Unhad Stttw
Environmental Protactlon
Agancy.
Off ioi of
Pacticida* and Toxic Subattneai
WMMngton DC 20460
                          March 1982
PMtieidw
MCPA

(4-chloro-2-
methylphenoxyacetic acid)
Pesticide Registration
Standard

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      MCPA and  its Salts and  Esters
     Pesticide  Registration Standard
              Support Team

Denise M. Keehner        Project Manaqer  (SPRD)
Anthony B. Hall          Project Manager  (SPRD)
Paul N. Parsons          Project Manager  (SPRD)
Stephanie April          Toxicologist  (HED)
George Beusch            Chemist (HED)
Ray Rent                 Chemist (HED)
John Jordan              Microbiologist  (HED)
Mike Rexrode             Fishery Biologist  (HED)
Steve Hopkins            Plant Physiologist  (HED)
Al Vaughn                Entomologist  (HED)
Bruce Sidwell            Plant Physiologist  (BFSD)
Roger Hoitorf            Economist  (BFSD)
Richard Mountfort        Product Manager  (RD)
              March, 1982
Office of Pesticides and Toxic Substances
     Environmental Protection Agency
           401 M Street, S.W.
         Washington, D.C.   21460

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                               TABLE OF CONTENTS

Chapter One                                                 Page Number
    How to Register Under a  Registration Standard               1
         Organization of the Standard                           1
         Purpose of the Standard          '                       1
         Requirement to Re-register  Under the Standard          3
         "Product Specific"  Data  and "Generic" Data             3
         Data Compensation Requirements under FIFRA 3(c)(l)(D)  5
         Obtaining Data to Fill "Data Gaps"                      6
         Amendments to the Standard                              7

Chapter Two
    Agency Position on MCPA
         Introduction                                            9
         Description of Chemical                                 9
         Regulatory^Position                                    9
         Regulatory Rationale                                  10
         Dietary Risk                                           11
         Applicator Exposure                                   12
         Test Substances for Required Testing                  13
         Potential for Nitrosomine Contamination               13
         Potential for Dioxin Contamination                     13

Criteria for Registration Under the  Standard                   14
    Manufacturing-Use MCPA                                      14
         Acceptable Ranges and limits                          14
              Product Composition Standard                     14
              Acute Toxicity Limits                             14
              Use Patterns                                      IS
         Required Labeling                                      15
    End-Use Products                                            16
         Acceptable Ranges and Limits                          16
              Product Composition Standard                     16
              Acute Toxicity Limits                             16
              Use Patterns and Application Methods             17
         Additional Uses                                        17
         Required Labeling                                      17

Chapter Three
    Data Requirements and Data Gaps                             19
         Manufacturing-Use MCPA                                 19
              Generic Data Requirements                        19
              Product Specific Data  Requirements:
                   Manufacturing  the MZPA                      20
 .   End-Use MCPA Products                                       21
         Product Speciic Data Requirements for
              End-Use Products                                  21

Chapter Four
    Product Chemistry of MCPA                                  35
    Introduction
         Manufacturing-Use MCPA
              Product Chemistry Profile
              Topical Discussions
                   Chemical  Identify

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                   Manufacturing Process                       3?
                   Discussion of the Formation of              37
                        Unintentional Ingredients
                   Declaration and  Certification of            3t
                        Ingredient  Limits
                   Product  Analytical Methods and Data         ^
                   Physical  and Chemical Properties            yg
                   Sunroary  of Major Data Gaps                  *1
                   Labeling Requirements         -              3<\
         End-Use MCPA                                          V°
              Product Chemistry Profile                        ^°
              Topical Discussions
                   Chemical Identiy                            V°
                   Active Ingredients in Pesticide Products    H°
                   Product  Analytical Methods and Data         V(
                   Physical  and Chemical Properties            f
                   Labeling Requirements                       *||'
                   ' *
Chapter Five
    Environmental Fate of M2PA
         Introduction                                          VJ
              Use Profile                                       V*
              Environmental  Fate Profile                       VI
              Exposure Profile                                 &
              Topical Discussions
                   Physico-Chemical Degradation                *°
                   Metabolism                                  '°
                   Mobility                                    5A
                   Groundwater Contamination                   SA
                   Dissipation                                 *>}
                   Label Restrictions                          $1

Chapter Six
    Toxicology of MCPA
         Introduction                                          5y
              Manufacturing-Use MCPA                           J'f
                   Toxicology Profile                          5^
                   Acute Toxicity                              54
                   Acute Delayed Neurotoxicity                 5H
                   Subchronic Testing                          5M
                   Teratogenicity and Mutagenicty Testing      5f
                   Reproduction                                Tf
                   Metabolism                                  '&
              Topical Discussions                              55"
                   Acuate Oral Toxicity                        &
                   Acute Dermal Toxicity                       5V
                   Acute Inhalation Toxicity                   "&
                   Primary  Eye Irritation                      ST.
                   Primary  Dermal Irritation                   Sk
                   Dermal Sensitization                        *>!»
                   Acute Delayed Neurotoxicity                 &
                   Subchronic Inhalation Toxicity              S^
                   Subchronic Neurotoxicity                    fco
                   Chronic  Feeding                              (*>o
                   Oncogenicity                                to
                   Teratogenicity                              t|

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                   Reproduction                                 W
                   Mutagenicity                                 ^
                   Metabolism                                   (6
                   Human Exposure                               
                        Butyl  and Isopropyl Ester Mixtures     &

Chapter Seven       ^
    Residue Chemistry of MCPA
         Residue Chemistry Profile                              TO
         Data Requirements and Data  Gaps                       7o
              Topical Discussion                                7<
                   Uptake, Distribution, and Metabolism
                        in Plants                               71
                   Metabolism  in food-Producing Animals        7^
                   Analytical  Methods                          7^
                   Residues  in Plants                          13
                   Residues  in Food-Producing Animals          7?
                   Other Sites                                 
                   Effects on  Estuarine and Marine Organisms   11
                   Effects on  Freshwater Aquatic Invertebrates 11
                   Effects on  Beneficial Insects               I"6

Chapter Nine
    Case Bibliography                                           .  .
    Guide to Use of Bibliography                                m
         Section I

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                                   Chapter I

                                HOW TO REGISTER
                         UNDER A REGISTRAT1CN  STANDARD

Organization of the Standard
Purpose of tne Standard
Requirement to Re-register Under tne  Standard
"Product Specific" Data and "Generic"  Data
Delta Compensation Requirements under  FIFRA 3(c)(l)(D)
Obtaining Data to FiU "Data Gaps;" FIFRA 3(c)(2)(B)
Amendments to the Standard

Organization of the Standard

Tnis first cnapter explains the purpose of a Registration Standard and
summarizes the legal principles involved in registering or re-registering
under a Standard.  The second chapter sets forth the  requirements that must be
met to obtain or retain registration  for products covered by this particular
Registration Standard.  In the remaining chapters, the Agency reviews tne
available data by scientific discipline,  discusses the Agency's concerns with
tne identified potential hazards,  and  logically develops the conditions and
requirements that would reduce those  hazards to acceptable levels.

Purpose of the Standard

Section 3 of the Federal Insecticide,  Fungicide, and  Rodenticide Act (FIFRA)
provides that "no person "in" any State  may distribute,  sell, offer for
sale, hold for sale, ship, deliver for shipment, or receive (and having so
received) deliver or offer to deliver, to any  person  any pesticide which is
not registered with tne Administrator [of EPA)."  To  approve tne registration
of a pesticide, the Administrator  must find, pursuant to Section 3(c)(5) tnat:

         "(A)  its composition is  such as to warrant  the proposed claims for
               it;
         (B)   its labeling and other material required to be submitted comply
               with the requirements of this Act;
         (C)   it will perform its intended function  without unreasonable
               adverse effects on  the  environment; and
         (D)   wnen used in accordance with widespread and commonly recognized
               practice it will not generally  cause unreasonable adverse
               effects on the environment."

In making these findings, the Agency  reviews a wide range of data which
registrants are required to submit, and assesses tne  risks and benefits
cissociated with the use of the proposed pesticide.  But the established
approacn to making these findings  has been found to be defective on two counts:

First, EPA and its predecessor agency, the United States Department of
Agriculture (USDA), routinely reviewed registration applications on a 'product-
by-product1 basis, evaluating each product-specific application somewhat
independently.  In the review of products containing  similar components, there

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was little opportunity  for a  retrospective review of the full range of
pertinent data available  in Agency files and in the public literature.  Thus
the 'product-by-product'  approacn  was  often inefficient and sometimes resulted
in inconsistent or  incomplete regulatory judgements.
Second, over the years, as a  result  of inevitable and continuing advances in
scientific knowledge, methodology,  and policy,  the data base for nany
pesticides came to  be considered inadequate- by  current scientific and
regulatory standards.   Given  the long  history of pesticide regulation in
several agencies, it is even  likely  that materials may have been lost from the
data files.  When EPA issued  new requirements for registration in 1975 (40 CFR
162) and proposed new guidelines for hazard testing in 1978 (43 FR 29686, July
10, 1978 and 43 FR  37336, August 2,  1978), many products that had already been
registered for years were being sold and used without the same assurances of
human and environmental safety as  was  being required for new products.  Because
of this inconsistency,  Congress directed EPA to re-register all previously
registered products, so as to bring  their registrations and their data bases
into conpliance with current  requirements [See  FIFRA Section 3(g)].
                     • *
Facing the enormous job of re-reviewing and oalling-in new data for the
approximately 35,000 current  registrations, and realizing the inefficiencies
of the 'product-by-product' approach,  the Agency decided that a new, more
effective method of review was needed.

A new review procedure  has been developed.  Under it, EPA publishes documents
called Registration Standards, each  of which discusses a particular pesticide
active ingredient.  Each  Registration  Standard  summarizes all the data avail-
able to the Agency  on a particular active ingredient and its current uses, and
sets forth the Agency's comprehensive  position  on the conditions and require-
ments for registration  of all existing and future products which contain that
active ingredient.  These conditions and requirements, all of which must be
met to obtain or retain full  registration or re-registration under Section
3(c)(5) of FIFRA, include tne submission of needed scientific data which the
Agency does not now have, compliance with standards of toxicity, composition,
labeling, and packaging,  and  satisfaction of the data compensation provisions
of FIFRA Section 3(c)(l)(D).

The Standard will also  serve  as a  tool for product classification.  As part of
the registration of a pesticide product, EPA may classify each product for
"general use" or "restricted  use"  [FIFRA Section 3(d)J.  A pesticide is
classified for "restricted use" when seme special regulatory restriction is
needed to ensure against  unreasonable  adverse effects to man or the
environment.  Many  such risks of unreasonable adverse effects can be lessened
if expressly-designed label precautions are strictly followed.  Thus the
special regulatory  restriction for a "restricted use" pesticide is usually a
requirement that it be  applied only by, or under the supervision of, an
applicator who has  been certified  by the State  or Federal government as being
competent to use pesticides safely,  responsibly, and in accordance with label
directions.  A restricted-use pesticide can have other regulatory restrictions
[40 CFR 162.11(c)(5)] instead of,  or in addition to, the certified
applicator requirement.  These other regulatory restrictions may include such
actions as seasonal or  regional limitations on  use, or a requirement for the
monitoring of residue levels  after use.  A pesticide classified for "general

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use," or  not  classified  at all,  is available for use by any individual who  is
in compliance with  Stste or local regulations.  The Registration Standard
review cmpares  information about potential adverse effects of specific uses
oi: tne pesticides witn risk criteria listed in 40 CFR 162.11(c), and tnereby
determines vnether  a  product needs to he classified for "restricted use."   If
tne Standard  does classify a pesticide for "restricted use," this
determination is stated  in the second chapter.

Requirement ^o Re-register Under tne Standard

FIFRA Section 3(g), as amended in 1978,  directs EPA to re-register all
currently registered  products as expeditiously as possible.  Congress also
agreed tnat re-registration should be accomplished by the use of Registration
Standards.

Each registrant  of  a  currently registered product to which this Standard
applies,  and  who wishes  to continue to sell or distribute his product in
commerce, must apply-for re-registration.  His application must contain
proposed  labeling that complies  with this Standard.

EPA will  issue a notice  of intent to cancel the registration of any currently
registered product  to which this Standard applies if the registrant
fails to  comply  with  tne procedures for re-registration set forth in the
Guidance  Package which accompanies this Standard.

"Product  Specific"  Data  andj"Generic" Data
In  the course of  developing th is"Standard yEPA"has~rteterm it ial lhe--types-of	
data  needed  for evaluation of the properties and effects of products to which  ~
the Standard applies,  in the disciplinary areas of Product Chemistry,
Ehvironmental Fate,  Ibxicology,  Residue Chemistry, and Ecological Effects.
These determinations are based primarily on the data Guidelines proposed  in
1978  (43  FR  29686, July 10,, 1978, and 43 FR 37336, August  2, 1978), as applied
to  the use patterns  of  the products to which this Standard applies.  Where it
appeared  that data from a normally applicable Guidelines requirement was
actually  unnecessary to evaluate these products, the Standard indicates that
tne requirement has  been waived.  On the other hand, in some cases studies not
required  by  the Guidelines may be needed because of the particular composition
or  use pattern of products the Standard covers; if so, the Standard explains
the Agency's reasoning.  Data guidelines have not yet been proposed for the
Residue Chemistry discipline but the requirements for such data have been in
effect for seme tine and are, the Agency believes, relatively familiar to
registrants.  Data which we;have found are needed to evaluate tne registra-
bility of sere products covered  by the Standard may not be needed for the
evaluation of other  products, depending upon the composition, formulation
type, and intended uses of the product in question.  The Standard states  which
data  requirements apply to which product categories.  (See tne second
chapter.) The various  kinds of  data normally required for registration of a
pesticide product can be divided into two basic groups:

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     (A)  data  that  is  "product specific," i.e., data tnat relates only to tne
         properties or effects of  a product with a particular ccmposition (or
         a group of products  with  closely similar composition); and

     (B)  "generic" data that  pertains to the properties or effects of a
         particular ingredient,  and thus is'relevant to an evaluation of risks
         and benefits  of all  products containing that ingredient (or all such
         products having a  certain use pattern), regardless of any such
         product's unique composition.

The Agency requires certain "product specific" data for each product to
characterize the product's  particular composition and physical/chemical
properties (Product Chemistry),  and to characterize the product's acute
toxicity (wnich is a function of its total composition).  The applicant for
registration or re-registraton of  any product, whether it is a manufacturing-
use or end-use product, and without regard to its intended use pattern, must
submit or cite enough'JctL this kind of data to allow EPA to evaluate the
product.  For such purposes,  "product specific" data on any product other than
the applicant's is irrelevant,  unless the other product is closely similar in
composition to the applicant's.  (Where it has been found practicable to group
similar products for purposes of evaluating,  with a single set of tests, all
products in the group,  the  Standard so indicates.)  "Product specific" data on
the efficacy of particular  end-use products is also required where the exact
formulation may affect efficacy and where failure of efficacy could cause
public health problems.     j

All other data needed  to evaluate  pesticide products coneerns-^tne-properties
or effects of a particular  ingredient of products (normally a pesticidally
active ingredient, but in seme cases a pesticidally inactive, "inert,"
ingredient).  Some data in  this "generic" category are required to evaluate
the properties and effects  of all  products containing that ingredient [e.g.,
the acute ID-50 of the active ingredient in its technical or purer grade; see
proposed 40 CFR 163.81-1(a);  43 FR 37355].

Other "generic" data are required  to evaluate all products which both contain
a particular ingredient and are intended for certain uses (see, e.g., proposed
40 CFR 163.82-1, 43 FR 37363,  which requires subchronic oral testing of the
active ingredient with respect to  certain use patterns only).  Where a par-
ticular data requirement is use-pattern dependent, it win apply to each end-
use product which is to be  labeled for that use pattern (except where such
end-use product which  is to be labeled for that use pattern (except where such
end-use product is formulated from a registered manufacturing-use product per-
mitting such formulations)  and to  each manufacturing-use product with labeling
that allows it to be used to  make  end-use products with that use pattern.
Thus, for example, a subchronic oral dosing study is needed to evaluate the
safety of any manufacturing-use product that legally could be used to make an
end-use, food-crop pesticide.   But if an end-use product's label specified it
was for use only in ways that involved no food/feed exposure and no repeated
human exposure, the subchronic oral dosing study would not be required to
evaluate the product's safety; and if a manufacturing-use product's label
states that the product is  for use only in making end-use products not

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involving  food/feed  use  or  repeated human exposure, the subchronic oral study
would not  be reievcint  to tne  evaluation of tne manufacturing-use product
either.

If .-». registrant  of a currently registered manufacturing-use or end-use product
wisr.es to  avoid  the  costs of  data  compensation [under FIFRA Section
3(c)(l)(D)] or data  generation [under Section 3(c)(2)(B)] for "generic" data
that is required only  with  respect to seme use patterns, he may elect to
Delete those use patterns from his labeling at the time he re-registers his
product.   An applicant for  registration of a new product under this Standard
may similarly request  approval of  only certain use patterns.

p£ta_ Compensation Requirements under FIFRA 3(c) (I) (ID)

Under FIFRA Section  3(c)(l)(D), an applicant for registration,
re-registration, or  amended registration must offer to pay compensation for
certain existing data^the Agency has used in developing the Registration
Standard.  The data  for  which compensation must be offered is all data which
is described by  all  the  following  criteria:

    (1)  tne data were first  submitted to EPA (or to its predecessor agencies,
         USDA or FDA), on or  after January 1, 1970;

    (2)  the data were submitted to EPA (or USDA or FDA) by some other
         applicant or  registrant in support of an application for an
         experimental  use permit,  an amendment adding a new use to a
         registration, or for re-registration, or to support or maintain in
         effect  an existing registration;

    (3)  the data are  relevant to  the Agency's decision to register or
         re-register tne applicant's product under the Registration Standard,
         taking  into account  the applicant's product's composition and
         intended use  pattern(s);

    (4)  the data are  determined by EPA to be valid and usable in reaching
         regulatory  conclusions; and

    (5)  the data are  not those for which the applicant has been exempted by
         FIFRA Section 3(c)(2)(D)  frcm the duty to offer to pay compensation.
         (This exemption applies to the "generic" data concerning the safety
         of an active  ingredient of the applicant's product, not to "product
         specific" data. The exemption is available only to applicants whose
         product is  labeled for end-uses for which the active ingredient in
         question is present  in the applicant's product because of his use of
         another registered product containing that active ingredient which he
         purcnases from  anotner producer.)

An applicant for re-registration of an already registered product under this
Standard,  or for registration of a new product under this Standard, accord-
ingly must determine wnich  of the  data used by EPA in developing the Standard

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must be the subject of  an  offer to pay compensation, and must submit with his
application the  appropriate statements evidencing his compliance with FIFRA
Section 3(c)(l)(D).

An applicant would never be required to offer to pay for "product-specific"
data submitted by another  firm.  In many,  if not in most cases, data which are
specific to another firm's product will not suffice to allow EPA to evaluate
the applicant's  product, that  is,  will not be useful to the Agency in
determining whether the applicant's product is registrable.  There may be
cases, however,  where because  of close similarities between the composition of
two or more products, another  firm's data  may suffice to allow EPA to evaluate
scne or all of the "product specific" aspects of the applicant's product.  In
such a case, the applicant may choose to cite that data instead of submitting
data frcm tests  en his  own product,  and if he chooses that option, he would
have to comply with the offer-to-pay requirements of Section 3(c)(l)(D) for
that data.

Each applicant for registration or re-registration of a manufacturing-use
product, and each applicant for registration or re-registration of an end-use
product, who is  not exempted by FIFRA Section 3(c)(2){D), must comply with the
Section 3(c)(l)(D) requirements with respect to each item of "generic" data
that relates to  his product's  intended uses.

A detailed description  of  the  procedures an applicant must follow in applying
for re-registration (or new registration)  under this Standard is found in the
Guidance Package for this  Standard.

Obtaining Data to Fill  "Data 'Gaps^rFIFRA- 3(c)T2) (B)

Some of the kinds of data  EPA  needs for its evaluation of the properties and
effects of products to  which this Standard applies have never been submitted
to the Agency (or, if submitted, have been found to have deficiencies
rendering them inadequate  for  making registrability decisions) and have not
been located in  the published  literature search that EPA conducted as part of
preparing this Standard.   Such instances of missing but required data are
referred to in the Standard as "data gaps."

FIFRA Section 3(c)(2)(B),  added to FIFRA by the Congress in 1978, authorizes
EPA to require registrants to  whom a data  requirement applies to generate (or
otnerwise produce) data to fill such "gaps" and submit those data to EPA.  EPA
must allow a reasonably sufficient period  for this to be accomplished.

If a registrant  fails to take  appropriate  and timely steps to fill the data
gaps identified  by a Section 3(c)(2)(B) order, his product's registration may
be suspended until the  data are submitted.  A mechanism is provided whereby
two or more "registrants may agree to share in the costs of producing data for
wnich tney are both responsible.

The Standard lists, in  its summary second  chapter, the "generic" data gaps and
notes the classes of products  to which these data gaps pertain.  The Standard
also points out  that to be registrable under the Standard, a product must be
supported by certain required  "product specific" data.  In seme cases, the

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Agency nay possess  sufficient "product specific" data en one currently
r
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Unile the Registration Standard discusses  only the uses and hazards of
products containing the designated  active  ingredient(s), the Agency is also*
concerned with the potential hazards of  sore inert ingredients and impurities.
Independent of the development of any  one  Standard, the flgeney has initiated
the evaluation of sate inert ingredients of  concern in a specific product to
which the Standard applies, these ingredients will be pointed out in the
Guidance Package.

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                                   C; j-.PTER II

                            TiGH'C"-' ^SITIOI' Gi '1CPA

Introduction

This chapter describes  in  detail  the  Agency's regulatory position on products
that contain MCPA as the sole  active  ingredient.   The regulatory position
adopted by the Agency incorporates a  number of considerations.  Forenost anong
these considerations is an analysis of  the registrability of products
containing MCPA based on tne risk criteria found  in Section 162.11(a) of Title
40 of the U.S. Code of  Federal Regulations.  The  Agency's determination and
tne rationale for its determination are presented below.

In addition to tnis decision,  standards of product composition, acute
toxicity, and use are established. The rationale for establishing a
particular standard follows the presentation of the standard.  Regulatory
actions such as requiring  protective  clothing during application are
prescribed, and any additional data to  support the registrations are
requested.  Tne basis for  any  regulatory action can be found by first reading
the rationale for the action,  which follovs the chosen option.  Further
information, on tne scientific basis  for an action, can be found by reading
tr>e various chapters that  surmrize available scientific data on the safety of
MCPA.

Description o£ Chcrical

MCPA is tne common nane for t1"1? rrv^rucsl 4-cnloro-2-methylnnenoxyacetic acid.
MCPA is a pnenoxy herbicide registered  for use in a variety of crop and
ncncrop sites to control a vide spectrun of broadleaf weeds.  It is
principally used in wheat, rice,  and  other small  grains.  The Chemical
Abstracts Registry (CAS) number for MCPA is 94-74-6, and the EPA Shaugnnessy
Code is 030501.

Currently registered manufacturing-use  products include MCPA acid, the
dimethylamine salt of MCPA, the butoxyethyl ester, the butyl ester, the
isooctyl ester, and a mixture  product containing  the isobutyl, isopropyl, and
butyl esters.
                                                                     P
MCPA formulated products are marketed under the trade names Mephanac ,
Nethoxone  , Agroxone  ,  MCF , and  VJeedar , to name a few.  These
products are available  as  soluble concentrates and emulsifiable concentrates,
and they contain nany different forms of MCPA (tne sodium salt, the
dietnanolamine salt, the dimethylamine  salt, the  isooctyl ester, the
butoxyetnyl ester, and  a mixture  of butyl and isopropyl esters).

Regulatory Position

MCPA (4-cnloro-2-methylphenoxyacetic  acid), MCPA sodium salt, tne
dimethylamine salt of MCPA, the diethanolamine salt of MCPA, the isooctyl
ester of MCPA, the butoxyetnyl ester  of MCPA, the butyl ester of MCPA, tne
mixture of butyl and isopropyl esters of MCPA, and the mixture of isobutyl,

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 isopropyl,  and  butyl  esters of MCPA as described in this Standard, nay be
 registered  for  sale,  distribution, reformulation, and use in trie United
 States.  In  preparing  this Standard,  the Agency has considered the scientific
 daCo obtained from tne open literature through April 1981 and data submitted
 by  tne  registrant  up  to the date of publication of the Standard.  Based on a
.review  of these data, the Agency finds that MCPA has neither net nor exceeded
 any of  the  risk criteria found in section 162.11(a) of Title 40 of the U.S.
 Code of Federal Regulations.  Gaps in the data base preclude the completion of
 the Agency's risk  assessment.   The Agency has determined that MCPA does not
 cause unreasonable adverse effects to either man or the environment when used
 in  accordance with prescribed  label directions and precautions.

 Currently registered  products  containing MCPA as the sole active ingredient
 may be  reregistered under this Standard.  New products may be registered under
 this Standard,  provided the proposed products meet acceptable standards of
 product composition,  use and toxicity as described below.

 Regulatory  Rationale  -

 MCPA (4-chloro-2-methylphenoxyacetic acid) and its salts and esters are
 pnenoxy herbicides with chemical structures very similar to 2,4-D.  The
 najority of flCPA is applied postemergence by farmers or professional
 applicators.  MCPA is currently registered for outdoor, nondcnestic food crop
 and nonfood crop uses.  From 85 to 95% of MCPA usage is on wheat, rice, barley,
 oats, and rye.   Other uses include applications to rangelands and turf.

 The Agency  has  completed a thorough review of available data on tne safety of
 tCPA, and has identified several studies that indicate MCPA may be
 teratogenic, fetotoxic, and may affect spermatogenesis.  In addition, data
 were available  that indicated  MCPA may be a weak nutagen.  Scne of the data
 indicating  adverse effects do  not meet Agency standards for testing.  Flaws in
 protocol and study design reduce Agency confidence in reported results (see
 Chapter 6 for details).  Also, additional data were available that indicated
 MCPA did not induce teratogenic, fetotoxic, reproductive, or mutagenic
 effects. In tne face of conflicting and inconclusive data, the Agency does not
 consider it prudent regulatory policy to proceed with a presumption against
 the registration of MCPA at this time.

 However, the Agency is concerned whenever positive effects are reported in
 submitted data.  Because of its concern, the Agency has completed a
 preliminary dietary risk assessment using the No Observable Effect Level
 (NOEL)  of 4 mg/kg  (the lowest  NOEL reported).  A suimary of available positive
 effects data follows, and the  dietary risk assessment follows this summary.
 Chapter 6 includes full discussions of all reviewed data.

 Available data  on  tne teratogenic potential of MCPA include studies indicating
 that dietary administration of MCPA induced dose-related minor skeletal
 defects and decreased fetal weights.  The NOEL based on the incidence of minor
 skeletal defects and  decreased fetal weights was 25 mg/kg in rats (see Chapter


                                        10

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6 for details).   In a separate  study,  f-CPA was annunii^-red to rats in dietary
doses of. 2, 30, 60, and' 1:10 mg/]cg.   At 60 nnc; inp rr;/'-.-;, trio nnlfor^otior. r?.tc-
vas significantly  increased,  and  fetal weights werr  ~i~ni£icantly decreased.-
Tne i>*JEL for fetotoxicity was 30  mg/kg (see Cnapter n ror details).

Available data on  potential effects of MCPA administration on spematogenesis
includes a study  tnat indicates dietary administration of nCPA may induce
dcse-related curtailment of spematogenic activity,  tubular atrophy, and
prostatic alterations.   The NOEL  based on tne effects described above is 4
mgAg in beagle dogs.   In a separate study, deened inadequate by Agency
standards, MCPA was administered  to young male Sprague-Dawley rats at doses  of
100, 500, 1,000,  2,000  and 3,000  ppm.   Rats receiving inn ppm (3 mgAg/day)
had slight degeneration of tne  seminiferous tubules.  Those receiving doses  of
500 ppn (61 mgAg/day)  and 1,000  ppm (112 ngAg/day) had mild degeneration of
trie seminiferous  tubules with loss  of  speraatids.  The use of less than 10
rats per dose, the short duration of the study, and discrepancies in the
recording of seme  data  were the major  deficiencies noted in the Agency's
rcview of tnis study.•,

Available data on  potential mutagenic  effects of ?1CPA include studies
suggesting MCPA is a weak mutagen in Saccharomyces cerevisiao and a weak
mutagen in Drosopnila.   In addition, one study indicates that MCPA may cause
inhibition of testicular DNA  synthesis in male mice.

The Agency is requiring additional  testing of fICPA for reproductive effects
because available  data  are inconclusive (?ce Chapter 6).  However, because
adverse reproductive effects  were reported in several studies, the Agency has
completed a preliminary dietary risk assessment, usinn tr»e conclusions of
tne subcnronic feeding  study  which  reported effects on spermatogenesis and a
NOEL of 4 ngAg.

Dietary Risk

In order to assess the  risk for dietary exposure to MCPA, a worst case dietary
risk assessment based on the  conclusions of the subchronic feeding study in
beagle dogs is used  (Holsing, 1970, 000004757).  The NOEL reported in this
study is tne lowest level reported  that indicated adverse effects.  This study
reported adverse effects on spermatogenesis and a 130EL of 4 ngA<3«  (see
Table 2-1)

                                    TABLE 2-1

                   Reported Incidence of Spematogenic Effects
Cose (ngAg)    0               4               8              16



Incidence       1/4             1/4             2/4             3/4


                                        11

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The TMRC  (Theoretical Maximum Residue Contribution)  of  MCPA to the human diet
is .77 ng/day (sec Chapter 7).  The  theoretical  dietary exposure of an average
man equals tne TMRC divided by  the weignt of  the average man (60 kg):   .013
mgAa/day.  The oral NOEL from  the study discussed  above is 4 mgAg*  The PADI
(Provisional Acceptable Daily Intake), using  a  2,000-fold safety factor,
is .002 mgAg/day.  (The ADI is termed provisional  because chronic feeding
studies are not available to confirm the reported NOEL  in subchronic testing.
Likewise, a 2,000-fold safety factor is  used  because the NOEL is from a
subchronic study.)  The theoretical  dietary exposure of an average man to
residues of MCPA  in food exceeds tne (provisional)  acceptable daily intake by
a factor of approximately 6.  Thus,  there is  a safety factor of approximately
333 rather tnan 2,000.

The ADI is provisional and was  calculated using  a 2,000-fold safety factor.
Chronic testing of MCPA is required  as one of the conditions for continued
registration under this Standard.  Calculations  of  an ADI using the customary
100-fold safety factor (when long-term testing  is available) and the sane ^DEL
as reported above, give an ADI  of  .04 mgAg.  The theoretical dietary exposure
figure of .013 mgAg/day would  be acceptable  because it is less than the ADI.

Because the ADI is only provisional, the Agency  is  not  taking any action to
revoke existing tolerances even though theoretical  dietary exposure exceeds
tne maximum permissible intake. However, the Agency will not consider any
additional tolerances for the use of MCPA in  or  on  food or feed until
acceptable chronic feeding data have been provided.

Applicator Exposure

The vast majority of .'1CPA is applied postemergence  by farmers and professional
applicators.  Product concentrations of  MCPA  acid equivalent range from 1 to 4
pounds active equivalent per gallon  of product,  with 4  pounds being tne most
ccmon.  Most is  broadcast by fixed-boon ground  rig sprayers in about 10-30
gallons of water  carrier per acre.   An appreciable  amount is also broadcast
aerially, especially in rice.   Aerial applications  use  2 to 10 gallons of
v/ater per acre.   Crop sites are normally sprayed only once per season at an
average application rate of 0.5 pounds active ingredient per acre.

MCPA may induce adverse reproductive effects  at  concentrations as low as 4
mgAg body weight.  Therefore,  the Agency is  concerned  about applicator
exposure during tne mixing and  application of spray formulations.  Because the
Agency is awaiting the results  of  further reproductive  testing, quantitative
applicator exposure and risk assessments are  not being  completed at this time.

The Agency will ccnplete a full applicator exposure and risk assessment if the
results of required toxicological  testing confirm the Agency's preliminary
determination that MCPA may induce adverse effects  on spermatogenesis.
                                        12

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Test Substances for Required Testing
As a typical weak acid  (pK^ =  3.1),  MCPA exists in solution in tv;o fcrr .c ,
depending on the pH.  Below pll 3.1,  tne  un-ionized, protonated torn (MCPA acid)
prodcnin^tes, and above this pH, 'TTPA anion  (salt form)  prec!cnin?tes.   Pocnijse
of tne interconvertability of  *CPA acid  and  salt forms,  MCPA and its salts nay
be considered as one entity for most categories of testing.

For esters of MCPA, tne situation  is different.  The fgency has no data on tne
rates of hydrolysis of MCPA esters in living or nonliving systems, and
therefore nas no basis  for saying  that MCPA  acid and its esters are equivalent
for testing purposes.  Registrants of products containing esters of MCPA *cid
have tne option of providing all categories  of data on each ester fom, or of
citing data showing that a particular ester  would be equivalent to MCPA acid
under test conditions.  The Agency will  consider such a rationale based on
registrant-supplied data on analogous chemicals (for instance, 2,4-D).

Potential for Mitrosatnine Contamination

Amine and alkanolamine  salts of phenoxyacetic acids may contain nitrosamines
as a result of  (1) nitrosamine contamination of the amine or alkanolamine used
to produce tne salts, or  (2) addition of nitrite to tne product to innibit
corrosion during storage.  Samples of an oir.ine salt fcrnulticn of .MCPA
obtained "off-tne-shelf" contained up to .7  ppm N-nitrosodimethylanine.

Because 80% of all N-nitrosamines  have been  shown to be carcinogens, the
Agency is requiring analyses of products that are most likely to be
contaminated with N-nitrosamines. - -Each  registrant of a nanufacturing^use --------
product containing an amine or alkanolamine  salt of MCPA is required to
analyze tne product for nitrosamines immediately after manufacture, and either
certify that nitrites are not  added  to the formulated products, or analyze the
formulated products after storage.

Following tne submission of data and the submission of required risk
assessments where necessary in accordance witn 45 FR 42854, the Agency will
reevaluate the registrability  of MCPA.

Potential for Dioxin Contamination

Some published procedures for  the  manufacture of MCPA use chlorocresols as
starting or intermediate materials.   Chlorinated phenols are dioxin
precursors under certain conditions.  The Agency is requiring the analysis
of MCPA technical acid  (manufactured with chlorocresols) for chlorinated
dioxins.  In addition,  end-use products  developed under an integrated
formulation system (for which  there  is no registered MCPA technical  product)
must also be analyzed for cnlorinated dioxins.  Alternatively,
registrants nave the option of supplying detailed discussions of why dioxins
are not likely to be found in  the  product.
                                        13

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Criteria for Registration Under the  Standard

1b be subject to tnis Standard,  MCPA products nust:

    - contain MCPA as tne sole  active ingredient;
    - be within any established  standards  of product canposition;
    - be within acceptable  acute toxicity  limits;
    - be labeled for acceptable  end-uses;  and
    - bear required labeling.

The applicant for registration  or reregistration of  products under this
Standard must ccnply with all terms  and  conditions described in this Standard,
including a commitment  to fill  any data  gaps in accordance with the time
schedule specified by the Agency,  and, when  applicable,  offer to pay
compensation to the extent  required  under  Section 3(c)(l)(D) of FIFRA,  as
amended, 7 U.S.C. 136(c)(1)(D).   As  discussed in Chapter I,  applicants  for
registration under this Standard must contact the Agency for specific
instructions, including updated  information  on  data  and  compensation
requirements.

A.  Manufacturing-use MCPA

    1.  Acceptable Ranges and Limits

        a.  Product Composition Standard

MCPA manufacturing-use  products  are  available in a variety of forms: MCPA
acid, the dimethylamine salt of  MCPA,  the  isooctyl ester of MCPA, the butyl
ester, the butoxyetnyl  ester of  MCPA,  and  a  mixture  of the iscbutyl,
isopropyl, and butyl esters of  MCPA.  Manufacturing-use  MCPA products with any
percentage of the above listed  acids,  salts, or esters are acceptable under
tnis Standard with appropriate  certification of limits.

Manufacturing-use products  containing amine  and alkanolamine salts of MCPA
must be analyzed for the presence of N-nitrosamines  immediately following
manufacture and after storage (see pp.  13  for option of  certifying that
nitrites are not added).  Registrants of products containing nitrosamines in
excess of 1 part per million must provide  the Agency with a risk analysis (45
FR 42R54).

Manufacturing-use MCPA  products manufactured with chlorocresols must be
analyzed for the presence of cnlorinated dioxins, or, alternatively,
registrants may provide the Agency with  detailed explanations of why tne
formation of chlorinated dioxins is  unlikely to occur in their product(s).

        b.  Acute Toxicity  Limits

The Agency will consider registration of proposed manufacturing-use MCPA
products that nave established  acute toxicity I-IV ratings for each of  tne
following effects:

                                        14

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                Acute Oral Toxicity
                Acute Dermal Toxicity
                Acute Innalation Toxicity
                Primary' Eye Irritation
                Primary Dermal  Irritation

        c.  Use Patterns

To be covered under this Standard, manufacturing-use MCPA products must be
labeled for formulation into end-use products  that are intended for outdoor,
nondomestic (general) or domestic  (restricted),  terrestrial or aquatic, food
crop or nonfood crop applications.

Under section 130.339 of the Code of Federal Regulations Title 40, tolerances
have been established for the use of MCPA in or  on barley, flax, flaxseed,
grasses, oats, pea vines, rice, rye, sorghum,  vegetables (seed and pod),
wheat, cattle, goats,-: hogs, horses, milk,  and  sheep (see Chapter 7 for full
tables of existing tolerances).

Because the Provisional Acceptable Daily Intake  (PADI) of ?CPA pas been
exceeded by the tneoretical dietary exposure figure, additional tolerances
will not be considered under this Standard (sec  Tolerar.ee FfeasE'iG
Additional nonfood use patterns of  MCPA are  acceptable under this standard,
provided registrants demonstrate  tnat the new use will not result in
unreasonable adverse effects  to applicators  or the environment.  Products
intended for domes tic- -use -will -be -restricted-use -pesticides —
                            t

    2.  Required Labeling

Ml proposed manufacturing-use products must bear appropriate labeling as
specified in 40 CFR 162.10.,

    3.  Tolerance Reassessment

See the Residue Chemistry Chapter of  this Standard for full discussions of
existing U.S. tolerances and  Codex  tolerances.

Tolerances for residues of  MCPA and of its metabolite 2-methyl-4-chlorophenol
nave been established for a number  of food and feed commodities (see Chapter
7).  Certain esters of MCPA are not listed as included in the regulation
establishing tolerances for ; MCPA.   40 CFR 1G0.339 should be amended to add
those esters not now included, i.e.,  the butyl ester, and the isobutyl and
isopropyl esters.

Based on these tolerances,  the theoretical maximum residue contribution  (T-IRC)
of MCPA and its metabolite  to the human diet is calculated to be ca 0.77 mg/day
(assuming a 1.5 kg diet), or  .013 mgAg.  The PADI of MCPA in the human diet
equals the no-observable-effect-level (NOEL) (4 mgAg) divided by a 2,000-fold

                                        15

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safety factor.  The PADI  is  .002 ngAg«   The provisional maximum permissible
intake (P:!PI)  is  the  ADI multiplied by 60 kg (the average weight of a human).
Tr.e PMPI is  .12 ng/clay.

Tne tneoretical dietary exposure to MCPA is approximately 6 times the maximum
permissible  intake.   A 2,000-fold safety factor is used for the purpose of
calculating  the P.ADI  and PMPI because the NOEL was established in a subchronic
feeding study.  It is Agency policy to utilize  a 2,000-fold safety factor when
NOEL's are based  on subchronic data and chronic feeding studies are
unavailable.

When the Agency uses  the customary safety factor of 100 instead of 2,000, tne
theoretical  dietary exposure level does  not exceed the maxiraum permissible
intake.

Because tne  ADI (based on  existing subchronic .data) is provisional, pending
the receipt  of chronic feeding data,  the Agency will not take action at this
tine to revoke any existing  tolerances.   However, the Agency will also not
consider any additional tolerances under this Standard.

B.  End-Use  MCPA

    1.  Acceptable Ranges  and Limits

        a.   Product Conposition Standard
                             j
MCPA end-use products are  available in soluble and emulsifiable concentrate
formulations.  nMCPA end-use  products contain -*he- sodium-s^l-t-of--l4CPAT—tine-
die tnanolamine salt of MCPA, the dimethylamine salt of MCPA,-the isooctyl
ester, the butoxyethyl ester, and a mixture of the butyl and isopropyl
esters.  End-use  MCPA products with any  percentage of the above-listed salts
or esters are acceptable under this Standard with appropriate certification of
limits.

End-use products  containing  amine and alkanolanine salts of flCPA must be
analyzed for the  presence  of N-nitrosamines intnediately following manufacture
and after storage (see pp. 13 for option of certifying that nitrites are not
added).  Registrants  of products containing nitrosamines in excess of 1 part
per million  must  provide the Agency with a risk analysis (45 FR 42854).

        b.   Acute Toxicity Limits

The Agency will consider  the registration of MCPA end-use products for general
nondonestic  use or restricted domestic use witn established acute toxicity
ratings of:
    Acute oral  toxicity
    Acute dermal  toxicity
    Acute inhalation  toxicity
    Primary eye irritation
    Primary dermal  irritation
    I
   Yes
Amendment*
Anendment*
   Yes
   Yes
II
Yes
Yes
Yes
Yes
Yes
III
Yes
Yes
Yes
Yes
Yos
IV
Yes
Yes
Yes
Yes
Yes
                                        16

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    * An amendment  is  required;  for  the  registration of products in category I _
      for acute dermal toxicity and acute inhalation toxicity, because dermal
      and innalational routes represent the routes with the highest potentials
      for significant  exposure  during  the rr.ixirrj nr.d application of liquid
      formulations.

          c.  Use Patterns  and  Application Methods

*sfvCPA end-use products nay be  used nondomestically and dcnestically as
•"  lerbicides  in barley, flax, flaxseed, grasses (including turf), oats,
   >ea vines,  rice, rye, sorghum,  alfalfa, clover, vegetables (seed and pod), and
   i/neat, or in noncrop areas.

  ,-2.  Additional Uses

  Because the Provisional Maximum Permissible Intake (PMPI) of MCPA has been
  'exceeded by the Theoretical Maximum  Residue Contribution (TMRC), additional
  tolerances  will not  be considered under this Standard (see Tolerance
  Reassessment).
   ilditional nonfood use patterns  are  acceptable under this standard, provider
  ^registrants demonstrate  that  tne new use will net pose an unreasonable risk tc
  applicators or  to tne environment.

  3.  Required Labeling

  General

  IA11 end-use products must  bear appropriate labeling as specified in 40 CFR
  •162.10.

  Product Chemistry
  ,i
  'For some emulsifiable concentrate products, tne flash points are between 30°
  ,and 150°F.  These products must  bear the following precautionary statement:


  1                "Eb not  use or store near heat or open flame."
  I

  Environmental Fate

  To decrease the likelihood of spray  drift, all end-use products must bear tne
  following restriction:

                   "Avoid  use of small-diameter spray nozzles."
  '  •
      Restrictions (see Residue Chemistry Chapter for details)

  The following use restrictions are required to provide assurance that the
  tolerances for meat, fat,  meat byproducts, and for milk will not be exceeded:


                                          17

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Snail grains,  flax, and  sorghum:

              "Do  not  fornne  or graze meat animals on treated areas
                       witnin seven days of slaughter."

Additional restrictions:

Products  for  use  on aquatic  sites (such as drainage ditch banks) must bear
restrictions  against  use of  the product on potable water, water used for
irrigating crops,  and water  containing edible fish or shellfish.  Treated water
should not be drained into a flowing stream that contains edible fish or
shellfish or  is a potential  source of potable water or irrigation water.  In
lieu of labeling  restrictions,  appropriate tolerances for potable water, fish,
shellfish, or irrigated  crops,  may be necessary.  Other labeling restrictions
nay be imposed as  tne required  environmental fate data gaps arc filled.

A restriction against the practice of growing crayfish or catfish in treated
rice fields is requirjed  to preclude the possibility of residues in crayfish or
catfish:

           "Do not grow  crayfish  or catfish in treated rice fields."

For nonfood uses,  when the application rate exceeds 2 Ibs. a.e./acre (rights
of way and fallow lands), the following labeling is suggested:

               "Do not forage or graze livestock on treated areas
                       within seven days of treatment."
                                        18

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                                   CHAPTER  III

                        DATA  PEOUinnriErTTS and DATA GAPS

A.  Manufacturing-Use MCPA

    1.   Generic Data Requirepents;

Table A, entitled:  Generic Data  Requirements and Data Gaps for Manufacturing-
Use Products includes tnose data  that pertain to the properties or effects of
MCPA as an active ingredient.  Tnus,  these data are relevant to an evaluation
of tne risks and benefits of  all  products containing MCPA.  Providing data to
fill indicated gaps in tne data base  is  the primary responsibility of trie
registrant(s) of manufacturing-use MCPA.   Registrants of end-use products wnich
are not exempted by FIFRA Section 3(c)(2)(D)  are also responsible for the
submission of these data.  To preclude unnecessary studies from being
conducted, registrants are strongly urged to consult with appropriate Agency
scientists (i.e., Hazard Evaluation Division, Office of Pesticide Program)
before initiating studies.  For useful background information, consult the
Agency's Guidelines.  Applicants  for  the  registration or reregistration of
manufacturing-use MCPA products must  acknowledge reliance on existing data
wnich fill indicated data requirements under FIFRA Section 3(c)(l)(D).  These
data are listed under the column  entitled Bibliographic Citation in this
table.

                            Environmental Fate Data

Data on physico-chemical degradation, mobility, metabolism, and accumulation
are required on MCPA acid AND on  each salt and ester of MCPA.  Because of tne
interconvertability between MCPA  acid and salt forms, MCPA and its salts can be
considered one entity for Environmental  Fate testing.  This is not the case for
MCPA esters.  The Agency has  no basis for saying that MCPA and its esters are
equivalent for testing purposes.   Therefore data on the fate of each ester are
required.  Alternatively, registrants have the option of citing data from
analogous chemicals which indicate that  a particular ester would be equivalent
to MCPA  acid under test conditions.

                              Product  Chemistry Data

Certain data on the physical/chemical properties of technical fCPA acid are
required for the registration of  all  salts and esters of MCPA.  Additional data
specific to particular salts  and  esters  are also required.

                                Toxicology Data

A full battery of toxicologies! testing  is required on MCPA acid, each salt and
each estor.  Alternatively, registrants  may submit evidence which substantiates
that a particular salt or ester will  be  toxicologically equivalent to MCPA
acid.
                                        19

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                            Ecological  Effects  D?.ta

Fish and wildlife  (ecological effects)  safety testing most be conducted on HCPA
acid (for the registration of products  containing  MCPA acid)  and on a number of
different salts ana esters  (for  tne  registration of  products  containing the
salts and esters).  Separate testing is required because data indicate that the
physical/chemical properties (ie. solubility) of the salts and esters differ.
These differences could influence the acute  toxicity of these compounds to fish
and wildlife.

    2.   Product Specific Data Requirements:  Manufacturing-Use MCPA

Table B, entitled:  Product Specific Data Requirements for Manufacturing-Use
Products includes tnose data that relate only to the properties or effects of a
product with a specific ccmposition  (or substantially similar composition).
Thus, these data are required of each product (or  substantially similar
product) to characterize the products's particular conpositicn and
physical/chemical properties, and to characterize  the products's acute toxicity.

Product ccnpositicn data are required for each  manufacturing-use product.
Providing data to fulfill these  requirements  is the  responsibility of each
applicant for the registration or reregistration of  a manufacturing-use fCPA
product.  If the Agency has data which  fulfills this requirement for a
particular product (s) then this  is indicated  in the  chart and in the guidance
package accompanying tnis Standard.

Data on the pnysical/chemical properties and  acute toxicity of manufacturing-
use products are required for eacn product or substantially similar product.
Providing data to fulfill these  requirements  is the  responsibility of each
applicant for tne registration or reregistration of  a manufacturing-use MCPA
Product specific data need not  be  acknowledged  under FIFRA Section 3(c)(l)(D)
unless the Agency or a registrant  has  established  that one product is
substantially similar to another product  for which the Agency has received
acceptable data.

Existing manufacturing-use fICPA products   are substantially similar in
ccnpositicn for the purposes of establishing product-specific testing
requirements.

                            Product  Chemistry Data

Data requirements 163.61-3 through 163.61-7 apply to each proposed or currently
registered manufacturing-use MCPA  product.
                                        20

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                                Toxicology  Date

Data requirements 163.81-1 and 163.81-2  (acute oral and dermal toxicity) apply
to manufacturing-use products wnich  are  not toxicolcgirr>lly equivalent to tne
tecnnical grade of tne active ingredient.   Testing is required of each
manufacturing-use product.  Alternatively,  registrants nay choose to sutmit
references to existing data on analogous cnemicals which substantiate that a
particular salt or ester  is toxicolcgically equivalent to 'CPA acid.

Data requirements 163.81-3 through  163.81-6 apply to each nanufacturing-usc
product or substantially  similar  product.   Testing nust be supplier) on fCPA
acid and on each manufacturing-use  product, unless registrants argue for
toxicological equivalence to MCPA acid by citing data on analogous chemicals.

B.   End-Use MCPA Products

Applicants for the registration of  end-use  products containing MCPA are advised
that if the Agency does not receive  commitments, within the specified time,fran
manufacturing-use MCPA registrants  to fill  data gaps identified for the
manufacturing-use product, manufacturing-use product registrations will bo
suspended.  Fomulators nust tnen bear tne  burden of supplying tnese data if
continue:', availability of the nanufacturing-use product is desired.

    1.   Product Specific Data Requirements for End-Use Products

Tnblo C:  Product Specific Data Requirements and Data Gaps for End-Use MCPA
includes tr.cse rirrta that  relate only to  the properties or effects of products
with a specific composition  (or substantially similar composition).  Thus,
these data are required of each product  (or substantially similar product) to
cnaracterize tne product's particular composition and pnysical/chemical
properties, and to characterize the  products acute toxcicity.

Product composition data  are required for each end-use product.  Providing data
to fulfill tnis requirement is tne  responsibility of each applicant for tne
registration or reregistration of an end-use MCPA product.  If the Agency has
data which fulfills this  requirement for a  particular product(s) then this is
indicated in the chart and in the guidance  package accompanying this Standard.

Data on the physical/chemical properties and acute toxicity of end-use products
are required for each product or  substantially similar product.  Providing data
to fulfill these requirements is  the responsibility of each applicant for the
registration or reregistration of an end-use MCPA product.

Product-specific data need not be acknowledged under FIFTA Section 3(c)(l)(D)
unless tne Agency or a registrant has established tnat one product is
substantially similar to  anotner  product for which tne Agency has received
acceptable data.
                                        21

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                         Substantially Similar Products

•testing of representative products containing each  type of  registered salt and
ester of !CPA is required.

                             Product Chemistry Data

Data requirements 163.61-3 through 163.61-3 apply to each proposed  or currently
registered end-use MCPA product.

                                Toxicology Data

Data requirements 163.31-1 through 163.81-6 apply to representative products
containing each type of MCPA salt and ester.
                                        22

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                                               nrrcmc twm
                                                                                  cwrn
Guideline Hanc of Are Dnta Test hies rpA llavn Data to
Citation Test i Required? Substance Partially or Totally
Satisfy RcqiilrcBmts?
Product Chjenlstry
Ul.ei-lTnt Product Tes Tech Rrmto* . Tes
Identify
163.61-Kc) Product Tea Tcrh Rrade* Ho
Ccnroaltlcn
161.61-7 Analytical Tea Terh Grade* Partla.lt tlped
• nVjthtyhi t data on each
Data ' product
161.61-nlcM It Color Tea Tech Grade* . Partial1
I61.6l-R|cll2| Odw Tea Tech Grade* Partial
IC1.61-Rlc|l1t Heltlni Point Tes Tech Grad"** Partial2
I61.61-B(c)t4l Solubility Tes Tech Cra** Partial2
I61.6l-ifc)(5) Stability Tes Tech Grad-* No
I61.6l-H(cll6l Octanol/Hnter Tea Pure Font Ho
', Partition of A.l«"
Coefficient
I61.6l-8(c)|7) Physical Tea Toch Gradp* Tea
Statd
IK1.6l-Blc)|R| tensity or Tes Tech Gra.b* Partial1
. Specific
riravlty
l61.6l-fl(cH9| Dolllnq Point Tes Tech Grade Rstoro tb
161.61-ftlcHIOI Vapor Tes Pure For* tb
of A.I.'"
niblloqrnphlc Hint Mlltlonal l\ita to Rub-
rltntlm ultted Onrter FIFWX I|r)|2)|ni7
If So. f>>idllne for Sttmlsnlnn
No
Vest
Harwell. I97R, 00021977 Vest
Akzo 7out. Chomlc. 1971. OO004710
Chlpunn, 1971, 0002191 7
ATKJ 7«it Ch-mle, 197.1. OOO04735
KenilBk V*.rli Koqe, 1972, OOOO4S76
Collier. 1974, 05001559
Stevens, 1979. 05012650 ,\
Mallna, IO7I, 050O14SO
nt. John, 1965, 0000499% Yrsi
CSFl 11616-2
rSFi 11636-3
CSFi 1 1616-1
CSFl 11636-2 Yesi
C!Fi II616-J
OJF: II61R-I
St. Jdtn, 1965, OOO010OS Yesi
tr.F: 11616-2
St. John. 1965. OOOO499S Yest
r.:r: II61K-2
Yes,
Yes,
St. John, 19^5. OO0044<>S No
TSF'B of Prmlurts
St. John. 1961, 00004995 Yrsi
CSF! IK.16-2
CSFi 11616-3
rr.r: II61R-I
Yrsi
Yon*

6 mnnths
6 imnths
6 months
6 mnnths
6 ™t,,fl
6 imnths
Rmmtns
6 mmths

6 mrwittin
6 nrmths
M1.«l-aiel(lll|«l.         Yes      Terf.Or.vi,.         No                                                 Vps,  * „„,,„
           *
D^ta ff^ilrnnnnts are ciirrwrt IM of rirtnly*r  I*WI.   Bw quiatnoc r**+»Virtn cnntalnhvj tlv nrxlliira  s-iH,
     dlnrthylamlnc 8.1 It and  dletMnolnmln<> svilts of NCPA.

•*   Data arc required on  technical qr.-vle HTT(\ arid only.

•••  frtta are required on  the annlyt  -ally pure form of >TPA acid and each ester.

I    data are available on MTPA acid, the Inmctyl  ester, and the mixed esters.

2    Rita arc available on NCPA acid.

-------
                                                               TAW*

Guideline
Citation
DivIroroEntal
l«3.*2-7(bt

I63.fi2-7(cl

If3.62-9(b( •

163.62-IMel


163.62-Btd)


!63.62-8(f)

l63.62-B(q)


)63.62-9(b)


163.62-9IC)
t

161.fi2-rch GradE Tes


Hon-Rndlo- No
labeled
Matorlnl
Tech firadr-' No

Rrp- Form7 Mo

l»rp. Form" Mo



Rrp. Form11 Pnrt.lnl"

Anily^cal No
CrjirV?
llrp. Fomi" Mo

Tech firnde' Ho
n^jmwvpfs

Dlblloriraphlr Mint nrUltlcml l«t.i be Sub-
Cltntlon Bitted Mntter Finw Hrl(2l(n|?
If So, fxr-adlln^ for ftiintlsftlon

Sodcriulst. 1974. 0000444R Teal
f-orV-rTulst. 1975. nsmi«45
Sod^rqulst, 1974, 00004MB Teat
Rodnnrilnt. 19^5. O'flOIMS
Tost

Test
t

«v Test
f






llclllnq. 1971. OSOI6652 Ho
Itelllnq. I9AB. 05004203
llcrzcl. 1979. IS0212K
Teat


YPJII

Yp«t

Test



Frnnlt, 1179. OSOI0951 Tost

Ycsi

Yes:

Yont

12 months

12 nrmthn

|O tmnthn

10 imntha


12 mnntha










10 mnnthiv


10 imnthq

in itontht

12 months



14 ninth*

2« nontlis

14 months

24 mnnths
                IntIon

163.62-13       Disposal      Reserved
                and fitoraq"

flata reqiilrcnents  current as of Ortcter  I9BI.   Ri?fer to qulrtanre parkao/? for iinhtp.1

-------
        1    Radio-labeled an.ilyMo.il nractp preferred or non-r.idlo-liiheled t>x-hnlr.il qradp MTPA acid and each estor.   ivyilnt-r-inf-.s tvivo tl«o
             option of tostinq fl at one oononntration undnr natural  or Blmiln^vl (>2no nm)
             sunllqht

        4    TV; requirement for Uio ttutmlsaior of tlioso data  IB currently nelnq reserved pendinq the couplet ion of Armey ter.tinq
             protocols.

        5    For terrestrial noncron wva, orrMrd crop uson,  field or vr»«r»»-nhle crop uses, and forestry uses,  the mobility of t-.ho tost
             siinstanoe and its ilnnrndatr'S  In Kill rtvill hr» asscnapd either ly soil thin layer chromatoqraphy. soil noluim. or h.itr!h
             equilibrium (.-vteorptlon/itrRorptlor ) procedures.                                            >N

        7    For domestic outdoor uses, qrcenhtMw uses, aquatic usoa,  and aquatic inpact uses, the nobility of the test Bubst.ince and its
             dcgradates in soil shall he asses(.!d only by tho  hat.ch equilibrium (adsorption/desorptian) procedure.

        8    Testing required on representative formulation types.

        9    Field and vegetables crops, pastutrs land, domestic outdoor parku and omnmentaiAurf use, and rights of  way.

        10   Aquatic food crops.
0 \                                                                                •
^     11   Additional data needed on MCPA huloxyethyl ester.

        12   Rndlolabeled analytical grade preferredj if residue found, field testing using representative fomulations

        13   Flew through only.

        14   This data requirement ia currently reserved pending completion of applicable Agency guidelines.

-------
TA1UK  A  (continued)
CTNKIUC DATA RHCNMRFII^^HVID (WTA CAPS
pon fwiupAcninifii^B^ npcAa
Qii'toline
Citation
Ihx loo logy
161.81-1
163.81-2
163.81-7
163.82-1
163.82-2
163.82-3
163.82-4
163.82-5
163.83-1
163.83-2
161.83-3
161.83-4
163.04-1-4
163.85-1

163.. 86-1
Him* of Are liata
Tcr.t norpiirtxl?
Aruto Oral Yea
ToxIcUy
Acutn Hernnl Yes
Toxlclty
Acutn Hr>2
Dclayort
Ncurotoxiclty
- . Sttochronlc Yes
Oral
Toxlclty
S«*«*ronlc No1
(21 oViy)
Deriml Ten.
Subchronlc ' tlo1
(90-rlay)
Dcrnnl Tox.
Suhchronic No1
Inh.nl. Tox.
Subchronlc No1
Ncurotoxiclty
Chronic Yos
Onoocrntclty Yos
Terato- Yos
qenicity
Reprorluction Yos
Mutanonlclty Yos
Hetahollsm Yns

Pnitr'stic Ho
Animil
Rafoty
TVst lloos RPA llav-» nnta to nihllographlc Hunt Mrlltlonal r*nta N! Ruh-
Sijhstano; Partially or Totally Citation mlttoH Unrfcr FIFIJA l(c)(21(n)?
Satisfy Rerpilromnnts? If f5o, Dr>a<1Uno for r.u*tnlsslnn
1>:<?rti r.rar*?* Yoa llolsinq S Kunrlxin, ,1<>70, OOOO4776 Mn
HolRlnq ft KuivV.ln, l«>6n, 00004775
llolnlm, 1970, 00004756
llolsinq, 1970, 00004757



Ttech Rra«lo* Mo Yoss
T?rh Ormln* Ho Yos:
Torh nrar*!* Mo Palmer ft r^unll, 19'?, 00004441 No
Yasurfe ft Mflerti, 1«»72, 05003566
trvlne, 1900, OOOO4I617
T«rh Crar*!* Partial Rloft Parvlnen, 1976, 05004101 Yos:
Torn firacb* Partial Bottorlmrti, l«»79, 05004970 Yos:
7.cttcrt«rq, l"79, 05001571
H--»qnusson ot al, I9"'7, 05016919
Pmpplnq oh al. 1"71, 05009217
nun>»lmnior oh al, li"1?, 0501655
Tsrh f!ra/>5 Mo
n^rV.e, 197 Ib, 00004626
Elo, 1976, 05001256
Ollhert. ft Hopkins, 1978, 00041614


6 n^h.





18 months
48 months

12 months
24 months




-------
a    These data are •required for  the  nxilstr.it Ion of  technical  chemic.ilft,  and for the registration of other products whoneworthe
     source of the active  ingredient  In  :ho product In  not  registered.

*  .  The Agency la requiring n  full battery of  toxioologlcal testing on technical grade MCW\ acid to support the* food i«os of thin
     active Ingredient.  The Aqr»ncy has midr> a  preliminary  determlnnHon that acute,  suhchronic and chronic toxtmloqlnl tontlnq
     of MCPA acid Will provlds  'sufflcicut  Information to stipport  tho rrrjulremcnts for testing of the technical qrvub CR^ors of MCPA
     and each mnnufacturlnq-usc MCPA  snlt.  Rnqistrants have the option of supplying  the full hattery of acute, suhchronic. nnd
     dironlc toxlcolcqiciil  testing on each technical  gr.ifte  ester or of  citing data which show th.it a particular ester or salt will
     be equivalent to NCPA  acid under test oondtlons.

1    Testing is available on MTPA acid.

2    Testing of the structurally  similar compound, 2,4-0 is currently underway.   If results are postlve, testing of MCPA is
     required.

.3    May he required when acute testing  Is completed.

-------
                                                              TNVF.  A   (continued)
                                                      DATA  nmuinrjtnnr; AND DATA
                                                   rrm rvNNiiFWTiuniMn-iBE HPTA
Gulcfellne
Citation
  Nanc of   Arc Kit.-TesT
   .Tsst     RequlrrV. t  Rut-stano;
                                                        n>A II* vc hnta to
                                                   Partially or Totally
                                                   Rntlafy Rrqiilrcnrnts?
Hlbllnr|rar*ilc
  Citation
  Hint MHtlonal ivita h? SoB-
•Ittod Unrtor FIFDA l(rl(2)(n|?
?f So, rtwllln1' for
Residue Chemistry.      ..
               nctahollaa    Tea        C-MCPA or
               In Plants              Tccn i
                                                         Pnrtlal
Metahollsa    Tea
In Animals
               Analytical    Tea
                                       C-HCPA or
                                          i GratV
                                      IVdinlcal or
                                      Pun'r
                                          Partial
               Residue       Tea      Rep Form*
               Data i RAC
                                                         Partial
                                                             Ram*.
                                                                                       l . OV11SS95
                                                                                             No
                                                                             tobcrteon ct al,  I1K7, OSOIS04A
                                                                             Abcrq ct fll . l<)78, 0^019071   •
                                                                             Klrkunol et al.  1972. 0500427}
                                                                             Klrkvra>l rt al,  llf.9, OSO|ll>>r, 1976. OS02I715
                                                                             Fyskc.  1975. nVI44%
                                                                             HnntTiorrY. 1970, onoOSVJS
                                                                             toos,  1971, OSOIfilOO
                                                                             FysVe,  1976. 0501)377
                                                                             Ueafe.  !"«, OS005791;
                                                                             Collins et it],  1971. 0500172S

                                                                             Bache ct al. 1961, 00004701
                                                                             Lrtv} ct al. 1971. nnn04fi22
                                                                             Hntllh et al, 1971. 05015451
                                                                             Dnrhc ct nl. I9M, 00004702
                                                                             Polrnoowa. I97B. 05017929
                                                             Conk In, I951. OOOOS552          Tcs
                                                             Tip anrl riry.  |9Mi, CS 0017-109
                                                             Guarrflnll,  1170, 000047KR
                                                             Illqhim, 1975, 00004631
                                                             IliTh.in, 1974, OO004«i}2
                                                             St. J7|. Ofl004«<27
                                                                  o ct al, 1971. 00004fi25
                                                                    "t al. 1971, OOn01K2R
                                                             Jonson. 197J, 00004419
                                                             llrrmnn ct a), 1970, 00004492
                                                             nterkc ct al. 1972. 05001259
                                                             Mlllor ct al, 1971. 0000441B
                                                             Illqhan,  1975. 00005567
                                                             lllqlnn.  1975, 00004KI1
                                                             Illqliam ot al. 1975, 00004611
                                                             Am. CyJimniM, 1971, 00004"'4I
                                                             Am. Cyammlrl, |974. on0046O<)
                                                                                                            tk>

-------
        •  Flax


          Grasses,
          Pastureland
          and Rangeland

          Oats

          Rice
          Rye
          Sorghum

          Reed i fni
          Vegptahles
tea


Yes



Tea

Yes




Yes


Yes

Yes
          Residue In   Yea
          Processed
          Foods

          Storage      Yes
          Stability
Rep Form*


Rrp Form*



l«rp Form*

Hep Form*




Kep Form*


Hep Form*

Rep Form*
          Wheat        Yes     F«p Form*
          Residues In  Yes     ftp Form*
          Food Pro-
          ducing Animals
         Rpp Form*
         Frp Form*
Yes


Yes



PartInl

Yes




Partial


Yea

Yes





Yes




Yea
                   Partial
                            Ho
Hnmanto, 1959. 00004473        No
CVinnMqll. 1970. OOO047M.

Ruirdlnll. 1071. 00004449       No
Rydrych et al, 1071, OO0216fl7   Ho

Irvine. 1070, 00004764          Ho
U?ng et al. 1070, 000047R5
WrrlU, |07|, 00004594
           et nl. |O7S. OS001445
                                                                                                      No
Dnta frno oth»r snnll qralm
           to ry»«.
IntcrrctlorMl, 1974, 00004491   No

Ctnkln, I95S, 00005SS2 •         No
Chow et al. 196S, 05001765
Winter!In et al. 1974, OOO044S1
Hendlncn, 1974, 00004454
ttunrdlqll, 1974. 000047RM

Yip and N»y. 19AA. CS 0017-109  Ho
Hontfiowry. IOTO, OOO05575
Rydrydi et al, 1971. 0002JR87
tllqhani et «l, 1974. 00005570
                                                      et  al,
                                               Jensen et  al.
                                               BJnrko ct  al,
                                               nacho et nl,
                                               Herman et  al,
                                               njorkc et  aa.
                                               Mrrnnn et  al,
                                               IXiqrpn et  al.
                                                     ct al,
                                 1971, 00004625
                                 1971. 00004419
                                 1971. 0000462'!
                                1964. 00004701
                                 1970, 00004491
                                 1972. 00003259
                                 1971. 00004624
                                 1967, 00025154
                                1964. 00004702

                                      00004766
                                      00004765
                                                                              No
                                                                     Hr>
                                                                              Ho
from applications of representative  formi I/it Inns.

There bolnq little,  If any t«*ldue4  In those raw agricultural commdltlmi f mm whlrti processed ranimdltlen imy he dcrlvrd,  the
need for further data on realties  In thn  Intter Is
There being little.  If any re*ldur>  In grains, a staple of poultry rntlons. MK> nn«yt for dntn on rcnldu»a In poultry and
Is waived.

 Information obtained  from Individual studies Indicates that thn analysis of  mnptes w.-n qrn»rnlly prrfoniRd within n  frw
 nnnths.  and generally not  later than 6 moths after nnnpllng.   lln^jr the rlrrunBtnnc»?s, the  nood for residue storage data  In
 waived.

-------
0


Gulitellno
Citation
Ecological
163.71-1

163.71-2

163.72-1


163.72-2

163.72-3



Nairn of Arc IVit.i
Test Required?
Effects
Avian Single Yes
l>3so Oral Ulgo
Avian ' Yes
Dietary ir^
Fish Acute Yes
UVn

Acute Tnx. Yes
to Aquatic
Invertebrates
Acute Tox . Yes
to Entiiarine
t Marine
TARtj: A uflBtlnued)
OFJIERIC DATA WI.AJT WrM-i FTR JMHHATA CAPS?
FOR MWIUFACniRlHG-IKn MPCA
Test Does EPA Have Data to nlhlloqraphic Must Additional aita tn r.ub-
Subst.inne Partially or Totally Citation mltt"d (hvler FIFRA i(f-W2)(n)?
Satisfy Requirements? If Roj Head 1 In" for Siitmlsalon
I
Tech Grade Ho Yes: 6 months*

Tech Grade2 Yea nrWltt. OS nnn-ini Ho

Tech Orade Partial IKTPA, OS 0017-inn Yes: fi mnni-hs
and I end-use
product ' » ^
Tech Oradn Partial4 USTPA. OS Oni7-infl Yess 'finnnihn
and 1 ei*1-»isc
product
Tech Orade Ho YPSJ f< moiiMin
nnrl 1 ep'I-use
ptwluct
               Organ isim

Data requirencnta current as of nrtobor I'Hl.  See quldano? package  for uprbted requirements.

*    24 months after promulgatlm of Subnart .1

a    These data are required for the registration of technical chemicals, and  for the registration of other products whenever tho
     source of the active Ingredient In the product Is not- registered.

1    Testing required In one avion specter (preferably mil lard duck  or hohwhlte quail) using technical grade MCPA acid and isooctyl
     and butoxyethyl esters, and the manu :acturlng-tise products containing  the sodium and dlmethylamlne  salts.

2    Testinq In required on one species of waterfowl (preferably mnlla'rd duck) and one species of upland game bird (preferably
     hobvwhlte quail or ring-necked pheasant) using technical butoxyothyl and  isooctyl esters, and ttie manufacturing-iigr-
     products containing the sodium and dltmthylamtne salts.

3    Testing In btucglll sunflsh and rainbow trout In required with  technical  MCPA acid,'the butoxyethyl ester, and the iscortyl
     ester and the manufacturing-use products containing tfw dlmetlyl;»inlne  salt.  Testing of the 16.7» butoxyethyl  ester end-use
     formulation Is also required because of Its use In rice.

4    Available data fulfill requirements for MCPA acid.

5    Testing Is required In Daphnla mngna for the B6.71 butoxyethyl  ester end-use product.  Aquatic Invertebrate  testing is also
     required on MCPA acid.

6    Testing Is required on technical MCPA acid, the butoxyethyl enter, and the Isooctylopter, and th»  imnufacturlng-os"  products
    containing the dlncthyiamin>» salt.  Testing  In shrimp and fish,  and .either oyster larvae testing"™: mollusc shell deposition
    testing with the 66.71 butoxyethyl ester formulation la  required.

-------
                                                                 ?  n

                                                 T-ecinc wrr* raooiRfmrra Mm nrnw
                                                 FOR MwuFjeromtR-iKf: MPO\
Guideline Na*o of Are Dati Teat Orca KPA Have Data to nlnHogrnpMe Huat Additional Datn be nub-
Cl tat Ion Teat Required? nuhnt.inrr* Partially or Totnlly Cltntlon mlH~1 Under FIFIW l|r)(?Hn|?
, . Satlafy Requirements? If So, Deadline for SUhmt union
Product Cnealatry .
163.61-3 Product Yc« facti NIP" partial1
Identify
and Disclosure
of Inqrcdlenta
161.61-4 Description Yea tach NIP** No
of Mf(J PpnC£Bfl
163.61-5 Olec. of Yea Mch NIP"
Format of
Unlnt. Innre-
dlenta
163.61-6 Declaration Ye* f*ch NIP**
of Ingredient
Umlta
161.61-7 Product Yea Bach HUP** Partial1
Analyt. Pat*
I63.6l-R(cll7) Phyalcal Yea Pach NIP** Yea
State
163.61-8(cH8) Denalty or Yea f.n* NIP** Partial1
Specific
Gravity
I63.61-8ICMUI P" Yea Fach NIP** Ho
163.6MMc>M2) Storaqe Yea F,irh NIP" Ho
Stab.
I63.6l-8|e)(13l riamm- Yea Fndi NIP" Partial1
blllty
!61.6l-8lcH14) Oxldlsln) Yea fach NIP** No
Rnduclnq
Action
I63.6l-8lc)(15) explosive- Yea Rnrh NIP** No
ness
I61.6l-8(c)ll6| MlBclhlllty Yea Fnrh NIP" Ho
I63.6l-8(cl(l7| Vlamslty Yea Txch HIP** No
161.6|-3(clllR| Corrosion Yes Rmti NIP** Ho
CRF'a2




St. John. 1965, 00004915
CSFt 11636-2
CSFi 11636-3
CT-Ft 1 1616-1
St. John. 1965, 00004995
CSFi 11616-1
CSFt 11636-2
CSFi 11616-3


CSF 11636-1 thru 3
(T.Ft 1 1616-2
C?Ft M616-1




Yes i 6 mnths
Vest 6 montha
Yest 6 rnrmths
Yeat 6 mnnths
Yeat 6 months
no
Yesi 6 months
Yest 6 mrmtha
Yesi 6 mrmths
Vest 6 month*
Vest 6 months
Yesi 6 mrmths
Yesi 6 months
Yrsi 6 months
Vest 6 mnntlis
    Data arc required for the reqlatratlan of each imnufarturlnq-use product.
•   For currently registered producta.
            for eart> nmiufacturl lift-use proluct.


I   ftita are available on HTPA acid,  the laonctyl enter, and ths mixed mtem.


2   llprVitprl statenrnta an- required for all mmufacturlnq-uae products.


3   Satisfactory methnda are avall.ihlo  ISee Table M hut data are re,      on each nanuforrurlni-une product.

-------
                                                              TABU!  n  (continued)
JJ
PRODUCT-SPECIFIC DATA RflQUT KWKN1T! AND DWTA (TAPS
FOR HMUFACTURIHMBT: MPOA*
Guideline
Citation
Toxicology
163.B1-1

163.81-2
163.81-3

163.81-4
163.81-5

163.81-6
Name of Are Data nest
Test Required? Substance
Acute Oral
Toxicity
Acute Dertml
Acute Inhal
Toxicity
Yes

Yes
Yes

Prim Rye Yes
Irritation****
Prim Demnl
Irritation
Dermal
Yes

Yes
NJP**

HUP**
HUP***

HUP***
HUP***

. HUP***
Docs EPA Have Data to Bibliographic Must Addition:*) nnta be Suh-
Partially or Totally Citation mitted Under FIFRA 3(r)(2)(R)?
Satisfy Requirements? • If So, Deadline for Sirt-rolssion
Yes1 Raltech, 1977, 000021972 Ho

No • Yeni 1 months
i \
No Vest 6 months

Yes2 Raltech 19??, 00021974 No
No ' Vest 6 months

No i Test 6 months
               Sensitlzation
*     For currently registered products.

**    Required for manufacturing-use products which are not the sane as the technical grade of the active ingredient.  The Agency
      has mads a preliminary determination that testing on technical HCPA acid will support this requirement for tenting of the
      technical grades of the esters antl manufacturing-use salts (see Table A).  Acute toxicity testing of each iwinufnrturlng-
      use product (or substantially similar product) which is not equivalent to the technical grades of the active
      ingredients is required.

***   Required for ea<.'i manufacturing-une product or substantially similar product.

****  A demonstration of pll between 1 and 3, or 12 ami 14_or_dr-nonst-ratlon of dermal irritation will he sufficient to cateqnrlz? a
      product as an ocular irritant, and additional testing will not he required.

1 .    Available testing is on technical grade HCPA acid.

2     Available testing is on a sodium italt end-use formulation.  This testing indicates that this product is a Category I eye
      irritant.  Registrants have the option of accepting this clnsolfIcntlon for their productfs) or of providing actual testing
      of each product (or substantially similar product).

-------
                                                          DKTA imnnREmns »m nm-A CAPS
                                                  FOR mNHFAcnnrnK-ire: MIT*"
Guideline Nanc of Are Data . Test toca EPA Have Data to Mbllogrophlc Must Additional Data be Sub-
Citation Test Required? Substance Partially or Totally Cltatlm Bitted Undrjr FIFRA Mc)(2)ini?
Satlafy Requirements? If So, tlmdlln" for Suhmlsnlnn
Product Chemistry
163.AI-3 Product Tea
Identity t
Disclosure of
Ingredients
163.61-6 Declaration Tea
of Ingredient
Units
163.61-7 Product Tea
Analyt Methods
t Data
163.61-8lc)Ul Color Tea
163.61-8(c)(2| Odor Tea
163.61-8(c){7) Physical Tea
State
163.61-8(0)1111 pit Tea
163.6l-8lcH12) Storage Tea
Stab.
I63.6l-B(cl(13l Plasm Ten
163.61-B(cH 14) Oxidizing Tea
or Reducing
Action
161.61-fllclilS) Explosive- Tes
ness
163.6l-8(c)(l6) Nlsclblllty Tes
163.61-8(cl(17) Viscosity Tes
I63.6l-R(cl(18) Corrosion Tes
Characteristics
Each E.U.
Product"
Each E.U.
Product**
Each E.U.
Product **
Each E.U.
Product"
Each E.U.
Each E.U.
Each E.U.
Prodcut"
Each E.U.
Product"
Each E.U.
Product"
lach E.U.
:»roduct"
Each E.U.
Product"
Each E.U.
Product"
>ch E.U.
E.-»ch E.U.
Product**
Partial1
No
Partial2
Ho
No
Tea
Partial*
Partial'
Partial"
No
Mo
rio
Mo
Partial5
CSF's Test fi months
Test 6 mnnths
Test 6 mnnths
•N Test 6 months
Test •> mnnths
CSF's and tahcls Test K months
Test 6 months
Hlrth ft M.ISOD. !•»??, 00005577 Test 6 mnnths
Test 6 months
Test fi months
Trst 6 mnnths
Test R mnnths
Tes: fi mnnths
Wlrth ft W.TSOO. 19??, 0000«i577 Tent « mnnths
•    These data are required for the roqlstratlnn of rnd-use HTPS products.


•    For currently registered prodict


••   Each end-use ncPA Product


1    Uprtated statencnta are required for earh product.


2    Satisfactory methods nre avalliihlo (sen T.ible Al hut d>ita arc required on each rnd-usr product..


3    Reel  "Product Chpmlatryi  End-Use Fornilatlons* for listing of avall.-ihlr* rlitn on thh d?nsltles of rurrently
     proKicta


4    Seet  •Product Chemistryi  End-Use Formulations* for llst.lng of avallahlp d,ita on th» r"'" of currmtly rpqlstcrod products.


5    Data are avallnhle on a dlmpthyl.-imlnc amlnp salt formulation (4«i4-1<>4|.


6    Sect  'ProAjrt Chemistry!  End-4l»! Formilatlons* for listing of available dnta on the flarnm blllty of currently rrglstorM
     producta.

-------
                                                                   .  r  (continued)
                                                         o DATA
                                                                           s »m rwm
ro.ffirummir^mW'
Guideline
Citation
Toxicology
163.81-1
Maim of
Test
•
Acute Oral
Toxicity
Are tlata
Required?
Yea
Test
Substance
E.U.
Product
Hoes EPA Have Data »o
Partially or Totally
Satisfy Requirements?
Partial2
niblioqraphlc
Citation
Curd. 1964,
Ourd et nl,
riust
mltt'vl
If So,
00022569
1964, 0002256B
A-V1ition.il Po»-a bo Sub-
llnfV^r FIFTIA l(r)(2M«)?
iv-adlinr- for Siihmlsr.lon
Yes: 6
mnnthn

163.81-2
163.81-3
163.81-4
Acute Dermal
Toxicity
Acute Inh.il.
Toxicity
Prim. Eye
Irritation
Yea
Yea
Yes
iro.Bi-s
          Prim. Derml  Yea
          Irritation
R.O.
Product

E.ll.   .
Product

E.ll.
Product1
                                             ,
                                      E.ll.
                                      Product
.
                                                         Partial
                                                         Partial"
                                                         Partial
            Partial
                                                                1
                                                                       Raltoch, 19??. 00021973
Raltech, 19??, 00021974
tobriel, 1971, 00004513

Raltech, 19?? 0002197fi
                                                               Yes«  fi nrmths
                                                                       niespndar f. »\nc|cvlne, 1979,     Yens  fi mnnths
                                                                           00021975
                                                                                                       Vest  6 months
                                                                      Y«?st  fi months
     For currently roqlatored products.

     Teatinq required of earh end-use product or substantially aim! lar product.  The Arpncy has iitw*? a preliminary 'V»»-ormln.itlon
     thati  soluble conmntratos containlnq the sodium, salt are substantially similar! that soluble concentrate prtylurts rontalninq
     the dlnethyJamine salt arc suhntantially almllarj that soluble concentrate products containing the diethanolamlne RiJt are
     substantially nltnl Inn that emulsif table concentrate products contalnlnq the butoxyctnyl ester are similar! that cmulslfiable
     concentrates containing thr« laooctyl ester are similar! and that emilnifinble concentrates contninlnq mixtures of tho butyl
     and isopropyl cstera are similar.
Available data ont  2
dlethanolnmlne salt.
                                 .  soluble concentrate containing the sollum salt and a soluble concentrate contalnlnq th>»
     Available data on a 2 Ih/qal. soluble concentrate contalnlnq the sorlium salt.

     Available dnta on the 2 Ib/qal. sodium salt fornulation indicate that this product Is a severe irritant.  Ifrviistmntn have the
     option of acceptinq this classification for their product (n), or of provldinq specific tcstinq.  Dnta were nlnn a«niab1e on an
     emilaifiahlc concentrate nrmtalninq the butoxyet-hyl ester.

-------
                                  CHAPTER IV
                             MCPA ProiXJCT CIDilSTRY
A.  Introduction

FIFRA 3(c)(2)(A) requires  the  Agency to establish guidelines for registering
pesticides in the United States.  The Proposed Guidelines require registrants
to provide quantitative data on all  active and added inert ingredients, and on
impurities that are equal  to or greater than 0.1 percent of the product by
weight.

To evaluate the composition of products proposed for registration, the Agency
requires data and information  not only on  the manufacturing and formulation
processes, but also a discussion on  tne formation of manufacturing impurities
and other product ingredients, intentional and unintentional.   Further, to
assure that the composition of the product as marketed will not vary from the
composition evaluated-at the time of registration,  applicants  are required to
submit a statement certifying  upper  and lower composition limits for the
active and inert ingredients,  and upper limits only for seme unintentional
ingredients.  Subpart D of the Proposed Guidelines (40 FR 29696, July 10,
1978) suggests specific precision limits for ingredients based on the
percentage of ingredients  and  the standard deviation of the analytical method.

In addition to the data on product composition, the Agency guidelines also
require data on the physical and chemical  properties of both the herbioirial
active ingredient and its  formulations. For example, data are needed
concerning the identity and physical-state-of-tne acti'7e-ingre^ient,--s'..'rr> as
melting point and boiling  point data,  ambient vapor pressure,  and solubility.
Data are also required on  the  properties of tne formulated product to
establish labeling precautionary statements (e.g.,  flammability, corrosiveness,
or storage stability).  The Agency uses these data to characterize the
herbicide and to determine its environmental and health hazards.

Product Chemistry;  Manufacturing-Use MCPA

                           Product Chemistry Profile

HCPA is the common name for 4-chloro-2-nethylphenoxyacetic acid.
Manufacturing-use and end-use  products are marketed under the  trade names
Mephanac, Methoxone, Agroxone  , MCF\ and Vfeedar .  MCPA
maijfccturing-use products are available in a variety of forms, including the
technical acid, the dimethylamine salt, the isooctyl ester, the butyl oster,
tne butoxyethyl ester, and a mixture of the isopropyl, iscbutyl, and N-butyl
esters.  In this Standard, MCPA refers to  the undissociated acid.  Esters and
salts of MCPA are identified as such.

Manufacturing-use MCPA acid contains a minimum of 35% 4-chloro-2-metnyl-
phenoxyacetic acid.  The dimethylamine manufacturing-use product contains a
minimum of 64% active ingredient.  The isooctyl ester manufacturing-use
products contain a minimum of  96% active ingredient.  The butoxyethyl
manufacturing-use products contain a minimum of 97% active ingredient, the

-------
butyl ester contains a minimum of 97% active ingredient,  and the
nancr-r-tu ring-use product,  containing a mixture of esters, contains 47.5%
isopi.Tr.-yl ester, 2B.5% isobutyl ester,  and 19% N-butyl ester.

Pure [1C PA is a wnite, crystalline powrter with a melting point of lift -119°C
and a bulk density of 0.7768  gm/cc.   MCPA is only slightly soluble in water,
but very soluble in etnanol and ethyl ether. • Manufacturing-use MCPA salts are
highly water-soluble, and manufacturing-use MCPA esters tend to be insoluble
in water.  The MCPA salts are less volatile than the esters.

Detailed manufacturing processes have not been submitted for currently
registered manufacturing-use  products.   Some published procedures for the
manufacture of MCPA use chlorocresols as starting or intermediate materials.
Because chlorinated phenols are dioxin precursors under certain conditions,
the Agency is requiring registrants  of technical fCPA acid and integrated
end-use products manufactured with chlorocresols to analyze the product(s) for
chlorinated dioxins or, alternatively,  to explain in detail why chlorinated
dioxins are unlikely to: be  found in  the product(s).

Amine and alkanolamine salts  of phenoxyacetic acids may contain nitrosamines
as a result of (1) nitrosame  contamination of the amines or alkanolamines used
to produce the salts, or  (2)  addition of nitrite to the product to inhibit
corrosion during storage.   Each registrant of a product containing an amine or
alJcanolamine salt of MCPA is  required to analyze the product immediately after
manufacture and after storage.  In lieu of analyses on stored products,
registrants may certify that  nitrosating agents are not added to the product
after manufacture.

For many products, Confidential Statements of Formula have not been submitted
or are outdated, incomplete,  or contain errors.  Although satisfactory methods
for the product analysis of MCPA and associated impurities are available,
analytical data have not been submitted by any registrant.

                               Topical Discussions

Chemical Identity

MCPA (Figure 1) is the common name for tne chemical 4-chloro-2-inethylphenoxy-
acetic acid.  Alternative chemical names for MCPA include 2-methyl-4-chloro-
pnenoxyacetic acid and  l(4-chloro-c-tolyl)oxy] acetic acid.  KCPA is also known
by many trade names including Mepnanac , Methoxone , Agroxone , MCF\
and tfeedar .  The Chemical  Abstracts Registry (CAS) number for MCPA is
94-74-6, and the EPA Shaughnessy Number is 030501.  The common name will be
used throughout tnis standard in lieu of other chemical or trade names.

-------
The cneraical formula  is CgHn,Cl(Kf  and  tne molecular weight is 200.62.
The structural formula is:
                                      0	CH,—C	OH
                         2-Methyl-4-chlorophenoxyacetic  acid

                                    Figure 1

In this standard, "MCPA" refers only  to  the undissociated acid.   Salts and
esters are identified, as such.

Manufacturing Process

Process descriptions submitted by registrants are considered Confidential
Business Information and are discussed in the Confidential Appendix.

Processes for the manufacture of  technical MCPA have been submitted to the
Agency by two producers,  neither of  the process descriptions is sufficiently
detailed to satisfy Guidelines requirements.
Discussion of the Formation,of Uhihte~ritiohal "Ingredients

No registrant of a product  containing  MCPA or an MCPA derivative has submitted
a discussion of the  formation of  unintentional ingredients in the product as
required by the Guidelines  <163.61-5).

Some published procedures for the manufacture of MCPA use cnlorocresols as
starting or intermediate materials  (Synerholin and Zimmerman,  1945, 05003614;
Talbot, 1949, 05020338; Talbot, 1952,  05020337).  Because chlorinated phenols
are dioxin precursors under certain  conditions,  the Agency requests that each
registrant of technical MCPA  manufactured with chlorocresols analyze the
product for chlorinated dioxins or,  alternatively,  explain in detail why
chlorinated dioxins  are unlikely  to  be found  in the product.

Mine and alkanolamine salts of pnenoxyacetic acid nay contain nitrosamines as
a result of (1) nitrosamine 'contamination of  the amines or alkanolamines used
to produce the salts or  (2) addition of nitrite to the product to inhibit
corrosion during storage.   Samples of  an amine salt formulation of MCPA
obtained "off-the-shelf" contained up  to 0.7  ppm N-nitrosodirtethylamine (Concn
et^'al^., 1978, 0506328).  Each registrant of a product containing an amine
or alkanolamine salt of MCPA  is requested to  analyze the product for
nitrosamines immediately after manufacture and after storage.  In lieu of
analyses of the stored product, a registrant  may certify that nitrosating
agents are not added to the product  after manufacture.

                                        37

-------
Sane data or. nitrosanir.es  in ar.ine  salts of  !O>A nave  been sub?.ittr:l by
Fallck-Lenkro  (Song,  1977,  00021962;  Paudlcr,  1979,  00021979 - see Confidential
Appendix).  However,  specific data  are  needed  on each  product.

Declaration and Certification of  Ingredient.Limits

For no product containing  MCPA or an  MCPA  derivative has the registrant of the
product established upper  and lower limits for the active ingredient and each
intentionally added inert  ingredient, and  upper limits for each identifiable
impurity as required  by tne Guidelines  (163.61-6).

Product Analytical Methods and Data

Fallek-Lankro  (Harwell, 1978, 00021977), Akzo  Zout Chemie (1971, 00004730), and
Chipman (1973, 00021917) have submitted GLC  methods by which MCPA and
phenoxyacetic acid imparities in  technical MCPA and in formulations are
determined as their methyl esters.  A spectrophotometric method for the
determination of chloropnenol in  MCPA-containing products has been submitted
(Akzo Zout Chemie, 1973, 0004735).  The method will determine cnloropnenols
down to 0.02% of tne  product weight.  Kemisk Vaerk Koge (1972, onorv.iy?*,) nas
sutmitted a combined  titrimetric-GLC  method  for the analysis of products
containing MCPA esters.

Various product analytical methods  for  MCPA  and associated impurities nave
been described in the  literature, including  GLC (Gardner and Cvortcn, I960,
05004565; Zweig and Snerma,,1972, 05005846;  Collier and Grimes, 19"M,
05003559), nigh-pressure - liquid -chrorm:orjr?.pny - tStevens-and-€ror-«4-, —.UP-a,-
05012650), and infrared spectrophotometry  (Malina 1971, 05003450).


Although satisfactory methods for the product  analysis of MCPA and associated
impurities are available,  analytical  data  required by  section 163.61-7 of tne
Guidelines have not been submitted  by any  registrant of an MCPA-containing
product.

Physical and Chemical Properties

St. John (1965, C0004995)  reports the physical and cnemical properties of
purified fCPA as:

        Color                 white
        Melting point       ;  118°-119°C
        Solubility            ethanol             153
        (gm/100 gm solvent  ;  ethyl etner           77
        at 25°C             •  toluene               6.0
                            /  xylene                 5.0
                              N-heptane             0.5
                              water                 0.15
        Physical state:       crystalline  powder or flakes
        Bulk density:         0.7768  gn/cc

                                        38

-------
The pKa of MCPA has been variously reporter? as  3.09,  by potcnticnetric
titration (Nelson and Faust, 1969, 05002356); 3.11, by a  conductimetric inethod
(Matell and Lindenfors, 1957, 05004185); and 3.13, by a spectrophotonetric
method (Cessna and Grover,  1978, 05004R44).

Sane physical and chemical  properties of technical f-CPA and  ICPA esters have
been submitted by registrants.  The data were submitted in conjunction with
Confidential Statements of  Formula.

                        MCPA (acid)        Iscoctyl ester       Mixed  esters
                     (Reg.  fto. 11636-2)  (Reg.  No. 11636-3)   (Reg.  No.  11636-1)
Color:
Odor:
Melting Point:
Solubility
  in VJater:
Physical State:
Density or
  Specific Gravity:
Bulk Density:
Flamnability:
 light brown
 phenolic
 115°C

1825 ppm at 15°C
 snail flakes

 0.6 gm/cc
 37.4 lbs./ftj
 not flammable
  clear brownish
  pleasant, fresh
insoluble
  liquid

  1.0 at 20°C
  100°C
  clear brownish
  pleasant, fresh
insoluble
  liquid

1.0 at 20°C
70°C
                          Summary of Major Data Gaps
No registrant of a product containing MCPA or  an MCPA derivative  has  submitted
a detailed manufacturing process, a discussion of  the formation of
unintentional substances in the product, a declaration  and  certification  of
ingredient limits, or analytical data en the product.   For  many products,
Confidential Statements of Formula  (EPA Form 8570-4)  nave not  been  submitted,
are outdated, are incomplete, or contain errors.   Scne  inert ingredients  in
food-use formulations have not been cleared for sucn  use under 40 CFR
180.1001.  Data on numerous physical and chemical  properties have not been
submitted.
                             Labeling Requirements

Ingredient Statement.  The  ingredient statement  for manufacturing-use  MCPA
will list the active ingredient as:

    2-metnyl-4-chlorophenoxyacetic acid  	  N% (run.)

The ingredient statement for manufacturing-use containing  MCPA derivatives
will list the active ingredient and  the  equivalent percentage  of  MCPA, for
example:

    2-methyl-4-chlorophenoxyacetic acid,  sodium  salt	N% (min.)
      (Equivalent to M% of  2-methyl-4-cnloropnenoxyacetic  acid)

-------
Product Chemistry;  End-Use Formulations

                           Product  Chemistry Profile

End-use MCPA products are available in emulsifiable  and  soluble concentrate
femulations.  End-use products  contain  a  variety of foms of MCPA,  including
the sodium salt of MCPA, the diethanolamine  salt of  f-CPA,  the dinethylamine
salt of MCPA, the isooctyl ester of MCPA,  the butoxyethyl  ester of MCPA and a
mixture of the butyl and isopropyl  esters  of MCPA.

Few data were available on the physical/chemical properties of any end-use
product.  Sere data on the pH, density,  and  flaimability of particular end-use
products are available (see topical discussions). Because tne flash points of
several enulsifiable concentrates  (the esters)  range between 30° and 150°F,
special labeling is required for these products.

Mine and alkanolamine" salts of  phenoxyacetic acids  may  contain nitrosamines
as a result of (1) nitrosomine contamination of the  amines or alkanolamines
used to produce the salts or (2) addition  of nitrite to  the product  to inhibit
corrosion during storage.  Each  registrant of a product  containing an amine or
alkanolamine salt of F1CPA is required to analyze the product immediately after
manufacture and after storage.   In  lieu  of analyses  on stored products,
registrants nay certify that nitrosating agents are  not  intentionally added to
the product after manufacture.

For nany products, Confidential  Statements of Formula have not boon  submitted
or are outdated, incomplete, or  contain  errors.  Although  satisfactory methods
for the product analysis of 71CPA and associated impurities are available;	-~ '
analytical data have not been submitted  by any  registrant.

                             Topical Discussions

Chemical Identity

End-use products formulated as soluble concentrates  contain the sodium salt of
MCPA, the diethanolamine salt of MCPA, or  the dimethylanine salt of  f'CPA.
End-use products formulated as emulsifiable  concentrates contain the
dimethylamine salt of MCPA, the  isooctyl ester  of MCPA,  the butoxyethyl ester
of MCPA, or a mixture of butyl and  isopropyl esters. The  dimethylanine salt
formulations are the most frequently used  products.

Active Ingredients in Pesticide  Products

Product concentrations of fCPA acid equivalent  range from  1 to 4 pounds acid
equivalent per gallon of product, with tne 4-pounds-per-gallon measure being
tne most common.

For no product containing an MCPA derivative has the registrant of the product
established upper and lower limits  for the active ingredient and each
intentionally added inert ingredient, and  upper limits  for each identifiable
impurity as required by the Guidelines (163.61-6).


                                       So

-------
Product Analytical Methods and Data
See discussion in Manufacturing-use section for details on acceptable
analytical methods.  Analytical data have not been submitted by any registrant.
Physical and Chemical Properties

EPA Registration number         Density

  Dimethylamine Salts
       148-1120                    9.38
       228-143                     9.39
       264-47                      9.403
       359-365                     9.38
       464-394                     9.4
       524-80                      9.358
       554-60                      9.37
       677-298      •'•'•>             9.47
       802-138                     8.79
      1386-587                     9.4
      1685-61                      8.58
     39335-7                       9.55
     39511-65                      9.4

     Sodium Salts
       264-55                      9.212
       359-170                     9.35
       802-374                     9.19
     39335-6                       9.413

 Diethanolamine Salts
       554-123                     9.898

    Iscoctyl Esters
       359-554                     8.3
       554-125                     3.5056
     39511-76                      8.51

  Butoxyetnyl Esters
       264-240                     8.971
                                                     7.5

                                                   7.5-8.0
                                                   9.0-9.5
                                                     7.4
                                                   8.0-9.0
                                                   6.8-7.2
                                                     7.5
                                                   8.0-8.5

                                                     8.0


                                                   8.0-8.6
                                                                Flanmability
                                     190°F TOC
                                    >200°F TCC
                                                                     168°F
                                                                   133°F TOC
                                                                     125°F
     Mixed Esters
       554-91
      8.308

Labeling Requirements
                                                                   129°F TOC
The ingredient statement for end-use products containing MCPA derivatives will
list the active ingredient and the equivalent percentage of T-CPA, for example:

        2-nethyl-4-cnlorophenoxyacetic acid, sodium salt 	 M%  (min.)
          (Equivalent to H% of 2-methyl-4-chlorophenoxyacetic acid)
                                        H\

-------
Pnysical Hazard Precautionary Labeling

The fl~:sn points of  scne  emulsifiahle concentrates of MCPA esters are between
80° and 150°F and  labels  on  tnese  produces are tnerefore required to bear
try? following flarmability warning (40 CFR 162.1fl(nM2)(iii)(13)l:
                "Co not  use  or  store near neat or open flame."

-------
                                    CHAPTER V



                          E^VUOMEtfTAL  FATE  OF  MCPA
Introduction
Data on the fate of a pesticide once  it  enters  the  environment are required to
predict and estimate any potentially  harmful effects  on man  and the
environment.  The fate of pesticide depends on  its  formulation type,
application methods or use patterns and  its chemical,  physical, and biological
behavior in the environment.

Environmental studies from which data are  required  include physical and
chemical degradation, metabolism,  field  dissipation,  and  accumulation.

MCPA is available in soluble and emulsifiable concentrate formulations.  These
formulations contain a variety of  salts  and esters  of MCPA including  the
sodium salt of MCPA, the dimethylamine salt of  MCPA,  the  diethanolamine salt
of MCPA, the isooctyl ester of MCPA,  and the butoxyethyl  ester of MCPA.  MCPA
acid, tne dimethylamine salt of MCPA,  the  isooctyl  ester, the butyl ester, tne
butoxyethyl ester, and a mixture of the  isobutyl, isopropyl,  and butyl  esters
are registered manufacturing-use products.  The Agency requires data  on the
fate of MCPA acid in the environment,  and  data  on the fate of each salt and
ester found in end-use products.

Because of the interconvertability of MCPA acid and salt  forms, MCPA  acid and
its salts may be considered as one entity  for Environmental  Fate testing
requirements.

For MCPA esters, the situation is  different.  The Agency  has no data  on the
rates of hydrolysis of MCPA esters in living or nonliving systems. The Agency
has no basis for assuming tnat MCPA esters are  equivalent to MCPA acid  for
testing purposes.  Therefore, registrants  of manufacturing-use MCPA esters and
registrants of integrated end-use  products containing unregistered technical
esters, must provide testing on each  ester, or, cite  available data showing
that a particular ester would be equivalent to  MCPA acid  under test
conditions.  Data on analogous chemicals (e.g.  2,4-D)  would  be acceptable.

                                   Use Profile

MCPA is a phenoxy herbicide used on a variety of crop and non-crop sites to
control a wide spectrum of broadleaf  weeds.  MCPA is  formulated as 1-4
pound(s) per gallon emulsifiable concentrates and soluble concentrates.  There
are 62 products containing MCPA as the sole active  ingredient (SAI) registered
with EPA.  The forms of fCPA available as  SAI are MCPA acid}  sodium salt,
diethanolamine salt, dimethylamine salt, isoocytl ester,  butyl ester, and
butoxyethyl ester.  The dimetnylamine salt is the most frequently used
formulation.  The salts are highly water soluble \/hile tne esters are not water
soluble but are readily mixed.  Table 5-1  presents  the forms, formulations and
number of products containing MCPA that  are registered with  EPA.


                                        43

-------
Table 5.1  MCPA Formulations and Products
Form
MCPA (acid)
Salium Salt
Diethanolamine salt
Dietnylamine salt
H n
n ii

Isooctylester
Butylester
Butoxyethyl ester
(Mixture) Butyl and
Formulations

SC*
SC
SC
SC
SC or EC*
• <*•
EC or SC*
EC
EC
EC
Pounds acid
equivalent
per gallon

2
4
1
5
4

4
4
4
'total
Huinber
of Pro-
ducts
8
8
2
1
1
21

• 8
1
3
1
Manufacturing
Products
8
0
0
1


4
1
2
2
  Isopropyl esters

(Mixture) Iscbutyl,
Isopropyl, and Butyl esters
*  SC = soluble concentrate
   EC = emulsifiable concentrate
Based on tne preliminary quantitative  usage  analysis  prepared  by EPA
economists, tne net domestic supply of MCPA  for  1979  was  estimated at 3.25 to
3.70 million pounds.  The majority of  MCPA produced  in  the  U.S.  (55 to 65%) is
used on wheat grown in tne Plains States.  The second largest  use (12 to 14%)
is on rice in California.  These two sites,  in addition to  the other small
grains  (barley, oats, rye), comprise  85 to  95%  of MCPA annual usaqe.  Other
sites for wnicn WCPA use is registered are:   alfalfa, clover,  flax, grasses
(grown for seed), non-crop areas, pastures,  peas, rangeland, grain sorghum, and
turf.  MCPA is used domestically on hcme lawns.  Table  5-2  presents use
information.

Most MCPA is applied postemergencc by  farmers or professional  applicators.
Application Is usually made by  fixed-bocm ground rig  sprayers  in 10 to 3C
gallons of water per acre.  MCPA is also applied aerially in 2 to 10 gallons of
water per acre, primarily on rice.  Application  of MCPA is  subject to tho same
kinds  of state restrictions as other  pnenoxy herbicides.  These restrictions
are designed to reduce drift and off-target  movement  by

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                                                           Table 5-2.  PestlcldaJ Uses of HCPA
BJP
Use Sites Formula-
tions
Small grains - Ml
oats, barley,
rye, wheat

Small grains Sodium
with legumes and amine
(clover or salts
alfalfa)
Season or Crop
Growth Stage
Apply after crop 1' as
reached 3 or 4 leaf
stage up to boot
stage.
Apply after cereal is
well-tillered and
before boot stage.
Application
Type Equipment
Postenergent Aerial or
broadcast ground rig
sprayers

Postenergent Aerial or
broadcast ground rig
sprayers
                                                                                             0.125 to 1.5
                                                                                             Ibs. active
                                                                                             Ingredient
                                                                                             per Acre
                                                                                             0.125 to 0.5
                                                                                             Ibs. ai/A
                                                                                                             Hunter of
                                                                                                            > Treatments/
                                                                                                             Intervals
1 per crop
1 per crop
                Cannon Tank
                Mixes
Hith dicamba,
brcmoxynil,
plcloram
None
                  Notes and
                  Limitations
Application rate
depends on nature
of weeds; average
rate is about
0.5 Ibs.
Legune should be
protected from
herbicide by
grain or weed
cover.  Apply
in not more than
5 to 10 gal. of
water per acre.
Rice
Sodium
and amine
salts.
butoxy-
etnanol
esters
Apply at nidseaaon
35 to 65 days after
seeding.



Postenergent Aerial
broadcast




0.75 to 1.5
Ibs. ai/A




1 per crop
None
Field should be
flooded with
2 to 3" of water.
Mr tempera-
ture should be
below 90 F.

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                                                           •table 5-2.  Pesticidal Uses of HCPA

Use Sites
Flax
Clover and
Alfalfa
V
Grasslands
and Seed
Grasses
HIP
Formula-
tions
All
Sodium
and arolne
salts
All
Season or Crop
Growth Stage
Apply when flax has at
least 3 or 4 leaves tnd
before it cores intc
bud.
Apply in fall after
frost when legumes nee
fully dormant.
Apply when weeds an;
actively growing;
before grass boot stage.

Type
Postenergent
broadcast
Postenergent
broadcast
Postenergent
broadcast
Application
Brjuiprtnnt
Aerial or
ground rig
sprayers
Ground rig
sprayers
Aerial or
ground rig
sprayers
Number of Cannon Tank
Rate Treatments/ Mixes
Intervals
0.125 to 0.75 1 per crop With TCA,
Jbs. al/A da la pan
0.125 to 0.5 1 per crop None
Ibs. ai/A
0.5 to 1.5 tepeat as
Ibs. ai/A needed
Notes and
Limitations

Treatment air
benperature
' should be above
above 40
degrees P.
Grass for seed
is treated at
lower applica-
                                                                                                                                              tion rates and
                                                                                                                                              treated before
                                                                                                                                              boot stage to
                                                                                                                                              avoid seed blast.
PeasTfleTd"       Sodium or    Appljf no later than"
 or green)        amine        3 nodes before first
                  salta        pea flowering (spring).
Postenergent      Ground rig       oTliS to tfTTfS  T per crop"
broadcast         sprayers, sane   Ibs. ai/A
                  sane aerial
None
Do not spray peas
stressed tram lack
of moisture.

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Table 5-2.  Pesticlda] Uses of NCPA
GUP
Use Sites Formula-
tions
Sorghum Sodium
salt
Turf Sodium
or amine
salt
Noncrop such All
as:
fallowland,
farm premises,
fenoerows,
commercial/
industrial
site, parks,
forest
chaparral,
shelter belts,
tlmberlanda,
roadsides and
rights-of-way
Season or Crop
Growth Stage
Apply when crop la
6 to 12" but be fort;
boot stage « Heeds
should be less than
5- tall.
Apply when weeds are
actively growing
(best In spring or
fall).
Apply when weeds are
actively growing.
Application Nunfcer of Cannon Tank
Type Equipment Rate "Treatments/ Mixes
Intervals
r
Postemergent Aerial or 0.75 Ibs. 1 per crop None
broadcast ground rig a I/A
sprayers
Postenergent Ground rig 0.5 to 2.0 Repeat as
broadcast sprayers and Ibs. ai/A necessary
knapsack
sprayers
Postemergent Mostly fixed 0.125 to 3.0 Repeat as With picloram
broadcast or ground rig Ibs. ai/A necessary
directed spray sprayers or (depends
hand-directed on weed)
sprayers,
sane aerial
Notes and
Lint tat ions
Sorghum hybrids
vary in their
tolerance to
ttPA. Use of a
surfactant may
increase chance
of crop injury.
Do not mow
within 2 days
before or after
application.
For control of
whitebcush add
1 gallon diesel
oil to ML'PA in
8 gallon water
per acre.

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Table 5.2   Manufacturing Product Labels for MCPA

Label^ Number	Active Ingredient	%A. I.

264-228

359-588

6305-12

7173-127

7969-34

8203-18

9618-11

39335-4

359-628
                                    Product Name
                                             Manufacturers
359-669

534-131

9618-12

39511-44

39511-43

11687-76

39511-45


9618-10
MCP Acid

MCP Acid

MCP Acid

MCP Acid

MCP Acid

MCP Acid

MCP Acid

MCP Acid
95%

98.5%

94%

95%

85%

94%

95%

94%
MCP Dimethylamine Salt   64.1%


MCP Isooctyl Ester       96%

MCP Isooctyl Ester       99.0%

MCP Isooctyl Ester       99.9%

ICP Isooctyl Ester       97%

MCP Butyl Ester          97%

ICP Butoxyethyl Ester    97.0%

ICP Butoxyethyl Ester    97%
MCP Isopropyl Ester      47.5%
ICP Isobutyl Ester       28.5%
ICP N-Butyl Ester        19.0%
ICPA

Rhodia MCPA Acid

ICPA (Technical Grade)

Chempar MCPA Technical Acid

O-46 MCP
                         *\
MCPA Acid

ICPA Acid

MCPA Acid

Rhodia MCPA Amine
(5 Ib. Concentrate)

Rhodia MCPA Isooctyl Ester

Technical MCP Ester

Technical I 0 Ester

Transvaal MCPA Isooctyl

Transvaal MCPA Butylester

MCPA Low Volatile Oxy Ester

Transvaal MCPA Low Volatile
   Oxy Ester

Mixed Technical MCP
MCP Ester
Amchem Products, Inc.

Rhodia, Inc.

Robeco  Chemicals, Inc.

Chempar Chemical Co., Inc.

BASF Wyandotte Corporation

Chipman Chemicals, Ltd.

Trans Chemic Industries, Inc.

Pallek-Lankro Corp.

Rhodia, Inc.


Rhodia, Inc.

AGSCO, Inc.

Trans Chemic Industries, Inc.

\fertac, Inc.

\fertac, Inc.

Transvaal, Inc.

\fertac, Inc.


Trans Chemic Industries, Inc.

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volatilization  (particularly  esters).   Typical restrictions include limits on
certain formulations  (usually esters),  wind speed,  temperature and application
method.  Scne states  (California  and Oregon)  require special permits for the.
use of pnenoxy  nerbicides.
                           Environmental  Fate Profile

Data on pnysico-cnemical degradation, mobility, and accumulation are requried
for MCPA acid,  salts, and esters  of MCPA.   However, the Agency has determined
that because of the interconvertability of  MCPA acid and salts, MCPA and salts
may be considered as one entity for testing purposes.  For esters the situation
is different.  The Agency has no  data on  the rates  of hydrolysis of MCPA esters
in living and non-living systems, and,  therefore, there is no reason to believe
that MCPA acid  and esters are equivalent  for testing purposes.  Registrants of
products containing esters of MCPA acid have the option of providing all
categories of data on each ester  form,  or of citing data showing that a
particular ester would be equivalent to MCPA acid under test conditions.  The
Agency will accept references to  valid  data on analyogous chemicals (i.e.,
2,4-D).

Preliminary data indicate that MCPA may not hydrolyze at pH 7, because MCPA
was not lost following heating at temperatures of 34 to 35°C for 13 days.
MCPA appears to pnotolyze, and has a photolytic half-life of 20 to 24 days in
sunlight at pH  8.3.  When exposed to fluorescent light, three major photolysis
products (4-chloro-2-methyl-pnenol, 4-chloro-2-formylpnenol, and o-cresol)
are formed within 71 hours at pH  9.8.
                            'i
Because MCPA adsorbs to organic matter, it  is degraded more rapidly in soils
containing less than .10% organic .natter .than _in .soils ogn^ining higher levels
of organic matter.  The half-life of MCPA at pH 5.5 to 8.5 is 5 to 6 days. /At...
pH's of 5 and below, the half-life increases and ranges from 13 to greater than
50 days.

MCPA is degraded by aquatic organisms within 13 days of application.  Soil
bacteria, fungi, and algae are capable  of metabolizing MCPA, with MCPA being
utilized as a source of carbon in many  species.  In general, growth and other
biological functions of microorganisms  are  not inhibited by MCPA.  However,
there are data  available which indicate that MCPA may inhibit nitrogen
fixation in Phizobium spp. and in blue-green algae.

MCPA can be expected to leach in  most soil  types, with the degree of leaching
being inversely related to the amount of  organic matter in the soil.  Mobility
increases as the amount of organic natter decreases, probably duo to the
adsorption of MCPA to soil organic natter.   Because of its ability to readily
leach in certain soil types,  MCPA may contaminate groundwater.  This would be
especially true of fCPA salts, which are  highly water soluble.  Sampling and
monitoring data frcm wells in Ontario,  Canada indicated MCPA residues (1.1-
1,000 ppb) in 2 of the 237 wells  sampled.

Since MCPA is degraded less rapidly and leaches more slowly in soils high  in
organic matter, MCPA can be expected to dissipate at a much slower rate in
these soil types.  The field  dissipation  of MCPA may require up to 20 weeks

                                        HI

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following initial application.   In  the aquatic environment,  however,
dissipation occurs much more rapidly, typically within 32 days of application.
A cannon netabolite of MCPA, 5-cnloro-o-cresol, is formed at low levels
within 1 day of application to water.  Although data  indicate that hCPA does
not seem to persist in water, it may  indeed persist in sediments.  MCPA also
seems to persist in leaf litter  and the  upper 3 on of soil in the forest
ecosystem.

                               Exposure  Profile

The high volatility of most MCPA ester formulations increases the potential of
respiratory exposure, whereas the MCPA salt formulations are essentially
nonvolatile.  Spray drift, primarily  from aerial spraying
operations using ester formulations,  may lead to exposure of humans,
livestock, wildlife, and crops outside of the application site.  It is
anticipated that the most significant direct exposure will be to workers
during mixing and loading operations.  Dermal and  ocular exposure from
splashing of the concentrates can occur  during mixing of the SC/L and EC
formulations.  Respiratory exposure to highly volatile ester formulations may
also occur.  However, no data are available to assess such exposures.  Dermal
and ocular exposures could be minimized  by the use of gloves, goggles,  and
otner protective clothing while  MCPA  is  being handled.  Respiratory exposure
during mixing could be minimized by working in well ventilated areas  or
wearing an appropriate respirator.

More data are necessary to fully estimate potential exposure to MCPA.  These
data include:  bioaccumulaticn data and  the octanol/water partition
coefficient; da.ta to quantify human exposure during handling and application
operations; data showing dissipation  of  dislodgeable  residues on plant
surfaces; and volatility data which would indicate potential inhalation
exposure.

                              Topical Discussions

Physico-Chemical Degradation

One preliminary study indicated  that  MCPA is resistant to hydrolysis  at pH 7,
because MCPA \ras heated to 34 to 35°C for 13 days  at  pH 7 without any
noticeable loss (Soderquist and  Crosby,  00004448 and  05003445).  MCPA in 1%
tlaHCO-j aqueous solution (pH 8.3) has  a photolytic  half-life of 20 to  24 days
in sunlight  (Soderquist and Crosby,  00004448 and  05003445).  When exposed to
fluorescent light (>290 urn), MCPA in  aqueous solution (pH 9.3) produces three
minor «10%) photolysis products:   4-chloro-2-methyl-phenol, 4-chloro-2-formyl-
phenol and o-cresol in 71 hours.

Metabolism  •

MCPA is degraded more rapidly in soils containing  less than 10% organic matter
tnan in soils containing higher  levels of organic  matter.  In soils containing
less than 10% organic matter, MCPA was degraded within 1 day.  In soils
containing higher percentages of organic matter, degradation was slowed to
between 3 and 9 days (Torstensson,  1975, 05008552).  This may be due  to

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 adsorption to the soil organic natter.  MCPA, when applied a second time  to
 soil, is degraded almost twice as fast (5 to 12 days) as  it is after one
 application (15 to 28 clays).  The nalf-.life of MCPA,  in a soil-inoculated  salt
 solution, is 5 to 6 days at pH 5.5 to 8.5 but increases to 13 to >50 days  at
 pH's of 5 and below.  Preliminary evidence indicates  t-.nni: oersistence  is not
.influenced greatly by soil type (Loos et al., 050121941.

 Unlabeled MCPA in rice paddy water under dark conditioas  is almost totally
 degraded (over 99%) by aquatic microorganisms in 13 days  (Soderquist and
 Crosby, 00004443 and 05003445).

 Several bacteria are capable of metabolizing MCPA, and degradation is  rare
 rapid if bacteria become adapted to (CPA.  The proposed MCPA degradation
 patnway for Pseudonpnas (NCIB 9340) (Ganar and Gaunt, 05005451; Gaunt  and
 Evans, 05003416) is as follows:  side-chain loss (5-chloro-o-crcsol),
 hydroxylation (5-chloro-3-methylcatecnol), ring fission (/-chloro- c<-  -
 -methylnuconic acid), denalogenation and lactone fomation (/-carboxynethy-
 lene-o(-inetnylct-£butenolide), and lactone splitting (jj-hydroxy c* -
 metnyLnuconic acid).  Other products isolated from culture fluids indicate the
 possiblity of  minor metabolic pathways.

 Arthrobacter sp. and Flavobacterium peregrinum also cleave tne acetate side
 cnain, yielding 5-chloro-g -cresol (Bollag ot al., 05004641).  The above
 bacteria, as well as Acnronobacter sp., are capable of oxidizing 5-chloro-
 o-cresol and/or 4-chlorocatecnol, a potential fICPA degradation product
 (Boll^g  et a_l., 05004641; Loos et a.L., 05001910; Steonson and tlalker,
 05004430 and 05013551).  Pseudononas (NCIB 93'!0) and Arthrobacter sp.,
 adapted to MCPA,  ccnplete ring fission arr? dehalogenation of MCPA at'very~nlnrv
 concentrations (1,000 and 2,000 ppm, respectively) within 120 hours (Bollag et
 al. , 05004641; Gaunt and Evans, C5CC3-U6).  Alcaligenes poradoxus JMP116  and
 a"Corynebacteriun-like" bacterium also oxidize riCPA and, as with some  of
 the above bacteria, nay utilize MCPA as the sole carbon source (Fisheret al.
, 05003428; Jensen and Peterson, 05003757 and 05004434; Steenson and WaTJcer,
 05015452).  A transferrable plasmid, pJPl, allows A. paradoxus to utilize  MCPA
 as a carbon source (Fisher et a_l., 05003423).

 Several fungi (Aspergillus niger, Fusariun culmorum, Gloeosporun kaki, G.
 olivarum, Mucor sp., Penicillium sp., Scnizophyllum connune, Verticilliun
 spp., and Zygorhynchus moelleri) metabolize MCPA (Faulkner and Vfoodcock,
 05003766; tfel^j ima et a_l., 05005543; Tbrstensson et al., 05P04649).  Two
 fungal metabolites are 4-chloro-5-hydroxy-2-metnyIphenoxyacetato and
 2- (2-nethyl-4-cnlorophenoxy )etnano.l.

 Microorganisms, in general, are not inhibited by MCPA at recommended
 application rates (0.1 to 1.5 ppn).  While not inhibiting growth of Rhizobiun
 spp. or blue'-green algae, MCPA at 0.1 ppn inhibits nitrogen fixation by
 Rhizobium spp.; and at 20 ppn, nitrogen fixation by blue-green algae (Abou
 Elfadl and Fahmy, 0500C511; Balezina, 05012661; DaSilva et al., 05005265 and
 05009423; Fletcher and Raymond, 050057C8; Gillberg, OSOO^SB; Hutber et al.,
 05020356; Noll and Bauer, 05020^66; Torstensson, 05004429; Vintikova et aT.,
 05C03543).  Soil microbial functions other than nitrogen  fixation are  generally
 not affected by >VCPA at recommended rates of application, although nitrifi

                                        S\

-------
cation nay be temporarily  inhibited  (De and  Mukhopadhyay,  05004661;  Grossbard,
05015630; Jensen and Sorensen,  05004656;  Sooner,  050204C4;  Torstcnssen,
0500418S; Verona, 05019175).  The growth  of  bacteria,  fungi,  and algae
similarly is not inhibited by MCPA (Balezina,  05012661;  Da Silva et al.,
05009865; Efe and Muknopaenygy,  05004661;  Kulinska,  05019112;  Kunert ,"0*5008678;
Metting and Rayburn, 05019047;  Nakajima et-al., 05005548;  Steenson and
Walker, 05015452; Torstensson,  05004188;  Toure and  Stenz,  05016148;  Verona,
05019175; Wehr and Klein,  05015407; Wilkinson  and Lucas, 05006526; Zauner et
al., 05021608).

Mobility

MCPA would be expected  to  leach in most soils.  Phytotoxic levels of MCPA
leached 30 cm in a sandy soil column eluted  with  50 cm of  water (Herzel  and
Schmidt, 05021236).  Using soil thin-layer chromatographic techniques, MCPA
was mobile (Rr-0.6-1.0) in calcium montmorillonite  clay  (Helling, 05016652)
and in sandy loan and silty clay loam  soils  (Helling and Turner, 05004203).
Mobility increases as" the organic matter  content  decreases, possiblity due to
the adsorption of MCPA  to  this  soil component.
Significant volatilization of MCPA  is  unlikely in  the  environment since no
MCPA volatilizes from an aqueous  solution  (pH 7.0) heated at 34 to 35°C for
13 days  (Soderquist and Crosby, 00004448 and  05003445).
Adsorption of MCPA  to soil  requires  further study.   MCPA adsorbs to goethite
(nyclrated iron oxide) only  at pH's below  the point  of zero charge «pH 8)
and adsorption increases with decreasing  pH (Kavanagh et al.,  05005526).   The
role of such positively charged clay minerals in  tne absorption of MCPA to
natural soils in unknown.

Groundwater Contamination

Because MCPA leaches in most soils,  there is a potential for contamination of
groundwater (Herzcl and Schmidt,  05021236;  Helling, 05016652;  and Helling  and
Turner, 05004203).  MCPA residues were  detected in  2 of 237 wells sampled  in
Ontario, Canada, between 1969 and 1978  (Frank et  jd., 05019954).  One
positive sample had MCPA residue  levels in  the 1.1  to 10 ppb range and the
other positive sample had MCPA residue  levels in  the 101 to 1,000 ppb range.
An accidental spill of 1,000 liters  of  a  40% MCPA solution on  soil in
Czechoslovakia contaminated wells within  150 m of the spill site.  The wells
contained MCPA at 0.1 to 6.4 ppm  for 8  to 11 months after the  spill before the
concentrations decreased below detectable levels  (Syneket al., 05009727).
Although ICPA is nobile in  soils  and has  been detected in isolated well water
samples, degradation of MCPA in soil and  water may  reduce the potential for
groundwater contamination  (Bollag et al^., 05004641; Faulkner and Woodcock,
05003766; Fisher, Appleton, and Pemberton,  05003428; Gamar and Gaunt, 05005451;
Gaunt and Evans, 05C03416;  Jensen, 05003757; Jensen and Petersen, 05004434;
Loos et al^., 05003910; Nakajima,  et  a_l.,  05005548;  Steenson and Walker,
05015452, 05004430, 05013551; Soderquist  and Crosby, 00004448; Soderquist  and
Crosby, 050024-15,  ; Torstenssen et al., 05004649).

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Dissipation

Using bioassays, MCPA appears  to  dissipate  within 3  to 7 weeks from soil
treated witn 0.75 to 1.5 ppm for  6  to IS  previous years (Doltose,  05011006;
Fryer and Kirkland, 05006578;  Tbrstensen  et al.,  05004649).   An initial
application of MCPA may require up  to 20  weeks  for complete  dissipation.

In the forest ecosystem, MCPA  remains in  soil  (0  to  3  cm) and leaf litter at
0.7 and 32 ppm, respectively,  10  months after application at 2.5  kg ae/ha
(Eronen et a_l. , 0500R355).  MCPA residues  in noss decline to 7%  of tne
initial level within 40 days.  Residues in  soil  (3 to  15 en  deep) arc- not
detectable after 40 days.

MCPA dissipates from soil at similar  rates  whether applied alone  or in
combination witn dicamba and bronoxynil  (Suzuki,  00004563).   The  time required
for MCPA to dissipate to nondetectable levels from sandy and silt loam soils,
alone or in combination* is 30 to 60  days.

In the aquatic environment, MCPA  dissipates rapidly  (14 to 32 days) in water,
but residue levels in the flooded soil remain unchanged (Soderquist and  Crosby,
00004443 and 05003445; Sokolcv et al., 05010497 and  05012269). A cannon
metabolite, 5-chloro-o-cresol, is Tomed  at low levels (1.3% or less)
within 1 day of treatement.  Frank  et al.,  (05019954)  detected MCPA residues
(1.1 to 1,000 ppb) in two of 237  weTTs sampled in Ontario, Canada, between  1969
and 1978.

                               Label Restrictions

Current label restrictions prohibit the use of MCPA-butoxyethyl ester in
greenhouses, on heavy clay soils, or  wnere  crcps  './ill  be planted  in a rough,
cloddy seed bed.  rCPA-diethanolamine salt  or :CPA-isooctyl  ester should not
be apnlied by air in the vicinity of  sugar  beets. .MCPA-isooctyl  ester should
not •'  l used around homes, recreation  sites, or similar areas.  MCPA-sodium
salt should not be applied with nozzles tnat produce a fine  spray.

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                                  CHAPTER VI

                              TOXICOLOGY  OF HCPA

Introduction

A wide range of MCPA products are currently'registered for use.
Manufacturing-use products containing MCPA acid,  the  dimethylamine salt of
MCPA, the isooctyl ester, the butyl ester, the  butoxyethyl ester,  or a mixture
of the isobutyl, isopropyl, and butyl esters  are currently available.   End-use
products containing the sodium salt of MCPA,  tne diethanolamine  salt of MCPA,
the dimetnylamine salt of MCPA, the isooctyl  ester of MCPA,  the  butoxyethyl
ester, or a mixture of tne butyl and  isopropyl  esters are also available.

The Agency is requiring a full battery of toxicological testing  on technical
grade MCPA acid to support tne food uses  of this active ingredient.  The
Agency nas made a preliminary determination that acute, subchronic, and
cnronic toxicological itesting of MCPA acid will provide sufficient information
to support the requirements for testing of the  technical grade esters of MCPA
and each manufacturing-use MCPA salt.  Registrants have the option of
supplying the full battery of acute,  subchronic,  and  chronic toxicological
testing on each technical grade ester and eacn  manufacturing-use MCPA salt or
of citing data which show that a particular ester or  salt will be  equivalent
to MCPA acid under test conditions.

Manufacturing-Use MCPA

                              Toxicology  Profile

Acute Toxicity

Single-dose oral toxicity testing of  MCPA indicates  that MCPA acid has a
relatively moderate acute oral toxicity in rats, with an LD^Q value of 1.33
g/kg in nale rats and .765 gAg in female rats.  Ib data were available with
respect to the acute dermal toxicity, acute inhalation toxicity, primary
dermal irritation potential or dermal sensitization potential of MCPA.
Primary eye irritation testing of an  end-use  formulation indicates that MCPA
may be a severe irritant.

Acute Delayed iteurotoxicity

Because MCPA is structurally similar  to a suspected neurotoxin,  2,4-D, testing
of MCPA may be required.  The Agency  is reserving its decision to  require  this
testing on MCPA until testing of 2,4-D has been completed.  Testing of 2,4-C
is currently underway.

Subchronic Testing

Sufficient data were available to set = no-observed effect level (NOEL) for
MCPA of 3 mgAg in rats.  Testing in  beagle dogs indicates that  MCPA may

                                       5H

-------
 induce dose-related curtailment of  spermatogenic activity,  tubular atrophy,
 flnci prostntic cnangcs,  including  iimature  and  atropnio ^ppearancr?.  Tne KCEL
 for these effects was set at  4 mg/kg«

 The Provisional Acceptable Daily  Intake  (PADI) of riCPA in the human diet is
 .002 mgAgAfay or MPI .12 mg/day  based on  the  NOEL reported in the subcnronic
dog study.

Teratogenicity and Mutagenicity Testing

 In teratology testing of MCPA, reported  results indicated that !£PA nf»y be
 teratogenic and fetotoxic.  The incidence  of minor skeletal variants and
 decreased fetal weights in mice was significantly greater at ICO r.ig/};g dietary
 levels of fCPA.  Tne NOEL for this  effect  was  set at 25 mg/kg«  In a separate
 study at dietary levels of 60 and 100 mg/kg» the major nalformation rate was
significantly increased and fetal weights  were significantly decreased.  The
NOEL for fetotoxicity was set at  30 mgAg-

 in mutagencity testing of ?1CPA, data were  available wnicn indicated that MCPA
nay be a weak mutagen in certain  study systems.  MCPA was observed to induce
mutations in Saccnaroryces cerevisiae and  in Drosopnila.  liCPA nas also been
 reported to cause inhibition  of testicular DNA synthesis in male mice.

Other mutagenicity testing indicates tnat  MCPA does not induce mutations.
Thus, data are inconclusive,  and  additional testing is required.

 Reproduction

A valid reproduction study was not  available for review.  However, a
 supplementary spematogenesis study showed that male rats receiving as low as
 13 mgAg/day MCPA in drinking water had  slight degeneration of the semini-
 ferous tubules with loss of spermatids.   It should ho noted that those effects
were erratic, but nonetheless similar events were demonstrated in the
 subchronic feeding study using dogs.
M,
 letabolisra

Metabolism data  indicate  tnat  the major route of excretion is urinary
elimination in rats within 192 hours of dosing.   The data did not indicate
MCPA bioaccumulation.

No other valid data on the toxicity of  ?£PA acid were available for review.
Chronic feeding  studies,  additional reproduction studies, and oncogenicity
testing are required.

                               Topical Discussions

Acute Oral Toxicity

Adequate acute oral toxicity testing  in rats (Raltecn, 19??, 00021972) is
available for technical grade  MCPA acid.  In this study,  MCPA was administered

                                        •35-

-------
in water by means of a  feeding  needle  to 8 male and 3 female Sprague-Dawley
albino'rats.  Tnc estimated  oral  LD^Q  in tne male rat was found to be 1.383^
gAg body wsight v/ith 95%  confidence limits  of 1.124 to 1.71fi g./kg, and in tnp
female rat was determined  to be 0.765  g/kg body weignt with 95% confidence
limits of 0.598 to 1.025 gAg«  Gross  autopsy revealed no significant specific
toxicity.  Data are sufficient  to satisfy Agency requirements.


No data were available  on  any manufacturing-use salt or ester of MCPA.
Testing is required unless registrants provide suitable evidence to
substantiate tnat particular salts and esters will be similar in toxicity to
MCPA acid.

Acute Dermal Toxicity

Mo data were available; testing of MCPA acid is required.  Testing of each
manufacturing-use salt  and ester  of MCPA is  also required unless registrants
provide suitable evidence  to substantiate that particular salts and esters
will be similar in toxicity  to  MCPA acid.

Acute Inhalation Toxicity

Partial data are available for  the sodium salt of MCPA that indicate that this
salt is in Toxicity Category IV.   Testing of all other manufacturing-use salts
and esters of MCPA is also required unless registrants provide suitable
evidence to substantiate that particular salts and esters will be similar in
toxicity to MCPA acid.

Primary Eye Irritation

Available data on a soluble  concentrate formulation containing the sodium salt
of :r""A indicates that  this  formulation is a severe irritant to the eye.  This
testing places MCPA in  Category I for  primary eye irritation.  See the topical
discussion under end-use MCPA for details on this study.  Registrants have the
option of accepting this determination and classification for T1CPA acid and
each of its salts and esters, or  of supplying data specific to technical grade
MCPA acid and each of its  salts and esters.

Primary Dermal Irritation

No data were available; testing of MCPA acid is required.  Testing of each
manufacturing-use salt  and ester  of MCPA is  also required unless registrants
provide suitable evidence  to substantiate that particular salts and esters
will be similar in toxicity  to  MCPA acid.

Dermal Sensitization

No data were available; testing of MCPA acid is required.  Testing of eacn
manufacturing-use salt  and ester  of MCPA is  also required unless registrants
provide suitable evidence  to substantiate that particular salts and esters
will be similar in toxicity  to  MCPA acid.

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Acute Delayed Heurotoxicity
                        /
Although MCPA is not expected  to cause cholinesterase depression, it is
structurally related to  2,4-D  wnicn  is suspected  of causing neuropathy.
lasting of 2,4-D is currently  underway.   The Agency is reserving tnis
requirement for testing of  MCPA  until  the results from 2,4-D testing have been
subnitted and evaluated.

Subcnronic Oral Toxicity

The minimum data requirement for subcnronic oral  toxicity is one test of iiCPA
acid in two mammalian species, preferably the rat and dog.   Testing of eacn
manufacturing-use salt and  ester of  MCPA is also  required unless registrants
provide suitable evidence to substantiate that particular salts and esters
will benave similarly under test conditions.

A subcnronic oral toxicity  test  is required for FCPA because its uses
(application to food crops) require  a  tolerance.

An adequate study was conducted  on Charles River  rats (10 animals/sex/dose) fed
0, 4, 8 and 16 mgAg/day technical MCPA acid for  90 days (Holsing and Kundzin,
1«70, 00004776).

Tne mean body weights, weight  ranges,  food consumption,  and survival data of
the test animals were comparable to  the  control values.   Ito mortality was
noted.

The hematocrit and hemonlobin  dot^r^.ir.ritions, erythrocyte counts, tots! *nd
differential leukocyte counts, fasting blood sugar, BUII, total serum protein,
total serum bilirubin, SGCT, serum alkaline pnosphatase, and scrum
electrophoresis, recorded at 1 and 3 months from  5 rats  of  eacn sex fron tne
control and each test group, revealed  no significant differences from tne
control values.  The serum  albumin,  serum sodium, serum  potassium, serum
chloride, carbon dioxide, serum  calcium, and SOOT determinations, mede at 3
months only from 5 animals  of  each sex frcm the control  and each test group,
revealed no significant differences  between tne test and control values.  The
urine analysis conducted at 1  and 3  months revealed no abnormalities.

Organ weignts of tne heart, liver, spleen, kidneys, testes with epididynis,
thyroid, and adrenals revealed signficiant increases in  the male kidney weight
and organ to-body-weight ratio for tne males at 16 mg/kg/day.  Hale kidney
weignts at the 4.0 and 8.n  mgAg/day levels shoved a moderate increase in
weight.

The microscopic examination of the pituitary, thyroid, heart, liver, spleen,
kidney, adre'nal, stcnacn, pancreas,  small intestine, large  intestine,
mesenteric lymph node, urinary bladder,  testis, ovary, and bone marrow from
five male and five females  fron  the  control and 16 mgAg level, plus the
liver, kidney and unusual lesions from five of eacn sex  of tne remaining test
groups, revealed no histopathological  alterations which  could be considered as
compound-related.  The no-effect level for rats is

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An adequate study was conducted en Beagle dogs  (4  animals/sex/dose)  fed (0,  4,
8 and 16 mgAg/day) technical MCPA for 13 weeks (Holsing  and Kundzin,  1970;
00004757).

The appearance, behavior, and appetite, of  the  test  animals was considered
normal.  The hematology data showed normal  variations.  Ib  compound-related
alterations were evident.  The blood chemistry  data  revealed no significant
alterations.  Within these normal observations  two trends were  noted,  one
being the slight increase in BUM value at 13 weeks for  males and the other an
increase in the bronsulphalein retention at 13  weeks in males.

The 16 ngAg males showed decreased testis  weights and  weight ratios.   Other
organ weights were not remarkable.  Microscopic examination of  tissues
revealed 3 of the 4 high level dogs to exhibit  curtailment  of spermatogenic
activity and varying degrees of tubular atrophy.   Prostatic changes  associated
with the testicular abnormalities were immature or atrophic appearance.  A
similar prostatic alteration was noted in 2 of  4 animals  at the 320  ppn level
and 1 of 4 animals at'the 160 ppm and in 1  control dog.  These  data  show that
the no-effect level for dogs is 4 mgAg.

A supplementary study (Holsing, 1968, 00004756) was  conducted on Beagle
dogs (3 animals/sex/dose) fed technical MCPA for 13  weeks at the following
dose levels:  control, 25 mgAg* 50 mgAg»  100  mgAg*   There was body  weight
loss noted at all dosage levels.

The hematolcgical data for low level  (25 ngAg) revealed  only 1 female with
gradual decrease in the hemogran at 1 month.  The  middle  level  (50 mgAg)
animals also showed lowered nemograms in addition  to marked increase in hand—
cells and slignt increases in metamyelccytes.   All dogs of  the  high  dose (100
mgAg) level showed a decrease in hemograms at  the 1 month  interval.

The biochemical studies snowed a variety of abnormal findings throughout the
test and control animals.  The abnormal findings which  appear compound related
were elevated BUN at all dosage levels, elevated SCOT at  all dosage  levels and
a decrease in the serum postassitrn.  The data resulting from the 13  week dog
feeding study indicate that the no-effect level is less than 25 mgAg.

A supplementary study (Holsing and Kundzin  1968; 00004775)   was conducted on
Charles River rats (10 animals/sex/ dose) fed 0, 25, 50 and 100 mgAg/day
technical MCPA for 90 days Body weight gain inhibition  was  noted for both
sexes at the 100 mgAg level.  Food consumption for  this  level  showed  a
decrease as compared to the control values. The doses  selected were too high
to ascertain the no-effect level.

The clinical laboratory studies conducted on 5  animals  of each  sex from the
control and test groups, at 1 and 3 months  consisting of  hematocrit  and
hemoglobin determinations, erythrocyte counts,  total and  differential
leukocyte counts, fasting blood sugar, BUN, total  serum protein, total serum
bilirubin, SGPT, serum alkaline phosphatase, serum electropnoresis,  plus the
serum albumin, serum sodium, serum potassium, serum  chlorides,  carbon  dioxide,
serum calcium and SCOT revealed no significant  differences  between the test
and control values.

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Urino analysis conducted  at  1 and 3 months and consisting of specific gravity,
pH, glucose, ketones,  total  protein, bilirubin, and microscopic examinationvof
trc sediment stowed no significant compound related differences between the
test and control animals.  Organ weights of tne heart, liver, spleon, kidneys,
thyroid, adrenals, and testis witn epididymis. revealed a significant decrease.
Of tnese findings only the decreased liver weight appears to be conpound-
related.

The microscopic examination  of the pituitary, thyroid, adrenal, heart, spleen,
kidney, liver, stomach, pancreas,  snail  intestines, large intestines,
mesenteric lympn node, urinary bladder,  testes, ovary and bone marrow revealed
dose related cytopathologic  changes in the kidney and liver.  The data
indicate that tne no effect  level in rats is less tnan 25 mg/kg/day.

Available data satisfy Agency requirements for testing of MCPA acid.
                       • s
Otner inadequate subchfonic  oral toxicity tests were conducted in rats and are
briefly discussed below:

In an inadequate subchronic  oral toxicity study (Hattula et al., 1077,
05003795), male Sprague-Dawley rats (10  or 20/dose) were given analytical
grade MCPA acid in drinking  water at concentrations of 100, 500, 1,000, 2,nno
and 3,000 mg/liter for 9 weeks.   The deficiencies in this study included
observations on less tnan 10 rats per dosage, use- of only one sex, incomplete
pathological data, lack of clinical observations, and inadequate reporting of
group findings.  These deficiencies preclude tne uso of this study.

In another inadequate  oral study,  the toxic effects of analytical grade I-'CPA
on spematogencsis in  young  rats were investigate (Elo and Parvinen, 197 G,
C50C41G1).  Tne use of less  than 10 rats per dose, the short duration of
the study, and discrepancies in recording some of the data preclude the uso of
this study.

Subchronic Inhalation  Toxicity

The minimum data requirement for subchronic inhalation toxicity is one test on
technical MCPA acid and each salt and ester, preferably using the laboratory
rat.  Testing of each  salt and ester is  required unless registrants submit
evidence substantiating that the particular salt or ester will be similar in
toxicity to MCPA acid.

A subcnronic inhalation toxicity test is required if pesticidal use will
result in repeated inhalation exposure at a concentration which is likely to
bo toxic as determined from  tne results  of tne acute inhalation testing and
other testing.  This test could be required pending the results of the acuto
innalation toxicity tests of the technical chemicals.  The acute inhalation
testing with the acid  and sodium salt 2  Ib/gallon soluble concentrate/liquid
places that in Toxicity Category IV indicating very mild toxic effects.

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Subcnronic Ileurotoxicity
                                                                             V
The minimum data requirement  for  sutxnronic neurotoxicity testing is one test
on technical MCPA acid, using a marmalian  species.

A subchronic neurotoxicity  test may be  required if  the pesticide snows
positive results in the acute delayed neurotoxicity test or induced
irreversible neurological toxicity  in a mammalian species.  Testing of each
salt and ester of !CPA may  also be  required.

A subcnronic neurotoxicity  test may be  required if  the neurotoxicity test is
positive for 2,4-D (and !CPA, if  tested).

Chronic Feeding

The minimum data requirement  for  chronic feeding is one test on technical MCPA
acid, preferably using the  laboratory rat.  Testing of each salt and ester of
MCPA is also required'unless  registrants provide evidence substantiating that
a particular salt or ester  will be  toxicologically  equivalent to TCPA acid.

A chronic feeding study is  required if  pesticidal use requires a tolerance or
an exemption frcn a tolerance, requires the issuance of a food additive
regulation, or is likely to result  in repeated human exposure over a
significant portion of the  life span.

A cnronic test is required  for 'JCPA because its uses (application to food
crops) require a tolerance. »•

No data were available to assess  tne cnronic feeding of MCPA.  Testing' in a
mammalian species is  required, and  since the dog is the more sensitive
species, a 1-year dog study is necessary with nistopatnology of the gonads.

Oncogenicity                ;-

The minimum data requirement  for  oncogenicity is testing in two mammalian
species, preferably the rat and mouse,  using technical MCPA acid.  Testing of
each salt and ester is also required unless registrants provide evidence
substantiating that a particular  salt or ester will be toxicologically
equivalent to MCPA acid.

An oncogenicity test  is required  if the active ingredient, or any of its
metabolites, degradation products,  or  impurities is structurally related to a
recognized carcinogen or causes a mutagenic effect; requires a tolerance or an
exemption frm a tolerance; requires the issuance of a food additive
regulation; or is likely to^result  in  repeated human exposure over a
significant portion of the  life span.

Oncogenicity testing  is required  for MCPA because its uses (application to
food crops) require a tolerance.

Ilo data wore available to assess  tne oncogenicity of MCPA acid or its salts or
esters.  Testing in two mammalian series  is required.

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To ITS tcocn ic i ty

The minimum data  requirement  for teratogenicity is testing in two mammalian
species, using  technical  i-CPA acid.   Testing of each salt and ester of MCPA is
also required unless  registrants subnit evidence substantiating that a
particular salt or  ester  will be toxicologically equivalent to MZPA acid.

Teratogenicity  testing  is required if pesticidal use requires a tolerance or
an exemption fron tolerance,  requires the issuance of a food additive
regulation, or  is likely  to result in significant exposure to females.

Teratogenicity  testing  is required for MCPA because certain uses (application
to food crops)  require  a  tolerance.

A supplementary study has been submitted in two parts on tne teratology of
technical grade MCPA  in the rabbit (Tucker, M. L., 1978; 000041635) and
Irvine, L. F. H., 1980;^ 000041637).   The Tucker study is a range finding
attempt which used  an extended duration of treatment frcn day 1 to day 27
gestation.  This  study  on two dose levels (100 mgAg and 25 mg/kg) resulted in
no live foetuses  at the nigh  dose and no teratology at the lower dose.  In
tnis experiment there was maternal death and toxicity from lung congestion due
to improper gavage  techniques in the control group as well as at both levels
of MCPA.

Based on tnis range-finding study, Irvine dosed rabbits (15/or) at 5, 12, 30
and 75 mg/kg technical  !-CPA by gavage.  This protocol was appropriate to core
minimal guidelines  with dosing -from day 6-to -day-IB..- -Thf3j-«?_uas-aasia-3:itn.cnal
lung congestion from  inappropriate gavage dosing techniques which appeared to
be dose related to  >CPA.   The dans affected had otner thoracid pathology sucn
as fibrous adhesions  to the thorax.   The litters affected by tciratogenicity
were not correlated with  tne  maternal pulmonary affects.  The protocol
indicated that eacn group would be randomly selected to have similar mean
weight and weight distribution which was not done.  The animal room
temperature was to  be 17°C; 'however, tnere were sharp changes in temperature
wnicn elicited sufficient animal stress (to induce changes in weignt in
maternal animals) at  time of  mating.  This stress was sufficient to correlate
with teratogenicity in  the litters.   Thus the maternal loss is not dose
related nor was the number of corporal lutea, number of implantations, total
of early plus late  fetal  deaths as the percentage of implantations and the
litter weight.  These parameters can, however, be stress-related.

In an adequate  teratogenicity test,  the cormercial formulation llorotcx 750
containing 75* w/w  MCPA (2-methyl-4-cnloropnenoxyacetic acid) 75% purity, was
given daily by gastric  intubation to pregnant mice, 20 per group, frcn day 6
to 15 of gestation  at daily doses of 5, 25, and 100 ng/kg (Palmer and Lovell,
197-1, OC04447).   Litter weights and mean fetal weights were significantly
reduced at 100 mg/kg.  The incidence of minor skeletal variants was
significantly greater at  100  mgAg tnan in the controls,  llo overt signs of
maternal toxicity except  decreased weight gain at 100 mgAg compared to tr»e
control group.  The no-effect level, based on the incidence of minor skeletal
defects and fetal weignts, was 25 ngAg.

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In an adequate teratogenicity  test,  the  technical  grade  fCPEE (4-cnloro-2-
metnylphenoxyacetic  acid etnylester),  94.12% purity,  was mixed with food at'
levels of 2, 30, 60  and 100 ngAg  and  given  to pregnant  rats, 10 to 16 per
group, from day R to day 15 gestation  (Yasurla and  Msecte, 1972; 05003566).
Daily intake of MCPEE, based on  food consumption,  was calculated to he 2.7,
30, 60, and 100 mgAg.

The no-effect level  for the fetuses  was  30 mgAg.   At 60 and 100 mgAg» tne
malformation rate was significantly  increased and  fetal  weights were
significantly decreased.  Cleft  palate,  ventricular septal defect, and kidney
anomalies were the major malformations.   There was no maternal toxicity except
a dose related lower rate of weight  gain in  comparison to the controls group.
The major malformations were not significantly different fron controls.

Another adequate study completed in  Sprague-Dawley rats  (Irvine,
L.F.H.,1980;000041637) using MCPA  tecnnical  grade  20, 50, and 125 ngAg
resulted in minimal  maternal toxicity  at all doses, no effect on pregnancy
incidence, no difference in maternal weight  gain and  no  difference fron
controls for tne mean number of  corpora  lutea, preimplantation losses and
implantations.  There was also no  significant MCPA associated early or total
intrauterine deaths, and no change in  number of fetuses  per dam.  The litter
weights in all MCPA  treated groups were  significantly different from control
while the sex ratios for all MCPA  groups were comparable to controls.


Minor external/visceral defects  of fetuses were present  in all MCPA-treated
groups but the incidence of these  wero not significantly different from
controls.  These include skeletal  and  muscular anomalies, dilated ureters,
increased renal pelvic cavitation  and  subcutaneous haemormagic areas and
skeletal defects.

There were no major  skeletal defects in  any  of the flCPA-treated groups or the
negative control group.

The major visceral defects included  encephalocele, craniorachischisis with
anopntnalmia, open eye, onphaloc,  arthrogryposia,  and disphragmatic hernia;
but these did not occur in significant numbers.

In conclusion, the Yasuda study  differs  fron the  Irvine  study in the extent of
teratology occurring with MCPA in  the  rat but in  neither study was it
considered to be significant.  The one mouse study by Palmer and Lovell (1971)
indicates that MCPA  is not a significant teratogen.

The minimum data requirement for testing in  two mammalian six-cies using MCPA
acid has beeh satisfied by Yasuda  and  Maeda  (1972) in the rat and by Palmer
and Lovell (1971) in the mouse.

Reproduction •

The minimum data requirement for reproduction is  testing In one mammalian
species, preferably  the laboratory rat,  using JCPA acid, and lasting for two

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generations.  Testing of eacn salt and ester  of  MCPA is also required unless
registrants proviJe evidence substantiating tnat a particular salt or ester
will IDG toxicologically equivalent to MCPA acid.

Reproduction testing is required  if nesticirlal use requires a tolerance or an
exception fion a tolerance, requires the  issuance of n  food additive
regulation, or is likely to result in repeated human exposure over a
significant portion of the lifespan.

In an inadequate study of the toxic effects on spermatogenesis,  analytical
grade MCPA was given to young nale Sprague-Dawley rats  in tne drinking water
at concentrations of 100, 500,  1,000, 2,000 and  3,000 ppn (Elo and Parvinen,
1976, 050041E1).  Rats receiving  100 ppm  (3 ragAg/day)  nad slignt degeneration
of tne seminiferous tubules; those receiving  500 ppn (61 mgAg/day) and 1,000
ppm  (112 mgAg/3ay) had mild degeneration with loss of  spermatids; and the
rats receiving 2,000 ppn (190 mgAg/day)  and  3,000 ppn  (246 mgAg/day) had
moderate degeneration with occasional loss of sperraatids and spernatccytes.
The effect was erratic and some rats receiving 3,000 ppn had almost normal
spematogenesis.  The study does  not indicate what possible effects,  if any,
MCPA could have on fertility, births, or  survival.  The use of less than 10
rats per dose, the short duration discrepancies  in recording of  seme data, and
failure to use females precludes  the use  of this study.

The above data is not sufficient  to satisfy the  requirement for  reproduction
testing of MCPA acid.  It should  be emphasized that subchronic oral testing
revealed reduced spermatogenesis  and tubular  atrophy in testcs in both rsts
and dogs.

Testing is required.

Mutagenicity

The minimal data requirements for mutagenicity testing  v/ill be finalized
pending formulation of Agency Guidelines.

Mutagenicity testing is required  for MCPA because certnin uses (application to
food crops) require a tolerance.

One study was done to evaluate  the ability of f£PA to induce histidine
reversion in Salmonella typninurium  (Zetterbcrcj, 1979,  C5004970).  Although the
study was not sufficient to satisfy the data  requirement because of incomplete
protocols (i.e., use of an incomplete set of  tester strains, use  of a single S-
9 concentration for microscnal  activation, and lack of  confirmatory testing),
the data suggest tnat MCPA, and 5-cnlorosalicylic acid  (hydroxnethyl derivative
of ICPA), 3-chloro-o-crcsol, 4-cnloro-cresol, and 5- chloro-3-methyl-catecnol
were not rnutagenic under tne conditions of tne test system.

An adequate study was done to evaluate fCPA  in tne above mentioned system by
Lassner et ad., (1977, 05003531)  \;no reports  negative results using 99% pure
MCPA on a set of four AMES tester strains of  SeIrenelie typnimurium wnicn wore
pretested for genetic marks in  addition to testing one  of these strains
against four concentrations of  S-9.

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Adequate studies  to evaluate  the  toxic and mutagenic (histidine reversion)
effects of '1CPA and its methyl  ester in tne Saccharonyces corevisiac? haploid
strain rad-18 were done by Zetterberg (1979,  05004970) MCPA was observed to
induce nutations, but only at amounts (3-6x10 -5 M of undissorriated 2cid) that
caused 95 to 99%  lethality.   The  results were highly variable and were affected
by changes in temperature  and pH.  The data suggest  that MCPA is a weak
nutagen in this study system.  Also, a relationship was reported between pH,
temperature, and  number of reversions.  The degree of acidity of tne p!I and
elevation of the  temperature  drive  the activity of MCPA to induce reversion of
tne histidiene (i.e., mutagenicity).

Zetterberg states that tne increase in hydrogen ions inside the cells to an
overwhelming amount causes this mutagenicity.  Zetterberg theorized that
mutagenicity (histidiene reversion)  in rad-18 cells only occurs in the
presence of overwhelming increased  hydrogen ion overproduction fron the MCPA
being in an acid  medium.   This  should be considered if other in vitro
mutagenicity tests are performed.  MCPA methyl ester was about 100-fold less
active tnan MCPA. Zetterberg  failed to disclose the purity of the test material
he used.

An inadequate study was done  to determine tne percentage of X-cnronosomal
recessive lethals in meiotic  and  postmeiotic male germ cells of Drosophila
that were fed MCPA (unspecified portion) at concentrations of 5 and 10 mil
(Vogel and Chandler, 1974, 05003752).  An increase in the percentage of
sex-linked of recessive lethals over that of controls was observed, but tne
difference was barely significant (p = 0.015) at pH = 8.  The results suggest
tr.at MCPA is a weak nutagen in  Drosoprsila, but tnis conclusion is derived from
combined data at  "doses" of 5 and 10 mfl.  There was no dose response data in
addition to other inadequacies.  IJone of tne other chemically-related
herbicides tested (i.e., 2,4-D, 2,4,5-T; fCPB) caused any significant
increases in lethals.  MCPA was not tested at acidic ptt's (5.8 or below).

An adequate study by Magnusson  et al., (1977, 05016939) in which Drosophila
were continuously fed MCPA (94% pure) throughout their larval stages at "doses"
of 250 and 500 ppm, reported  no increased sex-chromosome non-disjunction, loss
or exchange, but  in contrast  indicate an increase in number of recessive
lethals for both  2,4-D and 2,4,5-T when coapared to their own controls at a
significance level  (P  ,0.01)  when the total F^ and ?2 data wcre combined.

In a review Propping et al.,  (1973;  05009237) mentioned negative results
reported by Buselmaier et  al.,  1972, 0501655 who tested MCPA in tne host
mediated assay in mice given  1000 mgAg subcutaneously against the Salmonella
typnimurium G-46  his- and  Serratia marcescens A-21 leu; these studies further
support the notion that these "hormonal" herbicides present minor hazard in
systems involving namalian metabolism at pH's of 7.2 to 7.4.

MCPA has been reported to  cause inhibition of testicular DMA synthesis
following intraperitoneal  injection of tne chemical to male mice at a dose of
200 mg/kg (Seiler, 1979; 05003508).   The study is inadequate because of
failure to report the purity  of tne MCPA sample used.

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Tne above infomation  is  not  sufficient  to satisfy the criterion of multi-test
evidence required  for  mutagenicity.   Only insufficient dat? nas been presented
in these minimal studies  and  additional  testing is required especially in
          species  as recorranenotrd  above.
Metabolism

Tne minimum data requirement  for metabolism is a single dose using tne
analytical pure grade of the  active  ingredient in the radioactively labeled
form.

A metabolism study  is required  for MCPA because certain of its uses
(widespread application as an herbicide on  food crops)  requires a chronic
feeding study and oncogenicity  testing.

Unlabeled ICPA, stated to be  pure, was  administered for a single day in the
diet of a steer (5  ppm) and in  the diet of  two cows (2.5 snf 5 ppn).  Ttie
unchanged MCPA could be detected, but was not adequately quantified, in the
urine of these animals (Bacne et_ a_l. ,  1964,  05006168).

Unlabeled t-CPA was  administered for  28  days  in the diet for beef calves so
that the amount consumed was  7  or 14 mgAg/day.  One day after removal from
either diet, levels of MCPA were 1.4 to 23.3 ppm in kidney tissues, 0.06 to
0.09 ppm in liver tissue, and ,0.05 ppm in muscle and fat.  Calves removed from
the high-dose diet  for 6 days had 0.07  to 0.34 ppm in the kidney and 0.05
ppm,muscle, liver and fat. A  possible metabolite, 2-Metnyl-4-cnloropnenol , was
found occasionally  in kidney  tissue  in  trace amounts (0.05 ppm) (Bjerke and
Herman, 1971a, 00004625).

Unlabeled MCPA (98.2% pure) was administered for 23 d?ys in the diet to
yearling sheep so that tne amount consumed was 15 ngAg/d^y.  One day after
remo^l from the diet, levels of MCPA were  0.31 to 1.7 ppm in kidney tissue,
0.05 .0 0.12 ppm in liver tissue, and  0.05  in fat and muscle.  2-Methyl-4-
chloropnenol was found in trace amounts (0.05 ppm) in kidney tissue (Bjerke
and Herman, 1971b,  00004626).
1/1
  "C-acetic acid-MCPA, of unstated purity, was administered by gastric
injection to Sprague-E&wley rats in a dose of 3 mg.  In 24 hours, 92.3% of the
radioactivity was excreted in the urine and  6.8% in the feces.  Between 2 and
.°. hours after injection, the  highest concentrations of radioactivity were
present in the blood, kidney, lung,  heart,  suprarenal gland, liver, thyroid,
and bone marrow.  Radioactivity disappeared  from adipose tissue more slowly
than from other tissues  (Elo, 1976;  050003256).

In an adequate study  (Gilbert and Hopkins,  1978, 000041634) rats rapidly
absorbed and- excreted  (C  O-MCPA.   Urinary excretion represented tne major
route of elimination accounting for  94.9 and 36.1 percent of the administered
radioactivity in male and female animals, respectively, in 192 hours.  Fecal
elimination of radioactivity  accounted  for  only 6% of the administered
radioactivity in animals of eitner sex  during tne same period.  1*»e majority of
tne eliminated radioactivity  (78.19%) was excreted by animals of eitner sex
during the first 48 hours.

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3.7% of tnc administered radioactivity was detected  in the 24 hour bile from 3
bil« duct cannulated rats administered 100 rag/kg.  P.O. (C  )-MCPA, the
levels in the urine and feces of  these aninals  (20.3 and 10.5% of the
administered dose).  Tissue concentrations of radioactivity in tne 3 male bile-
cannulated rats were markedly higher  than the levels of tissue radioactivity
in^the non-cannulated animals 24  hours after a  single oral administration of
(i'¥C)-MCPA.

Altnougn the author attributes  these  differences  to  relatively poor recoveries
of the radioactivity in the bile-cannulated  rats  (34.5%) and or relatively
poor medical conditions of the  bile-cannulated  rats, no evidence is presented
to support this hypothesis.

Three other fractions having R^ values of 0,0.8 and  0.15, (each accounting
for less tnan 5% of tne sample  radioactivity) were not identified in the
study.  The distribution of chronatographed  radioactivity was not altered by
incubating tne urine samples with Beta-glucuronidasc compared with tne levels
detected in the 0-24 hours without  incubation.

The tissue radioactivity levels in  rats  receiving  multiple administrations of
the herbicide (mgAl3/d» P.O. x!4  d) show that bioacummulations did not occur.
Female rats receiving the multiple  administration  of the herbicide had
sligntly higher tissue radioactivity  levels  than did the male animals.

The results of tne latter experiments indicated the  absorptions,
distributions, and eliminations of  tne radioactivity were not affected by
repeated adminstrations of the  herbicide.

Thin layer chromatography of urine  sample indicated  the presence of 5
radioactive fractions.  The major fractions  (accounting for 7.89% of the
sample radioactivity) behave in a chranatograpnically similar manner to MCPA
(Rf=0.412).  A second fractions (Rj=0.40), accounting for 13.8% of tne
sample radioactivity was not identified  in the  study.

Tissue levels of radioactivity  followed  a similar  time course as the plasma
radioactivity levels.  Tissue radioactivity  was seen 3 hours after the
administration of 100 mg/kg/day,  P.O.   C=MCPA).   The level of radioactivity
in most tissue (the fat, skin,  and  ovaries are  exceptions) were very low 192
hours after dosing.

                                                                        14
Body autography of male and female  animals,  6,  24, and 48 hours after (  C)-
ttPA administration, yielded results  that were  similar.

The major route of excretion is urinary  elimination  (94.9% male and R6.1%
female) in the rat in 192 hours and much smaller  percentages by the bile and
feees.

The lack of an indication of tissue bicaccumulation  of tne labelled MCPA or
metabolites is preliminary evidence that toxic  events presumably would not
occur within the first few days of  exposure; therefore further testing is not
required.

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Hunan Exposure

Three cases reports of  hunsn poisoning  by riCPA were available (Popr.an and
Davies, 1964, 05003770; Johnson  and Koumides,  .1965, 05004100; Jones et al.,
1967, 005008955).  A  32-year old nan died as  ,  result of drinking water which
contained about 85 nl of  the herbicide  "Verdone" comprised of 25% MCPA.  The
letnal dose was approximately  440 mg/kg of MCPA (Popham and Davies, 1964).
Deatn occurred 20 hours after  admission for treatment.  The blood level of
MCPA was 23 mg/100 ml.  In the second fatal case, (Johnson and Koumides,
1965), 65-year old man died after drinking an  unverified 57 nl of "VercJone."
The letnal dose of MCPA was estimated to  be 250 ng/kg-  Deatn occured 20.5
hours after tne patient was found unconscious.   The blood level of MCPA was 13
mg/100 ml.  Stonacn washings contained  250 mg/100 ml of MCPA.  The third
patient survived oosumption of tne herbicide  "Phenoxyler.e Triple," which
contained 33% tCPA, 3.5%  cresols, and other impurities.

Clinical signs of toxicity were  similar in the  three reports and included loss
of consciousness, constricted  pupils, involuntary skeletal muscle twitching,
low blood pressure, excessive  oral secretions  and deep sighing respiration
with coarse rales.  Clinical laboratory tests  in Jones .et al. (1967)
suggested that kidney damage,  liver damage and  gastrointestinal bleeding
occurred after MCPA ingestion.

MCPA End-Use Products

  1.  Soluble Concentrates

Acute toxicity testing of each end-use  product  or substantially similnr
product is required for the registration  of these products.  A determination
of substantial similarity takes  into consideration both the form of the active
ingredient found in a particular product  as well as the types and nature of
inert ingredients.  For purposes of acute toxicity testing or end-use soluble
concentrate products, acute tests are required  on representative products
containing each different type of salt  and ester.  Alternatively, registrants
nay submit evidence substantiating that the toxcity of their end-use product
will be equivalent to MCPA acid.

                               Toxicology Profile

Soluble Concentrates Containing  the Sodium Salt

Sufficient data were  available to show  tnat the 2 Ib/gal SC/L MCPA sodium salt
had a relatively high acute oral LDcn in  mice  (560 ngAg) (Cure!, 1964,
00022569) Cat. Ill; a high acute dermal LD™  in rabbits (2.0 mgAg)
(Raltech, 19??, 00021973) Cat. IV; and  a  very high acute inhalation LC50 in
rats (21.4 mg/liter)  (Biesemiar  and Angevine',  1977, 00021975) Cat. IV.


Sufficient data were  available to show  tnat tne 2 Ib/gal SC/L MCPA sodium salt
is a severe eye irritant  (Raltech 1977, 00021974) Cat. I and is a mild skin
irritant (Raltc-cn, 1977,  00021976) Cat. IV.

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Soluble Concentrates Containing  Dime tny lamina Salt


No valid data v.'pre svai.l^hl^  to  gs?r>sc
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Bnulsifiaole Concentrates Containing Mixture of Dutyl and  Isopropyl Esters

No data vjere available  to assess t^e acute oral, ncut*? riomal,  acute
inhalation, prinisry  eye or^ priiuary denral irritation toxicity.   Testing is
required or suitable rationale Trust be subrdtted to substantiate that tne
toxicity of tnis mixture will be similar to MPCA acid.

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                                  CHAPTER VII

                           .RESIDUE  CHeilSTRY OF NCPA

rCPA is a selective post-emergence  herbicide used  for the control of
broad-leafed weeds in small gain  crops,  especially wheat and rice.  A wide
diversity of sites comprises the  remaining uses and includes both croplands
and non-crop areas.

MCPA is registered for use in  the form of its  sodium, diethanolamine, and
dimethylamine salts, its  iscoctyl and  butoxyetnyl  esters, and in a mixture of
its butyl and isopropyl ester.  Table  5-2 lists the individual sites registered
for MCPA use.

MCPA is not registered for use  in the  form of  its  ethanolamine, triethanola-
mine, isopropanolamine, diisopropanolamine and triisopropanolamine salts,
although these forms are  sanctioned in 40 CFR  180.339 (a).

The uses of MCPA on crops are  food  uses,  and are expected to result in residues
in human food and in feed of food-producing animals.

The uses on ornamentals,  rights-of-way;  agricultural, ccmercial and industrial
premises; and aquatic, forest,  chaparral, nonagricultural and wasteland sites
nave generally been regarded as non-food (N.F.) uses; but sane of these are
now viewed as food (or feed) uses with a potential for contaminating food.

                           Residue  Chemistry Profile
MCPA is readily absorbed  and  translocated  by plants,  both through the roots
and leaves.  It is concentrated  primarily  in the metabolically active portions
of the plant.  MCPA  is extensively metabolized in plants to 2-methyl-4-cnloro-
phenol and subsequently to  breakdown  products.  It is likely that 2-raethyl-4-
chloropnenol and MCPA are readily conjugated with glucose and amino acids.

Available evidence indicates  that in  animals MCPA binds readily to the albunin
fraction of animal serum  protein and  is transported to the kidneys for the
renal excretion.  MCPA does not  appear  to  accumulate  in muscle or fat tissue
nor in the liver or  in milk.

The first determinations  of MCPA were made using spectrophotometric methods.
Currently, most assays use  sore  form  of gas chrcmatography.

                        Data  Requirements  and Data Gaps

The proposed Guidelines for residue chemistry have not been published.
Consequently there are no citations for guidelines corresponding to the types
of-residue chemistry data required to support individual registrations.  In
general, nowever, the Agency  must have  sufficient data to be assured that the
residues of the parent material  and its metabolites have been identified.

Available residue studies on  small grains  are weak in two respects.  They are
sparse, and  it is not always possible  to  relate the  residues to an adequately

                                         •20

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        d and validated  method.   It is not always clear whether or not  total
rc-sri'/iu'js are  in  f^ct  being determined.  Additional cUita en grains are
required, with a  revaluation of the tolerance when these are received.   In
  e meantime, n&nitoring of trie  grains is roconnnended.
For tnc riitcn  ban);  use  of MCPA,  tolerances or labeling restrictions are needed,
to be consistent with   the policy established for 2,4-D.

                               Topical Discussions

Uptake, Distribution, and Metabolism in Plants

wnen applied in water,  it is believed tnat MCPA is liberated from its salts or
esters, by dissociation or hydrolysis, in the spray, on the plant surface or
even within" the plant.   The rates of dissociation and of hydrolysis are
believed to be rapid, although there seems to have been no direct evidence for
this for tne MCPA esters.  There is a question as to v.-hether or not the MCPA
esters do in fact hydrblyze as rapidly as believer].  The residue nay consist
of some intact ester.   Here the  Agency asks the registrant to resolve this
question by developing  a rationale, with references to data or analogous
pnenoxyalkanoic acids  (2,4-D for example).  Tne residual inorganic sodium
salt, amine or alcohol  fron these processes nay linger for a time on the plant
before dissipating.  More importance has been given to the fate of IICPA, which
like the other structurally-related pnenoxy herbicides, is readily absorbed
and translocated by bie plant (Robertson fit a_l_. , l'X>7, H5C15046).

MCPA is readily absorbed via tne roots.  When hydroponically grown Acrostenna
gitnago plants were exposed to carhoxv-labelerl MCPA, the radioactivitv was
readily absorbed by the roots and translocated to the upper portions of the
plant (Sanad,  1971,  05015695).

A study conducted in Dickursby,  Finland, shows that residues of MCPA in soil
will be absorbed by seme species and not by others.  For example, Marrow stem
kale was found to contain MCPA at levels up to 0.7 ppn at 37 and 100 days
after applications  of 1.5 kg/ha  and 7.5 kg/ha at planting time.  Under these
seine conditions, no residues (>0.no9 ppm) could be detected in barley and
clover (Lallukka, 1974, 05021559).

In some species, MCPA accumulates in seeds of treated plants in sufficient
quantities to  disturb tne growth of subsequently produced seedlings (£berg et
£l., 1978, 05019071).

Badiotracer studies snowed that  MCPA readily penetrates tne plant cuticle.  As
the age of the leaf increased, the amount of F-'CPA bound in the cuticle wax
increased (Kirkwood et  ai . , 1972, 05004272).  Addition of a surfactant
increased tnd  movement  of the MCPA into a plant cell.  When young bean leaves,
Vicia faba were treated, the MCPA was readily translocated throughout the
plant but primarily to  the shoot apex and other rapidly growing portions of
the plant (Xirkwood et  al., 19f>9, 05015041; Mueller, 1976, C5021735).

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                                                   14
When leaves of Sonchus arvensis were  treated  with  C-labeled MCPA, the
direction and extent of translocation of  radioactivity varied with plant age
and stage of development.  When plants were very snail (largest 3 cm),
translocation was primarily directed  to other leaves  of the developing
rosette.  When leaves of a large rosotto  were treated, (loaves 5 to 15 cm)
translocation was directed primarily  to the.roots.  There was greater
accumulation in secondary than in primary roots.  After the shoot started to
develop, (15 to 20 cm tall) radioactivity from   C-labeled MCPA applied to
rosette leaves moved both acropetally and basipetally, with the major portion
moving to tne roots.  At this stage,  movement was similar whether a rosette
leaf or a leaf.near the inflorescence was treated.  It is reasonable to
conclude that   C-labeled MCPA tends  to be translocated in the direction of
the metabolic sink at the time of application (Fykse, 1975, 050144%).

Some data on tne metabolism of MCPA are available.  Most of the studies
presented employ   C-MCPA where the radioactivity is  in the carbonyl carbon.
As a result, little information is  available  on  the breakdown of the phenoxy
ring.                ";

In one metabolism study (Montgomery,  1970, 00005575)  14C-MCPA, as the
triethanolamine salt, was applied to  the  foliage  of wheat plants.  Thirteen
days later tne plants were harvested. The plants were extracted witn 80%
ethanol and the extracts subjected  to thin-layer chromatograpny.  Most of the
Kf band   C was in a very low R^ band, indicating that the ccmponents
or tne residue containing "C were  conjugated with plant constituents.  A
portion of the alcohol extract was  evaporated to dryness and hydrolyzcd with
1 M hydrochloric acid on a s^team bath for one hour.   After acidification, the
hydrolysate was extracted with ether  and-again subjected—to-tftin=layer-
chromatography.  Two radioactive  components were found in tne hydrolysed -  	
chronatograpny.  Two radioactive  ccmponents were found in the hyrolyzed
extracts.  One was MCPA while  tne other was of lower Rj, suggesting tne
presence of a more polar ccnpound.

Analysis of field samples  treated at the boot stage, for the MCPA metabolite,
assuming it to be an hydroxy-MCPA compound, indicates that seme of it may
persist in the plant up to the time of  harvest.  However, as with MCPA, no
detectable amount of the metabolite was translocated to the grain.  GLC-Mass
spectrograpnic analysis indicates that  the metabolite of flCPA in wheat is a
conjugated hydroxy-MCPA which  undergoes seme rearrangement upon hydrolysis
from plant constituents.

MCPA is degraded in plants by  oxidative degradation of the acetic acid side
chain witn the production  of a phenol metabolite (Aberg, 1978, 05019071).
The acid chain may be  removed  at  the ether linkage, resulting in
2-methy1-4-cnlorophenol.

This occurs in red currants and is similar to metabolism of other pnenoxy
compounds.  The methyl  group at the two position is replaced in an -CH
substitution to fora 2-chlorocatecnol with subsequent ring cleavage of the
latter compound.  MCPA can also be expected to be conjugated with glucose or
anino acids which could be a detoxification nechanism (Loos, 1979, 05016100;
Fykse, 1976, 05013377;  Leafe,  1962, 05005795; Collins et al., 1971,

                                        73.

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L'5003725).  The metabolism of the pnenoxy herbicides in plants  has  been
extensively studioc  ever tne years.  Ilov;ever, data clocumenting  the  metabolism
of ''CPA  in flax,  pe-js,  rice, pasture grasses, and clover were not submitted."

flCPA is  readily ttsk^p. iio ?r.d tr?r.r located throughout the plant, concentrating
primarily in the  met-aboiically active portions of the plant.  MCPA  is  exten-
sively metabolized  in plants to 2-metnyl-4-chlorcphenol and subsequently to
breakcb\;n products.   It is likely that the 2-metnyl-4-chlorophenol  and MCPA
are readily conjugated with glucose and amino acids.  Available data satisfy
Agency requirements  for plant metabolism data.

i-'etr.bolism in  Food-Producing Animals

When use of a  pesticide on agricultural crops may result in residues in animal
feeds, the Agency requires data on the fate of the pesticide in food animals.
Data on  metabolism of MCPA in food animals consists of four feeding trials.

In 1%4, a one-cow feeding trial was conducted, in which a Jersey cow  was fed  a
complete ration containing 50 ppm MCPA for 4 days.  ?3o f^CPA residues were
detected in the milk of this cow.  Since this was a study done  using early
analytical methods,  the phenolic metabolite or tne presence of  conjugated
residues was not  determined (Bacne, et al., 1%4,
When beef cattle,  sheep,  and dairy cattle were fed !CPA at increasing  levels
ranging frorn 10 to 20no pin in the total diet for two woc-k intervals  (Lcnq,  ejt
el., 1979, COOH4&22),  significant residues of MC?.'. «0.^r nrO or  its
phenolic metabolite «0.05 ppn) v;ere not detected in r.usclc, fst,  liver,  or
nil!'. SiJTv^l^r \jntil a ~ciicto>*v lev^l of—?H(vT>Tm~'?rT''—•~m^>e>^-i—(^Mr^t^a-aij^tMe—
ingcstion of 1000  ppm  MCPA in the total diet of dairy rows is required to cause
tne consistent appearance of residues in excess of C.05 ppm MCPA or tne
pnenolic metabolite in milk or cream.  The data also show that in  general
residues of the pnenoxy herbicides and their phenolic metabolites  do not  occur
in conjugated form in  milk../ The residues dissipate within one to  three days
after withdrawal of the cows from a diet containing 1000 ppn of  the pnenoxy
acids.  Residues of phenolic metabolite are not greater than residues  of  the
parent compounds in each  tissue.  Residues of <0.05 ppm 2-methyl-4-chlorophenol
were found only in kidney of one calf and three sheep given 500  ppm MCPA  in  the
total diet for 2R  days and slaughtered the next day.  To detectable residues
were found in any  other tissues of cattle and sheep fed 250 or 500 ppm MCPA  for
28 days and slaughtered the next day or a 7 days after withdravral.


JCPA readily binds to  the albumin fraction of animal serum protein and is
readily transported to the kidneys for renal excretion (Matlib j5t  al., 1971,
05015451).  \vnen MCPB  and MCPA are fed to dairy animals at low levels  (5  ppm),
the MCPB is partially  converted to MCPA and that MCPA is quantitatively
recovered in the urine (Bacne, et al., 19G4, 00004702).  In Holencova  "(1973,
05017929), seme European  workers found that the formulation and  materials in
tne formulation affected  tne metabolism of MCPA in guinea pigs.

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Analytical Methods

Because residue data were generated ever a  period of many years, different •
methods were used to determine residues.  The earliest determinations were
mad*? using spectrophotoraetric methods which may or nay not have detected MCPA
present in conjugated  form.   (The  latter would  not have been detected unless
the method included a  hydrolytic step to liberate the MCPA from its
conjugate).Analyses have since been nade by methods  utilizing seme form of gas
chromatography.  In these methods, steps were taken  to liberate the MCPA and
to include it in the analysis.

Residue data were generated with one or  more of the  following methods:

"Procedures for determining residues of  MCPA  (2 methyl-4-chlorophenoxy-acetic
acid) in treated crop" by Conkin  (Monsanto  Chemical  Company, 000005552) in
1956.

"Analysis of 2,4-D residues in milk and  forage" by Yip and Ney, (1966, GS-0017-
109).  (It was adapted to the determination of  MCPA  and modified with an
alkaline hydrolysis step).

Tne procedure described by St. John in "Plant Growth Regulators and Food
Additives", Vol. V., G. Zweig, editor, (Academic Press, New York) 1967;
000004724.  (A version of this method later appeared as Rhodia Analytical
Method No. 104 and modified as Rhodia Analytical Method No. 122, described by
Guar-Jigli.  (00004766  and 00021920).)

The procedure of St. John has been validated and found to givo good recoveries
of the MCPA and 2-methyl-4-chloropnenol  on  grass crops.  Fresh crop material
is extracted with an acidified solution  of  acetone.   An aliquot is taken for
analysis and the organic interfering medium is  partitioned into diethyl ether
from a dilute solution of strong base.   Then the aqueous solution is acidi-
fied, the MCPA is removed with diethyl ether, the solvent is evaporated, and
the residue is nitrated in a hot phosphoric acid solution.  The methyl ester
is formed by subjecting the reside to BF^ methanol solution and partitioning
the ester into hexane  for subsequent injection  into  a gas partitioning the
ester into hexane for  subsequent injection  into a gas chrcmatographic column.
This method has been validated for barley straw and  grain.

MCPA recoveries were 82.6% and 72.4% at  the fortification levels of 0.05 and
0.50 ppm in barley grain and 78.3% and 69.6% at the  fortification levels of
0.2 to 1.00 ppm in barley straw (Higham,  1975,  00004633).  MCPA recoveries
ranged from 77.1% to 76.6% and 85.7% at  fortification levels of 0.10 to 0.50
ppn in wheat straw (Higham, 1974,  00004632).  The method is applicable to
grasses, with spike recoveries ranging from 72  to 100% (average, 87%) and a
sensitivity-of 0.1 ppn (St. John,  1967,  00004724).

Tne procedure has been modified and expanded to determine both the free and
conjugated forms of HCPA and 2-methyl-4-chlorophenol (Montogomery, M.L., 1970,
00005575).  The need for hydrolysis, in  order to recover total residues, is

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demonstrated by comparison of  the  do.-Bribed netnod with a previously published
method \-nich does not  include  nydrclysis  Ocv,  P.N.,  1974,  n?G027r.5).
Recovery of i-CPA spikes  frcn wheat grain  are  greater than 89% at C.05 pm.

These- ilCPA extraction  procedures  including a  base hydrolysis step ancl slightly
modified or varied clean-up procedures  nave been used  to determine total MCPA,
2-methyl-4-chlorophenol  residues  in flax  (Guyton, 1977, 00004R22), range and
pasture grasses (Guardigli, iy73,  000021920)'and peas  (00004287).  In flax, tne
rigorous extraction and  clean-up procedures along with the determinative steps
employed should confer adequate specificity for  detection of 'CPA in flax
foliage, straw, aid seed.  Hydrolysis of  conjugates by cold alkali treatment
probably liberate all conjugates,  but  this has  not been demonstrated (Guyton,
C.C., 1977, 00004822).

Guardigli (1973, 00021920), subjected grasses to acid  or alkaline hydrolysis
and exhaustive solvent extraction.   Additional residues were not recovered
after exhaustive Soxhlet extraction. After clean-up on acid alumina, MCPA is
nitrated and methylated  before determination  by  gas chrcroatography using
electron capture detection.  The  2-nethyl-4-chlorophcnol is estimated after
thin-layer chrcmatograpny via  color development  of spots.  A detection limit
of 0.05 ppn is found for J1CPA  and  tne metabolite is detected down to 0.1 ppn.
Recoveries for both compound are greater  than 80%.  VJhen pea vines wore
subjected to alkaline  hydrolysis prior  to organic solvent extraction,
detection limits of about 0.04 ppn an 0.1 were obtained for ICPA (Cuardigli,
1974, 00004737).

A method for the determination of  residues in animal tissues is described by
Herman (1971; 00004627).  "Trio"MCPA and  "2-methyl-4-chloro3hcnol arc "extracted
from the tissues (muscle, liver,kidney  and fat)  with anmoniacr-i mctr.snol.  The
extract is concentrated, diluted with v;ater,  acidified with phosphoric acid
and partitioned into diethyl ether. Tnc  two  components arc separated by
liquid chromatography.  on an acidic alumina column.  The phenol is determined
as free phenol and tne MCPA as its methyl ester  by gas chromatography, using a
microcoulcmetric detector.  When muscle and liver were fortified 
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hexane followed by dietnyl etner.   The  cream extracts are partitioned with
sodiirti hydroxide arid  the  basic  solutions  acidified with phosphoric acid
followed by extraction with dietnyl ether.   Cleanup of the samples is
accomplished by liquid cnronatograpny en  an acidic alumina column.  Tne etner
eluate, containing the 2-methyl-4-chlorophenol  is chrcnatographed directly.

MCPA is cluted from the column  with bicarbonate solution, acidified, extracted
into ether, esterified with diazcmethane, and determined as the methyl ester
by gas chrcmatography.

When milk and cream samples were  fortified  with MCPA and 2-metnyl-4-chloro-
phenol over tne range of  0.05 to  1.0 ppm, recoveries of MCPA and 2-methyl-4-
chloropnenol from milk averaged 103 + 23% and 85 + 17% respectively; while
recoveries fron cream averaged  89 + 23% and 83  + 20%, respectively, within 95%
confidence limits for individual determinations.  This procedure was
roverified by Bjerke  e± al.,  (1972; 05003259) in a study where dairy cattle
were fed MCPA and residue levels  in the milk and cream were determined.  The
method will detect MCPA and 2-metnyl-4-chlorophenol at levels as low as 0.05
ppm.

Modificfttion of tne above milk  method  (See  Herman et al., 1970, 00004492) to
include alkaline hydrolysis (determination  of free plus conjugated residues of
MCPA plus metabolite) is  outlined by Miller et  al_., (1975; 00004438).  The
method is sensitive to 0.02 ppm of  both conpounds with average recoveries
ranging from 62 to 98% for MCPA and 60  to 92% for 2-nethyl-4-chlorophenol.
VJhen milk samples frcn covs fed JCPA at a level of 1000 ppn were examined,
(Miller et al., 1973, 00004433) tne levels  of MCPA and its phenolic
metabolite were found to  be the same with the alkaline hydrolysis method as
those found using an  acid hydrolysis.

The general methods for cnloropnenoxy acids (including MCPA) in both fatty and
non-fatty foods, described in the Pesticide Analytical Manual, \folume 1,
Section 221, 222, 421, and 422  are  recommended  for enforcement purposes (See
citation under "2-roethyl-4-chlorophenoxy  acetic acid in Pesticide Analytical
Manual, \folume II), provided  these  are  modified with an alkaline hydrolysis
step to ensure recovery and measurement of  conjugated residues.  These methods
v/ill not determine the metabolite,  2-metnyl-4-chlorophenol.  If necessary, Dow
methods ACR 70.17 (for milk and cream)  and  71.10/71.10S (for animal tissues)
may be used.  The latter was  tested and validated in the Agency's laboratories
at 0.05 and 0.10 ppm  MCPA and metabolite, but not without modifications.
Owing to the necessity for modifications, there is some question of the
validity of the residue data.   Monitoring of residues in meat and milk is
therefore reconnended.

Residues in Plants

No-data are available on  the  presence or  absence of residual inorganic salt,
amine, alcohol or intact  esters on  plants following the application of MPA in
the form of its sodium or amine salts or  of its esters.  Their clearance will
require data en the amount present  or must  continue to rest solely on tneir
toxicology.  Uith respect to  the  intact ester,  tne Agency requests the
registrant to estimate its amount if present (with references to data)

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involving analogous  cncmicals,  and  the ability of the- anclyticnl methodology
to account for MCPA  ester  (if  preront).  In tnis connoction it should be noted
that according to  the  EPA  Index,  fCPA is registered for use in the form of its
souiuTi, diothanolaniinc and dimethylanine salts arvJ iu3 isooctyl and
butoxyethyl esters.  According  to -1C CFR 18C..399 (a), the use of J-CPA in the
form of its ethanolamine,  diisopropanolamine and triisoprorx»nolamine salts is
sanctioned.  In addition,  the  Product Chemistry Chapter for this Standard
indicated tnat tne isopropyl,  isobutyl and butyl esters are also being
used—based upon available confidential statements of formula.  It should
therefore be expected  that MCPA is  being used in all of these forris.

The question of nitrosamine contamination is raised in tne Product Chemistry
Chapter of this Standard.   Before tne Agency can assess tne presence of absence
of residues of nitrosamine on plants the Agency will need data on the amounts
of nitrosamine contamination in those formulations containing MCPA in tne form
of its amine salts,  in particular for the secondary and tertiary
alkanolanines.         '

The residue data evaluated in  tne following sections pertain to MCPA, its
metabolite, 2-methyl-4-cnlorophenol and their conjugates, obtained primarily
througn tne use of tne sodium  and dimetnylamine salts and the isooctyl ester.

Barley:

Grab samples from  Colorado, Minnesota, Montana, ar.d the Canadian provinces of
Alberta and Ontario  indicate that an application of T'CPA, dinotnylamine sr,lt
(when known) at rates  of 0.25  to 0.75 ib. a.e./acre in combination with Avenge
and bronoxynil results in  no detectable residues «0.05 ppn) in grain, and
«0.20 ppn) in straw of wnat must be presumed to be free .MCPA.  The
intervals fron treatment to harvest were ('./hen available) fi9 to 81 days.  A
method of the ftncrican Cyanomid Company utilizing GLC, poorly described, or
not 
-------
in the "flax", but blank values, wnicn  are  usually 0.2 ppm.  arc nigner tnan
expected for the  level of  residues  being  measured.  The reported net residues
of 0.1 ppm cannot be relied  upon.   The  study,  there for*-:,  is  of questionable •
value for tolerance reassessment.

In tne second study, the dimctnylamine  salt of MCPA was applied at a rate of 1
Ib a.e./acre, when the flax  was  3 to 4  and  5 inches high (i.e. 90 or 73 days
before harvest).  Flaxseed and "meat/oil" from plots treated in accordance
with the recommended use but at  an  exaggerated application rate (of 1.3X) were
found to contain no detectable residues «0.04 ppm) in seed  and «0.1 ppm)  in
extracted (seed) meat/oil.   These determinations were made by Analytical
Metnod No. 104 of Rhodia,  Inc.   (previously described under  Analytical
methods) which does not liberate bound  MCPA.  Therefore bound MCPA would have
escaped detection.

The data in these 'two studies do not adequately support the  contention that the
use of MCPA will not result  in detectable residues in flax,   ibwever, the
evidence accumulated ifc tne  Standard indicates that MCPA is  not translocated to
the seeds of crops, and that there  is no  reasonable expectation of residues of
MCPA in any form  in flaxseed.

There are no data for the  flax straw which  may be fed to livestock.  In this
case, it is reasonable to  expect that residues in flax straw will resemble
tnose in the straws of tne small grains.

Grasses, Pasture and Rangf;land

A variety of range grasses growing  in locations representing a cross-section
of the country were treated  with a  single application of the sodium salt of
MCPA at a rate of 1.5 Ib.  a.e./A.

The method described by Guardigli ct a_l., (1973; 00004449) was used to
determine total residues of  MCPA and 2-roethyl-4-chlorophenol as separate
entities.

Forage samples were collected at various  periods after treatment and the
residues determined (Table 7-1).  The maximum for residues of MCPA was 206.4
ppra at 1 day after treatment, with  an average value of about 75 ppm.  An
initial deposit of 220 ppm on forage grasses is estimated.  The residue
remaining on pasture and range grass after  7 days (the specified waiting
period for dairy cattle) is  23.7 ppm.  Samples of grass hay  (fresh/green and
dried) were taken for analysis at 21 to 22  days after treatment.  Maxima for
residues of MCPA were 7.90 ppm in the fresh and 13.10 ppm in the dried hay.

Inasmuch as the rate for application is somewhat higher (i.e. 2 Ibs a.e./A)
for tne dimetnylamine salt,  an adjustment for the difference indicates maxima
of -2.0 x 22C = 292 ppm on  day zero  and  2.0  x 23.7 = 3C cpn at 7 days in
   1.5                                  375"
pasture and range grass, and 2.n x  13.1 = 13 ppm in grass fay at the higher
                             TTB"
rote.

-------
                             TABLE 7-1.   SllftlAW TARtJ? OF RTOtnUFR  IN/TN PASTURR MID WKTXJtm GRASSES

                                                  SAI.T OF MTPA,  RATF.t   1.5 Ihn  a.l./Acn?)

                                                             (00004449)


                                                    Past Treatment  Period  (rays)
Grass Species
•lohnsonqrass
Bermuda
Sudan Grass
Bermuda
RliKqrass Fescue
Rah la Crass
Rlueqrass
Remuda
Actual
days
(1)
(3)
(1)
(2)
(0)
(2)
(1)
(0)
(1)
(1)
(3)
0-3

Phenol MCPA Actual
ppm ppm days
Forage
<0.1 93
-0.8 39
"0.4 111
-0.4 163
~0.1 103
-vl.6 59
<0.l 42
<0.1 110
-'1 .0 52
7
4
<0.1 42
-"0.8 24
.10
.16
.84 (7)
.44 (9)
.44
.55 (9)
.00 (7)
.40
.65
.60 (7)
.05
.00
.24
6-9
Phenol MCPA Actual
ppm ppm days
Foraqe
(14)
-1.6 28.68 (14)
-1.2 34.34 (14)
-1.6 18.60 (14)
~0,2 18.66 (14)
(14)
3.24 (15)
(14)
13-16
Phenol
ppm
Foraqe
-0.6
-0.8
~0.8
-2.0
-
-0.9
-
-0.4
MCPA
ppm
14.64
12.54
4.97
5.59
1.49
28.95
0.45
9.72
21-22
Actual Phenol
Hays : ppm
* \
Green/Fresh
(21) -0.4
(21) ~0.4
(21) <0.1
(21) -0.3
(21) -vO.4
(21) ~0.2
(21)
(21) -0.2
MCPA
ppm
Hay
7.14
6.53
0.12
6.82
2.82
1.28
0.15
1.84
Actual
days
(21)
(21)
(21)
(21)
(21)

(21)

(21)
21-22
Phenol
Ppm
Dried (lay
-0.4
<0.1
-0.1

-0.2 .

-0.2
MCPA
PPm
12.06
11.37
0.18
13.10

2.61

4.00
Rlueqrass, Fox-   (1)     <0.1   19.60   (7)       -     8.76    (14)    ~0.4     5.80    (21)      -      4.09    (21)     <0.1    O.22
    tail Fescue

Timothy Crass     (1)    -0.2   95.40   (6)    ~0.fl   38.16    (13)    —0.8     6.48    (21)    ~0.2   .  3.55    (21)    -0.4    4.78
Rye, Foxtail      (1)    -0.4   49.68   (6)    -2.0   14.28    (11)    -1.2     6.12    (21)      -      2.76    (21)    "2.0    1.10
Chest, Rromeqrasa

Blueqrass, Fescue (1)     <0.1  206.40

Bentqrass         (3)    -0.4   14.28   (7)    -1.2    4.08    (14)       -      0.95    (22)    ~0.6     0.10    (22)       -    0.12

Fescue            (0)       -    71.40
                  (3)       -    34.60   (7)       -    28.12                           (21)      -      7.90    (21)       -    12.24

Orcfvird Crass     (0)     <0.1   73.20
nentqrass         (.1)    —0.4   21.84   (7)    —0.9   19.68                           (21)    -0.1     1.57    (21)    "0.4    1.17

.lohnsnnqrass      (1)    -^0.2   55. >O   (1)    "1.0     -     (16)    ^/0.15    1.10

-------
Tne metabolite, 2-netnyl-4-cnlorophenol  was detectable even up to harvest in
drietf nay at 21 days after  treatment.  A maximum of about 2.0 ppn <.:as observed
in forage at 6 days after tne  high  residi*?  levels in the grasses.

Trie levels of residues are  consistent  with  those of the established tolerances.

Oats;

A single grab sample of oats from Minnesota indicates that an application at
0.25 Ib/acre of MCPA (used  in  combination with dicamba) will not result in
detectable residues «O.C5  ppm) of  what  must be presumed to be free MCPA in
oat grain and straw.  The interval  frcn  treatment to harvest was 02 days.  A
method of tne Velsicol Chemical Corporation utilizing GLC, not otherwise
described, but having adequate recovery  with grain, was used (Rydrych et al.,
1971, 000236S7).

These few data and the absence of a decription of the analytical method
provide poor support -for the established tolerance.  However, conclusions
drawn from residue data on  tne grain,  forage and straw of other small grains
are considered applicable to oats.

Rice

Results of field  tests conducted  from  1069  to 1971 aro summarized by Devine,
1970, 00004764; Lsng et al.., 1970,  00004765; and Rhodic .   Incorporated, 1971,
00004594).

In a 1969 study (Leng et al^.,  1970, 00004765), rice was treated at two stages
of growtn witn an unspecified  formulation of MCPA at rates of 1 to 3 Ib a.e.
MCPA per aero in  California.   No  residues of MCPA were detected  «O.C2 ppn)
in any samples of the grain, rice mill (by-product), hulls, 'rice polish1 and
bran from treatments made 106, 103  and 73 days previously.  No residues were
dett_lable «0.05 ppm) in rice straw at  106 days, but up to 0.75 ppm were
found at 78 days. The method  is  presumed to be tnat described and used by
Winterlin for wheat.  No attempt  was made to measure the conjugated i'CPA.

Rice bran and rice straw treated  two times  during the 1970 growing season with
MCPA at a rate of 1.5 Ibs a.e./acre in Arkansas, Texas and Louisiana were
found to contain  no free MCPA  residues «0.05 ppm) or MCPA which could be
liberated witft acid hydrolysis, using  the method of Yip and Ney  (196f3; GS 0017-
109).

Residues of TiCPA  \rcre were  found  in straw harvested in California at levels
ranging from <0.05 ppm to 0.14 ppm  (Devine, 1970, 00004764).

When MCPA was aerially applied, at  a rate of 0.5 Ib a.i./A to growing
stubble rioe, no  residue of MCPA  was found  on rice grain ans straw at narvest
time (Rnodia, Incorporated,  1C-71; 00004594).  Since no analytical details were
given, it is assumed that tne  free  MCPA  alone was determined.

-------
Tne dissipation of *CPA in a California rice  field treated  at  a  rate  of 0.4 oz
ci.i./acre was investigated by Soderquist, et  ad.,  (1975,  05003445).   Samples*
orwacer, rioe plants and mud were collected at  intervals  for 20  days  and
analyzed from MCPA by establisned methods for plants, mud an^  water.   Water
residues declined to less than 0.01 ppm of MCPA within  14 days after
application; plant residues declined  from 20"  ppm to  1 ppm within 20 days;  mud
residues remained constant at about 0.1 ppm.  Photolysis  of dilute aqueous
MCPA solutions with either sunlight or an indoor photoreactor  yields  2-methyl-4-
chloropnenol as the major product; o-cresol and 4-chloro-2-formylphenol
also were identified.  While photosensitization was  observed in  water taken
from the rice field, all environmental compartments  except  air contained
measurable amounts «0.01 ppm) at some time,  but water  contained the  bulk  of
tne applied MCPA whose eventual disappearance was  shown to  be  due to  biological
and chemical degradation and not dilution.

The one limitation in this study is the use of  a relatively insensitive flame
ionization detector irf the GLC analysis (with a method  sensitivity of 10
ppb).  Many plant species (i.e., tobacco, tcmatoes,  cotton,  etc.) are
sensitive to pnenoxy herbicides in irrigation water  at  levels  as low  as 0.1
ppb.  Thus the discharge to the relatively water soluble  MCPA  into the
irrigation canal may result in crop injury by reuse  of  irrigation water.

Based on grab sample data (1969-1971) from numerous  locations, the use of  MCPA
in normal rice production does not result in  detectable residues of MCPA in
edible rough rice grain.  low levels  «0.70 ppm) of  MCPA  nay be  found in
straw which nay be used for livestock feed.

The levels of residues are consistent with those of  the established tolerances.

Rye:

Residue data are not available for rye grain, forage and  straw.   However the
conclusions drawn frcn residue data on the grain,  forage  and straw of other
small grains are considered to be applicable  to rye. This  same  correlation
was possible for the grain and forage of barley, oats,  rye,  and  wheat, though
not necessarily at the same level of  tolerance, for  2,4-D in 40  CFR 130.142?.

Sorghum;                                                               ,

In studies reported by tne Interregional Research  Project No.  4, (1974;
00004493) a single posteracrgence application  was made to  sorghum in the
preboot stage.  The test locations were in tfebraska  and Texas, which  are
important producers of sorghum.

MCPA was applied in tne form of its sodium and  dimetnylamine salts at rates of
0.5 and 2.0 Ib a.e./A; and in the form of its isooctyl  ester at  rates of 0.75
and 1.5 Ib a.e./A.  The sodium salt alone is  registered for use  on sorgnum.

Rhodia Analytical Method £122 was used to determine  total residues of '1CPA and
2-metnyl-4-chlorophenol as separate entities.

-------
Samples Harvested at  57 days  after  application of the sodiun salt at 0.5 and
2.0 Ibs a.e./A snow total  residues  of  tICPA ranging from O..H to 0.83 ppn and
from 1.16 to 4.07 ppm in fodder.  None (i.e.  <0.04 ppn) was found in grain
at the- higher rate.

Residues of 2-nethyl-4-cnloropnenol (i.e.  <0.1 ppn) were found in neither
fodder nor grain at the higher rate.

Residues of total MCPA, adjusted  for tne difference in rates (2.0/0.75 =
2.67x) would not exceed about 1.5 ppm  in the  fodder.

The data remaining  from the trials  on  the  dimethylanine salt and trie isooctyl
ester support these findings.

There are no residue  data  on  the  forage.   However, data on the grain forages
can be utilized for this purpose  and snow  residue values of up to 16 ppn after
7 days, from tne application  of 2 Ibs  a.e./A  made up to the boot stage.
Adjusting as before for the difference in  rates,  residues of total MCPA would
not exceed about 6 ppm.

Levels of residues are consistent with tnose  of the existing tolerances.

Sec-d and Pod Vegetables

The existing tolerance for residues in seed and pod vegetables is an extension
of a negligible residue tolerance previously  established for poas alone.

The data submitted  reflect tests  conducted during tne period fron 1?% to
1974.  The earliest residue determinations were made using colorimetric
methods described by  Marquer-lt and  Luce (in J. Agr. Food Chen. 3, 51; 1955)
and by Conkin (1956,  00005552).   The first method is considered too
insensitive to yield  reliable results  at the  0.1 ppm level of the tolerance
(cf:  blanks ranging  fron  <0.1 ppm  to  0.6  ppm); and data from the DP! Monte
trials 1, 2 and 3 (described  in Del Monte, 196G;  00044403) were eliminated for
this reason.

After 1965, determinations were made by means of GLC, with greater
sensitivities of the  order of 0.01  to  0.02 ppm.  One of these methods (that of
Chow et al., (1965, 05003765) utilizes alkali to liberate the conjugated MCPA
and tnus determines the total residues of  fCPA (See Del Monte, 1973, 00004444).

Tne data of the Summary Table (7-2) indicate  tnat even under exaggerated rates
(up to Z<) and timing  (up  to  14 days before harvest), there are no residues of
MCPA in excess of 0.1 ppm, and probably much  less than this level, in peas.

Winterlin £t'al., (1574, 00004453)  and Bendixen (1974, 00004454) reported the
results of postemergence shielded spray applications made in 1974 to beans
grown in California.  MCPA was applied in  tne fcm of its dimotnylamine salt et
from 1 to 2 Ibs a.e./acre, at 110 days before harvest.

The metnod of Chow et el., (1965, 005003765)  with modifications was used to
determine total residues of f-CPA  in dried  lina beans, small white beans and

-------
garbanzos.  Ito fCPA  (i.e. <0.01 ppm  to  <0.02 ppm)  was detected in any of
those sanples.

Supportive data from Minnesota furnished  by Guardigli (1974,  000004788) from
applications to peas of MCPA  in the  form  of its  sodium salt at 1 Ib a.e./acre,
not later than the three-nodes stage before, pea  flowering, indicate no residues
«0.04 ppn of MCPB, and <0/04 ppm of fCPA,  and  <0.01 ppm of the netabolite2-
metny1-4-chlorophenol.  The method of application, aerial versus ground
application, did not affect the residue levels.

The levels of residues in peas and beans  (i.e.,  seed and pod vegetables) and
in peavines as well, are consistent  with  those of  the established tolerances.

Wheat

Wheat from test plots in North Dakota and two separate plots in Oregon which
has been treated with^fCPA, isooctyl ester (one  is the boot stage and the
other in the tiller stage) at rates  of  0.5, and  2  Ibs a.e. per acre were
analyzed for total fCPA residues.

The method used was based on  that of Yip  and lley (1966; GS 0017-109) and
indicates an alkaline hydrolysis as  described in the section on analytical
methods.

Residues could not be detected by tnis  method in samples of wheat grain
sampled at harvest.         J
Montgomery T-1.L. (1970,""000005575") "reporter^ "Fi^rii^icant~T»sir)ues"1.Ti" wrv5a"t~stravr
especially following treatments at  the  tiller  stage.   Following applications
at this stage, residues at  zero-day were 36  ppn,  121  ppn and -icn.6 ppn for the
three rates.  At harvest  (56th day)  residues of f'CPA  could no longer be
detected  «0.05 ppm) after  corrections  for recovery and baciirjround.

Grab samples of spring and  winter wheat frcm locations in Minnesota, Oregon,
South Dakota and Washington'indicate tnat an application of 0.25 Ib/acre of
f-CPA (used in combination with dicamba, 5-CH dicamba  and bromoxynil) will not
result in detectable residues of wnat is presumed to  be free MCPA «n.05
ppm) in green wheat, grain  or straw. The shortest interval from treatment to
harvest was 31 days for green winter wheat.  A method of the Velsicol Chemical
Corporation utilizing GLC (not otherwise described) was used with a recovery
of 80% at 0.1 ppn added MCPA (Rydrych et a_l.,  1971, 0000236C7).

Field samples from Oregon indicate  that an application of 0.5 Ib/acre of MCPA
(used in combination with Avenge  ,  bromoxynil  and 2,4-D at various rates up
to 0.75 Ib/acre) will not result  in detectable residues «0.05 ppn) of what
is presumed to be free MCPA'in wheat grain.  The application \ias nade when tne
wheat was 6 to 3 inches high and after  it had  tillered; the interval being 117
days to harvest.  Residues  were determined by  the American Cyanamid Company,
with a method (see Company  report C-575) utilizing a  gr»s chrcnatograpf
equipped with a Coulson electrolytic conductivity detector operating in the
halogen mode.  The methcn was validated for  residues  in wheat grain; the
sensitivity is 0.05 ppm (Hignam £t  a^., 1974,  OOGOP5570).


                                        tj?

-------
                            Table 7-2.  SUMMARY TABLE Of, MCPA ANALYSES CONDUCTED ON PEA SAMPLES
1
Pile No CROP
Monsanto
Company
00004773 Peas
and
00004441 Peas
Peas
Del Monte
Corporation
00004442 Peas
and
00004443
YEAR LOCATION MCPA TREATMENT RATE MCPA RESIDUES

1956 Idaho 0.25 lb a. e. /acre peas <0.1 ppm
»\
1956 Wisconsin 0.25 lb a. e. /acre peas <0.1 ppm
1956 Wisconsin 0.50 lb a To. /acre peas <0.1 ppm

1968 Utah 0.33 lb a. e. /acre peas (shelled)
<0.01 ppm vines
<0.01 ppm @ 37 days
MCPA FORM

Not identified
r.


Sodium Salt
00004443
Del Monte
Corporation
00004444
Peas

Peas
1972     Utah

1972     Utah
0.25 lb a.e./acre

0.50 lb a.e./acre
Peas
                Peas
          1973
         Jtah
0.38 jib a.e./acre
peas (shelled) <0.02
ppm (30 days) vines
<0.02 ppm (16 days)
peas (shelled) <0.02 ppm
(30 days) vines <0.02 ppm
(16 days)
peas 0.010-0.013 ppm
vines 0.014-0.020 ppm
          1973     Utah
                                  0.75
                             lb a.e./acre
                                                  when {peas are  6-
                                                  inches tall
                                                                                       Sodium  Salt
Sodium Salt
                      peas 0.013-0.020 ppm
                      vines 0.016-0.028 ppm
                      relative to checks of
                      0.011-0.015 ppm (peas)  and 0.015-0.022 ppm
                                                      (vines)

-------
These and other studies are  listed  in the Summary Table of Residues in/on VJneat
(Table 7-3).

The residue levels  aire consistent with tfic levels of the established
tolerances.

Grain fractions;

Because little, if  any residue  has  been shown to be present in the grain
portion (apart from tne forage  and  straw) of  the snail grains, there is little
or no expectation of residues in grain fractions, and therefore, no need to
establish food additive tolerances  for residues in grain fractions of barley,
oats, rice, rye and wheat.   The data  on rice  grain fractions (byproducts)
confirms this.

Small grain ^ legume mixture

MCPA has been registered  for use on barley -  legume mixtures, oat - legume
mixtures, rye-legune mixtures,  wheat  - legune mixtures, snail grain - legume
mixtures and  flax - legune mixtures,  but tnere is as yet no tolerance for
residues which result in  the legumes  from tnis use.  Such a tolerance has been
proposed in Pesticide Petition  No.  6E 1356, which is still pending.

Residues in Food-Producing Animals

VJhen use of a pesticide on agricultural crops results in residues in animal
feed, the Agency requires data  on whether or  not residues are transferred to
meat, milk, poultry and eggs.

In a beef calf feeding study (Bjerke   et £l., 1971, 00004625) tv;elve yearling
calves were subdivided into  four groups of three calves each and fed a diet
containing 0,250, 500 and 500 ppn of  FCPA for 29 days.  Average feed consump-
tion during the feeding period  ranged from 194 to 291 kg per animal with no
apparent relationship to  the presence of 'VCPA in the diet.  Ingestion rates
for MCPA averaged 7.1 mgAg/day for the groups on the 250 ppm diet, and
14.4 to 14.5 mgAg/day for the  two  groups on  tnc 500 ppn diet.  Feeding
resulted in residues of M3PA which  varied among samples of each of four tissues
at tne two feeding  levels.   Some variation is due to the fact tnat at the
higher feeding level one  group  was  sacrificed 6 days after the last feeding,
during  wnicn time, residues will have diminished.  Residues of tCPA and 2-
nethyl-4-chloropnenol were determined in the  four tissues, muscle, liver,
kidney and fat by a validated analytical method (Dow ACR 71-10), with a claimed
lover limit for sensitivity  of  O.C5 ppm for both components of the residue.

Significant residues were found in  liver and  especially in kidney at both
feeding ratess.  Vvithdrawal for  6 days resulted in a substantial reduction of
residues in tnese tissues (see  Summary Table  of Residues in Tissues of
Calves (Table 7-4)).

In a supplement to  tnis study,  Jensen et al^., 1973 (00004439), incorporated
an alkaline hydrolysis step  in  the  analytical procedure, but could not liberate
any additional residues of MCPA and cf tne metabolite, 2-mcthyl-4-chloro-

-------
                                                         •nrtr. vi

                                             Mtwv iMU rr mitnin mAM mmr
                                           .
                    nw   TFAII   tnrATifn       nnMitcim Apvuni       AT IWIWIHT             mm ppsiinifs

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of Aqrl.  OM..
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                                             rymnlnr* dlocnl««n»mt                    detectable cymiailna nr

           •* •!.
                                        .m  »CH» («.» th •.»./M>     rt^M na
                                                    10. M INi/AI      lTri.tr> t Mmiil
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                  on.    mi
                               IRfi<< m«tl*l  l»m*l IB. II IKi/KI

      li.D. it It.
BOB21U1          MhMt   l"0   nrr
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                          1*14
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                                                    II.B lt./»l         41.11 n«MTJW
 ft ml.
                  Mhrat   nn   Htmnrt*    HTM |t.f !>• •.•./HI*     .« Ita •.r./
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  00004M4           W>m   I*TI   I«    O.M nv<|r»ln   OI.BJ
                                               Dlcnta  IB. in IIM/KI      O.n fpn Mrw   tO.OI
                                                                         |CD| CtOTtlnl
   Cocporat lot                    •                               '
  OOOOtMl           Mm.    lt?4   fln IWinla    fCHk W.n Ib* «.•./»!«    lrm*>i 10. Ji


                                               ICM 10.11 Ita «.«./»(.    <0.0f rt_ qr»lr

                                                                I

                                tnc<1 WYV «*H4«te<1 tMlnrf HCVA fortified •MV>|»«.   II ««n* not pnHilhle to 4etrnMln
  rlrt^/tta«tpr rrvlm* pnt*.m If A tv»nr> hytlrolyillN v^fl MM Inrlmi^.  •nv^ipfrw.  fivitt* r)*«iM N* tjAf^i In Inrllrntr
  ICFA KM.

-------
                            Table 7.4  Summary Table of Residues in Tissues of Calves

                                           Residues in Tissues  (ppm)*
Daily
Feeding
Rate ' Calf
(ppm MCPA) Number
25Ql/ 1765
1649
1761
500l/ 1644
1645
1646
500i/ 1767
3 1764
1647
Muscle
MCPA
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
Met
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
Liver
MCPA
<0.05
0.10
<0.05
0.08
0.15
0.14
<0.05
<0.05
<0.05
Met
0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
Kidney
MCPA Met
1.2
2.5y
0.58
2.0
2.2
2.7
0.34
0.07
0.05
<0.05
<0.05
<0.05
^0.05
<0.05
<0.05
<0.05
<0.05
<0.05
Fat
MCPA
<0.05
0.05
<0.05
0.06
<0.05
<0.05
<0.05
<0.05
Met
<0.05
<0.05
<0.05
<0.0b
<0.05
<0.05
<0.05
<0.05
*A11 values corrected for recoveries
I/  Fed at 250 or 500 ppm for 28 days, slaughtered on day following last feeding.

2/  Fed at 500 ppm for 28 days, slaughtered on 7th day following last feeding.

Met = Metabolite, 2-methyl-4-ch).orophenol.

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pnenol.  Therefore  it  is  concluded that there are no conjugated residues of
MCPA or 2-r.ctnyl-4-chlorophenol  in tneso tissues.

In a sheep  feeding study (Bjerke et el., 1971, 0004626), nine sheep were
subdivided  into  three groups of  throe each and fed a diet containing 0, 250
and 500 ppm MCPA for 28  Hays.  Average feed consumption duri...J the feeding
period ranged  from 25 to 31 kg per animal, with no apparent relationship to
tne presence of  MCPA in  the diet.  Ingestion rates for MCPA averaged 14.9 and
14.6 mgAg/day for the two groups on the 500 ppm diet.  Residues of HCPA and
2-methyl-4-cnlorophenol  were determined  in the four tissues, muscle, liver,
kidney and  fat,  as in the  calf study, using the same analytical nethcd (Dow
ACR 71.10).  Significant residues were again found in liver and kidney.
Withdrawal  for six days  resulted in a substantial reduction of residue in
these tissues  (see Summary of Residues in Tissues of Sheep (Table 7-5).

Results of  an  early  cow  feeding  study (Bache et a_l., 1964, 00004701),
indicate that  dietary;MCPA data  a level  of 50 ppm for 4 days did not result in
detectable  residues  of the MCPA  in the milk.  The level of the phenolic
metabolite  was not determined.

In a subsequent  study (Herman et al., 1970, 00004491; Bjerke et al., 1972,
00003259; and  Herman, J.L. et al., 1971, 00004624) three lactating Itolstein
cove were fed  a  complete ratTon  containing MCPA at six levels in sequence frcn
10 to 1000  ppm for 2 or  3  weeks  at eacn  level.  Three cows were maintained as
controls.   Six milk  samples were collected during eacn 2-v/eek period (at
levels of 10,  30, 100 and  300 ppn), nine samples during tne 3-week oeriod, (at
1,000 ppm)  and four  samples during the 1-week withdrawal period.  Cream
collected from morning milk only was obtained by compositing the milk from tne
three test  COVE  and  separating to mediun heavy cream.

Residues of MCPA greater than 0.05 ppm and up to 0.07 ppn wore found in only
six ,^~Tiples of milk  fron covs fed at the 1000 ppm level.  Small residues of
O.OS ^iprn and 0.17 ppm of 2-methyl-4-chlorophenol were found in milk at tne 300
and 1000 ppm feeding levels. Residues of both are lower in cream at the 1000
pprn feeding level.   Withdrawal resulted  in rapid disappearance of residues
from the milk, the residues dropped below 0.05 ppm on the first to third ciay
after withdrawal.

The experimental design  for the  cattle feeding study leaves something to be
desired.  The  dairy  covs were given increasing doses of riCPA; that is, tnoy
were fed 10 ppm  for  2 weeks, 30  ppm for the next 2 weeks, 100 ppm for the next
2 weeks, 300 ppm for the next 2  weeks, and 1000 for the last 2 weeks.
This gives  the animal's  metabolism a cnance to acclimate and adapt to the
herbicide and  possibly develop an increased ability to exrrrete (or secrete)
the herbicide.  If untreated cows were given the higher levels without
pretreatment",  higher residue levels may  have resulted in milk.  This is
important since  early results of tne FEA survey of rcady-to-eat foods indicate
the occasional occurrence  of fCPA residues in dairy products (Duggan e_t si.,
1967, 0025154).  Bache et  al. (1964, 00004702) have shown that the animal

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                                  Table 7.5  Summary Table of Residues  in Tissues of  Sheep
Residues In Tissues (ppm)*
Daily
Feeding
Rate
(ppm MCPA)
500^


500^


•

Sheep
Number
2546
2547
2553
2548
2549
2554


Muscle
MCPA
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05



Met
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05


Liver
MCPA
<0.05
<0.05
0.12
<0.05
<0.05
<0.05



Met
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05



MCPA
>N 0.31
1.7
0.45
<0.05
<0.05
3/


Kidney
Met
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05



MCPA
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05


Pat
Met
<0.05
• <0.05
<0.05
<0.05
<0.05
<0.05
*A11 values corrected for recoveries




If Fed at 500 ppm for 28 days, slaughtered on day  following  last  feeding.



2J Fed at 500 ppm for 28 days, slaughtered on 7th  day  following last  feeding.




_3/ Sample lost during analysis.



Met - Metabolite, 2-methyl-4-chlorophenol.

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eliminates "CPA at a  high  rate  in urine.   Were it not for tnis nigh rate of
excretion, tne criticism of  tnis  study night well bo valid.  It is not expected
that I-CPA will be preferentially  secreted in nilk under these circumstances'.

There are no residue  data  for poultry and eggs.

With the realization  tnat  residues cannot be maintained long at their highest
level of 300 ppm  (as  in  pasture and rangeland grasses)  owing to inevitable
decline of these residues,  it is  expected that carryover of residues into meat,
fat and meat by-products will be  less tnan tnose observed in tne foregoing
feeding studies.  Therefore  the existing  tolerances for meat, fat and meat by-
products are considered  adequate.  The one week preslaughter interval gives
added assurance of this.

Because tnere is little, if  any,  residue  in tne small grains, a staple of
poultry rations, there is  no expectancy of residues in poultry and eggs, and
no need for a tolerance.
                    • •
Other Sites

Applications of fICPA  to  other sites, e.g., ornamentals, rights-of-way,
agricultural, commercial and industrial premises; and aquatic, forest,
cnappatvd , non-agricultural  and wasteland areas were formally regarded as
non-food uses.  It is now  recognized that such is not always the case.

The application of fCPA  to drainage ditcn banks m?y contaminate water, the
fisn and snellfisn inhabiting it, and eventually potable water.  If the
contaminated water is used for  irrigation tnere may be contamination of crops.
Therefore, tnis use should be the subject of a tolerance or the subject of
labeling restrictions to preclude sucn contamination.
      r concern  is  tne  foraging  or grazing by livestock of gr.iss growing on
tneiv- sites  (for example,  sheep  are allowed to graze on golf courses).  If the
rates of application are higher  (and they are in sane instances) tnan the rate
of 2 Ibs a. o. /acre  permitted  on  pasture grass, then an appropriate restriction
e.g., "Do not spray areas  likely to be  foraged or grazed by livestock" shouldbe
imposed.  Such is tne case for rights-of-way and fallow land.

                         Current Tolerance Information

Under section 130.339 of CFR  40, tolerances are established for residues of
"•CPA frcn application of the  herbicide  in its acid form or in the form of its
sodium, ethanolamine , dietnanolame, triethanolamine , diisopropanolamine,
triisopropanolamine or  dimethylamine salts or its isooctyl or butoxyetnyl
esters in or on  raw agricultural commodities as follows:

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         CaTriodity                                P?rt-.s per million

         Darlcy, forage	20
         Barley, grain	0.1 (II)
         Barley, straw	2
         Flax, straw	.'	2
         Flaxseed	0.1 (N)
         Grasses, pasture	300
         Grasses, rangeland	300
         Grass, hay	20
         Oats, forage	20
         Oats, grain	0.1 (il)
         Oats, straw	2
         Peavines	0.1 (N)
         Peavines, hay	0.1 (H)
         Rioe, grain..,	0.1 (N)
         Rice, straw.. .*	2
         Rye, forage	20
         Rye, grain	0.1 (N)
         Rye, straw	2
         Sorghum, fodder	20
         Sorghum, forage	20
         Sorghum, grain	0.1
         Vegetables seed and pod	0.1
         Wheat, grain	0.1 (N)
         Vineat straw	2
         Uneat, forage	20

Tolerances are also established  for combined negligible residues (U)  of MCPA
and its metabolite 2-rnethyl-4-chloropnenol  in  or on the following rav;
agricultural commodities:

         Commodity                                Parts per million

         Cattle, fat	0.1 (N)
         Cattle, mbyp	0.1 (N)
         Cattle, meat	0.1 (N)
         Goats, fat	0.1 (11)
         Goats, nbyp	0.1 (N)
         Goats, neat	0.1 (N)
         Hogs, fat	0.1 (N)
         Hogs, mbyp	0.1 (13)
         Hogs, meat	0.1 (N)
         Horses, fat	0.1 (N)
         Horses, mbyp	0.1 (11)
         Horses, meat	0.1 (N)
         Milk	0.1 (N)
         Sheep, fat	0.1 (N)
         Sheep, mbyp	0.1 (N)
         Sneep, meat...	0.1 (11)

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                            Tolerance  Reassessment

Theoretical :-laxinum Residue Contribution

Tolerances for residues of fCPA, and of  its metabolite 2-methyl-4-chlorptK!nol
nave been established  for a number of  food and feed earnedities (see previous
section).  Based on these tolerances,  the theoretical maximum residues contri-
bution  (TMRC) and KIPA and its metabolite to  the human diet is calcuLafH to
be ca 0.77 mg/cfey (assuming a 1.5 kg diet).   For a comparison of the TTIRC with
tnc maximum permissible daily intake (see the Regulatory Chapter of this
Standard—Chapter 2).

International Tolerances;

Codex maximum residue  limits  (MRLs) have not  been recommended for MCPA.
Tolerances have not been established in  Canada or Mexico for residues of J1CPA
in any  food or feed comnodities.
                     • /•
                        Enforcement/Monitoring Actions

Tnere is no record of  any enforcement  action  involving !CPA.  Its residues are
not usually monitored  in FEA or USDA surveillance programs.  Owing to
weaknesses in tne residue data on the  grains,  and reservations over tne
methodology for neat and milk, monitoring of  the grains, meat and milk is
recommended.

                             Labeling  Requirements

Tne limitations against foraqing and grazing  should be consistently
maintained.  Tnere  are, for example, different foraging and grazing
limitations for barley for different salts.   Unless there is sane compelling
reason  for these differences, they should be  removed in the interest of
consistency.  The following should provide assurance that tne tolerances for
meat, fat and meat  by-products and for milk will not be exceeded:

    "ED not forage or  graze meat animals on treated areas within 7 days of
    slaugnter."

    "Do not forage or  graze dairy animals on  treated areas within 7 days after
    treatment."

Until a tolerance for  residues of 'CPA in potable water, fish and shellfish is
established, the use of ICPA on drainage ditch banks snould not be permitted
witnout labeling restrictions to prevent contamination of potable water, fish,
or shellfisn.  If there is a probability that the ditch water is used for
irrigation, -tnen some  accomodation should be  made for residues in irrigated
crops.

A restriction against  tne practice of  growing crayfish or catfish in treated
rice fields is recommended to preclude the possibility of residues in crayfisn
or catfish.

-------
For otner so-called non-food uses, v/nen  the application  rate exceeds 2 lb?
a.e./acre, an appropriate restriction, e.g.,  "Do not  spray areas likely to be
foraged or grazed by livestock" stould be  imposed.  Such is the case for
rights-of-way and fallow land.

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                                  CHAPTER VIII

                          ECOLOGICAL EFFECTS OF MCPA

Introduction

In order to evaluate potential  fish  and  \/ildlife effects resulting from the
use of ;-CPA, the Agency' requires  certain toxicity testing.   Depending on the
characteristics and uses of ?CPA  end-use formulated products, data
requirements for wildlife and aquatic organisms can be completely or partially
fulfilled with tests on tne manufacturing-use products.  However, for sane
end-use formulations whicn contain salts and esters of MCPA which are not
registered MUP's, tne technical grade of the ester or the manufacturing-use
salt in the product must be tested.   Additional testing on specific end-use
products can also be required if  a particular inert ingredient is determined
to significantly alter the toxicity  of the active ingredient.
                     • t
A full battery of fish" and wildlife  testing is required on MCPA acid.  This
includes acute oral avian testing, fisn  acute LC5Q testing, acute tcxicity
testing on aquatic invertebrates, and acute estuarine and marine invertebrate
toxicity testing.  In addition, avian dietary LC^Q testing in one species
(bobwnite quail), fisn acute LC^g testing in two species, and acute
estuarine and merino invertebrate toxicity testing is required on the
following salts and esters:  sodium  salt, dirvcthylamine salt, butoxyethyl
ester, and isooctyl ester.

Because MCPA nan an aquatic >-uso,  involving direct application to water (uso in
rice), tho Agency is" "required t6~consider~tho~ne"ea~for~a^^il:ionril~t(3Stirif] on"
end-use formulations.  "Jne only end-use  formulation that requires additional
testing is tne emulsifiable concentrate  formulated with the butoxyotnyl ester
of MCPA.  Fish acute LCcQ testing in two species, acute toxicity testing on
aquatic invertebrates, and acute  estuarine and marine invertebrate toxicity
testing is required on this>formulation.

                          Ecological Effects Profile

Results frcm the acute aquatic  studies on technical fCPA acid suggest that
MCPA is slightly toxic to freshwater fish.  The calculated LCcn values for
rainbow trout and bluegills were  89  to 91 ppm and 97 ppm (USEPA, 1076, GS 0017-
108) respectively.  The 48-hour Daphnia  magna toxicity test produced an LC5n
>180 ppm (USEPA,1976, GS 0017-108),  which suggested that MCPA acid is
practically nontoxic to freshwater invertebrates.  There were no ccologic
effects data concerning aquatic organisms available on any manufacturing-use
t'CPA salts or esters.  Two formulations  of MCPA also appeared to be practically
nontoxic to freshwater fish.  The 96-hour LCcQ for freshwater fish ranged
from 1GO to 1000 ppn  (LE002G927)  for MCPA sodium salt formulations.  The ?6-
nour LCcp for freshwater fish was greater than 180 ppm for MCPA dinetnylamino
salt formulation  (USEPA, 1972,  GS 0017-104).

-------
Results frcn acute dietary studies on technical TCPA acid  suggest  tnat JVCPA is
practically nontoxic to birds.  The  calculated LC5Q  values for mallard duck,
bobwrdte quail, and ring-necked pheasant were greater tnan 2000 ppm (D3witt,
1S62, GS 0017-101).
MCPA was relatively nontoxic to honey bees.

                        Data Requirements and Data Gaps

    1.   Manufacturing-use MCPA (acid, salts, esters)

The following acute wildlife and aquatic organism tests were  needed  on
technical MCPA (acid) in order to perform a  hazard evaluation:

    a)   Estuarine and marine organism toxicity study  (preferably 96-hour
         LC™ on shrimp and fish, and either a 43-hour I£c0 oyster
         emBryolarvae" or a 96-hour ECen shell deposition  tor  molluscs).
         163.72-3.                   3

    b)   Avian single-dose oral LDe0 testing performed on one avian  species
         (preferably mallard duck or bobwhite quail).  163.71-1

The following acute wildlife and aquatic organism tests are needed on
tecnnical MCPA butoxyethyl ester and isooctyl ester, and  the  manufacturing-use
products containing the MCPA sodium salt and dimethylamine salt:

    a) - Acute 96-hour fish studies on coldwater species  (preferably rainbow
         trout) and a wam;atcr species (preferably blucgill  sunfish).
         163.72-1

    b)   Acute 48-nour toxicity studies on a freshwater invertebrate
         (preferably Daphnia magna).  163.72-2
                           ;
    c)   Acute estuarine and marine organism toxicity  studies (preferably
         96-hour LCjjQ for shrimp and fish, and either  a 48-nour LCeo
         oyster embryolarvae testing or a 96-hour EC50 mollusk shell
         deposition testing).  163.72-3

    d)   Avian acute dietary IT^ testing performed on one species of
       .  waterfowl (preferably mallard duck) and one species  of upland game
         bird (preferably bcbwhite quail or  ring-necked pheasant). 163.71-2

    e)   Avian single-dose oral LD^ testing performed on one avian  species
         (preferably mallard duck or bobwhite quail).  163.71-1

Additional chronic fish and wildlife testing may be required  after review of
tne acute toxicity studies on tne technical  (acid and  esters) or  manufacturing-
use (salts) material.

-------
    2.   Formulated Prcduct(s)

The direct application of !'CPA  to v;ater  (rice  use}  triggers a potential hazard
co dquatic oryaiusnis.  Tue  following  acute  toxicity studies will be required
on tne butoxyethyl ester fomulation  of  MCPA:

    a)   Acute 96-nour fisn studies on one  coldwater species (preferably
         rainbow trout) =>nd one warmwater species (preferably bluegill
         sunfisn).

    b)   Acute 4G-nour toxicity study on a  freshwater invertebrate (preferably
         Daphnia magna).

    c)   Acute estuarine and narine toxicity studies (preferably 96-nour
              on snrimp and fish, and either a 48-hour LCc0 oyster
            ryolarvae or a 96-hour LCcQ  shell  deposition for molluscs).

                    •'•'-        Topical Discussions

Effects on Freshwater Fisn

Sixteen studies (contained  in twelve  references)  were received and evaluated
under this topic.  These sixteen studies were  acceptable for use in a hazard
assessment.

              Author                  ID

              Hat tula            050nf!234
              USEPA              GS 0017-108
              Sleight            C0022f>9C
              Bentley            OC004512
              Pitcher            00026927
              Tooby              05020144
              McCann             00026928
              Buchanan           GS 0017-002
              USEPA              GS 0017-107
              USEPA              GS 0017-104
              USEPA              GS 0017-105
              USEPA              GS 0017-106

In order to establish the acute toxicity of MCPA to fish, two 96-hour acute
aquatic studies are required on tne technical  material.  These studies should
be performed on one coldwater species (preferably rainbow trout) and one
warmwater species  (preferably bluegill).   Since there are aquatic uses
involved, formulated product testing  is  also required.
            •
'•iCPA Acid

Two acute aquatic  studies (USEPA, 1976,  GS  0017-108) were conducted by tne
USEPA laboratory at Beltsville  on technical grade ?CPA (94% a.i.).  The studies
were performed on  rainbow trout end bluegill sunfish, and wore acceptable for
fulfilling the Guideline requirements for MCPA acid.  Tne toxicity values were

-------
calculated as follows:  rainbow trout  96-hour  LC^p  = 09-91 ppn;  blucgill
sunfish 96-hour I£CQ =  97 ppm.   These  values suggest tn?.t '1CPA acid is
slightly toxic to fish.

Salts and Esters

Five studies on the 24% sodium  salt  formulation were submitted (3entleyf
1974,000004512; Picner, 1973, 000026927;  USEPA, 1973, GS  0017-105;  USEPA,  1973,
GS 0017-106).  All were acceptable for fulfilling the Guideline  requirements on
this formulation.  The calculated !£JQ values  ranged from 180 ppn to greater
than 1000 ppm, suggesting the MCPA sodium salt is practically nontoxic to fish.

Five studies were evaluated on  the 52% dimethylamine salt formulation (USEPA,
1973, GS 0017-107; McCann, 1972, 000026923; USEPA,  1972,  GS 0017-104).  All
were acceptable in fulfilling the Guideline requirements  on this formulation.
The calculated I£eg values were greater than 180 ppm for  bluegill and trout.
These findings suggest that the dimethylamine  salt  of MCPA is practically
nontoxic to fish.  ..-,

No studies were submitted on the technicals of the  butoxyetnyl ester, the
butyl ester, the iscoctyl ester, the mixture of butyl/isopropyl  esters,  the
mixture of isobutyl, isopropyl,  and  butyl esters, or the  manufacturing-use
products containing the sodium  salt, the  dimethylamine  salt,  or  the
dietnanolamine salt.

Studies were not submitted on the butoxyetnyl  ester formulation  of  f£PA.
Since this formulation  (emulsifiable concentrate) is used on rice,  96-hour
acute fish studies on trout and bluegill  are required on  each of the
formulated products in order to assess the potential hazard to fish.

One study (Hattula, 1977, 05003234)  was submitted on residue uptake on tne
primary metabolite and contaminant of  MCPA, 4-chloro-o-cresol.  This stuciy
appears scientifically sound; however,  there are no Guideline requirements
regarding residue analysis.  Information  from  this  study  suggests that the
primary metabolite and contaminant of  MCPA, 4-chloro-o-cresol, will
bioaocumulate only moderately   and cause  damage to  gills  and kidneys in fish.

Mixtures of MCPA with Other Active Ingredients

Four studies were submitted on  MCPA  mixtures.  (Sleight,  1973, 0022698;
Bucnanan, 1980,  GS 0017-002; Tooby, 1975, 05020144; Bentley, 1974,
00004512).All were acceptable for fulfilling possible Guideline  requirements.
f'ondak TP658 (dicamba + MCPA) was tested  on rainbow trout and bluegill,
producing toxicity values greater than 1000 mg/1 for the  96-nour acute toxicity
to fisnPresco S (mecoprop + MCPA + 2,3,-6 Trichlorobenzion acid) was tested on
harlequin fisn and produced an  LC5q  =  5600 mg/1.  This  mixture appeared to be
practically nontoxic to fish.   Weeaar  64A/MCPA (2,4-D + MCPA) was tested on
rainbow trout and bluegill, producing  an  LC^Q  >1030  ng/1 and >75 <1000
mg/1, respectively.  These findings  suggested  that  this'   mixture was
practically nontoxic to fish.

Effects Cn Estuarine and Marine Organism

-------
r?..<^ st'j:>i_-s  (contained  in one  r-^irnrence)  were receive and evaluated under
this tonic.  These  studies  are scientifically sound and were acceptable for
use in 6 Hazard asscssaent.

              Author                    H)  .
           Union Carbide             00022673

Estuarire and marine organism  toxicity tests on technical and formulated
pesticides are required to  support  registration if tnere is an intended direct
application  to an estuarine or marine environment, or if the pesticide may be
expected to  enter these environments in significant concentration because of
use or mobility pattern.  These studies include acute LD^Q testing on
shrimp, oysters, and estuarine fish.

The use pattern for MCPA includes rice.  Costal rice acreage in Louisiana and
Texas accounts for  about 792,000 acres.  The proximity of this large acreage
to estuarine or marine environments justifies the need for estuarine and
marine organisms toxicity studies on the  technical, as well as the formulated
product.

MCPA Acid

Ito studies were submitted on MCPA acid.  The Guideline requirements for an
acute L£5Q on estuarine and marine  organisms on tecnnical (acid) MCPA have
not been satisfied.  Depending upon tne results of those studies, additional
cnronic tests on mysid shrijrp  and/or sheepshead minnow nay be required.

Salts and Esters

Ito studies \/ere submitted on tne technicals of tne butyl ester, the
butoxyethyl  ester,  the mixture of the butyl and isopropyl esters, or the
manufacturing-use products  containing the sodium or dimethylamine salts.
Acute testing on estuarine  and marine organisms is required in order to
establish the toxicity of the  technicals.

Acute estuarine and marine  studios  on the butoxyethyl ester formulation is
required because of the use of MCPA on rice.  However, acute studies on the
formulations of the sodium  salt, the dimethylamine salt, and the mixture of
the butyl and isopropyl esters are  not required, since tne inert ingredients
(other than  water)  account  for less than 4% of the total formulation.

Mixtures of  flCPA with Other Active  Ingredients

Two studies  on the  mixture  Mondak 5P43 (dicamba + FCPA) were submitted, but
only one study (Union Carbide, 1975; 000022673) was acceptable for fulfilling
possible Guideline  requirements on  a mixture.  The results of this acute
marine invertebrate test  (LCcQ = 44.8 mg/1) suggest that this mixture is
slightly toxic to grass shrimp.

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Effects on Freshwater Aquatic  Invertebrates

Two studies were received  and  evaluated  under tnis topic.   Doth studies
appearol scientifically sound  and were acceptable  for use  in a  hazard
assessment.

              Author                   ID

            USEPA                    GS  0017-108
            Union Carbide            00022504

In order to establish the  acute  toxicity of MCPA to aquatic freshwater
invertebrates, a 48-hour acute aquatic study  is  required on the technical
material.  Test organisms  should be  first instar Daphnia magna  or early instar
ampnipods, stoneflies, or  nayflies.  Since aquatic uses are involved,
formulated product testing is  also required.
                     ' f
fOA Acid

One acute aquatic study (USEPA,  1976, GS 0017-108) was conducted by the USEPA
laboratory at Beltsville on technical grade MZPA acid (94% a.i.).  Tnis dapnnid
study was acceptable for fulfilling  Guideline requirements.  The calculated 43-
hour LCtjQ value was greater than 180 ppm.  This  finding suggest? that TKTPA
technical (acid) is practically  nontoxic to aquatic freshwater  invertebrates.

Salts and Esters

Ito studies wore submitted  on the technicals of the butyl ester, tne
butoxyethyl ester, the mixture of butyl  and isopropyl esters, or the
manufacturing-use products containing the sodium or dimethylanino salts.
Acute aquatic DC™ testing on  dapnnids will be required to establish tr.e
toxic '•y for the technicals.

Studies were not submitted on  MCPA formulations  (salt and  esters).  Guideline
requirements for acute I£cp testing  on freshwater  aquatic  invertebrates
using these formulations nave  not been satisfied.   The direct application of
JCPA to water (rice use) triggers a  potential hazard to aquatic organisms.  In
order to assess the extent of  this danger, acute aquatic freshwater
invertebrate testing, using the  butoxyethyl ester  formulation,  will be
required.  However, acute  studies on tne formulations of the sodium salt, tne
dimethylamine salt, and the mixture  of the butoxy  and isopropyl esters is not
required, since the inert  ingredients (other  than  water) account for less tnan
4% of each total formulation.

Mixtures of MCPA with Other Active Ingredients

One" study (Union Carbide,  1976,  00022504)  on  the mixture Mondak 5P4R (dicamba +
MCPA) appeared to bo acceptable  for  fulfilling possible Guideline requirements
on e mixture.  The calculated  48-hour aquatic freshwater invertebrate LCeC
value was greater tnan 670 mg/1. This suggests  that Mondak 5P43 is practically
nontoxic to dapnnids.

                                         n

-------
Hiifr'Cts on Riir^r

Ei^i.L scuJies were- received and evaluate  under this topic.  Six studies were
ni:o.utable for determining MCPA toxicity tc birds.

             Author                     ID

              Fink                    0002R293
              Fink                    00004544
              Fink                    00004545
              Parke                   00004H05
              DeWitt                  GS 0017-101

MCPA Acid

In order to establish^the acute toxicity of MCPA to birds,  the following test
is required using MCPA acid:  one avian single-dose oral  study on one avian
species (preferable mallard duck or  bobwhite quail).

Results frcm acute dietary studies  (DeWitt, 1962, GS 0017-101) on nallard
ducks, bobwnite quail, and ring-neck pheasant suggest that  MCPA acid is
practically nontoxic.  The calculated dietary !£CQ  values were greater than
2COO ppn for each species tested.

Pr- .1 ts and Enters

Ito studies wer« submitt«YV on  tne technicals of the  butoxyethyl ester, tho
isooctyl ester, tne butyl ester, the mixture of butyl and isopropyl esters,
the mixture of tno isobutyl,  isopropyl, and butyl esters, or tne mar.uf^cturing-
use products containing  the sodium dinethylamine or diethanolenine salts.
Since these compounds are used on crops where birds nay be  affected, one acute
dietary study (bobwhite  quail) will  be required on  each technical compound to
assess the potential hazard to avian species.

Mixtures of MCPA with Other Active Ingredients

Three studies on mixtures were reviewed (Fink, 1973, 00028293; Fink, 1973,
00004544; Fin);, 1973, 00004545).  All were acceptable for fulfilling possible
Guideline requirements on a mixture.  Mondak TP658  (dicamba + *CPA) was tested
on bobwnite quail and mallard duck in two  eight-day dietary studies.  The acute
LCcQ values were 1155 ppn and 4640 ppn, respectively.  These findings suggest
that this mixture is slightly toxic  to avian species.  Banvel 4S + Dronoxyr.il-
MCPA was tested on mallard duck in an acute dietary study.   The LCcQ v/as
greater than 4640 ppn, suggesting slight toxicity to avians.
            •

Effects on Beneficial Insects

Nine studies were received and evaluated under this topic.   Seven studies were
not acceptable for use in a hazard assessment.  The following two studios were
acceptable.

-------
              Author                        ID

         Stevenson                        05001991
         Glynne Jones and Cornell         05C15G32

Table 8-1;  Toxicity Studies on Beneficial Insects with HCPA

                                                                   Fulfills
                                                                   Guideline
  Species   Fornulation	Results	Author    Date   IDft   Requirements

Honey bee   Technical    Contact LD^    Stevenson 1978  05001991      HA
(Apis                  100 micrograms/
mellifera)           bee. Oral LDjQ
                         >10 micrograms/bee.
                         (Relatively non-
                         toxic.)

Honeybee    Technical'   Relatively non-   Glynne    1954  05015632      HA
                         toxic thrdugh     Jones &
                         oral exposure     Connell

There is sufficient information to characterize MCPA as low in toxicity to
honeybees.  There are curently no Guidelines requirements for evaluating
toxicity to nontarget insects.

-------
A.  G'j!•.':: "•; Use of This  Biblioiirapny

    I.   Content of Bibliography
 This bibliography nas  two  sections:   1]  citations tnat contributed information
useful to the review of the chemical  and  considered to be part of the data base
supporting registrations  under  tr>e  standard;  2]  citations examined and judged
to be inappropriate for use in  developing the standard.  The second section of
tne bibliography is on  file witn tne  Agency,  and is available for review.
Primary sources for studies in  tnis bibliogrpny  have been the body of data
submitted to EPA and its  predecessor  agencies in support of past reulatory
decisions, and tne published  technical literature.

    2.   Units of Bitry

The unit of entry in tnis bibliography is called a "study".  In the case of
published materials, this corresponds closely to an article.  In the case of
unpublisned materials submitted to  tne agency, the Agency has sought to
identify documents at a level parallel to a published article from within the
larger volumes in wnicn they were submitted.   The resulting "studies" generally
navo 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 tnem, .treating thorn as  a single study.

    3.   Identification of  Entries

The entries in tnis bibliography are  sorted by autnor, date of the document,
and title.  Each entry  bears, to the  left of the citation proper, a nine-digit
identifier.  This number  is unique  to tne citations, and should be used at any
time specific reference is  required.   This number is called the "Master Record
Idef  fier", or "MRID".   It is  not  related to tne six-digit "Accession number"
wnich nas been used to  identify volumes of submitted data; see paragraph
4(d)(4) below for a further explanation.

    4.   Form of the Entry

In addition to the Master Record Identifier (MRID), each entry consists of a
bibliograpnic citation  containing standard elements followed, in the case of
materials submitted to  EPA, by  a description of  the earliest ];nown submission.
The bibliographic conventions used  reflect the standards for tne Meric?n
national Standards Insitute (ANSI), expanded to provide for certain special
needs.  Seme explanatory  notes  of specific elements follow:

         a. .  Author

Whenever tne Agency could confidently identify one, the Agency has chosen to
snow a personal author,   bhen no individual was  indentified, the Agency has
shown an identificable  laboratory or  testing facility as autnor.  As a lest
resort, the Agency has  shown  the first knov<-n submitter as author.

-------
         b.   Document Date

When trie date appears as  four digits with  no question marks,  the Agency took it
directly fron the document.  When a four-digit  date  is followed by a question
nark, tne bibiographer 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

This is the third element in the citation. In  some  cases it  has been necessary
for the Agency bibliographers to create  or enhance a document title.  tr\y such
editorial insertions are  contained between square  brackets.

         d.   Trailing Parenthesis
                     • •
For studies submitted"to  us in  the past, the trailing parenthesis include (in
addition to any self-explanatory text) the following elements describing the
earliest known submission.

              1)   Submission Date.  Immediately following the word
                   'received' appears the  date  of  the earliest known submission.

              2)   Administrative Number.   The  next  element,  immediately
following tne work 'under', is  the registration number,  experimental permit
number, petition number,  or other administrative number associated with the
earliest known submission.

              3)   Submitter.  The third element is  tne submitter, following
                   the phrase 'submitted by1,   When  authorship is defaulted to
                   the submitter, this element  is  emitter].

              4)   Volume Identification.   The  final element  in the trailing
                   parenthesis  identifies  the EPA  accession number of the
                   volume in which the original submission cf 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; tne 26th, 123456-Z;
                   and the 27th 123456-M.

-------
               OFFICE OF PESTICIDE PROGRAMS
            ^.^ITPOTITM 55T.R*TT'B.RD RIDLTOGPAPHY
Citations Considered to be Part of the Data Rase Supporting
MRID #
005019071
005008511
000004735
000004730
005004650
005015044
000004493
000004741
                        registrations
                           Ur.der the Standard
 CITATION
 Aberg, B. : Eliasson, L.  (1978) The herbicidal effects of chenoxy
    compounds.  Pages 86-100, In Chlorinated Phenoxy Acids  and
    Their Dioxins: Mode of Action, Health Risks and  Environmental
    Effects, Report from  a Conference;  1977, Stockholm,  Sweden.
    Edited by C. Ramel.   Stockholm, Sweden:  Swedish Natural
    Science Research Council.   (Ecological bulletins (Stockholm),
    no. 27)

 Abou Elfadl, M.M. ; Fahmy, M. (1958) Effect of sodium 2,4-D and
    M.C.P.A. on root nodulation of legumes and soil  microorganisms.
    Agricultural Research Review 36:333-338.

 Akzo Zout Chemie Nederland B.V. .(1973) Spectrophotometric  Determi-
    nation of Chlorophenol in Phenoxy Acetic Acid or Phenoxy  Propi-
    onic Acid and Their Salts with 4-Mino Antipyrine.   Method Mr.
    259.3 dated Feb 12, 1973.   (Unpublished study received  Feb 20,
    1973 under 6305-10; submitted by Robeco Chemicals, Inc.,  New
    York, N.Y.; CDL:02238R-F)

 Akzo Zout Chemie nv (1971) Gas Chromatographic Determination of
    .(Methyl) -(chloro)phenoxyace tic acids and  (Methyl) .(chloro)- ___
    phenoxypropionic acids and Their Salts.  Method  nr.  247.1 dated
    Apr 20, 1971.  (Unpublished study received Feb 20, 1973 under
    6305-10; submitted by Robeco Chemicals, Inc., New York, N.Y.;
    CDL:022388-A)

 Allard, R.W. ; DeRose, H.R. ; Swanson, C.P. (1946) Some effects of
    plant growth-regulators on  seed germination and  seedling
    development.  Botanical Gazette 107: 575-583.

 Allen, F.C. (1966) Tolerance of barley to MCPA and  dicamba.  Paqes
    25-27 , J[n Proceedings of the New Zealand Weed and Pest  Control
    Conference.  Vol. 19.  Hamilton, New Zealand:  New Zealand Weed
    and Pest Control Conference.

 Amchem Products,  Incorporated  (1968) Summary of Performance  Data:
    Brominal Plus.  Summary of  studies  002199-B through  002199-P.
    (Unpublished study received Oct 30, 1968  under 264—239;
    submitted by Union Carbide Agricultural Products Co., Aribler,
    Pa.;(CDL:  002199-A)

 American Cyanamid Company (1973) General Summary.   (Unpublished
    study received Sep 19, 1975 under 241-EX-64; CDL:094696-C)

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

000004609   American Cyanamid Company (1974) General Sumnary.  Stannary of
               studies 224170-R through 224170-V.  (Unpublished study received
               Jan 8, 1975 under 241-EX-64; CDL:224170-Q)

000004701   Bache, C.A.; Hardee, D.D.; Holland, R.F.; Lisk, D.J. (1964) Absence
               of Phenoxyacid herbicide residues in the milk of dairy cows at
               high feeding levels.  Journal of Dairy Science XLVII(3):29B-299.
               (Also ^n unpublished submission received Sep 12, 1968 under
               8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:
               092980-0)

000004702   Bache, C.A.; Lisk, D.J.; Wagner, D.G.; Wagner, R.G. (1964) Elimina-
               tion of 2-Methyl-4-chlorophenoxyacetic acid and 4-(2-Methyl-4-
               chlorophenoxybutyric) acid in the urine from cows.  Journal of
               Dairy Science XLVII(l):93-95.  (Also In unpublished submission
               received Sep 12, 1968 under 8F0676; submitted by Dow Chemical
               U.S.A., Midland, Mich.; CDL:092980-P)

005006168   Bache, C.A.; Lisk, D.J.; Wagner, D.G.; Warner, R.G. (1964)
               Elimination of 2-methyl-4-chlorophenoxyacetic acid and
               4-(2-methyl-4-chlorophenoxybutyric) acid in the urine from
               cows.  Journal of Dairy Science 47(l):93-95.

005012661   Balezina, L.S. (1967) Vliyanie nekotorykh gerbitsidov na razvitie
               pochvennykh vodoroslei.  [Effect of some herbicides on the
               development of soil algae.]  Mikrobiolcgiya.  [Microbiology.]
               XXXVI(1):163-167.

000004570   Ball, R.W.E.; Soundy, M. (1958) 2,4-DB and MCPB in Lucerne:
               Part I.  The Effect of 2,4-DB and MCPB on the Development of the
               Lucerne Plant.  (Preprint, British Weed Control Conference,
               November, 1958; unpublished study received Dec 5, 1960 under
               359^400; prepared by May & Baker, Ltd., Agricultural and Horti-
               cultural Research Station, Eng., submitted by Rhone-Poulenc,
               Inc., Monmouth Junction, N.J.; CDL:023310-C)

000004454   Bendixen, W.E. (1974) Report of Planned Work Accomplished: Bean
               Weed Control—Shield Spraying MCPA and 2,4-D: Project No. 19.
               (Unpublished study received Feb 10, 1976 under 6E1746; prepared
               by Univ. of California, Agricultural Extension Service in copo-
               eration with California, Dept. of Food and Agriculture, Chemis-
               try Laboratory Services, submitted by Interregional Research
               Project No. 4, New Brunswick, N.J.; CDL:095368-D)
                                      I or

-------
 MRID I
 000004512
 000021975
 000004625
                          OFFICE OF PESTICIDE PROGRAMS
                       REGISTRATION ST7'-T1.\'r PIBLIOGRArTY
           Citations Considered to be P*rt of the nata Base Supporting
                        Registrations Under the Standard

            CITATION

            Bentley, R.E. (1974) Bioassay Report Submitted to Afichem Products,
               Inc., Ambler, Pennsylvania: Acute Toxicity of Three Amchem Com-
               pounds to Bluegill (Lepomis macrochirus) and Rainbow Trout
               (Salmo gairdneri).  (Unpublished study received Sep 13, 1974
               under 264-55; prepared by Bionomics, EG&G, Inc., submitted by
               Union Carbide Agricultural Products Co., Ambler, Pa.; CDL:
               131084-B)

            Biesemeier, J.A.; Argevine, D.M. (1979) Inhalation—EPA.  (Unpub-
               lished study received Jul 23, 1979 under 39335-1; prepared by
               Raltech Scientific Services, Inc., submitted by Fallek-Lankro
               Corp., Tuscalcosa, Ala.; CDL:233870-E)

            Bjerke, E.L.; Herman, J.L. (1971) Residues of 2-Methyl-4-chloro-
               phenoxyacetic acid and 2-Methyl-4-chlorophenol in Tissues of
               Beef Calves Fed MCPA.  (Unpublished study received Oct 11, Wl
               under 9F0761; prepared by Dow Chemical Co., submitted by Nation-
               al Agricultural Chemicals Association, industry Task Force on
               Phenoxy Herbicide Tolerances, Washington, D.C.; CDL:091311-F)
- 000004626
            Bjerke,-E.L.; Herman-, -J.t.—fl^T}) ltesix3ues-of-2=Methyl-4-chloro- —
               phenoxyacetic acid and 2-Methyl-4-chlorophenol in Tissues of
               Sheep Fed MCPA.  (Unpublished study received Oct 11,  1971 under
               9F0761; prepared by Dow Chemical Co., submitted by National
               Agricultural Chemicals Association, Industry Task Force on
               Phenoxy Herbicide Tolerances, Washington, D.C.; CDL:091311-G)

005003259   Bjerke, E.L.; 'Herman, J.L.; Miller, P.W.; Wetters, J.H.  (1972)
               Residue study of phenoxy herbicides in milk and cream.  Journal
               of Agricultural and Food Chemistry 20(5):963-967.

005004641   Bollag, J.M.; Helling, C.S.; Alexander, M.  (1967) Metabolism of
               4-chloro-2-methylphenoxyacetic acid by soil bacteria.  Applied
               Microbiology 15(6):1393-1398.

GS 0017-002 Buchanan, S., Pell, I.E., Woodhouse, R.N. (1979) Acute Toxicity  of
               MCPA to Mirror Carp and Rainbow Trout.   (Unpublished  study
               received Nov 19,1980; submitted by Diamond-Shamrock Corp.)

005015003   Bueno, A.J.; Cabanilla, H.C.  (1971) Study on the reaction of
               recommended rice varieties  to early-post and pre-emergence
               herbicides.  Down to Earth  27(3):8-ll.

-------
MRID #

005016555




005003491




005004844




005014225



000021917


000004782
                OFFICE OF PESTICIDE PROGRAMS
             REGISTRATION STANDARD BIBLIOGRAPHY
 Citations Considered to be Part of the Data Base Supporting
              Registrations Under the Standard

  CITATION
                                         /
  Buselmaier, W.; Rcehrborn, G.; Propping, P. (1972)
     Mutagenitaets-Untersuchungen mit Pestiziden im Host-mediated
     assay und mit dem Dominanten Letaltest an der Maus.

  Byford,  W.J.; Prince, J. (1976) Experiments on the effect of
     hormone weedkillers on sugar beet.  Journal of Agricultural
     Science 86(1):135-139.

  Cessna,  A.J.; Grover, R. (1978) Spectre-photometric determination
     of dissociation constants of selected acidic herbicides.
     Journal of Agricultural and Food Chemistry 26(1):289-292.

  Chang, W.L. (1969) Performance of granular herbicides for
     transplanted rice.  Nung Yen Yen Chiu.  [Agricultural
     Research.] 18(4):11-18.

  Chipman, Incorporated (1973) M.C.P. Acid.  Includes undated method.
     (Unpublished study received Jun 20, 1973 under 8203-18; CDL:
     005990-A)  3
  Chipman  Chemical Company, Inc. (1967) Effectiveness and Crop Safety
	Data:-SR3/67. -^Unpublished -study-including summary tables and	
005003765
005006328
005003559
     efficacy reports Port 64.12,  Port 65.4,  Port 65.21, Port 65.22,
     Port 65.28,  Port 66.58,  Port 66.60,  BB.65.100, BB.65.102,
     BB.65.151,  BB.66.7, BB.66.87, C.65.9, C.65.11, C.65.21, C.65.24,
     C.65.40, C.65.42, C.65.57,  C.66.13,  C.66.16, C.66.18, C.66.45,
     C.66.47, C66.49, C.66.50, PA.64.8, PA.65.2 and weed control
     summary 1966,  received Mar 10, 1967 under 359-601; submitted by
     Rhone-Poulenc, Inc., Monmouth Junction,  N.J.; CDL:023320-B)

  Chow,  C.;  Montgomery, M.L.; Yu,  T.C. (1971) Methodology and
     analysis for residues of MCP and 2,4,5-T in wheat.  Bulletin of
     Environmental  Contamination and Toxicology 6(6):576-580.

  Cohen, S.Z.; Zweig, G.; law, M.; Wright, D.; Bontoyan, W.R. (1978)
     Analytical  determination of N  -nitroso compounds in pesticides
     by the  United  States Environmental Protection Agency—a
     preliminary study.  Pages 333-342, Jn Environmental Aspects
     of N -Nitroso Compounds.  Washington, D.C.:  Environmental
     Protection Agency. (IARC scientific publications, vol. 19)

  Collier, R.H.;  Grimes, G.S. (1974) Determination of chlorophenoxy
     acids in formulations by gas-liquid chromatography of their
     trimethylsilyl derivatives.  Journal of the Association of
     Official Analytical Chemists 57(4):781-784.
                                     101

-------
                          OFFICE OF PESTICIDE PROGRAMS
                       REGISTRATION STANDARD BIBLIOGR^P^'
           Citations Considered to be Part of the Data Rase S'Jiooortina
                        Registrations Under the Standard

MRID t      CITATION

005003725   Collins, D.J.; Gaunt, J.K. (1970) The tnetabolic fate of
               4-chloro-2-methylphenoxyacetic acid in peas.  Biochemical
               Journal 118(3):54.

000005552   Conkin, R.A. (1956) Procedures for Determining Residues of MCP
               (2-Methyl-4-chlorophenoxyacetic acid) in Treated Crops.  Method
               dated Oct 29, 1956.  (Unpublished study received Dec IB, 1967
               under 9F0676; prepared by Monsanto Chemical Co., submitted by
               National Agricultural Chemicals Association, Industry Task Force
               on Phenoxy Herbicide Tolerances, Washington, D.C.; CDL:0929R1-A)
                   • s
005004651   Crosby,*D.G.; Bowers, J.B. (1966) Determination of 2,4-D residues
               in animal products.  Bulletin of Environmental Contamination
               and Toxicology 1(3):104-107.

005009423   DaSilva, E.J.; Henriksson, L.E.; Henriksson, E. (1974) Effect of
               pesticides on nitrogen fixation by blue-green algae.  Revista
               de Microbiologia 5(4):73-74.

005005265   DaSilva, E.J.; Henriksson, L.E.; Henriksson, E. (1975) Effect of
               pesticides on blue-green algae and nitrcaen-fixation.  Archives
               of Environmental Contamination and Toxicology 3(2):193-204.

005009865   DaSilva, E.J.; Henriksson, L.E.; Udris, M. (1977) Growth responses
               of mycorrhizal Boletus and Rhizopogon species to pesticides.
               Transactions of the British Mycological Society 68(3):434-437.

005004661   De, B.K.; Mukhopadhyay, S. (1971) Effect of MCPA and Stam F-34 on
               the occurrence of seme nutritional groups of bacteria in the
               rice fields of West Bengal.  International Rice Ccrmission
               Newsletter 20(3):35-40.

000004442   Del Monte Corporation  (1968) MCPA Rer.idues on Peas and Pea Vines:
               Del Monte Code No.  19708.  (Unpublished study received on un-
               known date under 9F0761; submitted by Dow Chemical U.S.A., Mid-
               land, Mich.; CDL:092000-H)

000004443   Del Monte Corporation  (1968) MCPA Residues on Peas and Pea Vines:
               Del Monte Code Mo.  19708.  (Unpublished study received on un-
               known date under 9F0761; submitted by Dow Chemical  U.S.A., Mid-
               land, Mich.; CDL:092000-H)

000004444   Del Monte Corporation  (19??) Trails with the sodium salt of MCPA
               for weed control inpeas.  (Unpublished study conducted by Donald
               W. Davis, Utah State University, togan, Utah; PCC 73-E-21).

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

 CITATION
005011096   DeRose, H.R.  (1946) Persistence of  some plant growth-regulators
               when applied to the soil  in herbicidal  treatments.   Botanical
               Gazette 107:583-589.

000004764   Devine, J.M.  (1970) Report on MZPA  Residues  in  Rough Rice & Rice
               Straw.  Includes two undated methods.   (Unpublished  study re-
               ceived Jan 22, 1971 under 9F0761; prepared by Syracuse Univ. Re-
               search Corp., submitted by National Agricultural  Chemicals Asso-
               ciation, Industry Task Force on  Phenoxy Herbicide Tolerances,
               Washington, D.C.; CDL:091308-L)

GS 0017-101 DeWitt, J.B. et al., Effects of Pesticides on Fish and  Wildlife,
               USDI, FS.W Circ. 143 pp 4,5,33,45, 1962

005012898   Domingo, I.S.; Palis, G.T. (1966) Chemical weed control experiment
               in upland rice at the La  Granja  Experiment Station.   Philippine
               Journal of Plant Industry 31(3):145-156.

005004273   Dorschner, K.P.; Buchholtz,  K.P.  (1956) Wetting ability of aqueous
               herbicidal sprays as a factor  influencing stands  of  alfalfa	
               seedlings.  Agronomy Journal 48(2):59-63.

000025154   Duggan, R.E.; Barry, H.C.; Johnson, L.Y. (1967) Residues in food
               and feed:  Pesticide residues  in total  diet  samples  (II).   Pesti-
               cides Monitoring Journal  1(2):2-12.  (Also In unpublished  sub-
               mission received Nov 5, 1970 under 1F1060; submitted by Wlsicol
               Chemical Corp., Chicago,  111.; CDL:099195-U)

005006190   Edmond, D.B.  (1956) The effect of MCPB (sodium
               2-methyl-4-chlorophenoxybutyrate) on young red clover
               (Trifolium pratense) and  weeds.  New Zealand Journal of
               Science and Technology, Section A 38(4):397-402.

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

MRID #      CITATION

000004659   Elenewski, C.A. ; Wang, T. (1975) AvengeR (CL 84,777): Determi-
               nation of CL 84,777 (l,2-Dimethyl-3,5-diphenyl-lH-pyrazoliun
               methyl sulfate), Bromoxynil  (3,5-Dibromo-4-hydroxylbenzonitrile)
               and MCPA ( 2-Methyl-4-chlorophenoxyacetic acid) Residues in Wheat
               Grain and Straw Following Ground Application of Avenqe Alone and
               in combination with MCPA or Bromoxynil, (Oregon): Report No. C-
               820.  (Unpublished study received Nov 14, 1975 under 6F1703;
               prepared in cooperation with Biodynamics , Inc., submitted by
               American Cyanamid Co., Princeton, N.J.; CDL:094738-AH)
                   • s

000004655   Elenewski, C.A. ; Wang, T. (1975) AvengeR (CL 84,777): Determi-
               nation of CL 84,777 (l,2-Dimethyl-3,5-diphenyl-lH-pyrazolium
               methyl sulfate), Bromoxynil  (3,5-Dibrorro-4-hydroxylbenzonitrile)
               and MCPA (2-Methyl-4-chlorophenoxyacetic acid) Residues in Durum
               Wheat Grain and Straw Following Aerial Application of Avenge
               Alone and in Combination with MCPA or Brcmoxynil, (Minnesota):
               Report No. C-823.  (Unpublished study received Nov 14, 1975 un-
               der 6F1703; prepared in cooperation with Biodynamics, Inc., sub-
               mitted by American Cyanamid Co., Princeton, N.J.; CDL:094733-^D)
005006302   Elliott, B.R.; Lumb, J.M.; Reeves, T.G.; Telford, T.E.  (1975)
               Yield losses in weed- free wheat and barley due to
               post-emergence herbicides.  Weed Research 15 (2): 107-111.

005003256   Elo, H. (1976) Distribution and elimination of
               2-methyl-4-chlorophenoxyacetic acid (MCPA) in male rats.  Acta
               Pharmacologica et Toxicologica 39(1): 58-64.

005004181   Elo, H.; Parvinen, M.  (1976) Effect of sodium
               2-methyl-4-chlorophenoxyacetate on spermatogenesis in the rat.
               Journal of Reproduction and Fertility 48:243-244.

005006041   Erdelska, 0. (1966) The effect of 2-methyl-4-chlorophenoxyacetic
               acid on the development of Hprdeum distichum L. Ovule.
               Biologia Plantarum  8 (2): 117-121.

005008355 " Eronen, L. ; Julkunen,  R. ; Saarelainen, A.  (1979) MCPA residues  in
               developing forest ecosystem after aerial spraying.   Bulletin of
               Environmental Contamination and Toxicology 21(6):791-798.

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MRID f

005003766
                          OFFICE OF PESTICIDE PROGRAMS
                       REGISTRATION STANDARD BIBLIOGRAPHY
           Citations Considered to be Part of the Data Base Supporting
                        Registrations Under the Standard

            err AT ION
            Faulkner, J.K.; Woodcock, D. (1%5) Fungal detoxication.  Part
               VII.  Metabolism of 2,4-dichlorophenoxyacetic and
               4-chloro-2-methylpnenoxyacetic acids by Aspergillus niger  .
               Journal of the Chemical Society :1187-1191.

000028293   Fink, R.; Broughton, W.S., Jr. (1973) Final Report: Eight-Day Die-
               tary LCgQ—Mallard Ducks: Project No. 686-136.  (Unpublished
               study received Feb 18, 1976 under 876-25; prepared by Hazleton
               Laboratories, Inc., submitted by Velsicol Chemical Corp., Chi-
               cago, 111.; CDL:225100-K)
                   ' f
000004544   Fink, R.; Broughton, W.S., Jr. (1973) Final Report: Eight-Day Die-
               tary LC^—Bobwhite Quail: Project No. 686-137.  (Unpub-
               lished study received Dec 11, 1974 under 876-45; prepared by
               Hazelton Laboratories, Inc., submitted by \felsicol Chemical
               Corp., Chicago, 111.; CDL:003548-E)

000004545   Fink, R.; Broughton, W.S., Jr. (1973) Final Report: Eight-Day Die-
               tary LCcQ—^Mallard Ducks: Project No. 6R6-13S.  (Unpublished
               study received Dec 11, 1974 under 876-45; prepared by Hazelton
               Laboratories, Inc., submitted by \felsicol Chemical Corp.,
               Chicago, 111.; CDL:003548-F)

005003428   Fisher, P.R.; Appleton, J.; Pemberton, J.M. (1978) Isolation and
               characterization of the pesticide-degrading plasmid pJPl
               from Alcaligenes paradoxus  .  Journal of Bacteriology
               135(3):798-804.

005005788   Fletcher, W.W.; Raymond, J.C. (1956) Toxicity and breakdown of
               "hormoneM herbicides.  Nature 178(4525):151-152.

005005860   Flinchum, W.T.; Stansel, J.W. (1972) Effects of applications of
               phenoxy herbicides on Bluebelle rice yields and dayflower
               control.  Pages 21-24, Jjn Texas Agricultural Experiment Station
               Progress Report.  College Station, Tex.:  Agricultural
               Experiment Station.

005005531   Flinchum, W.T.; Westfall, D.G.; Stansel, J.W. (1973) Effects of
               phenoxy herbicides on yield of first and second crop rice.
               Pages 1-3, Jto Texas Agricultural Experiment Station Progress
               Report No. PR-3177.  College Station, Tex.:  Texas Agricultural
               Experiment Station, TexasA & M University.
                                      m

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

 CITATION
005019954   Frank, R.; Sirons, G.J.; Ripley, B.D. (1979) Herbicide
               contamination and decontamination of well waters in Ontario,
               Canada, 1969-78.  Pesticides Monitoring Journal 13(3):120-127.

000004473   Frost, K.R., Jr. (1966) Weed Control Headlines 1965-1966.   (Unpub-
               lished study received Nov 6, 1967 under 464-398; prepared by
               South Dakota State Univ., submitted by Dow Chemical U.S.A.,
               Midland, Mich.; CDL:003622-R)

005006578   Fryer, 3.D.; Kirkland, K. (1970) Field experiments to investiqate
               long-term effects of repeated applications of ?CPA, tri-allate,
               simazine and linuron: report after 6 years.  Weed Research
               10(2):133-158.

005014496   Fykse, H. (1975) Untersuchungen ueber Sonchus arvensis L.:  II.
               Translokation von 14C-MCPA unter verschiedenen Bedinqunqen.

005013377   Fykse, H. (1976) Untersuchungen ueber Sonchus arvensis L.;  III.
               Metabolismus von MCPA.   [Investigations with Sonchus arvensis
               L: III.  Metabolism of MCPA.  Weed Reserach 16(5):309-316.
000004513   Gabriel, K.L. (1971) Draize Eye Irritation—Rabbits.   (Unpublished
               study received Nov 16, 1971 under 264-36; prepared by Biosearch,
               Inc., for Amchem Products, Inc., submitted by Union Carbide
               Agricultural Products Co., Ambler, Pa.; CDL:100823-A)

005005451   Gamar, Y.; Gaunt, J.K. (1971) Bacterial metabolism of
               4-chloro-2-methylphenoxyacetate: formation of glyoxylate by
               side-chain cleavage.  Biochemical Journal 122(4):527-531.

005004565   Gardner, K.; Overton, K.C. (1960) Analysis of MCPA/TBA herbicide
               formulations: II.  A gas-liquid chromatograDhic method for the
               determination of 4-chloro-2-methyl phenoxyacetic acid.
               Analytica Chimica Acta 23:337-345.

005003416   Gaunt, J.K.; Evans, W.C. (1971) Metabolism of
               4-chloro-2-methylphenoxyacetate by a soil pseudomonad:
               preliminary evidence for the metabolic pathway.  Biochemical
               Journal 122(4):519-526.

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

MRID #      CITATION

000041634   Gilbert, C.M., Hopkins, R.; MacDonald, C.M.; et al. (1978) The Met-
               abolic Fate of (14O-MPCA (4-Chloro-l-methyl(Ring-U-14C) phenox-
               yacetic acid) in the Rat:  Report No., 1334R3-277/1.
               (Unpublished study including submitter surmary, received Sep 4,
               1980 under 2217-EX-2; prepared by Hazleton Laboratories Europe,
               Ltd. and Boots Co., Ltd., cubmitted by PBI-Cordon Corpt., Kanasa
               City, Kans.; CDL:243193-A)

005005888   Gillberg, B.O. (1971) On the effects of some pesticides
               on Rhizobium and isolation of pesticide-resistant mutants.
               Archives of Microbiology 75(3):203-208.

005015632   Glynne Jones, G.D.; Cornell, J.U. (1954) Studies of the toxicity
               to worker honey-bees (  Apis mellifera L.) of certain chemicals
               used in plant protection.  Annals of Applied Biology
               41(2):271-279.

000020121   Grogan, B.; Banner, J.; Hayner, J.; et al. (1970) Diuron plus
               Bromoxynil—Winter Wheat.  (Unpublished study including letter
               dated Jun 1, 1970 from A.A. Baber to file, received Jan 26, 1971
               under 352-247; submitted by E.I. du Pont de Nemours & Co.,
               Wilmington, Del.; CDL:002858-A)

005015630   Grossbard, E. (1971) The effect of repeated field applications of
               four herbicides on the evolution of carbon dioxide and
               mineralization of nitrogen in soil.  Weed Research
               11(4):263-275.

000004766   Guardigli, A. (1970) MCPA Residues in Flax Seed: Field Test Project
               No. STP 69-26; 69-27.  Includes method no. 104 dated Nov 25,
               1969.  (Unpublished study received Jan 22, 1971 under 9F0761;
               prepared by Rhodia, Inc. in cooperation with Univ. of Minnesota
               and North Dakota State Univ. of Agriculture and Applied
               Science, submitted by National Agricultural Chemicals Associa-
               tion , Industry Task Force on Phenoxy Herbicide Tolerances, Wash-
               ington, D.C.; CDL:091308-O)

000021920   Guardigli, A. (1973) Rhodia Analytical Method No. 122: Electron
               Capture GLC Residue Measurement of Total 2-Methyl-4-chlorophen-
               oxyacetic acid, MCPA, after Formation of Its Nitro Derivatives
               and Esterification to Its Methyl Ester, and TLC Residue Determi-
               nation of Total Chlorophenols.  Method dated Oct 1973.  (Unpub-
               lished study received Oct 3, 1975 under 6E1681; submitted by
               Rhone-Poulenc Chemical Co., Monmouth Junction, N.J.; CDL:
               097351-B)

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

 CITATION
000004787   Guardigli, A. (1974) Rhodia Analytical Method No. 123.  Includes
               two methods dated March 1974.  (Unpublished study received Jan
               30, 1976 under 359-534; prepared by Rhodia, Inc., submitted by
               Rhone-Poulenc, Inc., Monmouth Junction, N.J.; CDL:222737-A)

000004788   Guardigli, A. (1974) MCPB Sodium Salt in Peas: Aerial Applications.
               (Unpublished study received Jan 30. 1976 under 359-534; prepared
               by Rhodia, Inc., submitted by Rhone-Poulenc, Inc., Monmouth
               Junction, N.J.; CDL:222737-B)

000004449   Guardigli, A.; Henckler, P.M. (1973) Final Summary: MCPA and Phenol
               Metabolite in Pasture and/or Range Grasses.  (Unpublished study
               received on unknown date under 9F0761; prepared by Rhodia, Inc.,
               submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:0920ni-F)

000022569   Gurd, M.R.; Harmer, G.L.M.; Lessel, B. (1964) The Toxicity of Meco-
               prop and MCPA to Rats: Report No. 1254.  (Unpublished study re-
               ceived Jan 21, 1965 under unknown admin, no.; prepared by Roots
               Pure Drug Co., Ltd., submitted by ; CDL:102704-A)

000004822   Guyton, C.L. (1977) Procedures for the Measurement of Asulam, MCPA,
               Sulfanilamide and Acetylasulam in/on Flax: Forages, Straw, Seed
               and Mill-Processed Flax Seed Fractions.  Method no. 143 dated
               Jul 1977.  (Unpublished study received Apr 13, 1979 under 359-
               662; prepared by Rhodia, Inc., submitted by Rhone-Poulenc, Inc.,
               Monmouth Junction, N.J.; CDL:238025-B)

000021977   Harwell, C. (1978) A Gas Chromatography Method for Determination of
               2 Methyl 4 Chlorophenoxyacetic acid and Impurities in Technical
               MCPA.  Method no. lA/1/2 dated Jan, 1978.  (Unpublished study
               received Jul 23, 1979 under 39335-1; submitted by Fallek-Lankro
               Corp., Tuscalcosa, Ala.; CDL:238B71-A)

005003795   Hattula, M.L.; Elo, H.; Reunanen, H.; Arstila, A.U.; Sorvari, T.E.
               (1977) Acute and subchronic toxicity of
               2-methyl-4-chlorophenoxyacetic acid (MCPA) in male rat.  I.
               Light microscopy and tissue concentrations of MCPA.  Bulletin
               of Environmental Contamination and Toxicology 18(2):152-15B.

005016652   Helling, C.S. (1971) Pesticide mobility in soils: II.
               Applications of soil thin-layer chromatography.  Proceedings of
               the Soil Science Society of America 35(5):737-743.

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

MRID «      CITATION
 005004203   Helling, C.S.; Turner, B.C.'(1968) Pesticide mobility:

               determination by soil thin-layer chromatography.  Science
               162(3853):562-563.

000004492   Herman, J.L.; Bjerke, E.L. (1970) Determination of MCPA and 2-Meth-
               yl-4-chlorophenol in Milk and Cream by Gas Chromatography.
               Method no. fCR 70.17 dated Dec 2, 1970.  (Unpublished study re-
               ceived Jan 11, 1971 under 9F0761; prepared by Dow Chemical Co.,
               submitted by National Agricultural Chemicals Association, Indus-
               try Task Force on Phenoxy Herbicide Tolerances, Washington,
               D.C.i; CDL:091313-J)

000004627   Herman, J.L.; Bjerke, E.L. (1971) Determination of MCPA and 2-
               Methyl-4-chlorophenol in Cattle and Sheep Tissues by Gas Chrcma-
               tography.  Method ACR 71.10 dated Jun 24, 1971.  (Unpublished
               study received Oct 11, 1971 under 9F0761; prepared by Dow Chem-
               ical Co., submitted by National Agricultural Chemicals Associa-
               tion, Industry Task Force on Phenoxy Herbicide Tolerances,
               Washington, D.C.; CDL:091311-H)

000004491   Herman, J.L.; Bjerke, E.L.; Getzendaner, M.E. (1970) Residue of
               2-Methyl-4-chlorophenoxyacetic acid and 2-Methyl-4-chlorophenol
               in Milk and Cream from Cows Fed MCPA.  (Unpublished study re-
               ceived Jan 11, 1971 under 9F0761; prepared by Dow Chemical Co.,
               submitted by National Agricultural Chemicals Association, Indus-
               try Task Force on Phenoxy Herbicide Tolerances, Washington,
               D.C.; CDL:091313-1)

000004624   Herman, J.L.; Bjerke, E.L.; Getzendaner, M.E. (1971) Residues of
               2-Methyl-4-chlorophenoxyacetic acid and 2-Methyl-4-chlorophenol
               in Milk and Cream from Cows Fed MCPA.  (Unpublished study re-
               ceived Oct 11, 1971 under 9F0761; prepared by Dow Chemical Co.,
               submitted by National Agricultural Chemicals Association, Indus-
               try Task Force on Phenoxy Herbicide Tolerances, Washington,
               D.C.; CDL:091311-E)

005021236   Herzel, F.; Schmidt, G. (1979) (Testing the leaching behavior of
               herbicides on lysimeters and small columns.]  WaBoLu-Berichte
                                     IV5"

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

MRID *      CITATION

000004632   Higham, J.W. (1974) The Gas Chromatographic Determination of MCPA
               (2-Methyl-4-chlorophenoxyacetic acid) and Bronoxynil  (3,5-Dibro-
               no-4-hydroxybenzonitrile) in Fortified Wheat Grain and .Straw:
               Report No. C-575.  (Unpublished study received Nov 14, 1975
               under 6F1703; prepared in cooperation with State Univ. of New
               York~0swego, Lake Ontario Environmental Laboratory,  submitted
               by Anerican Cyanamid Co., Princeton, N.J.; CDL:094738-D)

000004633   Higham, J.W. (1975) The Gas Chromatographic Determination of MCPA
               (2-Methyl-4-chlorophenoxyacetic acid) and Bronoxynil  (3,5-Dibro-
               mo-4-*hydroxybenzonitrile) in Fortified Wheat Grain and Straw:
               Report No. C-804.  (Unpublished study received Nov 14, 1975
               under 6F1703; prepared in cooperation with Biodynamics, Inc. and
               State Univ. of New York—Oswego, Lake Ontario Environmental
               Laboratory, submitted by American Cyanamid Co., Princeton, N.J.;
               CDL:094738-G)

000005570   Higham, J.W.; Feeny, R.W. (1974) AvengeR (CL 84,777): Determi-
               nation of Bromoxynil (3,5-Dibromo-4-hydrcxylen7onitrile) and
               MCPA (2-Methyl-4-chlorophenoxyacetic acid) Residues in \Jheat
               Grain Following Ground^ Postemergence Application Where Each.Was
               Applied in Combination with Avenge (l,2-Dimethyl-3,5-diphenyl
               pyrazolium methyl sulfate), (Oregon): Report No. C-578.  (Unpub-
               lished study received Nov 14, 1975 under 6F1703; prepared in
               cooperation with State Univ. of New York—Oswego, Lake Ontario
               Environmental Laboratories, submitted by American Cyanamid Co.,
               Princeton, N.J.; CDL:094738-Z)

000004650   Higham, J.W.; Feeny, R.W. (1974) AvengeR (CL 84,777): Determi-
               nation of MCPA (2-Methyl-4-chlorophenoxyacetic acid)  Residues in
               Wheat Grain and Straw Following Ground, Postemergence Applica-
               tion in Combination with Avenge (1,2-Dimethyl 3,5-diphenyl
               •pyrazolium methyl sulfate), (Montana): Report No. C-577.  (Un-
               published study received Nov 14, 1975 under 6F1703; prepared in
               cooperation with State Univ. of New York—Oswego, Lake Ontario
               Environmental Laboratories, submitted by American Cyanamid Co.,
               Princeton, N.J.; CDL:094738-X)
                                      lit

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

MRID *      CITATION

000005567   Higham, J.W.; Feeny, R.W.; Cheston, K.G.; Snyder, E.H.; Wingfield,
               C.B. (1975) AvengeR (AC 84,777): Determination of CL 84,
               777 (l,2-Dimethyl-3,5-diphenyl pyrazolium methyl sulfate), Bro-
               moxynil (3,5-Dibromo-4-hydroxylbenzonitrile) and MCPA (2-Methyl-
               4-chlorophenoxyacetic acid) Residues in Barley Grain and Straw
               Following Ground Application (Colorado): Report No. C-594.  (Un-
               published study received Jan 8, 1975 under 241-EX-64; prepared
               in cooperation with Lake Ontario Environmental Laboratory, sub-
               mitted by American Cyanamid Co., Princeton, N.J.; CDL:224170-T)
000004611
000004613
005014853
Higham, J.W.; Feeny, R.W.; Snyder, E.H; KUshnak, G.; O'Hare, T.R.
   (1975) AvengeR (CL 84,777): Determination of CL 84,777 (1,
   2-Dimethyl-3,5-diphenyl pyrazolium methyl sulfate), Brcnoxynil
   (3,5-Dibromo-4-hydroxylbenzonitrile) and MCPA (2-Methyl-4-
   chlorophenoxyacetic acid) Residues in Barley Grain and Straw
   Following Ground Application of Avenge Alone and in Combination
   with MCPA, Bronoxynil, 2,4-D and Bromoxynil plus MCPA: Montana:
   Report No. C-593.  (Unpublished study received Jan 8, 1975 under
   241-EX-64; prepared in cooperation with Montana State Univ. and
   Lake Ontario Environmental Laboratory, submitted by American
   Cyanamid Co., Princeton, N.J.; CDL:224170-S)

Higham, J.W.; Feeny, R.W; Cheston. K.G.; Snyder, E.H.; Nowatski,
   R.; O'Hare, T.R. (1975) AvengeR (CL 84,777): Determination
   of CL 84,777 (l,2-Dimethyl-3,5-diphenyl pyrazolium methyl sul-
   fate), Brcnoxynil (3,5-Dibromo-4-hydroxylbenzonitrile) and MCPA
   (2-Methyl-4-chlorophenoxyacetic acid) Residues in Barley Grain
   and Straw Following Ground Application of Avenge Alone and in
   Combination with MCPA, Bromoxynil or 2,4-D (North Dakota): Re-
   port No. C-596.  (Unpublished study received Jan 8, 1975 under
   241-EX-64; prepared in cooperation with Lake Ontario Environ-
   mental Laboratory, submitted by American Cyanamid Co., Prince-
   ton, N.J.; CDL: 224170-V)

Holroyd, J. (1957) The breakdown of MCPA, 2,4-D and CIPC in soil.
   Pages 793-801, In Proceedings of the 3rd British Weed Control
   Conference; 1956, Blackpool, England.  Vol. 2.  Droitwich,
   England:  British Weed Control Conference.
                                     in

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MRID #

000004756
000004757
000004775
000004776
005015747


005020356



000004993



000041637
                OFFICE OF PESTICIDE PROGRAMS
             REGISTRATION STANDARD BIBLIOGRAPHY
 Citations Considered to be Part of the Data Base Supporting
              Registrations Under the Standard

  CITATION

  Holsing, G.C. (1968) Final Report: 13-Week Dietary/Oral Administra-
     tion — Dogs: Project No. 517-101.  (Unpublished study received
     Jan 22, 1971 under 9F0761; prepared by Hazleton Laboratories,
     Inc., submitted by National Agricultural Chemicals Association,
     Industry Task Force on Phenoxy Herbicide Tolerances, Washington ,
     D.C.; CDL-.091309-A)

  Holsing, G.C. (1970) Final Report: 13-Week Dietary Administration —
     Dogs: Project No. 517-107.  (Unpublished study received Jan 22,
     1971 Bunder 9F0761; prepared by Hazleton Laboratories, Inc., sub-
     mitted by National Agricultural Chemicals Association, Industry
     Task Force on Phenoxy Herbicide Tolerances, Washington, D.C. ;
     CDL:091309-B)

  Holsing, G.C. ; Kundzin, M. (1963) Final Report: Three-Month Dietary
     Administration — Rats: Project No. 517-100.  (Unpublished study
     received Dec 18, 1970 under 9F0761; prepared by Hazleton Lab-
     oratories, Inc., submitted by Dow Chemical U.S.A., Midland,
     Mich.; CDL:>094531-B)

-  Hols ing, -G.C. ; Kundzin ,"M.— ( 1970 ) -Final -Report : ^tree-Month -Pietary-
     Administration — Rats: Project No. 517-106. ~ (Unpublished study
     received Dec 18, 1970 under 9F0761; prepared by Hazleton Lab-
     oratories, Inc., submitted by Dow Chemical U.S.A., Midland,
     Mich.; CDL:094531-C)

  Hopkins, R. ; Rain, J.M. (1971) The effect of marine pollutants on
     Laminarea hyperboria.  Marine Pollution Bulletin 2(5):75-77.
            Hutber, G.N.; Rogers, L.J.; Smith, A.J.  (1979)
               pesticides on the growth of cyanobacteria .
               Allgemeine Mikrobiologie 19 (6): 397-402.
                                                 Influence of
                                                 Zeitschrift fur
  IR-4 Project at Rutgers, the State University (1974) MCPA—Sorghum
     Residue Studies.   (Unpublished study received Oct 3, 1975 under
     6E1681; CDL:097351-A)

  Irvine, L.F.H.; Whittaker, D. ; Hunter, J.; et al. (1980) M.C.P.A.
     Oral Teratogenicity Study in the Dutch Belted Rabbit:  Report
     No. 1737R-277/5.  (Unpublished study including submitter
     summary, received Aug 28, 1980 under 2217-EX-2; prepared by
     Hazleton Laboratories Europe , Ltd . , submitted by PBI-Gordon
     Corp., Kansas City, Kans.; CDL:243170-A)

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MRID f
000004439
005004434



005003757


005004656



005008955



005004190"


005015461



005005526



000004576




005005091


005015041
               OFFICE OF PESTICIDE PROGRAMS
            REGISTRATION STANDARD BIBLIOGRAPHY
Citations Considered to be Part of the Data Base Supporting
             Registrations Under the Standard

 CITATION

 Jensen, D.J.; Miller, P.W.; Berhenke, L.F. (1973) Total Residues of
    MCPA and 2-Methyl-4-chlorophenol in Tissues of Animals Fed MCPA:
    Report No. GH-C-689.  (Unpublished study received on unknown
    date under 9F0761; submitted by Dow Chemical U.S.A., Midland,
    Mich.; CDL:092000-D)

 Jensen, H.L.; Petersen, H.I. (1952) Decomposition of hormone
    herbicides by bacteria.  Acta Agriculturae Scandinavica
    2:215-231.

 Jensen, H.L.; Petersen, H.I. (1952) Detoxication of hormone
    herbicides by soil bacteria.  Nature (London) 170(4314):39-40.

 Jensen, H.L.; Sorensen, H. (1952) The influence of some organic
    sulfur compounds and enzyme inhibitors on Nitrosomonas europaea.
    Acta Agricultural Scandinavica 2:295-304.

 Jones, D.I.R.; Knight, A.G.; Smith, A.J. (1967) Attempted suicide
    with herbicide containing HCPA.  Archives of Environmental
    Health 14(2"): 363-366.
 Johnson, "H.R'.M.; Kbumides," 0." (1965) A further case of'M.C.P.A.
    poisoning.  British Medical Journal 2(5462):629-630.

 Kaufman, P.B.; Crafts, A.S. (1956) Responses of the rice plant to
    different formulations and methods of application of 2,4-D,
    MCP, and 2/4,5-T.  Hilgardia 24(15):411-453.

 Kavanagh, B.V.; Posner, A.M.; Quirk, J.P. (1977) The adsorption of
    phenoxyacetic acid herbicides on goethite.  Journal of Colloid
    and Interface Science 61(3):545-553.

 Kemish Vaerk Koge A/S (1972) Determination of MCPA in MCPA-Isopro-
    pylester.  Method dated Feb 18, 1972.  (Unpublished study
    received Mar 6, 1972 under 961R-10; submitted by Trans Chemic
    Industries, Inc., New York, N.Y.; CDL:123581-A)

 Kingham, H.G.; Fletcher, J.T. (1963) The effects of MCPA and
    2,3,6-TBA on glasshouse cucumbers.  Weed Research 3(3):242-245.

 Kirkwcod, R.C.'; Dalziel, J.; Matlib, A.; Somerville, L. (1969)
    Seme factors influencing the activity of foliage applied MCPA
    and MCPB in Vicia faba  .  Pages 650-658, In Proceedings of the
    9th British Weed Control Conference; 1968.  Vol. 2.  Droitwich,
    England:  British VJeed Control Conference.

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

 CITATION
005004272   Kirkwood, R.C.; Dalziel, J.; Matlib, A.; Somerville, L.  (1972) The
               role of translocation in selectivity of herbicides with
               reference to MCPA and MCPB.  Pesticide Science 3(3):307-321."

005019112   Kulinska, D. (1967) Wjplyw herbicydow na pobieranie tlenu przez
               glebe.  [Effect of herbicides on oxygen uptake by soil.]
               Roczniki Nauk Rolniczych, Seria A.   [Annals of Agricultural
               Sciences, Series A.] 93(1):125-130.
                   • s
005003678   Kunert, G. (1959) Der Einfluss einiger Herbicide auf die
               Lipaseaktivitaet von Aspergillus niger  .   [Effect of some
               herbicides on the lipase activity of Aspergillus niger   .]
               Naturwissenschaften 46(21):603.

005021559   Lallukka, R. (1974) Rester av TCA, linuron, dicamba och MCPA i
               skordeprcdukter efter odling i behandlad jord—resultat  fran
               finska undersokningar.  [Residues of TCA, linuron, dicaTiba and
               MCPA in crops grown in treated soil—results of Finnish
               research.]  Pages 114-115, _In Herbicider i Jord—\terkan  pa
               Kulturvaxter.   [Herbicides in the Soil—Effects on Crop
               Plants.]  Uppsala, Sweden:  Agricultural College of Sweden,
               Department of Plant Husbandry.

005004440   Large, E.G.; Dillon Vfeston, W.A.R. (1951) Ear distortion in barley
               and other cereals caused by spraying with MCPA and 2,4-D.
               Journal of Agricultural Science 41(4):338-349.

005005848   Lavake, D.E.; Chenault, E.W.; Wiese, A.F.; Vandiver, C.W.  (1971)
               Tolerance of sorghum hybrids to postemergence herbicides.
               Pages 74-105, Jn Texas Agricultural Experiment Station Progress
               Report.  College Station, Tex.:  Texas Agricultural Experiment
               Station.

005005795   Leafe, E.L. (1962) Metabolism and selectivity of plant-growth
               regulator herbicides.  Nature 193(4814):485-486.

005006390 . Lee, S.A.  (1972) Effects of six post-emergence herbicides on young
               pineapple.  Malaysian Pineapple 2:47-52.

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MRID #

000004765
000004622
005016100
               OFFICE OF PESTICIDE PROGRAMS
            REGISTRATION STANDARD BIBLIOGRAPHY
Citations Considered to be Part of the Data Base Supporting
             Registrations Under the Standard

 CITATION

 Leng, M.L., ccmp. (1970) Summary of Residue Data for MCPA on Rice
    and Rice Byproducts.  (Unpublished study received Jan 22, 1971
    under 9F0761; prepared by Dow Chemical Co. in cooperation with
    Univ. of California—Davis, Dept. of Environmental Toxicology,
    Agricultural Toxicology Laboratory, submitted by National Agri-
    cultural Chemicals Association, Industry Task Force on Phenoxy
    Herbicide Tolerances, Washington, D.C.; CDL:091308-M)

 Leng, M.L., comp. (1971) Summary of Residue Data for 2,4-D; 2,4,5-
    T; Silvex and MCPA in Milk, Meat and Meat Byproducts.  (Unpub-
    lished study received Oct 11, 1971 under 9F0761; prepared bv
    Dow Chemical Co., submitted by National Agricultural Chemicals
    Association, Industry Task Force on Phenoxy Herbicide Toler-
    ances, Washington, D.C.; CDL:091311-C)

 Loos, M.A. (1971) Metabolism of phenoxy herbicides by plants and
    soil micro-organisms.  Pages 291-304, Bi Pesticide Terminal
    Residues: Invited Papers from the International Symposium on
    Pesticide Terminal Residues; Feb 17-19, 1971, Tel Aviv, Israel.
    Edited by A.S. Tahori.  London:  Butterworths.
005003910
005012194
005016319
005016939
005003450
 Loos, M.A.; Bollag, J.M.; Alexander, M. (1967) Phenoxyacetate
    herbicide detoxication by bacterial enzymes.  Journal of
    Agricultural and Food Chemistry 15(5):858-860.

 Loos, M.A.; Schlosser, I.F.; Mapham, W.R. (1979) Phenoxy herbicide
    degradation in soils: quantitative studies of 2,4-D- and
    MCPA-degrading microbial populations.  Soil Biology and
    Biochemistry 11 (4)-.377-385.

 Luckwill, L.C.; Campbell, A.I. (1957) The tolerance of fruit crops
    to certain selective and pre-emergence herbicides.  Pages
    539-542, In Proceedings of the 3rd British Weed Control
    Conference; 1956, Blackpool, England.  Droitwich, England:
    British Weed Control Conference.

 Magnusson, J.; Ramel, C.; Eriksson, A.  (1977) Mutagenic effects of
    chlorinated phenoxyacetic acids in Drosophila nelanogaster.
    Hereditas 87:121-123.

 Malina, M. (1971) Collaborative study of infrared analysis of
    dicamba-2-methyl-4-chlorophenoxyacetic acid and
    dicaraba-2,4-dichlorophenoxyacetic acid formulations.  Journal
    of the Association of Official Analytical Chemists
    54(3):706-710.

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MRID *
               OFFICE OF PESTICIDE FHDGRWE
            REGISTRY ION STANDARD BIBLIOGRAPHY
Citations Considered to be Part of the Data Base Supporting
             Registrations Under the Standard

 CITATION
GS 0017-110 Marquardt and Luoe (1955) Jour. Agr. Food Chem. 3:51

005004185   Matell, M.; Lindenfors, S. (1957) Thermodynamic dissociation
               constants of 2,4-dichlorophenoxyacetic acid (2,4-D) and some
               related plant growth regulators.  Acta Chemica Scandinavica
               11(2):324-328.

005015451   Matlib, M.A.; Kirkwood, R.C.; Patterson, J.D.E. (1971) Binding of
               certain substituted phenoxy-acids by bovine serum albumin.
               Weed'Research 11(2/3):190-192.

000026928   McCann, J.A.; Pitcher, F. (1972)  [MCP Weed Killer: Toxicity to
               Bluegill]: Test No. 512.   (U.S. Agricultural Research Service,
               Pesticides Regulation Div., Animal Biology Laboratory, unpub-
               lished report.)

005019347   Metting, B.; Rayburn, W. (1979) The effects of the pre-emerqence
               herbicide di-allate and the post-er^nergence herbicide MCPA on
               the growth of some soil algae.  Phycologia 18(3):269-272.
05013388
005013713
000004438
 Meadly, G.R.W.; Pearce, G.A.  (1957) The tolerance of subterranean
    clover  (Trifolium subterraneum L) to chlorinated
               phenboxyacetic derivatives.  Journal of the Department of
               Agricultural, Western Australia 6:357-361, 364-368,  371-374,
               380.
                                                                  377-
000003472
 Miller, J.H.; Kempen, H.M.; Wilkerson, J.A.; Foy, C.L.  (1963)
    Response of Cotton to 2,4-D and Related  Phenoxy Herbicides.
    Washington, D.C.:  U.S. Department of Agriculture, Agricultural
    Research Service. (USDA technical bulletin no. 1289)

 Miller, P.W.; Jensen, D.J. (1973) Study of  Alkaline Hydrolysis  for
    Determination of Residues of MCPA and 2-Methyl-4-chloroohenol  in
    Milk: Report No. GH-C 628.  Method dated Feb 13, 1973.   (Un-
    published study received on unknown date under 9F0761; submitted
    by Dow Chemical U.S.A., Midland, Mich.;  CDL:092000-C)

 Mobil Chemical Company  (1973) Experiment: Wheat Herbicide
    Screening.  (Unpublished study received  May 7, 1974  under
    4G1505; CDL:093987-AR)

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

MRID #      CITATION

000004773   Monsanto Company (1956) [MCP Residue in and Recovery of MCP from
               Garden Peas, Flax, Rice and Oatsl.  (Unpublished study received
               Oct 19, 1971 under 8F0676; submitted by National Agricultural
               Chemicals Association, Industry Task Force on Phenoxy Herbicide
               Tolerances, Washinton, D.C.; CDL:091183-O)

000004441   Monsanto Company (19??) Petition for the establishment of
               tolerances for the pesticide chemical 2-methyl-4-
               chlororophenoxyacetic acid (MCPA) on raw agricultural
               conmodities, Section D:  The results of tests on the amount of
               residues remaining, including a description of the analytical
               method used.  (Submitted by the National Agricultural Chemicals
               Association Industry Task Force on Phenoxy Herbicide
               Tolerances.  December 12, 1967).

00005552   Monsanto Company (1956) Procedures for determining residues of MCP
              (2-methyl-4-chlorophenoxyacetic acid/in treated crops.

000005575   Montgomery, M.L. (1970) MCPA Residue in Wheat: Oregon State Univer-
               sity Report.  Includes methods dated Jun 17, 1970 and Apr 1,
               1970.  (Unpublished study including summary report and letters
               dated Apr 2, 1970 from M.L. Montgomery to Don T. Lillie and J.A.
               Ignatoski, received Jan 22, 1971 under 9F0761; prepared by Ore-
               gon State Univ., Dspt. of Agricultural Chemistry, submitted by
               National Agricultural Chemicals Association, Industry Task Force
               on Phenoxy Herbicide Tolerances, Washington, D.C.; CDL:09130S-T)

005004849   Moore, R.M. (1950) Differential effects of certain phenoxyacetic
               acid compounds and phenylcarbamates on plant species: II.
               Effects of foliage applications with special reference to
               yields of wheat.  Australian Journal of Agricultural Research
               44:401-412.
005021735   Mueller, F. (1976) Summary.  Pages 141-144, In Translokation von
               14C-markiertem MCPA in verschiedenen EntwTcklungsstadien
               mehrjaehriger Unkraeuter.   fTranslocation of 14C-Labelled MCPA
               at Different Stages of Development of Perennial Weeds. 1
               Berlin, Germany:  \ferlag Paul Parey. (Acta phytomedica, vol. 4)

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

MRID *      CITATION

005005548   Nakajima, S.; Naito, N.; Tani, T. (1973) Microbial transformation
               of 2,4-D and its analogues.  Chemical and Pharmaceutical
               Bulletin 21(3):671-673.

005002356   Nelson, N.H.; Faust, S.D. (1969) Acidic dissociation constants of
               selected aquatic herbicides.  Environmental Science and
               Technology 3(11):1186-1188.

005020766   Noll, M.; Bauer, U. (1974) Phormidium autumnale als
               Indikatororganismus fuer algizide Substanzen im wasser.
                   • t

000004447   Palmer, A.K.; Lovell, M.R. (19??) Effect of MCPA on Pregnancy of
               the Mouse.  (Unpublished study received on unknown date under
               9F0761; prepared by Huntingdon Research Centre, England, sub-
               mitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092001-C)

005015694   Parascan, D. (1966) Cercetari privind actiunea ierbicidelor asupra
               semintelor de molid in timpul germinatiei lor.  [Herbicide
               action on the spruce seed during germination.1  Revista
               Padurilor.  [Forestry Review.] 81(10):543-547.

000004805   Parke, G.St.E.; Terrell, Y. (1974) Report: Eight Day Dietary LC50
               Study of Anchem Weedar Sodium MCPA in Bobwhite Ouail and Mallard
               Ducks.  (Unpublished study received Jul 15, 1975 under 264-55;
               prepared by Cannon Laboratories, Inc. for Amchem Products, Inc.,
               submitted by Union Carbide Agricultural Products Co., Ambler,
               Pa.; CDL:132039-A)

000021979   Paudler, W.W. (1979) Analyses of N-Nitroso Compounds.  (Unpublished
               study received Jul 23, 1979 under 39135-1; prepared by Univ. of
               Alabama, Dept. of Chemistry, Mass Spectroscopy Laboratory, sub-
               mitted by Fallek-Lankro Corp., Tuscalcosa, Ala.; CDL:238R73-A)


000026927   Pitcher, F.G. (1973)  [Spot Treat: Toxicity to Bluegilll: Test
               No. 609.  (U.S. Environmental Protection Agency, Pesticides Reg-
               ulation Div., Agricultural Research Center, Animal Biology Lab-
               oratory, unpublished report.)

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                          OFFICE OF PESTICIDE PROGRAMS
                       .REGISTRAT ION STANDARD BIBLIOGRAPHY
           Citations Considered to be Part of the Data Base Supporting
                        Registrations Under the Standard

MRID *      CITATION

005003770   Popham, R.D.; Davies, D.M.  (1964) A case of M.C.P.A. poisoning.
               British Medical Journal  1(5384):677-678.

005009237   Propping, P.; Buselmaier, W.; Poehrborn, G. (1973) Kritiscne
               Betrachtung ueber die intra-animale Kultur von Mikrcorganismen,
               eine Methode zum Nachweis chemisch induzierter Mutationen.
00021973


00021976


00021974
Raltech Scientific Services, Inc. (19??) MCPA dermal
    New Zaland white strain rabbits.
                                                                      study in
           Raltech Scientific Services, Inc.  (19??) MCPA primary dermal
               irritation study in New Zealand white strain rabbits.

           Raltech Scientific Services, Inc.  (19??) MCPA primary dermal eye
              irritation study in New Zealand white strain rabbits.
00021972   Raltech Scientific Services, Inc.  (19??) MCPA Oral defined LD,
005013116
005004197
000004594
005015046
              study in Sprague-Dawley albino rats.
                                                             '50
 Reynolds, J.D.; Proctor, J.M.; Hind, R.A. (1957) Studies with
    phenoxybutyric herbicides in peas, 1955-56.  Pages
    499-513, In Proceedings of the 3rd British Weed Control
    Conference; 1956, Blackpool, England.  Droitwich, England:
    British Weed Control Conference.

 Rhodes, A.; Templeman, W.G. (1947) Effect of 4-chloro-2-methyl
    phenoxyacetic acid on the mineral content and growth of plants
    letter.  Nature 160(4076):825-826.

 Rhodia, Incorporated (1971) Phenoxy Herbicides on Stubble Crop
    Rice.  (Unpublished study received Nov 21, 1973 under 359-170;
    submitted by Rhone-Poulenc, Inc., Monmouth Junction, N.J.; CDL:
    230485-B)

 Robertson, M.M.; Kirkwood, R.C. (1967) Differential uptake and
    movement as a factor influencing selective toxicity of MCPA and
    MCPB.  Pages 269-277, ^n Proceedings of the 8th British Weed
    Control Conference; 1966.  Vol. 1.  Droitwich, England:
    British Weed Control Conference.

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MRID #
                          OFFICE OF PESTICIDE PROGRAMS
                       REGISTRATION STWDARD BIBLIOGRM^Y
           Citations Considered to be Part of the Data Base Supporting
                        Registrations Under the Standard

            CITATION
005006391   Rojas-Garciduenas, M. ; Ruiz, M.A. ; Carrillo, J. (1962) Effects of
               2,4-D and MCPA on germination and early growth.  Weeds
005017929
000023687
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005005247
00fn03508
005013749
000022698
            Rolencova, H. (1978) Stanoveni nekterych pesticidnich latek v
               biologickem materialu.  [Determination of sere pesticides in
               biological material.]  \feterinarstvi.  [Veterinary Medicine. 1
               29(4):177-179.

            Rydrych, D. ; Behrens, R. ; Wallace, K. ; et al. (1972) [Residues from
               Varidus Chemicals on Grains! .  (Unpublished study received Jan
               3, 1973 under unknown admin, no.; prepared in cooperation with
               Univ. of Minnesota and others, submitted by Velsicol Chemical
               Corp., Chicago, 111.; CDL:120182-A)

            Sanad, A.J. (1971) Untersuchungen ueber Aufnahme und Translokation
               von 14C-markierten Herbiziden in Agrostemna githago L.
               und Tussilago farfara L.   [Studies of the uptake and
               translocation of 14C-labelled herbicides in Agrostemma

            Sattar, M.A.; Paasivirta, J.  (1979) Effects of MCPA on the
               germination and root system of cereal crops.  Chemosuhere
               8(4): 201-203.

            Seiler, J.P. (1979) Phenoxyacids as inhibitors of testicular m\
               synthesis in male mice.  Bulletin of Environmental
               Contamination and Toxicology 21 (1/2): 89-92.

            Sen, K.M. (1960) Studies on the Influence of Some Auxin Herbicides
               on Grass-seed Crops.  Wageningen, Netherlands:  Centrum vcor
               Landbouwpublikaties en Landbouwdocumentatie .  (Verslagen van
               Landbouwkundige Onderzoekingen no. 66.11)

            Sleight, B.H., III (1973) Acute Toxicity of Mondak to Rluegill
               (Lepomis.macrochirus) and  Rainbow Trout  (Salmo.gaird neri)
               Report No. 040280.   (Unpublished study received May 2T,  19"? 3
               under unknown admin, no.;  prepared by Bionomics, Inc., submitted
               by Velsicol Chemical Corp., Chicago, 111.; CD:128293-A)

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

MRID #      CITATION

000004448   Soderquist, C.J.j Crosby, D.G. (1974) The Dissipation of  4-Chlo-
               ro-2-methylphenoxyacetic acid (MCPA) in  a  Rice Field.  Includes
               four methods dated Apr 15, 1974.  (Unpublished study received
               on unknown date under 9F0761; prepared by  Univ. of California—
               Davis, Dept. of Environmental Toxicology,  submitted  by Dow Chem-
               ical U.S.A., Midland, Mich.; CDL:092001-E)

005003445   Soderquist, C.J.; Crosby, D.G. (1975) Dissipation of
               4-chloro-2-methylphenoxyacetic acid  (MCPA) in a rice field.
               Pesticide Science 6(1):17-33.
                    ' *
005012269   Sokolov, M.S.; Knyr, L.L.; Strekozov, B.P.; Agarkov, V.D. (1975)
               Osobennosti povedeniya propanida, yalana,  2M-4Kh i 2,4-D v
               risovykh orositel'nykh sistemakh Kubani.   [Behavior  of
               propanide, yalan, MCPA and 2,4-D in rice irrigation  systems of
               the Kuban River.]  Khimiya v Sel'skom Khozyaistve.   [Chemistry
               in Agriculture.] 13(3):224-234.

005010497   Sokolov, M.S.; Riyr, L.L.; Strekozov, B.P.; Agarkov, V.D.;
               Chubenko, A.P.; Kryzhko, B.A. (1974) Povedenie nekotorykh
               gerbitsidov v usloviyakh risovoi orositel'noi sistemy.   [The
               behavior of some herbicides under the conditions of  a rice
               irrigation system.]  Agrokhimiya.  [Agricultural Chemistry.1
               (3):95-106.

005020404   Scrmer, K. (1970) Beeinflussung der Nitrifikation und des
               Stickstoffhaushaltes in Bceden durch verschiedene
               Pflanzenschutzmittel.  [Effect of various  pesticides on
               nitrification and nitrogen transformations in soils.]
               Landwirtschaftliche Forschung, Sonderheft  25:22-30.

000021962   Song, L. (1977) Formal Report of Analysis: Contract No. 000563.
               Undated method.  (Unpublished study received  Jul 12, 197R  under
               39335-7; prepared by Thermo Electron Corp., submitted by Fallek-
               Lankro Corp., Tuscalcosa, Ala.; CDL:236544-A)

000004995   St. John, L.E., Jr. (1965?) MCPA.  Pages 439-454, In By N.P
               (Also In unpublished submission received Jan  18, 1975 under
               241-EX-64; submitted by American Cyanamid  Co., Princeton,
               N.J.; CDL:224170-Z)

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

MRID *      CITATION

000004724   St. John, L.E., Jr. (1967) MCPA.  Paqes 445-454, ^n Analytical
               Methods for Pesticides, Growth Regulators and Food Additives:
               \folume 5.  Edited by G. Zweig.   Hew York: Academic Press.   (Al-
               so In unpublished submission received Sep 12, 1968 under RF0676;
               submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092980-\P)

005019284   State Institute of Agricultural Chemistry, Finaldn (1977) Residue
               Analysis of the Official Testing of Pesticides, 1976.  Helsinki,
               Finland: State Institute of Agricultural Chemistry.  (State
               Institute of Agricultural Chemistry publication No. 12)
                    • s
005015452   Steenson, T.I.; Walker, N. (1956) Observations on the bacterial
               oxidation of chlorophenoxyacetic acids.  Plant and Soil
               VIII(1):17-32.

005004430   Steenson, T.I.; Walker, N. (1957) The pathway of breakdown of
               2:4-dichloro- and 4-chloro-2-methyl-phenoxyacetic acid by
               bacteria.  Journal of General Microbiology 16(1):146-155.

005013551   Steenson, T.I.; Walker, N. (1958) Adaptive patterns in the
               bacterial oxidation of 2:4-dichloro- and	    -	 	
               4-chloro-2-methyl-phenoxyacetic acid.  Journal of General
               Microbiology 18(3):692-697.

005012650   Stevens, T.; Grorud, R.B. (1979) High pressure liquid
               chrcmatography of ester and salt formulations of
               2-methyl-4-chlorophenoxyacetic acid.  Journal of the
               Association of Official Analytical Chemists 62(4):738-741.

005001991   Stevenson, J.H. (1978) The acute toxicity of unformulated
               pesticides to worker honey bees (Apis mellifera L.).  Plant
               Pathology 27(1):38-40.

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

MRJD *      CITATION

000004568   Suzuki, H.K. (1977) Dissipation of Banvel, Bromoxynil or MCPA or
               Combination Thereof in Two Soil Types: Report No. 181.   (Unpub-
               lished study received Nov 2, 1977 under 876-25; prepared  in co-
               operation with International Research and Development Corp.;
               submitted by Velsicol Chemical Corp., Chicago, 111.; CDL:
               232171-B)

005009727   Synek, M.; Tibenska, M.; Vteresikova, M. (1973) Znehodnotenie
               pcdzemnych vod dikotexon (Na-sol'ou kyseliny
               2-methyl-4-chlorfenoxycctovej).  [Contamination of ground
               waters with dikotex (Na-salt 2-methyl-4-chlorophenoxyacetic
               acid:]  Bratislavske Lekarske Listy.  [Bratislava Medical
               News.] 59(2):203-207.

005003614   Synerholm, M.E.; Zimmerman, P.W. (1945) The preparation of  some
               substituted phenoxy alkyl carboxylic acids and their properties
               as growth substances.  Contributions from Boyce Thompson
               Institute 14:91-103.

005020337   Talbot, F.; Foster, R.T., inventors; Imperial Chemical Industries,
               assignee (1952) Improvements in or relating to the production
               of soluble salts of methylchloropnenoxyacetic acids.  British
               patent specification 664,069.  Jan 2.  7 p.

005020338   Talbot, F.f inventor; Imperial Chemical Industries, assignee
               (1949) Improvements in or relating to
               2-methyl-4-chloro-phenoxyacetic acid.  British patent
               specification 623,217.  May 13.  4 p.

000004443   Thornburg, W. (1973) MCPA Residues in Peas: A Summary of Residue
               Data.  (Unpublished study received on unknown date under 9F0761;
               prepared by Del Monte Corp., submitted by Dow Chemical U.S.A.,
               Midland, Mich.; CDL:092000-1)

005003431   Tin, U.; Baruah, P.; Baruah, H.K. (1949) Biological effects of
               methoxone on water hyacinth.  Science and Culture 15(3):106-109.

005020144   Tooby, T.E.; Hursey, P.A.; Alabaster, J.S. (1975) The acute
               toxicity of 102 pesticides and miscellaneous substances  to
               fish.  Chemistry and Industry (London) (12):523-526.

005004188   Torstensson, L. (1974) Effects of MCPA, 2,4,5-T, linuron and
               simazine on some functional groups of soil microorganisms.
               Swedish Journal of Agricultural Research 4(3):151-160.

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

MRID #      CITATION

005004429   Torstensson, L. (1975) Effects of bentazon and dinoseb on soil
               microorganisms and on the Rhizobium-Leguminosae symbiosis.
               Swedish Journal of Agricultural Research 5(4):177-l«3.

005008552   Torstensson, N.T.L. (1975) Degradation of 2,4-D and MCPA in soils
               of low pH.  Pages 262-265, Jjn Pesticides: IUPAC Third
               International Congress; Jul 3-9, 1974, Helsinki, Finland.
               Edited by F. Coulston and F. Korte.  Stuttgart, West Germany:
               George Thieme.  (Environmental Quality and Safety, Supplement,
               vol., 3)

005004649   Torstensson, N.T.L.; Stark, J.; Goransson, B. (1975) The effect of
               repeated applications of 2,4-D and MCPA on their breakdown in
               soil.  Weed Research 15(3):159-164.

005004846   Tottman, D.R.; Davies, E.L.P. (1978) The effect of herbicides on
               the root system of wheat plants.  Annals of Applied Biology
               90(1):93-99.
                         j

005016148   Toure, I.M.y Stenz, E. (1977) Der Einfluss ausgewaehlter Herbizide
               auf Bakteriophagen urid EscherichTa"c61T  ;(Tne~acttbn~of
               selected herbicides on bacteriophages and Escherichia coli  ~.1
               Zentralblatt fuer Bakteriologie, Parasitenkunde,
               Infektionskrankheiten und Hygieine, Abteilung II 132:163-177.

000041635   Tucker, M.L.r Irvine, L.F.H. (1978) MCPA Oral Teratogenicity Dose
               Ranging Study in Rabbits: Report No. 684R-277/4.   (Unpublished
               study including submitter summary, received Sep 4, 1980 under
               2217-EX-2; prepared by Hazleton Laboratories Europe, Ltd., sub-
               mitted by PBI-Gordon Corp., Kansas City, Kans.; CDL:243196-A)

000022673   Union Carbine Corporation (1975?) Acute Toxicity of Mondak 5P48 to
               Grass Shrimp, Palaemonetes Vulgaris and Fiddler Crabs, Una
               Pugilator.  (Unpublished study received Feb 28, 1979 under 876-
               45? submitted by Velsicol Chemical Corp., Chicago, 111.;
               CDL:237738-A)

000022504 _  Union Carbide Corporation (1976) Acute Toxicity of Mondak 5P48 to
               the V7ater Flea Daphnia magna Straus.  (Unpublished study
               received Aug 31, 1976 under 876-45; submitted by Velsicol
               Chemical Corp., Chicago, 111.; CDL:225539-A)

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

MRID *      CIT«riCN

GS 0017-104U.S. EPA 1972. Report on the toxicity of MCPA dimethylamine  salt
                52.2% a.i.  (Midlnd MCP Weed Killer) to bluegill and rainbow
                trout. (U.S. EPA, Chemical and Biological  Investigation Branch,
                Beltsville, Md.; Static Jar Test Nos. 512, 11/72;  525,  12/72;
                unpublished report).

GS 0017-105 U.S. EPA 9173.  Report en the toxicity of MCPA, sodium salt 24%
               a.i. (Spot Treat) to bluegill.  (U.S. EPA,  Chemical and
               Biological Investigation Branch, Beltsville, Md.; Static Jar
               Test No. 628, 9/73; unpublished report).

GS 0017-106 U.S. EPA 1973. Report on the toxicity of MCPA, sodium  salt  24%,
               a.i. (Weedar sodium MCPA) to bluegills (U.S. EPA, Chemical and
               Biological Investigation Branch Beltsville, Md.; Static  Jar Test
               No. 693, 10/73; unpublished report.

GS 0017-107 U.S. EPA 1973. Report on the toxicity of MCPA, dimethylamine salt
               52.1% a.i. (Dow MCP Amine Weed) to rainbow  trout and bluegills
               (U.S. EPA, Chemical and Biologist Investigation Branch,
               Beltsville, Md.; Static Jar Test Nos. 553;  3/73 and 580,  5/73;
               unpublished report).-

GS 0017-108 U.S. EPA 1976. Report on the Toxicity of MCPA  94% active  ingredient
               (technical grade) to rainbow trout, Daphnia magna and  bluegill.
               (U.S. EPA, Chemical and Biological Investigation Branch,
               Beltsville, Md.; Static Jar Test No. 927, 1/19/76; Test  No. 936,
               2/2/76; Test No. 942, 2/9/76; and Test No.  972, 4/21/76;
               unpublished report).

000004549   \felsicol Chemical Corporation (1965) Flax.  (Unpublished  study re-
               ceived Jan 28, 1966 under 876-25; prepared  in cooperation with
               North Dakota State Univ. of Agriculture and Applied Science,
               Dept. of Agronomy and Univ. of Minnesota; CDL:022209-A)

000005569   Velsicol Chemical Corporation (1972) Summary:  [Tank Mixtures of
               Dicamba + Bromoxynil and Dicamba + Bromoxynil + MCPA for Weed
               Control].  (Unpublished study received Jan  3, 1973  under 876-25;
               CDL:005050-A)

000004566   \felsicol Chemical Corporation (1972) Wheat (Fall Seeded): Report
               No. 123.  (Unpublished study received May 21, 1973  under 876-45;
               prepared in cooperation with Northwestern Agricultural Research
               Center; CDL:021027-A)

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

MRJD #      CITATION

 000004541   Velsicol Chemical Corporation  (1974) Summary of Mondak  Residue

               Studies—Winter Wheat.  (Unpublished study including  Velsicol
               Report #147 and 1150, received Dec 11, 1974 under 876-45; CDL:
               003548-A)

005019175   Verona, 0. (1948) Effetti di alcuni erbicidi selettivi sulla
               microflora, in particolare, del terreno.   [Effect of  sone
               selective herbicides on microflora, particularly of the  soil.1
               Annali della Facolta di Agraria, Universita di Pisa,   fAnnals
               of the Faculty of Agriculture of the University of Pisa.l
               9:189^199.

005003548   Vintikova, H.; Skrdleta, V.; Srogl, M. (1965) The sensitivity  of
               nodule bacteria to several herbicides.  Pages 264-263, _In Plant
               Microbes Relationships: Proceedings of a Symposium on
               Relationships Between Soil Microorganisms and Plant Roots;  Sen
               24-28, 1963, Prague.  Edited by J. Macuira and V. Vancura.
               Prague, Czechoslovakia:  Academia.

005003752   Vogel, E.; Chandler, J.L.R. (1974) Mutacenicity testinq  of
               cyclamate and some pesticides in Drosophila melanogaster.
               Experientia 30(6):621-623.

005004390   Vyas, L.N.; Garg, R.K. (1974) Reversal of the effect of  growth
               inhibitors by gibberellic acid and indole acetic acid.
               Bicchemie and Physiologic der Pflanzen 166(5/6):549-554.

005015458   Way, J.M. (1962) The effects of sub-lethal doses of MCPA on the
               morphology and yield of vegetable crops: I.  Lettuce. Weed
               Research 2(4):233-246.

005015457   Way, J.M. (1963) The effects of sub-lethal doses of MCPA on the
               morphology and yield of vegetable crops: II.  Cabbage,
               cauliflower and Brussels sprouts.  Weed Research 3(1):11-25.

005015459   Way, J.M. (1963) The effects of sub-lethal doses of MCPA on the
               morphology and yield of vegetable crops: III.  Carrots and
               parsnips.  Weed Research 3(2):9R-108.

005015456   Way, J.M. (1963) The effects of sub-lethal doses of MCPA on the
               morphology and yield of vegetable crops: IV.  French  and broad
               beans.  Weed Research 3(4):312-321.

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

MRID #      CITATION

005019963   Way, J.M. (1964) The effects of sub-lethal doses of MCPA on the
               morphology and yield of vegetable crops: V.  Beet, spinach,
               turnip and onion.  Weed Research 4(1):12-23.

005015754   Way, J.M. (1964) The effects of sub-lethal doses of MCPA on the
               morphology and yield of vegetable crops: VI.  Comparison with
               2,4-D, 2,4,5-T, mecoprop and 2,3,6-TBA.  Weed Research
               4(4):319-337.

005015407   Wehr, N.B.; Klein, D.A. (1971) Herbicide effects on Bdellovibrio
               bacteriovorus parasitism of a soil pseudomonad.  Soil Biology
               and Biochemistry 3(2):143-149.

000004589   Welch, J. (1974) Final Report: District Project No. 244274-004.
               (Unpublished study received Mar 24, 1976 under 359-170; prepared
               by Rhodia, Inc., submitted by Rhone-Poulenc, Inc., Monnouth
               Junction, N.J.; CDL:223772-N)

000005558   Welch, J. (1974) Product Development Department: Final Renort:
               District Project No. 244274-003.  (Unpublished study received
               Mar 24, 1976 under 359-170; prepared by Rhodia, !nc*> submitted
               by Rhone-Poulenc, Inc., Monnouth Junction, N.J.; CDL:223772-L)

005006301   Wiedman, S.J.; Appleby, A.P. (1972) Plant growth stimulation by
               sublethal concentrations of herbicides.  Weed Research
               12(l):65-74.

005006526   Wilkinson, V.; Lucas, R.L. (1969) Effects of herbicides on the
               growth of soil fungi.  New Phytology 68(3):709-719.

000004453   Winterlin, M.; Radosivich, S.R. (1974) Report of Analysis: Environ-
               mental Toxicology Report No. 3445.  Includes undated method.
               (Unpublished study received Feb 10, 1976 under 6E1746; prepared
               by Univ. of California—Davis, Dept. of Environmental Toxicol-
               ogy, submitted by Interregional Research Project No. 4, New
               Brunswick, N.J.; CDL:095368-C)

000005577   Wirth, M.; Wasco, J.L. (19??) MCP-/amine Weed Killer: Evaluation of
               Formulation M-3539.  Includes undated method.  (Unpublished
               study received Jul 17, 1970 under 464-147; submitted by Dow
               Chemical U.S.A., Midland, Mich.; CDL:003427-A)

005003566   Yasuda, M.; Maeda, H. (1972) Teratogenic effects of 4-chloro-2-
               methylphenoxyacetic acid ethylester (MCPEE) in rats.
               Toxicology and Applied Pharmacology 23(2):326-333.
                                      IV5

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MRID #
                          OFFICE OF PESTICIDE PROGRAMS
                       REGISTRATION STANDARD BIBLIOGRAPHY
           Citations Considered to be Part of the Data Ease Supporting
                        Registrations Under the Standard

            CITATION
GS 0017-109 Yip and Ney (1966) Analysis of 2,4-D residues  in milk and forage.
               Weeds 14:167.

005021603   Zauner, E.; Bronn, W.K.; Dellveg, H.; Tressl,  R. (1979)
               Hemmwirkung von Nebenkanponenten der Ruebennelasse und von
               Pflanzenschutzmitteln auf die Atmung und Gaerung von Hefe
               ( Saccharcnyces oerevisiae).   [Inhibitor activity of
               impurities of beet molasses and plant protectants on the
               respiration and fermentation of yeast ( Saccharomyces )
                   . ^                                   «HMMMVW^M«^^^^^^^^^^^^

005004970   Zetterberg, G. (1979) Mechanism of the lethal  and mutagenic
               effects of phenoxyacetic acids in Saccharonyces oerevisiae   .
               Mutation Research 60(3): 291-300.

005005846   Zweig, G. ; Snerma, J. (1972) 2,4-Dichlorophenoxyacetic acid.
               Pages 630-635, In Analytical Methods for Pesticides and Plant
               Growth Regulators.  Vol. VI: Gas Chromatographic Analysis.  Mew
               York:  Academic Press.

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