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)

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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.

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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.

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      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.

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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.

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   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

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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."

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   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

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    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

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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

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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

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