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                     540/RS-89-028
Guidance for the
Reregistration  of
Pesticide Products
Containing METALDEHYDE
as the Active Ingredient

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                           OMB Control No.  2070-0057
                           Expires 11/89
            GUIDANCE FOR THE

  REREGISTRATION OF PESTICIDE PRODUCTS

                CONTAINING

               METALDEHYDE

        AS  THE  ACTIVE  INGREDIENT

CAS REGISTRY NO.  9002-91-9  (HOMOPOLYMER)
                  108-62-3  (TETRAMER)

        OPP Chemical Code  053001




          EPA CASE  NUMBER  0576

              December 1988
     ENVIRONMENTAL PROTECTION AGENCY

       OFFICE OF PESTICIDE PROGRAMS

          WASHINGTON, DC  20460

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                      TABLE OF CONTENTS
I.    Introduction  	 1

II.   Chemical Covered by this Standard	.  . 4
          A.  Description of Chemical
          B.  Use Profile
          C.  Background
III.  Agency Assessment  	 7
          A.  Health Effects Assessment
          B.  Environmental Profile
          C.  Tolerance Reassessment

IV.   Regulatory Position and Rationale	10
          A.  Regulatory Positions and Rationales
          B.  Criteria for Registration
          C.  Acceptable Ranges and Limits
          D.  Required Labeling

V.    Products Subject to this Standard	15

VI.   Requirement for Submittal of Generic Data	17
          A.  What are generic data?
          B.  Who must submit generic data?
          C.  What generic data must be submitted?
          D.  How to comply with DCI requirements
          E.  Registrant requests regarding data
              requirements and Agency responses
          F.  Test protocols and standards
          G.  Procedures for requesting a change in protocol
          H.  Procedures for requesting extensions of time
          I.  Data Format and Reporting Requirements
          J.  Existing stocks provisions upon suspension or
              cancellation

VII.  Requirement for Submittal of
          Product-Specific Data	24

VIII. Requirement for Submittal of Revised Labeling ... 25

IX.   Instructions for Submittal	26
          A.  Manufacturing use products (sole active)
          B.  Manufacturing use products (multiple active)
          C.  End use products (sole active)
          D.  End use products (multiple active)
          E.  Intrastate Products

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                          APPENDICES

I.   DATA APPENDICES	29

     Guide to Tables
     Table A
     Table B

II.  LABELING APPENDICES  	 58

     Summary of label requirements and table
     40 CFR 156.10 Labeling Requirements
     Physical/Chemical Hazards Labeling Statements
     Storage Instructions
     Pesticide Disposal Instructions
     Container Disposal Instructions

III. BIBLIOGRAPHY APPENDICES 	 83

     Guide to Bibliography
     Bibliography

IV.  FORMS APPENDICES  	 88

     EPA Form 8580-1     FIFRA  3(c)(2)(B) Summary Sheet
     EPA Form 8580-3     Generic Data Exemption Statement
     EPA Form 8580-4     Product Specific Data Report
     EPA Form 8580-6     Certification of Attempt to Enter
                         Into an Agreement with Other
                         Registrants for Development of Data
                              11

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             GLOSSARY OF TERMS AND ABBREVIATIONS
ADI



a. i.

CAS

CSF

EEC




EP

EPA

FIFRA

FFDCA

LC50
LD50
LEL

MPI

MRID




MP
Acceptable Daily Intake.  Also known as the
Reference Dose or RfD.

Active ingredient

Chemical Abstracts Service

Confidential Statement of Formula

Estimated Environmental Concentration.   The
estimated pesticide concentration in an
environment, such as a terrestrial ecosystem.

End Use Product

U.S. Environmental Protection Agency

Federal Insecticide, Fungicide, and Rodenticide Act

Federal Food, Drug, and Cosmetic Act

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 or feed, e.g. ,  mg/1 or
ppm.

Median lethal dose - a statistically derived single
dose than 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.

Lowest Effect Level

Maximum Permissible Intake

Master Record Identification (number).   EPA's
system of recording and tracking studies submitted
to the Agency.

Manufacturing Use Product
                             111

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NOEL      No Observed Effect Level
OPP       Office of Pesticide Programs
PADI      Provisional Acceptable Daily Intake
ppm       Parts per million
TMRC      Theoretical Maximal Residue Contribution
                              IV

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                       I.   INTRODUCTION

     EPA has established the Registration Standards program
in order to provide an orderly mechanism by which pesticide
products containing the same active ingredient can be
reviewed and standards set for compliance with FIFRA.  The
standards are applicable to reregistration and future
applications for registration of products containing the same
active ingredient. Each registrant of a product containing an
active ingredient subject to this Standard who wishes to
continue to sell or distribute that product must bring his
product and labeling into compliance with FIFRA, as
instructed by this Standard.

     The Registration Standards program involves a thorough
review of the scientific data base 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 the pesticide meets the "no unreasonable
adverse effects" criteria of FIFRA.  In its review EPA
identifies:

     l.  Studies that are acceptable to support the data
requirements for the currently registered uses of the
pesticide.

     2.  Additional studies necessary to support continued
registration.  The additional studies may not have been
required when the product was initially registered or may be
needed to replace studies that are now considered inadequate.

     3.  Labeling revisions needed to ensure that the product
is not misbranded and that the labeling is adequate to
protect man and the environment.

     The detailed scientific review, which is not contained
in this document, but is available upon request,1 focuses on
the pesticide active ingredient.  The scientific review
primarily discusses the Agency's evaluation of and
conclusions from available data in its files pertaining to
the pesticide active ingredient.  However, during the review
of these data the Agency is also looking for potential
hazards that may be associated with the end use products that
contain the active ingredient.  The Agency will apply the
provisions of this Registration Standard to end use products
if necessary to protect man and the environment.
      The scientific reviews and Compendium of Acceptable _
Uses may be obtained from the OPP Public Docket.  Write to
OPP Public Docket, Field Operations Division (H7506C),
Office of Pesticide Programs, EPA, Washington, D.C.   20460

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     EPA's reassessment results in the development of a
regulatory position, contained in this Registration Standard,
on the pesticide and each of its registered uses.   See
Section IV - Regulatory Position and Rationale.   Based on its
regulatory position, the Agency may prescribe a variety of
steps to be taken by registrants to maintain their
registrations in compliance with FIFRA.  These steps may
include:

     1.  Submittal of data in support of product
registration;

     2.  Modification of product labels;

     3.  Modifications to the manufacturing process of the
pesticide to reduce the levels of impurities or contaminants;

     4.  Restriction of the use of the pesticide to certified
applicators or other specially trained individuals;

     5.  Modification of uses or formulation types; or

     6.  Specification of packaging limitations.

     Failure to comply with these requirements may result in
the issuance of a Notice of Intent to Cancel or a Notice of
Intent to Suspend (in the case of failure to submit data).

     In addition, in cases in which hazards to man or the
environment are identified, the Agency may initiate a special
review of the pesticide in accordance with 40 CFR Part 154 to
examine in depth the risks and benefits of use of the
pesticide.  If the Agency determines that the risks of the
pesticide's use outweigh the benefits of use, the Agency may
propose additional regulatory actions, such as cancellation
of uses of the pesticide which have been determined to cause
unreasonable adverse effects on the environment.

     EPA has authority under the Data Call-in (DCI)
provisions of FIFRA sec. 3(c)(2)(B) to require that
registrants submit data to answer our questions regarding the
chemical, toxicological, and environmental characteristics
and fate of a pesticide. This Registration Standard lists the
data EPA believes are necessary to resolve our concerns about
this pesticide. These data are listed in the Tables A, B, and
C in Appendix I. Failure to comply with the DCI requirements
enumerated in this Registration Standard may result in
issuance by EPA of a Notice of Intent to Suspend the affected
product registrations.

     Registrants are reminded that FIFRA sec. 6(a)(2)
requires them to submit factual information concerning
possible unreasonable adverse effects of a pesticide at any
                          -2-

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time that they become aware of such information.   Registrants
must notify the Agency of any information, including interim
or preliminary results of studies, if that information
suggests possible adverse effects on man or the environment.
This requirement is independent of the specific time
requirements imposed by EPA for submittal of completed
studies called in by the Agency and continues as long as the
products are registered under FIFRA.
                          - 3 -

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              II.   CHEMICAL COVERED BY THIS STANDARD


                   A.  DESCRIPTION OF CHEMICAL

Common Name:  Metaldehyde

Chemical Name: 2,4,6,8-tetramethyl-l,3,5,7-tetraoxycyclo-octane

Chemical Family:  Hydrocarbon

Trade Names:  Meta, Metason, Halizan, Antimilace, Namekil,
                   Cekumeta

CAS Registry No.:  9002-91-9 (homopolymer)
                   108-62-3  (tetramer)

OPP Chemical Code: 053001

Empirical Formula:  C8H16O4

Molecular Weight:  176.2

Chemical/Physical Characteristics:

     Color:  White
     Physical State:  Crystalline powder
     Odor:  Aldehyde odor
     Melting Point:  246° C
     Bulk Density:  65g/100cc
     Solubility:  at 20° C, 0.2 g/L in water and very
          slightly soluble in alcohol
     Vapor Pressure:  1mm Hg at 20° C
     Flammability:  36-40° C
                         B.  USE PROFILE

Type of Pesticide:  Molluscicide

Year of Initial Registration: 1962

Registered Uses:

     TERRESTRIAL FOOD CROP:   alfalfa, almond, anise, apple,
     apricot, artichoke, asparagus, avocado, banana, barley,
     beans, beets, blackberry, blackeyed peas, blueberry,
     boysenberry, broccoli, brussels sprouts, cabbage, caneberry,
     cantaloupes, caraway, carrots, catnip, cauliflower, celery,
     cereal crops, cherry, chicory, chive, citrus fruits, clover,
     cole crops, collards, coriander, corn, cowpeas, cucumber,
     currant, dewberry, dill, eggplant, endive, garlic, ginseng,
     gooseberry, grapefruit, grapes, horseradish, kale, kohlrabi,

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     leek, legume, lemon, lentils, lettuce, lime, loganberry,
     melons, muskmelons, mustard, mustard greens, nectarine,
     oats, okra, onion, orange, oregano, parsley, parsnip, peach,
     pear, peas, pecan, peppermint, peppers, pimento, plum,
     potato, pumpkin, radish, raspberry, rhubarb, rutabaga, sage,
     salsify, savory, shallot, spearmint, spinach, squash, stone
     fruits, strawberry, sugar beets, sweet potato, swiss chard,
     thyme, tomato, turnips vegetable crops, walnut, watermelons,
     wheat;  seed crops;  alfalfa, beans, clover, corn  (sweet),
     grasses, peas, potato.

     TERRESTRIAL NONFOOD CROP:  seed crops;  beets, cabbage,
     carrots, collards, kale, kohlrabi, lettuce, mustard, radish,
     spinach, swiss chard, tobacco, turnips.

     GREENHOUSE FOOD CROP;  asparagus, beans, beets, cabbage,
     carrots, celery, corn, cucumber, eggplant, endive, lettuce,
     melons, onion, peas, peppers, potato, radish, spinach,
     squash, tomato, turnips.

     GREENHOUSE NONFOOD CROP:  orchids, ornamental plants.

     DOMESTIC AND NONDOMESTIC OUTDOOR:  domestic dwellings,
     greenhouses, lath houses, lawns  (including dichondra),
     ornamental grasses, ornamental plants  (including nursery
     stocks), turf.

     INDOOR:  farm buildings.

Pests Controlled:   slugs and snails

Methods of Application:  by hand, ground, or aerial equipment

Formulations:  wettable powders, dusts, emulsifiable
               concentrates, flowable concentrates, granules,
               ready-to-use products  (liquids) and
               pelleted/tableted

Annual Usage:  400,000 - 600,000 Ibs ai  (1986 estimate)

Predominate Usage:  home orchards, gardens and ornamentals, and
                    commercial vegetables  (artichokes,  broccoli,
                    cauliflower, lettuce, cabbage, and  tomatoes),
                    and fruits  (citrus, stone, pome, and
                    strawberries)

U. S. Producer:     Lonza, Incorporated

Number of Registrations: 77 end-use products  (EPs), 4 technical
                         products/formulation intermediates, and
                         7 "special local need" registrations
                             -  5  -

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                          C.   BACKGROUND

     Historically, the Agency did not consider the use of baits
in-field to protect fruits and vegetables to be a food use and
tolerances were not required.  However, Residue Chemistry
Guidelines, updated in October 1982, state that if residues could
occur in foods or feed, the use is considered to be a food use
and a petition for tolerance/exemption from tolerance is
required.  The Agency has no basis for concluding that residues
will not occur in the food and feed crops treated with
metaldehyde.   Therefore, EPA will require data on metaldehyde to
support food uses.

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                     III.  AGENCY ASSESSMENT


     The Agency has reviewed all data currently supporting the
registration of metaldehyde as of April 1988.  Based on the
available data, EPA has reached the following conclusions.

                  A.  HEALTH EFFECTS ASSESSMENT

     Toxicology.  Metaldehyde is of moderate to low acute
toxicity by the oral route and of low acute toxicity by dermal
and inhalation exposure.  Metaldehyde was not found to be a
dermal irritant. However, all of the available acute studies must
have the purity of the test material established before they can
be fully accepted.

     The only other available data are a partially acceptable
mutagenicity study and a nonrodent subchronic study which
provides supplementary information but is not acceptable for
fulfilling data requirements.

     In the chromosome aberration assay, the portion performed in
the absence of metabolic activation system is acceptable;
metaldehyde was not found to be clastogenic under the conditions
of the assay.

     In a 26-week dog feeding study with metaldehyde, the
possibility of- degenerative changes in the liver, prostate, and
male gonads was suggested.  Because of certain deficiencies in
its conduct, this study is not acceptable for fulfilling
registration requirements.

     The remainder of the toxicity data base is essentially
either inadequate or vacant because of past policy classifying
bait formulations as nonfood uses.  Data are required as set
forth in Table A of this document.

     Poisoning Incidents.  Poisoning incident reports show that
the use of metaldehyde, especially homeowner use, has been
associated with dog poisonings.  These reports indicate that dogs
have died as a result of metaldehyde poisonings.  There are also
numerous reports of children ingesting metaldehyde baits, but no
adverse effects have been reported.

     Worker Exposure/Reentry.  Because of the low acute toxicity
of metaldehyde, mixer/loaders and applicators are not expected to
experience adverse effects as a result of their exposure to
metaldehyde.  The Agency has determined that, because of the low
acute toxicity of metaldehyde and the use patterns of this
pesticide, reentry data are not required.
                             — 7 —

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                    B.  ENVIRONMENTAL PROFILE

     Ecological Effects.  None of the available ecological
effects data meet Agency requirements.  However, the available
data suggest that metaldehyde is of low toxicity to birds and is
practically nontoxic to aquatic organisms.  Data are required as
set forth in Table A.

     Based on the nature of registered metaldehyde formulations
and uses, significant bee exposure is not anticipated.  Thus, bee
data are not required for metaldehyde.

     Environmental Fate.  Presently, the Agency does not have
adequate environmental fate data on which to base environmental
fate and groundwater leaching assessments for metaldehyde.
Metaldehyde is a polymer of acetaldehyde and its initial
breakdown product is expected to be acetaldehyde.  Data are
required as set forth in Table A.

                   C.  TOLERANCE REASSESSMENT

     Tolerances Issued.  Although tolerances had not been
generally required for food/feed uses of baits, there is a food
additive regulation of zero ppm for strawberries (40 CFR
185.4025).  This is not supported by adequate data.  A tolerance
assessment will be made when the essential toxicity and residue
data are available.  The tolerance is expressed in terms of
metaldehyde per se.

     EPA has evaluated the residue and toxicology data pertaining
to metaldehyde.  The results of the Agency's evaluation are as
follows:

     Residue Data.  No acceptable data are available on the
nature of the residues in both plants and animals, including
identification of major metabolites and degradates of the
pesticide.  Data are required as set forth in Table A.

     No acceptable analytical methodology for determining the
levels of residues in plants and animals are available.  Data are
required as set forth in Table A.

     The submitted data do not establish appropriate storage
conditions.  Data are required as set forth in Table A.

     Data on the magnitude and levels of residues of metaldehyde
in individual raw agricultural commodities, animal products, and
processed food and feed items are either inadequate or completely
lacking.  Data are required as set forth in Table A.

     The Food and Drug Administration (FDA) Total Diet Studies,
as well as Surveillance and Compliance program for domestic and
imported commodities do not employ methodology capable of
determining residues of metaldehyde.


                             - 8 -

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     No Codex MRLs or Canadian or Mexican tolerances have been
established in or on food or feed commodities or in animal
products.

     Toxicology.  The toxicological data are inadequate to allow
an assessment of any dietary exposure to metaldehyde.
                             - 9 -

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              IV.   REGULATORY  POSITION AND RATIONALE
     Based on review and evaluation of all available data and
other relevant information on metaldehyde, the Agency has made
the following determinations:

     1.  Metaldehyde is not being placed into Special Review at
this time.

     Rationale:  Since there are so few acceptable studies
available to support registration of products containing
metaldehyde, the Agency is not able to determine whether any of
the criteria of 40 CFR 154.7 have been met or exceeded.

     2.  The Agency is not restricting the use of metaldehyde at
this time.

     Rationale:  FIFRA section 3(d)(l)(C) provides that some or
all uses of a pesticide will be classified for restricted use if
the Administrator determines that without such restriction the
pesticide "may generally cause unreasonable adverse effects in
man or the environment."  The Agency does not have sufficient
data at this time to determine if metaldehyde meets any of the
risk criteria of 40 CFR 152.170.  Upon receipt of data required
under this Standard, the Agency will apply the criteria of 40 CFR
152.170 to determine if any uses of metaldehyde warrant
restricted use classification.

     3.  The Agency will continue to require precautionary
statements to protect dogs and other pets, but special
precautionary statements for children are not necessary.

     Rationale;  Poisoning incident reports continually indicate
fatalities to dogs associated with the use of metaldehyde baits
but there is no evidence that exposed children have been
adversely affected.

     4.  The Agency will assess metaldehyde's potential for
contaminating ground water upon receipt of the required
environmental fate data set forth in Table A of this Standard.

     Rationale;  The Agency is unable to assess the potential for
metaldehyde to contaminate ground water because the environmental
fate of this chemical is uncharacterized.  When data required in
this Standard have been received and evaluated, the Agency will
assess metaldehyde's potential for ground water contamination.

     5.  The Agency is classifying in-field uses of metaldehyde
on food and feed crops as food uses and is requiring
tolerances/exemptions from tolerances.  Tolerances supported by
                             -  10  -

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data must be proposed for residues of metaldehyde in or on any
agricultural commodities on which metaldehyde is used.  When a
strawberry tolerance is established, the existing food additive
regulation for strawberries will be revoked.  Additionally,
tolerances must be proposed, and supporting residue data
provided, for the forage and fodder of field corn, popcorn and
sweet corn, for the forage hay, and straw of wheat (which will be
translated to barley and oat straw) and for spent mint hay.
Alternatively for these latter commodities, the registrant may
propose a feeding restriction for such commodities as
appropriate.

     Rationale;  Historically, the use of baits in-field to
protect fruits and vegetables was not considered to be a food use
and tolerances were not required.  Current Residue Chemistry
Guidelines (October 1982;34) state that "... if residues could
occur in foods or feed, then the use is a food use and a petition
for tolerance/exemption from tolerance is required."  The Agency
has no basis for concluding that residues will not occur in the
food and feed crops listed.  Therefore, these uses are now
considered to be food uses.

     6.  The Agency will not approve tolerances until the Agency
has received data sufficient to perform a tolerance reassessment.

     Rationale;  Plant and animal metabolism studies, analytical
methods, residue studies, storage stability studies, and
processing studies are needed before the Agency can determine
appropriate tolerance levels and perform a tolerance
reassessment.  A full set of chronic toxicology data is also
required.

     7.  The Agency is not requiring a reentry interval for
metaldehyde products.

     Rationale;  Based on the toxicological data available to the
Agency, metaldehyde products are of low toxicity.  Because of
these low toxicity levels, it is not considered necessary to
establish a reentry interval.

     8.  The Agency is not requiring protective clothing labeling
for end-use products.

     Rationale:  The available data base for metaldehyde shows
that metaldehyde has low acute toxicity.  There are no other data
to indicate that protective clothing is needed.  The Agency will
reassess this position when required toxicity studies have been
submitted and evaluated.

     9.  Current label warnings on some products indicating that
"Metaldehyde is toxic to fish and wildlife" and "Birds feeding on
treated areas may be killed" are not now required.
                             - 11 -

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     Rationale:  The Agency has no data to support the imposition
of such warnings.  Available supplementary data indicate that the
magnitude of the risk is unlikely to require such warnings for
metaldehyde.

    10.  The Agency will assign priority review for metaldehyde
studies involving animal and plant metabolism, potential to
contaminate ground water, and exposure to fish and wildlife.

     Rationale;  The metabolism studies are needed prior to
commencement of residue studies and the other studies are needed
to determine whether additional studies are required.

    11.  While data gaps are being filled, currently registered
products containing metaldehyde may be sold, distributed,
formulated, and used, subject to the terms and conditions
specified in this Registration Standard.  Registrants must
provide or agree to develop additional data, as specified in the
Data Tables, in order to maintain existing registrations.

     Rationale;  Even when authorized under FIFRA sections
3(c)(2)(B) and 3(c)(7), the Agency may elect not to cancel or
withhold registration even though data are missing or are
inadequate.  Issuance of this Standard provides a mechanism for
identifying data needs.  These data will be reviewed and
evaluated, after which the Agency will determine if additional
regulatory actions are necessary.


                 B.  CRITERIA FOR REGISTRATION

To be registered or reregistered under this Standard, products
must contain this pesticide, bear required labeling, and conform
to the product composition, acute toxicity limits, and use
pattern requirements listed in this document.


                 C.   ACCEPTABLE  RANGES  AND LIMITS

     Product Composition Standard.  To be registered or
reregistered under this Standard, manufacturing-use products
(MPs)  must contain this pesticide.  Each MP formulation proposed
for registration must be fully described with an appropriate
certification of limits, stating maximum and minimum amounts of
the active ingredient and inert ingredients which are present in
products, as well as impurities found at greater than 0.1
percent.

     Acute Toxicity Limits.  The Agency will consider
registration of technical grade and manufacturing-use products
containing this pesticide provided that the product labeling
bears appropriate precautionary statements for the acute toxicity
category in which each product is placed.
                             - 12 -

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     Use Patterns.  To be registered under this Standard,
manufacturing-use products bearing federally registered uses.
The EPA Index to Pesticide Chemicals (for availability, see page
1) lists all federally registered uses of this pesticide
ingredient, as well as approved maximum application rates and
frequencies.
                      D.  REQUIRED LABELING

     All products must bear appropriate labeling as specified in
40 CFR 156.10, PR Notices 83-2, 83-3,  and below.  Appendix II
contains further information on label requirements.

     Pesticide products containing this pesticide as an active
ingredient may not be released for shipment by the registrant
after December 23, 1989, unless the product bears amended
labeling that complies with the requirements of FIFRA, as set out
in this Registration Standard.

     Pesticide products containing this pesticide as an active
ingredient may not be distributed or sold by any person after
December 23, 1990, unless that product bears amended labeling
that complies with the requirements of this Standard.

     The labels of all products must bear the appropriate storage
and disposal statements (see Appendix II).

a.  Manufacturing-Use Products (MPS)

     1.  The ingredient statement for MPS must declare the active
ingredient as:

          Metaldehyde (2,4,6,8-tetramethyl-l,3,5,7-
               tetraoxycyclo-octane) 	 %

     2.  Labels for MPS must bear the following identifying
phrase directly beneath the product name:

          "A molluscicide for formulating use only."

     3.  In the directions for use, the following statement must
appear:

          "Formulators using this product are responsible for
          obtaining EPA registration of their formulated
          product."

     4.  In the directions for use, the following statement
regarding acceptable use patterns must appear; however, no
use may be included on the label where the registrant fails to
agree to comply with the data requirements for that use pattern:
                             - 13 -

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          "For formulation into end-use insecticide products
          intended only for (list acceptable sites)-11

     5.  If detailed instructions for formulating are not
provided on the label, the following statement must appear:

          "Refer to attached Technical Bulletin for formulating
          and other information."

     6.  The following statements are required to appear under
the "Environmental Hazards" heading:

          "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."

b.  End-Use Products  (EP)

     1.  The active ingredient for EPs must declare the active
ingredient as:

          Metaldehyde (2,4,6,8-tetramethyl-l,3,5,7-
               tetraoxycyclo-octane) 	 %

     2.  All EPs allowing for outdoor uses must bear the
following environmental hazards statements:

          "Do not apply directly to water or wetlands (swamps,
          bogs, marshes, and potholes).  Do not contaminate water
          when disposing of equipment washwaters."

          "This pesticide may be fatal to dogs or other pets if
          eaten.  Keep pets out of treated area."
                             - 14 -

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            V.  PRODUCTS SUBJECT TO THIS STANDARD

     All products containing one or more of the pesticides
identified in Section II.A. are subject to certain
requirements for data submittal or changes in composition,
labeling or packaging of the product.  The applicable
requirements depend on whether the product is a manufacturing
or end use product and whether the pesticide is the sole
active ingredient or one of multiple active ingredients.

     Products are subject to this Registration Standard as
follows:

A.   Manufacturing use products containing this pesticide as
     the sole active ingredient are subject to:

     1.   The restrictions (if any) upon use, composition, or
          packaging listed in Section IV, if they pertain to
          the manufacturing use product.

     2.   The data requirements listed in Tables A and B.2

     3.   The labeling requirements specified for
          manufacturing use products in Section IV.

     4.   Administrative requirements (application forms.
          Confidential Statement of Formula, data
          compensation provisions) associated with
          reregistration.

B.   Manufacturing use products containing this pesticide as
     one of multiple active ingredients are subject to:

     1.   The data requirements listed in Table A.
     2Data requirements are listed in the three Tables in
Appendix I of this Registration Standard.  The Guide to
Tables in that Appendix explains how to read the Tables.

     Table A lists generic data requirements applicable to
all products containing the pesticide subject to this
Registration Standard.  Table B lists product-specific data
applicable to manufacturing-use products.  The data in Tables
A and B need not be submitted by an end-use producer who is
eligible for the generic data exemption for that active
ingredient.

     Table C lists product-specific data applicable to end-
use products.  The Agency has decided that, in most cases, it
will not require the submittal of product-specific data for
end-use products at this time.  Therefore, most Registration
Standards do not contain a Table C.
                         - 15 -

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     2.   The labeling requirements specified for
          manufacturing use products in Section IV.

C.   End use products containing this pesticide as the sole
     active ingredient are subject to:

     1.   The restrictions (if any) upon use, composition, or
          packaging listed in Section IV if they pertain to
          the end use product.

     2.   If eligible for the generic data exemption,3 the
          data requirements listed in Table C.

     3.   If not eligible for the generic data exemption, the
          data requirements listed in Table A and the data
          requirements listed in Table C.

     4.   The labeling requirements specified for end use
          products in Section IV.

D.   End use products containing this pesticide as one of
     multiple active ingredients are subject to:

     1.   If not eligible for the generic data exemption, the
          data requirements listed in Tables A and C.

     2.   If eligible for the generic data exemption, the
          data requirements listed in Table C.

     3.   The labeling requirements specified for end use
          products in Section IV.
     3If you purchase from another producer and use as the
source of your active ingredient only EPA-registered
products, you are eligible for the generic data exemption for
generic data concerning that active ingredient (Table A) and
product-specific data for the registered manufacturing use
product you purchase (Table B).

     Two circumstances nullify this exemption:

     1)  If you change sources of active ingredient to an
unregistered product, formulate your own active ingredient,
or acquire your active ingredient from a firm with ownership
in common with yours, you individually lose the exemption and
become subject to the data requirements in Table A.

     2)  If no producer subject to the generic data
requirements in Table A agrees to submit the required data,
all end-use producers lose the exemption, and become subject
to the data requirements in Table A.
                         - 16 -

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       VI.  REQUIREMENT FOR SUBMISSION OF GENERIC DATA

     This portion of the Registration Standard is a notice
issued under the authority of FIFRA sec. 3(c)(2)(B).  It
refers to the data listed in Table A, which are required to
be submitted by registrants to maintain in effect the
registration of products containing this active ingredient.4

A.  What are generic data?

     Generic data pertain to the properties or effects of a
particular active ingredient.  Such data are relevant to an
evaluation of all products containing that active ingredient
regardless of whether the product contains other ingredients
(unless the product bears labeling that would make the data
requirement inapplicable).

     Generic data may also be data on a "typical formulation"
of a product.  "Typical formulation" testing is often
required for ecological effects studies and applies to all
products having that formulation type.  These are classed as
generic data, and are contained in Table A.

B.  Who must submit generic data?

     All current registrants are responsible for submitting
generic data in response to a data request under FIFRA sec.
3(c)(2)(B) (DCI Notice).  EPA has decided, however, not to
require a registrant who qualifies for the formulator's
exemption (FIFRA sec. 3(c)(2)(D) and 152.85) to submit
generic data in response to a DCI notice if the registrant
who supplies the active ingredient in his product is
complying with the data request.

     If you are granted a generic data exemption, you rely on
the efforts of other persons to provide the Agency with the
required data.  If the registrants who have committed to
generate and submit the required data fail to take
appropriate steps to meet the requirements or are no longer
in compliance with this data requirements notice, the Agency
will consider that both they and you are not in compliance
and will normally initiate proceedings to suspend the
registrations of both your product(s) and their product(s)
unless you commit to submit and submit the required data in
the specified timeframe.  In such cases, the Agency
generally will not grant a time extension for submitting the
data.
     Registrations granted after issuance of this Standard
will be conditioned upon submittal or citation of the data
listed in this Registration Standard.
                         - 17 -

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     if you are not now eligible for a generic data
exemption, you may qualify for one if you change your source
of supply to a registered source that does not share
ownership in common with your firm.  If you choose to change
sources of supply, the Confidential Statement of Formula must
identify the new source(s) and you must submit a Generic Data
Exemption Statement.

     If you apply for a new registration for products
containing this active ingredient after the issuance of this
Registration Standard, you will be required to submit or cite
generic data relevant to the uses of your product if, at the
time the application is submitted, the data have been
submitted to the Agency by current registrants.  If the
required data have not yet been submitted, any new
registration will be conditioned upon the new registrant's
submittal or citation of the required data not later than the
date upon which current registrants of similar products are
required to provide such data.  See FIFRA sec. 3(c)(7)(A).
If you thereafter fail to comply with the condition of that
registration to provide data, the registration may be
cancelled (FIFRA sec. 6(e)).

C.  What generic data must be submitted?

     You may determine which generic data you must submit by
consulting Table A.  That table lists the generic data needed
to evaluate current uses of all products containing this
active ingredient, the uses for which such data are required,
and the dates by which the data must be submitted to the
Agency-

D.  How to comply with DCI requirements.

     Within 90 days of your receipt of this Registration
Standard, you must submit to EPA a completed copy of the form
entitled "FIFRA Section 3(c)(2)(B) Summary Sheet" (EPA Form
8580-1,  enclosed) for each of your products.  On that form
you must state which of the following six methods you will
use to comply with the DCI requirements:

     1.   You will submit the data yourself.

     2.   You have entered into an agreement with one or more
registrants to jointly develop 
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who will be submitting the data that you may rely upon its
submittal. The Agency will also require adequate assurance
that the person whom you state will provide the data is
taking appropriate steps to secure it.  The agreement to
produce the data need not specify all of the terms of the
final arrangement between the parties or a mechanism to
resolve the terms.

     If you and other registrants together are generating or
submitting requested data as a task force or consortium, a
representative of the group should request a Joint Data
Submitter Number, as part of your 90-day response.  The
request must include the following information:

     a.   A list of the members of the consortium;
     b.   The name and address of the designated
          representative of the consortium, with whom EPA
          will correspond concerning the data;
     c.   Identity of the Registration Standard containing
          the data requirement;
     d.   A list of the products affected (from all members
          of the consortium); and
     e.   Identification of the specific data that the
          consortium will be generating or submitting.

     The Agency will assign a number to the consortium, which
should be used on all data submittals by the consortium.

     3.  You have attempted to enter into an agreement to
jointly develop data, but no other registrant has accepted
your offer.  You request that EPA not suspend your
registration for non-compliance with the DCI.  EPA has
determined that, as a general policy, it will not suspend the
registration of a product when the registrant has in good
faith sought and continues to seek to enter into a data
development/cost sharing program, but the other registrants
developing the data have refused to accept its offer.  [If
your offer is accepted, you may qualify for Option 2 above by
entering into an agreement to supply the data.]

     In order to qualify for this method, you must:

     1.  File with EPA a completed "Certification of Attempt
to Enter into an Agreement with other Registrants for
Development of Data" (EPA Form 8580-6, enclosed).

     2.  Provide us with a copy of your offer to the other
registrant and proof of the other registrant's receipt of
your offer (such as a certified mail receipt).  Your offer
must, at a minimum, contain the following language or its
equivalent:

     [Your company name] offers to share in the burden of
producing the data required pursuant to FIFRA sec.
                         - 19 -

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3(c)(2)(B) in the [name of active ingredient] Registration
Standard upon terms to be agreed or failing agreement to be
bound by binding arbitration as provided by FIFRA section
     The remainder of your offer may not in any way attempt
to limit this commitment.  If the other registrant to whom
your offer is made does not accept your offer, and if the
other registrant informs us on a DCI Summary Sheet that he
will develop and submit the data required under the DCI,
then you may qualify for this option.  In order for you to
avoid suspension under this method, you may not later
withdraw or limit your offer to share in the burden of
developing the data.

     In addition, the other registrant must fulfill its
commitment to develop and submit the data as required by this
Notice in a timely manner.  If the other registrant fails to
develop the data or for some other reason would be subject to
suspension, your registration as well as that of the other
registrant will normally be subject to initiation of
suspension proceedings, unless you commit to submit and
submit the required data in the specified timeframe.  In such
cases, the Agency generally will not grant a time extension
for submitting the data.

     4.  You request a waiver of the data requirement.  If
you believe that a data requirement does not (or should not)
apply to your product or its uses , you must provide EPA with
a statement of the reasons why you believe this is so.  Your
statement must address the specific composition or use
factors that lead you to believe that a requirement does not
apply. Since the Agency has carefully considered the
composition and uses of pesticide products in determining
that a data requirement applies, EPA does not anticipate
that many waivers will be granted.  A request for waiver does
not extend the timeframes for developing required data, and
if your waiver request is denied, your registration may be
suspended if you fail to submit the data.  The Agency will
respond in writing to your request for a waiver.

     5.  You request that EPA amend your registration by
deleting the uses for which the data are needed.  You are not
required to submit data for uses which are no longer on your
label.

     6.  You request voluntary cancellation of the regis-
tration of your product (s) for which the data are needed.

E.   Registrant Requests Regarding Data Requirements and
     Agency Responses

     All requests for modification of data requirements
(inapplicability, waiver), approval of protocols or protocol
                         - 20 -

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changes, or time extensions must be submitted in writing.
The original requirement remains in effect unless the Agency
has notified you in writing that it has agreed to a change in
the requirement.  While being considered by the Agency, such
requests for changes in the requirements do not alter the
original requirements or extend the time allowed for meeting
the requirement.

F.  Test Protocols and Standards

     All studies required under this Notice must be conducted
in accordance with test standards outlined in the Pesticide
Assessment Guidelines, unless other protocol or standards are
approved for use by the Agency in writing.  All testing must
be conducted in accordance with applicable Good Laboratory
Practices regulations in 40 CFR Part 160.

     The Pesticide Assessment Guidelines, which are
referenced in the Data Tables, are available from the
National Technical Information Service (NTIS), Attn: Order
Desk, 5285 Port Royal Road, Springfield, VA  22161 (tel:
703-487-4650) .

     Protocols approved by the Organization for Economic
Cooperation and Development (OECD) are also acceptable if the
OECD-recommended test standards conform to those specified in
the Pesticide Data Requirements regulation (Part 158.70).
Please note, however, that certain OECD standards (such as
test duration, selection of test species, and degradate
identification which are environmental fate requirements) are
less restrictive than those in the EPA Assessment Guidelines
listed above.  When using the OECD protocols, they should be
modified as appropriate so that the data generated by the
study will satisfy the requirements of Part 158.  Normally,
the Agency will not extend deadlines for complying with data
requirements when the studies were not conducted in accord
with acceptable standards.  The OECD protocols are available
from OECD, 1750 Pennsylvania Avenue, N.W., Washington, D.C.
20006.

G.  Procedures for requesting a change in test protocol.

     If you will generate the required data and plan to use
test procedures which deviate from EPA's Pesticide Assessment
Guidelines or the Reports of Expert Groups to the Chemicals
Group, Organization for Economic Cooperation and Development
(OECD) Chemicals Testing Programme, you must submit for EPA
approval the protocols you propose to use.

     You should submit your protocols before beginning
testing, because the Agency will not ordinarily accept as
sufficient studies using unapproved protocols.  A request for
protocol approval will not extend the timeframe for submittal
of the data, nor will extensions generally be given to


                          - 21 -

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conduct studies due to submittal of inappropriate protocols.
The Agency will respond in writing to your request for
protocol approval or change.

H.  Procedures for requesting extensions of time.

     If you think that you will need more time to generate
the data than is allowed by EPA's schedule, you may submit a
request for an extension of time.

     EPA will view failure to request an extension before the
data submittal response deadline as a waiver of any future
claim that there was insufficient time to submit the data.
While EPA considers your request, you must strive to meet the
deadline for submitting the data.

     The extension request should state the reasons why you
believe that an extension is necessary and the steps you have
taken to meet the testing deadline.  Time extensions normally
will not be granted due to problems with laboratory capacity
or adequacy of funding, since the Agency believes that with
proper planning these can be overcome.  The Agency will
respond in writing to any requests for extension of time.

I.  Data Format and Reporting Requirements

     All data submitted in response to this Notice must
comply with EPA requirements regarding the reporting of data,
including the manner of reporting, the completeness of
results, and the adequacy of any required supporting (or raw)
data, including, but not limited to, requirements referenced
or included in this Notice or contained in PR Notice 86-5
(issued July 29, 1986).  All studies must be submitted in the
form of a final report; a preliminary report will not be
considered to fulfill the submittal requirement.

J.   Existing stocks provision upon suspension or
     cancellation.

     The Agency has determined that if a registration is
suspended for failure to respond to a DCI request under FIFRA
sec. 3(c)(2)(B), an existing stocks provision for the
registrant is not consistent with the Act.  Accordingly, the
Agency does not anticipate granting permission to sell or
distribute existing stocks of suspended product except in
rare circumstances.  If you believe that your product will be
suspended or cancelled and that an existing stocks provision
should be granted, you have the burden of clearly
demonstrating to EPA that granting such permission would be
consistent with the Act.  The following information must be
included in any request for an existing stocks provision:

     1.  Explanation of why an existing stocks provision is
necessary, including a statement of the quantity of existing


                         - 22 -

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stocks and your estimate of the time required for their sale
or distribution; and

     2.  Demonstration that such a provision would be
consistent with the provisions of FIFRA.
                          - 23 -

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  VII.  REQUIREMENT FOR SUBMISSION OF PRODUCT-SPECIFIC DATA

     Under its DCI authority, EPA has determined that
certain product-specific data are required to maintain your
registrations in effect.  Product-specific data are derived
from testing using a specific formulated product, and,  unlike
generic data, generally support only the registration of that
product. All such data must be submitted by the dates
specified in this Registration Standard.

     If you have a manufacturing use product, these data are
listed in Table B.  If you have an end use product, the data
are listed in Table C.  As noted earlier, the Agency has
decided that it will not routinely require product-specific
data for end use products at this time.  Therefore, Table C
may not be contained in this Registration Standard; if there
is no Table C, you are not required to submit the data at
this time.

     In order to comply with the product specific data
requirements, you must follow the same procedures as for
generic data. See Section VI.D through J.  You should note,
however, that product chemistry data are required for every
product, and the only acceptable responses are options
VI.D.I. (submit data) or VI.D.6. (cancellation of
registration).

     Failure to comply with the product-specific data
requirements for your products will result in suspension of
the product's registration.
                          -  24 -

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    VIII.   REQUIREMENT FOR SUBMITTAL OF REVISED LABELING

     FIFRA requires each product to be labeled with
accurate, complete and sufficient instructions and
precautions, reflecting the Agency's assessment of the data
supporting the product and its uses.  General labeling
requirements are set out in 40 CFR 156.10 (see Appendix II -
LABELING and SUMMARY).  In addition, labeling language
specific to products containing this pesticide is specified
in Section IV.D of this Registration Standard.  Responses to
this Registration Standard must include draft labeling for
Agency review.

     Labeling must be either typewritten text on 8-1/2 x 11
inch paper or a mockup of the labeling suitable for storage
in 8-1/2 x 11 files.  Draft labeling must indicate the
intended colors of the final label, clear indication of the
front panel of the label, and the intended type sizes of the
text.

     If you fail to submit revised labeling as required,
which complies with 40 CFR 156.10 and the specific
instructions in Section IV.D., EPA may seek to cancel the
registration of your product under FIFRA sec. 6.
                          - 25 -

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               IX.  INSTRUCTIONS FOR SUBMITTAL

     All submittals in response to this Registration
Standard must be sent to the following address:

          Office of Pesticide Programs
          OPP Mailroom (TS-767C)
          Environmental Protection Agency
          401 M St., SW
          Washington, B.C.  20460

          Attn:  Metalhyde Registration Standard

     All submittals in response to this Registration
Standard are non-fee items, including 90-day responses,
protocols and waiver requests, data, and revised labeling.
Submittals must be clearly identified as being in response to
the Registration Standard.  Under no circumstances may
Registration Standard responses be combined with other types
of filings for which fees are required.

A.   Manufacturing Use Products (MUPs) containing the subject
     pesticide as sole active ingredient.

     1.  Within 90 days from receipt of this document, you
must submit for each product subject to this Registration
Standard:

     a.   Generic Data Exemption Statement (EPA Form 8580-3),
          if applicable, or the "FIFRA Section 3(c)(2)(B)
          Summary Sheet"  (EPA Form 8580-1), with appropriate
          attachments.

     b.   Confidential Statement of Formula (EPA Form
          8570-4).

     c.   Evidence of compliance with data compensation
          requirements of FIFRA sec. 3(c)(l)(D).  Refer to 40
          CFR 152.80-152.99.

     2.  Within 9 months from receipt of this document you
must submit:

     a.   Application for Pesticide Registration (EPA Form
          8570-1).

     b.   Two copies of any required product-specific data
          (See Table B).

     c.   Three copies of draft labeling, including the
          container label and any associated supplemental
          labeling.

     d.   Product Specific Data Report (EPA Form 8580-4).

                          - 26 -

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     3.  Within the times set forth in Table A, you must
submit all generic data, unless you are eligible for the
generic data exemption.  If for any reason any test is
delayed or aborted so that the schedule cannot be met,
immediately notify the Agency of the problem, the reasons for
the problem, and your proposed course of action.

B.   Manufacturing Use Products containing the subject
     pesticide in combination with other active ingredients.

     1.  Within 90 days from receipt of this document, you
must submit:

     a.   Generic Data Exemption Statement (EPA Form 8580-3),
          if applicable, or the FIFRA sec. 3(c)(2)(B) Summary
          Sheet, with appropriate attachments (EPA Form
          8580-1).

     b.   Confidential Statement of Formula (EPA Form 8570-4)

     2.  Within 9 months of receipt of this document, you
must submit:

     Three copies of draft labeling, including the container
label and any associated supplemental labeling.

     3.  Within the time frames set forth in Table A, you
must submit all generic data, unless you are eligible for the
generic data exemption.  If for any reason any test is
delayed or aborted so that the schedule cannot be met,
immediately notify the Agency of the problem, the reasons for
the problem, and your proposed course of action.

C.   End Use Products containing the subject pesticide as
     sole active ingredient.

     1.  Within 90 days from receipt of this document, you
must submit:

     a.   Generic data exemption Statement (EPA Form 8580-3),
          if applicable, or the FIFRA Section 3(c)(2)(B)
          Summary Sheet, with appropriate attachments (EPA
          Form 8580-1).

     b.   Confidential Statement of Formula (EPA Form
          8570-4).

     2.  Within 9 months from receipt of this document you
must submit:

     a.   Two copies of any product-specific data, if
          required by Table C.
                          - 27 -

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     t>.   Product Specific Data Report (EPA Form 8580-4), if
          Table C lists required product-specific data.

     c.   Three copies of draft labeling, including the
          container label and any associated supplemental
          labeling.

     3.  Within the times set forth in Table A, you must
submit all generic data, unless you are eligible for the
generic data exemption.  If for any reason any test is
delayed or aborted so that the schedule cannot be met,
immediately notify the Agency of the problem, the reasons for
the problem, and your proposed course of action.

D.   End Use Products containing the subject active
     ingredient as one of multiple active ingredients

     1.  Within 90 days from receipt of this document, you
must submit:

     a.   Generic data exemption Statement (EPA Form 8580-3),
          if applicable, or the FIFRA Section 3(c)(2)(B)
          Summary Sheet, with appropriate attachments  (EPA
          Form 8580-1).

     b.   Confidential Statement of Formula (EPA Form
          8570-4).

     2.  Within 9 months from the receipt of this document,
you must submit:

     Three copies of draft labeling, including the container
label and any associated supplemental labeling.

     3.  Within the times set forth in Table A, you must
submit all generic data, unless you are eligible for the
generic data exemption.  If for any reason any test is
delayed or aborted so that the schedule cannot be met,
immediately notify the Agency of the problem, the reasons for
the problem, and your proposed course of action.

E.  Intrastate Products

     Applications for full Federal registration of intrastate
products were required to be submitted no later than July 31,
1988.  Unless an application for registration was submitted
by that date, no product may be released for shipment by the
producer after July 31, 1988.
                          - 28 -

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I. DATA APPENDICES
   - 29 -

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                            TGUIDE-1

                        GUIDE TO TABLES

     Tables  A,  B,  and  C contain listings of data requirements
for the pesticides covered  by  this Registration Standard.

     Table A 'contains  generic  data requirements that apply to
     the pesticide in  all products, including data requirements
     for which  a  "typical formulation"  is the test subst.ance.

     Table B contains  product-specific data requirements that
     apply only to a manufacturing use product.

     Table C contains  product-specific data requirements that
     apply only to an  end use  product.

     The data tables are generally organized according to the
following format:

1.  Data Requirement (Column 1).  The data requirements are
listed in the order in which they appear in 40 CFR Part 153.
The reference numbers  accompanying each test refer to the
test protocols  set out in the  Pesticide Assessment Guidelines,
which are available from the National Technical Information
Service, 5285 Port Royal Road, Springfield, VA  22161.

2.  Test Substance (Column  2).  This column lists the composition
of the test  substance  required to be used for the test, as
follows:

     TGAI =  Technical  grade of the active ingredient
     PAI =   Pure active  ingredient
     PAIRA = Pure  active ingredient, radio labeled
     TEP =   Typical end  use formulation
     MP =    Manufacturing use  product
     EP =    End use product

Any other test  substances,  such as metabolites, will be
specifically named in  Column 2 or in footnotes to the table.

3.  Use pattern  (Column  3).  This column indicates the use
patterns to  which  the  data  requirement applies.  Use patterns
are the same as those  given in 40 CFR Part 153.  The following
letter designations are  used for the given use patterns:

     A = Terrestrial,  food
     3 = Terrestrial,  non-food
     C = Aquatic,  food
     D = Aquatic,  non-food
     E = Greenhouse, food
     F = Greenhouse, non-food
     G = Forestry
     H = Domestic  outdoor
     I- = Indoor

Any other designations will b/a defined in a footnote to the table,

                         -  30  -

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                           TGUIDE-2

4-  Does EPA have data? (Column 4).  This column indicates  one
of  three answers:

     YES - EPA has data in its files that satisfy this  data
     requirement.  These data may be cited by other registrants
     in accordance with data compensation requirements  of
     Part 152. Subpart E.

     PARTIALLY - EPA has some data in its files, but such data
     do not fully satisfy the data requirement.   In some cases,
     the Agency may possess data on one of two required species,
     or may possess data on one test substance but not  all.
     The term may also indicate that the data available to
     EPA are incomplete.  In this case, when the data are
     clarified, or additional details of the testing submitted
     by the original data submitter, the data may be determined
     to be acceptable.  If this is the case, a footnote to
     the table will usually say so.

     NO - EPA either possesses no data which are sufficient
     to fulfill the data requirement, or the data which EPA
     does possess are flawed scientifically in a manner that
     cannot be remedied by clarification or additional  infor-
     mation.

5.  Bibliographic citation (Column 5).  If the Agency has
acceptable da'ta in its files, this column lists the identifying
number of each study.  This normally is the Master Record
Identification (MRID) number, but may be a GS number if no
MRID number has been assigned.  Refer to the Bibliography
Appendices for a complete citation of the study.

6.  Must additional data be submitted? (Column 6).  This
column indicates whether the data must be submitted to the
Agency.  If column 3 indicates that the Agency already has
data, this column will usually indicate NO.  If column 3
indicates that the Agency has only partial data or no data,
this column will usually indicate YES.  In some cases, even
though the Agency does not have the data, EPA will not require
its submission because of the unique characteristics of the
chemical;  because data on another chemical can be used to
fulfill the data requirement; or because the data requirement
has been waived or reserved.  Any such unusual situations
will be explained in a footnote to the table.

7.  Timeframe for submission (Column 7).  If column 5 requires
that data be submitted,this column indicates when the data
are to be submitted, based on the  issuance date of the Regis-
tration Standard.  The timeframes are those established either
as a result of a previous Data Call-in letter, or  standardized
timeframes established by PR Notice 85-5 (August 22, 1985).

8.  Footnotes (at the end of each table).  Self-explanatory.

                              - 31 -

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                                                                       TABLE A
                                GENERIC DATA REQUIREMENTS FOR THE METALDEHYDE TECHNICAL GRADE OF THE ACTIVE INGREDIENT













1
co
to

1




Data Requirement
Part 158 Suboart C -
Product Composition
61-2. Beginning Materials and Production Process
61-3. Formation of Impurities
Analysis and Certification of Product Ingredients
62-1 -Preliminary Analysis
Physical and Chemical Characteristics
63-2. Color
63-3. Physical State
63-4. Odor
63-5. Melting Point
63-6. Boiling Point
63-7. Density, Bulk Density or Specific Gravity
63-8. Solubility
63-9. Vapor Pressure
63-10. Dissociation Constant
63-11. Octanol/Uater Partitioning Coefficient
63-12. pH
63-13. Stability
Other Requirements;
64-1. Submittal of Samples
Test
Substance


TGAI
TGAI

TGAI

TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI or PAI
TGAI or PAI
TGAI or PAI
PAI
TGAI
TGAI

N/A
Does EPA have data
to satisfy this
requi rement?


No
No

No

No
No
No
No
No
No
No
No
No
No
No
No

N/A
Bibliographic
Citation


N/A
N/A

N/A

N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A

N/A
Must additional data be
submitted under FIFRA
Section 3
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                                                                                TABLE A.
                                         GENERIC DATA REQUIREMENTS FOR THE METALDEHYDE TECHNICAL GRADE OF THE ACTIVE INGREDIENT
         and (9)  a description of  the procedures used to assure consistent composition of the substance produced (quality control methods).

         3.   A discussion regarding the origin of the following potential  impurities  must  be provided:  (1)  each impurity associated with  the active  ingredient
         which was found to be present if  any analysis of the product conducted by or for the registrant, and (2) each impurity which the  registrant  has  reason
         to  believe may  be  present at a level equal to or greater than 0.1% (w/w) based on the composition of each starting material, intended and side reactions
         which may occur during production,  the  possible degradation of ingredients  after production,  post-production reactions  between  ingredients, possible
         contamination from packaging materials or production equipment, and process control, purification and quality control  measures.

         A.   Five or more representative samples must  be  analyzed for  the amount of active ingredient  and  each impurity present at 0.1X or greater.  If the product
         is  produced  by  a batch process, five separate batches  should be represented  in preliminary analyses.  Complete and detailed descriptions of the methods
         used for sample analysis  must be submitted,   including statements  of their precision and accuracy.  The preliminary analysis report  should include  the
         identity and quantity of each  ingredient for which  analysis  is conducted along with  the mean and relative standard deviation of  the  analytical results.
         Based on the preliminary  analysis,  a statement of the composition of the technical grade of active ingredient must be  provided.

 I        5.   Data on  melting point  are required if the technical chemical   is a solid at room temperature.

^       6.   Data on  boiling point  are required if the technical product is a liquid at room temperature.

 I        7.   Data on  octanol/water  partition coefficient are required if the technical chemical is organic and non polar.

         8.   Data on  pH  are required if the test substance is dispersible  in water.

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                                                                                 TABLE A
                                                                GENERIC DATA REQUIREMENTS FOR  METALDEHYDE
 I
00
Data Requirement
158.240
171-4.
171-4.
171-4.
171-4.
171-4.







Residue Chemistry
Qualitative Nature of the
residue (Metabolism)
- Plants
Qualitative Nature of the
residue (Metabolism)
- Livestock
Residue analytical methods
Storage stabi I i ty
Magnitude of the residue
in plantsS
Root/Tuber Vegetables Group
Leaves of Root/Tuber
Vegetables Group
Turnip Tops
Bulb Vegetables Group
Leafy Vegetables Group
Brassica Leafy Vegetables
Group
Legume Vegetables Group
Foliage of Legume
Vegetables Group
Fruiting Vegetables Group
Test Does EPA
Substance Have Data?

PAIRA Partially
PAIRA and plant No
metabolites
TGAI and Partially
metabolites
TEP and Partially
metabolites

TEP No
TEP No
TEP No
TEP No
TEP No
TEP No
TEP No
TEP No
Bibliographic
Citation

00138262.
N/A
00138262.
00138262.

N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Must additional data
be submitted?

Yes1
Yes2'3
Yes4'5'6
Yes7

Yes12
Yes13
YesU
Yes15
Yes16
Yes17
Yes18
Yes19
Time Frame
for Data
Submission

18 Months
18 Months
15 Months
18 Months

18 Months
24 Months
18 Months
18 Months
18 Months
18 Months
18 Months
18 Months
18 Months
24 Months

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                 TABLE A
GENERIC DATA REQUIREMENTS FOR HETALDEHYDE


Test Does EPA
Data Requirement Substance Have Data?
158.240 Residue Chemistry
Cucurbit Vegetables Group TEP No
Citrus Fruits Group TEP No
Pome Fruits Group TEP No
1 Stone Fruits Group TEP No
u>
en
Small Fruits and Berries TEP Partially
1 Group
Tree Nuts Group TEP No
Cereal Grains Group TEp No

Bibliographic Must additional data
Citation be submitted?

N/A Yes20
N/A Yes^1
N/A Yes23
N/A Yes2?
Yes26
00033213, 00138262 Ies27
N/A Yes29
N/A Yfl3°32
Time Frame
for Data
Submission

18 Months
18 Months
24 Months
18 Months
24 Months
18 Months
24 Months
18 Months
24 Months
18 Months
18 Months
24 Months
Grass Forage, Fodder, and       TEP
Hay Group

Non-Grass Animal Feeds Group    TEP

Herbs and Spices Group          TEP

Miscellaneous Commodities

- Artichoke                     TEP

- Asparagus                     TEP

- Avocados                      TEP
    No


Partially

    No



    No

    No

    No
  N/A


00127145

   N/A



   N/A

   N/A

   N/A
Yes33


Yes34
                                                           Yes
                                                              37
                                                           Yes
                                                              38
                                                           Yes
                                                              39
                                                                                     18 Months
                                                                                     18 Months

                                                                                     18 Months
                                                                                     24  Months
                          18 Months

                          18 Months

                          18 Months

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                                                                        TABLE A
                                                       GENERIC  DATA  REQUIREMENTS  FOR HETALDEHYDE


Data Requirement
- Bananas
- Mint

- Okra

Test
Substance
TEP
TEP

TEP

Does EPA
Have Data?
Partially
No

No

Bibliographic
Citation
00127144
N/A

N/A

Must additional data
be submitted?
Yes40
Yesg
Yes
Yes43
Time Frame
for Data
Submission
18 Months
18 Months
24 Months
18 Months
        - Tobacco                   PAIRA & TEP
171-4.  Magnitude of residue  in     TGAI or plant
        Meat/Milk/Poultry/Eggs     metabolites
                                                              No
No
                                                                                     N/A
                        N/A
Yes

Reserved46
18 Months
18 Months

18 Months
1.  Data depicting the distribution and metabolism of universally ring-labeled  I  Clmetaldehyde in or on three dissimilar food crops (e.g., a root crop,
a legume or cereal grain crop, and a leafy vegetable) are required.  If metabolism is not similar in the three crops, additional studies using other crops
may be  required.   A completely characterized  test substance representative of technical metaldehyde used  in commercial  formulations  must  be applied
foliarly and via  the  soil  several  times up to and including the day of harvest at rates sufficiently high to permit complete characterization of   C-
residues.   The  identities and quantities of  residues in  or  on  mature  plant parts  must  be determined  in order  to elucidate terminal  residues.
Representative samples must also be analyzed by proposed enforcement methods to ascertain that all residues of concern are determined.

2.. Metabolism studies utilizing runinants and poultry are required. Animals must be dosed orally for a minimum of 3 days with universally ring-labeled
[Clmetaldehyde  at a level sufficient  to make residue identification and quantification possible.  Milk and eggs must be collected twice a day during
the dosing period.  Animals must be sacrificed within 24 hours of the final dose.  The distribution and identity of residues must be determined in milk,
eggs, liver, kidney, muscle, and fat.  Samples from these studies must also be analyzed using enforcement methods to ascertain that the methods are capable
of adequately recovering and identifying all residues  of toxicological concern.

3.  Data depicting the qualitative nature of metaldehyde residues in swine are also required if the required metabolism studies with ruminants and poultry
reveal that the metabolism of metaldehyde  in these animals differs  from that in rats.

4.  The results of a successful  confirmatory trial of the Selim and  Seiber GLC method (or other proposed enforcement method) conducted by an independent
laboratory must be submitted for a representative fatty and  nonfatty plant-derived food commodity.  The rationale for selection of commodities must be
provided.  If the method must be significantly modified to accommodate analysis of  specific commodities, separate  confirmatory trials for each specific
commodity are required.  Results of at least one set  of samples per commodity (a total of six samples,  including two control samples, two control samples
fortified at the  tolerance level,  and two control samples fortified at 2-5 times the tolerance level)  must be submitted.  No  more than three sets of
samples per commodity may be tested to achieve successful recovery rates of 70-120% with negligible interference compared tot he established tolerance(s).
For additional details of data requirements,  refer to PR Notice 88-5, Tolerance Enforcement Methods -  Independent Laboratory Confirmation by Petitioner.

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                                                                        TABLE A
                                                       GENERIC DATA REQUIREMENTS FOR METALDEHYDE
5.  The nature of the residue in plants and animals has not been adequately described.   If  the metabolism studies  requested  in the section "Qualitative
Mature of the Residue in Plants" reveal the presence of  additional metabolites of concern  in  or on plant commodities, additional validated methods for
data collection and tolerance enforcement will be required.  Also, if the metabolism studies requested in the section  "Qualitative Nature of Residue in
Animals" reveal  the  presence of residues of concern in  meat,  milk,  or eggs, validated methods for data collection  and tolerance enforcement will be
required.

6.  Representative samples of fatty and nonfatty plant  commodities bear-ing  residues of metaldehyde must be subjected to multiresidue protocols I and III
which are available from the National  Technical  Information Service under Order No.  PB203735/AS. If residues of concern are found in animal commodities,
these commodities must also  be  subjected to analysis using multiresidue protocols I and III.

7.  All  residue  data requested  in  this Standard must accompanied by information specifying the storage intervals and conditions  for samples analyzed.
Data must also be provided which depict the decline  in metaldehyde residues  of concern in  commodities stored under the range of conditions and for the
range of intervals specified.   One representative sample  from  each  crop group bearing field-weathered  residues  or fortified  samples  must  be analyzed
immediately after  harvest  or fortification and again  after storage  intervals that  represent actual  residue sample storage conditions and  allow for
reasonable unforeseen delays in sample analysis.  For additional guidance on conducting storage stability studies, the Registrant is  referred to an August
1987 "Position Document on the  Effects of Storage on Validity of  Pesticide Residue Data" available from NTIS under order no. PB88112362/AS.

8.  It should be noted that  data gaps exist for  plant  and  animal  metabolism  and storage stability.  Since the data required for individual  conmodities
are dependent on the metabolism data,  that  the required metabolism data must  be obtained and submitted for review prior to  initiation of residue trials.

9.  Data are  required depicting metaldehyde  residue of  concern  in  or on  (1)  carrots,  radishes,  and potatoes harvested after the  last multiple  soil
applications with a  pelleted/tableted (p/t)  formulation at 20  Ib ai/A as  a  broadcast soil  treatment  repeated at  14-day intervals and  (2) sugar beets
harvested 6 days following  the last of multiple broadcast soil applications  (7-day intervals) with the 4X  P/T formulation at 2.4  Ib ai/A.  Radish,  carrot,
and potato samples must be collected immediately after the last application and at  several  closely spaced intervals thereafter so that  a residue uptake
and decline curve can be established.   Tests  for carrots,  potatoes,  and radishes must  be conducted in states  that represent the major growing  regions
for each crop according to the  latest edition of Agricultural Statistics (USDA) or  the  1982 Census of Agriculture (U.S. Department  of Commerce). Sugar
beet tests must be conducted in OR.

10. Data depicting residues  of  concern in granules, chips, wet  peel,  and dry peel processed from potatoes bearing measurable weathered residue must be
submitted.  If residues concentrate, appropriate food/feed additive  regulations must be proposed.

11. Data depicting metaldehyde  residues of  concern in dehydrated pulp, molasses, and refined sugar processed from sugar  beets bearing measurable weathered
residue must be submitted.   If  residues concentrate, appropriate  food/feed additive regulations must be proposed.

12.  Data are required depicting metaldehyde residues  of concern  in  or on  (i) turnip tops harvested following the last of multiple applications with a
P/T formulation at 20 Ib ai/A applied as a broadcast soil application at  14-day intervals and  (ii) sugar beet tops harvested 6 days following the  last
of multiple broadcast soil applications (7 day intervals) with  the 4% P/T  formulation at 2.4 Ib ai/A.  Turnip top samples must be collected immediately
after the last application  and  at  several  closely spaced intervals thereafter  such  that  a  residue uptake and  decline curve can be established.  Tests
on turnips must be conducted in states that represent the major  growing regions for each crop according to the latest edition of Agricultural statistics
(USDA) or the 1982 Census of Agriculture (U.S. Dept. of  Commerce. Tests on  sugar beets tops must be conducted in OR.

13.  Data are required depicting metaldehyde  residue  of concern in or on onions (green and  dry bulb) and garlic following the  last  of  several  soil
treatments with a P/T formulation at 20 Ib  ai/A applied as  a  broadcast soil treatment using ground equipment  repeated at  14-day intervals.  Samples must
be collected immediately after  the last application and at several closely spaced  intervals thereafter such  that a  residue uptake and decline curve can
be established.  Test must  be conducted in  states that  represent the  major  growing regions for each crop according to the latest edition of Agricultural

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                                                                                   TABLE A
                                                                   GENERIC DATA REQUIREMENTS FOR METALDEHYDE
            Statistics. (USDA) or the 1982 Census of Agriculture (U.S. Dept. of Commerce).

            14.  Data  are  required depicting metaldehyde residue  of  concern in or on celery,  lettuce  (head and leaf) and spinach following  the  last  of several
            applications with a P/T formulation at 20 Ib ai/A made as a broadcast soil treatment using ground equipment and repeated at 14-day intervals.   Samples
            must be collected immediately after the last  application and at several closely spaced intervals thereafter such that  a residue uptake and decline curve
            can be  established.   Tests must  be conducted in states  that represent the  major  growing  regions for each  crop according to the latest  edition of
            Agricultural Statistics (USDA) or the 1982 Census of Agriculture (U.S. Dept.  of Conmerce).

            15.  Data are required depicting metaldehyde  residue of concern  in or on broccoli,  cabbage  and mustard greens following the last  of several broadcast
            soil applications with a P/T formulation at 20 Ib ai/A repeated at  14-day intervals.  Samples must be collected immediately after  the  last application
            and at several closely spaced intervals thereafter such that  a residue uptake and decline curve can be established.  Tests must be conducted in states
            that represent the major growing regions for each crop according to  the latest edition of Agricultural Statistics (USDA) or the 1982 Census of Agriculture
            (U.S. Dept. of Commerce).

            16.  Data are required depicting metaldehyde residue of  concern in or on beans and peas (a succulent and dry variety of each)  following the last  of several
            soil applications made at 14-day intervals with a P/T  formulation at 20  Ib ai/A.  Samples must be collected immediately after  the  last  application  and
            at several  closely spaced intervals thereafter such that a residue uptake and decline curve  can be established.  Tests must be conducted in states that
            represent the major growing regions for each  crop according  to the latest  edition of Agricultural  Statistics  (USDA)  or  the 1982 Census of Agriculture
 I           (U.S. Dept. of Commerce).

<-°          17.  Data are  required depicting metaldehyde residue of concern in or on bean vines and hay and pea vines and hay harvested following the last of  multiple
00          soil treatments with a  P/T  formulation at 20 Ib ai/A  applied as  a broadcast soil treatment repeated at 14-day intervals.  Samples must be collected
 I           immediately after the last application and at several closely spaced intervals  thereafter such that a residue uptake and decline curve can be established.
            Tests must  be  conducted in states that represent the major  growing regions for each crop according to the latest  edition of Agricultural Statistics (USDA)
            or the 1982 Census of Agriculture (U.S. Dept. of Commerce)

            18.  Data are required depicting metaldehyde residue of concern  in or on peppers  and tomatoes  harvested following the  last of  multiple broadcast soil
            treatments with a P/T formulation at 20 Ib ai/A.   Samples must  be collected immediately after  the last application and at several closely spaced intervals
            thereafter such that a residue uptake and decline curve can be established.   Tests must be conducted in states that represent the major growing regions
            for each crop according to the latest edition of Agricultural Statistics (USDA) or the 1982 Census of Agriculture (U.S.  Dept.  of Commerce).

            19.  Data  are  required  depicting  metaldehyde residues  of concern in dry pomace,  puree,  catsup,  and  juice  processed  from  tomatoes bearing measurable,
            weathered residues.  If residues concentrate  in any product,  an appropriate food/feed additive regulation must be proposed.

            20.  Data are required depicting metaldehyde residue of concern  in or on cucumbers,  melons  (cantaloupe or muskmelon),  and sunnier  squash  following  the
            last of several broadcast soil application with a P/T formulation at 20 Ib ai/A applied at  14-day intervals.  Samples must be collected immediately after
            the last application and at several closely spaced intervals thereafter such that  a  residue  uptake and decline curve can be established.  Tests must be
            conducted in states that represent the major  growing regions  for each crop according to the latest edition of Agricultural Statistics (USDA)  or  the 1982
            Census of Agriculture (U.S. Dept. of Commerce).

            21.  Data are required depicting metaldehyde residue of concern in  or on grapefruits, lemons,  and oranges following the last of several broadcast  soil
            applications with  a P/T  formulation at 1.5 Ib ai/A.   Samples must be collected immediately after the last application and at  several  closely spaced
            intervals thereafter such that a residue uptake and decline curve can be established.  Tests must be conducted in states that  represent the major growing
            regions for each crop according to the latest edition of Agricultural Statistics (USDA) or the 1982 Census of Agriculture (U.S. Dept.  of Conmerce).

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                                                                                              TABLE A
                                                                 GENERIC DATA REQUIREMENTS FOR METALDEHYDE
          22.  Data are required depicting metaldehyde residues  of concern  in wet and dried pulp,  oil molasses, and juice processed from citrus  bearing measurable,
          weathered residues.   If  residue concentrate in  any product,  an appropriate food/feed additive  regulation must be proposed.

          23.  Data are required depicting metaldehyde residue of concern in or on apples  and pears following the last of several  broadcast  soil applications with
          a P/T formulation at  1.5  Ib ai/A.  Samples  must be collected immediately after  the  last application and at several closely spaced intervals thereafter
          such that a  residue uptake and decline curve can be established.  Tests must be conducted in states that represent the major growing regions for each
          crop according to the latest edition of Agricultural  Statistics  (USDA)  or the 1982 Census of Agriculture (U.S. Dept. of Commerce).

          24.  Data depicting metaldehyde residues  of concern in juice, and wet and dry pomace processed from apples bearing measurable, weathered residues are
          required.  If residue concentrate  in any  product,  an  appropriate food/feed additive regulation must be proposed.

          25.  Data are required depicting metaldehyde residue of concern in  or  on cherries  (sweet and  sour),  plums,  and peaches following the  last  of several
          broadcast soil treatments with a P/t formulation at 1.5  Ib  ai/A.  Samples must be collected immediately after the  last  application  and at several closely
          spaced intervals thereafter such that a residue uptake and decline curve can be  established.  Tests must be conducted  in states that represent the major
          growing regions for each crop according to the latest edition  of Agricultural Statistics  (USDA) or the 1982 Census of Agriculture (U.S. Dept. of Commerce).

 I         26.  Data are required depicting metaldehyde residues  of concern  in dried prunes  processes from plums bearing measurable  weathered  residues.  If residues
          concentrate  in dried  prunes, an appropriated food  additive regulation must be proposed.
OJ
vo
          27.  Data are required depicting metaldehyde residue of concern in or on (i) blackberries and grapes harvested after the last of multiple broadcast soil
 I         applications with the 2.75X P/T made at 7-day intervals at  1.5 Ib ai/A,  (ii) blueberries harvested after the last or multiple broadcast soil application
          with the 10% G made at 7-day intervals at 1.6 Ib ai/A , (iii) strawberries harvested 6  days after  the  last of multiple applications at 14-day intervals
          with a G formulation  at 5.23  Ib ai/A,  and (iv)  strawberries harvested  after the last of multiple soil-directed applications at  21-day intervals with
          the 3.25% EC formulation at 1.12 Ib ai/A (4 gal product/A).  Samples of blackberries, grapes, blueberries, and strawberries (iv only) must be collected
          immediately after the last application  and at several closely spaced intervals thereafter such that a residue uptake and decline curve can be established.
          Tests must be conducted in states that represent the major growing regions for each crop according to the latest edition of Agricultural Statistics (USDA)
          or the 1982  Census of Agriculture  (U.S. Dept. of Commerce).

          28.  A processing study depicting metaldehyde residues of concern in products (raisins,  dry pomace,  raisin waste, and juice)  processed  from grapes bearing
          measurable,  weathered residues is  required.   If residues concentrate in any product, appropriate  food/feed additive regulations must be proposed.

          29.  Data depicting metaldehyde residue of concern  in or on almonds, pecans  and walnuts harvested following the last of  multiple broadcast soil treatments
          with the 2% G MAI formulation  at 0.44 Ib ai/A applied at 14-day  intervals using  ground  equipment.   Samples must be collected  immediately after the last
          application and at several closely spaced intervals thereafter such that a residue uptake and decline curve can be established.  Tests must be conducted
          in states that represent  the major growing regions for each crop according to the latest edition of Agricultural Statistics (USDA)  or  the 1982 Census
          of Agriculture (U.S.  Dept. of  Commerce).

          30.  Data depicting metaldehyde residues of concern in or on (i) wheat grain harvested  30 days  after the last of several broadcast soil applications of
          a G formulation  at 2.4 Ib ai/A, (ii) wheat grain harvested after the last of several  broadcast soil applications with  a G formulation at 2.4 Ib ai/A,
          (ii) wheat grain harvested after the last of  several  broadcast soil  applications with a G formulation at 1.5 Ib ai/A [wheat grown for seed], and (iii)
          corn grain (field corn)  and sweet  corn kernels  plus cob with husks removed harvested after the last of several broadcast soil applications made at 14-
          day intervals with a  P/T formulation at 20 Ib ai/A.   Samples of wheat grown for seed (ii) and corn must be collected immediately after the last application
          and at several closely spaced  intervals thereafter such that a residue  uptake and decline curve can be established.  Tests must be conducted in states

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                                                                                               TABLE A
                                                                  GENERIC DATA REQUIREMENTS FOR HETALDEHYDE
            that represent the major growing regions for each crop according to the latest edition of Agricultural Statistics (USDA) or the 1982 Census of Agriculture
            U.S. Dept.  of  Commerce).

            31.  A processing study is required depicting metaldehyde residues of concern in wet milled products (starch, crude oil, and refined oil) and in dry milled
            products  (grits, meal, flour, crude and  refined oils),  and grain dust from the  processing  of  field corn bearing measurable,  weathered residues.   If
            residues  concentrate in any product,  appropriate food/feed additive regulations must  be proposed.

            32.  A processing study depicting metaldehyde residues of concern in milled products (bran, flour, middling and shorts) and grain dust from the processing
            of wheat  bearing measurable, weathered residues is required.  If residues  concentrate  in any product, appropriate  food/feed additive regulations must
            be proposed.   [Wheat data will  be  translated to oats  and barley].

            33.  Data are required depicting metaldehyde residues  of  concern  in or on grass hay, forage and seed (Bermuda grass, bluegrass, and bromegrass or fescue)
            harvested after  the last of several  broadcast soil  application with a G formulation made at  7-day intervals  at  1.5  Ib ai/A.  Samples must be collected
            immediately after the last application and at several closely spaced intervals thereafter such that a residue uptake and decline curve can be established.
            Tests must  be conducted in states that  represent the major growing regions for each crop according to the latest edition of Agricultural Statistics (USDA)
            or the  1982 Census  of Agriculture  (U.S. Dept. of Commerce).

            34.  Data are  required depicting metaldehyde residue  of  concern  in or on alfalfa and  clover  hay,  forage,  and seed harvested after the last of multiple
 I           soil  applications with the 4X G formulation at 2.4 Ib ai/A applied as broadcast  soil  applications  and  repeated  at 7-day  intervals.   Samples must be
            collected immediately after the last application and at  several closely spaced intervals thereafter such  that a residue  uptake and decline curve can be
**          established.   Test  must be conducted in states that represent the major growing regions for each crop according  to  the latest edition of Agricultural
°          Statistics  (USDA) or the 1982 Census of Agriculture (U.S.  Department of Commerce).
 I
            35.  Data are  required depicting metaldehyde residue  of  concern  in or on coriander (seeds and foliage),  chives, dill (seeds and foliage), oregano, and
            sage harvested 6 days following  the  last  of multiple soil  treatments with the 4X G formulation at 2.4 Ib  ai/A applied as a broadcast treatment prior to
            the  formation  of edible parts, and as a band application following edible  part  formation, at  7-day intervals  using ground  equipment.   Tests must be
            conducted in states that represent the major growing regions for each crop according to  the latest edition of Agricultural statistics (USDA)  or the 1982
            Census  of Agriculture (U.S. Department of Commerce).

            36.   Data are required depicting metaldehyde residues of  concern in or on  dried  herbs  and spices.   If  residues  concentrate in any herb or spice, an
            appropriate food additive regulation must be proposed.

            37.  Data are  required depicting metaldehyde residue  of  concern  in or on artichokes harvested following  the  last  of  multiple broadcast soil  treatments
            with a  P/T  formulation at 20 Ib ai/A and  repeated at 14-day intervals.  Samples must be collected immediately after  the  last application  and at several
            closely spaced intervals thereafter so that a residue uptake and decline curve can be  established.  Tests must be conducted  in states that represent the
            major growing  regions for artichokes according to the  latest edition of Agricultural Statistics (USDA) or  the  1982 Census of Agriculture (U.S.  Department
            of Commerce).

            38.  Data are  required depicting metaldehyde residue of concern in or on asparagus harvested following  the  last  of  multiple broadcast soil  treatments
            with a  P/T  formulation at 20 Ib ai/A and  repeated at 14-day intervals.  Samples must be collected immediately after  the  last application  and at several
            closely spaced intervals thereafter so that a residue uptake and decline curve can be  established.  Tests must be conducted  in states that represent the
            major growing  regions for artichokes according to the  latest edition of Agricultural Statistics (USDA) or  the  1982 Census of Agriculture (U.S.  Department
            of Commerce).

            39.  Data are required depicting metaldehyde residue of concern in or on avocados harvested following the  last of multiple broadcast  soil treatments with

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                                                                       TABLE A
                                                       GENERIC DATA REQUIREMENTS FOR METALDEHYDE
a P/T formulation at  1.5  Ib ai/A  using  ground equipment.  Samples must be collected immediately after the last application and at several closely spaced
intervals thereafter so that a residue uptake and decline curve can be established.  Tests must be conducted in states that  represent the major growing
regions for avocados according to the latest edition of Agricultural Statistics (USDA) or the 1982 Census  of Agriculture  (U.S. Department of Commerce).

40.  Data are required depicting  metaldehyde residue of concern in or on bananas harvested following the last of multiple  broadcast soil treatments with
the  10% G  formulation  at 4.8  Ib  ai/A and repeated at  14-day  intervals using  ground  equipment.    Samples  must be collected immediately after the last
application and at several closely spaced intervals  thereafter  so that a residue uptake and decline curve can be established.  Tests must be conducted
in states  that represent the major growing  regions  for bananas  according to the latest edition of Agricultural Statistics (USDA) or the 1982 Census of
Agriculture (U.S. Department of Commerce).

41.  Data are  required depicting metaldehyde residue of concern in or on spearmint or peppermint harvested 30 days following the last of multiple broadcast
soil treatments with the 4X P/T formulation at 2.4  Ib ai/A, repeated at 7-day intervals.  Tests must be conducted in OR.

42.  Data  are required depicting metaldehyde  residues of  concern in or on spend  hay and oil processed from fresh mint  bearing measurable  weathered
residues.  If residues concentrate in any product,  an appropriate food/feed additive  regulation must be proposed.

43.  Data  are required depicting metaldehyde residue of concern in or on okra harvested following the last  of multiple broadcast soil  treatments  with
a P/T formulation at 20 Ib ai/A  using  ground equipment applied at 14-day intervals.   Samples must be collected immediately after the  last  application
and at several closely spaced  intervals thereafter so that a residue uptake and decline curve can be established.  Tests must  be conducted in states  that
represent the major growing regions for okra according to the latest edition  of Agricultural Statistics (USDA) or the 1982 Census of Agriculture  (U.S.
Department of Commerce).

44.  Data are  required depicting metaldehyde residue of concern in or on green and cured or dry tobacco harvested following  the last of multiple broadcast
soil treatments with the 3.25X P/T formulation at 1.4  Ib ai/A using ground equipment.   Samples must be collected immediately after  the  last  application
and at several closely spaced intervals thereafter  so that a  residue uptake and decline curve can be established.

45.  If metaldehyde  residues  of concern are > 0.1  ppm in or on dry  or  cured tobacco, pyrolysis products derived from  the  active ingredient must  be
characterized and the level of the residue  in'smoke must be quantified.  Universally  ring-labeled [  C] metaldehyde must  be used for  identification of
pyrolysis products.

46.  Data  requirements regarding the magnitude of the residue in animal  products  will not be determined until all  requested data  regarding metabolism
in animals and magnitude of residue in feed items have been received.

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 I

to
                                                                                  Table A
                                                                 Generic Data Requirements for Netaldehyde


Data Requirement Composition
Section 158.290 Environmental Fate
DEGRADATION STUDIES - LAB;
161-1 - Hydrolysis
PHOTOOEGRADATION
161-2 - In Water
161-3 - On Soil
161-4 - In Air
METABOLISM STUDIES - LAB;
162-1 - Aerobic Soil
162-2 - Anaerobic Soil
162-3 - Anaerobic Aquatic
162-4 - Aerobic Aquatic
Does EPA
Have Data to
Use Satisfy This Bibliographic
Patterns Requirement? Citation


A,B,E,F.H,I No

A,B No
A No
A No

A,B,E,F,H No
A No
No
No
Must Additional
Data Be Submitted
Under FIFRA Section
3(c)(2)(B)7


Yes

Yes
Yes
Reserved

Yes
Yes
No2
No2

Timeframe
For
Submission


9 months

9 months
9 months


27 months
27 months


           MOBILITY STUDIES:

           163-1  -  Leaching and
             Adsorpt i on/Desorpt i on

           163-2  -  Volatility (Lab)
A,B,E,F,H


A.E.F
                       No
No
                                                       Yes
                                Yes
                                                                      12 months


                                                                      9 months

-------
                                                                       Table A
                                                     Generic Data Requirements  for Metaldehyde
Use
Data Requirement Composition Patterns
Section 158.290 Environmental Fate (cont'd)
163-3 - Volatility (Field) A,E,F
DISSIPATION STUDIES - FIELD;
164-1 - Soil A,B,H
164-2 - Aquatic (Sediment)
164-3 - Forestry
164-4 - Combination and
Tank Mixes
164-5 - Soil, Long-Term A
ACCUMULATION STUDIES:
165-1 - Rotational Crops A
(Confined)
165-2 - Rotational Crops A
(Field)

Does EPA
Have Data to
Satisfy This
Requirement?

No

No
No
No
No
No

No
No
kl«
Must Additional
Data Be Submitted
Bibliographic Under FIFRA Section
Citation 3(c)(2)(B)7

Reserved/ 1

Yes
No2
No3
No4
Reserved/5

Yes
Reserved/6
u.,2
Timeframe
For Data]/
Submission



27 Months





39 Months


165-3 - Irrigated Crops

165-4 - In Fish

165-5 - In Aquatic Nontarget
        Organisms
A.B.D

A,B,D
NO

NO
Yes

 Reserved/7
                                                                                       12 Months

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                                                                        Table A
                                                            Generic Data Requirements for Netaldehyde
Data Requirement
Composition
  Use
Patterns
Does EPA
Have Data to
Satisfy This
Requirement?
Bibliographic
  Citation
Must Additional
Data Be Submitted
Under FIFRA Section
3(cH2KB)?
Timeframe
   for
Submission
40 CFR 158.390

Reentry Protection:

132-1 - Foliar Dissipation

132-1 - Soil Dissipation

133-3 - Dermal Exposure

133-4 - Inhalation Exposure

Section 158.440 Spray Drift

202-1 - Spray Field Evaluation

202-1 - Drift Size Spectrum

Ground-Water Monitoring
    TEP          A,B,E,F,H,I    No

    TEP          A,B,E,F        No


    TEP       A,B,C,DfE,F,G,HfI No

    TEP       A,B,C,D,E,F,G,HfI No
                    A,B         No

                    A,B         No

                 B,C,E,F,H      No
                                                           Reserved
                                                           Reserved
                                                           Reserved

                                                           Reserved,
                                                           Reserved^/

                                                           Reserved^/
                                                                       FOOTNOTES

1/       This data requirement is reserved pending evaluation of the  laboratory volatility data.

2/       Data are not required because there are no aquatic or aquatic impact uses.

3/       Based on use pattern, study is not required.

l\l       Currently not imposed.

5/       This data  requirement  is  reserved pending  evaluation of  the aerobic  soil metabolism,  leaching, and dissipation data.

6/       Pending  evaluation  of  the confined crop rotation data and/or  toxicological data.

7/       This data  requirement  is  deferred pending  the evaluation of the  fish accumulation study and ecological issues.

8/       Spray drift data  requirements are deferred pending evaluation of ecological effect issues.

9/       There are  no data at present time to trigger  ground water  monitoring studies.

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                 Table A
Generic Data Requirements for Metaldehyde
Data
Requirement Composition
Use
Patterns
Does EPA
Have Data to
Satisfy This
Reaui rement?
Must Additional
Data Be Submitted
Bibliographic Under FIFRA Section
Citation 3(c)(2)(B)?
Timeframe
For Data
Submission
Section 158.340 Toxicology
ACUTE TESTING;
81-1
81-2
81-3
81-4
81-5
81-6
81-7
- Acute Oral - Rat
- Acute Dermal
- Acute Inhalation - Rat
- Eye Irritation - Rabbit
- Dermal Irritation- Rabbit
- Dermal Sensitization
Guinea Pig
- Acute Delayed
Neurotoxicity - Hen
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
A,B,E,F,H,I
A,B,E,F,HfI
A,B,E,F,H,I
A.B,E,F,H,I
A,B,E,F,H,I
A,B,E,F,H,I

N/A
Partially
Partially
Partially
No
Partially
No
No
00131435, 00131969 Yesl/
00131434 Yesl/
00131429 Yesl/
Yes
00131971 Yesl/
Yes
No2/
9 Months
9 Months
9 Months
9 Months
9 Months
9 Months

SUBCHRONIC TESTING:
82-1
- 90-Day Feeding -
Rodent
Nonrodent
TGAI
TGAI
A,B,E,F,H,I
A,B,E,F,H,I
No
No
No3/
No3/


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                  Table A
Generic Data Requirements for Metaldehyde
Data Requirement
Section 158.340 Toxicology
SUBCHRONIC TESTING (cont'd);
82-2 - 21 -Day Dermal
82-3 - 90-Day Dermal
82-4 - 90-Day Inhalation
82-5 - 90 -Day Neurotoxicity
CHRONIC TESTING:
83-1 - Chronic Testing
-Rodent
-Nonrodent
83-2 - Oncogenicity Study
-Rat
-Mouse
83-3 -Teratogenicity
-Rat
-Mouse
Composition

TGAI
TGAI
TGAI
TGAI

TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
Does EPA
Have Data to
Use Satisfy This
Patterns Requirement?

A,B,E,F,H,I No
A,B,E,F,H,I No
A,B,E,F,H,I No
N/A No

A,B,E,F,H,I No
A,B,E,F,H,I No
A,B,E,F,H,I No
A,B,E,F,H,I No
A,B,E,F,H,I No
A,B,E,F,H,1 No
Must Additional
Data Be Submitted
Bibliographic Under FIFRA Section
Citation 3(c)(2)(B)?

Yes
No4
No5
No6

Yes
Yes
Yes
Yes
Yes
Yes
Timeframe
For Data
Submission

9 Months




50 Months
50 Months
50 Months

15 Months
15 Months

-------
                                  Table A
             Generic Data Requirements for Metaldehyde
Data Requirement
Section 158.340 Toxicology
CHRONIC TESTING (cont'd);
83-4 - Reproduction
MUTAGENICITY TESTING;
84-2 - Gene Mutation
84-2 - Chromosome Aberration
84-4 - Other Mechanisms of
Does EPA
Have Data to
Use Satisfy This
Composition Patterns Requirement?
TGAI A,B,E,F,H,I No
TGAI A,B,E,F,H,I Mo
TGAI A,B,E,F,H,I Partially
TGAI A,B.E,F,H,I No
Must Additional
Data Be Submitted
Bibliographic Under FIFRA Section
Citation 3(c)(2)(B)?
Yes
Yes
00163832 Yes7
Yes
Timeframe
For Data 	
Submission
39 Months
9 Months
ii
u
       Mutagenicity

SPECIAL TESTING;

85-1 - General Metabolism
PAI or PAIRA
No
                                                                          Yes
                                                                                                   24  Months

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                                                                                  TABLE A
                                                                GENERIC DATA REQUIREMENTS  FOR HETALDEHYDE
                                                                             FOOTNOTES  (Cont.)


          1/   This requirement may be satisfied if the purity of the test material used in the existing study is submitted.

          2/   This test is required only for compounds which are organophosphate inhibitors of cholinesterase,  or related to
               such inhibitors or metabolites of such inhibitors.  Metaldehyde is not an organophosphate; therefore,  a study is
               not required.

          3/   Data requirement waived based on the requirement for a chronic oral toxicity study in rodent and nonrodent.

          4/  This study is not required because existing acceptable use patterns should not result in repeated or extended
               human skin contact.

          5/  This study is not required because existing acceptable use patterns should not result in repeated or extended
               human contact by the inhalation route.

          6/  Since an acute neurotoxicity study is not required for this compound and there is no evidence of neurotoxicity
               in mammalian species from the available data, this study is not required.

'         71  The portion of the study performed in the absence of a metabolic activation system is acceptable and need not
£*             be repeated.  However, the portion of the study performed in the presence of the metabolic activation  system is
oo             not acceptable because neither cytotoxicity not the limit of solubility was demonstrated.

 I

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                   Table A
Generic Data Requirements for MetaVdehyde
Data Requirement
Composition
Use
Pattern
Does EPA Have
Data to Satisfy
This Require-
ment? (Yes,
No Partially)
Must Additional
Data Be Submitted Timeframe
Bibliographic Under FIFRA Section For Data
Citation 3(c)(2)(B)7 Submission
Section 158.490 - Wildlife and Aquatic Organisms
SPECIAL TESTING
70-1 - Residue Monitoring
AVIAN AND MAMMALIAN TESTING
71-1 -Avian Acute Oral Toxicity
71-2 - Avian Subacute Dietary
Toxicity
- Upland Game Bird
- Waterfowl
71-3 - Wild Mammal Toxicity
71-4 - Avian Reproduction
- Upland Game Bird
- Waterfowl
71-5 - Simulated Field Testing
- Mammals
- Birds
- Actual Field Testing
- Mammals
- Birds

TEP

TGA1
TGAI
TGAI
TGAI
TGAI
TGAI
TEP
TEP
TEP
TEP

A.B.H

A,B,F,H
A.B.F.H
A.B,F,H
A,B,F,H
A.B.F.H
A.B.F.H
A.B.H
A.B.H
A,B,H
A.B.H

No

No
No
No
No
No
No
No
No
No
No

Reserved_

Yes 9 Months
Yes 9 Months
Yes 9 Months
No2
Yes 24 Months
Yes 24 Months
Reserved^
Reserved^
Reserved ,,
Reserved^'

-------
o
 I
                                                                      Table A
                                                     Generic Data Requirements  for Metaldehyde
Use
Data Requirement Compos it ion Pattern
Section 158.490 - Wildlife and Aquatic Organisms
AQUATIC ORGANISM TESTING
72-1 - Acute Toxicity to
Freshwater Fish Species
- Coldwater TGAI A.B.F.H
- Warmwater TGAI A,B,F,H
Does EPA Have
Data to Satisfy
This Require-
ment? (Yes, Bibliographic
No, Partially) Citation
No
Yes 0090362
Must Additional
Data Be Submitted
Under FIFRA Section
3(cH2HB)?
Yes
No
Timeframe
For Data
Submission
9 Months
72-2 - Acute Toxicity to
       Freshwater Invertebrates       TGAI
72-3 - Acute Toxicity to
       Estuarine and Marine
       Organisms
       - Fish
       - Mollusk
       - Shrimp

72-4 - Fish Early Life Stage
       and Aquatic Invertebrate
       Life Cycle
       - Freshwater Species
       - Estuarine/Marine
72-5 - Fish Life Cycle                TGAI
                                                             A,B,F,H
                                                                        No
                                                                                                                           Yes
TGAI
TGAI
TGAI
TGAI
TGAI
A,B.F,H
A,B,F,H
A,B,F,H
A.B.H
A,B,H
No
NO
No
No
No
                                                                                                                             Reserved
                                                                                                                             Reserved
                                                                                                                             Reserved
                                                                                                                             Reserved
                                                                                                                             Reserved
                                                                                                                                     V
                                                               A,B,H
                                                                          No
                                                                                                                   Reserved
                                                                                                                           V
                                                                                                                                                    9 Months

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 I
ui
                                                                                  Table A
                                                                  Generic Data Requirements for Metaldehyde


Data


Requirement
Section 158.490 - Wildlife and^
72-6
72-7



- Aquatic Organisms
- Simulated Field Testing
- Aquatic Organisms
- Actual Field Testing
- Aquatic Organisms
Does EPA Have
Data to Satisfy
This Requi re-
Use merit? (Yes, Bibliographic
Composition Pattern No. Partially) Citation
Aquat i c Organisms
TEP A,B,H . No
TEP A,B,H No

TEP A.B.H No

Must Additional
Data Be Submitted Timeframe
Under F1FRA Section For Data
3(c)(2)(B)7 Submission

No3
Reserved1 '

Reserved17

            I/ Data  requirement reserved pending  results  of  avian/aquatic  organism toxicity and environmental fate studies.
            2/ Based on use patterns,  this  study  is  not required.
            3/ See environmental fate  data  tables (Section 158.290,  Guideline 165.50).

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                                                                       Table A
                                                   Generic Data Requirements for Metaldehyde
Does EPA Have
Data to Satisfy Must Additional
This Require- Data Be Submitted Timeframe
Use ment? (Yes, Bibliographic Under FIFRA Section For Data
Data Requirement Composition Pattern No. Partially) Citation 3(c)(2)(B)7 Submission
Section 158.540 - Plant Protection


121-1

- Target Area Phytotoxicity EP A,B,F,H No
Tier 1
No1/

Nontarget Area Phytotoxicitv



1
(ji
to
1




121-1
122-1
122-2
123-1
123-1
123-2

124-1
124-2
- Seed Germination/ TGAI A.B.F.H No
Seedling Emergence
- Vegetative Vigor TGAI A.B.F.H No
- Aquatic Plant Growth TGAI A,B,F,H No
Tier II
- Seed Germination/ TGAI A.B.F.H No
Seedling Emergence
- Vegetative Vigor TGAI A,B,F,H No
- Aquatic Plant Growth TGAI A.B.F.H No
Tier III
Terrestrial Field TEP A.B.F.H No
- Aquatic Field TEP A.B.F.H No
No1/
No1/
No1/
No1/
No1/
No1/

No1/
No1/
I/ Based on available data, these studies are not required.

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ui
OJ
                                                                            Table A
                                                         Generic Data Requirements  for  Metaldehyde
Data Requirement
Section 158.590 •
Nontarget Insect
141-1 - Honey Bee
141-2 - Honey Bee
Composition
Montarget Insects
Testing - Pol I inators
Acute Toxicity TGAI
- Toxicity TEP
Does EPA Have
Data to Satisfy
This Requi re-
Use ment? (Yes, Bibliographic
Pattern No. Partially) Citation


A,B,H No
A,B No
Must Additional
Data Be Submitted
Under FIFRA Section
3(c)(2)(B)?


No1
No1
Timeframe
For Data
Submission




        of residues on foliage

141-4 - Honey Bee Subacute            Reserved2/
        Feeding Study

141-5 - Field Testing for             TEP               A,B,H
        Pollinators

Nontarget Insect Testing

142-1 - Acute Toxicity to             Reserved2/
        Aquatic Insects

142-2 - Aquatic Insect Life           Reserved2/
        Cycle Study

142-3 - Simulated or Actual           Reserved2/
        Field Testing for
       Aquatic  Insects

143-1   Nontarget Insect              Reserved /
thru    Test ing-Predators
143-3   and Parasites
                                                                                No
                                                                                                                         No1
      /  The nature  of  the registered metaldehyde formulations and uses precluded any  significant bee exposure.  Thus, bee data are not  required for
         metaldehyde.
      /  This requirement  is  reserved pending development of test methodology and/or decisions as to whether data should be  required.

-------
                                        TABLE B
PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING USE PRODUCTS CONTAINING METALDEHYDE
Test
Data Requirement Substance
Does EPA
Have Data To
Satisfy This
Requi rement?
Bibliographic
Citation 1
Must Additional
Data be Submitted
Under FIFRA Section
3?
Time Frame
For Data
Submission
Part 158. Suboart C - Product Chemistrv
Product Composition
61-1. Product Composition
61-2. Beginning Materials and
Production or Formulation
Process
61-3. Formation of Impurities
Analysis and Certification of
Product Ingredients
62-1. Preliminary Analysis
62-2. Certified Limits
62-3. Enforcement Analytical
Methods

MP
MP


MP


MP
MP
MP


No
No


No


No
No
No


N/A
N/A


N/A


N/A
N/A
N/A

Physical and Chemical Characteristics
63-2. Color
63-3. Physical State
63-4. Odor
63-7. Density, Bulk Density,
Specific Gravity
63-12. pH
62-14. Oxidizing or Reducing Action
62-15. F I amiability
63-16. Explodability
63-17. Storage Stability
63-18. Viscosity
63-19. Miscibility
63-20. Corrosion Characteristics
Other Requirements:
MP
MP
MP
MP

MP
MP
MP
MP
MP
MP
MP
MP

No
No
No
No

No
No
No
No
No
No
No
No

N/A
N/A
N/A
N/A

N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A


Yes'
Yes3


Yes4


Yes5
Yes6
Yes7


Yes*
Yes*
Yes«
Yes8
ft O
Ycs?o
Yes?
Yes!
Yes12
Yes
YCS4
Yes1*
Yes


6 Months
6 Months


6 Months


12 Months
12 Months
12 Months


6 Months
6 Months
6 Months
6 Months

6 Months
6 Months
6 Months
6 Months
15 Months
6 Months
6 Months
15 Months

     N/A
N/A
N/A
                                                                                     No

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                                                                                     TABLE B
                                             PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING USE PRODUCTS CONTAINING METALDEHYDE
           1.  Not Applicable.  Although product chemistry data may have been  submitted in the past, the Agency has determined that these data must be resubmitted
           for each  pesticide.   New requirements have been introduced and previously submitted data must be updated.  Therefore,  bibliographic citations for the
           old data  are not  applicable.

           2.   For  each manufacturing use product that consists of the technical grade of the active  ingredient only or is produced by an integrated system, the
           following information must  be provided:  (1) the CA-approved chemical name, CAS Registry Nunber, any common names,  the nominal concentration, upper and
           lower certified limits  in accordance with 40 CFR Section 158.175, and the purpose  of each active and inert ingredient in the product; (2) the molecular,
           structural and empirical  formulae,  and the molecular weight or weight range of each active ingredient in the product;  (3) the chemical name and nominal
           concentration  of  each impurity of toxicological significance associated with the active ingredient or present in any sample at a level equal  to or greater
           than 0.1X by weight of the TGA1;  and (4) sufficient information to enable the Agency to identify the source and qualitative composition of all ingredients
           that  are not characterized.  Impurities must be identified as such.  For each manufacturing-use product that is produced  from an EPA_registered product,
           the  following  information must be provided:   (1) the  chemical  and common name of each active ingredient as listed on the source product, its nominal
           concentration  in  the product based upon the nominal concentration in the source product, and upper and tower certified limits i accordance with 158.175;
           (2)  the  CA-approved  chemical  name of each inert ingredient in the  product, its CAS Registry Number, any common names, nominal concentration,  purpose,
           and upper and lower certified limits in accordance with 158.175;  and (2) sufficient information to enable the Agency to identify the source and qualitative
           composition of all ingredients that cannot  be characterized.

           3.   For  each manufacturing-end use product that is produced from an EPA-registered product, the following information must be provided:   (1)  the name
 I          and  EPA-registered product; (2) the brand name, trade name,  or other commercial  designation and information concerning the composition  of  each inert
           ingredient; (3) a general characterization  of  the formulation or production process (e.g., batch or continuous);  (4) the identity of the materials used
01         to produce the product, their relative amounts, and the order in which they are added;  (5) a description of the equipment used; (6) a description of the
           conditions (e.g., temperature, pressure, pH, humidity) that are controlled during  each step  of the process; and (7) • description of the procedures used
 I          to assure consistent composition of the substance produced (quality control methods).   For each manufacturing use product that consists of the technical
           grade of  the active ingredient only or is produced by an integrated system, the following Information must be provided in addition to that listed above:
           (1) the  name and  address of the producer of each starting material, the name and address of its producer, and information concerning its composition;
           (3) a flow chart of the chemical  equations of each intended reaction occurring at each step of the process and of the entire process;  and (4) • description
           of any purification procedures (including procedures to recover or recycle starting materials,  intermediates  or  the substance produced).

           4.   For  each manufacturing use  product  that  consists  of the technical grade of the active ingredient  only or  is  produced by an integrated system,  a
           discussion regarding  the origin of the following potential impurities must be  provided:  (1)  each  impurity  associated with the active ingredient which
           was found to be present in any analysis of the product conducted by or for the registrant, and (2) each impurity which the registrant has reason to believe
           may be present in the  product  at  a level equal to or greater  than 0.1X (w/w) based on the  composition of each starting  material,  intended and side
           reactions which may  occur in the production of  the  product,  the possible degradation of ingredients in the product after production,  post-production
           reactions between the  ingredients in  the product, possible contamination from  packaging materials  or  production equipment, and process  control,
           purification and  quality control measures.  For each  manufacturing use product that  is produced from an EPA-registered product,  a discussion must be
           provided  for each impurity associated with the active ingredient which the registrant has reason to believe may be present in the product at  a level equal
           to or greater  than 0.1X (w.w) based on the  possible  carryover of impurities  present  in the  registered product which serves as the source of the active
           ingredient, the possible carryover of impurities present  in the  inert  ingredients in  the product, possible reactions occurring during the formulation
           of the product, post-production reactions between any of the product's  active  ingredients and any other component of  the product or its packaging, and
           possible  contamination from packaging materials  or production equipment.

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                                                                       TABLE B
                               PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING USE  PRODUCTS CONTAINING METALDEHYOE
5.  For each manufacturing use product produced by an integrated system, the registrant must provide preliminary analyses of five or more representative
samples of each technical grade of active ingredient contained in the product  to identify all impurities present at 0.1% or greater of the TGAI.  If the
product is produced by a batch process, at least five separate batches should be represented.  The preliminary analysis should be conducted at the point
in the production process  after which no further chemical  reactions  designed  to produce or purify the substance are intended.  Complete and detailed
descriptions of the methods used for sample analysis must be submitted,  including statements of their  precision and accuracy.   The preliminary analysis
report should include the  identity and quantity of each ingredient for which analysis is conducted, along with the mean  and relative standard deviation
of the analytical results.  Based on the preliminary analysis,  a statement of the composition of the technical  grade of active ingredient must be provided.
If the technical grade of active ingredient cannot be isolated,  a statement of the composition of the practical equivalent of the technical grade of active
ingredient must be submitted.

6.  The registrant must propose upper and lower limits for each active and inert  ingredient, if such limits would differ from the standard certified limits
determined by the Agency according  to 40 CFR Section158.175(b)(2).  Also, if the manufacturing use product contains the technical grade of the active
ingredient only or is produced by an integrated system, upper limits must be proposed for each  lexicologically significant  impurity associated with the
active ingredients and  found to be present in any sample of  the product  (standard certified limits cannot  be used for impurities).   Certified limits
should be based on the sources and magnitude of variability in the manufacturing process and the stability of the ingredients following production.  The
registrant must certify the accuracy of the information presented, and that the certified limits will be maintained.  An explanation of how each certified
limit was established (e.g.,  sample analysis using a validated analytical procedure, quantitative estimate based on the amounts of ingredients used, etc.)
must be provided, along with information on the accuracy and precision of any analytical procedures used.  Certifications must be submitted on EPA Form
8570-4 (Rev. 2/85).

7.  Analytical methods which  are suitable for enforcement purposes must be provided for each active  ingredient and each additional ingredient or impurity
that is determined to be lexicologically significant.  Suitability for enforcement purposes shall be determined from validation studies of method accuracy
and precision submitted by the registrant.

8.  As required in 40 CFR Section 158.190 and more fully described in the Pesticide Assessment  Guidelines, Subdivision D, Guidelines Reference Nos. 63-
2 through  63-20,  data must be submitted on physicochemical characteristics of  each  manufacturing-use product  (color,  physical state,  odor,  specific
gravity, pH, oxidizing  or  reducing action,  flammability explodability, storage stability, viscosity, misclbility, and corrosion characteristics).

9. Data on pH are required if  the test substance is  dispersable in water.

10. Data are required on oxidizing/reducing  potential  if product contains an oxidizing or reducing agent.

11. Data are required on flanmabiltty if the product contains combustible liquids.

12. Data are required  if the product  is potentially explosive.

13. Data on  viscosity are  required  if  the product  is a  liquid.

14. Data on  miscibility are  required  if the  product  is  an  emulsifiable  liquid  and is  to be diluted with petroleum solvents.

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                                        Table B
Product-Specific Data Requirements for Manufacturing-Use Products Containing Metaldehyde
Data Requirement
Section 158.340 Toxicology
Acute Testing
81-1 - Acute Oral - Rat
81-2 - Acute Dermal
81-3 - Acute Inhalation - Rat
81-4 - Eye Irritation - Rabbit
81-5 -'Dermal Irritation
-Rabbit
81-6 - Dermal Sensitization
- Guinea Pig
Composition


HP
MP
HP
MP
MP
MP
Use
Patterns


All
All
All
All
All
All
Does EPA
Have Data to
Satisfy This
Requirement?


No
No
No
No
No
No
Must Additional
Data Be Submitted
Bibliographic Under FIFRA Section
Citation 3(c)(2)(B)7


Yes
Yes
Yes
Yes
Yes
Yes
Timeframe
For Data
Submission


9 Months
9 Months
9 Months
9 Months
9 Months
9 Months

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II.  LABELING APPENDICES
      - 58 -

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                          SUMMARY-1

                        LABEL CONTENTS

     40 CFR 156.10 requires that certain specific  labeling
statements appear at certain locations on the label.   This
is referred to as format labeling.  Specific label items  listed
below are keyed to the table at the end of this  Appendix.

     Item 1.  PRODUCT NAME - The name, brand or  trademark is
required to be located on the front panel, preferably centered
in the upper part of the panel.  The name of a product will
not be accepted if it is false or misleading.

     Item 2.  COMPANY NAME AND ADDRESS - The name  and address
of the registrant or distributor is required on  the label.
The name and address should preferably be located  at the
bottom of the front panel or at the end of the label text.

     Item 3.  NET CONTENTS - A net contents statement is
required on all labels or on the container of the  pesticide.
The preferred location is the bottom of the front  panel
immediately above the company name and address,  or at the end
of the label text.  The net contents must be expressed in the
largest suitable unit, e.g., "1 pound 10 ounces" rather than
"26 ounces." In addition to English units, net contents may
be expressed in metric units.  [40 CFR 156.10(d)]

     Item 4.  EPA REGISTRATION NUMBER - The registration
number assigned to the pesticide product must appear on the
label, preceded by the phrase "EPA Registration No.," or "EPA
Reg. No."  The registration number must be set in  type of a
size and style similar to other print on that part of the
label on which it appears and must run parallel to it.  The
registration number and the required  identifying phrase must
not appear in such a manner as to suggest or imply recommendation
or endorsement of the product by the Agency.
[40 CFR 156.10(e)]

    Item 5.  EPA ESTABLISHMENT NUMBER - The EPA establishment
number, preceded by the phrase "EPA Est." is the final estab-
lishment at which the product was produced, and may appear
in any suitable location on the label or  immediate container.
It must also appear on the wrapper or outside container of
the package if the EPA establishment number on the  immediate
container cannot be clearly read through  such wrapper or container.
[40 CFR 156.10(f)]

    Item 6A. INGREDIENTS STATEMENT - An  ingredients  statement
is required on the front panel.  The  ingredients  statement must
contain the name and percentage by weight of each  active ingredient
and the total percentage by weight of all inert ingredients.
The preferred location is immediately below  the product name.
The ingredients statement must run parallel with,  and be clearly
distinguished from, other text on the panel.  It must not be
placed in the body of other text.  [40 CFR  156.10(g)]


                              - 59  -

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                            SUMMARY-2

    Item 6B.  POUNDS PER GALLON STATEMENT - For liquid  agricul-
tural formulations . the pounds per gallon of active ingredient
must be indicated on the label.

    Item 7.  FRONT-LABEL PRECAUTIONARY STATEMENTS - Front panel
precautionary statements must be grouped together,  preferably
within a block outline.  The table below shows the  minimum type
size requirements for various size labels.

    Size of Label        Signal Word          "Keep Out of Reach
    on Front Panel       Minimum Type Size       of Children"
    in Square Inches     All Capitals          Minimum Type Size

    5 and under                6 point              6 point
    above 5 to 10              10 point              6 point
    above 10 to  15             12 point              8 point
    above 15 to  30             14 point             10 point
    over 30                    18 point             12 point

    Item 7A.  CHILD HAZARD WARNING STATEMENT - The statement
"Keep Out of Reach of Children" must be located on the front
panel above the  signal word except where  contact with children
during distribution or use is  unlikely.   [40 CFR 156.10(h)(1)(ii)]

    Item 7B.  SIGNAL WORD - The signal word (DANGER, WARNING,
or CAUTION) is required on the front panel  immediately below
the child hazard warning statement.  [40  CFR 156.10(h)(1)(i)]

    Item 7C.  SKULL & CROSSBONES AND WORD "POISON" - On products
assigned a  toxicity Category  I on  the basis of oral, dermal,
or inhalation toxicity, the word "Poison"  shall appear on the
label in red on  a background  of distinctly contrasting color and
the skull and crossbones shall appear in  immediate proximity to
the word POISON.   [40 CFR 156.10(h)(1)(i)]

    Item 7D.  STATEMENT OF PRACTICAL TREATMENT - A statement
of practical treatment  (first  aid  or other) shall  appear  on
the label of pesticide  products in  toxicity Categories I,
II. and III.  [40 CFR 156.10(h)(1)(ill)]

    Item 7E.  REFERRAL  STATEMENT  -  The  statement "See  Side
(or Back) Panel  for Additional Precautionary  Statements"  is
required on the  front panel  for all  products,  unless  all
required precautionary  statements  appear  on the  front  panel.
[40 CFR 162.56(h)(l)(iii)]

    Item 8.  SIDE/BACK  PANEL PRECAUTIONARY LABELING -  The
precautionary statements listed below must appear  together
on the label under  the  heading "PRECAUTIONARY STATEMENTS."
The preferred location  is at  the  top of the side or back
panel preceding  the directions for use, and it is  preferred
that these  statements be surrounded by  a block outline.   Each
of the three hazard warning  statements  must be headed by the
appropriate hazard  title.   [40 CFR 156.10(h)(2)].

                              - 60  -

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                          SUMMARY-3

    Item 8A.  HAZARD TO HUMANS AND DOMESTIC ANIMALS -  Where  a
hazard exists to humans or domestic animals, precautionary
statements are required indicating the particular hazard,  the
route(s) of exposure and the precautions to be taken to avoid
accident, injury or damage.  [40 CFR 156.10(h) (2) ( i) ]

    Item 8B.  ENVIRONMENTAL HAZARD - Where a hazard exists to
non-target organisms excluding humans and domestic animals,
precautionary statements are required stating the nature of
the hazard and the appropriate precautions to avoid potential
accident, injury, or damage.  [40 CFR 156.10(h) (2) (ii) ]

    Item 8C.  PHYSICAL OR CHEMICAL HAZARD - FLAMMABILITY
Precautionary statements relating to flammability of a product
are required to appear on the label if it meets  the criteria
in the PHYS/CHEM Labeling Appendix. The requirement is
based on the results of the flashpoint determinations  and
flame extension tests required to be submitted for all products.
These statements are to be located in the side/back panel
precautionary statements section, preceded by the heading
"Physical/Chemical Hazards."  Note that no signal word is
used in conjunction with the flammability statements.

    Item 9A.  RESTRICTED USE CLASSIFICATION - FIFRA sec. 3(d)
requires that all pesticide formulations/uses be classified
for either general or restricted use.  Products  classified
for restricted use may be limited to use by certified applicators
or persons under their direct supervision (or may be subject
to other restrictions that may be imposed by regulation).

    In the Registration Standard, the Agency has (1) indicated
certain formulations/uses are to be restricted (Section IV
indicates why the product has been classified for restricted
use);  or (2) reserved any classification decision until
appropriate data are submitted.

    The Regulatory Position and Rationale states whether
products containing this active ingredient are classified
for restricted use.  If they are restricted  the  draft  label(s)
submitted to the Agency as part of your application must
reflect this determination (see below).

     If you do not believe that your product  should be  classified
for restricted use, you must submit any  information and
rationale with your application for reregistration.   During
the Agency's review of your application, your proposed  classi-
fication determination will be evaluated  in  accordance  with
the provisions of Part 152, Subpart I.   You  will be notified
of the Agency's classification decision.
                              - 61 -

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                          SUMMARY-4

     Classification Labeling Requirements

     If your product has been classified for restricted use,
the following label, requirements apply:

     1.  All uses restricted.

         a.  The statement "Restricted Use Pesticide" must
     appear at the top of the front panel of the label.  The
     statement must be set in type of the same minimum size
     as required for human hazard signal word (see table in 40
     CFR 156.10(h) (1)(iv)

         b.  Directly below this statement on the front panel,
     a summary statement of the terms of restriction must
     appear (including the reasons for restriction if specified
     in Section I).   If use is restricted to certified applicators,
     the following statement is required:  "For retail sale
     to and use only by Certified Applicators or persons
     under their direct supervision and only for those uses
     covered by the Certified Applicator's Certification."

     2.  Some but not all uses restricted.  If the Regulatory
Position and Rationale states that some uses are classified
for restricted use, and some are unclassified, several courses
of action are available:

          a.  You may label the product for Restricted use.
     If you do so. you may include on the label uses that
     are unrestricted, but you may not distinguish them
     on the label as being unrestricted.

          b.  You may delete all restricted uses from  your
     label and submit draft labeling bearing only unrestricted
     uses.

          c.  .You may "split" your registration, i.e., register
     two separate products with identical formulations, one
     bearing only unrestricted uses, and  the other bearing
     restricted uses.  To do so, submit two applications  for
     reregistration, each containing all  forms and necessary
     labels.  Both applications should be submitted  simul-
     taneously.  Note that the products will be assigned
     separate registration numbers.

    Item 9B.  MISUSE STATEMENT - All products must bear  the
misuse statement, "It is a violation of Federal law  to use
this product in a manner inconsistent with  its labeling."
This statement appears at the beginning of  the directions
for use, directly beneath the heading  of  that  section.
                             -  62 -

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                          SUMMARY-5

    Item 10A.  REENTRY STATEMENT - If a reentry interval
has been established by the Agency, it must be included on
the label.  Additional worker protection statements may be
required in accordance with PR Notice 83-2, March 29.  1983.

    Item 10B.  STORAGE AND DISPOSAL BLOCK -  All labels are
required to bear storage and disposal statements.  These
statements are developed for specific containers, sizes, and
chemical content.  These instructions must be grouped  and
appear under the heading "Storage and Disposal" in the directions
for use.  This heading must be set in the same type sizes as
required for the child hazard warning.  Refer to Appendix II,
STOR, PEST/DIS, and CONT/DIS to determine the storage  and
disposal instructions appropriate for your products.

    Item IOC.  DIRECTIONS FOR USE - Directions for use must
be stated in terms which can be easily read and understood by
the average person likely to use or to supervise the use of
the pesticide.  When followed, directions must be adequate to
protect the public from fraud and from personal injury and to
prevent unreasonable adverse effects on the environment.
[40 CFR 156.10]
                     COLLATERAL LABELING

    Bulletins, leaflets, circulars, brochures, data sheets,
flyers, or other written or graphic printed matter which is
referred to on the label or which is to accompany the product
are termed collateral labeling.  Such labeling may not bear
claims or representations that differ in substance from those
accepted in connection with registration of the product.  It
should be made part of the response to this notice and submitted
for review.
                              -  63  -

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                  SUMMARY-6
LABELING REQUIREMENT OF TOE FIFRA, AS AMENDED
ITEM
1
2
3
4
I
c* 5
*>.
I
6A
6B
7
7A
7B
LABEL ELEMENT
Product name
Company name
and address
Net contents
EPA Reg. No.
EPA Est. No.
Ingredients
statement
Pounds/gallon
statement
Front panel
precaut ionary
statements
Keep Out of Reach
of Children
(Child hazard
warning)
Signal word
APPLICABILITY
OF REQUIREMENT
All products
All products
All products
All products
All products
All products
Liquid products
where dosage
given as Ibs.
ai/unit area
All products
All products
All products
PLACEMENT ON LABEL
REQUIRED
Front panel
None
None
None
None
Front panel
Front panel
Front panel
Front panel
Front panel
PREFERRED
Center front
panel
Bottom front
panel or end
of label text
Bottom front
panel or end
of label text
Front panel
Front panel,
immediately
before or
following
Reg. No.
Immediately
following
product name
Directly below
the main
ingredients
statement

Above signal
word
Immediately
below child
hazard
warning
COMMENTS

If registrant is not the producer, must
be qualified by "Packed for . . .,"
"Distributed by. . .," etc.
May be in metric units in addition to
U.S. units
Must be in similar type size and run
parallel to other type.
May appear on the container instead ot"
the label.
Text must run parallel with other text
on the panel.

All front panel precautionary statements
must be gcouptid together, preferably
blocked.
Note type size requirements.
Note type siie requirements.

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                                                            StMMARY-7
ITEM
7C
7D
7E
8
8A
8B
LABEL ELEMENT
Scull & cross-
bones and word
POISON (in red)
Statement of1
Practical
Treatment or
First Aid
Referral
statement
Side/back panel
precaut ionary
statements
Hazards to
hunans and
domestic
animals
Environmental
hazards
APPLICABILITY
OF REQUIREMENT
All products
which are Cat-
egory I based
on oral, der-
mal, or inhala-
tion toxic ity
All products
in Categories
I, II, and III
All products
where pre-
cautionary
labeling
appears on
other than
front panel.
All products
All products
in Categories
I, II. and III
All products
PLACEMENT ON LABEL
REQUIRED
Front panel
Category I:
Front panel
unless refer-
ral statement
is used.
Others:
Grouped with
side panel
precautionary
statements.
Front panel
None
None
None
FKEKEKKEL)
Both in close
proximity to
signal word
Front panel
for all.

Top or side
of back panel
preceding
directions
for use
Same as above
Same as above
COMMENTS



Must be grouped under the headings in
8A, 8B, and 8C; preferably blocked.
Must be preceded by appropriate signal
word.
Environmental hazards include bee
caution where applicable.
Ol
I

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                                                            SUMMARY-8
ITEM
8C
9A
9B
10A
10B
IOC
LABEL ELEMENT
Physical or
chemical
hazards
Restricted
block
Misuse
statement
Reentry
statement
Storage and
disposal block
Directions
for use
APPLICABILITY
OF REQUIREMENT
All pressurized
products, others
with flash
points under
150°F
All restricted
products
All products
PR Notice 83-2
or as determined
by the Agency
All products
All products
PLACEMENT ON LABEL
REQUIRED
None
Top center
of front
panel
Limed iately
following
heading of
directions
for use
In the
directions
for use
In the
directions
for use
None
PREFERRED
Same as above
Preferably
blocked

Immed iately
after misuse
statement
Immediately
before
specific
directions
for use or
at the end of
directions
for use
None
COMMENTS
Refer to Appendix II guide
PHYS/CHEM
Includes a statement of the terms of
restriction. The words "RESTRICTED USE
PESTICIDE" must be same type size as
signal word.
Required statement is:
"It is a violation of Federal law
to use this product in a manner
inconsistent with its labeling."

Mist be set apart and clearly distin-
guishable from from other directions
for use.
Refer to Appendix II guides STOR,
CONT/DIS. and PEST/DIS for further
information and required statements.
May be in metric as well as U.S. units
CT>

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 Chapter  I—Environmental Protection Agency


 §156.10  Labeling Requirements for Pesticides and Devices.

   (a)  General—(1)  Contents of the label.  Every pesticide
 product  shall bear a label containing the information specified  by
 the Act  and  the  regulations in this Part.  The contents  of  a
 label must show  clearly and prominently the following:
   (i)  The name, brand, or trademark under which the product  is
 sold as  prescribed in paragraph (b) of this section;
   (ii)   The  name and address of the producer, registrant, or
 person for whom  produced as prescribed in paragraph (c)  of  this
 section;
   (iii)  The net contents as prescribed in paragraph (d)  of this
 section;
   (iv)   The  product registration number as prescribed in paragraph
 (e) of this  section;
   (v)  The producing establishment number as prescribed  in  para-
 graph (f) of this section;
   (vi)   An ingredient statement as prescribed in paragraph  (g)  of
 this section;
   (vii)  Warning or precautionary statements as prescribed  in
 paragraph (h) of this section;
   (viii)  The directions for use as prescribed in paragraph (i)
 of this  section; and
   (ix)   The  use  classification(s) as prescribed in paragraph (j)
 of this  section.
   (2)  Prominence and legibility.  (i)  All words, statements,
 graphic  representations, designs or other  information required  on
 the labeling by  the Act or the regulations in this part must be
 clearly  legible  to a person with normal vision, and must be placed
 with such conspicuousness (as compared with other words, state-
 ments, designs, or graphic matter on the  labeling) and expressed
 in such  terms as to render it likely to be read and understood
 by the ordinary  individual under customary conditions of purchase
 and use.
   (ii)   All  required label text must:
   (A)  Be set in 6-point or larger type;
   (B)  Appear on a clear contrasting background;  and
   (C)  Not be obscured or crowded.
   (3)  Language  to be used.  All required label  or  labeling  text
 shall appear in  the English language.  However,  the Agency may
 require  or the applicant may propose additional  text  in other
 languages as is  considered necessary to  protect  the public.  When
 additional text  in another language  is necessary, all  labeling
 requirements will be applied equally to  both  the English and
other-language versions of the labeling.
   (4)  Placement of Label—(i)  General.   The label shall  appear
on or be securely attached to the  immediate  container  of the
                              - 67 -

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pesticide product.  For purposes of this Section, and the  mis-
branding provisions of the Act, "securely attached" shall  mean
that a label can reasonably be expected to remain affixed  during
the foreseeable conditions and period of use.  If the immediate
container is enclosed within a wrapper or outside container
through which the label cannot be clearly read, the label  must
also be securely attached to such outside wrapper or container,
if it is a part of the package as customarily distributed  or
sold.
  (ii)  Tank cars and other bulk containers—(A)  Transportation.
While a pesticide product is in transit, the appropriate
provisions of 49 CFR Parts 170-189, concerning the transportation
of hazardous materials, and specifically those provisions  con-
cerning the labeling, marking and placarding of hazardous  materials
and the vehicles carrying them, define the basic Federal require-
ments.  In addition, when any registered pesticide product is
transported in a tank car, tank truck or other mobile or portable
bulk container, a copy of the accepted label must be attached to
the shipping papers, and left with the consignee at the time of
delivery.
  (B)  Storage.  When pesticide products are stored in bulk
containers, whether mobile or stationary, which remain in the
custody of the user, a copy of the label of labeling, including
all appropriate directions for use, shall be securely attached to
the container in the immediate vicinity of the discharge control
valve.
  (5)  False or misleading statements.  Pursuant to section
2(q)(l)(A) of the Act, a pesticide or a device declared subject
to the Act pursuant to S 162.15, is misbranded if  its labeling is
false or misleading in any particular including both pesticidal
and non-pesticidal claims.  Examples of statements or representations
in the labeling which constitute misbranding include:
  (i)  A false or misleading statement concerning  the composition
of the product;
  (ii)  A false or misleading statement concerning the effectiveness
of the product as a pesticide or device;
  (iii)   A false or misleading statement about  the value  of  the
product for purposes other than as a pesticide  or  device;
  (iv)  A false or misleading comparison with other  pesticides or
devices;
  (v)  Any statement directly or indirectly  implying  that the
pesticide or device is recommended or endorsed  by  any agency of
the Federal Government;
  (vi)  The name of a pesticide which contains  two or more
principal active ingredients  if the  name  suggests  one or  more  but
not all  such principal active ingredients  even  though the names
of the other ingredients are stated  elsewhere  in the labeling;
  (vii)   A true statement used  in  such  a  way as to give a false
or misleading impression to the purchaser;
  (viii)  Label disclaimers which  negate  or detract from labeling
statements required under the Act  and  these regulations;
                               - 68 -

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 .  (ix)   Claims as  to  the safety of the pesticide or its ingredients,
 including statements  such as "safe," "nonpoisonous," "noninjurious,"
 harmless" or "nontoxic to humans and pets" with or without such
 a  qualifying phrase as "when used as directed"; and
   (x)   Non-numerical-  and/or comparative statements on the safety
 of  the  product,  including but not limited to:
   (A)   "Contains all  natural ingredients";
   (B)   "Among the  least toxic chemicals known"
   (C)   "Pollution  approved"
   (6)   Final printed  labeling.  (i)  Except as provided in
 paragraph (a)(6)(ii)  of this section, final printed labeling must
 be  submitted and accepted prior to registration.  However, final
 printed  labeling need not be submitted until draft label texts
 have been provisionally accepted by the Agency.
   (ii)   Clearly  legible reproductions or photo reductions will be
 accepted for unusual  labels such as those silk-screened directly
 onto glass or metal containers or large bag or drum labels.  Such
 reproductions must be of microfilm reproduction quality.
   (b)   Name, brand, or trademark.  (1)  The name, brand, or
 trademark under which the pesticide product is sold shall appear
 on  the  front panel of the label.
   (2)   No name, brand, or trademark may appear on the label which:
   (i)   Is false or misleading, or
   (ii)   Has not been  approved by the Administrator through
 registration or supplemental registration as an additional name
 pursuant to $ 162.6(b)(4).
   (c)   Name and address of producer,, registrant, or person for
 whom produced.  An unqualified name and address given on the
 label shall be'considered as the name and address of the producer.
 If  the  registrant's name appears on the label  and the registrant
 is not  the producer,  or if the name of the person for whom the
 pesticide was produced appears on the label, it must be qualified
 by appropriate wording such as "Packed for ***," "Distributed by
 ***,"  or "Sold by ***" to show that the name  is not that  of  the
 producer.
  (d)  Net weight or  measure of contents.  (1)  The net weight  or
measure of content shall be exclusive of wrappers or other
materials and shall be the average content unless explicitly
 stated as a minimum quantity.
  (2)   If the pesticide is a liquid, the net content statement
 shall be in terms  of  liquid measure at 68°F  (20°C)  and  shall  be
expressed in conventional American units'of  fluid ounces,  pints,
 quarts, and gallons.
  (3)   If the pesticide is solid or semisolid, viscous  or
pressurized, or is a  mixture of liquid and solid,  the  net  content
statement shall be in terms of weight expressed  as  avoirdupois
pounds -and ounces.
  (4)  In all cases,  net content shall be  stated  in terms  of  the
 largest suitable units, i.e., "1 pound  10  ounces"  rather than
 "26 ounces."
                                - 69 -

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   (5)   in addition  to  the  required units specified, net content
 may be expressed in metric units.
   (6)   Variation above minimum content or around an average is
 permissible  only to the  extent that  it represents deviation
 unavoidable  in  good manufacturing practice.  Variation below a
 stated minimum  is not  permitted.  In no case shall the average
 content of  the  packages  in a  shipment fall below the stated
 average content.
   (?)   Product  registration number.  The registration number
 assigned to  the pesticide  product at the time of registration
 shall  appear on the label, preceded  by the phrase "EPA Registration
 No.,"  or the phrase "EPA Reg. No."   The registration number shall
 be  set in type  of a size and  style similar to other print on that
 part of the  label on which it appears and shall run parallel to
 it.  The registration  number  and the required identifying phrase
 shall  not appear in such a manner as to suggest or imply
 recommendation  or endorsement of the product by the Agency.
   (f)   Producing establishments registration number.  The producing
 establishment registration number preceded by the phrase "EPA
 Est.",  of the final establishment at which the product was produced
 may appear  in any suitable location  on the label or immediate
 container.   It  must appear on the wrapper or outside container of
 the package  if  the  EPA establishment registration number on the
 immediate container cannot be clearly read through such wrapper
 or container.
   (g)   Ingredient statement—(1)  General.  The label of each
 pesticide product must bear a statement which contains the name
 and percentage  by weight of each active ingredient, the total
 percentage by weight of  all inert ingredients; and if the pesticide
 contains  arsenic in any  form, a statement of the percentages of
 total  and water-soluble  arsenic calculated as elemental arsenic.
 The active ingredients must be designated by the term "active
 ingredients" and the inert ingredients by the term "inert
 ingredients," or the singular forms  of these terms when appropriate.
 Both terms shall be in the same type size, be aligned to the  same
 margin  and be equally  prominent.  The statement "Inert Ingredients,
 none"  is  not required  for  pesticides which contain  100 percent
 active  ingredients.  Unless the ingredient statement  is a  complete
 analysis  of  the pesticide, the term  "analysis" shall  not be  used
 as a heading for the ingredient statement.
   (2)   Position of  ingredient statement.   (i)  The  ingredient
 statement is normally  required on the front panel  of  the label.
 If there  is  an  outside container or  wrapper  through which  the
 ingredient statement cannot be clearly  read, the  ingredient
 statement must  also appear on such outside container  or  wrapper.
 If the  size  or  form of the package makes  it  impracticable  to place
 the ingredient  statement on the front panel  of  the label,  permission
may be  granted  for  the ingredient statement  to appear elsewhere.
  (ii)   The  text of the  ingredient statement must  run parallel
with other text  on  the panel  on which  it  appears,  and must be
clearly  distinguishable  from  and must  not be  placed in the body
of other  text.

                               - 70 -

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   (3)  Names to be used in ingredient statement.  The name used
 for each  ingredient shall be the accepted common name, if there
 is one, followed by the chemical name.  The common name may be
 used alone only if it  is well known.  If no common name has been
 established, the chemical name alone shall be used.  In no case
 will the  use of a trademark or proprietary name be permitted unless
 such name has been accepted as a common name by the Administrator
 under the authority of Section 25(c)(6).
   (4)  Statements of percentages.  The percentages of ingredients
 shall be  stated in terms of weight-to-weight.  The sum of per-
 centages  of the active and the inert ingredients shall be 100.
 Percentages shall not  be expressed by a range of values such as
 "22-25%."  If the uses of the pesticide product are expressed as
 weight of active ingredient per unit area, a statement of the
 weight of active ingredient per unit volume of the pesticide
 formulation shall also appear in the ingredient statement.
   (5)  Accuracy of stated percentages.  The percentages given
 shall be  as precise as possible reflecting good manufacturing
 practice.  If there may be unavoidable variation between manu-
 facturing batches, the value stated for each active ingredient
 shall be  the lowest percentage which may be present.
   (6)  Deterioration.  Pesticides which change  in chemical
 composition significantly must meet the following labeling re-
 quirements:
   (i)  In cases where  it is determined that a pesticide formulation
 changes chemical composition significantly, the product must bear
 the following statement in a prominent position on the label:   "Not
 for sale or use after  [date]."
   (ii)  The product must meet all label claims up to  the expiration
 time indicated on the  label.
   (7)  Inert ingredients.  The Administrator may require the name
 of any inert ingredient(s) to be listed in the  ingredient statement
 if he determines that  such ingredient(s) may pose a hazard to man
 or the environment.
   (h)  Warnings and precautionary statements.   Required warnings
 and precautionary statements concerning the general areas of
 toxicological hazard including hazard to children, environmental
 hazard, and physical or chemical hazard fall  into  two groups;  those
 required on the front panel of the  labeling and those which may
 appear elsewhere.  Specific requirements concerning content,
 placement, type size,  and prominence are given  below.
   (1)  Required front  panel statements. ' With  the  exception  of  the
child hazard warning statement, the text required  on  the  front
 panel of the label is  determined by the Toxicity  Category of  the
pesticide.  The category is assigned on the basis  of  the  highest
hazard shown by any of the indicators  in  the  table below:
                               - 71 -

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Hazard Indicators

Oral LD
50
Inhalation 1C
Dermal LD.
50
Eye effects
Skin effects

|-
Up to and
Including
50 *g/kg
Up to and
Including
.2 mg/ liter
Up to and
Including
200 mg/kg
Corrosive;
cornea! opacity
not reversible
•Ithln 7 days
Corrosive
Toxicity <
II
From 50 thru
500 wig/kg
From .2 thru
2 mg/l Iter
From 200
thru 2000
Cornea 1 opacity
reversible
•Ithln 7 days;
Irritation
persisting for
7 days
Severe Irritation
at 72 hours
:ategor1es
III
From 500 thru
5000 mg/kg
From 2 thru
20 mg/l Iter
From 2,000 thru
20,000
No cornea 1 opacity;
Irritation
reversible
•Ithln 7 days
Mode-ate Irritation
at 72 hours

IV
Greater than
5000 mg/kg
Greater than
20 «g/Mter
Greater than
20,000
No Irritation
Mild or slight
Irritation at
72 hours
  (i)  Human hazard signal word.--(A)  Toxicity Category I.   All
pesticide products meeting the criteria of Toxicity Category I
shall bear on  the  front panel the signal word "Danger."  In
addition if the product was assigned
the basis of  its oral/  inhalation or
from skin and eye local effects) the
in red on a background  of distinctly
skull and crossbones shall appear in
word "poison."
  (B)  Toxicity Category II.
       to Toxicity Category I  on
       dermal toxicity (as distinct
       word "Poison" shall appear
       contrasting color and the
       immediate proximity to  the
criteria of Toxicity Category
the signal word  "Warning."
  (C)  Toxicity Category III.
criteria of Toxicity Category
the signal word  "Caution."
  (D)  Toxicity Category IV.
criteria of Toxicity Category
the signal word  "Caution."
All pesticide
II shall bear
products meeting the
on the front panel
 All pesticide products meeting the
III shall bear on the front panel
All pesticide
IV shall bear
products meeting the
on the front panel
                              -  72  -

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  .(E)  Use of signal words.  Use of any signal word(s) associated
with a higher Toxicity Category is not permitted except when the
Agency determines that such labeling is necessary to prevent
unreasonable adverse effects on man or the environment.  In no
case shall more than one human hazard signal word appear on the
front panel of a label.
  (ii)  Child hazard warning.  Every pesticide product label shall
bear on the front panel the statement "keep out of reach of
children."  Only in cases where the likelihood of contact with
children during distribution, marketing, storage or use is
demonstrated by the applicant to be extremely remote, or if the
nature of the pesticide is such that it is approved for use on
infants or small children, may the Administrator waive this
requirement.
  (iii)  Statement of practical treatment—(A)  Toxicity
Category I.  A statement of practical treatment (first aid or
other) shall appear on the front panel of the label of all
pesticides falling into Toxicity Category I on the basis of oral,
inhalation or dermal toxicity.  The Agency may, however, permit
reasonable variations in the placement of the statement of
practical treatment is some reference such as "See statement of
practical treatment on back panel" appears on the front panel
near the word "Poison" and the skull and crossbones.
  (B)  Other toxicity categories.  The statement of practical
treatment is not required on the front panel except as described
in paragraph (h)(1)(iii)(A) of this section.  The applicant may,
however, include such a front panel statement at his  option.
Statements of practical treatment are, however, required elsewhere
on the label in accord with paragraph (h)(2) of this  section if
they do not appear on the front panel.
  (iv)  Placement and prominence.  All the required front panel
warning statements shall be grouped together on the label,  and
shall appear with sufficient prominence relative to other front
panel text and graphic material to make them unlikely to be over-
looked under customary conditions of purchase and use.  The
following table shows the minimum type size requirements for  the
front panel warning statements on various sizes of  labels:
Size of label front panel
in square inches





Points
Required
signal word,
all capitals
6
10
12
14
18
"Keep out
of reach of
Children"
6
6
8
10
12
                                - 73 -

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    ( 2)   Other required  warnings and  precautionary  statements.
 warnings  and precautionary statements as required  below  shall
 together  on the  label  under  the                   "^*"*1irman
                                                           The
                                                           appear
-amines  ana precautionary statements as required  below  shall
together  on the  label  under  the general heading "Precautionary
Statements" and  under  aroria               s of  "Hazard  to Hu
                                                   " and  "Physical or

                                                            Where a hazard
                                  rae  sueang
 and  Domestic Animals,"  "Environmental Hazard
 Chemical  Hazard."
    (i)   Hazard  to humans and  domestic animals.   (A)   Where  a haz
 exists to humans or domestic animals, precautionary statements
 are  required indicating the  particular hazard,  the  route(s) of
 exposure  and the precautions to be taken  to avoid  accident, injury
 or damage.   The  precautionary paragraph shall be  immediately
 preceded  by the  appropriate  hazard signal  word.
    (B)   The  following  table depicts typical precautionary statements.
 These  statements must be modified  or expanded to  reflect specific
 hazards.
Toxic 11>
category
                          Precautionary statements by toxlc'ty category
         Oral, Inhalation, or dermal toxlcttv
                                     SKln and eye local effects
III .
 iv .
         Fatal  (poisonous) If swallowed (Inhaled or
         absorbed through sklnl.  Do not breathe
         vapor Idustl or spray mist).  Do not get
         In eyes, on skin, or on clothing (Front
         panel statement of practical treatment
         requ'red.l.
                                           Corrosive, causes eye and skin damage lor
                                            skin Irritation].  Do not get In eyes, on
                                            skin, or on clothing. Wear goggles or face
                                            shield and rubber gloves when handling.
                                            Harmful or fatal If swallowed.
                                           (Appropriate first aid statement required.)
        May be fatal If swallowed (Inhaled or       Causes eye (and sklnj Irritation.  Do not
         absorbed through the sklnl.  Do not breathe) get In eyes, on skin, or on clothing.
         vapo's [dust or spray mlstj.  Do not get 1n| Harmful If swallowed.  (Appropriate first
         eyes, on skin, or on clothing. (Appropriate) aid statement required.).
         first aid statements required.I.
        Harmful If swallowed I Inhaled or absorbed
        through the skin).  Avoid breathing vapors
        Idust or spray Mist).  Avoid contact with
        sk'n  (eyes or clothing).  (Appropriate
        first aid statement required.!.


        (No precautionary statements required.).
                               Avoid contact with skin, eyes or clothing.
                                In case of contact Immediately flush
                                eyes or skin with plenty of water.  Get
                                medical attention If Irritation persists.
                                             [No precautionary statements required.!.
   ( i i )   	^_
 target, organisms
 statements
 appropriate
         Environmental  hazards.
       	    Where  a hazard exists  to non-
       excluding  humans and  domestic animals, precautionary
are  required stating  the  nature  of the hazard and the
 precautions to  avoid potential  accident,  injury or
                                     - 74  -

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     damage.   Examples of the  hazard statements  and the circumstances
     under which they  are required follow:
       (A)   If a pesticide intended for  outdoor  use contains an active
     ingredient with a mammalian  acute oral LD5Q of 100 or  less, the
     statement "This Pesticide  is Toxic  to  Wildlife"  is required.
       (B)   If a pesticide intended for  outdoor  use contains an active
     ingredient with a fish acute LC50 of  1 ppm  or  less, the statement
     "This Pesticide is Toxic  to  Fish" is  required.
       (C)   If a pesticide intended for  outdoor  use contains an active
     ingredient with an avian  acute oral LD$Q of 100  mg/kg  or less, or
     a  subacute dietary LC^Q of  500 ppm  or  less,  the  statement "This
     Pesticide is Toxic to Wildlife" is  required.
       (D)   If either  accident  history or  field  studies demonstrate
     that use  of the pesticide may result  in fatality to birds, fish
     or  mammals, the statement  "This pesticide is extremely toxic  to
     wildlife  (fish)"  is required.
       (E)   For uses involving  foliar application to agricultural
     crops,  forests, or shade  trees, or  for mosquito  abatement
     treatments, pesticides toxic to pollinating insects must bear
     appropriate label cautions.
       (F)   For all outdoor uses  other than aquatic applications  the
     label must bear the caution  "Keep out  of lakes,  ponds  or streams.
     Do  not  contaminate water  by  cleaning  of equipment  or  disposal of
    wastes."
       (iii)    Physical or chemical hazards.  Warning statements  on the
     flammability or explosive characteristics of the pesticide  are
     required  as follows:
             Flash point
                                                  Required text
                         (A) PRESSURIZED CONTAINERS
                                                                           I
Flash point at or below 20*F; If there Is a
  flashback at any valve opening*
Flash point above 20*F and not over 80*F or If
  the flame extension Is more than 16 In. long
  at a distance of 6 In. fro* the flame.
All other pressurized containers
                                      Extremely flammable.  Contents under pressure.  |
                                        Keep away from fire, sparks, and heated      |
                                        surfaces.  Do not puncture or Incinerate     |
                                        container.  Exposure to temperatures above   |
                                        130*F may cause bursting.                |
                                      Flammable. Contents under pressure.  Keep away |
                                        from heat, sparks, and open flame.  Do not   |
                                        puncture or Incinerate container.  Exposure to|
                                        temperatures above 130*F may cause  bursting.  (
                                      Contents under pressure.   Do not use  or store  j
                                        near heat or open flame.  Do not punctur* or  |
                                        Incinerate container.  Exposure to tempera-  |
                                        tores above I30*F may cause bursting.	|
                         (B) NONPRESSURIZED CONTAINERS
                                     I
At or below 20*F
                 ..............|  Extremely flammable.  Keep away from fire,
                                     |   sparks, and heated surfaces.
Above 20*F and not over 80*F ......,...|  Flammable.  Keep away from heat and open  flame.
Above 80*F and not over 150*F ....... . .I  Do not use or store near heat or open flame.
                                 -  75  -

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   (i>   Directions  for  Use—(1)  General requirements—(i)   Adequacy
 and clarity of  directions.   Directions for use must be stated in
 terms  which can be  easily read and understood by the average
 person likely to use or  to supervise the use of the pesticide.
 When followed,  directions must be adequate to protect the  public
 from fraud  and  from personal  injury and to prevent unreasonable
 adverse  effects on  the environment.
   (ii)   Placement of directions for use.  Directions may appear
 on any portion  of the  label provided that they are conspicuous
 enough  to be  easily read by  the user of the pesticide product.
 Directions  for  use  may appear on printed or graphic matter which
 accompanies the pesticide provided that:
   (A)   If required  by  the Agency, such printed or graphic matter
 is securely attached to each package of the pesticide, or placed
 within the  outside  wrapper or bag;
   (B)  The  label bears a reference to the directions for use  in
 accompanying  leaflets or circulars, such as "See directions in
 the enclosed  circular."  and
   (C)  The  Administrator determines that it is not necessary  for
 such directions  to  appear on the label.
   (iii)  Exceptions to requirement for direction for use—(A)
 Detailed directions for use may be omitted from labeling of
 pesticides  which are intended for use only by manufacturers of
 products other  than pesticide products in their regular manu-
 facturing processes, provided that:
   (_!)   The  label clearly shows that the product is  intended  for
 use only in manufacturing processes and specifies the type(s)  of
 products involved.
   (2)   Adequate  information such as technical data  sheets or
 bulletins,  is available to the trade specifying the  type of
 product  involved and its proper use in manufacturing processes;
   O)   The  product  will not come into the hands of  the general
 public except after incorporation into finished products; and
   (_4)   The  Administrator determines that such directions are  not
 necessary to prevent unreasonable adverse effects on man or  the
 environment.
  (B)   Detailed directions for use may be omitted from  the  labeling
 of pesticide products  for which sale is limited to  physicians,
 veterinarians,  or druggists, provided that:
  (^)   The  label clearly states that the product  is for use  only
 by physicians or veterinarians;
  (2)   The  Administrator determines that' such directions are  not
 nece~ssary to prevent unreasonable adverse effects on man or  the
environment; and
  (3)   The  product  is also a drug and regulated under  the provisions
of "the  Federal  Food, Drug and Cosmetic Act.
  (C)   Detailed directions for use may be omitted  from  the  labeling
of pesticide products  which  are  intended  for  use  only  by  formulators
 in preparing pesticides for  sale to the public, provided  that:
  (1)   There  is  information  readily available  to  the formulators
on The  composition, toxicity, methods of  use,  applicable  restrictions
or limitations,  and effectiveness of  the  product  for pesticide
purposes ;

                               - 76 -

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   (2)   The  label  clearly  states  that  the product ** intended for
 use  only in manufacturing,  formulating, mixing, or repacking for
 use  as  a pesticide  and  specifies  the  type(s) of pesticide products
 involved;
   (_3)   The  product  as finally manufactured, formulated, mixed, or
 repackaged  is  registered; and
   M)   The  Administrator  determines that such directions are not
 necessary to prevent unreasonable adverse effects on man or the
 environment.
   (2)   Contents of  Directions for Use.  The directions for use
 shall include  the following, under the  headings "Directions for
 Use " :
   (i)   The  statement of use classification as prescribed in
 162.10(j) immediately under the  heading "Directions for Use."
   (ii)   Immediately below the statement of use classification,
 the  statement  "It is a  violation  of Federal law to use this
 product in  a manner inconsistent  with its labeling."
   (iii)   The site(s) of application,  as for example the crops,
 animals,  areas, or  objects  to be  treated.
   (iv)   The  target  pest(s)  associated with each site.
   (v)   The  dosage rate  associated with  each site and pest.
   (vi)   The  method  of application, including instructions for
 dilution, if required,  and  type(s)  of application apparatus or
 equipment requried.
   (vii)   The frequency  and  timing of  applications necessary to
 obtain  effective  results  without  causing unreasonable adverse
 effects  on  the environment.
   (viii)  Specific  limitations on reentry to areas where the
 pesticide has  been  applied, meeting the requirements concerning
 reentry  provided  by 40  CFR  Part  170.
   (ix)   Specific  directions concerning  the storage and disposal
 of the  pesticide  and its  container, meeting the requirements of
 40 CFR  Part  165.   These instructions  shall be grouped and appear
 under the heading "Storage  and Disposal."  This heading must be
 set  in  type  of the  same minimum  sizes as required  for the child
 hazard  warning (See Table in $ 162.10(h)(1)(iv).)
   (x)   Any  limitations  or restrictions  on use required  to prevent
 unreasonable adverse effects, such as:
   (A)   Required intervals between application and  harvest of  food
 or feed  crops.
   (B)   Rotational crop  restrictions.
   (C)   Warnings as  required against use on  certain crops, animals,
 objects,  or  in or adjacent  to certain areas.
   (D)   [Reserved]         (
   (E)   For  restricted use pesticides, a statement  that  the
 pesticide may  be  applied  under  the direct  supervision  of  a
 certified applicator who  is not  physically  present at  the  site of
 application  but nonetheless available to  the  person applying the
 pesticide, unless the Agency has determined  that the pesticide
may only  be  applied under the direct  supervision of a  certified
 applicator who is physically present.
                               - 77 -

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  (F)  Other pertinent information which the  Administrator
determines to be necessary for the protection of man  and the
environment.
  (J)  Statement ofuse Classification.   By October 22, 1976, all
pesticide products must bear on their labels  a statement of use
classification as described in paragraphs (j)(l) and  (2) of this
section.  Any pesticide product for which some uses are classified
for general use and others for restricted use shall be separately
labeled according to the labeling standards set forth in this
subsection, and shall be marketed as separate products with
different registration numbers/ one bearing directions only for
general use(s) and the other bearing directions for restricted
use(s) except that, if a product has both restricted  use(s) and
general use(s), both of these uses may appear on a product labeled
for restricted use.  Such products shall be subject to the
provisions of S 162.10(j)(2 ).
  (1)  General Use Classification.  Pesticide products bearing
directions for use(s) classified general shall be  labeled with
the exact words "General Classification" immediately  below the
heading "Directions for use."  And reference  to the general
classification that suggests or implies that  the general utility
of the pesticide extends beyond those purposes and uses contained
in the Directions for Use will be considered  a false  or misleading
statement under the statutory definitions of  misbranding.
  (2)  Restricted Use Classification.  Pesticide products  bearing
direction for use(s) classified restricted shall bear statements
of restricted use classification on the front panel  as  described
below:
  (i)  Front panel statement of restricted use classification.
(A)   At the top of the front panel of the label, set  in type of
the same minimum sizes as required for human hazard signal words
(see table in § 162.10(h)(1)(iv)), and appearing with sufficient
prominence relative to other text and graphic material on the
front panel to make it unlikely to be overlooked under customary
conditions of purchase and use, the statement  "Restricted Use
Pesticide" shall appear.
  (B)  Directly below this statement on  the  front panel, a summary
statement of the terms of restriction imposed  as a precondition
to registration shall appear.   If use is  restricted  to certified
applicators, the following statement is,required:  "For retail
sale to and use only by Certified Applicators  or  persons under
their direct supervision and only for those  uses  covered by  the
Certified Applicator's certification."   If,  however, other
regulatory restrictions are  imposed, the  Administrator will  define
the appropriate wording for  the terms of  restriction by regulation,
  (k)  Advertising.  [Reserved]


[40 FR 28268, July  3,  1975;  40  FR 32329,  Aug.  1,  1975;  40  FR
38571, Aug. 21,.1975,  as amended  at  43  FR 5786,  Feb. 9,  1978;
amended at 53 FR 15952, May  4,  1988;


                               - 78 -

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Criteria
                       PHYS/CHEM-1

                PHYSICAL/CHEMICAL HAZARDS

                                  Required Label  Statement
I.  Pressurized Containers
A.
        Flashpoint at or below
        20°F; or if there is a
        flashback at any valve
        opening.
    B.
    Flashpoint above 20°F
    and not over 80°F; or
    if the flame extension
    is more than 18 inches
    long at a distance of
    6 inches from the
    valve opening.

    All Other Pressurized
    Containers
II.  Non-Pressurized Containers

    A.  Flashpoint at or below
        20°F.
    B.  Flashpoint above 20°F
        and not over 80°F.

    C.  Flashpoint over 80°F
        and not over 150°F.

    D.  Flashpoint above
        150°F.
Extremely flammable.
Contents under pressure.
Keep away from fire,  sparks,
and heated surfaces.   Do  not
puncture or incinerate
container.  Exposure  to
temperatures above 130°F
may cause bursting.

Flammable.  Contents  under
pressure.  Keep away  from
heat, sparks, and flame.   Do
not puncture or incinerate
container.  Exposure  to
temperatures above 130°F
may cause bursting.

Contents under pressure.
Do not use or store near
heat or open flame.  Do not
puncture or incinerate
container.  Exposure to
temperatures above 130°F
may cause bursting.
                                  Extremely flammable.  Keep
                                  away from fire, sparks, and
                                  heated surfaces.

                                  Flammable.  Keep away from
                                  heat and open  flame.

                                  Do not use or  store near
                                  heat and open  flame.

                                  None required.
                              -  79  -

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                            STOR-1

             STORAGE INSTRUCTIONS FOR PESTICIDES

Heading;

All products are required to bear specific label  instructions
about storage and disposal.   Storage and  disposal  instructions
must be grouped together in the directions for  use portion  of
the label under the heading STORAGE AND DISPOSAL.   Products
intended solely for domestic use need not include  the  heading
"STORAGE AND DISPOSAL."

Storage Instructions;

All product labels are required to have appropriate storage
instructions.   Specific storage instructions  are not prescribed.
Each registrant must develop his own storage  instructions.
considering, when applicable, the following factors:

1.  Conditions of storage that might alter the  composition  or
    usefulness of the pesticide.  Examples could be temperature
    extremes,  excessive moisture or humidity, heat, sunlight,
    friction,  or contaminating substances or  media.

2.  Physical requirements of storage which might  adversely
    affect the container of the product and its ability to
    continue to function properly.  Requirements  might include
    positioning of the container in storage,  storage or damage
    due to stacking, penetration of moisture, and ability to
    withstand  shock or friction.

3.  Specifications for handling the pesticide container,
    including  movement of container within the  storage area.
    proper opening and closing procedures  (particularly for
    opened containers) , and measures to minimize exposure
    while opening or closing container.

4.  Instructions on what to do if the container is damaged in
    any way, or if the pesticide is leaking or has been
    spilled, and precautions to minimize  exposure  if damage occurs

5.  General precautions concerning locked  storage, storage  in
    original container only, and separation of pesticides
    during storage to prevent cross-contamination  of other
    pesticides, fertilizer, food, and feed.

6.  General storage  instructions for household products  should
    emphasize storage  in original container  and placement  in
    locked storage areas.
                              -  80 -

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                                PEST/DIS-1

                     PESTICIDE DISPOSAL INSTRUCTIONS

The label of all products, except those intended solely for domestic
use, must bear explicit instructions about pesticide  disposal.  The
statements listed below contain the exact wording that must appear on
the label of these products:

1.  The labels of all products, except domestic use,  must contain the
statement, "Do not contaminate water, food, or feed by storage or disposal."

2.  Except those products intended solely for domestic use, the labels
of all products that contain active ingredients that  are Acute Hazardous
Wastes or are assigned to Toxicity Category I on the  basis of oral or
dermal toxicity, or Toxicity Category I or II on the  basis of acute
inhalation toxicity must bear the following pesticide disposal statement:

    "Pesticide wastes are acutely hazardous.  Improper disposal of
    excess pesticide, spray mixture, or rinsate is a  violation of Federal
    Law.  If these wastes cannot be disposed of by use according to
    label instructions, contact your State Pesticide  or Environmental
    Control Agency, or the Hazardous Waste representative at  the nearest
    EPA Regional Office for guidance."

3.  The labels of all products, except those intended for domestic use,
containing active or inert ingredients that are Toxic Hazardous Wastes
or meet any of the criteria in 40 CFR 261, Subpart C for a hazardous
waste must bear the following pesticide disposal statement:

    "Pesticide wastes are toxic.  Improper disposal of excess pesticide,
    spray mixture, or rinsate is a violation of Federal Law.   If these
    wastes cannot be disposed of by use according to label instructions,
    contact your State Pesticide or Environmental Control Agency,  or the
    Hazardous Waste representative at the nearest EPA Regional Office
    for guidance."

4.  Labels for all other products, except those  intended  for domestic
use, must bear the following pesticide disposal  statement:

    "Wastes resulting from the use of this product may be disposed of  on
    site or at an approved waste disposal facility."

5.  Products intended for domestic use only must bear the following
disposal statement:  "Securely wrap original container in several layers
of newspaper and discard in trash."
                                    -  81 -

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                          CONT/DIS-1

               CONTAINER DISPOSAL INSTRUCTIONS

    The label of each product must bear container  disposal
instructions appropriate to the type of container.

    !•  Domestic use products must bear one of  the following
container disposal statements:
Container Type
Statement
Non-aerosol products
(bottles, cans, jars)
Non-aerosol products
(bags)
Aerosol products
Do not reuse container (bottle, can, jar).
Rinse thoroughly before discarding in trash.
Do not reuse bag. Discard bag in trash.
Replace cap and discard containers in
trash. Do not incinerate or puncture.
    2.  All other products must bear container disposal  instructions,
based on container type,listed below:
 Container Type
 Statement
Metal
containers
(non-aerosol)
Plastic containers
Glass containers
Fiber drums
with liners
Paper and
plastic bags
Compressed gas
cylinders
Triple rinse (or equivalent) . Then offer
for recycling or reconditioning, or puncture
and dispose of in a sanitary landfill, or by
other procedures approved by state and local
authorities.
Triple rinse (or equivalent). Then offer
for recycling or reconditioning, or puncture
and dispose of in a sanitary landfill, or
incineration, or, if allowed by state and
local authorities, by burning. If burned,
stay out of smoke.
Triple rinse (or equivalent). Then dispose
of in a sanitary landfill or by other
approved state and local procedures.
Completely empty liner by shaking and
tapping sides and bottom to loosen clinging
particles. Empty residue into application
equipment. Then dispose of liner in a
sanitary landfill or by incineration if
allowed by state and local authorities.
If drum is contaminated and cannot be
reused!, dispose of in the same manner.
Completely empty bag into application
equipment. Then dispose of empty bag in
a sanitary landfill or by incineration,
or, if allowed by State and local
authorities, by burning. If burned, stay
out of smoke.
Return empty cylinder for reuse (or
similar wording) \
  J_/ Manufacturer may replace this phrase  with  one  indicating
     whether and how fiber drum may be  reused.
                               -  82  -

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III.  BIBLIOGRAPHY APPENDICES
             - 83 -

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                            BIBGUIDE-1

              GUIDE TO USE OF THIS BIBLIOGRAPHY


1.  CONTENT OF BIBLIOGRAPHY.  This bibliography contains
    citations of all studies considered relevant by EPA in
    arriving at the positions and conclusions stated elsewhere
    in the Standard.  Primary sources for studies in this
    bibliography have been the body of data submitted to EPA
    and its predecessor agencies in support of past regulatory
    decisions.  Selections from other sources including the
    published literature, in those instances where they have
    been considered, will be included.

2.  UNITS OF ENTRY.  The unit of entry in this bibliography
    is called a "study."  In the case of published materials,
    this corresponds closely to an article.  In the case of
    unpublished materials submitted to the Agency, the Agency
    has sought to identify documents at a level parallel to
    the published article from within the typically larger
    volumes in which they were submitted.  The resulting
    "studies" generally have a distinct title (or at least a
    single subject), can stand alone for purposes of review,
    and can be described with a conventional bibliographic
    citation.  The Agency has attempted also to unite basic
    documents and commentaries upon them, treating them as a
    single study.

3.  IDENTIFICATION OF ENTRIES.  The entries in this bibliography
    are sorted numerically by "Master Record Identifier,"  or
    MRID, number.  This number is unique to the citation,  and
    should be used at any time specific reference is required.
    It is not related to the six-digit "Accession Number"
    which has been used to identify volumes of submitted
    studies; see paragraph 4(d)(4) below for a further explana-
    tion.  In a few cases, entries added to the bibliography
    late in the review may be preceded by a nine-character
    temporary identifier.  These entries are listed after
    all MRID entries.  This temporary identifier number is
    also to be used whenever specific reference  is needed.

4.  FORM OF ENTRY.  In addition to the Master Record  Identifier
    (MRID) , each entry consists of a citation containing
    standard elements followed, in the case of material
    submitted to EPA, by a description of  the earliest known
    submission.  Bibliographic conventions  used  reflect the
    standards of the American National Standards  Institute
    (ANSI), expanded to provide for  certain  special  needs.
                              -  84  -

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                        BIBGUIDE-2

a.  Author.  Whenever the Agency could  confidently  identify
    °ne, the Agency has chosen to show  a  personal author.
    When no individual was identified,  the  Agency has
    shown an identifiable laboratory or testing  facility
    as author.   As a last resort, the Agency  has shown
    the first submitter as author.

b.  Document Date.  When the date appears as  four digits
    with no question marks, the Agency  took it directly
    from the document.  When a four-digit date is followed
    by a question mark, the bibliographer deduced the
    date from evidence in the document.  When the date
    appears as (19??), the Agency was unable  to  determine
    or estimate the date of the document.

c.  Title.  In some cases, it has been  necessary for
    Agency bibliographers to create or  enhance a document
    title.  Any such editorial insertions are contained
    between square brackets.

d.  Trailing Parentheses.  For studies  submitted to the
    Agency in the past, the trailing parentheses include
    (in addition  to any self-explanatory text)  the  fol-
    lowing elements describing the earliest known  submission:

    (1)  Submission Date.  The date of the earliest known
         submission appears immediately  following  the word
         "received."

    (2)  Administrative Number.  The next element,
         immediately following the word  "under," is the
         registration number, experimental use permit
         number,  petition number, or other administrative
         number associated with  the  earliest known submission,

    (3)  Submitter.  The  third element is  the submitter,
         following the phrase "submitted by."  When
         authorship is defaulted to  the  submitter, this
         element  is omitted.

    (4)  Volume Identification  (Accession  Numbers).  The
         final element in  the trailing parentheses
         identifies the  EPA accession  number of the volume
         in which the original submission  of the study
         appears.  The six-digit accession number  follows
         the symbol "CDL,"  standing for  "Company Data
         Library."  This  accession  number  is in turn
         followed by an  alphabetic  suffix  which shows  the
         relative position  of  the  study  within  the volume.
         For example, within  accession number 123456,  the
         first  study would  be  123456-A;  the  second. 123456-
         B;  the 26th.  123456-Z;  and the  27th, 123456-AA.


                          -  85 -

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                 OFFICE OF PESTICIDE PROGRAMS
              REGISTRATION STANDARD BIBLIOGRAPHY
 Citations Considered to be Part of the Data Base Supporting
         Registrations Under the Metaldehyde Standard

MRID         Citation

00033213 Leganer, R.R.; Getzin, L.W.; Kimura, Y.; et al.
     (1962) Pesticide Residue Analysis.  (Unpublished study
     received Mar 9, 1964 under 271-12; prepared by
     Washington State Univ., Dept. of Agricultural Chemistry,
     submitted by International Minerals & Chemical Corp.,
     Terre Haute, Ind.; CDL:001932-B)

00090362 McCann, J.A.  (1972) [Metaldehyde 99%:  Bluegill
     (Lepomis macro chirus)]: Test No. 454.   (U.S.
     Agricultural Research Serv- ice, Pesticides Regulation
     Div., Animal Biology Laboratory, Fish Toxicity
     Laboratory; unpublished study; CDL:130286-A)

00127144 Morgareidge, K.  (1964) Analysis of Bananas for
     Residues of Metaldehyde: Laboratory No. 85214 a-g, 85352
     a-f, 85385 a-f.  (Unpublished study received May 9, 1964
     under unknown admin, no.; prepared by Food and Drug
     Research Laboratories, Inc., submitted by United Fruit
     CO., Boston, MA; CDL:119840-A)

00127145 Jones, L. (1956) Determination of Metaldehyde Spray
     Residue: R.D.M.-6804.  (Unpublished study received Mar
     19, 1957 under 271-12; submitted by International
     Minerals & Chemical Corp., Terre Haute, IN;
     CDL:119896-A)

00131429 Berczy, Z.; Cobb, L.; Cherry, C.  (1973) Acute
     Inhalation Toxicity to the Rat of Metaldehyde Dust:
     LZA1/73891.  (Unpublished study received Aug 19, 1983
     under 6836-90; prepared by Huntingdon Research Centre,
     Eng., submitted by Lonza, Inc., Fair Lawn, NJ;
     CDL:251377-A)

00131434 Davies, R. ; Collins, C. (1974) Acute Percutaneous
     Toxicity to Rats of Metaldehyde: Report No. 2330/D3/74.
     (Unpublished study received Aug 19, 1983 under 6836-90;
     prepared by Huntingdon Research Centre, Eng., submitted
     by Lonza, Inc., Fair Lawn, NJ; CDL:251377-F)

00131435 Hackenberg, U. (1973) Acute Toxicity of Metaldehyde
     after Administration of a Single Intragastric Dose to
     Female Rats: A 0409/1061.2.   (Unpublished study received
     Aug 19, 1983 under 6836-90; prepared by Institute fur
     Biologische Forschung GmbH, submitted by Lonza, Inc.,
     Fair Lawn, NJ; CDL:251377-G)
                            -  86  -

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                 OFFICE OF PESTICIDE PROGRAMS
              REGISTRATION STANDARD BIBLIOGRAPHY
 Citations Considered to be Part of the Data Base Supporting
         Registrations Under the Metaldehyde Standard

MRID         Citation

00131969 Hackenberg, U.  (1973) Acute Toxicity of Metaldehyde
     after a Single Intragastric Dose in the Male Rat: Report
     A 0409/1061.1; Inbifo Code No. S 2221 A.   (Unpublished
     study received Sep 6, 1983 under 6836-90; prepared by
     Inbifo Institut fur Biologische Forschung, W. Ger.,
     submitted by Lonza, Inc., Fair Lawn, NJ;  CDL:251378-A)

00131971 Jones, J.; Hoare, A.  (1983) P0071: A Primary Skin
     Irritation and Corrosivity Study in the Rabbit: Report
     No. 3478-733/165.   (Unpublished study received Sep 6,
     1983 under 6836-90; prepared by Hazleton Laboratories
     Europe, Ltd., Eng., submitted by Lonza, Inc., Fair Lawn,
     NJ; CDL:251380-A)

00138262 Interregional Research Project No. 4 (1974) The
     Results of Tests on the Amount of Metaldehyde Residue
     Remaining in or on Strawberries Including a Description
     of the Analytical Methods Used. (Compilation;
     unpublished study received Jun 19, 1974 under 4E1519;
     CDL:072538-A)

00163832 Debets, F. (1986) Evaluation of the Ability of P0071
     To Induce Chromosome Aberrations in Cultured Chinese
     Hamster Ovary  (CHO) Cells: NOTOX 0227/EC 112.
     Unpublished study prepared by NOTOX V.O.F.   23 p.
                            -  87  -

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IV.   FORM APPENDICES
       -  88 -

-------
          EPA Form  8580-1
OMB Approval  No.   2070-0057
Expires  11/30/89
                FIFHA SECTION 3ICH2H6) SUMMARY SHEET
                                                                                                  NO
PRODUCT NAME
          S NAME
                                                                                DATE GUIDANCE DOCUMENT ISSUED
 With rvptct to tttt rtouirtmtnt to Mbmit "|tntric" d«U impend by th« FIFRA action 3(C)(2KBI iwtict eenttintd m the rifcftneid
 Guidmct Oocurntnt. I am responding m ttit following monnir:
    G I. I will aibmit dm in i ttmiiy mitwitr to •tidy ttit following requirtmtnu. II thi mt proctdum I wiH vm dtmni (rom (or irt not
         WKifwd in) th« fttfinmion Guidtiinm or ttw frotocoli contunod HI tftt M«p«ra •< Ciptn Groupt to tn« Ch»m««ti Group. OECO
         Crtwniult Tonmf Progremmt. I melon tht pfoteceU thn I will UN:                                         '
    D i  I h*vt «nttrtd into M oorotmmt with ont or mort othor rttotnntt undor FIFMA Hction 3(C)(2)(l)(u) to atufy tht following dtu
          nquirtmtnn Th« ttm. ind my rtquirtd protocols, will bf wbmrntd to EPA by:
  NAME Of OTHE* REGISTRANT
    D 3.  t incloa i comptittd "CtnHiution ol Animpt to Enttt Into in Ao/Mmtnt with Othir Rtt>nr*nu tor Dtvitopmint ot 0*ti" with
          rttptct to tftt following dao nquiromtntt:
    C 4.  I nquon tnit you om«nd my ro|Hmtion by doiofiflf KM (ollowmi iu» (thu option • not •vtiltoii to icplicinu (or ntw produco):
     C S. I rtquin voluntory cinetllttion of tht rt|imtion 0« thu product (Thu option it not miiibli to tpplcinu lor niw product!.)
 MGirrRANT'I AUTHORIZED REPRESENTATIVE
                                                   SIGNATURE
                                                     -  89  -
                                 DATE

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                                                  CMB Approval No. 2070-0057
                                                  Expiration Date 11/30/89
                           GENERIC DATA EXEMPTION STATEMENT
ERA Product Registration Number:
Registrant's Name and Address:
As an authorized representative of the registrant of the product identified above,  I
certify that:

(1)  I have read and am familiar with the terms of the Notice from EPA dated
	 concerning a requirement for submission of "generic" data on the active
ingredient	 named under FIFRA Section 3(c) (2) (B).

(2)  My firm requests that EPA not suspend the registration of our product, despite
our lack of intent to submit the generic data in question, on the grounds that the
product contains the active ingredient solely as the result of the incorporation into
the product of another product which contains that active ingredient, which is
registered under FIFRA Section 3, and which is purchased by us from another producer.

(3)  An accurate Confidential Statement of Formula (CSF) for the above-identified
product is attached to this statement.  That formula statement indicates, by company
name, registration number, and product name, the source of the subject active
ingredient in my firm's product, or

The CSF dated	 on file with EFA is complete, current and accurate and
contains the information requested on the current CSF Form 8570-4.  The registered
source(s) of the above named active ingredient in my product(s) is/are	 and
their registration number(s) is/are	.

My firm will apply for an amendment to the registration prior to changing the source
of the active ingredient in our product.

(4)  I understand, and agree on behalf of my firm, that if at any time any portion of
this Statement is no longer true, or if my firm fails to comply with the undertakings
made in this Statement, my firm's product's registration may be suspended under FIFRA
Section 3(c)(2)(B).

(5)  I further understand that if my firm is granted a generic data exemption for the
product, my firm relies on the efforts of other persons to provide the Agency with the
required generic data.  If the registrant (s) who have committed to generate and submit
the required data fail to take appropriate steps to meet requirements or are no longer
in compliance with this Notice's data requirements, the Agency will consider that both
they and my firm are not in compliance and will normally initiate proceedings to
suspend the registrations of my firm's product (s) and their product (s), unless my firm
commits to submit and submits the required data in the specified time  frame.  I
understand that, in such cases, the Agency generally will not grant  a  time extension
for submitting the data.
Registrant's  authorized representative;      	
                                                   (Signature)
Dated:	
                                                      (Typed)
 EPA Form 8570- 3
                                       -  90  -

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                                                       OMB Approval No. 2070-0057
                                                       Expires 11/30/89
EPA Reg. No..
 PRODUCT SPECIFIC DATA REPORT

	   Date	
Guidance Document for

Registration
Guideline No.
Subpart C
PRODUCT
CHEMISTRY
61-1
61-2
61-3
62-1
62-2
62-3
63-2
63-3
63-4
63-5
63-6
63-7
63-8
63-9
63-10
63-11
fi.V-12
,
Name of Test

Identity of
incrredients
Statement of
composition
Discussion of
formation of
incrredients
Preliminary
analysis
Test not
required
for my
product
listed
above
(check
below)


I am complying with
data rpqni remPTYt-s hv
Citing MRID
Number or
EPA Accession
Number






Certification of
limits
Analytical methods
for enforcement
limits J

Submit-
ting
Data (For EPA Use Only)
(At- MRID Numbers
tached) Assioned









Color
Phvsical state
Odor
Meltina roint
Boilina coint
Density, buUc-
density, or
specific aravitv
Solubility
Vapor pressure
Dissociation
constant
Octanol/water
partition
coefficient
TH























EPA Form 8580-4
                                       -  91 -

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                                                  OMB Approval No.  2070-0057
                                                  Expires 11/30/89
EPA Reg. No..
 PRODUCT SPECIFIC DATA REPORT  (cont'd)

	Date	
Guidance Document for

Registration
Guideline No.
Subpart C
PRODUCT
CHEMISTRY
(cont'd)
63-13
63-14
63-15
63-16
63-17
63-18
63-19
63-20
63-21
Sec. 158.340
TOXICOLOGY
81-1
81-2
81-3
81-4
81-5
81-6
81-7
Name of Test

Stability
Oxidizing/reducing
reaction
Flammability
Fxplortahility
Storaae stability
Viscosity
Miscibilitv
Corrosion
characteristics
Dielectric break-
down voltaae

Acute oral
toxicity, rat
Acute dermal
toxic if y, rabbit
Acute inhalation,
toxic ity. rat
Primary eye
irritation, rabbit
Primary dermal
irritation
Dermal sensitiza-
tion.
Acute Delayed
neurotoxicitv. hen
Test not
required
for my
product
listed
above
(check
below)












I am complying with
data requirements bv
Citing MRID
Number or
EPA Accession
Number


















Submit-
ting
Data
(At-
tached)














(For EPA Use Only)
MRID Numbers
Assigned


















EPA Form 8580-4  (cont'd)
                                       - 92  -

-------
           EPA  Form  8580-6
                                                        OMB Approval  NO.   2070-0057
                                                        Expires 11/30/89
 (To tummy. cerr/n/4U four inrmt
                                      CERTIFICATION OF ATTEMPT TO ENTER
                                 INTO AN AGREEMENT WITH OTHER REGISTRANTS
                                           FOR DEVELOPMENT OF DATA
1. I em duly ouihorizod to represent the following firm(s) who ere subject to the require-
  ments of e Notice under FIFRA Section 3(c)(2IIB) contained in e Guidance Document
  to submit dau concerning the active ingfedient:
                                                                               OUIOANCt OOCUMINT O*T|
                                                                               ACTIVf
                                   MA*M Of FIRM
                                                                                       CFA COMPANY NUMBCH
 n nn tirm or group ot firms is referred to below as my firm".)
 2. My firm is willing to develop and submit the data • required by thn Notice. if necessary. However. my firm would prefer to enter
   into an agrMmcnt with one or more other registreim to develop jointly, or to share in the eon of developing, the following required
   items or data:
3. My firm das offered m writing to enter fata such a* agreement Copies of the often an attached. That offer MS irrevocable and included an offer to be
   bound by an arbitration decision vndor FIFHA Section XcMZHIHM)» fin* eajeiment en a« terns eowld not bs riser* otherwise This offer w^
   to thi following firm(i) on the following datadt:
                                   MAMIOf FIMM
                                                                                           OATI OF OFFIM
However, none of those firm (si accepted my offer.
4. My firm requests that 6PA not suspend the registrations) of my firm's produet(s). if any of the firms named in paragraph (3) above
  heve egreed to submit the data lined in paragraph (2) above in accordance with the Notice. 1 understand EPA will promptly inform
  me whether my firm must submit data to avoid suspension of its regmretiondl under FIFRA Section 3(c«2)(8l. (This statement
  does not apply to applicants for new products.)  1 give EPA permission to disclose this statement upon request.
                                                  aiONATUMC
                                                                                                  DAT!
                                                        -  93  -

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