August, 1987
                                     DICAMBA
                                 Health Advisory
                             Office of Drinking Water
                       U.S. Environmental  Protection Agency
                                                               DRAFT
I.  INTRODUCTION

        The Health Advisory (HA) Program,  sponsored  by  the Office of Drinking
   Water (ODW), provides information on the health effects, analytical method-
   ology and treatment technology that would  be  useful  in dealing with the
   contamination of drinking water.   Health Advisories  describe nonregulatory
   concentrations of drinking water contaminants at  which adverse health effects
   would not be anticipated to occur over  specific exposure durations.  Health
   Advisories contain a margin of safety to protect  sensitive members of the
   population.

        Health Advisories serve as informal technical guidance to assist Federal,
   State and local officials responsible for  protecting public health when
   emergency spills or contamination situations  occur.  They are not to be
   construed as legally enforceable Federal standards.  The HAs are subject to
   change as new information becomes available.

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

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    Dicamba
                      August, 1987
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II. GENERAL INFORMATION AND PROPERTIES

    CAS No.  1918-00-9

    Structural Formula
                                 Cl
                        3,6-Dichloro-2-methoxy-benzoic acid
    Synonyms
         0  Banes, Banex, Banlen, Banuel D, Banvel, Brush buster, Dianat, Dianate,
            Dicambe, Mediben, Mondak, MDBA, Velsicol Compound R
    Uses
         0  Herbicide used to control broadleaf weeds in field and silage corn,
            grain sorghum, small grains, asparagus, grass seed crops, turf,
            pasture, rangeland, and non-cropland areas such as fence rows,
            roadways and wastelands.  For control of brush and vines in non-
            cropland, pasture and rangeland areas (Meister, 1983).

    Properties  (Berg, 1986; CHEMLAB, 1985; Meister, 1983; Windholz et al., 1983;
                Worthing, 1983)
            Chemical Formula
            Molecular Weight
            Physical State  (at 25"C)
            Boiling Point
            Melting Point
            Density
            Vapor Pressure  (20°C)
            Specific Gravity
            Water Solubility  (20°C)
            Log Octanol/Water Partition
              Coefficient
            Taste Threshold
            Odor Threshold
            Conversion Factor
CQH6C1203
221.04
Crystals

114 to 116°C

3.75 x 10~3 mm Hg

6,500 mg/L at 25CC
3.67 (calculated)
    Occurrence
            Dicamba has been found in 249 of 624 surface water samples analyzed
            and in 39 of 275 ground water samples  (STORET,- 1987).  Samples were
            collected at 148 surface water  locations and 229 ground water locations
            dicamba was found in  12 states.  The 85th percentile of all non-zero
            samples was 0.15 ug/L in surface water and 0.07 ug/L in ground water.

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     Dicamba                                                     August, 1987

                                          -3-
             The maximum concentration found  in surface water was 3.3 ug/L,  while
             in ground water it was  0.8 ug/L.

     Environmental Fate

          0  In several aerobic soil metabolism studies,  dicamba (acid or salt form
             not specified)  had half-lives  of  1 to 6 weeks in sandy loam, heavy
             clay, silty clay,  clay  loam, sand and silt loam soils at 18 to  38°C
             and 40 to 100%  of  field capacity.  Degradation rates decreased  with
             decreasing temperature  and soil  moisture (Smith, 1973a,b; Smith,  1974;
             Smith and Cullimore,  1975; Suzuki, 1978;1979).

          0  For the dimethylamine salt,  half-lives in sandy loam and loam soils
             ranged from 17  to  32  days (Altom and Stritzke, 1973).  Phytotoxic
             residues, detected by a non-specific bioassay method, have persisted
             in aerobic soil for almost 2 years (Sheets,  1964; Sheets et al.,
             1968).

          0  Based on soil thin-layer chromatography (TLC), dicamba (acid or salt
             form not specified) is  highly  mobile in sandy loam, silt loam,  sandy
             clay loam, clay loam, loam,  silty clay loam  and silty clay soils
             (Helling, 1971; Helling and Turner, 1968).

          0  The free acid of dicamba and the dimethylamine salt were not appre-
             ciably adsorbed to any  of five soils ranging from heavy clay to loamy
             sand (Grover and Smith, 1974).  The dicamba  degradation product,
             3,6-dichlorosalicylic acid,  adsorbed to sandy loam (30%), clay  and
             silty clay (55%) (Smith, 1973a,b; Smith and  Cullimore, 1975).

          0  Losses of 12 to 19% of  the applied radioactivity from nonsterile  soils
             indicated that metabolism contributes substantially more to l4C-dicamba
             losses than does volatilization (Burnside and Levy, 1965; 1966).

          0  Under field conditions, dicamba  (acid or salt form not specified) had
             half-lives of 1 to 2  weeks in  a  clay and a sandy loam soil when applied
             at 0.27 and 0.53 Ib/A.   At either application rate, less than 30  ppb
             of dicamba remained after 4 weeks (Scifres and Allen, 1973).  In
             another study,  using  a  nonspecific bioassay  method of analysis,
             dicamba phytotoxic residues dissipated within 2 years in loam and
             silty clay loam (Burnside et al., 1971).

          0  Ditchbank field studies indicated vertical movement of dicamba  in
             soil; the soil  layers at 6 to  12 inches contained a maximum of  0.07 ppm
             and 0.28 ppm in canals  treated at 0.66 and 1.25 Ib/A, respectively
             (Salman et al., 1972).
III. PHARMACOKINETICS

     Absorption

          0  Atallah and Yu (1980)  reported  that mice,  rats,  rabbits and dogs
             administered single oral doses  of 14C-dicamba (99% purity,

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    Oicamba                                                     August, 1987

                                         -4-
            approximately).  100 mg/kg)  excreted an average of 85% of the admini-
            stered dose in  urine in the 48 hours after dosing.

         0  Similar findings were reported for rats by Tye and Engel (1967) (96%
            excreted in 24  hours) and by Whitacre and Diaz (1976) (83% excreted
            in 24 hours).  The data indicate that dicamba is rapidly absorbed
            from the gastrointestinal tract.

    Distribution

         0  The retention of dicamba (99% purity, approximately 100 mg/kg) was
            investigated in rats, mice,  rabbits and dogs following single doses
            by oral intubation (Atallah and Yu, 1980).  Tissue levels 16 hours
            after treatment were low.  Tye and Engel (1967) also found low residue
            levels of dicamba in kidneys, liver and blood.  The data indicate
            that dicamba does not accumulate in mammalian tissues.

    Metabolism

         0  The metabolism  of 14c-dicamba (99% purity) was investigated in mice,
            rats, rabbits and dogs after administration of single oral doses at
            approximately 100 mg/kg (Atallah and Yu, 1980).  Between 97 to 99%
            of the dicamba  was recovered unchanged in the urine of all four
            species*  3,6-Dichloro-2-hydroxybenzoic acid (DCHBA, a metabolite)
            was not detected in any urine sample at a level greater than 1% of
            the dose.  There was also a small amount of unknown metabolites
            totaling about 1%.

    Excretion

         0  Atallah and Yu  (1980) investigated the excretion of 14C-dicamba (99%
            purity) after a single oral dose (approximately 100 mg/kg) in mice,
            rats, dogs and  rabbits, and reported that 67 to 93% of the administered
            dose was excreted in urine of the four species within 16 hours.  The
            compound was found to a lesser degree in feces (0.5 to 5.7%) and
            various tissues (0.17 to 0.5%) 16 hours postdosing.


IV. HEALTH EFFECTS

    Humans ,

         0  The Pesticide Incident Monitoring System data base revealed 10
            incident reports involving humans from 1966 to March 1981 for
            dicamba alone (U.S.  EPA, 1981).  Six of the ten reported incidents
            involved spraying operations.  No concentrations were specified.
            Exposed workers developed muscle cramps, dyspnea, nausea, vomiting,
            skin rashes, loss of voice or swelling of cervical glands.  Four
            additional incidences resulted in coughing and dizziness in one child
            involved in an undescribed agricultural incident.  Three children who
            sucked mint leaves from a ditch bank previously sprayed with dicamba
            were asymptomatic.

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Oicamba                                                     August, 1987
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Animals

   Short-term Exposure

     0  Reported acute oral LD$Q  values for technical  dicamba [85.8% active
        ingredient (a.i.)]  range  from 757 to 1,414 mgAg (Witherup et al.,
        1962) in rats.  The acute oral LD$Q in mice has  been reported to be
        >4,640 mg/kg (Kettering Laboratory, 1962)  and  316 mg/kg in hens
        (Roberts et al.,  1983).

     0  An acute inhalation LC50  of >200 mg/L was  reported in rats (IRDC,  1973).

     0  The neurotoxic effects of dicamba in hens  were studied by Roberts
        et al. (1983).  Technical dicamba (86.2% a.i.) was administered per os
        (10 hens/dose) in doses of 0, 79, 158 or 316 mg/kg.  Two groups of
        ten hens each were dosed  at 316 mg/kg.  The various groups were
        observed for 21  days following treatment.   No  signs of ataxia were
        observed at any dose level tested.  Histopathological evaluation of
        nervous tissue from 13 hens treated at 316 mg/kg demonstrated
        sciatic nerve damage in 6 hens (46%).  The authors attributed this
        alteration to prolonged recumbency rather than a direct effect of
        dicamba.  Based on the absence of delayed  neurotoxicity and sciatic
        nerve damage, a NOAEL of  158 mg/kg is identified for this study.

     0  Rats (two/sex/dose) of the CD strain were fed diets containing 658
        or 23,500 ppm of technical dicamba (85.8% a.i.)  for up to three weeks
        (Witherup et al. , 1962).   Assuming that 1  ppm in the diet of rats
        is equivalent to 0.05 mg/kg/day  (Lehman, 1959),  these levels correspond
        to about 32.9 or 1,175 mg/kg/day.  No adverse effects on physical
        appearance, behavior, food consumption, body or organ weights, gross
        pathology or histopathology were reported.  Based on this information,
        a NOAEL of  1,175 mg/kg/day (the  highest dose  tested) is identified.

   Dermal/Ocular Effects

      0  IRDC  (1974) reported an acute LD50 of >2000 mg/kg in rabbit dermal
        studies.

      0  Heenehan et al. (1978) studied the sensitization potential of  technical
        dicamba  (86.8% a.i.) in albino guinea pigs.   The compound was  applied
        as a  10% suspension  to the shaved  backs of guinea pigs  (five/sex)  for
        6 hours three times per week  for 3 weeks.  Following nine sensitizing
        doses,  two  challenge doses were  applied.   Dicamba was judged  to cause
        moderate dermal sensitization.

      0  Technical  dicamba  (86.8% a.i.) was applied to the  shaved backs of
        New  Zealand White  rabbits  (four/sex/dose)  in  doses  of 0, 100,  500  or
        2,500 mg/kg/day, 5 days per  week for  3 weeks  (IRDC,  1979).   Slight
        skin  irritation was  observed  at  100 mg/kg, and  moderate irritation at
        500  mg/kg/day and  above.   No  changes  were  observed  in general  appearance,
        behavior,  body weight, organ  weight,  biochemistry,  hematology  or
        urinalysis.

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Dicamba                                                     August, 1987

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     9  Thompson (1984) instilled single doses (0.1  g) of technical dicamba
        (purity not specified) into the conjunctival sacs of nine New Zealand
        rabbits; three eyes were washed and six were not washed.  Dicamba was
        severely irritating and corrosive to both washed and unwashed eyes.

Long-term Exposure
                                                   s
     0  Laveglia et al. (1981) fed CD rats (20/sex/dose) technical dicamba
        (86.8% a.i.) in the diet for 13 weeks in doses of 0, 1,000, 5,000 or
        10,000 ppm.  Assuming that 1 ppm in the diet of rats is equivalent to
        0.05 mg/kg/day (Lehman, 1959), this corresponds to doses of about
        0, 50, 250 or 500 mg/kg/day.  No compound-related effects were observed
        in general appearance, hematology, biochemistry or in urinalysis valuesp
        survival and gross pathology at any dose levels tested.  There was an
        absence or reduction of cytoplasmic vacuolation of hepatocytes and a
        decrease in mean body weight for both sexes  (6.3% in females and 7.5%
        in males) at 10,000 ppm (500 mg/kg/day).  The body weight decrease
        was lower (p <0.05) at week 13 when compared to controls.  A NOAEL of
        5,000 ppm (250 mg/kg/day) can be identified  for this study.

     0  Male Wistar rats (20/dose) were fed diets containing technical dicamba
        at 0, 31.6, 100, 316, 1,000 or 3,162 ppm for 15 weeks (Edson and Sand-
        erson, 1965).  Assuming that 1 ppm in the diet of rats is equivalent
        to 0.05 mg/kg/day (Lehman, 1959), this corresponds to doses of about
        0, 1.6, 5, 15.8, 50 or 158 mg/kg/day.  Following treatment, general
        behavior, physical appearance, food consumption, organ weights, gross
        pathology and histopathology were evaluated.  However, the authors
        presented data only for the evaluation of body and organ weights.
        Hematological, urinalysis or clinical chemistry studies were not
        reported.  No adverse effects were observed  in the parameters measured
        at 316 ppm (15.8 mg/kg/day) or less.  Relative liver-to-body weight
        ratios increased (p value not specified) in  at 1,000 and 3,162 ppm
        (50 and 158 mg/kg/day).  Based on these data, the authors identified
        a NOAEL of 316 ppm (15.8 mg/kg/day).

     0  Davis et al. (1962) fed beagle dogs (three/sex/dose) technical dicamba
        (90% a.i.) in the diet in doses of 0, 5, 25  or 50 ppm for 2 years.
        Assuming that 1 ppm in the diet of dogs is equivalent to 0.025 mg/kg/day,
        (Lehman, 1959), this corresponds to doses of about 0, 0.125, 0.625 or
        1.25 mg/kg/day.  No compound-related effects were observed on survival,
        food consumption, hematology, urinalysis and organ weights.  A decrease
        in body weight was observed in males at 25 and 50 ppm and in females
        at 50 ppm.  No individual data except for body weight were reported,
        and no statistical evaluations were made.  The authors did not present
        data on gross pathology.  Histopathology was done only on the heart,
        lung, liver and kidney.  Based on marginal information, a NOAEL of
        5 ppm (0.125 mg/kg/day) can be identified.

     0  Sprague-Dawley rats (32/sex/dose) were fed technical dicamba (90% a.i.)
        in the diet for 2 years in doses of 0, 5, 50, 100, 250 or 500 ppm
        (Davis «t al., 1962).  Assuming that 1 ppm in the diet of rats is
        equivalent to 0.05 mg/kg/day (Lehman, 1959), this corresponds to
        doses of about 0, 0.25, 2.'5, 5, 12.5 or 25 mg/kg/day.  The authors

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Dicamba                                                     August,  1987

                                     -7-
        reported no adverse effects upon survival,  body weight,  food consump-
        tion, organ weight,  hematologic values or histology at the dose
        levels tested.   No  data were presented for evaluation of pharmacologic
        effects, gross  pathology,  urinalysis or clinical chemistry.  Incomplete
        histological data were presented.   A NOAEL could not be determined for
        this study due  to insufficient data.

   Reproductive Effects

     0  Charles River CD rats  (20  females  or 10 males/dose)  were fed diets
        containing technical dicamba (87.2% a.i.) in doses  of 0, 5, 50, 100,
        250 or 500 ppm  through three generations (Kettering Laboratory,
        1966).  Assuming that  1 ppm in the diet of rats is  equivalent to
        0.05 mg/kg/day  (Lehman, 1959), this corresponds to  doses of about 0,
        0.25, 2.5, 5, 12.5  or  25 mg/kg/day.  Fertility index, gestation
        index, viability index, lactation  index and pup development were
        comparable in treated  and  control  rats.  A NOAEL of 500 ppm
        (25 mg/kg/day)  was  identified.

   Developmental Effects

     0  Technical dicamba (87.7% a.i.) was administered per os to pregnant New
        Zealand White rabbits  (23-27/dose) at doses of 0,  1, 3 or 10 mg/kg/day
        from days 6 through 18 of  gestation (IRDC,  1978).x  No maternal toxicity,
        fetotoxicity or teratogenic effects were observed at 1  and 3 mg/kg/day.
        There were slightly reduced fetal  and maternal body weights and
        increased postimplantation losses  in the 10 mg/kg/day dose group when
        compared to untreated  controls.  The author did not consider these
        differences to  be statistically significant.  The author identified
        a developmental toxicity NOAEL of  10 mg/kg/day (the highest dose
        tested).  Based on  a reduction in  body weights and  increased post-
        implantation losses at the highest dose, a maternal and fetotoxic
        NOAEL of 3 mg/kg/day was identified by EPA/OPP.

     0  Pregnant albino rats (20-24/dose)  were administered technical-grade
        dicamba by gavage at dose  levels of 0, 64,  160 or 400 mg/kg/day on
        days 6 throught 19  of  gestation (Toxi Genetics, 1981).  No maternal
        toxicity was observed  up to 160 mg/kg/day.   Dicamba-treated dams in
        the 400-mg/kg/day dosage group exhibited ataxia and reduced body
        weight gain; they consumed less food during the dosing period when
        compared with controls given vehicle alone (p <0.05).  No fetotc :icity
        or developmental effects were observed at the dose  levels tested.
        Based on these findings, a NOAEL for maternal toxicity of 160 mg/kg/day
        is identified.   The NOAEL  for fetotoxic and developmental effects is
        400 mg/kg/day (the  highest dose tested).

   Mutagenicity

     0  Moriya et al. (1983) reported that dicamba (up to 5,000 ug/plate)
        exhibited no mutagenic activity against Salmonella  typhimurium
        (TA 98, TA 100, TA 1535, TA 1537 and TA 1538) or Escherichia coli
        (WP2 her) either with  or without metabolic activation.

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   Dicamba                                                     August, 1987

                                        -8-
        0  An increased number of chromosomal aberrations (p <0.01) were reported
           in mouse bone marrow cells exposed to 500 mg/kg dicamba (Kurinnyi
           et al.,  1982).  No other details were presented.

      Carcinogenicity

        0  Sprague-Dawley rats (32/sex/dbse) were administered dicamba (90% a.i.)
           in the diet for two years at doses of 0, 5, 50, 100, 250 or 500 ppm
           (Davis et al., 1962).   Assuming that 1 ppm in the diet of rats is
           equivalent to 0.05 mg/kg/day (Lehman, 1959), this corresponds to
           doses of about 0, 0.25, 2.5, 5, 12.5 or 25 mg/kg/day.  The treated
           rats did not differ from the untreated control animals with respect
           to the incidence, types and time of appearance of tumors.


V. QUANTIFICATION OF TOXICOLOGICAL EFFECTS

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

                 HA = (NOAEL or LOAEL) x (BW) = 	   /L (	   /L)
                        (UF) x (     L/day)
                                ~"^~~               \
   where:

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

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

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

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

   One-day Health Advisory

        No information was  found  in the available  literature that was suitable
   for determination of the One-day HA value for dicamba.  Accordingly, it is
   recommended that the Ten-day HA value of 0.3 mg/L (calculated below) for a
   10 kg child be used at this time as a conservative estimate of the One-day HA.

   Ten-day Health Advisory

        The developmental toxicity study by IRDC. (1978) has been selected to
   serve as the basis for the Ten-day HA value for dicamba.  In this study,
   pregnant rabbits administered  technical dicamba (87.7 % a.i.) by gastric
   intubation at dosage levels of 1, 3 or 10 mg/kg/day from days 6 through 18

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Dicamba                                                     August, 1987

                                     -9-
of gestation showed slightly reduced maternal body weights at 10 mg/kg/day.
Similarly, fetal body weights were slightly reduced, and postimplantation
losses were increased in the 10-mg/kg/day dose group.

     Based on these data,  a maternal and fetal toxicity NOAEL of 3 mg/kg/day
is identified.  A rat study (Toxi Genetics, 1981) of comparable duration deter-
mined higher maternal and fetal NOAELs (160 and 400 mg/kg/day, respectively).

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

           Ten-day HA = (3 mg/kg/day) (10 kg) = o.3 mg/L (300 ug/L)
                           (1 L/day) (100)

where:

        3 mg/kg/day = NOAEL, based on absence of body weight loss and post-
                      implantation losses.

              10 kg = assumed body weight of a child.

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

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

Longer-term Health Advisory

     No studies found in the available literature were suitable for
determining a Longer-term HA value for dicamba.  One 13-week rat study (Laveglia
et al., 1981) and one 15-week rat study (Edson and Sanderson, 1965) reported
NOAELs (250 mg/kg/day and 15.8 mg/kg/day, respectively) that were higher than
the NOAEL (3 mg/kg/day) of the rabbit study (IRDC, 1978) selected to derive
the Ten-day HA value.  It is therefore recommended that the Reference Dose
(RfD) derived below in the calculation of the Lifetime HA (0.0013 mg/kg/day)
be used at this time as the basis for the Longer-term HA values.  As a result,
the Longer-term HA is 13 ug/L for the 10-kg child and is 50 ug/L for the
70-kg adult.

Lifetime Health Advisory

     The Lifetime HA represents that portion of an individual's total exposure
that is attributed to drinking water and is considered protective of noncar-
cinogenic adverse health effects over a lifetime exposure.  The Lifetime HA
is derived in a three step process.  Step 1 determines the Reference Dose
(RfD), formerly called the Acceptable Daily Intake (ADI).  The RfD is an esti-
mate of a daily exposure to the human population that is likely to be without
appreciable risk of deleterious effects over a lifetime, and is derived from
the NOAEL (or LOAEL), identified from a chronic (or subchronic) study, divided
by an uncertainty factor(.s).  From the RfD, a Drinking Water Equivalent Level
(DWEL) can be determined (Step 2).  A DWEL is a medium-specific (i.e., drinking
water) lifetime exposure level, assuming 100% exposure from that medium, at
which adverse, noncarcinogenic health effects would not be expected to occur.
The DWEL is derived from the multiplication of the RfD by the assumed body

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Dicamba
                                     -10-
                                                            August, 1987
weight of an adult and divided by the assumed daily water consumption of an
adult.  Ihe Lifetime HA is determined in Step 3 by factoring in other sources
of exposure, the relative source contribution (RSC).  The RSC from drinking
water is based on actual exposure data or, if data are not available, a
value of 20% is assumed for synthetic organic chemicals and a value of 10%
is assumed for inorganic chemicals.  If the contaminant is- classified as a
Group A or B carcinogen, according to the Agency's classification scheme of
carcinogenic potential (U.S. EPA, 1986), then caution should be exercised in
assessing the risks associated with lifetime exposure to this chemical.

     The 2-year dog study by Davis et al. (1962) has been selected to serve
as the basis for deriving the Lifetime HA for dicamba.  In this study, beagle
dogs were administered technical dicamba at dietary levels of 0, 5, 25 or
50 ppm (0, 0.125, 0.625 or 1.25 mg/kg/day).  A decrease in body weight was
observed in males at 25 and 50 ppm and in females at 50 ppm.  A NOAEL of
25 ppm (0.125 mg/kg/day) was identified.

     The Lifetime HA is derived from this NOAEL as follows:

Step 1:  Determination of the Reference Dose (RfD)

                   Rf D = 0.125 mg/kgyday = 0. 001 3
                         0.125 mg/kgyday
                              (100)
where:
         0.125 mg/kg/day = NOAEL based on the absence of body weight loss.

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

Step  2:  Determination of the Drinking Water Equivalent Level (DWEL)

           DWEL  =  (0.0013 mg/kg/day) (70 kg) = 0.046 mg/L (46 ug/L)
                          (2 L/day)

where:

         0.0013 mg/kg/day = RfD.

                    70 kg = assumed body weight of an adult.

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

Step  3:  Determination of the Lifetime Health Advisory

             Lifetime HA = (0.046 mg/L) (20%) = 0.009 mg/L (9 ug/L)
where:
         0.046  mg/L  = DWEL.

                20%  = assumed relative source contribution from water.

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      Dicamba                                                     August,  1987

                                           -1 1-


      Evaluation of  Carcinogenic  Potential

           e   One study on  the  carcinogenic!ty of  dicamba  in rats  has been reported;
              it revealed no  evidence of carcinogenicity  (Davis  et al.,  1962).

           0   The International Agency  for  Research  on  Cancer has  not evaluated  the
              carcinogenicity of  dicamba.

           0   Applying the  criteria described in EPA's  guidelines  for assessment of
              carcinogenic  risk (U.S. EPA,  1986),  dicamba  is classified  in Group D:
              not classified.   This category  is used for  substances with inadequate
              evidence of carcinogenicity in animal  studies.


  VI.  OTHER CRITERIA, GUIDANCE  AND STANDARDS

           0   The NAS (1977)  has  calculated an ADI of 0.00125 mg/kg/day  based on a
              NOAEL  of 1.25 mg/kg/day from  a  2-year  feeding  study  in dogs  and .an
              uncertainty factor  of 1,000.   Assuming a  body  weight of 70 kg and  a
              20% source contribution factor, they calculated a  Suggested-No-Adverse-
              Reaction-Level  (SNARL) of 0.009 mg/L.

           0   Residue tolerances  from 0.05  to 40 ppm have  been established for a
              variety of agricultural products (U.S. EPA,  1985a).


 VII.  ANALYTICAL METHODS
              Analysis  of dicamba  is by a gas  chromatographic  (GC)  method applicable
              to  the determination of certain  chlorinated  acid  pesticides in water
              samples  (U.S.  EPA, 1985b).  In this method,  approximately  1 L of
              sample is acidified.  The compounds are  extracted with ethyl ether
              using a  separatory funnel.  The  derivatives  are  hydrolized with
              potassium hydroxide, and extraneous organic  material  is removed by
              a solvent wash.  After acidification, the  acids  are extracted and
              converted to their methyl esters using diazomethane as the derivatizing
              agent.   Excess reagent is removed, and the esters are determined by
              electron  capture  (EC) GC.  The method detection  limit for  dicamba has
              been estimated to be 0.2'7 ug/L.
VIII.  TREATMENT TECHNOLOGIES
              Available data  indicate granular-activated  carbon  (GAC)  adsorption
              to be a possible removal technique  for dicamba.

              Whittaker et al. (1982) report  that a reduction  of  pH from  7  to  3
              increased the extent of dicamba GAC adsorption.  No system  performance
              was  reported.

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IX. REFERENCES

    Atallah, Y.H., and C.C. Yu.*  1980.  Comparative pharmacokinetics and
         metabolism of dicamba in mice, rats, rabbits and dogs.  MRID 00128088.

    Altom, J.D., and J.'R. Stritzke.  1973.  Degradation of dicamba, picloram, and
         four phenoxy herbicides in soils.  Weed Sci.  21:556-560.

    Berg, G.L.  1986.  Farm Chemicals Handbook.  Willoughby, OH:   Meister
         Publishing Co.

    Burnside, O.C., and T.L. Levy.  1965.  Dissipation of dicamba.  Unpublished
         study prepared by the University of Nebraska, Department of Agronomy,
         submitted by Velsicol Chemical Corporation, Chicago, 111.

    Burnside, O.C., and T.L. Levy.  1966.  Dissipation of dicamba.  Weeds
         14:211-214.

    Burnside, O.C., G.A. Wicks and C.R. Fenster.  1971.  Dissipation of dicamba,
         picloram, and 2,3,6-TBA across Nebraska.  Weed Sci.  19:323-325.

    CHEMLAB.  1985.  The Chemical Information System, CIS, Inc.

    Davis, R.K., W.P. Jolly, K.L. Stemmer et al.*  1962.  The feeding for two
         years of the herbicide 2-methoxy-3,6-dichlorobenzoic acid to rats and
         dogs.  MRID 00028248.

    Edson, E.F., and D.M. Sanderson.   1965.  Toxicity of the herbicides 2-
         methoxy-3,6-dichlorobenzoic acid  (Dicamba) and 2-methoxy-3,5,6-tri-
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    Grover, R., and A.E. Smith.   1974.  Adsorption studies with the acid and
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    Heenehan, P.R., W.E. Rinehart and  W.G. Brun.*  1978.  A dermal sensitization
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    Helling, C.S.  1971.  Pesticide mobility in soils:  II.  Applications of soil
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    Helling, C.S., and B.C. Turner.  1968.  Pesticide mobility:  Determination of
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    IRDC.*   1974.  International Research and Development Corporation.  I.  Acute
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    IRDC.*   1978.  International Research and Development Corporation.  Teratology
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                                     -13-
IRDC.*  1979.  International Research and Development Corporation.  Three-
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Kettering Laboratory.*  1966.   The effects exerted upon the fertility of rats
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Kettering Laboratory.*  1962.   The cumulative toxicity of 2-methoxy-3,6-
     dichlorobenzoic acid (Banvel D) and 2-methoxy-3,5,6-trichlorobenzoic
     acid (Banvel T) when fed to rats.  MRID 00022503.

Kurinnyi, A.I., M.A. Pilinskaya, I.V. German and T.S. L'voya.  1982.  Imple-
     mentation of a program of cytogenetic study of pesticides:  Preliminary
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Laveglia, J., D. Rajasekaran,  L. Brewar.*  1981.  Thirteen week dieting
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Lehman, A.J.  1959.  Appraisal of the safety of chemicals in foods, drugs
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Meister, R., ed.  1983.  Farm Chemicals Handbook.  Willoughby, OH:  Meister
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Moriya, M., T. Ohta, K. Watanabe, T. Miyazawa, K. Kato and Y. Shirasu.  1983.
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NAS.  1977.  National Academy of Sciences.  Drinking Water and Health.
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Roberts, N., C. Fairley,  C. Fish et al.*  1983.  The acute oral toxicity
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Salman, H.A., T.R. Bartley and A.R. Hattrup.  1972.  Progress report of
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     No. REC-ERC-72-6; available from National Technical  Information Center,
     Springfield, VA. 22151.

Scifres, C.F., and T.J. Allen.  1973.  Dissipation of dicamba from grassland
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Sheets T.J. 1964.  Letter sent to Warren H. Zick dated Jan.3, 1964.  Greenhouse
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Sheets, T.J., J.w. Smith and D.D. Kaufman.  1968.  Persistence of benzoic
     and phenylacetic acids in soils.  Weed Sci.  16:217-222.

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                                     -14-
Smith, A.E.  1973a.  Degradation of dicamba in prairie  soils.  Weed  Res.
     13:373-378.

Smith, A.E.  1973b.  Transformation of dicamba in Regina heavy clay.
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Smith, A.E.  1974.  Breakdown of the herbicide dicamba  and  its degradation
     products 3,6-dichlorosalicylic acid in prairie  soils.   J. Agric.  Food Chem.
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Smith, A.E., and D.R. Cullimore.  1975.  Microbiological degradation of  the
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STORET.  1987.

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Suzuki, H.K.  1979.  Dissipation of Banvel or Banvel in combination  with
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     prepared in cooperation with Craven Laboratories,  Inc.; submitted by
     Velsicol Chemical Corporation, Chicago,  111.

Thompson, G.*  1984.  Primary eye irritation  study in albino rabbits with
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Toxi Genetics.*  1981.  Teratology study in albino rats with technical dicamba.
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Tye, R., and D. Engel.  1967.  Distribution and excretion  of dicamba by  rats
     as determined by radiotracer technique.  J. Agric. Food Chem.   15:837-840.

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Whitacre, D.M. and L.I. Diaz.*  1976.  Metabolism of 14c-dicamba in  female
     rats.  MRID 00025363.

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Whittaker, K.F., J.C. Nye, R.F. Weekash, R.J. Squires, A.C. York and H.A.
     Razemier.  1982.  Collection and treatment of wastewater generated by
     pesticide application.  U.S. Environmental Protection Agency.
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     Cincinnati, Ohio.

Windholz, M., S. Budavari, R.F. Blumetti, E.S. Otterbein, eds.  1983.  The
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Worthing, C.R, ed.  1983.  The Pesticide Manual:  A World Compendium,  7th Ed,
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•Confidential Business Information submitted to the Office of Pesticide
 Programs.

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