake (ADI).  The RfD is an esti-
mate of a daily exposure to the human population that is likely to be without
appreciable risk of deleterious effects over a lifetime, and is derived from
the NOAEL (or LOAEL), identified from a chronic (or subchronic) study, divided
by an uncertainty factor(s).  From the RfD, a Drinking Water Equivalent Level
(DWEL) can be determined (Step 2).  A DWEL is a medium-specific (i.e., drinking
water) lifetime exposure level, assuming 100% exposure from that medium, at
which adverse, noncarcinogenic health effects would not be expected to occur.
The DWEL is derived from the multiplication of the RfD by the assumed body
weight of an adult and divided by the assumed daily water consumption of an
adult.  The Lifetime HA is determined in Step 3 by factoring in other sources
of exposure, the relative source contribution (RSC).  The RSC from drinking
water is based on actual exposure data or,  if data are not available, a
value of 20% is assumed for synthetic organic chemicals and a value of 10%
is assumed for inorganic chemicals.  If the contaminant is classified as a
Group A or B carcinogen, according to the Agency's classification scheme of
carcinogenic potential (U.S. EPA, 1986a), then caution should be exercised in
assessing the risks associated with lifetime exposure to this chemical.

     The data used to determine the Lifetime HA are identical to those used
to determine the Longer-term HA.  Using the NOAEL of 8 mg/kg/day from the
2-year rat study by Paynter et al. (1960),  the Lifetime HA for the 70-kg
adult is calculated as follows:

Step 1:  Determination of the Reference Dose (RfD)

                     RfD =  (8 mg/kgydav) = 08   /L (2>800   /L,
                         (2 L/day)

where:

        0.08 mg/kg/day = RfD.

                 70 kg = assumed body weight of  an adult.

               2 L/day = assumed daily water consumption of an adult.

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      Dalapon                                                          August, 1987

                                           -10-


      Step 3:  Determination of the Lifetime Health Advisory

                  Lifetime HA » (2.8 mg/L) (20%) - 0.56 mg/L (560 ug/L)

      where:

              2.8 mg/L = DWEL.

                   20% = assumed relative source contribution from water.

      Evaluation of Carcinogenic Potential

           8   No evidence of carcinogenicity was found in a 2-year dietary study in
              which sodium dalapon was administered to rats at levels as high as
              50 mg/kg/day (Paynter et al.,  1960).

           8   Applying the criteria described in EPA's guidelines for assessment
              of carcinogenic risk (U.S.  EPA, 1986a),  dalapon may be classified
              in Group D:  not classified.  This group is for substances with
              inadequate human and animal evidence of  carcinogenicity.


  VI. OTHER CRITERIA, GUIDANCE AND STANDARDS

              The American Conference of  Governmental  Industrial Hygienists suggests ^^
              a Threshold Limit Value (TLV)  of 1 ppm (6 mg/m3)  as a time-weighted    ^r
              average for an 8-hour work  day.

           8   Tolerances have been established for dalapon in a wide variety of
              agricultural commodities (CFR, 1985) ranging from 0.1 ppm in milk to
              75 ppm in flaxseed.


 VII. ANALYTICAL METHODS

           0   Analysis of dalapon is by a gas chromatographic (GC) method applicable
              to the determination of certain chlorinated acid pesticides in water
              samples (U.S. EPA, 1986b).   In this method, approximately 1 liter of
              sample is acidified.  The compounds are  extracted with ethyl ether
              using a separatory funnel.   The derivatives are hydrolyzed with
              potassium hydroxide, and extraneous organic material is removed by a
              solvent wash.  After acidification, the  acids are extracted and
              converted to their methyl esters using diazomethane as the derivatizing
              agent.  Excess reagent is removed, and the esters are determined by
              electron-capture GC.  The method detection limit has not been determined
              for this compound.


VIII. TREATMENT TECHNOLOGIES

           0   No information on treatment technologies capable of effectively
              removing dalapon from contaminated water was found in the available
              literature.

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    Dalapon                                                          August, 1987

                                         -11-


IX. REFERENCES

    Brust,  H.   1953.   Hydrolysis of dalapon sodium salt solutions.  E.G. Britton
         Research Laboratory,  The Dow Chemical Co., Midland, MI.  November 4,
         1953.  Cited in Kenaga, 1974.

    CFR.  1985.   Code of Federal Regulations.  40 CFR 180.150.

    Emerson,  J.L.,  D.J.  Thompson and C.G.  Gerbig.  1971.  Results of teratological
         studies in rats treated orally with 2,2-dichloropropionic acid  (dalapon)
         during  organogenesis.  Report HH-417, Human Health Research and Develop-
         ment Laboratories,  The Dow Chemical Co., Zionsville, IN  (cited in
         Kenaga, 1974).

    Helling,  C.S.  1971.  Pesticide mobility in soils, I, II, III.  Proc. Soil
         Sci.  Soc.  Amer.  35:732-748.

    Hoerger,  F.   1969.   The  metabolism of  dalapon.  Blood absorption and urinary
         excretion patterns  in dogs and human subjects.  Unpublished report.
         Dow Chemical Company (cited in Kenaga, 1974).

    Holston,  J.T.,  and W.E.  Loomis.  1956.  Leaching and decomposition of
         2,2-dichloropropionic acid in several Iowa soils.  Weeds.  4:205-217.

    Kearney,  P.C.,  et al.  1965.  Behavior and fate of chlorinated aliphatic
         acids in soils.  Adv. Pest. Control Res.  6:1-30.

    Kenaga, E.E.  1974.   Toxicological and residue data useful in the environ-
         mental  safety evaluation of dalapon.  Residue Rev.  53:109-151.

    Kurinnyi,  A.I., M.A. Pilinskaya, I.V.  German and T.S. L'vova.  1982.  Imple-
         mentation of a  program of cytogenic study of pesticides:  Preliminary
         evaluation of cytogenic activity  and potential mutagenic hazard of 24
         pesticides.   Tsitologiya i Genetika.  16:45-49.

    Meister,  R., ed.   1984.   Farm chemicals handbook.  Willoughby, OH:  Meister
         Publishing Co.

    Paynter,  O.E.,  T.W.  Tusing,  D.D.' McCollister and V.K. Rowe.   1960.  Toxicology
         of dalapon sodium (2,2—dichloropropionic acid, sodium salt).  Agr. Food
         Chem.  8:47-51.

    Redemann,  C.T., and  J.W.  Hanaker.  1959.  The lactic secretion of metabolic
         products of ingested sodium 2,2-dichloropropionate by the dairy cow.
         Agricultural Research,  the Dow Chemical Company.  Seal Beach, CA (cited
         in Kenaga, 1974).

    Smith,  G.N., M.E. Getzendaner and A.H. Kutschinski.  1957.  Determination of
         2,2-dichloropropionic acid (dalapon) in sugar cane.  J. Agr. Food Chem.
         5:675.   Cited in Kenaga, 1974.

    Smith,  G.N., Y.S. Taylor  and B.S. Watson.  1972.   Ecological studies on dalapon
         (2,2-dichloropropionic acid).  Unpublished report NBE-16.  Chemical
         Biology Res., The Dow Chemical Co., Midland, MI (cited in Kenaga, 1974).

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Dalapon                                                          August, 1987

                                     -12-


STORET.  1987.

Thiegs, B.J.  1955.  The stability of dalapon in soils.  Down to Earth, Fall
     issue.  Cited in Kenaga, 1974.

Thompson, D.J., C.G. Gerbig and J.L. Emerson.  1971.  Results of tolerance
     study of 2,2-dichloropropionic acid (dalapon) in pregnant rats.
     Unpublished report HH-393.  Human Research and Development Center, Dow
     Chemical Company (cited in Kenaga, 1974).

Tracey, W.J., and R.R. Bellinger, Jr.  1958.  Hydrolysis of sodium 2,2-dichloro-
     ropionate in water solution.  Midland Division, The Dow Chemical Co.,
     Midland, MI (cited in Kenaga, 1974).

U.S. EPA.  1984.  U.S. Environmental Protection Agency.  Draft health and
     environmental effects profile for dalapon.  Environmental Criteria and
     Assessment Office, Cincinnati, OH.

U.S. EPA.  1986a.  U.S. Environmental Protection Agency.  Guidelines for
     carcinogen risk assessment.  Fed. Reg.  51(185)s33992-34003.  September 24.

U.S. EPA.  1986b.  U.S. Environmental Protection Agency.  U.S. EPA Method #3 -
     Determination of chlorinated acids in ground water by GC/ECD, January
     1986 draft.  Available from U.S. EPA's Environmental Monitoring and
     Support Laboratory, Cincinnati, OH.

Warren, G.F.  1954.  Rate of leaching and breakdown of several herbicides
     in different soils.  NC Weed Control Conf. Proc., 11th Ann. Meeting,
     Fargo, ND  {cited in Kenaga, 1974).

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