United States Environmental Protection Agency Office of Pesticides and Toxic Substances Office of Pesticide Programs (TS-767C) Washington, DC 20460 54Q/FS-89-D31 &EPA Pesticide Fact Sheet Name Of Chemical: 2-(2-Methyl-4-chlorophenoxy)propionic acid and its salts and esters for ISSUanCe: Registration Standard Date ISSUed: December 1988 Fact Sheet Number: 192 DESCRIPTION OF CHEMICAL Chemical Names: ANSI Common Names 2-(2-Methyl-4-chlorophenoxy)propionic acid; potassium 2-(2-methyl-4-chlorophenoxy)- propionate; diethanolamine 2-(2-methyl-4- chlorophenoxy)-propionate; dimethylamine 2-(2-methyl-4- chlorophenoxy)-propionate; isooctyl 2-(2-methyl-4-chlorophenoxy)- propionate MCPP (includes MCPP acid as well as the MCPP potassium salt; MCPP diethanolamine salt; MCPP dimethylamine salt; and MCPP isooctyl ester) ------- Other Common Names: Principal Trade Names: EPA (Shaughnessy) Code: Chemical Abstracts Service (CAS) Number: Year of Initial Registration: Pesticide Type(s): Chemical Family: U.S. and Foreign Producers: Mecoprop MCPP and Mecoprop 031501 (acid); 031503 (potassium salt); 031516 (diethanolamine salt); 031519 (dimethylamine salt), 031563 (isooctyl ester). 7085-19-0 (acid) 1929-86-8 (potassium salt) 1432-14-0 (diethanolamine salt) 32351-70-5 (dimethylamine salt) 28473-03-2 (isooctyl ester) 1964 (potassium salt) Herbicide; postemergence Chlorinated phenoxy Aceto Chemical Co., Inc.; Akzo Zout Chemie Nederland; Dow Chemical USA; Gilmore, Inc.; A.H. Marks Co., Ltd.; Rhone-Poulenc Ag Co. USE PATTERNS AND FORMULATIONS Registered Uses: Principle'' Uses: Formulations: Terrestrial nonfood crop - Golf courses, lawns, ornamental and sports turf, wide area general indoor/outdoor treatments. Aquatic nonfood crop - Drainage ditch banks. Forest trees - site preparation. Ninety-six percent of the production is used on turf, including lawns, sport turf and commercial sod production. A small percentage (1-4%) is used in noncrop areas such as rights-of-way, drainage ditch banks and forest site preparation. Granular, wettable powder, emulsifiable concentrate, soluble concentrate/liquid, pressurized liquid. ------- Methods of Application: Foliar applications by ground equipment including spreader, sprayer, pressure on hose-end sprayer and pressurized containers. Application by air on specific noncropland sites. SCIENCE FINDINGS Summary Science Statement: Virtually all data reviewed were on MCPP acid. Data are needed for the ester and each salt, with the exception of the potassium salt, for which the data on the acid will suffice, before the Agency can completely assess the effects the forms of MCPP pesticides to organisms and the environment. The Agency's Office of Pesticide Programs (OPP) has classified MCPP as a teratogen, based upon results of a study in rats. Margins of safety may not be adequate for some workers; additional data are required to refine estimates of worker exposure. A decision on the need for further regulatory action will be made when these data have been submitted and evaluated. MCPP is stable to hydrolysis, had slow photodegradation in water, and was very mobile in sand, sandy loam, silt loam, and silty clay loam soils. The submission of data are required for terrestrial nonfood and aquatic nonfood uses for all type formulations. Freshwater fish toxicity data on MCPP acid is incomplete, with a rainbow trout study that revealed very low acute toxicity of MCPP acid of 124 ppm. There were no acceptable acute freshwater aquatic invertebrate data submitted. There were no acceptable data for toxicity of any MCPP-formulations to nontarget plants, endangered species, or nontarget insects. It is possible that chlorinated dibenzo-p-dioxins or dibenzofurans aay be formed during the manufacture of MCPP. It is also possible that nitrosamines may be formed during the manufacture or storage of the MCPP amine salts. Thus, manufacturing process information is required to assess the possibility of the formation of these contaminants. ------- Chemica1 Characteri s t i c s Physical state: Color: Odor: Molecular Weight: Empirical Formula: Boiling Point: Vapor Pressure: Melting Point: Density, bulk: Solubility: Crystalline solid White to light brown Odorless 214. 7 ClOHllcl°3 Decomposes 1.4 x 10-5 Hg at 30°C 94°-95°C 0.6g/ml, dry uncompacted 0.06% in water at 20°C; readily soluble in alcohol, benzene, acetone, chlorinated hydrocarbons before reaching boiling mm Hg at 20°C; 4.7 x 10" oint mm Toxicology Characteristics Acute Toxicity Acute Oral: Acute Dermal: Acute Inhalation: Primary Dermal Irritation: Primary Eye Irritation: 558 mg/kg Toxicity Category* III Not lethal to rabbits at 2 g/kg Data gap No dermal irritation in rabbits exposed for 24 hours to abraded and unabraded skin Produces persistent corneal opacities, iritis, and conjunctival III IV irritation in both and unwashed eyes. Data gap. washed Dermal Sensitization: *For a--description of Toxicity categories, see 40 CFR 156.10 Delayed Neurotoxicitv: Data are not available. Testing is not required because MCPP and its derivatives and metabolites are not organophosphates or cholinesterase inhibitors. Subchronic Toxicity; Oral exposure of rats to technical MCPP caused increased creatinine levels in females and decreased glucose levels in males at 27 mg/kg; increased relative kidney weights in both sexes at 9 mg/kg and 27 mg/kg, respectively. The NOEL was 3 mg/kg. ------- Chronic Studies Chronic toxicity; No data are available and none are required because this pesticide does not have food uses. Oncoaenicity; There were no data available nor are any required. Teratogenicitv & Developmental Toxicitv: In a rat study, oral exposure to 125 mg/kq of MCPP on days 6-15 of gestation caused increased intra-uterine deaths, decreased crown/rump lengths, and an increased incidence of delayed or absent ossification of the sternebrae. The NOEL was 50 mg/kg/day. MCPP was not teratogenic in rabbits. A reproductive toxicity study is not required. Mutaaenicity Gene Mutations. In a spot test, no increases in reverse mutations in 4 strains of Salmonella were seen with or without metabolic activati'on and no forward mutations to streptomycin resistance were seen in S.CQelicolor A3(2) in spot or standard plates, with or without activation. Other Tests. MCPP caused an increase in sister chromatid exchange after single oral doses of 470 and 3800 mg/kg in Chinese Hamsters. Additional data are required. Major Route of Exposure; Dermal. Physiological and Biochemical Characteristics MCPP is absorbed through leaves and roots and is trans- located. It stimulates nucleic acid and protein synthesis and affects the efficacy of enzymes, either stimulating or inhibiting cell division. Environmental Characteristics Absorption and Leaching: Unaged MCPP is very mobile in sand,--sandy loam, silt loam, and silty clay loam soils. Absorption has been positively correlated with the organic matter of the soils. Hydrolysis; Technical MCPP at 51-52 ppm did not hydrolyze during 31 days of incubation in sterile buffered solutions (pH 5, 7, and 9) at 25'C ± 2'C. Bioaccumulation: Available data indicate a low potential of MCPP to bioaccumulate in fish. ------- Ground Water; Available data indicate that MCPP is mobile in many soils and may potentially leach to ground water. Ecological Characteristics Avian acute toxicitv; MCPP acid has been shown to have an acute oral LD50 of 700 mg/kg to the bobwhite quail and is considered to be of low toxicity. Avian dietary toxicity: Studies on MCPP acid indicate LC50 values of >5620 ppm and 5000 ppm for the mallard and the bobwhite quail, respectively. These values are considered practically nontoxic to avian species on subacute basis. Freshwater fish acute toxicity: MCPP acid has very low toxicity to the rainbow trout (LC5Q =124 ppm). Freshwater invertebrates toxicity: There were no acceptable freshwater invertebrate studies submitted. Fish early lifestage and Aquatic invertebrate life cycle toxicitv; There were no fish early lifestage nor aquatic invertebrate life cycle, studies submitted. Nontarget plant toxicity: There were no acceptable nontarget plant studies submitted. Nontaraet insects; There were no data on effects of MCPP to honeybees and nontarget insects submitted. Pesticide Incidents There were no reports of MCPP pesticide incidents. SUMMARY OF REGULATORY POSITION 1. Special review; The Agency is deferring a decision on initiating a Special Review of MCPP based on teratogenicity until data needed to refine worker exposure estimates have been submitted and evaluated. 2. Restricted Use: The Agency will not restrict the use of MCPP products at this time. 3. Special Data Requirements: The Agency is requiring a submission of special studies to refine exposure estimates to workers. These data will be used to assess the teratogenic risk posed by MCPP to workers or other persons exposed to MCPP. 4. Basic Data Requirements; The Agency is requiring data specific to the amines and the ester formulations as well as the ------- acid. Acceptable data received on the MCPP acid will be generally acceptable for the potassium salt. 5. Groundwater concerns: MCPP has the potential to contaminate groundwater because it is mobile in many mineral soils. Studies to evaluate the potential of MCPP and its metabolites to contaminate groundwater are required. A groundwater statement is required (see labeling section below). 6. Reentry requirement: Reentry data are required because of the potential teratogenic risk and because some use patterns involve post-treatment tasks that could result in dermal exposures of workers to MCPP residues. Workers are not permitted to reenter treated areas until sprays have dried and dusts have settled (see labeling section below). 7. Protective clothing requirement; The Agency is requiring mixers/loaders and applicators to use protective clothing and equipment. See the protective clothing statement in the labeling section below. • 8. Endangered species regulatory position: There has been no determination that MCPP acid or any MCPP formulation would affect endangered animal or plant species. 9. Dibenzo-p-dioxins/Dibenzofurans: The Agency is requiring submission of manufacturing process data on MCPP to assess the possibility of contamination by dibenzo-p-dioxins or dibenzofurans. 10. Nitrosamines; The Agency is requiring chemical analysis of products containing MCPP amine salts for possible nitrosamine contamination. 11. Data for Immediate Review; The Agency has identified data which will be reviewed as soon as they are received: product chemistry; environmental fate; dermal absorption, applicator exposure and reentry; toxicity on the amine salts and ester; and Tier II phytoxicity. LABELING-^REOUIREMENTS Statements for Manufacturing-Use Products "Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans or public waters unless this product is specifically identified and addressed in an NPDES permit. Do not discharge effluent containing this product to sewer systems without previously notifying the sewage treatment plant authority. For guidance, contact your State Water Board or Regional Office of the EPA." ------- Statements for End-Use Products Ground Water Contamination; "Although highly mobile, in general phenoxy herbicides such as MCPP are not sufficiently persistent to reach ground water from use as specified on product labels. Most cases of ground water contamination involving phenoxy herbicides have been associated with mixing/loading and disposal sites. Caution should be exercised when handling MCPP at such sites to prevent contamination of water supplies." Protective Clothing; "Mixer/loader and applicators must wear long pants, long sleeve shirts, and gloves. Persons applying liquid MCPP products such as sprays are required to use goggles to cover their eyes." Worker Reentry; "Do not reenter or permit workers to reenter treated areas until sprays have dried or dusts have settled." Nontaraet Plant Species; • Aquatic uses; "Drift or run-off may adversely affect nontarget plants. Do not apply directly to water except as specified on this label. Do not contaminate water when disposing of equipment washwaters." Nonaquatic uses: "Drift or run-off may adversely affect nontarget plants. Do not apply directly to water or wetlands (swamps, bogs, marshes and potholes). Do not contaminate water when disposing of equipment washwaters." SUMMARY OF DATA GAPS The following data are required as specified. Uses of MCPP potassium salt may be supported with data on either the salt or MCPP acid. Codes for the different formulations are MCPP Acid (1), Potassium Salt (2), Diethanolamine (3), Dimethylamine (4), and Isooefeyl Ester (5). MCPP Due Date - From Study Formulation Date of Standard Product Chemistry; All 9-12 months Toxicology; Acute Oral, Dermal, 3, 4, 5 9 months Inhalation, Eye ------- Irritation, Dermal Irritation and Sensitization Subchronic 21-Day Dermal All Chronic Teratogenicity 3, 4, 5 Mutagenicity 3, 4, 5 Chromosomal Aberration All Other (sister chromatid exchange) 3, 4, 5 Special Testing Dermal Absorption All Applicator Exposure All Reentry Protection; * Foliar Dissipation All Soil Dissipation All Dermal Exposure All Environmental Fate; Hydrolysis All Photodegradation Water and Soil All Metabolism Aerobic Soil All Anaerobic Aquatic 2, 4, 5 Aerobic Aquatic 2, 4, 5 Mobility Leaching and Ad- sorption/Desorption All Dissipation Soil All Aqoatic (sediment) 2, 4, 5 Forestry 4 Accumulation Irrigated Crops 2,4,5 Fish All Aquatic Nontarget Organisms 2, 4, 5 12 months 15 months 9 months 12 months 12 months 9 months (protocols due in 6 months) 27 months 27 months 27 months 9 months 9 months 27 months 27 months 27 months 12 months 27 months 27 months 27 months 39 months 12 months 12 months ------- Wildlife & Aquatic Organisms: Avian & Acute Avian Oral Avian Subacute Upland Game Bird Waterfowl 3, 4, 5 3, 4, 5 3, 5 9 months 9 months 9 months Acniatic Organism; Freshwater Fish Coldwater Fish TGAI Coldwater Fish TEP Warmwater Fish TGAI Warmwater Fish TGAI Freshwater Invertebrates TGAI Invertebrates TEP Plant Protection: Nontarget Phytotox- icitv - Tier II; Seed Germina- tion/Emergence TGAI All Vegetative Vigor TGAI All Aquatic Plant Growth TGAI Nontarget Insect; Honey Bee Contact TGAI 3, 4, 5 1, 3, 4, 5 All 2, 4, 5 All 2, 4, 5 All 2, 3, 4, 5 9 months 9 months 9 months 9 months 9 months 9 months 9 months 9 months 9 months 9 months CONTACT PERSON AT EPA; Mr. Richard Mountfort --*•- Product manager (Team 23) Fungicide-Herbicide Branch Registration Division (TS-767C) Office of Pesticide Programs Environmental Protection Agency 401 M St., SW Washington, D.C. 20460 Physical Location; Crystal Mall #2 1921 Jefferson Davis Highway Arlington, VA Telephone number: (703) 557-1830 10 ------- DISCLAIMER: The information in this Pesticide Fact Sheet is a summary only and may not be used to satisfy data requirements for pesticide registration and reregistration. The complete Registration Standard for the pesticide may be obtained from the National Technical Information Service. Contact the Product Manager listed above for further information. 11 ------- v°/EPA U.S. Environmental Protection Agency ./^ < Office of Pesticide Program (TS^STG* " '5 PMSD, Information Services Branch 401 M Street, S.W. Washington, D.C. 20460 Official Business Penalty for Private Use $300 First Class Mail Postage and Fees Paid EPA Permit No. G-35 ------- |