United States
           Environmental Protection
           Agency
Office of
Pesticides and Toxic Substances
Washington DC 20460
Sepwmber 1980
           •"esticides
x»EPA
        2-chloro-N-(2-ethyl-6-methylphenyl
           -N-(2-methoxy-1-methylethyl)
            acetamide       Metolachlor
           Pesticide Registration
           Standard

-------
              METOLACHLOR

   2-~chloro-~N-'(2~ethyl~6-methylphenyl)
   •~N— (2-*methoxy-il-rnethylethyl acetamide

     Pesticide Registration Standard
   David Gettman, Project Manager  (SPRD)
   Bill Audia, Plant Sciences Specialist  (BFSD)
   William Boodee, Residue Chemist  (BED)
   Larry Chitlick, Toxicologist  (HED)
   Harry Craven, Wildlife Ecologist  (HED)
   Carolyn Gregorio, Toxicologist  (HED)
   Samuel Howard, Environmental  Chemist  (HED)
   Alfred Smith, Residue Chemist  (HED)
   James Stone, Technical Product Manager  (RD)
             September, 1980

OFFICE OF PESTICIDES AND TOXIC SUBSTANCES
     ENVIRONMENTAL PROTECTION AGENCY
           401 M STREET S.W.
         WASHINGTON, DC  20460

-------
                               TABLE OF CONTENTS

I-fow to Register Under a  Registration Standard
    Organi zation of  the  Standard    	  7
    Purpose of the Standard    	•	  7
    Requirement to Re-register  Ihder the  Standard   	  9
    "Product Specific" Eata and  "Generic"  Data   	  9
    Data Compensation Requirements  under  FIFRA 3(c) (1) (D)    	 11
    Obtaining Eata to Fill "Eata  Gaps"; FIFRA  3(c) (2) (B)    	 12
    Amendments to the Standard    	 12

Requirements for Metolachlor  Products	 15
    Technical Metolachlor    	 16
    Emulsif iable Concentrate  Metolachlor    	 19

Use Profile  	 27

Product Chemistry
    Introduction   	 29
    Topical Discussions
         Chemical Identity    	 29
         Manufacturing Process    	 31
         Percentages of  Components  in  Pesticide Products    	 31
         Product Analytical Methods  and Eata    	 32
         Physical/Chemical Properties    	 32
    Disciplinary Review
         Chemistry Profile    	'.	 35
         Product Specific Data  Gaps    	 35
         Suggested Labeling    	 36
    Bibliography   	 37

Environmental Fate
    Topical Discussions
         Physico-Chemical Transformation	 39
         Soil Metabolism  	 41
         Microbial Metabolism   	 42
         Mobility    	 43
         Spray Drift   	 44
         Field Dissipation    	 44
         Accunulation    	 44
    Disciplinary Review
         Environmental Fate Profile    	 49
         Exposure Profile    	 51
         Generic Data Gaps    	,	 53
         Suggested Labeling	 53
    Bibl iography   	 55

Toxicology
    Topical Discussions
         Metabolism and  Pharmacodynamics    	 57
         Acute Effects and Neurotoxicity    	 58
         Local Irritation    	,	 59
         Subchronic  Effects and  Neurotoxicity    	 60
         Sensitization    	 61
         Chronic Effects  	 62
         Cncogenicity    	 52

-------
          Mutagenicity  . .	  63
          Teratology	  63
          Reproductive Effects   	  64
     Disciplinary Review
          Toxicology Profile	  65
          Toxicology Hazard Assessment	.	  66
          Generic Data Gaps   	«	  68
          Product Specific  Data Gaps	  68
          Suggested Labeling   	  68
     Bibliography	.	•	  69

 Residue Chemistry
     Topical Discussions
          Metabol ism in Plants	  73
          Metabolism in Animals   	.	  75
          Analytical Methodology	  75
          Residue Data	  78
          Present Tolerances   ..	  83
     Disciplinary Review
          Residue Chemistry Profile   	  85
          Tolerance Reassessment	  87
          Generic Data Gaps	  89
          Suggested Labeling	  89
     Bibl iography   	„	  91

 Ecological  Effects
     Topical Discussions
          Microbes	  95
          Algae   ....		....  97
          Aquatic Macrophytes	  97
          Terrestrial  Plants   .		  97
          Bi rds		...  97
          Wild  Mammals   .....		  99
          Aquatic Invertebrates	..	  99
          Fish			 100
          Ecosystem Effects	 101
     Disciplinary Review
          Ecological Effects Profile	 102
          Ecological Effects Hazard  Assessment	 103
          Generic Data Gaps	 103
          Suggested  Labeling	 104
     Bibl iography	 105

Regulatory  Rationale
     Technical  Metolachlor	 107
          The Delimitation  of Risks  to Hunans	 107
          The Delimitation  of Risks  to Wildlife   .		 108
     Emulsifiable  Concentrates of Metolachlor    	 109
          The Delimitation  of Risks  to Humans	 110
          The Delimitation  of Risks  to Wildlife   	 113

Append ix
    Chemical Data  Sheets	 117

Bibliography	•	 147
    Guide to the  Use  of This  Bibliography    	 149

-------
                                HOW TO REGISTER
                         UNDER A REGISTRATION STANDARD
Organization of the  Standard
Purpose of the Standard
Requirement to Re-register  Lhder  the  Standard
"Product Specific" Data and  "Generic"  Data
Data Compensation Requirements  under  FIFRA  3(c) (1) (D)
Obtaining Data to Fill "Data  Gaps"; FIFRA 3(c) (2) (B)
Amendments to the Standard
Organization £f  the Standard

    This  first chapter  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 the
available data by scientific discipline,  discusses the Agency's concerns with
the identified potential hazards, and logically develops  the conditions and
requirements that would reduce those hazards to acceptable levels.


Purpose o_f the Standard

    Section 3 of the Federal Insecticide, Fungicide, and  Fbdenticide 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  the Administrator [of EPA]."  Tb approve  the registration of a
pesticide, the Administrator must find, pursuant to Section  3(c) (5) that:
    "(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)  when 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 the risks and benefits
associated with  the use of  the proposed pesticide.  But the  established
approach  to making these findings has been found to be defective on two counts:
    First, EPA and its predecessor agency, the Lhited 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
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' approach was often inefficient and  sometimes resulted
in inconsistent  or incomplete regulatory  judgments.

-------
     Second,  over  the  years,  as  a  result  of  inevitable  and  continuing  advances
 in  scientific  knowledge, methodology,  and policy,  the  data base for many
 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  22, 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, Cbngress directed EPA to re-register all previously
 registered products,  so as to bring their registrations and their  data bases
 into compliance  with  current requirements  [See FIFRA Section 3(g) ] .
     Facing the enormous job of  re-reviewing and calling-in new data for the
 approximately  35,000  current registrations,  and realizing  the  inefficiencies of
 the 'product by product1 approach, the Agency decided  that a new,  more
 effective method  of review was  needed.
     A new review procedure has  been developed.  UYider  it,  EPA publishes
 documents called  Registration Standards, each of which discusses a particular
 pesticide active ingredient.  Each Registration Standard summarizes all the
 data available to  the Agency on a particular active ingredient and its current
 uses, and sets forth  the Agency's comprehensive position on the conditions and
 requirements 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  the 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) (1) (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)]. A pesticide  is
 classified for "restricted use" when some 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 use,"  or not
 classified at all,  is  available for  use  by  any individual  who  is in compliance
 with State or local regulations.   The  Registration Standard  review compares
 information about potential  adverse  effects  of specific uses of the pesticide
 with risk criteria listed  in 40 CFR  162.11(c),  and  thereby determines  whether a
 product needs to be classified  for  "restricted use."   If the Standard  does
classify a pesticide  for "restricted use,"  this  determination  is stated in  the
second chapter.

-------
Requirement _tp_ Re-register Under the 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 that 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-regisration.  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 the procedures for re-registration set forth in the
Guidance Package which accompanies this Standard.


"Product Specific" Data and "Generic" Data

    In the course of developing this Standard, EPA has determined the 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,
Environmental Fate, Tbxicology, 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 22, 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
the requirement has been waived.  Cn 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 some time and are, the Agency believes, relatively familiar to
registrants.  Data which we have found are needed to evaluate the
registrability of some 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 the second chapter.)
    The various kinds of data normally required for registration of a pesticide
product can be divided into two basic groups:

    (A)  data that is "product specific," i.e., data that relates only to
         the properties or effects of a product with a particular composition
         (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 the
         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 (which is a function of its total composition) .  The applicant for
registration or re-registration 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 of 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,  (Wiere 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.
     All other data needed to evaluate pesticide products concerns the
 properties or effects of a particular ingredient of products (normally a
 pesticidally active ingredient, but in some cases a pesticidally inactive, or
 "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 LD-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
 particular data requirement is use-pattern dependent,  it will apply to each
 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
 permitting 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 involving food/feed use or  repeated hunan exposure,  that
 subchronic oral study would not be  relevant to the evaluation of the
 manufacturing-use  product either.
     If  a registrant of a  currently registered manufacturing-use or end-use
 product  wishes  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 some 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  for  only certain use patterns.
®^± Compensation Requirements under FIFRA  3(c) (1) (D)

    Lhder FIFRA Section 3(c) (1) (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)  the data were first submitted to EPA  (or to its predecessor agencies,
         USDA or FE&) , on or after January  1, 1970;
    (2)  the data were submitted to EPA (or USDA or EER)  by some other
         applicant or registrant in support of an application  for an


                                    10

-------
         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 the 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) from 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
         purchases from another producer.)

    An applicant for re-registration of an already registered product under
this Standard, or for registration of a new product under this Standard,
accordingly must determine which of the data used by EPA in developing the
Standard 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)(1)(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 determin-
ing whether the applicant's product is registrable.  There may be cases,  how-
ever,  where because of close similarities between the composition of two or
more products, another firm's data may suffice to allow EPA to evaluate some 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
from tests on his own product, and if he chooses that option, he would have to
comply with the offer-to-pay requirements of Section 3(C) (1) (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)(1)(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 ^o Fill "Data Gaps"; FIFRA 3(c)(2)(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".
                                     11

-------
     FIFRA Section 3(c) (2) (B) ,  added to FIFRA by the Gbngress in 1978,
 authorizes EPA to require registrants to whom a data requirement applies to
 generate (or otherwise  produce)  data to fill such "gaps" and submit those data
 to EPA.  EPA must allow a reasonably sufficient period for this to be
 aceonplished.  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 which they  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 some cases,
 the Agency may possess sufficient "product specific" data on one currently
 registered  product,  but  may lack such data on another.  Chly those Standards
 which apply to a very small number of currently registered products will
 attempt to  state definitively  the "product specific" data gaps on a 'product by
 product'  basis.  (Although  the Standard will in some cases note which data that
 EPA does possess would suffice to satisfy certain "product specific" data
 requirements for a category of products with closely similar composition
 characteristics.)
     As part of the process  of  re-registering currently registered products, EPA
 will  issue  Section 3(c) (2)(B)  directives requiring  the registrants to take
 appropriate steps to fill all  identified data gaps  — whether that data in
 question is "product specific" or "generic" — in accordance with a schedule.
     Persons who wish to  obtain registrations for  new products under this
 Standard  will  be  required to submit (or cite)  sufficient "product specific"
 data  before their applications are approved.  Upon  registration,  they will be
 required  under Section 3(c) (2) (B)  to  take appropriate  steps to submit data
 needed to fill "generic"  data  gaps.  (Vfe expect they will respond to this
 requirement by entering  into cost-sharing agreements with other registrants  who
 previously  have been told they must furnish the  data.)   The Guidance Package
 for  this  Standard details the  steps that must be  taken by registrants to comply
 with  Section  3(c) (2) (B) .


 Amendments _to  the Standard

    Applications  for registration which propose  uses or formulations that are
 not presently  covered by  the Standard,  or which  present product compositions,
 product chemistry data, hazard data,  toxicity levels,  or labeling  that  do not
meet  the  requirements of  the Standard,  will  automatically be  considered  by the
 Agency to be  requests for amendments  to the  Standard.   In response  to such
 applications,  the  Agency may request  additional data to  support the  proposed
 amendment to  the  Standard,  or may deny the  application for registration  on the
grounds that the  proposed product  would  cause  unreasonable  adverse effects to
 the environment.   In the  former  case,  when  additional  data  have been
satisfactorily supplied,  and providing  that  the data do  not indicate the
potential for  unreasonable  adverse  effects,  the Agency will then amend the
 Standard to cover  the new registration.
    Each  Registration Standard is  based  upon all  data  and  information available
to the Agency's reviewers on a particular date prior to the publication date.
This  "cut-off" date  is stated at  the  beginning of the  second chapter.  Any
subsequent data submissions and any approved amendments will be incorporated
into the Registration Standard by means of addenda,  which are available for
inspection at EPA  in Washington,  B.C., or copies of  which may be requested from


                                      12

-------
the Agency.  When all the present  "data gaps" have been filled and  the
submitted data have been reviewed, the Agency will revise  the Registration
Standard.  Thereafter, when the Agency determines that the internally
maintained addenda have significantly altered the conditions for registration
under the Standard, the docunent will be updated and re-issued for  publication.
    While 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 some inert ingredients and  impurities.
Independent_of the development of any one Standard, the Agency has  initiated
the evaluation of some inert pesticide ingredients.  Where the Agency has
identified inert ingredients of concern in a specific product to which the
Standard applies, these ingredients will be pointed out in the Guidance Package.
                                    13

-------
                    REQUIREMENTS FOR METQLACHLOR PRODUCTS


    Tne following is the Agency's position on the present requirements  for
registration and re-registration under  this Metolachlor Registration  Standard,
including:   (1) what  'standards' of composition, acute toxicity, physical and
chemical properties, use, labeling, and packaging will ensure  the safe  use of
the pesticide active ingredient Metolachlor;  and  (2) what studies are  needed
to retain existing  registrations and to complete the data base  that will
support future registrations under the  Metolachlor Standard.   There are
different 'standards' and data requirements for technical  (manufacturing-use)
Metolachlor and for emulsifiable concentrate  (end-use) Metolachlor.   Producers
who use an  'integrated  formulation system' to manufacture a Metolachlor end-use
product are responsible for the data required for both a manufacturing-use and
an end-use  product.
    This Registration Standard is based on all pertinent data and information
on Metolachlor available to the Agency's reviewers as of June  30, 1980.


Metolachlor

    'Metolachlor'  [2-chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy-l-
methylethyl)acetamide]  is a selective herbicide used as either a pre-plant
incorporated or pre-emergence surface applied treatment for the control of most
annual grasses and certain broadleaf weeds in field corn (except fresh corn and
popcorn), soybeans, peanuts, and grain sorghum.
    There is presently only one registrant and data submitter for pesticide
products containing Metolachlor:  Ciba-Geigy Corporation (Agricultural
Division, P.O. Box  11422, Greensboro, ttorth Carolina, 27409).
    The three presently registered products containing Metolachlor as the sole
active ingredient are a manufacturing-use "technical1 and two emulsifiable
concentrate formulations, one containing 8 pounds of active ingredient per
gallon, and the other containing 6 pounds per gallon.  The formulation contain-
ing 6 pounds active ingredient per gallon is not presently in production,
although a small quantity remains on the market for 1980.  Metolachlor is also
marketed in a package mix with each of two other herbicides, 'Atrazine1 and
1 Propazine', and is often mixed by the applicator with other herbicides to
provide a broader spectrun of weed control.  However, please note that  this
Metolachlor Standard will only consider the registration of products which
contain Metolachlor as the sole active ingredient, and will only consider
those potential hazarxfs which arise from Metolachlor applied alone.
                                    15

-------
TECHNICAL METOLACHLOR

    In order to be registrable under this Standard, a Technical Mstolachlor
product must comply with the following standards of composition, purity, and
toxicity:  A Technical Metolachlor should contain at least 90  %  (by weight) the
active ingredient ' Matolachlor", i.e. 2-chloro-N- (2-^thyl-6-methylphenyl) -N- (2-
methoxy-1-methylethyl) acetamide.  If the manufacturing process submitted is
found by the Agency to be substantially different from the one used to  produce
the presently registered Technical Mstolachlor, a theoretical discussion
concerning the formation of unintentional ingredients will have to be submitted
to attest that potentially harmful impurities will not result  (see Proposed
Guidelines 163.61-5).  The "product specific" acute toxicology testing  on  a
Technical Metolachlor (or on a "substantially similar" Technical Metolachlor)
must demonstrate that it falls into Tbxicity Categories which are the same as
or numerically higher than the following:

               Acute Oral Tbxicity:   Category III
               Acute Eermal Tbxicity:  Category III
               Acute Inhalation Tbxicity:  Category III
               Primary Eye Irritation:  Category III
               Primary Dermal Irritation:  Category III

    The following 'Sample Label1  includes all those labeling statements which
the Agency has determined will provide an adequate mitigation of those  hazards
to man and the environment which may result from the handling, transport,
re-formulation, storage, or disposal  of Technical Metolachlor.  In order to be
registered under this Standard, therefore, a Technical Metolachlor must meet
the following standard  for labeling  by submitting a label which includes
these statements in  an  appropriate format.  [Consult the Proposed Guidelines
Section 162.10 for more  complete directions on formats for labeling.]
                                    16

-------
                              PRODUCT NAME
                    For Formulation of Herbicides  Chly

      Active  Ingredient:
         Metolachlor:  2-chloro-N-(2-ethyl-6-methylphenyl)-
                      N-(2-methoxy-l^nethylethyl)acetamide  	%
      Inert Ingredients:                                    	%
      Tbtal:                                                100%
                              CAUTION

                         PRECAUTIONARY STATEMENTS:
       Hazards _to Humans and Domestic Animals: Harmful  if swallowed. May
       cause  skin" sensitization. Wear protective clothing (coveralls and
       gloves) while handling and using  this product. Wash  thoroughly after
       handling. Remove and wash contaminated clothing  before re-use.
       Statement of Practical Treatment:  If swallowed,  drink one or two
       glasses of water. Induce vomiting by placing finger  in back of
       throat. Call a physician. Never give anything by mouth to an
       unconscious person.  If in eyes or on skin,  flush with plenty of
       water. If irritation persists, call a physician.
       Hazards to Wildlife: Do not discharge into  lakes, streams, ponds,
       or publicTwaters unless in accordance with  an NPDES  permit. For
       guidance, contact your regional office of EPA.

                            DIRECTIONS FOR USE
       Refer  to technical bulletin. It is a violation of federal law to
       use this product in a manner inconsistent with its labeling.

                           STORAGE AND DISPOSAL
       For bulk shipments in holding tanks, tank cars,  storage tanks, etc.:
            Do not contaminate water, food, or feed by  storage or disposal.
            Open dumping or open burning  is prohibited. Pesticide or
            rinsate that cannot be used,  recycled, or chemically reprocess-
            ed and tanks that cannot be  re-used should  be disposed of in
            a landfill disposal site approved for  pesticides. Thoroughly
            clean containers before re-use. Consult federal, state, or
            local disposal authorities for approved alternative measures.
       For metal drums, cans, etc.:
            Do not contaminate water, food, or feed by  storage or disposal.
            Open dumping or open burning  is prohibited. Re-seal container
            and offer for re-conditioning; or triple rinse  (or equivalent)
            and offer for recycling or re-conditioning. Pesticide or
            rinsate that cannot be used,  recycled, or chemically re-process-
            ed, and containers that cannot be re-used or recycled should
            be disposed of in a landfill disposal  site  approved for
            pesticides. Consult federal, state, or local disposal
            authorities for approved alternative measures.

    Note _to Formulators: formulators are  responsible for providing data
    to support the registration of products formulated  from this Technical.

EPA Registration No. 	    Net Wt. or Measure
Establishment No.  	                                    '
Name and Address of the producer, registrant, or person for whom produced.


                                   17

-------
    Finally, in order to re-register Technical I^fetolachlor under this
each registrant is required to submit or cite all the data below.  The product
Chemistry data are "product specific" studies specific to the currently
registered Technical Metolachlor;  the Environmental Fate, Toxicology, and
Ecological Effects data are "generic" studies that would test the active
ingredient or a typical formulation in order to assess the hazards due to end-
uses.  After each is listed the section in the Proposed Guidelines (43 FR
29686, July 10, 1978, and 43 FR 37336, August 2, 1978) which describes that
type of data and what test substances should be used.
         Product Chemistry
                                                           163. 61-8 (c) 6
                                                           163.61.8(c)13
                                                           163.61-8(c)14
                                                           163.61-3(0)15
                                                           163.61-8(c)17
                                                           163.61-8(0)18
     1)   Octanol/Ufeter Partition  Coefficient;
     2)   Flammability;
     3)   Oxidizing or Reducing Action;
     4)   Explosiveness;
     5)   Viscosity;
     6)   Corrosion Characteristics;
     7)   (and, if Technical Metolachlor  is  shown  to
          produce genetic effects  in future  testing:)
          An analytical method  (or reference       163.61-7
          to a method) for detecting and measuring
          each identifiable impurity (associated with
          the manufacturing of the Technical) in the
          formulated products of Metolachlor;
Environmental Fate
              8)    Adsorption/desorption studies;
              9)    Actual  field-use residue monitoring
                   studies at two watershed sites to be
                   approved by the Agency;
              10)   Accumulation studies on rotational
                   crops  for small grains, root crops,
                   and  leafy vegetables;
         Toxicology
              IT)Subchronic Oral Losing - Pathological
                   evaluation for both the rat and dog;
              12)   Chronic Feeding - A chronic feeding
                   study on laboratory rat;
              13)   Oncogenicity - Completion of the mouse
                   study;  and testing on a mammal other than
                   the  mouse (the laboratory rat is preferred),
                   or an oncogenic evaluation for the chronic
                   feeding study [see (12) above];
              14)   Teratology - A teratology study in a
                   mammalian species other than the rat;
              15)   Reproduction - A multi^generation
                   reproduction study on one mammalian
                   species (preferably the laboratory rat)
         Ecological Effects
              I6~)   Activated sludge metabolism study;
              17)   The  avian acute oral  LE>-50 for ona
                   species of waterfowl  (preferably the
                   mallard)  or  one species of upland  game
                   bird  (preferably the  bobwhite  quail); the
                   species must be one of  those  for which an
                   LC-50 was determined  under  FR  163.71-2.
                                                   163.62-9
                                                   (not discussed
                                                   in the  Proposed
                                                   Guidelines)
                                                   163.61-11(b)
                                                  163.82-1
                                                  163.83-1
                                                  163.83-2
                                                  163.33-3
                                                  163.83-4
                                                  163.62-8(g)
                                                  163.71-1
                                     18

-------
EMULSIFIABLE CONCENTRATE METOLACHLOR

    In order to be registrable under this Registration Standard, an end-use
pesticide product containing ffetolachlor must contain fetolachlor as the  sole
pesticide active ingredient.  The only end-use Metolachlor formulations
registrable under this Standard are Emulsifiable Concentrates of Mstolachlor,
which are liquids consisting of the active ingredient suspended or dissolved  in
one or more water-insoluble organic solvents, and if necessary, stabilized by
an emulsifying agent.  Tne strength of each i^tetolachlor Emulsifiable
Concentrate must be stated in pounds Matolachlor per gallon liquid.

    In order to registrable under this Standard, the "product specific" acute
toxicology testing on a Metolachlor Emulsifiable Concentrate  (or a
"substantially similar" one) must demonstrate that it falls into Toxicity
Categories which are the same as or numerically higher than the following:

               Acute Oral Toxicity:  Category II
               Acute Dermal Toxicity:  Category III
               Acute Inhalation Toxicity:  Category II
               Primary Eye Irritation:  Category I
               Primary Eermal Irritation:  Category II

    In order to be registrable under this Standard, the "product specific"
product chemistry testing on a Metolachlor Emulsifiable Concentrate must  show
that it has physical/chemical properties which fall within the limits listed
below.  For physical/chemical properties which are not shown below (see
the Product Chemistry chapter), no Standard has been set.

               Physical State:  liquid at room temperature
               Vapor Pressure:  between 0.05 and 1.0 mm Hg at 20 C
               pH:  between 6 and 8
               Flammability:  flashpoint above 80 F
               Explosiveness:  does not form explosive mixtures and is
                               not shock sensitive
               Corrosiveness:  must be no more than slightly corrosive to
                               steel or tin

    These acute toxicity and physical/chemical properties tests need not be
performed for a proposed Emulsifiable Concentrate if it is substantially
similar to a previously registered Mstolachlor Emulsifiable Concentrate.  The
applicant may request the Agency, in writing, to consider, by examination of
the statements of formula, whether the proposed product qualifies as
'substantially similar' to a previously registered product.
                                    19

-------
    In order to be registrable under  this  Standard,  a  Metolachlor Emulsi
Concentrate product must bear labeling  in  compliance with the following,
where appropriate, with label statements which  are correctly correlated  with
the product's toxicity categories  or  physical/chemical properties.  [Consult
40 CFR Section 162.10 for more complete directions on  formats for labeling = ]

    1)    The PRODUCT NAME at the  top  of the  front panel;
    2)    Beneath the name,  the product type  "Herbicide";
    3)    A general statement of the product's use: "Fbr weed control in  field
         corn (except fresh corn and  popcorn),  soybeans,  grain sorghun,  and
         peanuts", or any one or combination of these  crops;
    4)    A front panel statement of the ingredient percentages:
              Active Ingredient:
              Metolachlor:  2-chloro-N-(2-ethyl-6-methylphenyl)-
                           N-(2-methoxy-l-methylethyl)acetamide   ..... %
              Inert Ingredients:                                  ..... %
              Total:                                              100%
    5)    Directly below the ingredient statement, the  statement  "PRODUCT  NAME
         contains (   )  pounds active  ingredient  per  gallon";
    6)    A human hazard signal word on the front panel, selected  as  follows:
              If the Primary Eye  Irritation  is  Category I:   DANGER
              If the highest Toxicity Category  is II:   WARNING
              If the highest Toxicity Category  is III  or  IV:   CAUTION
    7)    Just above the signal word,  the statement "Keep  out of  reach
         of children".
    8)    Under the heading,  "PRECAUTIONARY STATEMENTS", (preferably  on front
         panel,  but  if not,  then print on  front  panel,  below the  signal word:
         "See side panel  for additional precautionary  statements"):
              Under  the heading, "Hazards  to Hunans  and Domestic  Animals":
                   The human hazard signal word  [same  as  (6)  above] ;
                   Fbr  acute oral  toxicity,
                        if  Category II:  "May be fatal  if swallowed."
                        if  Category III:   "Harmful if  swallowed."
                        if  Category IV:  no  statement  required
                   Bbr  acute dermal toxicity,
                        if  Category III:   "Harmful if  absorbed through skin.
                                          Avoid  contact with  skin  or
                                         clothing."
                        if  Category IV:  no  statement  required
                  For  acute  inhalation toxicity,
                        if  Category II:  "May be fatal  if inhaled. Do not
                                        breathe vapors or spray mist."
                        if  Category III:   "Harmful if  inhaled. Avoid breathing
                                         vapors or  spray mist."
                        if  Category IV:  no  statement  required
                  Fbr  primary eye irritation,
                        if  Category I:  "Corrosive,  causes eye damage.  Do not
                                       get  in eyes. Vvear goggles or  face
                                       shield  when  handling."
                        if  Category II:  "Causes eye irritation. Do not get
                                        in  eyes."
                                    20

-------
          if Category III:  "Avoid contact with eyes. In case of
                            contact immediately flush eyes or
                            skin with plenty of water. Get
                            medical attention if irritation
                            persists."
          if Category IV:  no statement required
     For primary dermal irritation,
          if Category II:  "Causes skin irritation. Do not get on
                           skin or on clothing."
          if Category III:  "Avoid contact with skin or
                            clothing. In case of contact,
                            immediately flush skin with plenty of
                            water. Get medical attention if
                            irritation persists."
          if Category IV:  no statement required
     For dermal sensitization,
          "May cause skin sensitization. Wear gloves and
          protective clothing while handling or using this
          product. Wash thoroughly after handling. Remove and
          wash contaminated clothing before re-use."
Under the heading, " Environmental Hazards":
     "Avoid direct application to any body of water. Eb  not apply
     where runoff is likely to occur. Co not contaminate water by
     cleaning of equipment or disposal of wastes. Eb not apply
     when weather conditions favor drift from target area."
Ihder the heading, "Physical/Chemical Hazards" :      Q
     For flammability, if the flash point is above 80 F and
          not over 150°F, the statement:  "Do not use or
          store near heat or open flame".
     For corrosiveness, if corrosive to steel or tin, the
          statement:  "Eb not place in unlined metal containers
          or tanks."
And beside the heading, "First Aid":
     If the formulation has greater than 10% by weight petroleum
     distillates, and has Category IV Acute Oral Tbxicity:
          "In case of contact with eyes, immediately flush with
          plenty of water for at least 15 minutes. Call  a
          physician. If inhalation occurs, the victim should be
          moved to fresh air, and medical attention should be
          sought. If swallowed contact your local Poison Control
          Center, hospital, or physician immediately. If patient
          is unconscious, maintain breathing and heartbeat (CPR:
          cardiopulmonary resuscitation) . Eb not induce  vomiting!
          [Note to Physician: If swallowed, there is no
          specific" antidote. The use of emesis and/or lavage
          should be weighed against the possibility of a chemical
          pneunonitis as this product contains petroleum
          distillates. Treat symptomatically!  The use of an
          aqueous slurry of activated charcoal (such as  ISbrit A)
          and a saline cathartic should be considered.]"
     If the formulation has greater than 10% by weight petroleum
     distillates, and has Category II or III Acute Oral  Tbxicity:
          "In case of contact with eyes, immediately flush with
          plenty of water for at least 15 minutes. Call  a
          physician. If inhalation occurs, the victim should be

                       21

-------
                    moved to fresh air, and medical attention should be
                    sought. If swallowed contact your local Fbison Control
                    Center, hospital, or physician immediately ..."   [The
                    remainder of this First Aid statement, which will
                    concern the use of emesis and/or lavage, will be
                    determined at the time of (re-) registration, and will
                    be based on the precise quantitative toxicity of the
                    formulation. See the NOTE below.]
               If the formulation contains, by weight, 10% or less (or does
               not contain)  petroleum distillates:
                    "In case of contact with eyes, immediately flush with
                    plenty of water for at least 15 minutes. Gall a
                    physician. If inhalation occurs, the victim should be
                    moved to fresh air, and medical attention should be
                    sought. If swallowed, contact your local R>ison Gbntrol
                    Center, hospital, or physician immediately. If patient
                    is unconscious, maintain breathing and heartbeat (CPR:
                    cardiopulmonary resuscitation) . If patient is
                    conscious, induce vomiting (syrup of ipecac; if not
                    available, stimulate back of throat with finger).
                    Never give anything by mouth to an unconscious person!
                    [Note to Physician: If swallowed, there is no
                    specific" antidote. Induce emesis and lavage stomach.
                    Treat symptomatically! The use of an aqueous slurry of
                    activated charcoal (such as Norit A)  and a saline
                    cathartic should be considered.]
9)  After precautionary statements, under "DIRECTIONS FOR USE":
          The statement:
               "It is a violation of Federal law to use this product in
               a manner inconsistent with its labeling."
          The statement (required for agricultural-use pesticides):
               "This product must be applied in accordance with 40 CFR
               Part 170."
          "Under the heading, "General Information":
               "PRODUCT NAME [( )  Ibs. a.i./gal.]  is a selective herbicide
               recommended as a preplant incorporated or pre-emergence
               surface-applied treatment in water or fluid fertilizer for
               control of most annual grasses and certain broadleaf weeds
               in corn grown for grain (except popcorn),  soybeans, peanuts,
               and grain sorghum",  or any one or combination of these
               crops.   When corn is listed as one of these crops, "Do not
               use on sweet corn or popcorn."  Also, the statement:
               "Failure to follow all precautions on this label may result
               in poor ,veed control, crop injury, or illegal residues."
          Also include, where spraying equipment if discussed:
               "Use conventional ground sprayers or center pivot irrigation
               application"  and any additional directions or precautions
               for using these methods of application.
10)   Under the heading, "PRODUCT NAME Applied Alone":
          If for  use on corn, under the heading, "Corn":
               Directions should specify all application  methods  and
               rates.   All applications must be pre-emergence.   to  rate
               in excess of 6 pounds active ingredient per  acre may be
               recommended.
                                 22

-------
          If for use on soybeans, under the heading, "Soybeans":
               Directions should specify all application methods and
               rates.  All applications must be pre-emergence.  No rate
               in excess of  3 pounds active ingredient per acre may be
               rec arm ended.
          If for use on peanuts, under the heading, "Peanuts":
               Directions should specify all application methods and
               rates.  All applications must be pre-emergence.  No rate
               in excess of  3 pounds active ingredient per acre may be
               recommended.
          If for use on sorghum, under the heading, "Grain Sorghum":
               Directions should specify all application methods and
               rates.  All applications must be pre-emergence.  No rate
               in excess of  2-1/2 pounds active ingredient per acre may be
               recommended.  (If the product will severely injure the
               crop when the sorghum seed is not pre-treated, it is
               advisable to  include a statement to this effect.)
          (When application methods and rates are the same for two or more
          crops, these directions may be listed under a combined heading
          such as "Corn and  Soybeans".)
          Under the heading,- "Rotational Crops":
               "1) If crop treated with PRODUCT NAME is lost, corn,
               soybeans, peanuts, or grain sorghum may be replanted
               immediately.  Do not make a second application of PRODUCT
               NAME. If the  original application was banded, and the second
               crop is planted in the untreated row middles, a second
               banded treatment may be applied.  2) Small grains may be
               planted 4-1/2 months following treatment. Field corn (except
               fresh corn and popcorn)  , cotton, soybeans, peanuts, sorghum,
               root crops, and small grains may be planted in the spring
               following treatment. Do not graze or feed forage or fodder
               from cotton or small grains to livestock. All other rota-
               tional crops may be planted 18 months after application."
11)  Under the heading, "STORAGE AND DISPOSAL":
          Concerning disposal,
               "Open dumping or open burning is prohibited. Do not re-use
               empty container; triple rinse or equivalent. Pesticide or
               rinsate that cannot be used, recycled, or chemically
               reprocessed, and triple-rinsed containers with their
               rinsate, should be disposed of in a landfill disposal site
               approved for pesticides. Consult federal, state, or local
               disposal authorities for approved alternative procedures."
          Concerning storage,
               the statement: "Keep out of reach of children";
               if the flash point is above 80°F and not over 150°F, the
                    statement:  "Do not store near heat or open flame.";
               if the product is corrosive to steel or tin, the statement:
                    "Do not store in unlined containers or tanks.";
12)  The label must also bear the 'EPA Registration Number1, the "Net
     Weight or Measure"  of the contents of the container,  and the Name and
     Address of the producer, registrant, or person for whom the product
     was produced.   Finally,  the "Establishment Number" should appear on
     either  the label or the  container.
                                  23

-------
NOTE:  Concerning labeling  for products containing petroleum distillates,
proper emergency medical treatment for the ingestion of petroleun
distillates  is a controversial subject.  Two significant  risks must be
weighed  in reaching a decision on whether or not to induce emesis or
perform  gastric lavage:  If emesis is induced, or gastric lavage  is
performed, petroleun distillates may be aspirated, possibly resulting in
fatal chemical pneunonitis.  However, retaining a highly  toxic pesticide  in
the stomach  even for a short period of time may also prove fatal.
     The Agency has contacted a nunber of authorities both within and
outside  EPA.  Tnere is no general agreement on how this problem may best  be
solved.   In  reaching a decision on appropriate labeling policy for
products, the Agency considers the toxic properties of the active
ingredients,  inerts, and impurities.  Thus, labeling requirements may
differ for chemicals and products addressed in these Standards.
     In  establishing a policy, the Agency has considered  that emergency
treatment may not be readily available, and that first aid will usually be
administered by a member of the general public who has little or no medical
training.
     In  general the Agency believes that the best advice  is to seek medical
help immediately and to keep the patient breathing until medical help
arrives. The Agency believes the following labeling is appropriate for all_
products which contain more than 10% by weight petroleum distillates:
     (1)  "If patient is unconscious, maintain breathing and heartbeat
          (CPR: cardiopulmonary resuscitation) . Cbntact your local Poison
          Control Center, hospital, or physician immediately."
     Pesticides in Acute Oral Toxicity Category I have an acute LD-50 of
less than or equal to 50 mg/kg, and a seriously toxic dose of such a
pesticide could readily be swallowed by both a 70 kg adult (a dose of 3*5
gm) and  a 12 kg child (a dose of 0.6 gm).  Thus for all products that con-
tain more than 10% by weight petroleum distillates and are in Oral Toxicity
Category I, it is prudent to recommend in addition to Statement (1) :
          "If patient is conscious, induce vomiting (syrup of ipecac; if
          not available, stimulate back of throat with finger). Never give
          anything by mouth to an unconscious person!"
     Pesticides in Acute Oral Toxicity Category IV have an acute LD-50  of
greater  than 5 g/kg , and a seriously toxic dose could not readily be
swallowed by either a 70 kg adult (a dose of 350 gm)  or a 12 kg child (a
dose of  60 gm) .  Thus, because the risk of chemical pneumonitis following
emesis is greater than the risk of allowing the pesticide to remain in  the
system,  for all products which contain more than 10% by weight petroleum
distillates and are in Oral Toxicity Category IV, the label should say  in
addition to Statement (1) :
          "Do not induce vomiting!"
     Products in Oral Toxicity Categories II and III, which could have  an
acute LD-50 anywhere between 50 and 5000 mg/kg, will be dealt with on a
product by product basis at the time of registration or re-registration,
and label statements will  be based on a review of the toxicity of active
ingredient(s) , inerts, and impurities.
                                   4

-------
    The Agency has determined that the above  'Standards' adequately limit  the
acute hazards of Bnulsifiable Concentrate tetolachlor  for agricultural workers
and others not directly involved in the application, and that therefore no re-
entry interval has been established for Emulsifiable Concentrate ffetolachlor.
Nevertheless, users should be aware that the "application of a pesticide in
such a manner as to directly or through drift expose workers or other persons
except those knowingly involved in the application" is expressly prohibited
under 40 CFR 170.3.  Registrants may amplify the statement on labels or
labeling to "apply in a accordance with 40 CFR Fart 170" by stating the
requirements of 40 CFR Part 170 or additions  thereto if they so choose.

    Finally, the following are "product specific" studies needed to complete
the data base which will support the re-registration of currently registered
Emulsifiable Concentrates under this Standard.  In order to re-register the
following Mstolachlor Emulsifiable Concentrates under this Standard, each
registrant is required to submit or cite these data.  After each requirement is
listed the section in the Proposed Guidelines which describes that type of data
and what test substances should be used.

    For currently registered Bnulsifiable Concentrate Mstolachlor of
    six  (6) pounds active ingredient per gallon:

         Product Chemistry
              I)   Color                                   163.61-8(c)l
              2}   Cdor                                    163.51-8(0)2

    For currently registered Emulsifiable Concentrate Matolachlor of
    eight  (8) pounds active ingredient per gallon:

         Product Chemistry
              Tj"   Color                                   163.61-8(0)1
              2)   Cdor                                    163.61-8 (c) 2
              3)   Ebcplosiveness                           163.61-8 (c) 15
         Toxicology
              4)   Acute inhalation toxicity study.        163.81-3
                                     25

-------
                                 USE  PROFILE


    The currently registered  end-use  formulations of Metolachlor are  two
Emulsifiable  Gbncentrates, one  at  six pounds  active ingredient  per gallon,  the
other at eight pounds per gallon.  Metolachlor  is a selective herbicide,  used
either as a pre-plant incorporated or pre-emergence surface-applied treatment
in water or fluid fertilizer  for the control  of most annual grasses and certain
broadleaf weeds  in  field corn (except fresh corn and popcorn) ,  soybeans,
peanuts, and  grain  sorghum.   This  Registration  Standard for Metolachlor only
considers the risks that arise  from  the use of  Metolachlor alone, and not when
it is formulated or tank mixed  with other pesticides.  Application for
Metolachlor alone is performed  as  follows for presently registered products:
    pre-plant incorporated -  1.5 to 3.0 pounds  active ingredient per acre
     (1.5 to 2.5 Ibs. ai/acre  for grain sorghum) (depending upon soil type),
    used when field has furrow  irrigation, or when a period of  dry weather  is
    expected.  fourteen days  before planting, (but after bed formation if the
    corn or soybeans are to be  planted on beds) , the chemical is diluted
    appropriately with water  or fluid fertilizer, applied to the soil by
    conventional ground sprayer (or center pivot irrigation system) , and
    incorporated into the top 2 inches of soil.  A finishing disc, harrow,
    rolling cultivator, or similar implement  is used to provide a uniform 2
    inch incorporation.
    pre-emergence surface-applied  -  1.5 to 3.0  pounds active ingredient per
    acre (1.5 to 2.5 Ibs. ai/acre  for grain sorghum)  (depending upon soil
    type), applied  by conventional ground sprayer (or center pivot irrigation
    system) during  planting (behind the planter), or after planting but before
    weeds or  crop emerge.
The directions for  application  to  sorghum fields require that grain sorghum be
treated with  Mstolachlor alone  only when the  seed have been pre-treated with
'Goncep' (registered trademark  of  CIBA-GEIGY) at 8 oz./100 Ibs. of seed,
which blocks  the herbicidal action of Metolachlor on sorghum.
    The registered  rotational crops restriction is:  small grains may be
planted 4-1/2 months following  treatment; field corn (except fresh corn and
popcorn), soybeans, cotton, peanuts, grain sorghun, root crops, and small
grains may be planted the spring following treatment; do not graze or feed
forage or fodder from small grains to livestock; all other crops may be planted
18 months after application without restriction.
    Studies which examine the use  of a pesticide in integrated pest management
(IPM) schemes may suggest ways  of  reducing application rates or frequency for
pesticide chemicals, without  reducing the degree of pest control achieved.  IPM
schemes may put the reduced use of a chemical in conjunction with one or more
of the following biological and cultural methods of control:  the development
of resistant  varieties of host  plants and animals, the introduction of natural
enemies, adjustments in crop  rotations, cropping systems and planting time,
water management and tillage  practices, and the diagnostic techniques for
evaluating the degree of pest infestation so  that the chemical  is used only
when needed.  Information about the use of Metolachlor in IPM schemes is
expected to become  available  as more  IPM weed control schemes are developed,
and the Standard for Matolachlor will then consider the degree  to which hazards
are lowered by these alternative,  but equally effective, uses of the chemical.
                                       27

-------
                              PRODUCT CHEMISTRY


INTRODUCTION

    FIFRA  3(c)(2)(A)  requires  the  Agency to  establish  guidelines  for
registering pesticides  in  the  United States.   The  Agency  requires registrants
to provide quantitative data on  all  added ingredients, active  and inert,  which
are equal  to or greater than  0.1%  of the  product by weight.
    To establish  the  composition of  products  proposed  for registration, the
Agency requires not only data  and  information on the manufacturing  and
formulation processes,  but also  a  discussion  on the 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 added ingredients,  or  only upper  limits for some  unintentional
ingredients.  Subpart D suggests specific precision limits for ingredients
based on the percentage of ingredient and  the standard deviation  of the
analytical method.
    In addition to the  data on product composition, the Agency also requires
data to establish the physical and chemical properties of both the  pesticide
active ingredient and its  formulations  (FR 163.61-10). For example, data are
needed concerning the identity and physical state  of the  active ingredient
(e.g., melting and boiling point data, vapor  pressure, and solubility) .   Data
are also required on  the properties  of the formulated  product  to  establish
labeling cautions (e.g., flammability, corrosivity, and storage stability).
The Agency uses these data to  characterize each pesticide and  to  determine its
environmental and health hazards.
TOPICAL DISCUSSIONS

    Corresponding  to  each of  the  Topical  Discussions listed below is  the  nunber
of the section  in  the 'Proposed Guidelines  for  Registering Pesticides' of July
10, 1978  (FR  Part  163), which explains  the  data  that the Agency will  need in
order to assess Matolachlor's Product Chemistry.

                                                        Guidelines Section
Chemical  Identity                                              163.61^3
Manufacturing Process                                         163.61-4
Percentages of  Components in  Pesticide  Products                163.61-6
Product Analytical Methods and Data                            163.61-7
Physical/Chemical  Properties                                   163.61-8


Chemical Identity

    'Metolachlor1  is  the acceptable common  name  for 2-chloro-N-(2-«thyl-6-
methylphenyl)-N-(2-methoxy-l-methylethyl)acetamide as determined by the
American National  Standards Institute  (1975).   Ciba-Geigy Corporation,
presently the sole manufacturer of Matolachlor  in the United  States,  has
assigned Metolachlor  the experimental number  'CGA-24705'  (for  the active
ingredient) , and the  trade name 'Dual1.   The name 'Metolachlor'  will  be
used in the Standard  in place of  the trade  name  or the chemical  name.


                                      29

-------
               METOLACHLOR AND RELATED


                     HERBICIDES
 Metolachlor
Alachlor
          .e
 Butachlor
          o

 Acetochlor
                                      Terbuciilor
Diethathyl-ethyl
                                               CH-CSCH
                                      Prynachlor
       1
      l-C-CH-O.
Allidochlor
                      FIGURE 1.1
                                      Propachlor
                        30

-------
    Metolachlor is both a 2-chloroacetamide and a 2-chloroacetanilide._  Figure
1.1 shows the relationship between ftetolachlor and other pesticide active
ingredients similar in chemical structure.  See the  'Chemical Data Sheet' on
'CCM-0011 in the Appendix for a complete chemical characterization of the
active ingredient Metolachlor.


Manufacturing Process

    Although specific manufacturing  information is withheld, the publicly-
available U.S. Patent for the synthesis of Metolachlor shows that it may be
produced by reacting the N-substituted aniline above with a chloroacetylating
agent, preferably an anhydride or halide of chloroacetic acid.  The general
process  is shown in Figure 1.2 below, which is taken from Vogel and Aebi, U.S.
Patent 3,937,730 (1975) and German Patent 2,328,340  (1973).
                                                  CICHj.-C-N-CH-
                                Figure  1.2


 Percentages  of Components _rn  Pesticide  Products

     For all  pesticide  products, the Agency requires a listing of the upper and
 lower  limit  established  (by the producer or  formulator) for each active
 ingredient,  and  the  upper limit for each impurity or contaminant, reaction
 product,  and degradation product which  is known to be present or which might
 reasonably be identified.
     Although the Agency has been supplied with all this information for
 Technical Metolachlor, the  manufacturer has  claimed that the identity of
 impurities or contaminants  can indirectly disclose details about the
manufacturing process, and  that the identity of Metolachlor impurities is
 therefore Confidential Business Information.  The Agency agrees that one can
 sometimes extrapolate part  of the manufacturing process from the identity of
 impurities or contaminants.  The identity of the impurities in Technical
 Metolachlor  is thus  not reported in this discussion, but is instead retained
by the Agency for  internal  reference.   (Accordingly, in the Appendix, the
 Chemical  Data Sheets for components CCM-002  through CCM-011 are also withheld
 from publication.)   The Agency does not presently have any reason for concern
about  the nature of  the identified impurities for Technical Metolachlor.
                                        31

-------
     Cnly the  percentage of active  ingredient has been supplied  for  the
 presently registered  formulated  end-use products containing  Metolachlor.

     Technical Metolachlor  (manufacturing-use preparations)
     1  presently registered:    Technical Metolachlor  is comprised  of minimum
                               90 to 95 %  (by weight) the active ingredient
                               'Metolachlor1, i.e.,  2-chloro-N-(2-ethyl-6-
                              methylphenyl) -N- (2-methoxy-l-methylethyl)
                               acetarnide.

     Emulsifiable Concentrate Metolachlor  (end-use pesticide)
     2  presently registered:  (a) EmulsiFiable Concentrate with  six  pounds of
                               active  ingredient per gallon  is comprised of
                               68.5% the active ingredient 'Metolachlor' and
                               31.5 %  inerts.
                             (b) Qnulsifiable Concentrate with  eight pounds of
                              active  ingredient per gallon  is comprised of
                               86.4% the active ingredient 'Metolachlor' and
                               13.6 %  inerts.
 Product Analytical Methods and Data

    Methods  for detecting and measuring the Matolachlor compound  in  its
 registered formulations have been submitted (Itelseth and Cole,  1973) .  Though
 all the non-Metolachlor components of the Technical product have  been
 identified by its manufacturer (Ciba-Geigy Corporation, 1974) , methods have
 not been reported for determining or measuring any of  the  impurities in
 Metolachlor products.  This analytical method would only be required if a
definite positive response were observed in genetic toxicological  tests
performed on the Technical.  (See the Toxicology chapter for a discussion of
genetics effects testing requirements.)


Physical/Chemical Properties

    Colo_r:   Technical Metolachlor is white to tan.  The color of  each
         Emulsifiable Concentrate was not reported.

    Odor:   Technical  Mstolachlor is odorless.  The odor of each Bnulsifiable
         Concentrate  was not reported.

    Solubulity:   The  solubility of Technical Metolachlor was reported to be:
    ~~   In water - 530 ppm at 20 C
         In organic solvents -
                   Insoluble in 1,2-ethanediol (ethylene glycol)
                   Insoluble in 1,,2-propanediol (propylene glycol)
                  Miscible  with dimethylbenzene (xylene)
                  Miscible  with methylbenzene (toluene)
                  Miscible  with N,N-dimethylformamide
                  Miscible  with 2-methoxyethanol  (methyl  cellosolve)
                  Miscible  with 2-butoxyethanol (butyl cellosolve)
                  Miscible  with 1,2-dichloroethane (ethylene dichloride)
                  Miscible  with cyclohexanone
                                      32

-------
Stability:  Ebr Technical Metolachlor, the half-life of a  0.25% aqueous
     solution at 100°C is 30 hours at pH  3,  18 hours at pH 7,  and  1.5
     hours at pH 10.

Cctanol/Water Partition Coefficient:  ND  octanoI/water partition
     coefficient has been reported for Technical Mstolachlor.

Physical State:  Both Technical and  Emulsifiable Concentrate Mstolachlor
     products are in liquid form at  room  temperature.

Specific Gravity;  The specific gravity of Technical Mstolachlor is  1.085
     H7- 0.005) at 20 C.  The specific gravity of the six  pound active
     ingredient per gallon Emulsifiable Concentrate is 1.04  (+/- 0.005) at
     20 C, and the specific gravity  of the eight pound ger gallon
     Emulsif iable Concentrate is 1.11 (+/- 0.005) at 20 C.

Boiling Point;  At 0.001 urn Kj, the  boiling  point of Technical
     ffiitolachlor is 100 C.  Ebr the  six pound per gallon Emulsifiable
     Concentrate (EC)  , it is 118 C,  and for  the eight pound per gallon,
     it is 140 to 160 C.

Vapor Pressure:  Ebr the Technical,  the vapor pressure is  about 10  mm
     Hg at 20 C.  Ebr the six pound  per gallon EC, the vapor pressure was
     reported to be 0.05 to 1.0 rrm Hg at  20  C, and for the  eight pound
     per gallon EC, it was 0.05 urn Hg at  20°C.

pH:  The pH of a 10% solution of six pound active ingredient per
     gallon Emulsifiable Concentrate is between 7 and 8, and that of an
     eight pound per gallon EC is between 6  and 8.

Storage Stability:  Results of ongoing studies show that Technical
     Metolachlor is stable for a minimum of  one year at room temperature.
     The shelf life of both concentrations of the Emulsifiable Concentrate
     is estimated to be a minimum of 5 years.

Flammability:  No data were available on  the flammability  of the
     Technical.  The flash point of £he six  pound per gallon Emulsifiable
     Concentrate was found to be 118 F (Setaflash C.C.T.) ,  and that of
     the eight pound per gallon was  found to be 185 (+/- 5)°F  (TCC) .

Oxidizing or Reducing Action;  isb data were  available for  the Technical,
     but th"i~ Emulsifable Concentrates were reported to be  clearly non-
     reactive.

Explosiveness:  Again no data were available about the Technical.  A
     study on the explosiveness of the six pound per gallon Emulsifiable
     Concentrate has shown that the material is thermally  stable at
     200°C, can be processed or handled at temperatures up to  150  C,
     (under normal use and application practices) does not form (nor does
     its vapor form)  explosive mixtures,  and is not shock  sensitive.  The
     study on the eight pound per gallon  EC  is currently in progress.

Miscibility:  Both Emulsifiable Concentrate  formulations form  a stable
     emulsion with water.
                                  33

-------
Viscosity:  ND data were available on the viscosity of the Technical.
     The six pound per gallon Hnulsifiable Concentrate has a viscosity of
     15.6  (+/- 0-3) CS at 25 C.  The eight pound per gallon, a viscosity
     of 120  (+/- 5) CD at 25 C.

Corrosion Characteristics;  Isb data were available on the corrosiveness
     of the Technical."for the Bnulsifiable Concentrates, however,  it was
     discovered that the six pound per gallon formulation was not  corrosive
     to steel or tin, while the eight pound per gallon did show a  slight
     corrosiveness.

Dielectric Breakdown Voltage:  As long as Mstolachlor is not registered
~    for""industrial weed control, it will not be used around high  power
     electrical machinery, and a dielectric breakdown voltage test will  not
     be needed.
                                   34

-------
DISCIPLINARY REVIEW

Chemistry  Profile
Product  Specific Eata  Caps
Suggested  labeling

Chemistry  Profile

    The  technical material  for  a  pesticide  is  the  toxicant  in pure form
(usually more than 90  %  the  active  ingredient)  as  it  is manufactured  by a
chemical company prior to being formulated  into an end-use  pesticide  product,
Technical  Metolachlor, which is at  least 90 to 95  % active  ingredient,  is an
off-white, odorless  liquid,  soluble in  water,  and  miscible  with  several organic
solvents.  Because it  is intended only  for  re-formulation into the end-use
pesticide, Technical Matolachlor  is a  'manufacturing-use product1. The
physical/chemical properties which  have so  far been determined for the
Technical  do not suggest any imminent hazards  from the handling  of the
Technical  product.

    An emulsifiable  concentrate is  an end-use  pesticide product, consisting  of
a toxicant suspended or  dissolved in a  water-insoluble organic solvent,
stabilized by an emulsifying agent. The strength  of  an emulsifiable
concentrate  is usually stated in  pounds toxicant per  gallon concentrate.
    Two  strengths of Emulsifiable Concentrate  Mstolachlor are currently
registered:  six pounds active ingredient per gallon and eight pounds  per
gallon.  These are somewhat  viscous liquids, miscible with water,  and having a
slightly greater density than water.  The physical/chemical properties  which
have so  far  been determined  for these emulsifiable  concentrates  indicate  a few
notable  characteristics, due primarily  to the  presence of the organic
solvents:  a significant vapor pressure,  a  relatively low flash point
temperature,  and a slight corrosiveness to metal containers for the eight
pound per gallon.  These properties suggest  the  need  for two warnings on  the
labels of emulsifiable concentrates:  due to the vapor pressure and high
flammability of the  solvent  in the  six  pound per gallon formulation,  the  user
should keep  any six  pounds or less  per  gallon  formulation away fron open  flame
or high  heat;  to prevent potential  leaks of the eight pound per gallon
formulation  due to its slight corrosiveness, it  should be placed only in
application  tanks and  storage containers  that  are  protectively lined.


Product Specific Data Gaps

    The  following are  "product specific"  data gaps  for Product Chemistry which
need to be filled in order to maintain  in effect current registrations  under
this Standard.  After each gap is listed  the section  in the Proposed Guidelines
(July 10, 1978, FR Part  163) which describes that type of data and when it is
required.

    For Technical Mstolachlor:
         1)   Octanol/Water  Partition Coefficient      163.61-8(c)6
         2)   Flammability                             163.61-8(c)13
         3)   Oxidizing or Reducing Action             163.61-8 (c)  14
         4)   Explosiveness                            163.61-8(c)15
                                        35

-------
          5)    Viscosity                                163.61-8(c)17
          6)    Corrosion Characteristics                163.61-8(c)18
          7)    [and,  if  the  Technical  is found  to  produce
               genetic effects  (see  Toxicology chapter) :]
               An analytical method  (or  reference        163.61-7
               to a method)  for detecting  and
               measuring each  identifiable impurity
               (associated with the manufacturing
               of the technical grade  of the active
               ingredient) in the  formulated
               products  of Metolachlor.

    For  Bnulsifiable Concentrate  tetolachlor  (6 Ibs.  ai/gallon) :
          1)    Color                                     163.61-8(c) 1
          2)    Cdor                                      163.61-8(c)2

    For  Snulsifiable Concentrate  Metolachlor  (8 Ibs.  ai/gallon) :
          1)    Color                                     163.61-8(c)l
          2)    Cdor                                      163.61-8(c)2
          3)    Explosiveness                             163.61-3(c)15
Suggested Labeling

    The ingredient statement for Metolachlor products should  list the
    active ingredient 'Metolachlor' as:
             "Pfetolachlor: 2-chloro-N- (2-ethyl-6-methylphenyl) -N- (2-methoxy-l-
              methylethyl) ace tarn ide"
                                       36

-------
                                BIBLIOGRAPHY

    Each of the following studies contributed useful  information  to  the
Agency's review of the product chemistry of Metolachlor, and  is considered  part
of the data base supporting registrations under  this  Standard.


American National Standards Institute  (1976).  American National  Standard ANSI
    K62.198-1976.  Common name for  the pest control chemical  2-chloro-N-(2
    methoxy-1-methylethyl) acetamide: "metolachlor".  New York, N.Y.

Ciba-Geigy Corporation  (1974) Section A, CGA-24705:   Name, Chemical  Identity
    and Composition of CGA-24705.   (Unpublished  study; received Sep  26,
    1974 under 100-EUP-44; CDL:96505:A)

Ciba-Geigy Corporation  (1975h) Section A, CGA-24705:  Name, Chemical  Identity,
    and composition of CAG-24705.   Received Nov  25, 1976 under 6G1708.
    (Unpublished study; CDL:96439-A)

Ciba-Geigy Corporation  (1976a) CGA-24705:  Name, Chemical Identity,  and
    Composition of CGA-24705.  Received Nov 23,  1976  under 100-587.
    (Unpublished study prepared by  Ciba-Geigy Corp.,  Greensboro,  N.C.;
    CDL:226955-A)

Ciba-Geigy Corporation  (1977) Aerial Application.  Received Feb 18,  1977
    under 100-583.   (Unpublished study that includes  studies  ID-9D with a
    summary; CDL:228101-F; 228122)

Ciba-Geigy Corporation  (1977ba) Section A General Chemistry.   (Unpublished
    study; received Jan 19, 1977 under 7F1913; CDL:95764-A)

Ciba Geigy Corporation  (1977b) Aerial Application.  Received Jun  20,  1977.
    (Unpublished study containing studies ID-10D with a summary;  CDL:230672-D,
    230683)

Helseth, J. ; Cole, G.  (1973)  The Determination of CGA-24705 in Hnulsifiable
    Concentrates by Gas Liquid Chromatograpy.  Method PA-9 dated  Nov  14,
    1973.  Received Sep 26, 1974 under 5G1553.   (Unpublished  report
    prepared by Ciba-Geigy Corp., Greensboro, N.C.; CDL:96666-A)

Vogel, C.; Aebi, R.,  inventors; Ciba-Geigy Corp., assignee (1976) Plant growth
    regulating agent. U.S. patent 3,937,730. Eeb 10:  8p. Int  CI  . C07G
    103.34.

Vogel, C.; Aebi, R.,  inventors; Ciba-Geigy Corp., assignee (1973)
    Haloacetanilides acting on plant growth.  German  patent 2,328, 340.
    Dae 20: 50p. Int. CI. C07C 103.38.
                                         37

-------
                              ENVIRONMENTAL FATE
TOPICAL DISCUSSIONS
    Corresponding to each of  the  Topical  Discussions  listed  below is  the nunber
of the section(s) in the  'Proposed  Guidelines  for  Registering  Pesticides'  of
July 10, 1978  (40 FR Part 163) which  explain(s)  the data  that  the Agency will
need in order to assess Matolachlor's  Environmental Fate.
Physico-Chemical  Transformation
Soil Metabolism
Microbial Metabolism
Mobility
Spray Drift
Field Dissipation
Accumulation
   Guidelines Section
        153752^7
        163.62-8
        163.62-8
        163.62-9
163.126-2,  -3,  and/or -4
        163.62-10
        163.62-11
Physico-Chemical Transformation

    Hydrolysis
         Metolachlor  in buffer pH  5,  7, and 9 at  30  , was respectively  97,
    100, and 96% stable for  28 days  (Burkhard 1974) .  From rate constants,
    Arrhenius parameters  for each  pH value were calculated.  Using  the
    Arrhenius parameters, half-lives  for Mstolachlor at  20 C were calculated
    to be greater than 200 days in 0.1N HQ (pH 1) and in buffer pH 5,  7, and
    9.   In 0.1N NaOH  (pH  13), the  calculated half-life was 97 days.  Hydrolysis
    of Metolachlor  in 0.1N NaOH at 30 C yields N-(2 'methoxy-1 -methyl-ethyl) -
    2-ethyl-6-methyl hydroxyacetanilide.  In 0.1N HC1 at 70 C, Metolachlor
    hydrolyzed to 4-(2-methyl-6-ethyl-phenyl)-3-methyl-morpholinone-5.
         These data were  sufficient  to show that  hydrolysis products  are not of
    envirormental concern because  Mstolachlor is  considered to be stable in the
    natural environment.

    Photolysis
         Because Matolachlor is used  on outdoor crops, studies on photolysis
    in both soil and water are needed.  Because an assessment of re-entry
    hazard is not required for any of the proposed uses of products containing
    Metolachlor, a study on photolysis in the vapor phase is not necessary.

         Photolysis in Aqueous Solution
              MetolacHlor was found  to be relatively stable in aqueous
         solution under natural sunlight (Aziz and Kahrs 1975).  Approximately
         6.6% was photolyzed in 30 days, which was less than 10% of the
         exposed activity.  Five photoproducts, accounting for about  4.7% of
         the activity, were found  in  the chloroform soluble fraction.   One
         photoproduct was identified  as 4-(2-methyl-6-ethylphenyl)-5-
         methylmorpholine.  Four of  the photoproducts were not identified.
                                     39

-------
 Qie  unknown was  found  in  the aqueous  fraction and amounted to about
 1,9% of  total  activity. These photoproducts do not need to be
 identified because they represent less than 10% of the exposed
 activity.
     Under high  intensity artificial  sunlight conditions, Matolachlor
 in aqueous solution was approximately 69% degraded in 15 days (Aziz
 and Kahrs 1974).  Five photoproducts  comprising about 13% of total
 radioactivity  were found  in the chloroform soluble fraction.  Three
 of the products  were identified as  4-(2-methyl-6-ethylphenyl)-5-
methylmorpholine  (MET-009) ,  N=(2-hydroxyacetyl-N-methoxyprop-2-yl) 2-
 ethyl-6=methylaniline  (MET-001), and  N-chloroacetyl-2-ethyl-6-methyl-
 aniline  (MET-010).   (See  the Appendix for identities of chemicals
 referred to by MET nunbersc)    Photolysis products in the aqueous
 phase amounted to 23% of  the activity*  Chloroform soluble products
 which stayed at  the origin on thin  layer chromatography (TLC),
 amounted to 17.2% of the  activity.  Mass spectroscopy and TLC
 analyses of this activity indicated that at least five major products
 were present.  Further efforts were taken to separate and identify
 these products using TLC  with a developer of chloroform and methanol
 (9:1) and chronotropic acid, methanolic sodiun hydroxide, and
 diaaonium fluoroborate as specific  spray reagents.  With this TLC
 system, at least seven photolysis products were separated.  None
 represented more than 4%  of the original   C activity.  These polar
 products did not contain  hydroxyl, aldehyde, or N-hydroxynethyl
groups as judged from tests with the  specific chromogenic agents.
     Based upon  the data discussed  in this section, Metolachlor is
 considered to  be stable in aqueous  solution under natural sunlight.

photolysis in  Soil
   ~ Studies~brr~soil slides were performed by Aziz (1974) .  Lhder
natural sunlight conditions, Metolachlor on soil slides was
approximately  50% photolyzed in 8 days.  Activity in chloroform
extract amounted to 44.9% of the applied radioactivity, of which
 32.7% was determined to be parent,  3.9% was identified as N-propen-1-
ol~2-yl-N-chloroacetyl-2~jnethyl-6-ethylaniline, and three unknowns
accounted for 7«7%o  ESich unknown was less than 10% of the applied
activity.  Non-extractable   C-activity in soil amounted  to 39% of
 the applied activity,  \folatiles accounted for 10.5% of the applied
activity, of which 5.2% was determined to be parent.
     Uider artificial sunlight conditions, Metolachlor on soil slides
was approximately 52% degraded  in 7 days.  Activity in the chloroform
extract amount to 47.1% of the applied activity, of which 24.1% was
determined to be parent,  5=6% was identified as N-propen-l-ol-2-yl-N-
chloroacetyl-2-methyl-6-ethylaniline, and 16.4% was comprised of 3
unknowns.  (Each unknown was less than 10% of the applied activity.)
Nonextractable " C-residue in soil amounted to 39%.  \blatiles
accounted for  6.8% of applied activity, of which 4.12% was determined
to be parento
     Though either study would have been adequate alone,  these
studies,  the one conducted under natural sunlight and the other under
simulated sunlight, provide sufficient information about  the
photodegradation of Metolachlor in soil.
                             40

-------
Soil Metabolism

    Elleghausen  (1976a  and  b)  studied  the  degradation of Matolachlor in soil
under sterile aerobic,  nonsterile  aerobic,  and  nonsterile aerobic  followed by
nonsterile  anaerobic  conditions.   Uhder  sterile aerobic conditions,  at the end
of  12 weeks, 30% of the reductively dechlorinated  analog of  Metolachlor (MET-
005) was  found.  No other metabolite could  be detected.  The remaining
radioactivity existed as undegraded Metolachlor.
    Also  at a time interval of 12  weeks, both the  aerobic nonsterile and
aged aerobic/anaerobic  nonsterile  tests  resulted in a degradation  pattern
wherein about 18%  of  the radioactivity was  identified as MET-02S»  Another 10%
                    MET-005
MET-025
of  the  initially applied  radioactivity was  found  as  polar, water  soluble
products.   They were  inseparable by  TLC, but could be methylated  with
diazomethane  to form  three  distinct  components, separable by gas  liquid
chronatography (GDC).   The  investigator considers these  to be ring
hydroxylated  analogs  of MET-025.   A  CH-CL--soluble nonpolar metabolite,
representing  about  5% of•initial radioactivity was compared, by TLC and GLC co-
chromatography, to  26 model Metolachlor metabolites  with no identity fit.
Small amounts of MET-005  as well as  unidentifiable polar and nonpolar
extractables  were also  found.
     Sumner, Szqlics,  and  Gassidy (1976) studied the  products of degradation of
ring labeled    C Matolachlor in silt loam treated at an  exaggerated rate
 (100 ppm) and incubated out-of-doors in open bottomed containers.  Besides
41.7% of total initial radioactivity found as Metolachlor, 0.9% of MET-001 and
0.1% MET-008 were fbind.  Additionally, an oxalic acid derivative was
tentatively identified as MET-025.  Chemicals contained in the leachate from
this study were qualitatively similar, as determined by comparative radioassay
of various TLC R~ zones.
    Concurrently, Sumner, Szolics, and Cassidy (1976) conducted a field plot
study of silt loam soil treated at 2 Ibs active ingredient per acre (a.i./A)
                                     41

-------
and aged 12 months.  This study yielded in addition to  MET-001, MET-008, and
MET-025, the additional compounds MET-003 and MET-026.
                   MET-003

    All metabolites in both substudies were less than 1% of total
radioactivity, except MET-001 in the leachate, which reprosented 2.5% of  total
radioactivity.  Two TLC spots, representing metabolites less polar than MET-
003 were also noted, both at the 1% level, in the extracts from the  field
experiment; the two spots as well as a spot near the TIC plate origin
represented 6.4% of the total radioactivity.
    Sunner and Cassidy  (1975a) showed that under field conditions, over a one
year period, the relative percentage of unextractable residues reached a
steady state (ca. 80% of total).  During the latter stages of the test, the
relative amount of extractable residue in the organic fulvic and humic acid
fractions decreased with a concomitant increase in the amount remaining in
H_0 soluble and mineral fractions.  The fractionation procedure used was
described by Sunner (1974).
    Dupre (1974a) conducted an anaerobic soil metabolism study as described  in
the Agency's Proposed Guidelines for testing and found that the gross
character (extractable polar, extractable nonpolar, or nonextractable) of soil
metabolites did not change over a 60-day anaerobic period following a 30-day
pre-conditioning aerobic period, as compared to the character of degradates
during a similar period of continued aerobic metabolism.
    Evidence is provided by Sunner and Cassidy (1975a)  that nonextractable
bound residues of Metolachlor and its metabolites are in dynamic equilibrium
with soluble forms and that the nonextractable portion may therefore serve as
a long term reservoir for extractable residues.
    When viewed as a composite, these tests satisfy the soil metabolism data
requirement for Metolachlor.  (The following additional studies contain
information related to metabolic transformation in soil but did not by
themselves supply adequate information about soil metabolism:  I&iser 1974,
Sunner and Cassidy 1974g, k, 1, m, f, and e) .


Microbial Metabolism

    Three microbial metobolism studies were available.  Cne was conducted
according to the alternative pure or mixed culture technique and two were
conducted by the sterile and non-sterile soil approach.
    In the pure and mixed culture study (MrGahen and Tiedje) , American Type
Culture Collection nunber 34507, identified as Chaetomium globosum, a soil
fungus, was used in resting cell experimentation at 0.035 mM concentrations  of
Metolachlor including control flasks without Metolachlor and without
C_. globosum.  Control flasks did not exhibit any degradation for 144
hours.  Flasks with C. globosum and Metolachlor exhibited substantial
degradation with only 55% of Mstolachlor remaining after 5-7 days.  An
adaptive lag period of approximately 20 hours was observed.  A total of at
least eight extractable products were identified or tentatively identified.

                                       42

-------
MET-009, MET-003, MET-018 and MET-019 were firmly  identified.   Identifications
of MET-020, MET-021, MET-022, MET-023, and MET-024 were  tentative.   The
formation of the oxoquinoline is unique to pesticide metabolism, with  the
three quinolines of Metolachlor unique to Metolachlor  itself.   It  is apparent
that the fungus did not remove any group from the  ring,  although it
dehydrogenated the ethyl moiety to form a vinyl on the ring.
    Kaiser, using labeled Metolachlor  (position of label unspecified)  added
Metolachlor to both sterilized and unsterilized sandy  loam soil at a
concentration of 10 mg/250 gm of soil  (40 ppm)  (Kaiser,  1974).  Essentially no
loss of total activity was noted in either sterile or non-sterile soil (5-15%
of the residual activity was found to be degradation products of
Metolachlor).  This study is not considered acceptable for the purpose of
describing the effects.
    In another sterile and non-sterile soil study  (Ellgehausen, 1976b,c), a
clay loam  (Stein, Switzerland) which was treated with  ring-labeled Metolachlor
at a concentration of 1 mg/232 gm of soil  (ca. 4 ppm) and a control  sample
(autoclaved soil) were monitored for degradation.  After a short lag phase, a
slow but steady evolution of   C0_ was evolved in  the non-sterile soil
reaching 4.8% of the applied dose after 12 weeks.  Analysis of the soils after
12 weeks indicated that 10% of the residual activity in  the non-sterile soil
was parent compound versus 65% Metolachlor in the sterile soil.
    Cn the basis of these studies, a general microbial transformation  scheme
can be postulated vtfiich involves dehalogenation, dehydrogenation, dealkylation,
ring formation, and oxidation of the acetyl group and/or ring oxidation.  Ring
oxidation apparently results after extended incubation of the compound in the
presence of microbes, but it is not a significant route of degradation.
    The studies by McGahen and Tiedje and by Ellgehausen followed acceptable
protocols, and are sufficient to support this facet of the fate assessment for
the present uses of Metolachlor.


Mobility

    Leaching
         Data on leaching have been developed by Eupre (1974c) and HDUseworth
    (1973b).  Parent Metolachlor leaches readily in sandy loam and sandy soils
    low in organic matter.  Twenty to 33% of the applied Metolachlor leaches
    more than 12 inches in the above soils when an equivalent of 20  inches of
    rainfall are applied to a soil colunn overlayered with Metolachlor.
    Cbnversely, insignificant leaching is expected in muck soils high  in
    organic matter.  Field studies (Ballantine, 1975) showed substantial
    leaching into the 6"-12" soil horizon in 5 different states with various
    soil types.  Metolachlor residues, aerobically aged  for 30 days  in soil,
    will also leach in soils low in organic matter.  These data are  sufficient
    to assess leaching potential for Metolachlor.

    Adsorption
         A laboratory adsorption/desorption study using  four concentrations of
    radiolabeled or non-radiolabeled pesticides and the same soil as used for
    the leaching study is not presently available for Metolachlor.   This
    constitutes a data gap.
                                     43

-------
Spray Drift

    Information on the likelihood or extent of spray drift for Emulsifiable
Concentrate Metolachlor when conventional ground sprayers are used is not
presently available, except for what is generally understood about the spray
drift behavior of similar agricultural chemical preparations.  Subpart J of the
Proposed Guidelines, which will cover drift as it relates to phytotoxic
effects, has not yet been accepted for regulatory use.  Because Metolachlor is
a herbicide which may potentially damage an adjacent crop or neighboring flora,
when these Guidelines do go into effect, drift studies may be required.


Field Dissipation

    Field dissipation studies were conducted by Ballantine (1975) on five
different soil types representing five geographical locations.  The following
conclusions were drawn from the studies:  1)  Approximately 10% of applied
Metolachlor was found in the upper 12 inches of Mississippi loam after 60 days
for both. 2 and 4 Ibs. active ingredient per acre (a.i./A) application rates.
2)  In bfebraska silt loam, approximately 10% of applied Metolachlor was found
in the upper 12 inches after 162 days for both 2 and 4 Ibs. a.i./A application
rates.  3)  In tew York, California, and Illinois,  soils that were not
analytically characterized, Metolachlor dissipated  to about 10% of the applied
in 60 to 150 days for both 2 and 4 Ibs. a.i./A application rates.
    These field dissipation studies under actual use conditions are sufficient
to show that Metolachlor, applied alone, dissipates to approximately 10% of
the applied amount in 60 to 160 days in each soil type tested, and that it
leaches to approximately 12 inches in loam and silky loam soils.  If uses were
proposed at greater than 4.0 pounds ai/A pre-emergent, then additional field
dissipation tests, at the proposed rates, would be  needed.


Accumulation

    Rotational Crops
    ~Oats in the greenhouse, and carrots and soybeans in the field, were
    grown as rotational crops to corn 9 months after soil treatment at 2 Ibs/
    acre using   C-ring labeled Metolachlor.  Low levels of residues ranging
    from 0.02 to 0.27 ppm, expressed as Metolachlor, were found in different
    portions of the various crops (Sumner and Cassidy 1974e; Sumner and
    Cassidy 1974f; Sunner and Cassidy 1974g).  The  preponderance of
    extractable residues were polar in nature (partition into H«0/MeOH vs.
    CHCL.J and the two major fractions constituting these polar residues
    were neutral and acidic in nature, as determined by ion exchange
    chronatography.  A typical analysis of such plant residues is provided by
    the following example for oat straw derived from oats grown as a
    rotational crop to corn where Metolachlor was applied at a rate of 2 Ibs/
    acre (Sumner and Cassidy, 1974f).
                                                                 Calculated ppm
              ,.                                                 as Metolachlor
    1)   Total   C activity                            = 0.27 ppm
    2)   H-O/MeOH extractable, % of total activity     = 67%            -18
        -Tfeutral Fraction, % of total activity       = 19%            -05
        - Acidic Fraction, % of total activity        = 45%            -12
    3)   CHCL  extractable, % of total activity        = 7.0%           -02
                                      44

-------
     The text of the review by Marco  (1974) of metabolism studies with
Metolachlor  in corn implies that only highly  polar  acid metabolites,  such
as conjugates involving  the N-acetyl  group of Metolachlor are  present.
However, the data presented in Table  IV of Marco  (1974) show that the
relative amounts of polar neutral and polar acidic  constituents  in
extracts of mature stalks differ by about  4 to  1.   These data  support the
contention that TLC characterization  of the polar neutral constituents
should be possible.  Sumner and Cassidy (1974d) did not adequately
characterize the polar neutral constituents,  though the very low levels of
radioactive  content in these  fractions  made further characterization
difficult by means of present-day technology.

                  (Adapted From Table  IV, Marco-1974)
      Ionic  Characterization  of Radioactive Metabolites in  Polar
      Fraction of Cbrn Treated with 2 Ib.  ai/A  14C  Metolachlor

                      Ionic Charge      	   «•-.-, 14,
Location
          weeks  after  treatment
Percent of Total   C in Plant
      Greenhouse
         Field
                  Neutral
                   Acid
                   Base
                Zwitterion

                  Neutral
                   Acid
                   Base
                Zwitterion
  8_

 7.0
73.1
 0.6
 6.2

 7.4
68.2
 1.7
 2.7
 12

 7.9
53.6
 0.9
21.4

10.8
70.4
 1.2
 8.4
                                               16 (mature forage)
  a
  a
  a
  a

 7.3
26.3
 1.0
15.3
(a = sample
decomposed
in shipment)
     Marco  (1975) , and  Sunner and  Cassidy (1975) , argue  that the metabolic
pathways  in  rotational  carrots  and soybeans are  qualitatively similar
based on  a comparison of  the ionic and  TLC comparative characteristics of
acidic constitutents.   While it is conceded the  conjugated metabolites of
Metolachlor  in corn grain may be the only ones worthy of consideration,
the same  is  not necessarily true with rotational crop uptake.  Compounds
unable to readily form  sugar and/or S-glutathione conjugates may be taken
up by rotational crops  and exist as discrete  residues.   These may
therefore be worthy of  individual  consideration by the toxicologists.
     Also, it should be noted that the  official  regulatory method for
Metolachlor  and its metabolites in corn is based on an acid hydrolysis
which forms  HP-001 and  HP-002.  (Aziz and  Ftass, 1975).
                                                 ,CH
This method will not detect MET 002, 004, 008, 009, or 010, all of which
are postulated degradation products of Metolachlor  (Marco, 1974), and none
of which can readily form the conjugates, but could form oxo-neutral
                                  45

-------
 conjugates 0   Again,  using  the  oat  (straw)  example,  cited  above, one  can
 conclude  that the entire neutral fraction  of  the  H_0/MeOH extractables
 equaling  0,05 ppn could be a mixture of MET 002,  004,  008,  009, and  010
 (or other degradates of a  similar  nature)  and  would not be  detectable by
 the method of Balasubramanian, Aziz, and Ross  (1975).  Such compounds
 should ba readily amendable to GLC and TLC separation  Rf  zone  and
 retention time comparisons with model compounds.
     Based on information  submitted by Ballantine (1975), the  roots  of  root
 crops, grain  of small grains, and  oil from oil seed crops (such as cotton
 seed) can reasonably be expected to contain little, if any,  residue  of
 Metolaehlor per se or its metabolites hydrolyzable  to  HP-001 or HP-002
 using the method of Balasubramanian, Aziz, and Ross (1975).  All residue
 analyses for  MET-007 were  0.03 ppn or less and were 0.10  ppn or less for
 MET-015.  The question as  to whether this  regulatory method  for corn-
 related products is applicable to  rotational crops  is moot  and must  await
 further elucidation of the nature  of the neutral  polar metabolites in
 rotational crops.
     The studies cited above show  that levels of  Metolachlor-derived
 residues in other plant portions of these  crops (carrot tops, soybean
 stalks, sugar beet tops, and wheat straw)  may at  times be expected to
 exceed this analytical "baseline"  level when grown  as  rotational crops to
 corn and analyzed by the procedure of Balasubramanian, Aziz, and Ross,
 1975o
     Lettuce  was grown outdors as  a rotational crop to soybeans in the fall
 and spring, 14 and 41 weeks respectively,  after soil was  treated at  2 Ibs.
 a.i./acre with   C-ring labeled Metolachlor«  The residue level,
 expressed as  Metolachlor,  found in the 26-week old  fall planting of
 lettuce, was  0*025 ppm.  The levels observed in the second crop (spring
 planting)  were 0*144 ppn in the 13-week old sample  and 0.062 ppn in  the  15-
 week old sample (final harvest).
     Oily the 54-week lettuce sanple (second crop,  spring sample)  was
 considered to contain a sufficiently high  level of  residues  for further
 characterization, which consisted of partitioning the  radioactivity  into
 organic, polar, and non-extractable fractions.  The  fractions contained
 21%, 73%, and 12% of the activity, respectively.  No further identification
 was attempted„
     The data on rotational crop residues  are deficient in  two respects:
 first, acceptable data are not available on residues in small grains, root
 crops, or leafy vegetables to establish an interval  between  ffetolachlor
 treatment and the planting of rotational crops so that carry-over residues
 into rotational crops are prevented;  second, although it is agreed  that
 present day analytical technology  is not easily adapted to the task, the
 extractable non-polar metabolites  in rotational crops were not sufficiently
 characterized to dispel concern over their potential contamination of the
 food web =
     The registered rotational crops restriction  provides that:  "Snail
grains may be planted 4-1/2 months following treatment. Field corn (except
 fresh corn and popcorn) , cotton, soybeans, peanuts,  sorghum, root crops,
 and snail grains may be planted in the spring following treatment. Do not
graze or feed forage or fodder from cotton or small  grains  to livestock.
 All other rotational crops may be planted  18 months  after application."
     However, the Agency has a new policy  on rotational crops:  EPA  will
 now accept petitions for "rotational crop  tolerances'  for rotated crops,
and where necessary, for meat, milk, and eggs.  When the  rotational  crop
 restrictions  that would ensure the absence of residues in rotated crops  are
not practical for the grower, tolerances may be set  for residues in


                                   46

-------
specific rotated crops, and an earlier planting of  those  rotated  crops may
be allowed.   In brief,  the registrant now has  the optionf  for  each rotated
crop, of:   (1) accepting a crop  rotation  restriction  interval  (not to
exceed 18 months) which is sufficient to  ensure that  residues  are not
present in the rotated  crop;  or (2) petitioning for  a  'rotational crop
tolerance1 for that crop, which  may allow for  an earlier  rotation.
    Studies in which Metolachlor was applied in accord  with existing
usage showed  residues,  and the need for tolerances  for  these residues, in
the forage and fodder of small grains, in the  tops  of sugar beets and
carrots, and  in lettuce.  Uider  the new policy, because there  is  no
'rotational crop tolerance' for  residues  in the forage  and fodder of small
grains, for residues in the tops of sugar beets and carrots, or for
residues in rotated lettuce (or  other leafy vegetables), crops in these
crop groupings should not be  rotated in MBtolachlor-treated fields before
18 months.  Cotton for  cottonseed would be an  exception to this
restriction,  because the data for rotational soybeans showed that the
mature soybean contained either  non-detectable or very  small amounts of
Metolachlor residues.   Higher levels were found in  soybeans foliage.
Therefore it  may be extrapolated that cotton foliage, but not cottonseed,
will contain  detectable levels of residues when cotton  is grown as a
rotational crop in the  spring following the treatment of corn, soybeans,
peanuts, or sorghun with Mstolachlor.  Because cotton foliage would be
expected to contain residues  of  Metolachlor, it should  not be fed to
livestock.
     Thus, unless additional  data are submitted to  demonstrate intervals
(less than 18 months) after which no residues  will  occur in rotational
crops, or unless tolerances are  established for those rotated crops which
would contain residues, the label on any  product formulated with
Metolachlor and intended for  use on food  or feed should carry the following
rotational crops restrictions:   "Field corn (grown  for  grain, except
popcorn) , cotton, soybeans, peanuts, and  grain sorghum  may be planted in
the spring following treatment.  CD  not rotate  other crops until 18 months
after application. Eb not graze  or  feed forage or fodder from cotton to
livestock."   In the meantime, in accordance with the  conditional
registration  policy authorized by Section 3(c) (7) of  FIFRA and implemented
under 40 CFR  162.18, this Standard  will retain the  existing rotational crop
restrictions  and simply state the data requirement  for  additional
rotational crop data for small grains, root crops,  and  leafy vegetables.

Fish Accumulation
     Elleghausen (1977) tested the  uptake, transfer and degradation of
Metolachlor by algae, daphnia, and  catfish.  After  90 minutes exposure to
0.1 ppm Mstolachlor, algae accumulated 10.4 ppm.  Bfowever, following 2
hours depuration, less  than 2 ppm remained in  the cells.  Daphnia,  exposed
for 24 hours  to 0.1 ppm, accunulated 0.60 ppm. Eight hours depuration was
needed to achieve a 50% loss.  Daphnids accunulated only  20% more when
exposed to both algae with 10.4  ppm Matolachlor and water containing 0.1
ppm Metolachlor as compared to fortified  water in the absence of  algae.
Catfish, exposed to 0.1 ppm   C  Metolachlor accunulated 1.20 ppm
Metolachlor in their tissues  after  96 hours.   However,  a plateau  was not
reached.
     Metabolites of Metolachlor  were noted but not  identified  in  the
algae, daphnids, and catfish.  At the end  of the 96-hour catfish  study,
only 1/2 of the   C-activity  remaining in the  water was Metolachlor.
The remainder was present as  3 unidentified degradation products.  The
theoretical basis for the model  system used was discussed in another paper

                                  47

-------
 (Elleghausen, 1976b) .  3nith (1977)  conducted a 30-day catfish exposure
study in a soil/water/fish ecosystem.  At an average concentration of 0.08
ppn in the water, bioaccunulation factors were 6*5 - 9.0 for edible
portions of the fish and 55.0 - 92.4 in the viscera.  After 14 days of
withdrawal, residue levels in the edible portion declined from a maximum
exposure value of 0*72 ppm to 0.03 ppn, and levels in the viscera declined
from a maximum exposure value of 7.39 ppn to 0.18 ppm.  The accumulated
residues in the edible portions remained relatively constant in terms of
extractable vs. nonextractable (about 8:1) .  Cn days 1 and 30 there was 16
times more organically soluble activity than aqueous soluble (ethyl acetate-
water system).  A cysteine conjugate of Metolachlor was identified as a
metabolite and reached a high of 12.8% of total   C activity in the
edible tissue on day 14.  Smaller amounts of other metabolites were found
in edible and/or visceral tissues but were not identified.
     N-(2'hydroxy-l'-methylethyl)-2-ethyl-6-methyl chloroacetanilide (MET-
003), N-2(2-hydroxy acetyl)-N-(l-methyl propane-2-yl)-2-ethyl-6-!nethyl
aniline, and a cysteine metabolite of Metolachlor were all found in water
along with three other unidentified degradation products.
     Barrows (1974)  reported on a bluegill sunfish flow-through study at
  C P-fetolachlor exposure levels of 10 and 1000 ug/liter.  Bioaccunulation
levels at the 1000 ug/liter exposure level reached 28 ppn in edible tissues
and 702 ppn in the nonedible tissues.  Existence of a plateau could not be
established.  After 28 days depuration, residues in edible portions of fish
decreased to 0.08 ppn for the 10 ug/liter   C Pfetolachlor exposure and to
11.7 ppn for the 1000 ug/liter  exposure.  The chemical nature of the fish
residues was not defined.   Mien the above studies are considered as a
composite, they are sufficient  to adequately characterize the fish
accumulation characteristics of Mstolachlor.
                                  48

-------
DISCIPLINARY REVIEW

Environmental Fate Profile
Exposure Profile
Generic Eata Gaps
Suggested Labeling
Environmental Fate Profile

    Mstolachlor is applied at a rate of  1.5 to  3.0 pounds  active  ingredient per
acre to soil where corn (excluding popcorn), soybeans, peanuts, or grain
sorghun are to be grown.  Normally, the  chemical  is  sprayed on  the soil during
or soon after planting, before sprouts emerge.  However, when dry weather  is
expected, or if furrow irrigation is being used,  the chemical is  sprayed on the
soil before planting, and incorporated into the top  2 inches of soil.
    Metolachlor is quite stable to hydrolysis over the environmental pH range
of 5 to 9  (the estimated half-life is 200 days  over  this entire pH range) .
Photolysis appears to be a more significant degradation pathway,  as
approximately 50% was found to have degraded on sunlit soil over  a period  of
eight days.  However, if Metolachlor is  applied and  incorporated  into  the  top  2
inches of soil, then degradation by photolysis  is expected to be  minimal.   Soil
metabolism, by both aerobic and anaerobic microorganisms,  would also play  an
important role in the degradation of Mstolachlor  in  the soil  (MrGahen  and
Tiedge, 1978) .
    About 30% of the photoproducts were  represented  by MET-009  and MET-001.
(See the Chemical Fact Sheets in Appendix A for characterizations of these
and other metabolites.)   Another 30% was represented by CHCL-, and water-
soluble polar metabolites.  Indirect evidence obtained from analysis of
aqueous photoproducts produced by artificial light of <280 nm suggests that
the polar products, both aqueous soluble and CHC1., soluble, are not  ,.
aldehydes or phenolic in nature (Aziz and Kahrs ,  1975).  Exposure of   C
Metolachlor treated soil thin layers to natural sunlight (Aziz, 1974)  resulted
in gradual photolysis to MET-003 and three unidentified products.  Two
unidentified products have moderate polarity and  one was relatively high in
polarity.  After 8 days exposure, about  1/2 of  the initially applied dose  had
decomposed .
    Soil metabolism of Mstolachlor appears to proceed by hydrolytic cleavage
of the N-alkyl terminal constituents followed by  oxidation and/or ring
closure.  The following reactions were found to occur on the N-alky groups:
                1)  R -C3 -CH.
                                 r-lnj doSUJTB
              ?3
             K^a^

            R-C-OI^ °
              II
              Q
[Elleghausen,  1976a  and  1976b;
              Sumner and Cassidy,  1974 and 1975)
               I
           SrC-C-CH
             0 0
Sunner, Szolics, and Cassidy 1976;
                                       49

-------
.•-retook of the benzenoid portion of the molecule to form phenolic metabolites
"as speculated but not proven  (Elleghausen, 1976b).  The likelihood of such
ring attack is contraindicated by the following observations:  (1) Evidence is
provided by Sumner and Cassidy (1974) that non-extractable bound residues of
Metolachlor are in dynamic equilibrium with soluble forms, (2) unextractable
residues represented by fulvic and hunic acid fractions decrease with
increased aging.  Incorporation of polyphenolic metabolites into the soil
organic matrix veuld mitigate against both of the above findings.
    Studies were also available on Metolachlor's environmental mobility.
feuseworth (1973b) , in a laboratory column leaching study, using a wide range
of soil types, stowed that Metolachlor per se is subject to extensive leaching
when applied to soils having low organic content.  Extensive  leaching can thus
be expected in soils such as agricultural sands and sandy loams having organic
contents of 2% or less.  Residues of aged   C-Metolachlor were also found
•r.o leach extensively in sandy loam soil  (Dupre, 1974).  Based on incremental
1 C activity at different soil depths, several discrete chemicals of
different mobilities were probably involved.  A runoff study by Dupre  (1974c)
showed that Metolachlor can be expected  to move from agricultural sites of
application both by sheet erosion and leaching.
    Field dissipations studies confirmed Metolachlor's potential for
significant movement in the soil, but left open the question of whether
i'-fetolachlor may sometimes persist undegraded.  Skipper, Cbssett, and 9nith
(1976), in field dissipation tests, concluded that extensive  leaching was the
major cause of dissipation from the upper 3-inch soil horizon in two different
plots containing sandy loam soils.  Field dissipation studies of Mstolachlor
applied at up to 4 Ibs. a.i./acre (pre-emergent)  showed residues generally less
than 10% of the amount originally applied over time spans ranging between 107
and 162 days»  A total of 5 states representing continental -USA climate
extremes were involved.  But absolute losses of Metolachlor between the day of
application and final sanpling were not always so great.  Ebr example, in a
Nebraska study, residues declined only 44% over a 107-day time span.  In sane
cases, substantial residues were found in the 6" to 12" soil  horizon
suggesting extensive leaching.  This high soil mobility, in combination with a
'potential for long-term environmental stability, may prove to be significant
concern in projecting potential exposures to Metolachlor residues.
    Additional studies were performed to estimate the possibility of
Metolachlor bioaccunulation«  KLuegill sunfish exposed for 70 days to a mean
level of 1=2 ppm ~ C Matolachlor accumulated 18 ppm of   C activity
(expressed as Metolachlor)  in their edible tissues and 486 ppm in non-edible
tissues.  After a 28-day depuration, the residue levels decreased to 12 and 13
ppm respectively.  The chemical nature of the residues was not investigated
(Barrows, 1974).  A catfish study (Smith, 1977) involving aged Metolachlor on
sandy loam soil resulted in an accumulation of 0.53 ppm in edible catfish
tissue at the end of 30-day exposure.  After 14 days of depuration, the level
decreased to 0.03 ppm.  values for viscera at the end of the  30 day exposure
and after 14 days depuration were 4.4 and 0.18 ppm, respectively.  The major
identified metabolite found in the edible tissues was CGA-46576.
    Though the available data do not indicate significant long-term
accumulation in fish, there is a possibility that residues may result in
rotated crops grown on Mstolachlor-treated soil.  Roots of root crops, grain of
small grains, and oil from oil seed crops, grown as rotational crops to corn in
a Metolachlor-treated field, were shown  to have little, if any, residues of
Metolachlor, as analyzed by the officially accepted regulatory method for corn
grain, forage, and fodder (Balasubramanian, Aziz, and Ross 1975; Ballantine
1975).  This method will detect Metolachlor per se and a series of sugar and
                                        50

-------
glutathione conjugates which can form .after hydrolysis of the N-alkyl groups of
Metolachlor to terminal OH groups.    C studies on  rotational crops to corn,
however, gave evidence of other possible metabolites which, if present in a
rotational crop, would not be detected by  the official regulatory method for
corn products.  Also, the following types  of rotational crop products were
found to contain finite residues in one or more samples collected for analysis
by the method of Balasubramanian, Aziz, and Ftoss  (1975):  carrot tops, soybean
stalks, sugar beet tops, and wheat straw.  Finally, lettuce rotated on a
soybean plot treated with   C-Metolachlor  contained detectable residues in
samples of spring and fall seedlings, 41 and 56 weeks after treatment,
respectively (Newby, 1979).


Exposure Profile

    Technical Metolachlor;  For persons involved  in the handling, storage, or
    shipment of Technical Metolachlor, there is little likelihood of oral
    exposure, and because of the low vapor pressure of the viscous liquid,
    there is also little chance of inhalation exposure.  The most likely hunan
    exposure is a repeated dermal exposure, and occasionally, by accident, an
    occular exposure.
         The fate data have indicated the  relative  stability of Metolachlor to
    hydrolysis and metabolic degradation,  and its high mobility in the
    terrestrial environment.  Thus, for wildlife  in the proximity of Technical
    Metolachlor manufacture, storage, shipping, or disposal, if significant
    amounts of the chemical were spilled,  drained, discharged, or disposed of
    in the natural environment, it is possible that exposure could occur to
    various species, but particularly aquatic species, and perhaps to
    carnivores feeding on contaminated fish.  Also, considering Metolachlor1s
    potential for rotational crop uptake,  plants growing on contaminated soil
    could pass on residues to herbivores,  including birds.

    Qnulsifiable Concentrate Metolachlor:  Though all pesticide products, but
    particularly those mixed with seed or  foodstock before application, present
    some possibility of accidental ingestion, for persons involved in the
    dilution, mixing, and application of Metolachlor formulations, there is
    little chance of oral exposure.  But there is a significant possibility of
    dermal and eye exposure from the splashing that may occur in diluting and
    tank mixing, and in the loading of spray equipment.  The vapors from
    the Emulsifiable Concentrates are limited by the vapor pressure and the
    viscosity of the solutions, thus limiting the chance of inhalation
    exposure during mixing or loading.  But the spray droplets generated by the
    application of end-use Matolachlor may result in an inhalation and/or
    dermal exposure for applicators and for agricultural workers or livestock
    who may be in direct proximity to the  spraying.
         As concerns the possibility of wildlife exposures from Metolachlor's
    end-uses, several aspects of Mstolachlor's fate combine to suggest that
    Metolachlor may have a potential to contaminate natural freshwater
    habitats.  This suspicion is supported by the following test findings:
    laboratory column leaching studies, using a wide range of soil types, show
    that Metolachlor per _se is subject to  extensive leaching when applied to
    soils having a low organic content;  field tests designed to show
    dissipation and mobility concluded that extensive leaching was the major
    cause of dissipation in soil,  with residues found to a depth of 12 inches
    below the surface;  runoff studies showed that Metolachlor can move from
    agricultural sites of application both by sheet erosion and leaching;


                                        51

-------
Metolachlor is stable to hydrolysis over the environmental pH range of  5
to 9;  the estimated half-life for Matolachlor  in water  is over  200 days;
loss due to photolysis is minimal  (6% over one month) ;   and Metolachlor can
be resistant to microbial degradation, with soil half-lives reported  to be
greater than 107 days, and anaerobic degradation rates observed  to be
slower and even non-existent.  It  is thus concluded that Metolachlor"s end-
uses may have the potential to contaminate groundwater via leaching and
possibly by surface contamination  (at the well head), thereby exposing
freshwater fish and other freshwater plants and animals, animals which
drink the contaminated water, or carnivores which feed on contaminated
fish.  Also, because of Metolachlor's demonstrated uptake by rotational
crops, it may be assumed that some aquatic or terrestrial plants may  either
suffer phytotoxic exposures or pass Metolachlor residues on to herbivores,
including birds.
     Because there is a concern that residues may migrate to and persist in
aquatic habitats, there is a need to quantitatively determine potential
aquatic exposures, so that these potential exposures can be compared  with
toxic levels for sensitive species.  Fbr this purpose, the Agency will
require that residue monitoring be performed after actual applications
at several sites selected for their ability to demonstrate the potential
for aquatic contamination.  The Agency has identified, in a three-step
process of selection, two watersheds which have been determined
appropriate for Mstolachlor field monitoring:  first, the Agency identified
the regions of the United States in which the most corn? soybeans, peanuts,
and grain sorghum are grown;  secondly, the Agency found six watersheds
within these potential Metolachlor use regions which have terrain and soil
types that could promote the contamination of freshwater by leaching  or
runoff (i.e., a relatively low organic content and flat  terrain  for
leaching, and a high organic content and hilly terrain for runoff)  (Radtke,
1980) ;  finally, the Agency selected the two watersheds which provided the
best delimitation of variables to allow for the clearest interpretation of
results.  The two sites which the Agency thereby selected as appropriate
for watershed residue monitoring are:  one watershed just south  of Treynor
in Fbttawattamie Cbunty, Iowa;  and the Little River experimental watershed
near Tifton, Georgia.
     The possibility for Matolachlor residues to occur in food or feed,
which may result in dietary exposures to hunans, livestock, or domestic
animals, is discussed in the 'Residue Chemistry1 chapter.
                                   52

-------
Generic Data Gaps

    The following are gaps  in  the  Environmental  Fate  data  base  vtfiich will  be
used to support registrations  under  this  Metolachlor  Standard.   Opposite each
gap is given the section  in the  Proposed  Guidelines of July 10,  1978 (FR Fart
163) which describes that type of  data  and  when  it is required.

          1) Adsorption/desorption  studies                  163.62-9
          2) Accumulation  studies on  rotational crops        163.61-ll(b)
            for small grains,  root crops, and  leafy
            vegetables.
          3) Actual  field  residue monitoring studies         (no  guidelines)
            at two  watershed sites to be  approved by
            the Agency.


Suggested Labeling

    There are no environmental  fate  labeling requirements  for manufacturing-
    use Metolachlor labels.

    Conditional upon the  registrant's agreement  to provide the  supporting
    rotational crops data,  Emulsifiable Concentrate Metolachlor  should  carry
    the following rotational crops restriction on  its label:
          "9nall grains may  be  planted 4-1/2 months following treatment. Field
          corn  (except fresh corn and popcorn) , cotton, soybeans, peanuts,
          sorghun, root crops,  and  anall grains may be planted in the spring
          following  treatment.  Eb not graze  or  feed forage  or fodder from cotton
          or anall grains  to livestock.  All  other rotational crops may be
          planted 18 months  after application."
                                        53

-------
                                BIBLIOGRAPHY

    Each of the following studies contributed  useful  information to  the
Agency's review of the environmental  fate of Metolachlor,  and  is considered
part of the data base which supports  registrations  under  this  Standard.


Aziz, S.A.  (1974) Photolysis of CGA-24705 on Soil Slides  under  Natural  and
   Artificial Sunlight Conditions:  GAAC-74102.  Received  Mar  26,  1975  under
   5F1606.  (Unpublished study prepared by  Ciba-Geigy Corp., Greensboro,  N.C.;
   CDL:94385-J)

Aziz, S.A.; Kahrs, R.A.  (1974) Photolysis of CGA-24705  in  Aqueous  Solution
   under Natural and Artificial Sunlight Conditions: GAAC-74041.  Received Sept
   26, 1974 under 5G1553. (unpublished study prepared by Ciba-Geigy  Corp.,
   Greensboro, N.C.; CDL:94222-A)

Aziz, S.A.; Kahrs, R.A.  (1975) Photolysis of CGA-24705  in  Aqueous  Solution —
   Additional Information:  GAAC-75021.  Received Mar 26,  1975  under 5F1606.
   (Unpublished study prepared by Ciba-Geigy Corp., Greensboro,  N.C.;
   CDL:94385-M)

Burkhard, N. (1974) Hydrolysis of CGA-24705 Under Laboratory Conditions,
   PP #5G1553, 'Vblime 2, AC 25.53; SPR 2/74. (Unpublished  report prepared by
   CIBA-GEIGY ltd., Basle, Switzerland; CDL: 94222-H)
                                                        14
Dupre, G.D. (1974a) Abbreviated Anaerobic Metabolism of   C-CGA-24705 in
   Silt Loam Soil under Greenhouse Conditions: Report No.  73019-3. Received Sep
   26, 1974 under 5G1553. (Unpublished study prepared by Bio/dynamics Inc. for
   Ciba-Geigy Corp., Greensboro, N.C. CDL:94222-B)

Ellegehausen, H. (1976a)  Project. Report 4/76:  A Madel system for Estimating
   the Uptake, Transfer and Degradation of  Agrochemicals by Aquatic  Organisms.
   AC 2.52. Received Feb 6, 1978 under 100-583- (Unpublished study prepared by
   Ciba-Geigy Ltd., Basle, Switzerland; CDL:232789-B)

Ellegehausen, H. (1976b)  Project Report 4/76:  Degradation  of CGA 24705  in
   Aerobic, Anaerobic and Autoclaved  Soil.  AC  2.52. Received Feb 6,  1978  under
   100-583. (Unpublished study prepared by  Ciba-Geigy Ltd., Basle,
   Switzerland; CDL:232789-D)

Ellegehausen, H. (1976c)  Project Report 5/76:  Addendum  to  Project Report  4/76:
   Degradation of CGA 24705 in Aerobic, Anaerobic and Autoclaved Soil.  AC
   2.52. Received Feb 6, 1978 under 100-583. (Unpublished  study prepared  by
   Ciba-Geigy Ltd., Basle, Switzerland; CDL:232789-E)

Ellegehausen, H. (19771. Project Report 3/77: Uptake,  Transfer  and Degradation
   of CGA 24705  (Dual1 ') by Aquatic  Organisms. AC  2.52.  Received Feb 6,  1978
   under 100-583.  (Unpublished study  prepared  by CIBA-GEIGY  Ltd.,  Basle,
   Switzerland; CDL:232789-C)
                                      55

-------
            L.D. (1973b) Report on Parent teaching Studies for CGA-24705:
   Report No. 1. Received Sep 26, 1974 under 5G1553. (Unpublished study
   prepared by University of Missouri—Columbia, Department of Plant Pathology
   for Ciba-Geigy Cbrp., Greensboro, N.C.; CDL:94222-E)

Marco, G. (1974) Summary of Section D: CGA-24705-Gom: Residues Cbserved and
   Metabolism Data Including the Analytical Methods Used: GAAC-74062. Received
   Sep 26, 1974 under 5G1553. (Unpublished study prepared by Ciba-Geigy Corp.,
   Greensboro, N.C. that includes studies AG-A-2929, AG-A-2969, AG-A-2973, AG-A-
   3105, AG-A-3133; CDL:94217-A; 94222)

McGahen, L. L.; Tiedje, J.M. (1978).  Metabolism of two new acylanilide
   herbicides, Antor Herbicide  (H-22234)  and Dual (Metolachlor) by the soil
   fungus Chactomium globosum.  Journal of Agricultural Food Chemistry
   26(2):414-419.

Smith, K.S. (1977)  Report: Catfish Bioaccunulation Study Following Exposure to
     C-Metolachlor in a Soil/Water/Fish Ecosystem. 7E-6506; Received Feb 6,
   1978 under 100-583.  (Unpublished study prepared by Cannon Laboratories, Inc.
   for Ciba-Geigy Corp., Greensboro, N.C.; CDL:232789-U)

Sunner, D.D.; Cassidy, J.E.  (1975a)  The  Degradation of CGA-24705 in a Field
   Soil: GAAC-75022.  Received Mar 26, 1975 under 5F1606.  (Unpublished study
   prepared by Ciba-Geigy Corp., Greensboro, N.C.; CDL:94385-M)

Sumner, D.D., Szolics, I.M.; Cassidy, J.E. (1976) Degradation of CGA-24705 in
   Soil. ABR-76057. Received Feb 6, 1978 under 100-583. (Unpublished study
   prepared by Ciba-Geigy Corp., Greensboro, N.C.; CDL:232789-V)
                                       56

-------
                                  TOXICOLOGY
TOPICAL  DISCUSSIONS

    Corresponding  to  each of the Topical Discussions listed below is the nunber
of the section(s)  in  the 'Proposed Guidelines'  of August 22, 1978 (FR Part 163)
which explain(s) the  data that the Agency will  need in order to assess
Matolachlor's  Toxicology.

                                               Guidelines Section(s)
Metabolism and Fharmacodynamics                      163.85-1:
Acute Effects  and  Neurotoxicity              163.81-1, -2,  -3,  and -7
local Irritation                                163.81-4 and 163.81-5
Subchronic Effects and  Naurotoxicity      163.82-1, -2, -4, -5,  and -6
Sensitization                                         163.81-6
Chronic  Effects                                       163.83-1
Chcogenicity                                          163.83-2
Mutagenicity                                    163.84-2,  -3,  and -4
Teratology                                            163.83-3
Reproductive Effects                                  163.83-4


Metabolism and Pharmacodynamics

    Metabolism studies  on Metolachlor (Hambock,  1974a,b)  demonstrated that:
         (a)  Most  orally administered Metolachlor is rapidly absorbed,
         metabolized, and excreted.
         (b)  The urine  and faces of  treated  animals contained a  complex  pattern
         of metabolites; each  metabolite accounted for less than 5% of the
         administered dose.  No unchanged drug  was detected in  urine or  feces
         samples.
         (c)  Approximately half the  urinary  and  fecal  radioactivity was
         extractable with organic solvents.
         (d)  No glucuronide  or sulfate  conjugates were found  in  the excreta.
         (e)  Several excreted  metabolites were  tentatively  identified and
         appear to  result from dechlorination,  0-methylation, N-dealkylation,
         and side chain  oxidation in  the rat.
    In an additional study (Hambock,  1974c) , male rats were treated with  C
Metolachlor (approximately 31mg/kg,  p.o.),  and  urine  and feces  were collected
for 48 hours.  The  urine and feces contained 21.5% and 51.4% of  the
administered dose,  respectively,  and  the halflife was  determined  to  be
approximately  28 hours.   TLC,  GLC, HVE  (high voltage electrophoresis) , colunn
chronatography, gel permeation chrcmatography,  and enzynatic  hydrolysis  were
adequately utilized to  identify radioactive  metabolites,  which were identified
as 2-ethyl-6-methylhydroxyacetanilide (MET-002)  and N-(2-ethyl-6-methylphenyl)-
N-(hydroxyacetyl)-DL-alanine (MET-004)  in the urine and 2-chloro-N-(2-ethyl-6-
methylphenyl)-N-(2-hydroxy-l-methylethyl)acetamide (MET-003)  and  MET-004 in
the feces.  The 48 hour  excreta  contained 1, 15,  and 22%  of the  administered
dose as MET-002, MET-004,  and  MET-003 respectively.  (See the Appendix for
Chemical Data  Sheets on  MET-002,  MET-003,  and MET-004.)
    These studies demonstrate  the relatively rapid metabolism and excretion of
Metolachlor, and are sufficient  to fulfill the  requirement  for  this type of
information.

                                      57

-------
Acute Effects and Neurotoxicity

    Acute Oral Toxicity
         The minimun testing needed on acute oral toxicity  is one  test on  the
    laboratory rat for each technical and formulation.
         Ebr Technical I«tetolachlor, the acute oral LD-50 in the  laboratory
    rat is 2,780 mg/kg with 95% confidence limits of 2,180-3,545 rag/kg  (Bathe
    1973).  Technical Mstolachlor in corn oil has been shovai to  be emetic  in
    beagle dogs to an extent that precludes the establishment of an oral LD-50
    in dogs (Affiliated Medical Research, Incorporated, 1974e).  The study
    did, however, establish the 'emetic dose 50! to be 19.0  (+/- 9.7) mg/kg.
    The Technical therefore falls into Category III with regard  to acute oral
    toxicity.
         Tests were also done on the two Bnulsifiable Gbncentrate formulations.
    In a test involving a 6-pound per gallon E.G. formulation,  the acute oral
    LD-50 was found to be more than 2,000 mg/kg but less than 5,000 mg/kg  in
    the rat (Affiliated' fkdical Research, Incorporated, 1974d) .  In a test
    involving an 8-pound per gallon E.G. formulation, the acute  oral LD-50 in
    the laboratory rat was 2,530 mg/kg with 95% confidence limits of 1,890-
    3,400 mg/kg (Nham and tferrison, 1977a).  A related study (Affiliated
    Msdical Research, incorporated, 1974f)  established that the  'emetic dose
    50' in dogs to a 6-pound per gallon E.G. was 24.5 (+/- 9.2)  mg/kg.  Based
    on the above data, it is anticipated that E.G. formulations of IVfetolachlor
    as high as 8-pounds per gallon can be expected to produce an oral LD-50 of
    not less than approximately 1,890 mg/kg in the rat.  The available data,
    then, places both existing E.G.  formulations in Category III with regard
    to acute oral toxicity„

    Acute Dermal Toxicity
         The minimum testing needed on acute dermal toxicity is one test,
    preferably on the albino rabbit, for each technical and formulation.
         Affiliated Medical Research, Incorporated (1974a)  established that
    the LD-50 of the Technical to the New Zealand rabbit is greater than
    10,000 mg/kg when tested by the unabraded dermal  route.  The above
    information is sufficient to meet the requirsnent for acute dermal toxicity
    data on intact skin.  The uiabraded dermal test results place the Technical
    in Category III with respect to  acute dermal toxicity.
         In a test involving a 6-pound per gallon E.G.  formulation, the acute
    dermal  LD-50 to the tew Zealand  rabbit was found  to be greater than 10,000
    mg/kg by the intact dermal route (Affiliated ffedical Research Incorporated,
    1974b).   For an 8-pound per gallon E»C.  formulation,  it was  established
    that the acute dermal LD-50 to the Wsw Zealand rabbit is greater than
    3,038 mg/kg via the intact denaal route (Nham and Eferrison  1977b).  A
    related study (Tryzna and Rsa, 1976)  determined that the acute dermal LD~
    50 of a  1 to 10 dilution of a 6-pound per gallon  E.G.  formulation was
    greater  than 16f000 mg/kg via the intact dermal route.   The  available
    data,  then? places both existing E*Co formulations  in Category III with
    respect  to acute dermal toxicity„
                                      58

-------
    Acute Inhalation Toxicity
         The minimum data needed on acute inhalation toxicity is one
    inhalation LC-50 test, using one mamnalian species, preferably the albino
    rat,  for each technical and formulation.
         Acute inhalation toxicity for the Technical was tested by Sachsse and
    ULlman (1974a).   In that test there were no deaths in albino rats at the
    maximun achievable level of exposure (1.752 mg/1 with four hours of
    exposure).  This study is adequate to establish a Category IV toxicity with
    regard to inhalation exposure for Technical Mstolachlor.
         In a test involving a 6 pouid per gallon E.G. formulation, the acute
    inhalation LC-50 was found to be greater than 257 mg/1 of air (with four
    hours of exposure)  in the albino rat (Affiliated Msdical Research,
    Incorporated 1974c) .  However, in the test for acute inhalation LC-50 for
    an 8  pounds per  gallon E.G. formulation, the gross pathology raw data
    indicate that the test material had an observable effect at both dosage
    levels in producing areas of consolidation on the lobes of the lungs.  But
    the failure of this Study to provide data on particle size distribution
    invalidates the  study, and it cannot be used to determine the acute
    inhalation toxicity category for the 8 pounds per gallon E.G.  The
    available data,  then, places the existing E.G. formulation of 6 Ibs. par
    gallon or less in Category IV with regard to acute inhalation toxicity»
    The inhalation LC-50 for the 8 pounds per gallon is a data gap.

    Acute Delayed Neurotoxicity
         This type of data is needed only if the active ingredient or any of
    its metabolites, degradation products, or impurities cause esterase
    depression or are structurally related to a substance that induces the
    specific neuropathy, delayed neurotoxicity.  ftetolachlor is a
    chloroacetanilide herbicide and is not expected to cause esterase
    depression or delayed neurotoxicity.  Therefore, this test is not required
    for Technical Metolachlor.
Local Irritation

    Primary Eye Irritation
    The minimun testing needed to evaluate eye irritation potential is one
    test for each technical and formulation, conducted on the albino rabbit*
        A study of eye irritation for the Technical was conducted by Sachsse
    (1973a)  on the New Zealand rabbit.  In that study 0.1 ml of Technical
    Metolachlor was used.  The test was evaluated using the system of Craiza
    (1959)  and produced the following eye irritation and indices at 24 hours
    and 7 days:
                        Cornea:       0
                        Iris:          0
                        Conj unctivae: 0
    This study establishes that Technical Ketolachlor is non-irritating to the
    rabbit eye (Category IV) .
         In a test involving a 6-pound per gallon E.G. formulation, the data
    indicates that this formulation is a severe irritant which can cause
    irreversible corneal opacity in the unrinsed albino rabbit eye  (Affiliated
    Medical Research,  Incorporated, 1974i) .  In a study involving an 8-pound
    per gallon E.G. formulation (Scribor and Ffestri , 1977a):  the results from
    tests conducted with unrinsed eyes showed moderate corneal opacity
    (reversed in 7 days)  and conjunctival effects (partially reversed in 7


                                       59

-------
    days) ; the results from tests on rinsed eyes showed slight iris and
    moderate conjunctival effects (reversed in 3 days).  The available data,
    then, places existing E.G. formulations in Category I  (for 6 Ibs.) or
    Category II  (for 8 Ibs.)  with regard to primary eye irritation.
    Considering the lack of irritation effects due to the active ingredient
    alone (in the Technical), and the difference in eye irritation effects
    between the two formulations, the degree of eye irritation produced by
    Matolachlor formulations appears to be directly dependent upon the type and
    amount of inert formulants used.

    Primary Dermal Irritation
         The minimum testing needed to determine the potential for primary
    dermal irritation is one test conducted on a maximal, preferably the albino
    rabbit, for each technical and formulation.
         Sachsse (1973b)  evaluated the dermal irritation of Technical
    Metolachlor on the New Zealand rabbit.  The test was evaluated using the
    system of Draize (1959)  and resulted in a primary irritation index of 0.1.
    This information is sufficient, and it establishes that Technical
    Metolachlor is non-irritating to rabbit skin (Category IV) .
         In a test involving a 6-pound per gallon E.G. formulation, the primary
    irritation index was determined to be 1.62 (Affiliated Medical Research
    Incorporated, 1974h) .  In a test involving an 8-pound per gallon E.G.
    formulation,  the dermal  irritation was described as:  moderate erythma,
    edema, and second degree burns at 72 hours (Scribor, 1971).  Based on the
    above data, it is anticipated that E.G. formulations of Matolachlor as
    high as 8 pounds per gallon can be expected to produce not less than a
    primary irritation index value of 1.62 (mild irritation)  in the albino
    rabbit.  The available data, then, places existing E.G. formulations in
    Category II (for 8 Ibs.)  or Category IV (for 6 Ibs.)  with regard to primary
    dermal irritation.  As with eye irritation, the degree of dermal irritation
    appears to be dependent  upon the type of inert components used in the
    formulations rather than on the concentration of the active ingredient,
    Metolachlor.
Subchronic Effects and Neurotoxicity

    Subchronic Oral Dosing
         Testing  should be performed in at least 2 mammalian species.  Cne
    species should be a generally recognized strain of laboratory rat while
    the second species should be a non-rodent.
         Three-month feeding  studies were performed with Sprague-Dawley rats
    (Coquet, Galland, Guyot,  Fbuillet,  and Ftouaud, 1974d)  and with beagle dogs
    (Coquet, Galland, Guyot,  Fbuillet,  and Fbuaud, 1974c) .   The Agency
    determined that the histopathology  evaluations for both the rat and the
    dog study were not performed by a pathologist.  Subsequently, the
    histopathology from the 90-day dog  study was re-read by a qualified
    pathologist,  and this  re-evaluation of histopathology was submitted to the
    Agency, allowing this  study to fulfill the Guideline's  requirement for non-
    rodent subchronic oral dosing.
         Because  a two-year rat chronic feeding study was initiated in support
    of tolerance  petitions (see discussion below under 'Chronic Effects'),
    the Agency decided to  waive the need for a re-evaluation of the
    histopathology of the  other 90-day  feeding study - the  one on rats (Coquet
    et al, 1974d) .  However,  because that two-year rat feeding study was
                                      60

-------
    subsequently found to be invalid (again see discussion below under
    'Chronic Effects'), the Agency presently requests (as an interim
    requirement until the two-year chronic feeding study on rats is re-done)
    the additional re-evaluation of the histopathology for the subchronic
    feeding study on rats by Gbquet et al  (1974d).  This histopathology review
    for the subchronic feeding study on rats thus presently constitutes a data
    gap for Mstolachlor.
         A six-month  (180 day) dog study  (IRDC,  1979) was performed in support
    of certain tolerance petitions in lieu of adequate chronic data.  Various
    questions about this study's methodology and statistical calculations have
    now been answered, and the Agency concludes that the 'no observed effect
    level'  (NOEL) in the study was 100 ppm.

    Subchronic 21-Day Dermal
         The minimum testing needed is one study in one mammalian species.
    Although no data is presently available on Technical ftetolachlor, a 21-day
    dermal study was performed using Metolachlor 6E  (68.5% active ingredient)
    and is considered to provide sufficient information (Affiliated Medical
    Research Inc., 1974f).  The study reported no significant evidence of
    systemic effects at a dose level of 540 mg Matolachlor per kilogram, per
    day.  At 1080 mg Metolachlor per kilogram, per day, the only indication of
    systemic effects was decreased body weight gain.

    Subchronic 90-Day Dermal
         This study is not needed because the existing acceptable end-uses
    should not result in repeated hunan skin contact for this long a period.

    Subchronic Inhalation
         The existing acceptable end uses should also not result in repeated
    inhalation exposure at a concentration which is likely to be toxic as
    determined by an acute inhalation test. Therefore, this study is not
    needed.

    Subchronic Neurotoxicity
         Metolachlor  is a chloroacetanilide and  is related in structure to
    registered chemicals that have not induced neuropathy nor delayed
    neurotoxicity, as evidenced by the results of an acute test.  This type
    of data is therefore not needed.
Sensitization

    The minimum data needed to assess dermal sensitization can be provided by
an intradermal test on one mammalian species, preferably the male albino
guinea pig.  The first evaluation of dermal sensitization was conducted by
Affiliated Medical Ftesearch, Incorporated  (1974g) .   Inappropriate methodology
(the patch test)  and the lack of sensitization  in a  positive control
invalidate this study and preclude its use in the regulatory process.  A
second study (Sachsse, 1977) used the intradermal injection method:  Technical
Metolachlor dissolved in the vehicle (propylene glycol) and the vehicle alone
(negative control) were intradermally injected  into  the skin of Pilbright
                                      6 1

-------
 guinea  pigs.   Positive  reaction  was  demonstrated in animals injected with
 Technical  tetolachlor dissolved  in the vehicle;  there was no reaction in
 animals injected  with the vehicle  alone.   Based  on this second study, which is
 sufficient,  it is established  that Technical  Metolachlor is a skin sensitizer
 in guinea  pigs.   Though there  are  no studies  available in which the E.G.
 formulations  were directly  tested, it is  anticipated that E.G. formulations of
 6 or 8  Ibs. ai/gal will also cause skin sensitization in guinea pigs.


 Chronic Effects

     Chronic testing  should  be  available on at least one mammalian species.
 The  species should normally be a generally recognized strain of the laboratory
 rat, and the  route of admnistration  should be through the animals'  diet.
     Cne two-year  feeding study on  the rat was performed (Kennedy, 1976b) , but
 the  Agency found  the study  to  be invalid  because of several deficiencies in
 protocol,  including  the fact that  dose levels were not verified by an analysis
 of the  diet.   The study does offer supplementary information on Metolachlor's
 potential  oncogenicity  (see below) .   Because  this study thus cannot be used to
 fulfill the guidelines  requirement,  the rat chronic feeding study for
 Matolachlor is currently a  data  gap.


 Cncogenicity

     For the adequate assessment  of oncogenicity,  studies  are needed in two
 mammalian  species:   normally,  the  mouse and the  laboratory  rat.
     A mouse study was conducted  with Charles  River CD-I albino  mice (50 of each
 sex)  at levels of 0, 30, 1,000,  and  3,000 ppn fed  in  the  diet.   The duration  of
 the  study  was  18  months for males  and  20  months  for females.   It  was conducted
 by Industrial  Bio-Test  laboratories  (IBT)  and  validated by  Ciba-Geigy
 Corporation (Gesme,  Albanese,  Marias,  and Arceo,  1977).   Because  EPA suspected
 that sane  of the  toxicology studies  performed  by  IBT  were deficient to  the
 point of not being valid for the support  of pesticide  registrations, Ciba-
 Geigy initiated a new mouse oncogenicity  study,   ffcwever, the Agency's
 subsequent in-depth  evaluation of  the  IBT study  found  that, despite certain
 deficiencies in good laboratory  practices  and  animal  husbandry  techniques,  the
 raw  data supported the  reported  negative  results.   The  IBT  study  therefore
 satisfies  the  requirement for mouse oncogenicity testing, and the Agency
 concludes  from it that  Metolachlor is not  oncogenic to mice  at  the  given
 dietary dosages.  Although  the additional mouse data  is not  required,  the
 second  mouse oncogenicity study  is still  underway  and  the Agency  will evaluate
 the  results if and when  they are submitted.
     Though the two-year  chronic  feeding study on rats discussed in  the  'Chronic
 Effects' section above)   (Kennedy,  1976b) was not valid  for  the  fulfillment of
 the  chronic feeding data requirement,  it did offer  supplementary  information
 for oncogenicity by reporting no evidence  that Metolachlor  is oncogenic.
 Nsvertheless,  this study does not  fulfill  the guideline requirement  for  an
oncogenicity test in the rat,  and this constitutes a data gap.  An oncogenic
evaluation performed on the  animals  in  the required two-year  rat  chronic
 feeding study would suffice  for this requirement on oncogenicity  in  the  rat.
                                      62

-------
Mutagenicity

    The following studies  represent  only the  minimum  requirements for data on
the potential heritable  effects  of a pesticide:   (1)  a mammalian in vitro point
mutation test;   (2) a sensitive  sub-mammalian point mutation  test~~(bacteria,
fungi, insect);   (3) a primary ENA damage test (i.e.,  sister  chromatid exchange
or unscheduled ENA synthesis;  and  (4)  a mammalian in vitro cytogenetics test.
If the last test suggests  a  positive result,  a dominant lethal  or heritable
translocation test may be  required.
    After results from these test systems and other  toxicology  disciplines have
been considered, additional  testing  may be required  to further  characterize or
quantify the potential genetic risks.  Although  the  Agency's  mutagenic testing
requirements are not final,  the  standards for these  tests  should be based on
the principles set forth in  the  Proposed Guidelines  (FR 43, No. 163,  August 22,
1978).  Protocols and choices  of test systems should  be accompanied by a
scientific rationale.  Substitution  of test systems  for those listed above will
be considered after discussion with  the Agency.
    These requirements should  be considered an interim guide  and not final
Agency policy.   However,  the Agency  has considered the above  testing scheme to
be a reasonable minimum  requirement.
    In accordance with the fact  that the above policy on mutagenicity testing
is an interim one, the minimum testing presently being required to assess
mutagenicity for Nbtolachlor is  testing in only  two  experimental systems.  The
potential of Metolachlor to  cause genetic changes has  been tested for in a
bacterial system utilizing activation by mammalian microsomes (Arni and Muller,
1976), and in an _in vivo system  to test the effect on developing sperm in the
mouse (Ciba-Geigy Limited, 1976a) .
    The bacterial  (Salmonella) system was tested for  base  substitutions
and point mutations at various ranges (10, 100,  1,000  and  10,000 ug/plate).
No increase in background  mutation rates was  observed.  Isbr were there any
effects noted, in the mouse  study, on fertility  rates, or  on  zygote or embryo
survivals, after single  oral doses of 100 and 300 mg/kg.  Also, no
malformations of resulting embryos were reported.  From these two studies,
which are presently sufficient for mutagenicity  testing, no evidence arose
to suggest that  Metolachlor  has  any  mutagenic potential.  Further mutagenicity
testing on ffetolachlor may later be  required  when a  final  policy on
mutagenicity testing has been  established.


Teratology

    The minimum data needed  to evaluate the potential  fetotoxic or teratogenic
effects of a pesticide are tests in  two mammalian species. A study of the
teratogenic effects of Technical Mstolachlor  on  rats  was conducted by Fritz
 (1976) .  The study found that  doses  of either 0, 60,  180,  or  360 mg/kg/day
during 6 to 15 days of gestation did not effect  the  offspring of female
Sprague-Cawley rats.  ND fetotoxic effects of the compound were observed.
The only possible effect on  the  rats was a decrease  in food consumption at
the highest dose during  the  first 1/3 of the  experiment which may indicate
that this was the beginning  of toxic maternal doses.   This study is sufficient
for the assessment of teratology in  one species  of mammal, and  does not show
any evidence of a teratogenic  hazard for Nfetolachlor.  Data is  still needed
on a second mammalian species.
                                       63

-------
Reproductive Effects

    The minimun data needed for measuring reproductive effects can be
provided by one rat study lasting two generations.  The one available study
(3nith and Adler, 1978)  had significant deficiencies including problems in
animal husbandry, mating performance and success (possibly caused by poor
animal health), and observation records, which cause the Agency to consider
its conclusions as only 'supplementary' information.  The study suggests no
reproductive effects, but Metolachlor still requires a satisfactory multi-
generation reproduction study.
                                     64

-------
DISCIPLINARY REVIEW

•toxicology Profile
Toxicology tezard Assessment
Generic Data Gaps
Product Specific Eata Gaps
Suggested Labeling


Toxicology Profile

    Technical Metolachlor:  Sufficient data were available to support
    an assessment of the Technical's acute toxicity.  The relatively high
    acute oral LD-50 in rats (2780 mg/kg) and the emetic effects in dogs
    indicate a low acute oral toxicity to hunans.  Eermally,  at least in the
    rabbit, Metolachlor does not appreciably penetrate intact skin.  Ebses of
    up to 10,000 mg/kg caused no signs of toxicity and little irritation.
    Pending receipt of data on abraded skin, it would appear that Metolachlor
    would' not be readily absorbed through human skin.  The lack of toxic signs
    or irritation from high acute dermal exposure in test animals indicates
    that Technical Metolachlor has a low dermal toxicity to hunans.  Testing of
    acute inhalation toxicity in rats failed to elicit any deaths at the
    maximum achievable concentration (1.752 mg/1 for 4 hours exposure), and so
    a low inhalation toxicity to humans for manufacturing-use Metolachlor may
    be expected.
         Information was also available on the irritation and sensitization
    potential of Technical Metolachlor.  In a primary eye irritation study
    conducted on albino rabbits, no signs of irritation were observed.  Based
    on the rabbit as an indicator species, Metolachlor is not expected to be
    irritating to human eyes.  A dermal sensitization study in guinea pigs
    indicated that Metolachlor was a skin sensitizer to that species.
    Metolachlor should therefore be considered a potential skin sensitizer in
    hunans.
         A six-month dog study indicated an oral 'no observed effect level1
    (NOEL)  of 100 ppn, and this is presently the only NOEL value available for
    tolerance setting.  (See Residue Chemistry 'Tolerance Reassessment1.)  The
    one available chronic (two year) feeding study was not valid, though it
    offered evidence to support the conclusion of the one oncogenicity study in
    mice that Metolachlor is not oncogenic by the dietary levels tested.
    Though data on a second species will be needed, there was one study of
    teratogenic effects in rats, and it reported no teratogenic or fetotoxic
    effects due to Metolachlor at the doses tested.  Metolachlor has been
    tested in two systems for mutagenicity:  a bacterial system, and an in vivo
    system in the mouse.  No evidence is presented in either study to sugge'sl;
    that Metolachlor has any mutagenic potential.
         The currently registered Metolachlor Technical product falls into the
    following 'Tbxicity Categories'  [see 40 CFR 162.10 (h)(l)]:
              Acute Oral Tbxicity:  Category III
              Acute Dermal Toxicity:  Category III
              Acute Inhalation Toxicity:  Category IV
              Primary Eye Irritation:  Category IV
              Primary Dermal Irritation:  Category IV
                                      65

-------
    Emulsifiable Concentrate;  For the E.G. formulations of  6 and 8 Ibs,
    aT7gallon, the" repTrtlcTvalues of 1,890 mg/kg or higher  indicate a
    relatively high acute oral LD-50 in rats, implying a low acute oral
    toxicity for huaans.  Dennally, at least in the rabbit,  the two existing
    B.C. formulations of ffetolachlor do not appreciably penetrate intact  skin,
    and doses of up to 3,038 mg/kg produced no signs of toxicity in the !few
    Zealand rabbit,  From existing data, it can thus be assumed that the  E.G.
    formulations of 6 and 8 Ibs. ai/gallon present a low overall acute toxicity
    to humans via the intact dermal route.  The test on acute inhalation  was
    only available for the six pound per gallon E.G., and demonstrated a  very
    low acute inhalation toxicity.  A test for the eight pounds per gallon
    EoC, is required because of the difference in volatile inerts.
         The potential for local irritation and sensitization appears to  be
    significant..  Based on the albino rabbit as an indicator species, the 8
    Ibs. ai/gallon formulation will produce moderate erythma, edema, and  second
    degree burns (severe irritation).  A dermal sensitization study in guinea
    pigs indicated that two registered E.G. formulations are also potential
    skin sensitizers in humans„  In a primary eye irritation study conducted on
    the albino rabbit, the 6 Ibs. ai/gallon formulation of Metolachlor was
    fo'jid to cause irreversible corneal opacity and severe irritation in
    uisrinsed eyes, which indicates a potential for serious hunan eye irritation
    due to that formulation„
         The currently registered Mstolachlor Emulsifiable Concentrate Products
    fsll into the following "Ibxicity Categories'  [see 40 CFR 162.10 (h) (1) ] :
         Snulsifiable Cbncentrate (6 Ibs, active ingredient per gallon):
              Acute Oral Tbxicity:  Category III
              Acute Dermal Tbxicity:  Category III
              Acute Inhalation Tbxicity:   Category IV
              Primary Eye Irritation:  Category I
              Primary Dermal Irritation:   Category IV
         Briulsifiable Cbncentrate (8 Ibs. active ingredient per gallon):
              Acute Oral Ibxicity:  Category III
              Acute normal Tbxicity:  Category III
              Acute Inhalation Tbxicity:   undetermined
              Primary Eye Irritation:  Category II
              Primary Dermal Irritation;   Category II


Tojdcology Hazard Assessment

    Technical tetolachlor;   Considering  first the  potential for human (or
    domestic animal)"'exposure  to  manufacturing-use Matolachlor,  it  was  stated
    in the Exposure Profile that  there is little likelihood of oral  exposure,
    and that because  of the low vapor pressure  of  the necessarily viscous
    liquid, there is  also little  chance  of inhalation exposure.  The most
    likely type  of  exposure for persons  involved in the handling,  storage,
    shipment, or re-formulation of Technical  ffetolachlor is a repeated  dermal
    exposure.
         Because of Technical  Fetolachlor's low acute oral  toxicity,  and  very
    low inhalation  toxicity, we may dismiss these  unlikely  exposure  routes as
    significant  sources of hazard.   The occasional occular  exposure  is  also
    not of serious  concern,,  as no eye irritation effects would  be expected.
    ait with respect  to dermal exposures,  although it has been  shown that
    i-etolachlor  is  not  readily absorbed by  the  skin,  the likelihood  of  repeated
    dermal  exposure  raises tv*o concerns:   first,  Metolachlor has been  observed


                                      66

-------
to^elicit a dennal sensitization reaction;  second, although no positive
evidence of general chronic,  teratogenic, fetotoxic, oncogenic, or
mutagenic effects has so far  been presented,  the available information is
presently insufficient  to satisfy all  the Agency's requirements for the
study of chronic effects.   Thus the risks to  hunans caused by repeated
dermal exposures to a Technical Metolachlor solution cannot be concluded at
this time, and the only presently known hazard of manufacturing-use
Mstolachlor is the potential  for dermal sensitization for factory,
transport? or re-formulation  workers.

anulsifiable Concentrate;   The hazards to humans and domestic animals
that may arise from the "end-use of an  agricultural pesticide are of three
kinds:  those hazards to humans which  arise in the tank mixing, dilution,
application, storage, or disposal of the end-use chemical;  those hazards
to humans and domestic  animals which arise as a result of ambient
residues from pesticide application, storage, or disposal, including
residues in air, water, and edible wildlife;  and, finally, those hazards
to hunans or domestic animals which may arise as a result of anticipated
residues in harvested food  or feed.  The first two kinds are considered
here in the Toxicology  chapter.  The last kind will be considered in the
Residue Chemistry chapter.
     As was stated in the Exposure Profile, there is little chance for
accidental oral exposure to a soil-sprayed pesticide that is not mixed
with foodstuffs before  application.  But there is a chance for dennal and
eye exposure for chanical applicators  who are tank mixing, diluting, or
loading.  There is also a chance of inhalation exposure for applicators,
agricultural workers, and livestock in the proximity of the spraying.
Though spray drift properties of Metolachlor  applications have not been
established, and Metolachlor  may therefore not be applied aerially, ambient
air residue exposures may conceivably  occur to persons or livestock outside
the ground-spray area.  Due to leaching and a stability to hydrolysis,
residues may also be found  in nearby freshwater streams or ponds, thus
posing the threat of repeated exposures to livestock drinking the water or
grazing on nearby plants, or  to persons ingesting contaminated fish or
water.
     The routine outdoor agricultural  field use of Metolachlor could
directly result in a number of minor hazards  for hunans.  The data show
that it is possible for a Metolachlor  formulation to cause irreversible
corneal opacity and severe  iritation to an applicator whose eyes are
unprotected during mixing,  loading, or diluting.  Similarly, an applicator
with unprotected hands  or face could run an acute risk of erythrna, edema,
and second degree burns due to contact with certain formulations.  If
dermal exposures to any Matolachlor formulation are repeated, there is a
risk of a sensitization reaction.  Finally, though the active ingredient
is not readily absorbed through the skin, various chronic or reproductive
effects from a repeated dermal or inhalation  exposure to a Metolachlor
formulation cannot presently  be ruled  out.
     Anbient residues from  the ground-spray application of a Metolachlor
formulation may present parallel, though significantly lesser, hazards to
persons or livestock outside  the spray area.  Of potential concern are the
long-term, repeated exposures for livestock or hunans drinking contaminated
water or feeding on nearby  aquatic and plant  life, possibly resulting in
undetermined chronic effects.
                                   67

-------
Generic Data Gaps

    The following are gaps in the Toxicology data base which  will  be  used  to
support registrations under this Metolachlor Standard.  After each gap  is
listed the section in the Proposed Guidelines of August 22,  1978  (FR  Part  163)
which describes that type of study and when it  is required.

         1)   Subchronic Oral Dosing - Acceptable pathology       163.82-1
              evaluation is required for the rat study.
         2)   Chronic Feeding - A chronic feeding study using     163.83-1
              the laboratory rat is required.
         3)   Oncogenicity - An oncogenic evaluation performed    163.83-2
              for the chronic feeding study [see  (2) above] ,  or
              an oncogenicity study in a mammalian species other
              than the mouse (preferably the laboratory rat) .
              The Agency is also awaiting the results of the
              second mouse study.
         4)   Teratology - A teratology study in a mammalian       163.83-3
              species other than the rat is required.
         5)   Reproduction - A multi-generation reproduction       163.83-4
              study on one mammalian species (preferably the
              laboratory rat).


Product Specific Data Gaps

    The following is a "product specific" data gap for Toxicology  which
needs to be filled in order to maintain in effect a current registrations  under
this Standard.  After the gap is the section in the Proposed  Guidelines
(August 22, 1978, FR Part 163)  which describes that type of data and  when  it
is required.

    For Bnulsifiable Concentrate Mstolachlor (8 Ibs. ai/gallon):
         1)   Acute inhalation toxicity study.                     163.81-3


Suggested Labeling

    See the tetolachlor Standard's 'Regulatory Rationale'  for  a discussion of
the levels of acute toxicity which the Agency will consider acceptable, and  the
second chapter of the Standard for a listing of the specific  label statements
appropriate to the acceptable 'Tbxicity Categories.'  Section  162.10 of the  CFR
40 explains the Agency's established toxicity labeling requirements as they
relate to the "Ibxicity Categories'.
    The only toxicology labeling suggested by the available data that does not
follow directly from ftetolachlor' s "Ibxicity Categories'  is a  precaution
concerning  dermal sensitization:  "my cause skin sensitization. Wear gloves
and protective clothing while  handling  or using this product.  Wash thoroughly
after handling. Remove and wash contaminated clothing before  re-use."
                                      68

-------
                                 BIBLIOGRAPHY

    Each of the  following  studies  contributed  useful information to the
Agency's review of the  toxicology  of  Metolachlor,  and is  considered part of the
data base which  supports registrations  under this  Standard.


Affiliated Medical Research,  Incorporated  (1974a)  Acute Dermal LDv,, of CGA-
    24705 - Technical in Rabbits:   Contract  ND.  120-2255-34.   Received Sep 26,
    1974 under 5G1553.   (Unpublished  study prepared  for Ciba-Geigy Corp.,
    Greensboro, N.C.; CDL:112840-E)

Affiliated Medical Research,  Incorporated  (1974e)  Emetic  Ebse 50 in Beagle
    Dogs with CGA-24705-Technical:  Contract No.  120-2255-34.  Received Sep 26,
    1974, Greensboro, N.C.; CDL:112840-C)

Affiliated Medical Research,  Incorporated  (1974f)  Twenty-one  Day Repeated
    Dermal Tbxicity  of  CGA-24705-6E in  Rabbits:   Contract No. 120-2255-34.
    Received Sep  26, 1974  under  561553.  (Unpublished study prepared for Ciba-
    Geigy Corp.,  Greensboro,  N.C.;  CDL: 112840-Q)

Affiliated Medical Research,  Incorporated  (1974g)  Evaluation  of CGA-24705
    Technical  (FL740408) as a Potential Skin Sensitizer in the Guinea Pig:
    Contract No.  120-2255-34. Received Sep  26,  1997 under 5G1553.
    (Unpublished  reportprepared  for Ciba-Geigy Corp., Greensboro, N.C.;
    CDL: 11284 0-K)

Arni, P.; Muller, D.  (1976) Salmonella/Mammalian-Microsome Mutagenicity Test
    with CGA 24705  (Test for  Mutagenic  Properties  in Bateria):  PH 2.632.
    Received Jan  19, 1977  under  7F1913.  (Unpublished study prepared by Ciba-
    Geigy, Ltd.,  Basle,  Switzerland;  CDL:95768-B)

Bathe, R. (1973) Acute  Oral LD^ of Technical  CGA-24705 inthe Rat:   Project
    No. Siss 2979.   Received  SSp 26,  1974  under  5G1553.  (Unpublised study
    prepared by  Ciba-Geigy Corp.,  Ltd., Basle, Switzerland; CDL:112840-A)

Ciba-Geigy Limited  (1976a) Dominant Lethal Study on  CGA 24705 Technical: Mouse
    (Test for Cytotoxic or Mutagenic  Effects on  Male Germinal Cells)  PH 2.632.
    Received Jan  18, 1978  under  7F1913.  (Unpublished study including
    Addendum; CDL:96717-C; 96717-D)

Ciba-Geigy Limited  (1976b)  Reproduction Study CGA 24705  Tech.:  Rat: Seg. II
    (Test for Teratogenic  or  Embryotoxic Effects)  PH 2.632.   Received Jan 18,
    1978 under 7F1913.   (Unpublished  study including Addendum; CDL:96717-A;
    96717-B)

Ciba-Geigy Limited  (1977)  Skin Sensitizing (Contact  Allergenic)  Effect in
    Guinea Pigs of Technical  CGA 24705:  Siss  5726.   Received Jan 18, 1978
    under 7F1913.   (Unpublished  study;  CDL:96717-E)
                                       69

-------
Cbquet, B.; Galland,  L.; Guyot,  D.;  Ebuillet,  X.;  Rouanud,  J. L. (1974a)  Essai
    de Tbxicite de 3 Mois chez  Le  Chien  par  Mbie  Orale  du Produit CGA 24 705.
     [Three-Month  Oral  Tbxicity  Trial of  CGA  24 705 in  Cog]:  IC-DREB-R-740119.
    Received Sep  26,  1974 under  5G1553.   (Unpublished  study prepared by the
    Chcins Research and Breeding Center  for  Ciba-Geigy  Corp.,  Greensboro, N.C.;
    CDL:94223-B)

Coquet, B.; Galland,  L.; Guyot,  D.; Fouillet,  X.;  Fbuaud, J. L.  (1974b)  Essai de
    Tbxicite de 3 Mois chez  Le Rat par Voie  Orale  du Produite CGA 24 705.
     [Three month oral  ToxicityTrial of CGA 24  705  in Rats]:  IC-DREB-R-740120.
    Received Mar  1, 1974 under 5G1553.   (Unpublished study  prepared bythe
    Cncins Research and Breeding Center  for  Ciba-Geigy  Corp., Greensboro, N.C.;
    CDL:94219-B)

Coquet, B.; Galland,  L.; Guyot,  D.; Fouillet,  X.;  Rouanud,  J. L. (1974c)  Three-
    Month Oral Toxicity Test of CGA 24 705 in  Dog.  A translation  of:  Essai de
    Toxicite de 3 Mois chez  Le Chien par  ^ie  Orale du  Produit  CGA 24 705:   IC-
    EREB-R-740119.  Received Sep 26, 1974 under 5G1553.   (Ihpublished study
    prepared by the Chcins Research and  Breeding Center  for Ciba-Geigy Corp.,
    Greensboro, N.C.; CDL:94223-A)

Coquet, B.; Galland L.; Guyot, D.; Fouillet, X.; Fbuaud,  J. L. (1974d)  Three-
    Month Oral Toxicity Test of CGA 24 705 in  Rats.  A  translation of:   Essai
    de Toxicite de 3 Mois chez te Pat par \foie Orale du Produit CGA 24 705:  IC-
    EREB- R-740120.  Received Mar 1, 1974 under 5G1553.   (Unpublished study
    prepared by the Cncins Research and Breeding Center  for Ciba-Geigy Corp.,
    Greensboro, N.C.; CDL:94219-A)

Draize, J.H. (1959) The Appraisal of Chemicals in  Food,  Drugs,  and Cosmetics.
    Association of Food and Drug Officials of the  United  States.  Austin,  Texas.

Fritz, H. (1976) Reproduction Study CGA  24705 Tech. Pat:  Sag. II:   (Test  for
    Teratogenic or Qnbryotoxic Effects):  PH 2.632.  Received Jan  19, 1977
    under 7F1913.   (Unpublished study prepared by  Ciba-Geigy Ltd., Basle,
    Switzerland; CDL:95768^)

Gesme, J.; Albanese, E.; Marias, A.J. (1977)  Report to  Ciba-Geigy Corporation:
    Carcinogenicity Study with CGA-24705  Technical  in Albino Mice:  IBT ND. 622-
    07925 (8532-07925).  Received Jan 18, 1978 under 7F1913.  (Unpublished
    study prepared by Industrial Bio-Test Laboratories,  Inc. for  Ciba-Geigy
    Corp.; including* Validation report prepared by  Ciba-  Geigy  Corp.,
    Greensboro, N.C.; CDL:96719^;  96720-^A; 96720-B)

Gfeller, W.  (1974) Tolerability Trial in Milk Cows with CGA-24705:   14,  21, and
    28 day Feeding Study:   AC 9.26; T73/23.  Received Sep 26, 1974 under
    5G1553.   (Unpublished  study prepared by Ciba-Geigy  Lt.,  St. Aubin,
    Switzerland; CDL:94216-F)

Bambock,  H.  (1974a)  Project ND . 7/74:  Metabolism of CGA  24 705 in the Pat.
    (Status  of Results Gathered up  to June 10,  1974):  AC 2.52.   Received Sep
    26,  1974 under 5G1553.   (Unpublished report prepared  by Ciba-Geigy  Ltd.,
    Basle,  Switzerland; CDL:94217-L)
                                       7 0

-------
Hambock, H.  (1974b) Project Report  12/74:   Addendum  to  Project  Report 7/74:
    Metabolism of CGA  24 705  in  the  Rat:  AC  2.52; Received  Nov.  25,  1975 under
    631708.   (Unpublished report prepared by  Ciba-Geigy Ltd., Basle,
    Switzerland; CDL:94984-P)

Hambock, H.  (1974c) Project Report No.  1/74:   Distributions, Degradation and
    Excretion of CGA 24 705 in the Rat.  Received Sep  26,  1974  under  5G1553.
    (Unpublished report prepared by  Ciba-Geigy Ltd., Basle,  Switzerland;
    CDL:94217-K)

Kennedy, G. L. (1975) 28-Day Mouse Pilot  Study with CGA-24705 (Technical).
    Received Feb 16, 1978 under  100-583:  dated  Nov  21.  1975; 1ST No.  622-
    07857.   (Unpublished study prepared  by  Industrial  Bio-Test  Laboratories,
    Inc. for Ciba- Gaigy Corp.,  Greensboro, N.C.; CDL-232855-B)

Kennedy, G. L. (1976a)  Letter  dated Dec  10,  1976,  relative  to the  results of
    the first generation of a three-generation reproduction  study in  albino
    rats with the chemical CGA 24705 (IBT No.  8533-079280] to George  Rolofson.
    Received Jan 19, 1977 under  7F1913.   (Unpublished  study  prepared  by
    Industrial Bio-Test Laboratory,  Inc., for  Ciba-Geigy Corp., Greensboro,
    N.C.; CDL:95768-E)

Kennedy, G. L. (1976b)  Letter  [dated  Dec  13, 1976, interim  reporton IBT No. 8531-
    07926, 2-year chronic toxicity of CGA 24705  in albino  rats] to George
    Rolofson.  Received Jan 19,  1977 under  7F1913.   (Unpublished  study prepared
    by  Industrial Bio-Test Laboratories,  Inc., for Ciba-Geigy Corp.,
    Greensboro, N.C.;  CDL:95768-D)

Kennedy, G. L. (1976c)  Letter  [dated  Dec  13, 1976, relative to the 2-year
    carcinogenicity study of  CGA 24705  in albino mice  (IBT Isb.  8531-07925)] to
    George Rolofson.   Received Jan  19,  1977 under 7F1913.  (Unpublished  study
    prepared by Industrial Bio-Test  laboratories, Inc.,  for  Ciba-Geigy Corp.,
    Greensboro, N.C.;  CDL:95768-C)

Cncins  Research and Breeding  Center  (1974)  Three-Month Dietary  Feeding Study  in
    Rats:  CGA 24 705.  A translation of:   Toxicite  de  3 Mois chez le Rat par
    A/bie Orale du Produit CGA 24 705, translated  by  F.  Roulet:   IC-DREB-R
    741009.  Received  Mar 26, 1975  under 5F1606.   (Unpublished  study  prepared
    by  Ciba-Geigy Corp., Greensboro, N.C.;  CDL:94377-B)

Sachsse, K.  (1973a)  Irritation of Technical CGA-24705  in the Rabbit Eye:
    Project  No. Siss 2979.  Received Sep 1974 under  5G1553.   (Unpublished
    report prepared by Ciba-Geigy Ltd.,  Basle, Switzerland;  CDL:112840-G)

Sachsse, K.  (1973b) Skin Irritation  in  the  Rabbit after Single  Application of
    Technical CGA-24705:  Project No. Siss  2979.  Received  Sep 26, 1974 under
    5G1553.   (Unpublished study  prepared by Ciba-Geigy Ltd., Basle,
    Switzerland; CDL:112840-1)

Sachsse, K.; Ullman, L. (1974a)  Acute Inhalation Toxicity  of Technical CGA-
    24705 in the Rat:  Project No.  Siss  3516.   Received Sep  26,  1974  under
    5G1553.   (Unpublished study  prepared by Ciba^3eigy Ltd., Basle,
    Switzerland; CDL:112840-L)
                                       71

-------
Sachsse, K. (1977) Skin Sensitizing  (Cbntact Allergenic)Effect  in  Guinea Pigs
    of Technical CGA-24705.  Project No. Siss  5726.   Received October  17,
    1977.  [Unpublished study prepared by Ciba-Geigy  Ltd.,  Basle,  Switzerland]

Smith, S.H.;  Adle'r", G. L. (1978) Final Report to Ciba-Geigy  Cbrp.:   Three-
    Generation Reproduction Study with CGA-24705 Technical  in Albino Rats:  IBT
    No. 8533-07928.  Received Jan 18, 1978 under 7F1913.   (Unpublished study
    prepared  by Industrial Bio-Test  Laboratories,  Inc.  for  Ciba-Geigy  Corp.
    Greensboro, N.C.; CDL:96718-A; 96718-B)

Sunner, D.D.  (1978a)  Audit Report CQted Nov 21, 1975:   28-Eay touse  Pilot  Study
    with CGA-24705 (Technical).  Received Feb  16,  1978  under 100-583;  IBT No.
    622-07857.  (Lhpublished study prepared by Ciba-Geigy Corp., Greensboro,
    N.C.; CDL:232855-C)

Sumner, D.D.  (1978b)  Addendum to Audit Report Dated Jan  12, 1978:
    Carcinogenic Study with CGA-24705 Technical in Albino Mice.  Received  Feb
    16, 1978  under 100-583; IBT No. 622-07925.  (Unpublished study prepared  by
    Ciba-Geigy Corp., Greensboro, N.C.; CDL.-232855-A)
                                       72

-------
                               RESIDUE CHEMISTRY
TOPICAL DISCUSSIONS

Metabolism  in  Plants
Matabolism  in  Animals
Analytical  Methodology
Residue Data
Present Tolerances
Metabolism in Plants

    The absorption, distribution,  and metabolic  fate  of  Metolachlor were
investigated in corn plants grown  under  field  and greenhouse conditions
(Sumner and Cassidy, 1974c,d)  and  in soybeans  grown under greenhouse
conditions only  (Sunner and Cassidy, 1975).
    Ring-labeled Metolachlor  was applied as  a  pre-emergence treatment at  2  Ibs.
ai/acre.  For corn, it was dissolved in  nutrient solution at a concentration of
approxiornately 2 ppm and  applied to field and  greenhouse soils.   For soybeans,
it was added to soil and  plantings were  incubated in  the greenhouse.  The
maximum levels of  residues found in the  various  plant parts, based on total
radioactivity, were as follows:  corn grain, greenhouse  and field, 0.05 ppn
and 0.02 ppm, respectively; corn forage, greenhouse and  field, 0.72 and 0.17
ppji, respectively; soybeans 0.17 ppm, soybean  hay 2.66 ppm, soybean oil 0.01
ppm and soybean meal 0.14 ppm.  These data show  that  the total residues in
soybeans are higher than  those  in  corn.
    The metabolism of Metolachlor  by corn plants consists of a major and a
minor pathway.  The figure in the  'Disciplinary  Review1  at the end of this
chapter depicts these pathways for both  corn and soybeajj4plants  (Marco 1975) .
    When corn plants were grown in soil  treated  with  fi-  C-Metolachlor at 2
Ibs. ai/acre (Sunner and  Cassidy 1974d),  extracts of  4-week old  corn plants
contained less than 10% of the extractable radioactivity present in the
organic fraction.  Very little, if any,  of the activity  was present as parent
Metolachlor.  More than 80% of the remaining activity was found  in the polar
fraction.  TLC characterization indicated the  presence of at least 10
metabolites.  The highly  polar  nature of these metabolites indicated
conjugation of the parent and/or its metabolites had  occurred with natural
products such as amino acids, sugars, or sugar acids  (Sumner and Cassidy,
1974C).
    One metabolic pathway in  the corn plants involves conjugation of
Metolachlor with glutathione  (Sunner and  Cassidy, 1974b).  Fourteen percent of
the radioactive Metolachlor recovered from corn  leaves was found conjugated
with glutathione.  It appears that degradation occurs through a  thio-ether
bond forming a glutathione conjugate via  the reactive chloroacetyl moiety of
Metolachlor.
    Metabolites, which upon hydrolysis,  produce  2-[(2-ethyl-6-methylphenyl)
amino]-1-propanol  (HP-001) and  4-(2-ethyl-6-methylphenyl)-2-hydroxy-5-methyl-3-
morpholinone (HP-002)  were found to be common  in plants  and in animals, from
high level feedings of Metolachlor (Hambock, 1974a,b,c;  Mattson,  1975).  When
partly purified plant conjugates were cleaved  by a reduction reaction with
                                       73

-------
Raney nickel, which breaks thio-ether bonds  (Gross, 1974a and Gross,  19745} ,
tvo compounds, M- (2-ethyl-6-methylphenyl) -N- (2-methoxy-l-methylethyl) acetamide
(MET-005) , and N-(2-ethyl-6-methylphaiyl)-N-(2-hydroxy-l-methylethyl)acetanide
(MET-006) ware produced, indicating that these compounds were moieties of
sulfur-bonded conjugates.  These two compounds represent 80% of the
radioactivity extracted from the corn leaves.  They were positively identified
by GLC <-iT:d mass spectrcmetry,,
    Further residue characterization, involving rigorous HQ hydrolysis
(Sunner,, Thomas, and Cassidy, 1975), showed the presence of either 2-[ (2-ethyl-
6-methyIphenyl)amino]-l-propanol (HP-001) or 4-(2-^thyl-6-methylphenyl) -2-
hydroxy-5-methyl=3-morpholinone (HP-002).  These data suggest that the
compounds present before hydrolysis are predominantly alpha-thioglycoside
metabolites and the alpha-oxygen glycoside analogues.  The relative amounts of
the compounds indicate that the major pathway of metabolism involves
conjugation with glutathione, breakage of the thio- bond to form the
rnercaptan, conjugation of mercaptan with glucuronic acid, hydrolysis of methyl
ether, and conjugation of the alcohol with a neutral sugar.  A minor pathway
assumes chloro replacement by hydroxyl.  The same pathway may also involve
direct conjugation with glucuronic  acid,  followed by demethylation and
conjugation of the hydroxyl with a  neutral sugar, all forming oxo- conjugates.
    When radiolabeled 0-  C-Metolachlor was applied to growing soybeans
(Summer and Cassidy, 1975b), characterization of the extracted residues
indicated that the metabolic pathways in soybeans are similar to 'those
observed in corn.  Thin-layer chronatography and partitioning data indicated
that higher concentrations of less  polar metabolites will occur in soybeans
when compared to corn grain.
    Because it has been suggested that the chloroacetyl group could split off
as monochloroacetic acid and occur  as part of the terminal residue, Tbxicology
reviewers expressed concern about the possible presence of monochloroacetic
acid as a component of the residues of Metolachlor, resulting from metabolism
or degradation of the parent compound.  However, Residue Chemistry reviewers
can find no reason to expect monochloroacetic acid to occur as a residue
following the use of Metolachlor.  While there is no definitive data on the
matter, the Agency has postulated,  based upon the unique chemical and
biological stability of the amide bond and the relatively unstable carbon-
chlorine bond in Metolachlor, that  any hydrolysis of the amide would be
preceded by displacement of the chlorine.  Consequently, the presence of
monochloroacetic acid as a product  of metabolism is not likely to occur.
    The above studies adequately define the fate of Metolachlor in soybeans
and corn for the purposes of establishing tolerances.              "    : ~~~
    Though no studies were available for peanuts or sorghum, the metabolism
studies for corn and soybeans are adequate to reflect the nature of Metolachlor
residues in peanuts and sorghum.  In other words, the Agency is taking the
position that the nature of the residues in peanuts and sorghum is similar to
that of corn and soybeans.  ND metabolism studies are yet available for root
crops such as potatoes.  Because the residue in root crops may differ from
that of non-root crops, we are unable to apply the data on corn and soybeans to
root crops such as potatoes.  If. a  tolerance is to be established root crops,
root crop metabolism data will be needed.
                                       7 4

-------
1'ietabollsm In Animals

    Matolachlor is rapidly metabolized and almost totally eliminated in the
urine and feces of runinants  (goats), non-runinants  (rats), and poultry (Roger
and Cassidy, 1974a; Hambock,  1974a-  Guth, 1974).  These findings ware made in
studies using both unlabeled  and   C-ring-labeled Metolachlor.  Matolachlor
per se was not detected in any of the excreta or tissues.
    Additional studies with goats (Cbunselman and Fbger, 1973; Fbger and
Cassidy, 1974a,b)  confirmed the finding that the urine and feces contain
almost all the metabolized products.
    In animals, trace amounts of metabolized Matolachlor were found in kidneys,
liver, blood, and milk (Biouetric Itesting Incorporated, 1973; Hambock, 1974a,
b,c; Schenker, 1975a) .
    No residues were found in eggs, meat, or fat samples of laying chickens.
The only metabolite found, in the liver (at 0.02 - 0.03 ppm), was the one
which upon hydrolysis yields  HP-001  (Mattson, 1974,  1975).  ND precursor of
the hydrolysis product HP-002 was found in the liver  (Oath, 1974).
    When   C-labeled metabolites of  Metolachlor, bio-synthesized in corn,
were fed to goats, no parent Metolachlor nor any metabolites were found in the
animals' tissues or milk  (Ciba-Geigy Limited, 1973;  Schenker, 1974, 1975b).
    It is concluded that  the metabolism of Metolachlor in animals appears to be
similar to and as complex as  that in plants.  Whereas plants retain their
metabolic products, animals eliminate their Metolachlor metabolic ..products
almost entirely.  Various studies with unlabeled Nfetolachlor and   C-ring
labeled Metolachlor fed to different animals indicate clearly the identity and
the amounts of the metabolites which result as residues in the excreta,
tissues, milk, and eggs.
    Although the exact metabolic pathway of Metolachlor in animals is not
known, the available metabolic studies adequately delineate the fate of
Matolachlor in animals for the purposes of establishing tolerances for corn
grain and soybeans.  (Ebr an evaluation of rat metabolism data, please see
Ibxicology Chapter.)


Analytical Methodology

    Metolachlor in Corn and Soybeans
         The reslcfue data submitted  for corn were obtained by the use of
    methods AG-265 (Balasubramanian, Gold, and Ross, 1974)  and AG-277
    (Balasubramanian, Aziz, and Ross, 1975).  The residue data for soybeans
    were obtained  by Method AG-286 (Aziz and Ross, 1975) .  Most of the corn
    residue data were obtained by Method AG-265.  This method utilizes HQ to
    hydrolyze Metolachlor and those metabolites which are capable of
    conversion to  2-[(2-ethyl-6-methylphenyl)amino]-1-propanol (HP-001).
         In Method AG-265, fifty grams of ground or chopped sample is refluxed
    with 250 ml  of 6N HO. for 16 hours.  The aqueous extract is filtered off,
    neutralized, and made basic with NaOH solution and extracted twice with
    hexane.  The combined hexane extracts are chromatographed on an alunina
    colunn.  The residues of HP-001 are eluted using 5% ether in hexane.  The
    eluate is evaporated and the residues are taken up in 0.5 ml of benzene.
    An aliquot of  the  sample solution is injected into a gas chromatograph
    equipped with  a Gbulson eletrolytic conductivity detector,  mown amounts
    of HP-001 are  used  for standardization.   Peak heights are compared with
                                      75

-------
those of the standard for quantification.  Residues are expressed as
parent Metolachlor equivalents using the 1.47 factor.
     The method was validated by the petitioner in three ways:  (1)
fortification with the determined compound, HP-001;  (2) fortification
parent Metolachlor, (CCM-001) ; and  (3) comparison of GLC analyses of   C-
labeled residues from metabolism study samples with total   C-combustion
analyses of duplicate samples.
     Recovery for samples of grain, forage, silage, and stover  fortified at
levels of 0.05-2.0 ppm with HP-001 averaged 81%.  All control samples were
determined to have <0.03 ppm (the method sensitivity).  Ebrtification
studies using parent Metolachlor averaged 63% for levels of 0.05-0.2 ppm
in stover.     ,.
     The total   C-activities in samples of corn plants taken from both
the field and greenhouse studies were determined by combustion  (Hermes,
1972).  The combustion technique determined all residues (both  extractible
and nonextractible) after conversion to   CO-.  The residues
(expressed as CCM-001) determined by Chemical Method AG-265 ranged from
12%  (mature crop)  to 27% (immature forage or silage)  of the total residues
found by combustion techniques.  Comparisons were also made of  the total
extractible residues by the chemical method vs. the   C-combustion
method using two extraction solvent systems, HQ, and combined  chloroform-
methanol solvent.  .About 50-60% of the   C-residues in mature corn were
extractable using either method.  The chemical method determined 20-30%
of the total extractable   C-residues.
     Except as stated directly below, method AG-265  (Balasubramanian, Gold,
and Ross, 1974) was found to be specific in the presence of other
pesticides with established tolerances on corn.  Six pesticides were not
available for testing: EPN, Vegadex, Avadex, Landrin, 4-amino pyridine,
and 2-(thiocyanomethylthio)-benzotriazole.  An alternate column liquid
phase is available and provides additional specificity for residues of
Metolachlor.
     Method AG—277  (Balasubramanian, Aziz, and Fbss, 1975) is a
modification of AG-265 which includes partitioning, clean-up,
derivatization, and micro-coulometric GLC steps determining two hydrolysis
products:  2-[ (2-^thyl-6-methylphenyl)amino]-l-propanol (HP-001) and 4-(2-
ethyl-6-methylphenyl)-2-hydroxy-5-methyl-3-morpholinone (HP-002).
     Residues of Metolachlor (CCM-001) in corn grain, ears, forage, fodder
and stover are converted to a mixture of HP-001 and HP-002 by refluxing 16
hours with 6N HQ.  The filtered acid extract is partitioned with
dichloromethane to extract the HP-002 into the organic phase.   The aqueous
phase containing HP-001 is made strongly basic with 50% sodium  hydroxide
and subjected to distillation-partition into isooctane using a  Bleidner
apparatus.  The isooctane phase containing HP-001 is cleaned up by using
an alunina colurm.  HP-001 is determined with a gas chromatograph equipped
with a Coulson electrolytic conductivity nitrogen detector.  It is
quantified by comparing it with the peak height of a standard amount of HP-
001 and then calculated as CCM-001 using the 1.47 equivalence factor.
     The dichloromethane phase containing HP-002 is washed with 5% sodium
carbonate solution and further cleaned up using an alunina colunn.  The
chloroethanol derivative of HP-002 is formed by reaction with boron
trichloride/2-chloroethanol at 90 C for 15 minutes.  The derivative is
partitioned into hexane and an aliquot is cleaned up using silica gel and
alunina columns.  A gas chromatograph equipped with Dohrmann
                                   76

-------
microcoulonetric chloride detector  is  used  for  analysis.   For
quantification, the  peak area  is  compared to  that of peak areas  of
derivatized standard HP-002.   Residues are  calculated as  CCM-001 using
the conversion factor  1.13.
     Controls for  HP-001 usually  ranged from  less than 0.02 ppm  to 0.05
ppm.   In some samples,  the controls ranged  up to  0.1 ppm  due to  an
interfering peak.  We  consider the  sensitivity  of the method for HP-001 to
be 0.05 ppm or less.   Recoveries  for 69 samples of fodder,  forage, grain,
or ears, fortified at  0.02 and 0.20 ppm, ranged from 57-115% with an
average of 65%.  Typical recovery data residues of HP-002 for  samples
fortified at 0.05-0.20 ppm ranged from 45-102%  with an average of 62%.
The method sensitivity is considered to be  0.10 ppm for HP-002 when
calculated as CCM-001.
     The method used for the soybean residue  data is Method AG-286 (Aziz
and Ross, 1975).   This method, "Analytical  Method for the Determination of
Residues of Metolachlor Soybean Metabolites (as HP-001 and  HP-002)  by Acid
Hydrolysis," is the method for regulatory enforcement which will be
incorporated in the  FDA pesticide Analytical  Methods, Mbl.  II.   Method  AG-
286 was tried out  in one of EPA's laboratories  and found  to be
acceptable.
     Method AG-286 was tested  for specificity with 54 of  the 58  pesticides
registered on soybeans. DC-200 and Carbowax  20 M are available  as
alternate liquid phases to enhance  the specificity of the GLC
de te rm ina t ive steps.
     The analytical methods are also adequate for the enforcement of
tolerances on peanuts  and sorghun.   However,  the  absence  of data indicating
the significant components of  residues in root  crops precludes valid
conclusions on the adequacy of these methods  for  the determination of
Metolachlor residues in root crops  for enforcement purposes.

Metolachlor _in Animal  Tissues
     Analyses~~of meat,  milk, and  egg samples  were conducted by methods
reported in Basle  REM  5/74 (Hermann,  Guth,  Ebrmica,  and Schenker,  1974)
and Basle REM 2/75 (Ramsteiner and  Karlhuber, 1975).  Analytical method
(REM 2/75) accounts  for "combined residues" of  Matolachlor, determined  as
HP-001 and HP-002.
     In the first  method  (REM  5/74), the herbicide and  the  potential
metabolites and/or conjugates  in  animal products  are subjected to  acidic
hydrolysis.  The resulting solution is made alkaline before steam-
distillation;  extraction of residues  into  isooctane is effected by means
of a steam distillation-extraction  head.  The HP-001 fraction  is cleaned
up by using an alunina  column  and,  if  necessary,  by  TLC.
     The HP-001 "residues" are detected by gas  chromatography/mass
spectrometry.  This method is  a minor  modification of AG-265 and  was used
for the gas chromatographic analysis of milk, blood,  meat,  fat,  liver,
kidney, egg white  and  egg yolk.   The limits of  detection  for HP-001 are
0.006 ppm for milk, 0.015 ppm  for eggs and  chicken tissues,  and  0.02 ppm
for cow tissues.
     The second method  (REM 2/75) determines  all  residues which  are
hydrolyzed by acid to HP-001 and  HP-002.  HP-002  is  converted to  a
derivative which is determined  by gas  chromatography.   This method for
animal tissues involves minor modifications of  Method AG-286.  The
reported limits of detectibility  are 0.01 ppm in  milk,  and  0.04  in for
                                   77

-------
    meat, liver, and kidney.
         F^fethod REM 2/75, CCM-001, "Determination of Total Residues  in Material
    of Animal Origin" (Ramsteiner and PSrlhuber, 1975), was tried on beef
    liver in one of EPA's laboratories.  Samples fortified in duplicate with
    HP-001 gave 99% and 100% recovery.  Samples fortified in duplicate with HP-
    002 showed 43% and 45% recovery.
         Methods AG-286 and REM 2/75 were found to have adequate specificity
    and are judged satisfactory for enforcement purposes.


Residue Data

    Field residue data for Metolachlor should reflect the use with respect to
dosage, mode of application, number and timing of treatments, formulations used
and geographical areas represented.  Pre-plant soil treatments for grain crops
should include examination of foliar parts of the plant during the growing
season as well as analyses of the harvested grain.
    The analytical methods used to generate the residue data involve a
conversion of residues of Metolachlor and its metabolites (through hydrolysis)
to 2-[(2-ethyl-6-methylphenyl)amino]-l-propanol (HP-001) and 4-(2^athyl-6-
methylphenyl)-2-hydroxy-5-methyl-3-fnorpholinone (HP-002) .  The resulting
residues from the application of Metolachlor are accordingly expressed as HP-
001 and HP-002, or combined as total residue and calculated as Metolachlor.
    A storage stability study of Metolachlor residues in corn fodder and grain
was performed to ensure that results obtained for samples stored prior to
analysis are valid  (Gold and Yahrs, 1975b).  Samples of corn fodder and corn
grain were fortified with Metolachlor at 1.0 ppm and 0.2 ppm, respectively.
The samples were kept frozen at -15 C and analyzed at pre-determined
intervals up to 13 months after storage.  The recoveries for the corn
fodder ranged from 92-115% of the fortified amount and the corn grain samples
ranged from 92-119%.
    Several samples of field-treated corn fodder were also monitored during the
13-month storage period.  Residues in one sample varied from 0.43-0.39 ppm and
residues in another sample ranged from 0.29-0.26 ppm over the 13-month period.

    Residues _in Corn
         The majority of the residue studies on field and sweet corn were
    performed by the use of a formulation of Metolachlor called 250 EC.  No
    data were submitted regarding the composition of 250 E.G. formulation.
    The residues of CCM-001 in these studies are determined as HP-001 alone.
    The HP-002 breakdown product was not determined.  These studies were
    performed in 9 states (Nebraska, Mississippi, Illinois, New York, Texas,
    Chio, California, Wisconsin, Indiana) .  (Tweedy, 1974; Ttoeedy and Mattson,
    1974; Mattson and Kahrs, 1975b.)  (Only studies performed with Metolachlor
    alone are considered here.)
         Nine studies with field corn, at 2 Ibs. and 4 Ibs. ai/acre of 250
    E.G., reported residues less than 0.03 ppm of Metolachlor (as HP-001) in
    grain at intervals of 111-162 days between pre-emergent application and
    harvest.  Three studies with sweet corn at 2 Ibs. and 4 Ibs. ai/acre of
    250 E.G. reported residues of Metolachlor (as HP-001) in ears as less than
    0.03 ppm at 61, 67, and 138 days after the pre-emergent application.  Two
    additional studies with field corn and one with sweet corn using the 5E
    formulation (at 3 and 6 Ibs. ai/acre )  indicated no detectable combined

-------
residues of HP-001  (as Metolachlor)  (less  than  0.03 ppm)  and  HP-002  (less
than 0.10 ppn)  in the grain and  fresh  ears respectively 62, 92 and 129
days after the  application.  At  a  later date  two  additional studies  at  2
Ibs. and 4 Ibs.ai/acre of  250  E.G.  formulation  on sweet corn  were
performed.  No  detectable  residues of  Metolachlor as HP-001 (less than
0.03 ppn) or HP-002  (less  than 0.10  ppn) were found in  the fresh ear
sample at 60 and 67 days after the application.
     Seventeen  residue studies where Nfetolachlor  was measured as HP-001
show forage residues were  less than  0.03 ppm  at intervals of  34 and  72
days following  1.5 Ibs. ai/acre.  Residues resulting from 2 Ibs. and 3
Ibs. ai/acre applications  (at  26 to  72 days)  range from less  than 0.03  to
0.14 ppm, and less than 0.03 to  0.10 ppm,  respectively.  At intervals of
26 to 64 days,  4 Ibs. ai/acre  resulted in  residues of less than 0.03 to
0.43 ppm; 6 Ibs. ai/acre rates showed  HP-001  residues at 0.03 to 0.19 ppm.
     Silage stage forage residues of Metolachlor  (measured as HP-001)
resulting from  2 Ibs. and  4 Ibs. ai/acre range  from less than 0.03 ppm  to
0.16 ppm, and less than 0.03 ppm to  0.43 ppm, respectively, at intervals
from 71 to 112  days after  application.
     Mature fodder and stover  residues ranged from less than  0.03 ppm to
0.44 ppn (measured as HP-001)  for both the 2  Ibs.  and 4 Ibs.  ai/acre  rates.
     Eleven studies in which Metolachlor was  later measured as combined
residues of HP-001 and HP-002  show residues in  early forage of less  than
0.03 ppn to 0.24 ppm and less  than 0.03 ppn to  0.08 ppn for 2 Ibs. and  3
Ibs. ai/acre treatments, respectively;  4  Ibs.  and 6 Ibs. ai/acre
applications resulted in forage  residues ranging  from 0.04 ppn to 0.64 ppn
and 0.03 to 0.19 ppn, respectively.
     Silage stage forage showed  combined HP-001 and HP-002 residues  (as
Metolachlor)  of 0.08 to 0.14 ppn,  0.04 ppn to 0.12 ppn,  and 0.05 ppn  to
0.28 ppn for treatments at 1.5 Ibs., 2.0 Ibs.,  and 3.0  Ibs.,  respectively.'
Combined residues from 4 Ibs.  and 6  Ibs. ai/acre  treatments were 0.14 to
0.63 ppn and 0.13 to 0.34  ppn, respectively.
     Ebdder and stover residues  for  1.5 Ibs., 2.0 Ibs.,  and 3.0 Ibs., ai/
acre treatments were less  than 0.03  to 0.06 ppn,  less than 0.03 to 0.23
ppn, and 0.07 to 0.30 ppn.
     Combined residues of  HP-001 and HP-002 (as Mstolachlor)   in mature
fodder and stover reported in  six studies  at  4  Ibs.  ai/acre ranged from
0.07 ppn to 0.90 ppn.  Three studies at 6  Ibs.  ai/acre  reported combined
residues in fodder ranging from  0.14 to 0.53  ppn.
     Because no detectable residues  were found  in corn  grain,  no residue
data are needed for corn grain by-products (corn  oil, corn meal, etc.) .

Residues in or  on Soybeans
     Twenty-lEEree residue  studies were performed  in eight states
representing the major soybean growing areas.   (Again,  only studies
performed with  Matolachlor alone are considered here.)   Application  rates
were from 2 to  6 Ibs. ai/acre  (Mattson and Rolla,  1975;  Texas  A & M
Cottonseed Products Research Laboratory, 1966;  Houseworth and  Rolla,  1976).
     Analyses involved the determination of both  HP-001 and HP-002.   No
detectable residues (less  than 0.05  ppn)  of HP-002 were found  in any of
the soybean samples.  Residues of HP-001 in the soybeans  which ranged from
less than 0.03  to 0.09 ppn resulted  from application rates of up to  5 Ibs.
ai/acre;  the maximum reported residue was from a  3 Ib.  ai/acre
application.   At 5 Ibs. ai/acre, residues  of  HP-001 ranged from less  than
                                   79

-------
 0.33 to  0.21 ppm.
     Three  fractionation studies showed no detectable  residues of  HP-001
 (less than  0.03 ppm) or HP-002  (less than 0.05 ppm) in any  fraction  (meal,
 crude and refined oil, soapstock) from soybeans treated at  rates of  2 to  5
 Ibs. ai/acre.  At 6 Ibs. ai/acre, the only finite residue was found  in
 the soybean meal where 0.04 ppm HP-001 was detected.   In one of the  three
 tests, soybean hulls (pods) contained 0.03 and 0.06 ppm HP-001 from
 treatment rates of  2.5 and 5 Ibs. ai/acre.
     Total  residues (sun of residues converted to HP-001 and HP-002) of
 Metolachlor in soybean forage ranged from 0.20 to 0.36 ppn  at a 2  Ibs. ai/
 acre application rate.  Total residues in soybean forage at the 3  Ibs. ai/
 acre ranged from 0.15 to 1.01 ppm.  At exaggerated rates of 4 Ibs. and 6
 Ibs. ai/acre, total residues ranged from 0.34 to 1.76 ppm.  These  residue
 studies  represented pre-harvest intervals of 30-92 days.
     Total residues in soybean hay at pre-harvest intervals of 122-194 days
 ranged from less than 0.10 to 0.84 ppm at rates of up to 3  Ibs. ai/acre.
 At exaggerated rates of 4 to 6 Ibs. ai/acre, total residues ranged from
 0,14 to  2.46 ppm.
     The above residue data for soybeans allows for an adequate range of
geographical variation.

 Residues _in or on Sorghum
     Forty^fTveTesidue studies were performed in seven states representing
 the major sorghum growing areas.  Application rates were 2 to 5 Ibs.
 ai/acre.  Analyses  involved the determination of both HP-001 and HP-002 in
 silage stage forage, harvest fodder, and mature grain.
     Residues of HP-001 in the silage stage forage (sampled at 55  to 111
days after treatment)  were 0.05 to 0.56 ppm due to a rate of 2 Ibs.
 ai/acre;  less than 0.03 to 0.34 ppm  due to 2.5 Ibs. ai/acre;  and, 0.14
 to 0.51 ppm due to a rate of 5 Ibs. ai/acre (two times the maximum
proposed rate) .  Residues of HP-002 in the silage stage forage were less
 than 0.05 to 0.43 ppm due to a rate of 2 Ibs.  ai/acre;  less than or
 exactly  0.05 to 0.11 ppm due to a rate of 2.5 Ibs. ai/acre;  and less than
 0.05 to  0.46 ppm due to a rate of 5 Ibs. ai/acre.
     Samples of mature grain and harvest fodder were collected at  intervals
of 85 to 169 days after treatment and analyzed.  Resides of HP-001 in the
harvest  fodder were 0.06 to 0.96 ppm due to a 2 Ibs. ai/acre application
 rate;  0.06 to 1.90 ppm due to a 2.5 Ibs. ai/acre rate;  and 0.14  to 0.99
ppm due  to a 5 Ibs. ai/acre rate.  Residues of HP-002 in the harvest fodder
were less than 0.05 to 0.20 ppm due to a 2 Ibs. ai/acre rate;  less than
 0.05 to  1.29 ppm due to a 2.5 Ibs. ai/acre rate;  and, 0.07 to 0.45 ppm due
 to a 5 Ibs.  ai/acre rate.
     Residues of HP-001 in sorghum grain were less than 0.03 to 0.11 ppm
due to the 2 Ibs. ai/acre application rate;  less than 0.03 to 0.18 ppm due
 to the 2.5 Ibs. ai/acre rate;  and less than 0.03 to 0.37 ppm due  to -the  5
Ibs. ai/acre rate.  ND detectable residues of HP-002 (less than 0.05 ppm)
were noted in sorghum grain from any application rate.
     Two processing studies were performed on sorghum grain.  The grain was
obtained from crops treated at 2 Ibs. ai/acre and harvested at intervals  of
 114 to 146 days after treatment.  The grain had HP-001 residues of less
than 0.03 to 0.09 ppm, but no HP-002 residues were detected (less  than 0.05
ppm) .  The bran had 0.03 ppm HP-001 residues.  However, no residues of HP-
 001 (less than 0.03 ppm)  or HP-002 (less than 0.05 ppm) were detected in

-------
the flour or shorts.
     These residue data are sufficient to reflect residues of Mstolachlor
and its metabolites in sorghun grain and its processing fractions  (bran,
flour, and shorts) and in sorghun forage and fodder.

Residues in or on Peanuts
     Seventy^six~residue studies were performed  in 5 major peanut growing
areas of the United States.  Application rates were 3 Ibs. ai/acre and 6
Ibs. ai/acre.  Analyses involved the determination of both HP-001 and HP-
002 in peanuts, peanut hulls, peanut forage, and peanut hay.  The peanuts,
hulls, and hay were sampled st intervals of 128  to 159 days after
treatment.  The peanut forage was sampled at intervals of 56 to 69 days
after treatment.
     The peanuts had no detecable residues of either HP-001 (less than 0.03
ppm) or HP-002 (less than 0.05 ppm) due to the 3 Ibs. ai/acre application
rate.  At the 6 Ibs. ai/acre rate, HP-001 residues were less than 0.03 to
0.05 ppm, and HP-002 residues were less than 0.05 to 0.10 ppn.
     The peanut hulls had HP-001 residues of 0.06 to 0.24 ppm and HP-002
residues of less than 0.05 to 0.45 ppm due to the 3 Ibs. ai/acre
application rate.  Residues due to the 6 Ibs. ai/acre rate were 0.07 to
0.74 ppn for HP-001 and 0.06 to 1.3 ppn for HP-002.
     The peanut forage had 0.09 to 1.7 ppn HP-001 residues and 0.12 to 1.2
ppn HP-002 residues due to the 3 Ibs. ai/acre application rate.  Residues
due to the 6 Ibs. ai/acre rate were 0.12 to 3.0 ppn HP-001 and 0.14 to 1.6
ppn HP-002.
     The peanut hay had 0.26 to 1.5 ppn HP-001 residues and 0.17 to 1.1 ppn
HP-002 residues due to the 3 Ibs. ai/acre application rate.  From the 6
Ibs. ai/acre rate, HP-001 residues were 0.46 to  3.0 ppn and HP-002 residues
were 0.26 to 2.9 ppn.
     Treated peanuts were processed to peanut cake (or, peanut meal), crude
oil, refined oil, and soapstock.  Processing was performed by either
mechanical extraction or solvent extraction of the oil.  The peanut cake
(or meal) and the crude and refined oil had no detectable residues of HP-
001 (less than 0.03 ppn) due to the 3 or 6 Ibs.  ai/acre rates.  The
soapstock had no detectable HP-001 residues due  to the 3 Ibs. ai/acre rate,
but at the 6 Ibs. ai/acre rate, the soapstock had HP-001 residues of less
than 0.03 to 0.04 ppn.  ND detectable residues of HP-002 (less than 0.05
ppn) were noted in the crude or refined oil, or  the soapstock due to either
the 3 or 6 Ibs. ai/acre rates.  The peanut cake  (or meal)  had no detectable
residues of HP-002 (less than 0.05 ppn) due to the 3 Ibs. ai/acre rate, but
at the 6 Ibs. ai/acre rate, the peanut cake had  HP-002 residues of less
than 0.05 to 0.07 ppn.
     These residue data are sufficient to reflect residues of Metolachlor
and its metabolites in peanuts, peanut forage, peanut hay, and peanut by-
products (meal, oil, and soapstock).

Residues in or on Potatoes
     Residue~data were available for the root crop, potatoes.  Eighty-four
residue studies were performed in seven states representing potato growing
areas.  Application rates were 3 Ibs. ai/acre and 6 Ibs. ai/acre.  Analyses
involved the determination of both HP-001 and HP-002 in immature  (48 to 84
days after treatment)  and mature (57 to 135 days after treatment)  potatoes.
     Residues of HP-001 in immature or mature potatoes due to the 3 Ibs.
                                   81

-------
 ai/acre  rate were  less  than  0.03  to  0.05 ppm.   Residues of HP-002 in
 immature  and mature  potatoes were less  than  0.05 to 0.07 ppm due to the 3
 Ibs.  ai/acre application  rata.  From the 6 Ibs.  ai/acre rate, residues  of
 HP-001 in immature potatoes  ware  less than 0.03 to  0.22 ppm and less than
 0.03  to  0.05 ppm in mature potatoes.  Residues  of HP-002 were less than
 0.03  to  0.28 ppm in  immature potatoes and less  than 0.05 to 0.06 ppm in
 mature potatoes.
      We  have concluded  (see  the discussion on  'Metabolism in Plants')  that
 the absence of metabolism studies on  root crops precludes an understanding
 of  the nature of the  residues  in  potatoes.   Therefore,  valid conclusions
 about these reported  residue levels  in  potatoes cannot  be determined.

 Residues _in Meat, Milk, Poultry,  and  Eggs
      Residues in meat and milk were  studied  in  a  three-level feeding study
 (Mattson,  1975).   In  this study,  eleven  cows were fed unlabeled Metolachlor
 at levels of zero, 0.02 ppm, 1.0  ppm, and 5.0 ppm of the  total  diet. Milk
 samples were collected at zero, 1, 2, 7,  14, 21,  and 28 days.  Animals  were
 sacrificed and samples of tissues  taken  at 14,  21,  and  28 days.   Oily milk
 and tissue samples from the two highest  feeding  levels  (1.0 and 5.0 ppm)
 were  analyzed.
      In  this study,  the analytical method determined "total" residues of
 Metolachlor, (i.e., parent compound and  all metabolites yielding  HP-001
 and HP-002 after hydrolysis with  6N  HCL) . All  residues in milk samples
 were  less than the method sensitivity of  0.006  ppm  for  HP-001 and 0.01  ppm
 for HP-002.  All residues in the muscle,  fat, kidney, and liver were less
 than  the method sensitivity of 0.02 ppm  for HP-001  and  0.04 ppm for HP-002.
      Tbtal   C-residues (calculated as  Metolachlor) were  determined in
 the goat metobolism study where 4.7 ppm  of   C-labeled  Metolachlor was
 fed for  10 days (Fbger and Cassidy,  1974a).  Activity levels were
 equivalent to 0.01 ppm in milk, 0.003 ppm in kidney, 0.07 ppm in liver,
 and less than0.006 POT.in other tissues.  The activity  was not
 characterized.  When   C-labeled corn biosynthesized metabolites  were
 fed to goats, no detectable   C-residues  resulted in milk or tissues
 (Fbger and Cassidy, 1974b) .
      Residues in poultry and eggs were determined in a  feeding  study
 involving 112 laying hens (Mattson, 1975).  The birds were fed  unlabeled
 Metolachlor at levels of zero, 0.1, 0.5,  and 2.0  ppm in the dry diet.   Egg
 samples were taken on days 1, 3,  7,  10,  14, and  21.  Birds were  sacrificed
 after 7,   14, 21, and 28 days for  tissue  analysis.  Cnly tissue  and eggs
 samples from the two highest feeding  levels  (0.5  and 2.0  ppm) were
 analyzed.  Residues as HP-001 in eggs, muscle,  and  fat  were reported as
 less  than 0.02 ppm.  Residues of  0.02 ppm and 0.03  ppm  as HP-001 were
 reported for the livers from birds fed at 0.5 and 2.0 ppm feeding levels,,
 respectively.  ND detectable residues (less than  0.04 ppm)  of HP-002 were
 found in eggs nor Jin any tissues.
      From the feeding of soybean meal, hulls, and soap-stock bearing
 residues  of 0.1 ppm,  the dietary residue  level could approach 0.04 ppm  for
cattle and 0.03 ppm for poultry.  The feeding levels at which barely
detectable residues were found in the feeding studies represent
 exaggerations of ca. 100x for cows and 25x for  poultry.
     A restriction against the feeding of soybean forage  or hay,  including
 the fodder or straw from the bean harvest, precludes dietary residues for
poultry and cattle except for the fractions of  soybeans.   Although the
                                   82

-------
    livestock feed use of soybean fractions may lead to small residues in
    meat, milk, poultry, and eggs, these residues, if present, would be at
    levels below the sensitivity of the analytical methods.


Present Tolerances

    In 1976, Matolachlor was registered for use on corn grain, and a permanent
tolerance of 0.1 ppm in corn grain (except popcorn)  was established for
residues of Mstolachlor and its metabolites pursuant to 40 CFR 180.368 (FR
41:178, 9/13/76).  Since then, Metolachlor has been conditionally registered
for use on soybeans, sorghun, and peanuts, 'conditional'  upon the accepted
fulfillment of the following Tbxicology data requirements:  a two-year rat
chronic feeding study, a new mouse oncogenic study, a rat oncogenic evaluation,
a teratology study in a species other than the rat, and a rat multi-generation
reproduction study.  Tb accompany the registered use on soybeans and the
conditionally registered uses on sorghum and peanuts, permanent tolerances wsre
established for residues of Metolachlor and its metabolites at:  1.0 ppm  for
corn forage and fodder;  0.1 ppn for soybeans;  2.0 ppm for soybean forage and
fodder;  0.02 ppn for meat, eggs, poultry, fat, meat by-products, and milk;
0.3 ppn for sorghum grain;  2.0 ppm for sorghum forage and fodder;  0.1 ppn for
peanuts;  1.0 ppn for peanut hulls;  and 3.0 ppn for peanut forage and hay.
The permanent tolerances for ffetolachlor and its metabolites of 0.02 ppm  for
eggs, milk, meat, fat, and meat by-products are enforced for the following
animals:  cattle, goats, hogs, horses, poultry, and sheep.
                                       83

-------
DISCIPLINARY REVIEW

Residue Chemistry Profile
Tolerance Reassessment
Generic Eata Gaps
Suggested Labeling


Residue Chemistry Profile

    When Matolachlor was applied as a pre-emergence treatment at 2 Ibs./acre to
corn and soybeans, total residues later found in plants parts were higher in
soybeans than in corn.  In corn, the residues were primarily metabolites
conjugated with polar plant molecules such as amino acids or sugars.  The
major pathway of metabolism appears to be conjugation with glutathione,
breakage of the thioglycoside bond to form mercaptan, conjugation of mercaptan
with glucuronic acid, hydrolysis of methyl ether, and conjugation of the
alcohol with a neutral sugar.  Metabolic pathways in soybeans were similar to
those observed in corn, and pathways in peanuts and sorghum are also expected
to be similar.
    The metabolism of Metolachlor in animals appears to be similar to and as
complex as that in plants.  But whereas plants retain their metabolic
products, animals eliminate their Mstolachlor metabolic products almost
completely.  The parent compound was rapidly metabolized and almost totally
eliminated in the urine and feces of goats, rats, and poultry, and no residues
or only trace amounts could be detected in the tissues, kidneys, liver, blood,
or milk of animals, or in the eggs, meat, or fat samples of laying chickens.
The most significant residue detected was 0.02 to 0.03 ppm in the liver of
chickens.
    Adequate ffetolachlor-specific and metabolite-specific analytical methods
are available for the detection of residues in com, soybeans, peanuts,
sorghum, meat, milk, and eggs, and data were available on actual residues in
these commodities.  Residue data were also available for the root crop
potatoes.)   No detectable residues were found in corn grain, and less than 1.0
ppn were found corn fodder, forage, and stover as a result of applying as much
as 6 Ibs. ai/acre.  Residue data for soybeans was adequate to allow for the
wide range in the geographical characteristics of the U.S. soybean crop.
Eetectable residues in the beans, soybean meal, hulls, forage, and hay showed
that an exaggerated rate of 6 Ibs. ai/acre resulted in as much as 2.46 ppm in
hay and 0.21 ppm in the soybeans.  But residues from treatments of up to 3
Ibs. ai/acre were all less than 2.0 ppm for hay and forage and 0.1 ppm for the
beans.  Residue data on sorghum grain, including its processing fractions, and
sorghum forage and fodder, showed that application rates of 2 Ibs. ai/acre
resulted in combined residues which did not exceed 2.0 ppm in forage or fodder
or 0.3 ppn in grain, while a rate of 5 Ibs. ai/acre resulted in as much as 0.37
ppm in grain, and a rate of 2.5 Ibs. ai/acre resulted in as much as 3.19 ppm in
harvest fodder.  Eata for peanuts showed that 3 Ibs. ai/acre was the maximum
application rate which did not cause residues in excess of 0.1 ppm in peanuts,
1.0 ppm in peanut hulls, and 3.0 ppm in peanut forage and hay.  £n application
rate of 6 Ibs. ai/acre resulted in as much as 2.04 ppm combined residues in
peanut hulls, 5.9 ppm in peanut hay, and 4.6 ppm in peanut forage.  Residues at
just above or below the sensitivity of the analytical method were reported for
cattle meat and milk, for goat meat and milk, and for poultry eggs, meat, and
                                       85

-------
            METABOLIC PATHWAYS  OF METOIACHEOR
                  IN CORN AND SOYBEANS
                      Metolachlor
Major  path
                                                 g lucur onie
                                                -glueuronic
                                                -g lueuronic
                             86

-------
fat.  The feeding levels at which barely detectable residues were found
represent exaggerations of about 100 times for cows and 25 times for
poultry.  Finally, the absence of metabolism studies on root crops precluded
the regulatory evaluation of levels observed for potatoes.
    Metolachlor has permanent tolerances of 0.1 ppm in corn grain (except
popcorn) , 1.0 ppm for corn forage and fodder, 0.1 ppm for soybeans, 2.0 ppm
for soybean forage and fodder, 0.02 ppm for meat, eggs, poultry, fat, meat by-
products, and milk, 0.3 ppm for sorghum grain, 2.0 ppm for sorghum forage and
fodder, 0.1 ppm for peanuts, 1.0 ppm for peanut hulls, and 3.0 ppm for peanut
forage and hay.  The permanent tolerances for Nfetolachlor and its metabolites
of 0.02 ppm for eggs, milk, meat, fat, and meat by-products are enforced for
the following animals:  cattle, goats, hogs, horses, poultry, and sheep.


Tolerance Reassessment

    The only presently available 'no observed effect level1 (NOEL)  on which to
base a re-assessment of Mstolachlor's established tolerances is given by a six-
month dietary study on dogs, which indicated a NOEL of 100 ppm  (see the
'Tbxicology1 chapter).  The following set of calculations re-assesses the
acceptability of the established tolerances for Metolachlor, that is, the
degree of hazard presented to the general population by dietary exposures to
Mstolachlor resulting from its registered end-uses.

    1)   The first step in the tolerance re-assessment is the calculation of a
         level of Metolachlor and metabolite residues which, on the basis of
         available animal studies, can probably be ingested by the general
         human population without the occurrence of toxicological effects in
         any individual.  The only available animal study which can be used to
         estimate this level was a six-month feeding study on dogs, which
         demonstrated a 'no observed effect level' (NOEL)  of 100 ppm in dogs.
              In the context of the dog study, a dietary exposure of 100 parts
         Metolachlor per million parts food is equivalent to 2.5 mg Metolachlor
         per kg of dog per day.  That is, the NOEL of 100 ppm is equivalent to
         a NOEL of 2.5 mg/kg/day.  The translation of a level which caused no
         toxicological effects in animals to a level safe for humans usually
         takes into account a safety factor of at least 100x, to allow for a
         10x greater sensitivity of humans over test animals, and to allow for
         the possibility of an individual who is 10x more sensitive than the
         average person.  But because of the numerous chronic data gaps for
         Metolachlor, a safety factor of 2000 times is recommended.  Thus, the
         dog study allows us to calculate an 'allowable daily intake1  (ADI)  of

               2.5 mg/kg/day  divided by  2000  =  0.0013 mg/kg/day

         0.0013 mg/kg/day for humans.  Ebr the average human, who weighs
         approximately 60 kilograms, the 'maximum permissable intake1  (MPI)  is

                    0.0013 mg/kg/day  x  60 kg  =  0.0750 mg/day

         thus 0.0750 mg/day.  This safe daily level of dietary exposure, the
         MPI, will be compared to the total residue intake permitted by the
         tolerances for Metolachlor.
                                      87

-------
     2)
    3)
 The maximum total  residue  intake permitted by  established  tolerances
 is then calculated  in  three  steps:   (a)  by multiplying  the tolerance
 level  (in mg/kg) for a particular commodity by the  percentage  of  the
 total  aggregate Anerican diet  supplied  by that commodity ('Food
 Factor');  (b) then converting that value into the  total mg of residue
 in an  individual's daily diet  contributed by that commodity (where  the
 average human daily diet is  taken to be  1.5 kg food);   (c)  and finally
 summing the total mg of residue in an individual's  daily diet  from  all
 possible food sources„  These  calculations are performed in the  table
 below  for each of ftetolachlor's established tolerances:

 Commodity    Tolerance    Food Factor    Maximum Residue  Contribution
         corn  (grain)
         soybeans
         meat, poultry
         milk, dairy
         eggs
         sorghum
         peanuts
              0.10 mg/kg
              0.10
              0.02
              0.02
              0.02
              0.30
              0.10
 1.00
 0.92
13.85
28.62
 2.77
 0.03
 0.36
0.00150 mg/day/1.5 kg diet
0.00138
0.00415
0.00858
0.00083
0.00014
0.00054
    Ibtal Maximum Residue Contribution = 0.01712 mg/day/1.5 kg diet

We see that the total maximum residues (TMRC) of Metolachlor and
metabolites, from all potentially contaminated dietary sources, that
may be ingested in 1.5 kg of food each day,  is 0.0171 mg.

The percentage of the toxicologically-determined 'maximum permissable
intake'  (MPI)  [from step (1) above] supplied by the  'total maximum
residue contribution1 (TMRC) [from step  (2) above],  is an indication
of the degree  to which the present tolerances ensure against human
effects due to dietary exposure.  For Metolachlor, the maximum
              TMRC   divided by the   MPI   x
                                       100
          0.0171 mg/day
                       0.0750 mg/day
                       %_ MPI in human diet
                       12TF2 %
         possible residues in the average 1.5 kg daily diet is only 22.82 % of
         the level which has been determined safe for the average 60 kg person
         on the basis of a 2000X safety factor.  This suggests that the present
         tolerances are more than adequate for ensuring against the potential
         hazards of human dietary exposure to Metolachlor.  It also suggests
         that additional dietary sources of residues may be added to the
         present ones - that is, additional similar tolerances may be
         established for Metolachlor - without exceeding the safe dietary level
         (the MPI) .

    The established tolerances for Matolachlor on corn grain, soybeans,
peanuts, sorghum, and meat, poultry, milk, and eggs have been re-assessed to be
sufficient to protect against adverse human effects with a margin of safety of
more than 2000X.  Although the approval and establishment of tolerances
requires other information, calculations also indicate that certain additional
tolerances could be accommodated without exceeding the 'maximum permissable
intake' for Metolachlor in the daily diet.

-------
Generic Data Gaps

If a permanent tolerance is to be considered for Ntetolachlor in root crops, a
root crop plant metabolism study will be needed.


Suggested Labeling

    none
                                       89

-------
                                 BIBLIOGRAPHY

     Each of the  following  studies  contributed  useful  information to  the
Agency's review of the residue chemistry of  Metolachlor,  and  is  considered  part
of the data base  which supports  registrations under  this  Standard.


Aziz, S.A; Ross,  J.A.  (1975) Analytical Method  for the  Determination  of
   Residues of CGA-24705 Soybean Metabolites as  CGA-37913 and  CGA-49751  by  Acid
   Hydrolysis.  Method AG-286 dated Jun 10,  1975.  Received Nov  6,  1975  under
   4G1469. (Unpublished report prepared by Ciba-Geigy Cbrp., Greensboro, N.C.;
   CDL:95190-E)

Balasubramanian,  K.; Aziz,  S.A.;  RDSS, J.A.  (1975) Analytical  Method  for the
   Determination of Residues of  CGA-24705 Corn Metabolites as  CGA-37913 and CGA-
   49751 by Acid  Hydrolysis.  Method AG-277  dated Jan 9,  1975.   Received Mar
   26, 1975 under 5F1606.  (Unpublished report prepared by Ciba-Geigy  Corp.,
   Ardsley, N.Y.; CDL:95190-D)

Balasubramanian,  K.; Gold,  B.; Ross, J.A. (1974) Validation of Method AG-265
   for the Determination of CGA-24705 Metabolites Which are Converted to the
   CGA-37913 Moiety:  GACC-74043.   Received  Sep  26,  1974  under 5G1553.
   (Unpublished report prepared by  Ciba-Geigy Corp., Greensboro,  N.C. ;
   CDL:94216-1)
                                                 14
Biometric Testing Incorporated  (1973) Metabolism   C-CGA-24705 Corn
   Biosynthesized Metabolites in  a  Lactating Goat:  A-1004.  Received Sep 26f
   1974 under 5G1553.  (Unpublished report prepared  for Ciba-Geigy COrp.,
   Greensboro, N.C.; CDL:94217-J)

Ciba-Geigy Limited (1973?) CGA 24 705 Feeding Study  in  Milk Cows: Methods.
   Received Sep 26, 1974 under 5G1553.  (Unpublished  report; CDL:94216-G)

Counselmanr ,C.J.; Roger, J.C. (1973) Biological  Report, Goat Metabolism  Study
   with 0-  C-CGA-24705 and 16-   C-CGA-17020. Received NDV 25,  1975
   under 6G1708.  (Unpublished report prepared by Ciba-Geigy Corp., Greensboro,
   N.C.; CDL:94984-K)

Gold, B.; Kahrs,  R.A.  (1975b) Freeezer Storage Stability  of CGA-24705 Residues
   in Com Fodder and Grain: GAAC-75062. Received Nov 25, 1975 under  6G1708.
   (Unpublished report prepared  by  Ciba-Geigy Corp., Greensboro,  N.C.;
   CDL:94877-Y)

Gross, D. (1974a)  Project Report  ND . 8/74: Uptake, Translocation  and
   Degradation of CGA 24 705 in  Com Grown under Controlled Conditions.
   Received Sep 26, 1974 under 5G1553. (Unpublished  report prepared by
   Ciba-Geigy Corp., Greensboro,  N.C.; CDL:94217-F)
                                       91

-------
Gross, D.  (1974b) Project Report to.  13/74: Addendum  to  Project  Report No.  8/
   74: Uptake, Translocation and Degradation of CGA  24  705  in Corn Grown under
   Controlled Conditions: AC 2.52. Received Mar 26,  1975 under 5F1606.
   (Unpublished report prepared by Ciba-Geigy  Ltd.,  Basle,  Switzerland;
   CDL:94378-H)

Guth, J.A. (1974) CGA 24705: Total Residues in Chicken  Tissues and Eggs, 1974:
   AC 2.53; RVA 88/74. Received Sep  26, 1974 under 5G1553.  (Unpublished  report
   prepared by Ciba-Geigy Ltd., Basle, Switzerland;  CDL:94216-D)

Hambock, H.  (1974a) Project to. 7/74: Metabolism of CGA 24  705 in  the  Rat.
   (Status of Results Gathered up to  JUne  10,  1974):  AC 2.52.  Received Sep  26,
   1974 under 5G1553. (Unpublished report  prepared by Ciba-Geigy Ltd., Basle,
   Switzerland; CDL:94217-L)

Bambock, H.  (1974b) Project Report 12/74:  Addendum to Project Report 7/74:
   Metabolism of CGA 24 705 in the Rat: AC 2.52; Received Nov 25,  1975 under
   6G1708-, (Unpublished report prepared by Ciba-Geigy Ltd.,  Basle, Switzerland;
   CDL:94984-P)

Hambock, H.  (1974c) Project Report to. 1/74: Distribution,  Degradation and
   Excretion of CGA 24 705 in the Rat. Received Sep  26,  1974 under 5G1553.
   (Unpublished report prepared by Ciba-Geigy  Ltd.,  Basle,  Switzerland;
   CDL:94217-K)

Helseth, J.; Cole, G. (1973) The Determination of CGA-24705 in Emulsifiable
   Concentrates by Gas Liquid Chrcmatography. Method  PA-9 dated  Nov 14,  1973.
   Received Sep 26, 1974 under 5G1553. (Unpublished  report  prepared by
   Ciba-Geigy Corp., Greensboro, N.C.; CDL:96666^A)

Itennes, P. (1972) Biphasic Extraction of Radioactive  Metabolites from  Treated
   Biological Material.  Method AG-214 dated Aug 15,  1972. Received Sep 26,  1974
   under 5G1553. (Unpublished report  prepared by Ciba^eigy Corp., Ardsley,
   N.Y.; CDL:94216-M)

Hormann, W.D. ; Guth, J.A.; Ebrmica, G. ; Schenker, M.  (1974)  CGA  24705:  Gas
   Gnrcmatographic Determination of Total  Residues in Material of  Animal
   Origin. (Provisional): AC 2.53; REM 5/74. Received Sep 26,  1974 under
   5G1553. (Unpublished  report prepared by Ciba-Geigy Ltd.,  Basle, Switzerland;
   CDL.-94216-E)

Bousevvorth, L.D. and Rolla, H. (1976)  Residues from  Metolachlor Alone and  in
   Tank Mix with Linuron, Metribuzin, and  Liquid Fertilizer  in Soybeans: ABR-
   76077. (Unpublished study received Jan  19,  1977 under 7F1913; prepared by
   Ciba-Geigy Corp., Greensboro, N.C.; CDL-95767-A)

Marco, G. (1974) Summary of Section D: CGA-24705-Corn:  Residues  Observed and
   Metabolism Data Including the Analytical Methods  Used: GAAC-74062.  Received
   Sep 26, 1974 under 5G1553.  (Unpublished report prepared  by Ciba-Geigy Corp.,
   Greensboro, N.C. that includes studies AG-A-2929, AG^V-2969,  AG-A-2973,  AG-A-
   3105,  AG-A-3133; CDL:94217-A; 94222)
                                         92

-------
Marco, G. (1975) Suimary of Section  D: CGA-24705 Corn:  Residues  Observed  and
   Metabolism Data Including the Malytical  Methods  Used:  GAAC-75001.  Received
   Mar 26, 1975 under 5F1606.  (Lhpublished report prepared by  Ciba-Gaigy  Corp.,
   Greensboro, N.C.; CDL.-94378-A)

Mattson, A.M. (1974) CGA-24705 Residues  in Milk,  Meat,  Eggs  and  Chickens
   (Three Level Feeding Studies): GAAC-74064.  Received  Sep 26, 1974  under
   5G1553. (Unpublished report prepared  by Ciba-Geigy Corp., Greensboro,  N.C.;
   CDL:94216-B)

Mattson, A.M. (1975) CGA-24705 Resideues in  Milk,  Meat,  Eggs and  Chickens
   (Three Level Feeding Studies): GAAC-75059.  Received  Nov 25, 1975  under
   6G1708. (Unpublished report prepared  by Ciba-Geigy Corp., Greensboro,  N.C.;
   CDL:94878-A)

Mattson, A.M.; Fahrs, R.A.  (1975b) Residues  in Field  Grown Corn  Following Use
   of CGA-24705 Determined as CGA-37913  and  CGA-49751:  GAAC-75015. Received Mar
   26, 1975 under 5F1606.  (Unpublished report  prepared  by  Ciba-Geigy Corp.,
   Greensboro, N.C. that includes studies AG-A-2967,  AG-A-2982, AG^-3255, AG-A-
   3289, AG-A-3299, AG-A-3328, AG-^-3383, AG-A-3501,  AG-A-3005,  AG-A-3153, AG-A-
   3446; CDL:94379-B)

Mattson, A.M.; Rolla, H. (1975) Summary  of Section D: CGA-24705-Soybeans:
   Residues Observed and Metabolism  Data Including the  Analytical Methods Used:
   GAAC-75057. Received NDV 25,  1975 under 6G1708. (unpublished  report  prepared
   by Ciba-Geigy Corp., Greensboro,  N.C. that  includes  studies AG^-3268, AG-A-
   3466, AG-A-3523, AG-A-3570, AG-A-3650 I & II,  AG-^A-3702, AG-A-3724,  AG-A-
   3743, AG-A-3776, AG-A-3780, AG^-3803; CDL:94984-A;  94878)

Ramsteiner, K; Karlhuber,  B. (1975)  CGA-24705:  Determination of  Total Residues
   in Material of Animal Origin: AC  2.53; REM  2/75. Received Mar  26, 1975 under
   5F1606. (Unpublished report prepared  by Ciba-Geigy Ltd., Basle, Switzerland;
   CDL:94379-I)
                                                                   14
Roger, J.C.; Cassidy, J. E.  (1974a) Metabolism  and  Balance  Study  of   C-
   CGA-24705 in a Lactating Goat: GAAC-74020.   Received  Sep  25,  1974 under
   5G1553.  (Unpublished report prepared by  Ciba-Geigy  Corp.,  Greensboro, N.C.;
   CDL:94217-G)
                                                                     14
Roger, J.C.; Cassidy, J.E.  (1974b) Metabolism  and  Balance  Study  of j6-   C-
   CGA-24705 Corn Biosynthesized Metabolites in a  Goat:  M6-68-2A: GAAC-74046.
   Received Sep 26, 1974 under 5G1553. (Unpublished report prepared  by  Ciba-
   Geigy Corp.,  Greensboro, N.C.; CDL:94217-1)

Schenker, M. (1974) CCA 24705:  Tbtal Residues  in  Milk  and Tissues of Swiss
   Cows: Switzerland 1973:  AC 2.53  RVA  81/74.   Received Jan 19,  1977 under
   7F1913.  (Unpublished report prepared by  Ciba-Geigy  Ltd., Basle,
   Switzerland; CDL:95747-F)
                                         93

-------
Schenker, M,  (1975a) CGA 24705:  Determination of the Degradation  Product CGA
   49751 in'thicken Liver:  Switzerland 1973:  RVA 02/75.  Received Jan  19,
   1977 under 7F1913.  (Unpublished report prepared by Ciba-Geigy  Ltd.,  Basle,
   Switzerland; CDL:95747-1)

Sunner, D.D.; Cassidy, J.E. (1974b) The Metabolism of CGA-24705  in Cbrn:  GAAC-
   74050.  Received Jan 19, 1977 under 7F1913.   (Unpublished report prepared  by
   Ciba-Geigy Corp., Greensboro, N.C.; CDL:95750-C)
                                                                   14
Sumner, D.D.; Cassidy, J.E. (1974c) The Uptake and Distribution  of?*  C-
   CGA-24705 from Soil in Greenhouse Grown Corn: GAAC-74015.  Received Jan 19,
   1977 under 7F1913.  (Unpublished report prepared by Ciba-Geigy Corp.,
   Greensboro, N.C.; CDL:95750-A)
                                                                    14
Sumner, D.D.; Cassidy, J.E. (1974d) The Uptake and Distribution  of &  C-CGA-
   24705 in Field Grown Corn:  GAAC-74022.  Received Mar 26, 1975 under 5F1606.
   (Unpublished report prepared by Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:94385-C)
                                                                      14
Sumner, D.D.; Cassidy, J.E,  (1975b) The Uptake and Distribution of j3-  C
   CGA-24705 from Soil in Greenhouse Grown Soybeans:  GAAC-75039.  Received Nbv
   26, 1975 under 6G1708.  (Unpublished report prepared by Ciba-Geigy Corp.,
   Greensboro, N.C.; CDL:94984-G)

Sumner, D.D.; Thomas, R.D.; Cassidy, J.E. (1975) Structure Elucidation of the
   Metabolites of CGA-24705 in Com:GAAC-75012.  Received Mar 26, 1975 under
   5F1606.   (Unpublished  report prepared by Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:94378-F)

Tweedy, B.B. (1974) CGA-24705-Corn:  Summary of Ftesidues Observed and
   Analytical Methods Used:  GAAC-74061.  Received Sep 26, 1974  under 5G1553.
   (Unpublished report prepared by Ciba-Geigy Corp., Greensboro, N.C., that
   includes tests number  AG-A 2967, AG-A 2982.  AG-A 3132, AG-A  2972, AG-A
   3057, AG-A 3005, AG-A  3083, AG-A 3153, AG-A 3141, AG-A 3103,  AG-A 3137, AG-A
   3070, AG-A 3255, AG-A  2974, AG-A 3057 II,  AG-A 3288, AG-A 3289, AG-A 3327,
   AG-A 3328; CDL:94216-A)

Tweedy, B.C.; Mattson, A.M. (1974)  CGA-24705:  Corn Summary of Residues
   Observed and Malytical Methods  Used:  GAAC-74067.  Received Mar 26, 1975
   under 5F1606.   (Unpublished report prepared by Ciba-Geigy Corp., Greensboro,
   N.C. that includes studies  AG-A-2967, AG-A-2972,  AG-A-2982,  AG-A-3057, AG-A-
   3103, AG-A-3132, AG-A-3137, AG-A-3141, AG-A-3255, AG-A-3289, AG-A-3299, AG-A-
   3327, AG^A-3005, AG-A-3083, AG-A-3153, AG-A-2974, AG-A-3057 II, AG^A-3070,
   AG^-3288,  AG-A-3298,  AC-^A-3325, AG-A-3326, AG-A 3406; CDL:94379-A)
                                      94

-------
                              ECOLOGICAL EFFECTS
TOPICAL DISCUSSIONS

    Corresponding to each of  the  Tbpical  Discussions  listed  below is  the nunber
of the sections  in the  'Proposed  Guidelines'  of  July  10,  1978  (FR Part  163)
which explain the data  that the Agency will  require  in  order to  assess
Matolachlor's Ecological Effects.

                                             Guidelines  Sections
Microbes                                      163.62-8(f)  and (g)
Algae                              (163.122-2,  .123-2,  .124-2,  and  .125-4)*
Aquatic Macrophytes                (163.122-2,  .123-2,  .124-2,  and  .125-4)*
Terrestrial Plants              (163.121-1,  .122-1,  .123-1,  .124-1,  and  .125)*
Birds                              163.70-1,  .71-1,  .71-2,  .71-4, and  .71-5
Wild Mammals                              163.70-1,  .71-3,  and  .71-5
Aquatic Invertebrates          163.70-1,  .72-2,  .72-4a(l),  .72-5, and .72-6
Fish                                  163.72-1,  .72-4,  .72-5, and  .72-6
Ecosystem Effects                           163.71-5 and 163.72-6

               * Subpart j of the  Proposed Guidelines,  which will
                 cover  phytotoxic  effects, has not yet  been
                 published as final  rulemaking.
Microbes

    Data on the effects of pesticides on microbes are obtained  from laboratory
studies employing non-radioisotopic analytical techniques.  These studies
determine effects on either microbial functions or microbial populations.
The study of effects on microbial functions constitutes a more direct
approach, but some effects cannot be measured directly and population studies
may be the only recourse.  Studies should be conducted over a long enough
period to demonstrate whether there is a temporary or long-lasting effect on
microbes.  Three studies were submitted for Metolachlor.  Two of the studies
used the population approach and one used the functional approach.
    In the first population study (Bbuseworth, 1973a) , reviewers noted
variations in tabulated results, and raised questions about the aggregation,
dilution, dispersal, enumeration, and identification of selected soil
microorganisms (such as Bacillus, pseudomonas, Arthrobacter, Cellulomonas,
Cytophaga, Flavobacterium, Achromopacter, Aspergillus, Chaetomium, Fusarium
and Penicillium).These issues will require clarification before this study
can be used to support regulatory decisions.
    In the other population approach study (Ercegovich, Bogus, and Buly, 1978),
a diverse selection of microorganisms with 27 species representing the family
                                      95

-------
 Actinomycetes  and  the  following  genera:   Bacillus,  Cellulomonas, Cytophaga,
 Flavobacterium,  Pseudomonas, Archromobacter, Aspergillus,  ChaetomTum,
 Fusarium,  Penicillium,  and  Trlcoderma, were evaluated  against three
 concentrations of  f-fetolachloT;5,  25, and  125 ppm.  At 5  ppm,  6 of 27; at 25
 ppn,  9 of  27;  and  at  125  ppm,  19 of 27 species were  inhibited with a static
 (but  not cidal)  effect  showi.  At 5 ppm,  4 of  27  species had  increased  counts
 and  1 species  did  not  show  any effect at  all three  concentrations.  Potential
 degraders  could  be estimated and 10 of 27 species could have  this potential.
 Eata  for oxygen  consumption, carbon dioxide evolution,  nitrogen cycling,
 dehydrogenase  activity, and phosphatase activity  were not  supplied.  Because
 application  rates  normally  used  for I^fetolachlor are  1-3 Ibs ai/A, the slight
 inhibitory/static  effect  on soil  commensal populations  would  not be as
 significant  as the laboratory  study indicates, would be alleviated with time,
 and would  allow  populations to recover.   The effect would  be  further minimized
 by reduction of  the pesticide  concentration by physico-chemical means,  of which
 photolysis is  a major pathway.   Based on  these actions, the fact that
 dehydrogenase  or phosphatase activity data were not submitted does not
 invalidate the use of this study.
    In a study by  Ercegovich,  Vallejo, and Bogus  (1978), the  effect of
 5,  25,  and 125 ppm concentrations of Mstolachlor  was evaluated  on the soil
 function processes of nitrification  in two soil types:  Morrison sandy loam and
 Bagerstown silt loam.   Morrison sandy loam did  not show any inhibitory  effects
 at any of  the  three concentrations  evaluated.   Ragerstovvn  silt  loam did  not
 show  any inhibitory effects at 5 or  25 ppm, but did show an inhibitory  effect
 at 125 ppm.  The rate of  nitrification was inhibited for seven  weeks, with a
 recovery starting  at eight weeks and continuing until the  end of  the
 experiment (at ten  weeks)  .  Rates between the  two soils varied  considerably.
    Ihough this latter study does not by  itself fully explore the  potential
 effects of Mstolachlor on microbial  functions  (for example, effects on  the
 degredation of cellulose, starch, and protein)  , it does support  the data  in
 Ercegovich,  Bogus,  and Buly (1978), and together  these  studies  provide
 sufficient information about potential effects on naturally occurring
 microorganisms.
    The activated  sludge  process used in wastewater treatment plants utilizes
 the metabolic  degredation activity of certain microbes  to break down raw
 sewage  into a  form acceptable for discharge in environmental waters.  Because
 Metolachlor rinsate or irrigation mix may inadvertently make its way into
 municipal  sewage systems, studies on its  potential effects on wastewater
 treatment microorganisms is important.  Not only may this cause unprocessed
 sewage  to  be released into the aquatic environment, but it may also  impede the
 degradation of other toxics that are disposed  of in sewer system drains.
    A laboratory study of the effects of Metolachlor on activated sludge
metabolism is not presently available for Technical Metolachlor, and this
 constitutes a data gap.
                                       96

-------
    Studies on Nfetolachlor's toxicity to algae are not presently available.
But because residues of Mstolachlor are expected to reach the  freshwater
aquatic environment, if such studies were available,  they would  be  reviewed
and assessed for information on potential effects to  freshwater  aquatic
ecology.  The Agency will not presently require data  on  Nfetolachlor's  effects
on algae because Subpart J of the  Proposed  Guidelines, which will cover
phytotoxic effects, has not yet been published as final  rulemaking.


Aquatic Macrophytes

    Studies about Metolachlor's effect on aquatic plants are not available.
But because residues of Matolachlor are expected to reach the  freshwater
aquatic environment, if such studies were available,  they would  be  reviewed and
assessed for information on potential effects to freshwater aquatic  habitats.
The Agency will not presently require data  on Matolachlor1s effects  on aquatic
macrophytes because Subpart J of the Proposed Guidelines, which  will cover
phytotoxic effects, has not yet been published as final  rulemaking.


Terrestrial Plants

    Studies on the ecological effects of Mstolachlor  on  non-target  terrestrial
plants are not presently available.  The Agency will  not now require data on
Matolachlor1s effects on terrestrial plants because Subpart J  of the Proposed
Guidelines, which will cover phytotoxic effects, has  not yet been published as
final rulemaking.
    Efficacy tests which examine the effects of an herbicide on  protected crops
can often supply sufficient information to  conduct an ecological effects review
of phytotoxicity.  Nevertheless, in accordance with present Agency  policy,
which requires an efficacy review  for pesticides only when the chemical's
intended effects has a direct impact on public health, efficacy  data was not
reviewed for the Matolachlor Standard.
Birds

    The minimum data required  for establishing  the acute and  subacute  toxicity
of Metolachlor to birds are the  results  from  two 8-day dietary  studies and one
oral study with technical Metolachlor.   Two types of birds -  waterfowl
(preferably mallard duck) and  upland game  (preferably bobwhite  quail)  are to  be
tested as per the specifications in FR  163.71-1 and 163.71-2.
    Five studies of technical  Metolachlor's effects on birds  were  available  for
evaluation, all performed by Fink:  two  studies performed in  1974, one in 1976,
and two in 1978.
    Fink's 1976 study reported data on  the effects of single  oral  doses of
technical Matolachlor to avian wildlife:   the acute LD-50 for mallards (Anas
platyrhynchos) was 4640  (3000-7200, 95%  confidence limits) mg/kg,  indicating
                                       97

-------
 that fetolachlor  is practically non-toxic, acutely, to waterfowl.  But due to
 deviations  from recommended protocols, such as discrepancies in body weights,
 this study  is  unacceptable for use in the regulatory process.  M avian single
 dose oral  LD-50 determination is thus a data gap for ffetolachlor.
     Acceptable data on the dietary DC-50 of technical Matolachlor for avian
 wildlife are  reported on the mallard (Anas platyrhynchos) (Fink, 1974a),
 and the bobwhite  quail (Colinus virgimanus](Fink, 1974b).  The 5-day
 dietary LC-50  (with 3 days observation)  for both species was greater than
 10,000 ppm,  indicating that technical ffetolachlor is practically non-toxic,
 subacutely, to upland gamebirds and  waterfowl.   These two studies meet the
 guidelines  requirement for avain dietary testing.
     Because, as was seen  in the Environmental Fate chapter,  technical
 Metolachlor is persistent under certain conditions and is stored in plant and
 rotational crop tissue,  information  on  avian reproduction effects was also
 needed.  In 1978,  Fink performed two studies of technical Mstolachlor1 s effects
 on  avian reproduction.
     The  first  reproduction study (Fink,  1978a)  tested the bobwhite quail with
 seventeen  (17)  weeks of dietary exposure during mating,  egg  laying,  and egg
 hatching.   In  comparison  with the controls, bobwhite quail exposed to 10, 300,
 and 1000 ppn Technical  Mstolachlor for  17 weeks produced significantly fewer
 chicks surviving  to 14  days.   (See table 1.)

                                   table !_
  Summary of Reproductive  Success of  Quail Bcposed to  IVtetolachlor  for  16 Ufeeks
        Pesticide        Percent,       Chi- _              Significance
      Concentration     Survival        Square         DF        Level
         Control         58.8%          -           ~         -
         10 ppm         47.0%         22.35          1         >0.001
         300 ppn         37.0%         62.4           1         >0.001
        1000 ppm         41.5%         44.5           1         >0.001

         The number  of chicks surviving  to age 14 days expressed as
       2   a  percentage of the  eggs  laid.
         Chisquare calculated by 2x2  Contingency Table  analysis of
            treatment versus control group survival.

Although the subacute dietary  LC-50  to quail  was  shown to  be greater  than
 10,000 ppn, there appeared to be  a dose  response  for mortality among  the
females  subjected to a dietary exposure  for  seventeen weeks, as seen  in  table  2
below*

                                    table  2
               Bctowhite Quail Dosed wrth"Metolachlor  for  17 Weeks

                   dietary dose       number  of  female deaths
                       0 pptf~( control)          2
                      10 ppm                    1
                     300 ppm                   4
                    1000 ppm                   7

The other reproduction study (Fink, 1978b) was performed on the mallard duck,
using the same dietary dose levels for the same  17 weeks.  In comparison with
                                      98

-------
the controls, mallard ducks  exposed  to  10 and 1000 ppm Technical Metolachlor
for 17 weeks produced significantly  fewer chicks surviving to 14 days.  (See
table 3 below.)

                                   table _3
Summary of Reproductive  Success of Mallards  Exposed to Mstolachlor for 16 Weeks
       Pesticide       Percent,       Chi- ~               Significance
     Concentration    Survival        Square          DF        Level
        Control          57.0%           -            ~          ^~~
          10 ppm          48.0%         11.29          1         >0,001
        300 ppn          57.6%         0.053          1           NS
       1000 ppm          51.0%         5.26          1         >0.025

        The number of ducklings surviving to age 14 days expressed as
       _    a percentage of  the eggs laid.
        Chisquare calculated by 2x2  Contingency Table analysis of
            treatment versus control group survival.

But the female ducks suffered no  dose-related mortality, as seen in table  4
below.  The one duck mortality at 300 ppm was attributed to an impacted

                                     table _4
                Mallard  Duck Dosed with Metolachlor for; 17 Weeks

                   dietary dose       number £f female deaths
                       0~ppn (control)0
                      10 ppm                   0
                     300 ppn                   1
                    1000 ppm                   0

oviduct,  rather than to a  chemical-related effect.   These two 1978 studies by
Fink are  sufficient to satisfy the guideline requirements for avian
reproductive testing.
    In sunmary, all guideline data requirements for avian effects are fulfilled
except the acute oral LD-50, which is presently a data gap for Metolachlor.
Cn the basis of available  data, this Standard will  not require precautionary
labeling  addressing toxicity to birds.


Wild Mammals

    Mammalian toxicity data  are not  needed for MBtolachlor because the data  on
laboratory animals reviewed  in the Toxicology Chapter are generally sufficient
for an estimation of toxicity to  wild mammals.  Based on the data in
Metolachlor's Tbxicology review,  there  does  not appear to be any unusual
toxicity, and therefore, no  special  precautions need be recommended.


Aquatic Invertebrates

    The minimum data required for an outdoor use pesticide to establish its
acute toxicity to aquatic  invertebrates  is the result of one 48  or 96 hour
study using the technical, as described  in FR 163.72-2.   Cne such study
                                       99

-------
by  Vilkas  (1976) was  available  for  Mstolachlor.   Vilkas exposed water fleas
 (Daphnia magna  Straus)  to  technical Metolachlor  for 48 hours.  The 48-hour
no-effect  level was  5.6 ppn.  The  48-hour  LC-50  at 95% confidence limits is
25.1  (21.6-29.2) ppn.   These  data  satisfy  the guidelines requirement for
aquatic invertebrate  testing  and are sufficient  to characterize Ntetolachlor as
being  slightly  toxic  to aquatic invertebrates.


Fish

    A  determination of  the  96-hour  LC-50 of  the  technical compound for one
cold-water  fish species (preferably rainbow  trout)  and one warm-water fish
species (preferably bluegill) is required  for all  outdoor use pesticides.  The
acute' toxicity of technical Metolachlor to freshwater  fizh was reported in two
studies conducted by  Buccafusco  (1978a, 1978b),  one study by Sachsse and
LTLlman (1974) , and one  study  by Dionne  (1978) .   As shown in the following
table, some of  these  tests  could be used to  satisfy Agency data requirements,
while  others, although  they also offered useful  information,  were not directly
applicable  to the data  requirements.
                                                              Satisfies EPA
     Species       96 hr LC-50          Author     Date    Data Requirements
  Bluegill sunfish   10.0 ppn
                   Buccafusco  1978
  Rainbow trout
  Fathead minnow
  Fathead minnow
  Crucian Carp
  Channel Catfish
  Guppy
 3.9 ppm
11.0 ppn (static)
 9.2 ppn (flow)
 4.9 ppn
 4.9 ppn
 8.6 ppn
Buccafusco
Dionne
Dionne
Sachsse
Sachsse
Sachsse
1978
1978
1978
1974
1974
1974
yes
yes
no
no
no
no
no
These tests provide sufficient information to characterize  I^fetolachlor  as
moderately toxic to both warm-water and cold-water fish.  The guidelines
requirement for LC-50's for both types of fish has been satisified.
    As was seen in the Bivironmental Fate chapter, Pfetolachlor  is  resistant  to
hydrolysis and metabolism in soil, and has a tendency to  leach. With this
potential for residues to migrate to freshwater aquatic habitats,  a  chronic
fish study, as described in FR 163.72-4, was required.
    Che such study was available.  It was performed by Dionne  (1978), and
tested the effects of 97.4% Metolachlor on the reproduction of  the Fathead
minnow (Pimephales promelas) .  When the minnows were exposed to a  measured
concentration of > 1.60 ppn, significantly (p=0.05) fewer first and  second
generation fry survived.  The majority of mortalities occurred  during the 4th
week of exposure.  The 'maximum acceptable toxicant concentration1  (MATC) , the
concentration below which no effects were observed, was reported to  be  between
0.78 and 1.60 ppn.
    The ratio of the mTC to the LC-50 for the same species is  called the
'application factor1  (AF) .  Because the AF is essentially a property of the
pesticide (i.e., its acute versus its chronic mode of action) ,  the AF can be
used to calculate an estimated MATC for any fish species  for which one  knows
the 96-hour LC-50.  Dividing the minnow mTC values of 0.78 and 1.60 by the  96-
                                      100

-------
hour flow-through LC-50 for minnows  (9.2 ppm) , the application factor  (AF)  for
Metolachlor was calculated to be between 0.08 and 0.17.  This AF  for
Mstolachlor was then used to calculate an estimation of the MATC  for other  fish
species :

                                                  estimated
         species       96-hour LC-50     max acceptable tox cone  (MATC)

     Bluegill sunfish    10.0 ppm             0.8 ppm to 1.7 ppm
     Rainbow trout        3.9 ppm             0.3 ppm to 0.7 ppm
     Crucian Carp         4.9 ppm             0.4 ppm to 0.8 ppm
     Channel Catfish      4.9 ppm             0.4 ppm to 0.8 ppm
     Guppy                8.6 ppm             0.7 ppm to 1.5 ppm
The 1978 minnow reproduction study by  Dionne satisfies the requirement for a
study of technical Metolachlor's chronic effects on a freshwater fish species,
and allows an estimation of potentially hazardous residue levels for several
other species.
    Cn the basis of available acute and chronic toxicity information, which
indicates a moderate toxicity to fish, the following precautionary labeling
appears appropriate.  For the technical:  "Do not discharge into lakes,
streams, ponds, or public waters unless in accordance with an NPDES permit."
And for the emulsifiable concentrate:  "Avoid direct application to any body of
water. Eb not apply where runoff is likely to occur. Eb not contaminate water
by cleaning of equipment or disposal of wastes."


Ecosystem Effects

    The need for studies of ecosystem  effects, including such field studies as
those described in FR 163.71-5 and 163.72-6, cannot presently be determined
because the available laboratory data  have not yet been correlated with an
estimation of potential 'environmental concentrations'.  If fate or monitoring
information suggest the potential for  chronic adverse effects to fish or birds,
the Agency will consider imposing a requirement for field data.
                                      101

-------
DISCIPLINARY REVIEW

Ecological Effects Profile
Ecological Effects tezard Assesanent
Generic Data Gaps
Suggested Labeling


Ecological Effects Profile

    Technical Metolachlor:  Scientifically sound data on the toxicity of
    Metolachlor to wildlife are available on a wide range of non-target
    organisms.  Fish appear to be the most sensitive class tested.
         A diverse selection of soil microorganisms were evaluated against
    three concentrations of Metolachlor: 5f 25, and 150 ppm.  Oily static, not
    cidal, effects were noted (Ercegovich, Bogus, and Buly, 1978).  Another
    study using the same concentrations showed no effects on nitrification at
    the two lower levels, and only temporary inhibition at the high level
    (Ercegovich, Vallejo, and Bogus, 1978).  Effects on wastewater treatment
    microorganisms have not yet been investigated.
         Subacute dietary studies on the mallard duck and bobwhite quail, as
    well as an acute oral test on the mallard duck, indicate that Metolachlor
    is practically non-toxic to birds,  tfcwever, in reproduction studies,
    Bobwhite Quail and Mallard ducks fed 10 ppm in their diet for 17 weeks
    experienced significant (p<0.001)  reproductive impairment:  fewer chicks
    surviving to 14 days.  Ten parts per million was the lowest of three
    concentrations tested, and therefore a "no observed effect level1 has not
    been established.
         Based on data reviewed in the Tbxicology chapter, Metolachlor appears
    to present a low toxicity to wild mammals.  Eata on the acute toxicity of
    Mstolachlor to the water flea show that the herbicide is slightly toxic to
    aquatic invertebrates, with a 48-hour LC-50 of 25.1 ppm»
         Fish were clearly the most acutely sensitive of the organisms tested.
    The cold-water fish Rainbow trout had an LC-50 of 3.9 ppm, and the warm-
    water Bluegill sunfish had an LC-50 of 10.0 ppm, indicating that
    Metolachlor is likely to be moderately toxic to both cold and warm water
    species.  Indeed, tests on additional warmwater species, including the
    Crucian carp, Channel catfish,  Guppy, and Fathead minnow showed comparable
    LC-50's ranging between 4.9 and 11.0 ppm.  In a fish reproduction study on
    the Fathead minnow, fry of both the F,. and F. generations suffered
    significant mortality at levels greater than 1.6 ppm.  The MATC was
    estimated for the various fish species, and ranged from 0.3 to 1.7 ppm.

    Emulsifiable Concentrate Matolachlor:  Information on the toxicity of
    the Emulsifiable Concentrate to non-target wildlife organisms is
    effectively supplied by the studies on the Technical chemical.
                                     102

-------
Ecological Effects Hazard Assessment

    Technical Metolachlor:  Ebr non-target organisms in the proximity of
    Technical Metolachlor manufacture, storage, shipping, or disposal,
    intentional discharges of the chemical into the environment, such as by the
    disposal or drainage of effluent, as wall as unintentional discharges, such
    as by spillage or fire, could result in fish and wildlife exposure.  Though
    •unintentional discharges could result in a risk to fish and birds in the
    contaminated area, the Agency does not perceive unintentional discharges to
    be any more likely with Technical Mstolachlor than with any other technical
    chemical.  As concerns the disposal of wastes or factory effluent,
    Ecological Effects data are available to EPA officials responsible for
    issuing a discharge permit should one become necessary, and to EPA
    officials responsible for regulating the handling of hazardous wastes.

    Emulsifiable Concentrate:  As was pointed out in the Exposure Profile in
    the Environmental Fate chapter, because of the relative stability of
    Matolachlor to hydrolysis, its high mobility in the terrestrial
    environment, and its potential resistance to metabolic degradation,  it is
    anticipated that the spraying of Metolachlor on certain terrains and soil
    types, and in certain types of weather, may result in the contamination of
    aquatic sites adjacent to treated fields.  It is possible that fish can
    be exposed to levels of Mstolachlor that would cause significant mortality
    to fry, although the presently available exposure information does not lead
    the Agency to suspect significant acute effects on freshwater fish.
         Other non-target organisms of potential concern include microbes,
    non-target plants, soil and surface invertebrates, mammals, and birds.
    Soil microbes and the nitrification process do not appear to be threatened,
    and mammalian wildlife do not appear threatened by acute effects.  Cata are
    not presently available on toxicity to non-target plants nor to soil and
    surface invertebrates.  Metolachlor's resistance to hydrolysis and
    metabolism, and the possibility of non-target plant uptake, suggest that
    birds may be exposed to residues in non-sensitive weeds, crops, or soil
    organisms from the pre-emergent application of Metolachlor to soil.   (If
    Matolachlor is applied post-emergent or to non-tilled fields, a higher
    dietary exposure WDuld be expected to occur to birds.)   Because of
    Metolachlor's low acute toxicity to birds, the acute risk to birds is
    minimal.  However, as concerns reproductive effects to birds, data have
    indicated reproductive effects at 10 ppn dietary exposure.  The presently
    available exposure information is not sufficient to conclude that a harmful
    exposure level will occur in Metolachlor treated fields.


Generic Data Gaps

    The following are gaps in the Ecological Effects data base which will be
used to support registrations under this Matolachlor Standard.  After each gap
is listed the section in the Proposed Guidelines of July 10, 1978  (FR Part 163)
                                      103

-------
which describes that type of test and when it is required.  The following
studies would test the Technical in order to assess the hazard associated with
the use of the Emulsifiable Concentrates.

         1)    Activated sludge metabolism study.              163.62-8(g)
         2)    The avian acute oral LD-50 for one species      163.71-1
              of waterfowl (preferably the mallard)  or
              one species of upland game bird (preferably
              the bobwhite quail).  The species must be
              one of those for which an LC-50 was
              determined under FR 163.71-2 (see the
              discussion on 'Birds') .
Suggested Labeling

    For Technical Mstolachlor:

    "Do not discharge into lakes,  streams, ponds, or public waters unless in
     accordance  with an  NPDES permit.  Ebr  guidance,  contact your• regional
     office of EPA."

    For Emulsifiable Cbncentrate Mstolachlor:

    "Avoid  direct application to any body  of water.  ED  not apply where runoff
     is likely to occur.  ED  not contaminate water by cleaning  of equipment or
     disposal  of wastes.  ED  not apply  when weather conditions  favor drift from
     target area."
                                     104

-------
                               BIBLIOGRAPHY

    Each of the following studies contributed useful  information  to  the
Agency's review of the ecological effects of Metolachlor, and  is  considered
part of the data base which supports registrations under  this  Standard.


Buccafusco, Robert J.  (1978a).  Acute  Tbxicity  Test Results of CGA-24705 to
    Bluegill Sunfish  (Lepomis macrochirus) . Report #BW-78-181. Received
    July 13, 1978 under 100.597.  (Unpublished study prepared by EG&G,
    Bionimics; Submitted by Ciba-Geigy Corp., Greensboro, N.C.; GEL:234396)

Buccafusco, Robert J.  (1978b).  Acute  toxicity  Test Results of CGA-24705 to
    Rainbow Trout (Salmo gairdneri) . Report #BW-78-6-186. Received July
    13, 1978 under 100-597.  (Unpublished study  prepared by EG&G,  Bionomics;
    Submitted by Ciba-Geigy Corp.,  Greensboro,  N.C.;  CEL:234396)

Dionne, E.  (1978).  Chronic Tbxicity of CGA-24705 to  the  Fathead  Minnow
    (Pimephales promelas); received 12-13-78 under 100-587,  (Prepared
    by EG&G Bionomics for Ciba-Geigy Corporation, Greensboro,  N.C.;
    CDL:236620)

Ercegovich, C.D. ; Bogus, E.R. ; Buly, R. L.  (1978) The  Effects of 5, 25, and 125
    PPM of Metolachlor,  [2-Chloro-N-(2-ethyl-6-methylphenyl)-N-(2-metnoxy-l-
    raethylethyl) acetamide] on Actinomycetes, Bacteria and Fungi  in  Laboratory
    Culture Tests. E-2/1-CG78. Received Feb 6,  1978 under 100-583. (Uipublishe
    report prepared by Pesticide  Research  Lab.,  Pennsylvania State University
    for Ciba-Geigy Corp., Greensboro,  N.C.; CDL:232789-F)

Ercegovich, C.D. ; Vallejo, R.P. ;  Bogus, E.R. (1978).  The Effects of 5, 25, and
    125 PPM of Mstolachlor,  [2-Chloro-N-(2-ethyl-6-methylphenyl) -N-(2-methoxy-l-
    methylethyl) acetamide], on Soil Nitrification. E-3/2-CG78. Received Feb 6,
    1978 under 100-583.  (Unpublished study prepared by Pesticide  Research Lab.,
    Pennsylvania State University for  Ciba-Geigy Corp., Greensboro, N.C.;
    CDL:232789-G)

Fink, R. (1974a) .  Eight-Day  Dietary LC-50 — Mallard Ducks Technical  CGA-
    24705: Project No. 108-111. Received September 26, 1974 under 5G1553.
    (Unpublished study by Truslow Farm, Inc. for Ciba-Geigy Corp., Greensboro,
    N.C.; CDL: 112840-0)

Fink, R. (1974a) .  Eight-Day  Dietary LC-50 — Bobwhite Quail Technical CGA-
    24705: Project No. 108-111. Received September 26, 1974 under 5G1553.
    (Unpublished study by Truslow Farm, Inc. for Ciba-Geigy Corp., Greensboro,
    N.C. ; CDL:112840-P)

Fink, R. (1976).  Acute Oral  LD-50  -Mallard Duck: CGA-24705 Technical: Final
    Report. Received November 23, 1976 under 100-587.  (Unpublished study
    prepared by Truslow Farm, Inc.  for Ciba-Geigy Corp.,  Greensboro, N,C.;
    CDL:226955-D)
                                       105

-------
 Fink, Ro  (1978a) .  Che-Generation  Reproduction  Study  - Bobwhite Quail
    CGA-24750 technical Final Report; received  12-13-78 under 100-587,
     (Unpublished report prepared by Wildlife  International  Ltd. for Ciba-Geigy
    Corp., Greensboro, N.C.; GEL:236620)

 Fink, R0  (1978b).  Che-Generation  Reproduction  Study  - Mallard  Duck
    CGA-24705 technical Final Report; received  12-13-78 under 100-587,
     (Unpublished report prepared by Wildlife  International  Ltd. for Ciba-Geigy
    Corp., Greensboro, N.C.; GEL:236620)

 Ebuseworth, L.D. (1973a) Effect of CGA-24705 on Microbial Populations in  Two
    Soils: Report ND . 2. Received  Sep 26, 1974 under  5G1553.  (unpublished study
    prepared by University of Missouri—Columbia, Department  of Plant Pathology
    for Ciba-Geigy Corp.,  Greensboro, N.C.; CEL:94222-F)

 Sachesse, K.; ULlman, L. (1974b).  Acute Toxicity to  Rainbow  Trout,  Crucian
    Carp, Channel Catfish, Bluegill, and Guppy of Technical CGA-24705:  Project
    tto.  Siss 3516.  Received September 26, 1074 under  5G1553.  (Unpublished
    study prepared  by Ciba-Geigy Ltd., Basle, Switzerland,  that includes  a
    cable from Ciba-Geigy  Corp.,  Greensboro, N.C. on  fish name  change;
    CrL:112840-N)

Vilkas,  A.Go  (1976).   Acute Toxicity of CGA-24705 Technical to  the Water  Flea
    Daphnia magna.  Received isbvember 23, 1976 under 100-587.  (unpublished
    study prepared  by Aquatic Environmental  Sciences,  Union Carbide  Corp. for
    Ciba-Geigy Corp.,  Greensboro, N.C.;  CEL:226955-C)
                                     10 6

-------
                            REGULATORY RATIONALE
TECHNICAL METOLACHLOR
    The risks which determine the conditions of a technical chemical's
registrability are those risks which arise in handling, storing, shipping,
re-formulating, and disposing of it - that is, in the various aspects of its
disposition as a manufacturing-use chemical.  Technical Metolachlor, at least
ninety percent the pure compound, is an off-white, odorless liquid, soluble in
water, and miscible with several organic solvents.

The Delimitation of Risks to Humans
         To review~our Toxicology findings, Technical Mstolachlor1 s acute
    toxicity to hunans appears to be mild:  it has a low acute oral toxicity,
    it is not readily absorbed by the skin, it has a very low inhalation
    toxicity, and no eye irritation effects are observable.  The only
    significant short-term effect is skin sensitization.  Once an exposure
    occurs, Metolachlor is rapidly metabolized and excreted.  Although the
    available chronic effects studies were not sufficient to satisfy all the
    Agency's requirements for such testing, the data that were available showed
    no evidence of general chronic, teratogenic, fetotoxic, oncogenic, or
    mutagenic effects.
         The Exposure Profile pointed out that for persons involved in the
    handling, storage, shipment, or re-formulation of Technical Metolachlor,
    there is little likelihood of oral exposure, and because of the low vapor
    pressure of the viscous liquid, there is also little chance of  inhalation
    exposure.  The most likely human exposure is a repeated dermal  exposure,
    and occasionally, by accident, an occular exposure.
         In sun, the acute risks of handling the presently registered
    Technical Metolachlor are minimal, and the currently available  studies
    show no evidence of general chronic, oncogenic, mutagenic, fetotoxic, or
    teratogenic effects due to Matolachlor.  Available studies only suggest
    a potential dermal sensitization problem for factory, transport, or re-
    formulation workers.
         For the professional handling of a manufacturing-use chemical by
    factory, transport, or re-formulation workers, acute risks higher than
    those found for Technical Matolachlor are normally acceptable,-  because the
    Agency expects members of such occupations to be responsive to  a chemical's
    accompanying label precautions.  However, because it is evidently possible
    to manufacture a Technical Matolachlor with a mild acute toxicity, the
    Agency should only register Technical Metolachlor products that fall into
    'Toxicity Categories'  IjT"or~IV"for each of the Tive acute tests:  acute
    oral toxicity, acute~dermaT~tox'i'cTty, acute InHalation toxicity, primary
    eye irritation, and 'primary dermal iTritation^  Technical Matolachlor
    products that faTT~into numerically lower "Ibxicity Categories'  are likely
    to be substantially different in either impurities or inerts from the
    chemical on which this Standard is based, and so a proposal to  amend the
    Standard should accompany the application for their registration.
         The Agency considers the dermal sensitization risk to be acceptable
    in the case of Technical Matolachlor because two reasonable regulatory
    actions are available  for helping to preclude repeated dermal exposures:
    a  label warning that the chemical "May cause skin sensitization" which will
                                       107

-------
    alert handlers to the possibility of the effect;  and a label direction to
    "Wear protective clothing (coveralls and gloves) while handling _o_£ using
    this product".(Jhless the absence of dermal sensitization effects can be
    demonstrated by the appropriate toxicology study, these two requirements
    should be applied to the registration of any Technical Metolachlor product.
         Because the most likely route of long-term exposure to a Technical
    Metolachlor is by repeated dermal contact, the above actions which help
    limit dermal exposures also  serve to render more acceptable the potential
    for the as-yet-undetermined  risk of chronic effects, at least until
    adequate long-term studies have been completed.

The Delimitation of Risks to Wildlife
         To review~our Ecological Effects findings, the available wildlife
    studies suggested several potential hazards for wildlife.   Though the
    toxicity of Technical Metolachlor to birds was showi to be low in one
    dietary LC-50 test, a several month dietary exposure of 300 ppn was shown
    to produce reproductive effects in upland game birds.  Fish were the most
    sensitive species tested, with relatively low L£-50's and  a high mortality
    for fry in the presence of concentrations less than 2 ppm.  Aquatic
    invertebrates have a lesser,  though still significant, sensitivity.
         As stated in our Exposure Profile,  for wildlife in the proximity of
    Technical Metolachlor manufacture, handling,  storage, shipping,-  re-
    formulation, or disposal, intentional discharges of the chemical into the
    environment, such as by disposal or drainage,  as well as unintentional
    discharges, such as by spillage or fire, could conceivably result in
    wildlife exposures.  But the  pathway of  exposure which is  the most direct
    concern is the discharge of  effluent or  the disposal of Matolachlor wastes
    into freshwater aquatic habitats.  The organisms that may  be exposed by
    route of freshwater aquatic  discharge are fish, aquatic invertebrates, and,
    because of plant uptake, local avian or  mairmalian herbivores.
         Thus, if the Technical  chemical or  effluent from its  manufacture or
    re-formulation were disposed  of or allowed to  drain into freshwater aquatic
    habitats, the stability of the Matolachlor compound to hydrolysis and its
    potential resistance to metabolic degredation,  together with its moderate
    acute and serious chronic toxicity for fresh water fish and their fry,
    indicate a potential long-term risk for  fish.   Further, birds continually
    feeding on contaminated leaves or seeds  could  conceivably suffer
    reproductive effects, and aquatic invertebrates, integral  to the watershed
    ecology, could possibly suffer a small population reduction.  The suggested
    label precaution, "Do not discharge into lakes, streams, ponds,  or public
    waters unless Jji accordance  with an NPDES permit" is therefore necessary to
    help control contamination of the~quatic environment.
         As concerns storage and  disposal, it should be noted  that soil
    injection, landspreading, and any unauthorized land disposal would not be
    acceptable for Technical Matolachlor because of its demonstrated mobility
    in soil and resistance to metabolic degradation.  Metolachlor's stability
    to extremes of pH preclude acid or alkalai hydrolysis as a technique for
    disposal or container decontamination.  Further, data are  not presently
    available to demonstrate the  effectiveness or  safety of incineration or
    open burning, nor the degree  of potential damage to activated sludge water
    treatment processes caused by disposal into a  sewage system.  Thus the only
    disposal practice that the Agency can recommend at this time is to place
    Technical Metolachlor _in_ a_ landfill disposal site approved for pesticides.
                                      108

-------
         Until the risks, particularly for fish and birds, are quantified by
    the comparison of toxic concentrations with anticipated  'environmental
    concentrations' resulting  from measured applications to  use sitas, the
    potential for hazard to wildlife cannot be quantified.   Nevertheless, bar-
    ring a severe concentrated spill, and providing that discharge and disposal
    practices are appropriately controlled, the Agency does  not perceive an
    imminent hazard to wildlife from the handling or manufacturing use of
    Technical Matolachlor.  Lhtil these  risks are quantified, the Agency should
    presune that as concerns Ecological  Effects, a Technical Metolachlor
    product will be registrable if  it bears the following warnings:
         Ihder 'hazards  to wildlife1:  "Do not discharge into lakes, streams,
    ponds, ££ public waters, unless in accordance with an NPDES permit. For
    guidanceT contact your Regional Office of EPA.11'  OnHer 'storage and
    disposal1 directions:  "Open dumping or~open burning is  prohibited.
    Thoroughly clean containers "or  tanks before re-use, o~re-seal and offer
    for recycling or reconditioning". Pesticide or rinsat~that cannot be
    used, recycled~or chemically reprocessed, and tanks or  other containers
    that cannot be refused or  recycled; should~~be disposed"^ in a landfill'
    approved for pesticide's. Consult federal, "state, o r lo^al'~d'i's'posaT
    authorities for approved' alternative procedures."

    Section  162.11(a) of 40 CFR states that the Agency shall presune against
the registration of a pesticide product which meets or exceeds certain specific
risk criteria set forth therein.  Because the available data on potential
effects to man or the environment do not indicate that any of these risk
criteria would be met or exceeded for a  Technical Metolachlor which meets all
the 'standards' suggested above, the Agency shall presume that such Technical
Metolachlor  is registerable for sale, distribution, and re-formulation in the
In i ted States.
EMULSIFIABLE CONCENTRATES of METOEACHLOR

    This Standard will presently only cover  'emulsifiable concentrate1 type
formulations of Metolachlor, because the hazards due to other formulation types
such as granulars or dusts, and the significantly different application methods
they would require, are not adequately considered by the data available on the
presently registered formulations.  Additional data pertaining to the product
chemistry, environmental fate, toxicology, residue chemistry, and ecological
effects of new formulation types and their application methods would be needed
to evaluate the registrability of such products.
    Emulsifiable Concentrate formulations containing Metolachlor alone are
appropriate for the control of weeds in non^kmestic, outdoor, terrestrial food-
crop fields.  When not 'tank mixed' with other herbicides, the Emulsifiable
Concentrates should be applied by conventional ground spray or through center
pivot irrigation systems before, during, or after planting, but always before
the emergence of the crop seedlings.  The applications must be pre-emergence
because residue data are not available to show that tolerances will not be
exceeded by post-emergence applications, and because the ecological effects of
a post-harvest application have not been determined, particularly for birds.
    The establishment of tolerances for agricultural-use pesticides requires
certain residue chemistry data.  Occasionally, sufficient residue chemistry
data are available for several crops within a crop grouping (e.g.,  'grain
crops', 'leafy vegetables', or 'root crop vegetables')  so that the  Agency can
                                     109

-------
establish a toleranca for other crops in the grouping without  requiring
additional data.  For Matolachlor, however, the presently available  residue
data are only sufficient to support tolerances for, and thereby  enable the  use
of  Emulsifiable Cbncantrate Matolachlor on:  corn grown for grain  (excluding
popcorn), soybeans,  (Concep-treated) grain sorghun, and peanuts.   Presently
available residue data show that Metolachlor Emulsifiable Concentrate can be
applied pre-emergence to corn fields at a rate of up to 6 Ibs. ai/acre,  to
soybean fields at a  rate of upTo 3 J5s.~ai/acre, _to grain sorghum fields _at
rates of up to ~2=l72 Ibs .~i7acre',~and to_ peanuts ~at_ _up _to 3 Ibs.  ai/acre,
withou~e3cceearing the established tolerances.
    If the crop treated with the Bnulsifiable Concentrate  is lost, it may be
replanted immediately with com, soybeans, peanuts, or (Concap-treated)  grain
sorghum without a second treatment.
    The recommended  rotational crop restriction (conditional upon  an agreement
to generate the required data as specified)  is as follows:  Small  grains may be
planted 4-1/2 months following treatment.  Field corn (except  fresh corn and
popcorn), cotton, soybeans, peanuts, sorghum, root crops,  and  small grains  may
be planted in the spring following treatment.  Do not graze or feed forage  o_r
fodder EronTco'tto'n or small grains to livestockT" All other rotational crops
may be planted 18 months after application.

The Delimitation of Risks _to Humans
         It may be~recalled~from our Tbxicology review that the presently
    registered Emulsifiable Concentrate formulations of Metolachlor have  sane
    potential for serious acute effects.  The eight pounds per gallon
    formulation could produce severe irritation and burns on contact.  The  six
    pounds per gallon formulation can cause serious eye irritation, including
    irreversible corneal opacity.  Like the active ingredient, any Emulsifiable
    Concentrate may produce skin sensitization with repeated exposures.
         The Ekposure Profile determined that for an outdoor agricultural
    ground spray, there is a possibility of dermal and eye exposure from  the
    splashing that may occur while diluting and tank mixing, and in the  loading
    of spray equipment.  If an Emulsifiable Concentrate has a  high vapor
    pressure, as do most products with organic solvents, an unprotected mixer
    or diluter who is handling an open container without adequate ventilation
    may be exposed to funes.  Also of concern are the spray droplets generated
    by the application of a ground-sprayed agricultural pesticide, which  could
    result in an inhalation exposure for applicators and other agricultural
    workers who may be in the proximity of the spraying.   Chronic dietary
    exposures for the general population are expected to occur at finite
    levels, due to residues on food (and in animal products from livestock  fed
    Metolachlor-treated plant parts)  which will be less than the established
    tolerances.
         The Agency concludes that there is presently no  evidence of general
    chronic, teratogenic,  fetotoxic, oncogenic, or mutagenic effects due  to
    end-use of Metolachlor.  Miown chronic dietary hazards for the general
    population were estimated to be avoidable at exposures less than 0.0750 mg
    per day.  But there may be acute risks involved in the end-use of
    Bnulsifiable Concentrate formulations.  The acute risks to hunans caused by
    the handling of  these Emulsifiable Concentrate formulations consist
    primarily in the potential for skin and eye burns from accidental
    splashing, the potential for skin sensitization from  repeated dermal
    contact, the danger of fune inhalation from mixing or  loading  in a poorly
    ventilated area, and the danger of spray inhalation near the point of
    ground spray application.  Except for the skin sensitization hazard,  the
    severity of these hazards from the use of a particular formulation depends

                                    110

-------
upon its acute toxicity and  irritation  categories.   The  sensitization
hazard depends directly upon the concentration  of the  active ingredient.
     First we will consider  the acceptability of  the various acute  risks.
     As concerns acute oral  toxicity, because Mstolachlor  is not  intended
for domestic use, and is not mixed with seeds or  foodstuffs  before
application, there is very little chance  of  accidental oral  exposure, and
the Agency should accept Metolachlor  formulations with an  acute oral
toxicity as high~as Category II.  A Category I  would not~be  acceptable
unless the formulation were  classified  for restricted  use  by certified
applicators.
     As concerns acute dermal  toxicity, because even with  appropriate label
precautions there1 is still a reasonable chance  for occasional accidental
dermal exposures in mixing,  diluting, loading,  or spraying,  the Agency
should not accept a Metolachlor formulation  with  an acute  dermal~boxicity
higher than Category III.~
     As concerns acute inhalation toxicity,  although Matolachlor  is an
outdoor use pesticide and is commonly mixed, diluted,  and  loaded outdoors,
because most Emulsifiable Concentrates  have  a high volatility, a high
inhalation exposure could even occasionally  occur outdoors.   The actual
spraying could also result in  inhalation  exposures for those nearby.
Nevertheless, because the loading and mixing do commonly occur outdoors,
because the spraying is limited to ground spraying, and  because the
accompanying warning "Do not breathe vapors" would be  reasonably effective
with even untrained applicators, a Category  II  inhalation  toxicity should
be acceptable.  A formulation with a  Category I inhalation toxicity,
however, would require sane  protective  apparatus,  and  without restricting
the chemical to use by trained applicators,  the Agency cannot be assured
that such equipment would be consistently used.   An additional limit  that
will not affect efficacy can be put on  the exposure to vapors by limiting
the physical/chemical property -vapor pressure1 to less  than 1.0 mm Hg.
The Agency will thus find acceptable a  Matolachlor formulation with an
acute inhalation toxicity as high but no  higher than a_ Category II, and a
vapor pressure between 0.03~and 1.0 mm  Hg.
     With the above limitations on th~e~  3e~rmal and  inhalation hazards,  the
Agency does not see the need to prescibe  a re-entry interval for
Metolachlor.  Nevertheless,  users should  be aware  that the "application of
a pesticide in such a manner as to directly  or  through drift expose workers
or other persons except those knowingly involved  in the  application"  is
expressly prohibited under 40 CFR 170.3.
     As concerns primary eye irritation,  the classification  guidelines
suggest that any Category I  toxicity  rating  should imply a restriction of
the product's use to certified applicators,  unless some  aspect of
"formulation, packaging, or  method of use of the  product (which)  can
reasonably be expected to eliminate the route of  exposure" is available and
is likely to be effective [162.11 (c)(2)].   In  the case  of Metolachlor as
an agricultural-use crop field spray, the requirement  to "Wear goggles or_
face shield when handling" which accompanies a Category  I  formulation can
be expected to be complied with by even untrained agricultural workers or
applicators, and it may be assumed that such protective  equipment as
goggles are conmonly available to pesticide applicators.   This assurance
allows the Agency to accept  a_ Metolachlor formulation  with _a primary  eye
irritation as high~as Category ^.
     As concerns primary dermal~irritation, because of the likelihood of
accidental dermal exposures, the Agency should not accept £  formulation
with a dermal irritation higher~than Category II.  (Category II is
acceptable for dermal irritation, but not for dlFrmal toxicity, because sane


                                  111

-------
high concentration accidental dermal exposures are certain to occur, and a
high exposure to a Category II dermal toxicity solution brings  the user too
close to a risk of whole body poisoning, including death, while a Category
II dermal irritation could at worst result in local dermal injury.)  The
Agency can further delimit the risk of dermal irritation, without affecting
efficacy, by limiting the physical/chemical property  'pli' _to the relatively
neutral range of pH 6 _to pH _8.
     Th~e Agency consTders~~Ehe dermal sensitization risk to be acceptable in
the case of Emulsifiable Concentrates of Metolachlor because two reasonable
regulatory actions are available for helping to preclude repeated dermal
exposures:  a label warning that "The active ingredient, metolachlor, may
cause skin sensitization", which will alert handlers to the possibility of
the effect;and label directions to "Wear gloves and protective clothing
when handling", "Wash thoroughly after handling", and "Remove and wash"
contaminated clothing before re-use".  Even though applicators and
agricultural workers who may cone in contact with the chemical might be
untrained in the handling of pesticide chemicals, the Agency can reasonably
assune that the simple and unencumbering direction to wear gloves or other
protective clothing will be obeyed most of the time.  Even if, as stated
above, occasional accidental dermal exposures are highly likely, only a
continous series of repeated exposure could lead to dermal sensitization.
     Three additional physical/chemical properties of concern for their
potential health effects are flammability, explosiveness, and
corrosiveness.  Because Emulsifiable Concentrate Metolachlor will be
handled by untrained applicators and is likely to be used or mixed near
combustion engines and other machinery, it should not be "flammable" by
Agency standards, which means that its flashpoint should be above 80°F.
Because the solvents, however, are likely to bring the flashpoint Below
150 F, users should be warned: "Do not use or store near heat or open
flame" in both the 'Precautionary Statements''" and 'Storage and~Disposal'
sections of the label.  Second, because it would require special training
for safe handling, no Matolachlor Emulsifiable Concentrate should be
explosive or shock sensitive.  Third, a corrosive pesticide might Horn
though application tanks or storage containers, potentially resulting in
harmful skin or eye exposures.  But a slight corrosiveness to steel or tin
is acceptable if the warning "Do not store in unlined containers or tanks"
appears in both the 'Precautionary Statements"1 and Storage and Disposal'
sections of the label.
     Finally, because without protective clothing the most likely route of
long-term exposure for applicators is the dermal route, the above actions
which help limit dermal exposures also serve to render more acceptable the
potential for the as-yet-undetermined risks of chronic effects, at least
until adequate long-term studies have been completed.  The known chronic
risks of a dietary exposure for the general public are limited by the
fact that residues resulting from acceptable use patterns will not exceed
established tolerances for the crops to which the formulations are applied
and for products from animals which are fed these crops.  Because the
chronic effects data base is not yet complete, the Agency will presently
consider additional food uses for Metolachlor on an incremental risk and
benefits assessment basis.  The established tolerances provide a more than
2000 fold safety factor between the highest potential human dietary
exposure and the "no observed effect level" from a valid six-month feeding
study on dogs.
                                   112

-------
The Delimitation of Risks to Wildlife
         The potential effects  to wildlife due  to Pfetolachlor exposures
    resulting from the use of the formulations  are estimated in toxicity
    studies on the Technical.   To review our  Ecological Effects findings for
    the Technical, the available wildlife studies suggested several potential
    hazards for wildlife.  Though the toxicity  of Technical f-fetolachlor to
    birds was shown to be low in one dietary  LC-50 test, a several month
    dietary exposure of  10  ppm was shown to  produce reproductive effects in
    upland game birds.  Fish were the most sensitive species tested, with
    relatively low LC-50's and  a high mortality for fry in the presence of
    concentrations less than 2  ppm.  Aquatic  invertebrates have a lesser,
    though still significant, sensitivity to  Nfetolachlor.
         As stated in our Exposure Profile, several aspects of Metolachlor's
    fate, including its tendency to leach or  runoff, its stability to
    hydrolysis, and its resistance to microbial degradation, combine to suggest
    that the end-use application of Metolachlor formulations could contaminate
    surface and groundwater, thereby exposing fish, freshwater plants and
    animals, animals which drink the contaminated water, or carnivores which
    feed on the contaminated fish.  Further,  because of Metolachlor's
    demonstrated uptake by rotational crops,  it may be assumed that some
    aquatic or terrestrial plants may either  suffer phytotoxic exposures or
    pass Matolachlor residues on to herbivores, including birds.
         Thus, several concerns about wildlife  risks arise from the suspicion
    that Pfetolachlor residues will migrate to and persist in aquatic habitats.
    The most notable of these potential, but  as yet unquantified,  risks is that
    to the fry of freshwater fish.  Lesser but potentially serious risks may
    exist for adult fish, nesting herbivorous birds, or aquatic invertebrates,
    the last of which can be integral to the  ecology of terrestrial watersheds.
         Uhtil the Agency compares toxic concentrations with the as yet
    undetermined 'environmental concentrations'  resulting from measured
    applications to use sites,  the potential  for hazard cannot be  quantified.
    But unless the formulated pesticide is directly applied to or  disposed of
    into water, heavily applied in an area of hilly terrain with soils of a
    high organic content, or applied when weather conditions favor drift to
    aquatic sites,  the Agency does not forsee an immanent risk to  wildlife from
    the routine use of Mstolachlor formulations.  Thus, the Agency considers
    these as yet unquantified risks to be temporarily acceptable,  at least
    until a quantification becomes possible,  if the labels for Mstolachlor
    formulations present the following statements under 'hazards to wildlife':
    "Avoid direct application _to any body ^f water. Do not apply where runoff
    is likely to occur. Do not~~contaminate water by cleaning of equipment or
    disposal o~F~wastes. Do not  apply when weatHer~conditions Tavor drift from
    areas tr'eaTed."
         As with the Technical, disposal practices involving soil  injection,
    landspreading,  hydrolysis,  incineration,  open burning, or discharge into a
    sewage system are  not supported by the current (fata.  Disposal should thus
    be limited to landfill disposal sites approved for pesticides: "Open
    dumping  or_ open burning _is  prohibited.  Do not re-use empty container;
    triple rinse or equivalent.  Pesticide or rinsate that cannot _be used,
    recycled,  or cHemically reprocessed, an? triple-rinsed containers with
    their rinsaTeTshould be  disposed of _in a landfill approved for
    pesticIcTes.  Consult federal, state,  or  local disposal  autHonties for
    approved alternative  procedures."
                                       113

-------
    Section 162.11(c)  of 40 CFR states .that the Agency may classify  for
•general use1 ,  that is, for purchase and use by any member of the general
public, any end-use pesticide product which meets certain specific criteria
set forth therein, or else has a formulation, package, or method of  use which
can reasonably  be expected to eliminate the route of exposure for each hazard
which exceeds a criterion [162.11 (c)(2)].  The available data on potential
effects to man  and the environment show that all of these criteria,  except for
eye irritation, would be met for an Hnulsifiable Concentrate Mstolachlor which
was in accord with all the 'Standards'  suggested in the above discussions;
and eye exposure can be effectively eliminated by the requirement to "Wear
goggles or face shield when handling".   An Emulsifiable Concentrate  Metolachlor
which meets all the Standards suggested in the above discussions is  therefore
classified for  'general use'.
                                      114

-------
   APPENDIX
115

-------
                           CHEMICAL DATA SHEETS
    Chemical Data Sheets have been prepared for the components, hydrolysis
products, and known metabolites of manufacturing-use Metolachlor.  The Data
Sheets are divided into Components COM001 through COM011, Hydrolysis Products
HP001 and HP002, and Metabolites MET001 through MET024.  Chemical Data Sheets
are not available for MET025 and MET026, though their structures are given in
the Environmental Fate chapter.
                                       117

-------
                          COMPONENT NUMBER COM001
01.  Chemical Abstracts Chemical names;

    01   Acetamide, 2-chloro-N-(2-ethyl-6-raethylphenyl)-N-(2-methoxy-l-
         methylethyl) - (CA9)

    02   o-Acetotoluidide,  2-chloro-6 ' -ethyl-N- (2-methoxy-l-methylethyl) -
         (CAS)

02.   Other Chemical Names;

    01   2-Chloro-N- (2-ethyl-6-methylphenyl) -N- (2' -methoxy-1' -methylethyl) -
         acetamide

    02   Acetanilide, 2-chloro-2'-ethyl-N-(2-methoxy-l^nethylethyl)-6'-methyl-

    03   N- (2' -Methoxy-1' -methylethyl) -2-ethyl-6-methyl-chloroacetanilide

    04   N- (Chloroacetyl) -6-ethyl-N- (2-methoxyisopropyl) -o-toluidine

03.   Structural Formula;
                         ^^NTT*
04.  Molecular (Empirical) Formula;

         C 15H22C1N°2

05.  Chemical Abstracts (CAS)  Registry Number;
 06.  Approved Common Name;

    01   Metolachlor

 07.  Other Common Names, Trade Names, or Codes;

    01   Dual

    02   CGA No. 24705



                                   119

-------
Chemical Data Sheets COM-002 through COM-011 have been
emitted in this Sample Registration Standard because of
      confidentiality claims by the manufacturer.
                            120

-------
                        HYDRQLYTIC PRODUCT NUMBER HP001








01.  Chemical Abstracts Chemical Names;




    01   1-Propanol, 2-[(2-ethyl-6-inethylphenyl)amino]- (CA9)




    02   1-Propanol, 2-(6-ethyl-o-toluidino)- (CAS)



02.  Other Chemical Names;




    01   1-Propanol, 2-(2-ethyl-6-methylanilino)-



    02   2-[(2-Ethyl-6-methyl)amino]-1-propanol




03.  Structural Formula;
04.  Molecular  (Empirical) Formula;








05.  Chemical Abstracts  (CAS) Registry Number;






06.  Approved Common Name;  None




07.  Other  Common Names,  Trade Names,  or Codes;




     01   CGA NO. 37913



     02   PHP (Propanol hydrolytic  product)
                                    121

-------
                       HYDRDLYTIC PRODUCT NUMBER HP002



01.  Chemical Abstracts Chemical Names;

    01   3-Morpholinone, 4~(2-ethyl~6-methylphenyl)-2-hydroxy-5-roethyl-

    02   3-Morpholinane, 4-(6-ethyl-2-tolyl)-2-hydroxy-5-roethyl-

02.  Other Chemical Names;
    01   4-(2-Ethyl-6-methylphenyl)~2-hydroxy-5~roethyl-3-morpholinone

03.  Structural Formula;
04.  Molecular (Empirical) Formula?



05.  Chemical Abstracts (GAS) Registry Number?


06o  Approved Correnon Name?  None

07.  Other Common Names, Trade Names, or Cedes;

    01   CGA No.  49751

    02   MHP (iRorpholinone hydrolytic product)
                                    122

-------
                           METABOLITE NUMBER MET001
01.  Chemical Abstracts Chemical Names;

    01   Acetamide, N-(2-ethyl-6-methylphenyl)-2-hydroxy-N-(2-methoxy-l-
         methylethyl)- (CA9)

    02   o-Acetotoluidide, 6'-ethyl-2-hydroxy-N-(2-methoxy-l-methylethyl)-
         (CA8)

02.  Other Chemical Names;

    01   Acetanilide, 2'-ethyl-2-hydroxy-N-(2-methoxy-l-methylethyl)-6'-methy1-

    02   N- (2-Ethyl-6-methylphenyl)-2-hydroxy-N-(2-methoxy-l-
         methylethyl )acetamide

03.  Structural Formula;
04.  Molecular (Empirical) Formula;

         C15H23N03

05.  Chemical Abstracts (CAS) Registry Number;

06.  Approved Conroon Name;  None

07.  Other Common Names, Trade Names, or Codes;

    01   CGA NO.  40172
                                    123

-------
                           METABOLITE NUMBER MET002








01.  Chemical Abstracts Chemical Names;




    01   Acetamide, N-(2-ethyl-6-methylphenyl)-2-hydroxy- (CA9)




    02   o-Acetotoluidide,  6'-ethyl-2-hydroxy-(CA8)



02.  Other Chemical Names;



    01   Acetanilide, 2'-ethyl-2-hydroxy-6'-methyl-



    02   N-(2-Ethyl-6-methylphenyl)-2-hydroxyacetamide




Structural Formula;
04.  Molecular (Empirical) Formula;








05.  Chemical Abstracts (CAS) Registry Number;






06.  Approved Common Name;  None



07.  Other Common Names, Trade Names, or Codes;



    01   CGA No. 37735
                                    124

-------
                           METABOLITE NUMBER MET003
01.  Chemical Abstracts Chemical Names;

    01   Acetamide, 2-chloro-N-(2-ethyl-6-methylphenyl)-N-(2-hydroxy-l-
         raethylethyl)- (CA9)

    02   o-Acetotoluidide, 2-chloro-6'-ethyl-N-(2-hydroxy-l-methylethyl)-
         (CA8)

02.  Other Chemical Names;

    01   Acetanilide, 2-chloro-2l-ethyl-N-(2-hydroxy-l-methylethyl)-6'-nethyl-

    02   2-Chloro-N- (2-ethyl-6-methylphenyl)-N- (2-hydroxy-l-
         methylethyl)acetamide

03.  Structural Formula;
                                 \    ^CH-CM-
                                            ct
04.  Molecular  (Empirical) Formula;


         C14H20C1N02

05.  Chemical Abstracts  (CAS) Registry Number;
06.  Approved Cannon Name;  None

07.  Other Common Names, Trade Names, or Codes;

    01   CGA No. 41638
                                     125

-------
                           METABOLITE NUMBER MET004








01.  Chemical Abstracts Chemical Names;



    01   DL-Alanine, N-(2-ethyl-6-methylphenyl)-N-(hydroxyacetyl)- (CA9)




    02   DL-Alanine, N-(6-ethyl-o-tolyl)-2-(hydroxyacetyl)- (CAS)




02.  Other Chemical Names;



    01   Propanoic acid, 2-[N-(2^thyl-6-methylphenyl)-2-hydroxyacetamido]



    02   Propionic acid, 2-[N-(6-ethyl-o-tolyl)-2-hydroxyacetamido]-



    03   N- (2-Ethyl-6-methylphenyl)-N-(hydroxyacetyl)alanine




03.  Structural Formula;
                            	\     xCH— COOH
04.  Molecular (Empirical) Formula;




         C14H19N03




05.  Chemical Abstracts (CAS) Registry Number;






06.  Approved Common Name;  None




07.  Other Common Names, Trade Names, or Codes;



    01   CGA No.  46129
                                    126

-------
                           METABOLITE NUMBER MET005



01.  Chemical Abstracts Chemical Names;

    01   Acetamide, N-(2-ethyl-6-methylphenyl)-N-(2-^nethoxy-l-methylethyl)'
         (CA9)

    02   o-Acetotoluidide, 6'-ethyl-N-(2-methoxy-l-methylethyl)- (CAS)

02.  Other Chemical Names;

    01   Acetanilide, 2'-ethyl-N-(2-methoxy-l-methylethyl)-6I-methyl-

    02   N-(2-Ethyl-6-methylphenyl) -N-(2-methoxy-l-methylethyl)acetamide

03.  Structural Formula;
04.  Molecular  (Empirical) Formula;


         C15H23ira2

05.  Chemical Abstracts  (CAS) Registry Number;
 06.  Approved Common Name;  None

 07.  Other  Common Names,  Trade Names,  or Codes;

     01    Dechlorometolachlor

     02    CGA No. 41507
                                    127

-------
                           METABOLITE NUMBER MET006



01.  Chemical Abstracts Chemical Names;

    01   Acetamide,  N-(2-ethyl-6-methylphenyl)-N-(2-hydroxy-l-methylethyl)•
         (CA9)

    02   o-Acetotoluidide, 6'-ethyl-N-(2-hydroxy-l-methylethyl)- (CA8)

02.  Other Chemical  Names;

    01   Acetanilide, 2'-ethyl-N-(2-hydroxy-l-methylethyl)-6'-methy1-

    02   N-(2-Ethyl-6-methylphenyl)-N-(2-hydroxy-l-methylethyl)acetamide

03.  Structural Formula;
                                       r
                                         -CHjOH
                                       v-wnj

                                 'V
-------
                           METABOLITE NUMBER MET007








01.  Chemical Abstracts Chemical Names;




    01   Acetamide, N-(2-ethyl-6-methylphenyl)- (CAS)



    02   o-Acetotoluidide, 6'-ethyl- (CAS)



02.  Other Chemical Names;




    01   Acetanilide, 2'-e thy 1-6'-me thy 1-




    02   &-(2-Ethyl-6-methylphenyl)acetamide




03.  Structural Formula;
 04.  Molecular  (Empirical)  Formula;








 05.  Chemical Abstracts  (CAS)  Registry Number;






 06.  Approved Common Name;   None



 07.  Other Common Names,  Trade Names,  or Codes;




     01   CGA No.  42444
                                     129

-------
                           METABOLITE NUMBER MET008








01.  Chemical Abstracts Chemical Names;



    01   3-Morpholinone, 4-(2-ethyl-6-methylphenyl)-5-methyl- (CAS)



    02   3-Morpholinone, 4-(6-ethyl-o-tolyl)-5-methyl- (CAS)




02.  Other Chemical Names;



    01   4-(2-Ethyl-6-methylphenyl)-5-methyl-3-morpholinone




03.  Structural Formula;
04.  Molecular (Empirical)  Formula;








05.  Chemical Abstracts (CAS)  Registry Number;






06.  Approved Common Name;   None




07.  Other Common Names,  Trade Names, or Codes;




    01   CGA No.  40919
                                   130

-------
                           METABOLITE NUMBER MET009



01.  Chemical Abstracts Chemical Names;




    01   Acetamide, 2-chloro-N-(2-ethyl-6-methylphenyl)- (CA9;




    02   £-Acetotoluidide, 2-chloro-6'-ethyl- (CAS)



02.  Other Chemical Names;




    01   Acetanilide, 2-chloro-2'-ethy1-6'-methyl




    02   2-Chloro-N- (2-ethyl-6-methylphenyl) acetamide




03.  Structural Formula;
 04.  Molecular  (Empirical) Formula;
 05.   Chemical Abstracts  (CAS) Registry Number;






 06.   Approved Common Name;  None



 07.   Other  Common Names,  Trade  Names, or  Codes;



     01    CGA No.  13656
                                     131

-------
                           METABOLITE NUMBER MET010








01.  Chemical Abstracts Chemical Names;




    01   Benzenamine, 2-ethyl-N-(2-methoxy-l-raethylethyl)-6-methyl-  (CA9]



    02   oj-Toluidine, 6-ethyl-N-(2-methoxy-l-methylethyl)-  (CAS)




02.  Other Chemical Names;



    01   Aniline, 6-ethyl-N-(2-methoxy-l-methylethyl)-6-^nethyl-




    0 2   2-Ethyl-N_- (2-methoxy-l-methylethyl) -6-methylbenzenamine




03.  Structural Formula;
04.  Molecular (Empirical) Formula;








05.  Chemical Abstracts (CAS) Registry Number;






06.  Approved Common Name;  None




07.  Other Common Names, Trade Names, or Codes;



    01   CGA No.  38502
                                    132

-------
                           METABOLITE NUMBER MET011

01.  Chemical Abstracts Chemical Names;

    01   Acetamide, N-(2-ethyl-6-methylphenyl)-2-mercapto-N-(2-methoxy-l-
         methylethyl)-,S-conjugate with Glutathione

    02   o-Acetotoluidide, 2'-ethyl-2-mercapto-N-(2-methoxy-l^nethylethyl)-,
         S-conjugate with Glutathione

02.  Other Chemical Names;

    01   Acetanilide, 2'-ethyl-2-inercapto-N-(2-methoxy-l-methylethy)-6'-
         methy1-,S-conjugate with Glutathione

    02   Glutathione, sulfide with 2-chloro-N-(2-ethyl-6-methylphenyl)-N-
         (2-methoxy-l-methylethyl)acetamide

    03   Glutathione, sulfide with 2-chloro-6'-ethyl-N-(2-methoxy-l-
         methylethyl)-o-acetotoluidide

03.  Structural Formula;
 04.  Molecular  (Empirical)  Formula;



 05.  Chemical Abstracts  (CAS)  Registry Number;


 06.  Approved Camon Name;   None

 07.  Other  Common Names,  Trade Names,  or Codes;

     01   Metolachlor glutathione  conjugate

     02   CGA No. 43826
                                    133

-------
                           METABOLITE NUMBER MET012
01.  Chemical Abstracts Chemical Names;

    01   Acetamide, N-(2-ethy1-6-methyIphenyl)-2-mercapto-N-(2-methoxy-l-
         methylethyl)-, S-con jugate with Glucuronic acid (CA9)

    02   o-Acetotoluidide, 2'-ethyl-2-mercapto-N-(2-methoxy-l^nethylethyl)-,
         S-conjugate with Glucuronic acid (CAS)

02.  Other Chemical Names;

    01   Acetanilide, 2'-ethyl-2-mercapto-N-(2-methoxy-l-methylethyl) -6' -
         methyl-,S-conjugate with Glucuronic acid

    02   Glucuronic acid, 1-S-[[[(2-ethy1-6-methyIphenyl)(2-methoxy-l-
         methylethyl )-amino]carbonyl]methyl]-1-thio-

    03   Glucuronic acid, 1-S-[[(6-ethyl-o-tolyl)(2-methoxy-l-methylethyl)
         carbamoyl]methyl]-1-thio-

03.  Structural Formula;
04.  Molecular (Empirical) Formula;

         C21H30"°8S

05.  Chemical Abstracts (CAS) Registry Number;
06.  Approved Common Name;  None

07.  Other Common Names, Trade Names, or Codes;

    01   Metolachlor glucuronic acid conjugate

    02   Compound N
                                    134

-------
                          METABOLITE NUMBER MET013

01.  Chemical Abstracts Chemical Names;

    01   Acetamide, N-(2-ethyl-6-methylphenyl)-N-(2-hydroxy-l-methylethyl)-2-
         mercapto-, 0-glucoside, S-conjugate with Glucuronic acid  (CA9)

    02   pj-Acetotoluidide, 6'-ethyl-N-(2-hydroxy-l-methylethyl)-2-mercapto-,
         0-glucoside, S-conjugate with Glucuronic acid  (CAS)

02.  Other Chemical Names;

    01   Acetanilide, 2'ethyl-N-(2-hydroxy-l-methylethyl)-2-mercapto-6'-
         methyl-, 0-glucoside, S-conjugate with Glucuronic acid

    02   Glucuronic acid, 1-S-[[(6-ethyl-o-tolyl)(2-glucosyl (1) -1-
         methylethyl)carbamoyl]methyl]-1-thio-

    03   Glucuronic acid, 1-S-[[[(2-ethyl-6-methylphenyl)(2-glucosyl(1)-1-
         methylethyl)amino]carbonyl]methyl]-1-thio-

03.  Structural  Formula;
                           ,CH
 04.  Molecular  (Empirical)  Formula;



 05.  Chemical Abstracts  (CAS)  Registry Number;


 06.  Approved Common Name;   None

 07.  Other  Common Names,  Trade Names,  or Codes;

     01    Compound No. 0
                                    135

-------
                           METABOLITE NUMBER MET014
01.  Chemical Abstracts Chemical Names;

    01   Acetamide, N-(2-ethyl-6-methylphenyl)-N-(2-hydroxy-l-methoxyethyl)-2-
         mercapto-, S-conjugate with Glucuronic acid  (CA9)

    02   o-Acetotoluidide,  2'-ethyl-N-(2-hydroxy-l-methylethyl)-2-mercapto-,
         S-conjugate with Glucuronic acid  (CAS)

02.  Other Chemical Names;

    01   Acetanilide, 2'-ethyl-N-(2-hydroxy-l-methylethyl)-2-mercapto-6I-
         methyl-, S-conjugate with Glucuronic acid

    02   Glucuronic acid, 1-S-[[[(2-ethyl-6-methylphenyl)(2-hydroxy-l-
         methylethyl)amino]carbonyl]methyl]-1-thio-

    03   Glucuronic acid, 1-S-[[(6-ethyl-o-tolyl)(2-hydroxy-l-
         methylethyl)carbamoyl]methyl]-1-thio-

03.  Structural Formula;
04.  Molecular (Empirical)  Formula;

         C2QH28N08S

05.  Chemical Abstracts (CAS)  Registry Number;


06.  Approved Common Name;   None

07.  Other Common Names, Trade Names, or Codes;

    01   Eemethyimetolachlor glucuronic acid conjugate
                                    136

-------
                           METABOLITE NUMBER MET015
01.  Chemical Abstracts Chemical Names;

    01   Acetamide, N-(2-ethyl-6-methylphenyl)-2-hydroxy-N-(2^nethoxy-l-
         methylethyl)-, O-conjugate with Glucuronic acid   (CA9)

    02   o-Acetotoluidide, 2'-ethyl-2-hydroxy-N-(2-fnethoxy-l-methylethyl)-,
         O-conjugate with Glucuronic acid  (CAS)

02.  Other Chemical Names;

    01   Acetanilide, 2'-ethyl-2-hydroxy-N-(2-methoxy-l-methylethyl)-6'-
         methyl-, O-conjugate with Glucuronic acid

    02   Glucuronic acid, 1-0-[[[(2-ethyl-6-methylphenyl)(2-methoxy-l-
         me thy lethyl )amino] carbony]methyl]-

    03   Glucuronic acid, 1-0-[[(6-ethyl-o-tolyl)(2-methoxy-l-methylethyl)-
         carbamoy 1 ] me thy 1 ] -


03.  Structural Formula;


                               Ctl,  
-------
                           METABOLITE NUMBER MET016
01.  Chemical Abstracts Chemical Names;

    01   Acetamide, N-(2-ethyl-6-methylphenyl)-2-hydroxy-N-(2-hydroxy-l-
         methylethyl)-, O-conjugate with Glucuronic acid

    02   £-Acetotoluidide, 2'-ethyl-2-hydroxy-N-(2-hydroxy-l-methylethyl)-,
         O-conjugate with Glucuronic acid

02o  Other Chemical Names;

    01   Acetanilide, 2'-ethyl-2-hydroxy-N-(2-hydroxy-l-methylethyl)-6'-methyl-,
         O-conjugate with Glucuronic acid

    02   Glucuronic acid, 1-0-[[[(2-ethyl-6-methylphenyl)(2-hydroxy-l-
         methylethyl )amino] carbonyl]methyl]-

    03   Glucuronic acid, 1-0-[[(6-ethyl-o-tolyl)(2-hydroxy-l-methylethyl)-
         carbamoyl]methyl]-

03,,  Structural Formula;
                                             COOM
04.  Molecular (Empirical) Formula;

         C20H29I:D9
05.  Chemical Abstracts (CAS) Registry Number;
06o   Approved Cannon Name;   None

07.   Other Common Names, Trade Names, or Codes;

    01 Desmethylmetolachlor glucuronic acid conjugate
                                    138

-------
                           METABOLITE NUMBER MET017
01.  Chemical Abstracts Chemical Names;

    01   Acetamide, N-(2-ethy1-6-methyIphenyl)-2-hydroxy-N-(2-hydroxy-l-
         methy lethyl)-, 0-glucoside, 0-conjugate with Glucuronic acid  (CA9)

    02   £-Acetotoluidide, 6'-ethyl-2-hydroxy-N-(2-hydroxy-l-methylethyl)-,
         O-glucoside, O-conjugate with Glucuronic acid   (CAS)

02.  Other Chemical Names;

    01   Acetanilide, 2'-ethyl-2-hydroxy-N-(2-hydroxy-l-methylethyl)-6'-
         methyl-,0-glucoside, O-conjugate with Glucuronic acid

    02   Glucuronic acid, 1-0-[[(6-ethyl-o-tolyl)(2-glucosyl(1)-1-
         methylethyl)-carbamoyl]methyl]

    03   Glucuronic acid, 1-0-[[[((2-ethyl-6-methylphenyl)(2-glucosyl(1)-1-
         methylethyl)amino]carbonyl]methyl]-

03.  Structural Formula;
 04.  Molecular  (Empirical)  Formula;


          C26H39ig°14

 05.  Chemical Abstracts (CAS)  Registry Number;
 06.  Approved  Common Name?   None

 07.  Other  Common Names,  Trade Names,  or Codes;   None
                                     139

-------
                            METABOLITE NUMBER: 018
01.  Chemical Abstracts Chemical Names:

     01 Quinoline, N-(2-methoxy-l-methylethyl)-8-
        ethyl-3-hydroxy-2-oxo-l,2,3,4-tetrahydro-
02.  Other Chemical Names:

     01 8-Ethyl-3-hydroxy-N-(2-methoxy-l-methylethyl)
        2-oxo-l,2,3,4-tetrahydroquinoline
03.  Structural Formula:
04.  Molecular (Empirical)  Formula:




05.  Chemical Abstracts (CAS)  Registry Number:


06.  Approved Common Names,  Trade Names,  or Codes:
                                      140

-------
                            METABOLITE NUMBER: 019
01.  Chemical Abstracts Chemical Names:

     01 Acetamide, 2-hydroxy-N-(2-methyl-6-vinylphenyl)
        N-(2-methoxy-l-methylethyl)-
02.  Other Chemical Names:

     01 2-hydroxy-N-(2-mothy1-6-vinylphenyl)-N-
        (2^nethoxy-l-methylethyl) acetamide
03.  Structural Formula:
04.  Molecular  (Empirical) Formula:
05.  Chemical Abstracts  (CAS) Registry Number:


06.  Approved Common Names: None

07.  Other Common Names, Trade Names, or Codes:
                                       141

-------
                            METABOLITE NUMBER: 020
01.  Chemical Abstracts Chemical Names:

     01 Quinoline, N-isopropyl-8-ethyl-3-hydroxy-2-oxo-
        1,2,3,4,-tetrahydro-
02.  Other Chemical Names:

     01 8-Ethyl-3-hydroxy-N-isopropyl-2-oxo-l,2,3,4-
        tetrahydroquinoline
03.  Structural Formula:
04.  Molecular (Empirical) Formula:
05.  Chemical Abstracts (CAS)  Registry Number:


06.  Approved Cortmon Names:  None

07.  Other Common Names, Trade Names, or Codes:
                                       142

-------
                            METABOLITE NUMBER: 021
01.  Chemical Abstracts Chemical Names:

     01 Quinoline, 8-methyl-N-(2-methoxy-l-methylethyl)-2-
        oxo-1,2,3,4-tetrahydro
02.  Other Chemical Names:

     01 8-Methyl-N-(2-methoxy-l-methylethyl)-2-oxo
        1,2,3,4-tetrahydroquinoline
03.  Structural Formula:
04.  Molecular (Empirical) Formula:
05.  Chemical Abstracts (CAS) Registry Number:


06.  Approved Common Names: None

07.  Other Common Names, Trade Names, or Codes:
                                        143

-------
                           METABOLITE NUMBER:  022



01.  Chemical Abstracts Chemical Names:

     01 Aniline, N-(2-methoxy-l-methylethyl)-2-methyl-6-vinyl-



02.  Other Chemical Names:

     01 N-(2-methoxy-l-methylethyl)-(2-methyl-6-vinyl)
        aniline



03.  Structural Formula:
04.  Molecular (Empirical)  Formula:
05.  Chemical Abstracts (CAS)  Registry Number:


06.  Approved Common Names:  None

07.  Other Common Names,  Trade Names,  or Codes:
                                       144

-------
                           METABOLITE NUMBER:  023



01.  Chemical Abstracts Chemical Names:

     01 Indole, 2,3-dihydro-N-(2-methoxy-l-methylethyl)-7-methyl-



02.  Other Chemical Names:

     01 N- (2-methoxy-l-methylethyl) -7-methyl-2,3-dihydroindole
        aniline




03.  Structural Formula:
                                  -OH—OHa
04.  Molecular (Empirical) Formula:
     C13H19NO
05.  Chemical Abstracts (CAS) Registry Number:


06.  Approved Common Names: None

07.  Other Common Names, Trade Names, or Codes:
                                        145

-------
                            METABOLITE NUMBER:  024








01.  Chemical Abstracts Chemical Names:



     01 Quinoline, N-(l-hydroxyethyl)-8-methyl-2-oxo-l,2,3,4-tetrahydro-








02.  Other Chemical Names:



     01 8-Methyl-N-(1-hydroxyethyl)-2-oxo-l,2,3,4-tetrahydrcquinoline








03.  Structural Formula:
04.  Molecular (Empirical)  Formula:
05.  Chemical Abstracts (CAS)  Registry Number:






06.  Approved Common Names:  None




07.  Other Common Names,  Trade Names,  or Codes:
                                      146

-------
BIBLIOGRAPHY
  147

-------
                     GUIDE TO THE USE OF THIS BIBLIOGRAPHY


Content of_ the Bibliography

    This bibliography contains citations of all the studies reviewed by EPA in
arriving at the positions and conclusions stated elsewhere in this Standard.
The two primary sources for these studies were: (a) the body of data submitted
to EPA and its predecessor agencies in support of pest regulatory decisions on
pesticide registration, and (b) published technical literature.  The
bibliography cites and distinguishes between three types of studies:
    (1)  Studies which were found to contribute useful information to the
         Agency's review of Mstolachlor and are considered part of the data
         base which supports registrations under this Standard.  (Each of these
         studies also appears in one or more of the Disciplinary Chapter
         bibliographies.)   These studies are identified by an asterisk (*)
         placed beside their citation.
    (2)  Studies which were examined and judged to be inappropriate for use in
         developing the Standard.  These studies do not have any mark placed
         beside their citation.
    (3)  Standard reference materials.  These materials are identified by a
         small circle (o)  placed beside their citation.


Units of_ Entry

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


Form _of the Entry

    The entries in the bibliography are sorted by author, date of the
document, and title.  Each entry consists of a bibliographic citation
containing standard elements.  In the case of materials submitted to EPA, these
elements are followed by a description of the earliest known submission.  The
bibliographic conventions used reflect the standards of the American National
Standards Institute (ANSI), explanded to provide for special needs.  Some
explanatory notes of specific elements follow:

    (a)  Author.    Whenever we could confidently identify one, we have chosen
         to show a personal author.   When no individual was identified, we have
         shown an identifiable laboratory or testing facility as author.  As a
         last resort, we have shown the first known submitter as author.
    (b)  Document Date.  When the date appears as four digits with no
         question marks, we took it directly from the document.  When a four
         digit date is followed by a question mark, the bibliographer deduced
         the date from evidence in the document.  When the date appears (19??),
         we were unable to determine or estimate the date of the document.

                                       149

-------
(c)   Title.   This  is  the  third  element  in  the  citation.   In some cases it
     has  been necessary for our bibliographers to  create  or enhance a
     document title.   Pny such  editorial  insertions  are contained between
     square brackets.
(d)   Trailing Parentheses.  Ebr studies submitted  to us in  the past, the
     trailing parentheses  include  (in addition to  any self-explanatory
     text) the following  elements  describing the earliest known submission:
          (1)   Submission  Date.  Immediately following the  word
               'received1  appears  the date of  the  earliest  known
               submission.
          (2)   Administrative Number.  The next element,  immediately
               following the word  'under', is  the  registration number,
               experimental permit number, petition  number, or other
               administrative number associated with the  earliest known
               submission.
          (3)   Preparer and/or  Submitter.  Fbllowing the  phrase 'prepared
               by' is  the name  of  the facility which conducted the study or
               reported its results, and following the phrase  'prepared
               for1 is the name of the submitter who submitted the data to
               support some application or petition.
          (4)   Volume  Identification.  The final element  in the trailing
               parentheses identifies the EPA  accession number of the
               volime  in which  the original submission of the  study
               appears.  The six-digit accession number follows the symbol
               'CDL', which stands for "Company Data Library."   This
               accession number is in turn followed  by an alphabetic suffix
               which  shows the  relative posiution  of the  study within the
               volume.  Fbr example, within accession number 123456, the
               first  study \vould be 123456-A;  the  second, 123456-B; the
               26th,  123456-Z;  and the 27th, 123456-AA.
                                150

-------
*  Affiliated Medical Research, Incorporated  (1974a) Acute Dermal LDsn of CGA-
      24705 - Technical in Rabbits:  Contract No. 120-2255-34.  (Unpublished study
      received Sep 26, 1974 under 5G1553; prepared for Ciba-Geigy Corp.,
      Greensboro, N.C.; CDL:112840-E)

   Affiliated Medical Research, Incorporated  (1974b) Acute Dermal LDsn of CGA-
      24705-6E:  Contract No. 12-2255-34.  Unpublished study received Sep 26,
      1974 under 5G1553; prepared for Ciba-Geigy Corp., Greensboro, N.C.;
      CDL:112840-F)

   Affiliated Medical Research, Incorporated  (1974c) Acute Inhalation Study of CGA-
      24705-6E for Albino Rats:  Contract No. 121-2253-34.  Unpublished study
      received Sep 26, 1974 under 5G1553; prepared for Ciba-Geigy Corp.,
      Greensboro, N.C.; CDL:112840-M)

   Affiliated Medical Research, Incorporated  (1974d) Acute Oral Toxicity in Rats
      of CGA-24705-6E:  Contract tto. 121-2255-34.  (Unpublished study received
      Sep 26, 1974 under 5G1553; prepared for Ciba-Geigy Corp., Greensboro, N.C.;
      CDL:112840-B)

*  Affiliated Medical Research, Incorporated  (1974e) Emetic Dose 50 in Beagle Dogs
      with CGA-24705-Technical: Contract No. 120-2255-34.  (Unpublished study
      received Sep 26, 1974 under 5G1553; prepared for Ciba-Geigy Corp.,
      Greensboro, N.C.; CDL:112840-C)

*  Affiliated Medical Research, Incorporated  (1974f) Emetic Dose 50 in Beagle Dogs
      with CGA-24705-6E: Contract No. 121-2255-34.(Unpublished study received
      Sep 26, 1974 under 5G1553; prepared for Ciba-Geigy Corp., Greensboro, N.C.;
      CDL:112840-D)

*  Affiliated Medical Research, Incorporated  (1974g) Evaluation of CGA-24705
      Technical  (FL740408) as a Potential Skin Sensitizer in the Guinea Pig:
      Contract No. 120-2255-34. (Unpublished study received Sep 26, 1977 under
      5G1553; prepared for Ciba-Geigy Corp., Greensboro, N.C.; CDL:112840-K)

   Affiliated Medical Research, Incorporated  (1974h) Primary Dermal Irritation of
      CGA-24705-6E in Albino Rabbits:  Contract No. 121-2255-34. (Unpublished
      study received Sep 26, 1974 under 5G1553; prepared for Ciba-Geigy Corp.,
      Greensboro, N.C.; CDL:112840-J)

   Affiliated Medical Research, Incorporated  (19741) Primary Eye Irritation of CGA-
      24705-6E in Albino Rabbits:  Contract No. 121-2255-34.  (Unpublished study
      received Sep 26, 1974 under 5G1553; prepared for Ciba-Geigy Corp.,
      Greensboro, N.C.; CDL:112840-H)

   Affiliated Medical Research , Incorporated (1974J) Twenty-One Day Repeated
      Dermal Toxicity of CGA-24705-6E in Rabbits:  Contract No. 120-2255-34.
      (Unpublished study received Sep 26, 1974 under 5G1553; prepared  for Ciba-
      Geigy Corp., Greensboro, N.C.; CDL:112840-Q)
                                       151

-------
   Ahrens, J.F.; Cubanski, M. (1977) Herbicides for hemlock seedbeds.  Pages  315-
      319,  In  Proceedings of the Thirty-First Annual Meeting of  the Northeastern
      Weed Science Society; Jan 4-6, 1977, Baltimore, Maryland.    Salisbury, Md.:
      [University of Maryland?].

   American Institute of Biological Sciences, Aquatic Hazards of Pesticides Task
      Group (1978) Criteria and Rationale for Decision Making in Aquatic Hazard
      Evaluation: Report to the Environmental Protection Agency.   Washington,
      D.C.: U.S. E.P.A. (EPA Contract No. 68-01-2457)

o  American National Standards Institute (1976).  Common name for  the pest control
      chemical 2-chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy-l-methylethyl)
      acetamide "metolachlor."   In American National Standard: ANSI K62,198-1976.
      New York: ANSI.

   Anon.   (1976) 2-Chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy-l-methylethyl)
     Acetamide: Tolerances for Residues. Federal Register 41(226):51400.

*  Ami,  P.; Miller, D. (1976) Salmonella/Mammalian-Microsonie Mutagenicity Test
      with CGA 24705 (Test for Mutagenic Properties in Bacteria):  PH 2.632.
      (Unpublished study received Jan 19, 1977 under 7F1913; prepared by Ciba-
      Geigy, Ltd., Basle,  Switzerland; CDL:95768-B)

   Ashley, R.A. (1976) Varietal response of sweet corn to Procyazine and CGA-
      24705.  Pages 193-196, _In Proceedings of the Thirtieth Annual Meeting of
      the Northeastern Weed Science Society; Jan 6-8, 1976, Boston, Massachusetts
      Salisbury, Md: University of Maryland, Vegetable Research Farm.

*  Aziz,  S.A.  (1974) Photolysis of CGA-24705 on Soil Slides under  Natural and
      Artificial Sunlight Conditions:  GAAC-74102.  (Unpublished study received
      Mar 26, 1975 under 5F1606 prepared by Ciba-Geigy Corp., Greensboro, N.C.;
      CDL:94385-J)

*  Aziz,  S.A.? Kahrs, R.A. (1974) Photolysis of CGA-24705 in Aqueous Solution
      under Natural and Artificial Sunlight Conditions: GAAC-74041.(Unpublished
      study received Sep 26, 1974 under 5G1553; prepared by Ciba-Geigy Corp.,
      Greensboro, N.C.; CDL:94222-A)

*  Aziz,  S.A.; Kahrs, R.A. (1975) Photolysis of CGA-24705 in Aqueous Solution —
      Additional Information:  GAAC-75021.  (Unpublished study received Mar 26,
      1975 under 5F1606; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
      CDL.-94385-M)

*  Aziz,  S.A; Ross, J.A. (1975) Analytical Method for the Determination of
      Residues of CGA-24705 Soybean Metabolites as  CGA-37913 and CGA-49751 by Acid
      Hydrolysis.  Method AG-286 dated Jun 10, 1975.  (Unpublished study received
      Nov 6, 1975 under 4G1469; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
      CDL:95190-E)

   Aziz,  S.A.; Ross, J.A.  (1976)  Specificity of Analytical Method  AG-286 for  the
      Determination of Residues of Metolachlor and Its Metabolites in Soybeans:
      ABR-76083.  (Unpublished study received Jan 19, 1977 under 7F1913; prepared
      by  Ciba-Geigy Corp., Greensboro, N.C.; CDL:95748-AC)
                                       152

-------
Bailey, G.W.; Leonard, R.A.;  Livank,  R.R., Jr.  (1976)  Land Application of Waste
   Materials: Transport,  Detoxification,  Fate,  and  Effects of  Pesticides  in
   Soil and Water Environment. Ankeny,  Iowa:  Soil Conservation Society of
   America,   (p.48-78)

Balasubramanian, K.; Aziz,  S.A.;  Ross,  J.A.  (1975)  Analytical  Method  for  the
   Determination of Residues  of CGA-24705 Corn  Metabolites as  CGA-37913 and CGA-
   49751 by Acid Hydrolysis.  Method  AG-277 dated Jan  9,  1975.   (Unpublished
   study received Nov 6,1975  under  4G1469; prepared by Ciba-Geigy Corp.,
   Ardsley, N.Y.; CDL:95190-D)

Balasubramanian, K.; Gold,  B.; Ross,  J.A.  (1973?) Gas  Chromatographic
   Determination of Residues  of CGA-24705 Metabolites  in  Corn  as CGA-37913.
   Method AG-265 undated.   (Unpublished study received Mar 26,  1975 under
   5F1606; prepared by Ciba-Geigy Corp., Ardsley, N.Y.; CDL:94380-P)

Balasubramanian, K.; Gold,  B.; Ross,  J.A.  (1974) Validation  of Method AG-265
   for the Determination  of CGA-24705 Metabolites Which are  Converted to  the
   CGA-37913  Moiety:  GACC-74043.   (Unpublished study  received Sep 26, 1974
   under 5G1553; prepared by  Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:94216-I)

Ballantine, L.G. (1975) CGA-24705:  Environmental Impact Statement:  GAAC-75011.
   (Unpublished study that  includes studies AG-A 2929  I-IV 1st Rept., Ag-A  2929
   I-IV 2nd Rept., AG-A 2969  I-III  1st  Rept., AG-A  2969 I-IV 2nd Rept., AG-A
   2973, AG-A 3105, AG-A  3133 1st Rept., Ag-A 3133  2nd Rept.,  AG-A 3150 I-II,
   AG-A 3244  II, AG-A 3282  I  (2nd)-II,  AG-A  3554; received Mar 26, 1975 under
   5F1606; prepared by Ciba-Geigy Corp., Greensboro, N.C. CDL:94385-A, 94376)

Ballantine, L.G. (1976a)  Metolachlor  plus Atrazine  Tank Mix  Soil Dissipation:
   ABR-76076.   (Unpublished study that  includes the reports  AG-A 3493 I-IV, and
   AG-A 3573  I-II; received Feb 18, 1977 under  100-583; prepared by Ciba Geigy
   Corp.; CDL:228125-A

Ballantine, L.G. (1976b)  Metolachlor  plus Linuron Tank Mix Soil Dissipation:
   ABR-76079.   (Unpublished study that  includes AG-A 3706 I-V,  AG-A 3719  I-IV,
   and AG-A 4139 I, II; received  Jan  19,  1977 under 100-583; prepared by  Ciba-
   Geigy Corp., Greensboro, N.C.; CDL:95763-D)

Ballantine, L.G. (1976c)  Metolachlor  plus Metribuzin Tank Mix  Soil
   Dissipation: ABR-76092.  (Unpublished study  that includes studies  AG-A 3807
   I-V, AG-A  3722 I-IV, and AG-A  4140;  prepared by  Ciba-Geigy  Corp. and studies
   no. 50842  and 50843 received Jan 19, 1977  under  100-583;  prepared  by
   Chemagro Agricultural  Division,  Mobay Chemical Corp.  [Kansas City, MO.]  for
   Ciba-Geigy Corp., Greensboro,  N.C.;  CDL:95763-A]

Ballantine, L.G. (1978) Metolachlor:  Update  of Environmental  Impact  Statement.
   ABR-78011.  Unpublished  study  that includes  studies AG-A  2929  I-IV 1st
   Rept., AG-A 2969 I-III 1st Rept.,  AG-A 3133  1st  Rept., AG-A 3706  I-V,  AG-A
   3707 I-V,  AG-A 3722 I-IV,  AG-A 4140; received Feb  6,  1978 under 100-583;
   prepared by Ciba-Geigy Corp.,  Greensboro,  N.C.   CDL:232789-A,  232789-N,
   232789-0,  232789-P, 232789-Q,  232789-R, 232789-S,  232789-T)
                                    153

-------
Ballantine, LoG.; Herman, M.M. (1977a) Metalochlor Plus Atrazine Plus  Paraquat
   Tank Mix Soil Dissipation:  ABR-77068.   (Unpublished study containing
   studies Ortho T-4QS8, Ortho T-4089, AG-A 4084 I-IV, AG-A 4085 I-IV;  received
   Nov 8, 1977 under 100-EUP-59; CDL:232193-G, 232193-J, 232193-K,  232193-L,
   232193-M)

Ballantine, L.G.; Herman, M.M. (1977b) Metolachlor Plus Dicamba Tank Mix Soil
   Dissipation Studies:  ABR-77067.  (Unpublished study including studies AG~A
   4141 I-III, AG-A 4156 I-IV, Craven Lab 76-1-D; CDL:232193-A, 232193-D,
   232193-E, 232193-F)  received Nov 8, 1977 under 100-EUP-59 prepared by Ciba-
   Geigy Corp,, Greensboro, N.C.;
                                         14
Barrows. M.E. (1974) Exposure of fisjj to   C-CGA-24705.  Accumulation
   Distribution, and Elimination of  C Residues.  Report No.:73019-3.
   (Unpublished study received Mar 27, 1975 under 5F1606; prepared  by
   Bionomics E G & G Environmental Consultants for Ciba-Geigy Corp.,
   Greensboro, N«Co; CDL:94376-E)

Bathe, R. (1973) Acute Oral LD,-0 of Technical CGA-24705 in the Rat:  Project
   No. Siss 2979.  (Unpublished study received Sep 26, 1974 under 5G1553;
   prepared by Ciba-Geigy Corp., Ltd., Basle,  Switzerland; CDL:112840-A)

Bayer, G.H. (1977) Herbicide combinations for soy, snap, and kidney beans in
   Hew York. Pages 34-38,  _In Proceedings of the Thirty-First Annual Meeting of
   the Northeastern Weed Science Society; Jan 4-6, 1977, Baltimore, Maryland.
   Salisbury Md; [University of Maryland.]

Bing, Ac (1977) 1976 pre-emergence weed control in nursery liners.  Pages 320-
   325,  In  Proceedings of the Thirty-First Annual Meeting of the  Northeastern
   Weed Science Society; Jan 4-6, 1977, Baltimore, Maryland.   Salisbury, Md.
   [University of Maryland?]
                                                 14
Biometric Testing Incorporated (1973) Metabolism   C-CGA-24705 Corn
   Biosynthesized Metabolites in a Lactating Goat:  A-1004.  (Unpublished
   study received Sep 26, 1974 under 5G1553; prepared for Ciba-Geigy Corp.,
   Greensboro, NoC,; CDL;94217-J)

Bleidner, W.E.? Baker, H.M.; Levitsky, M.;  Lowen, W.K. (1954) Determination of
   3-(p-chlorophenyl)-l, 1-dimethylurea in soils and plant tissues. Journal of
   Agricultural and Food Chemistry 2(9): 476-479. (Also In unpublished  study
   received Sep 26, 1974 under 5G1553; prepared by Ciba-Geigy Corp.,
   Greensboro, N.C.s CDL;94221-A)

Bonn, J.A.? Price, J*H,; Rieck, C.E. (1976).  Comparison of the herbicidal
   activity of chloro-acetamides.  Pages 30-  , Page 150,  _In Proceedings of
   the North Central Weed Control Conference;  December 9-11, 1975,  Milwaukee,
   Wisconsin,  Gnaha, Neb.; by Stauffer Chemical Company for the North  Central
   Weed Control Conference:

Brashears, A.D.; Abernathy, J.R.; Schrib, J.V. (1976) An evaluation of  yellow
   nutsedge control techniques in West Texas cotton: Abstract. In   Proceedings
   of the 29th. Annual Meeting of the Southern Weed Science Society; Jan 27-29,
   1976, Dalles,, 'Itexas<   Raleigh, N.C.: Glover Printing for the Southern Weed
   Science Society
                                   154

-------
Buccafusco, Robert J.  (1978a) Acute Toxicity Test Results of CGA-24705 to
   Bluegill Sunfish  (Lepomis macrochirus): Report #BW-78-6-181.
   (Unpublished study  received Jul 13, 1978 under 100.597; prepared by E G  &
   G,Bionomics, Submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:234396)

Buccafusco, Robert J.  (1978b) Acute Toxicity Test Results of CGA-24705 to
   Rainbow Trout  (Salmo gairdneri): Report #BW-78-6-186.  (Unpublished
   study received Jul  13,1978 under 100-597; prepared by E.G. & G., Bionomics,
   submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:234396)

Buckhard, N. (1974) CGA-24705: Hydrolysis of CGA Under Laboratory Conditions?
   AC 2.5.53; SPR 2/74. (Unpublished study received Sep 26, 1974 under 5G1553;
   prepared by Ciba-Geigy Ltd,, Basle, Switzerland; CDL:94222-H)

Cannizzaro, R.D.: Hofberg, A. (1972) Analysis of Water in Soils and Column
   Adsorbants Using  the Aquatest  II Electronic Karl-Fischer Titration System,
   Method AG-192  dated Mar 9, 1972.   (Unpublished study received Sep 26, 1974
   under 5G1553;  prepared by Ciba-Geigy Corp., Ardsley, N.Y.; CDL:94216-K)

Centre de Recherche et d'Elevage  des Oncins (1974) Toxicite De 3 Mois chez  le
   Rat par Voie Orale  du Produit  CGA 24 705.  [Three-Month Dietary Feeding Study
   in Rats: CGA 24 705]: IC-DREB-R 741009. (Unpublished study received Mar  26,
   1975 under 5F1606;  prepared for Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:94377-C)

Chalmers, A.H. (1974)  Studies on  the mechanism of formation of 5-mercapto-l-
   methyl-4-nitroimidazole, a metabolite of the immunosuppressive drug
   Azathioprine.  Biochemical Pharmacology 23:  1891-1901. (Also In  unpublis
   report received Mar 27, 1975 under 5F1606; prepared by Ciba-Geigy Corpc,,
   Greensboro, N.C.; CDL:94382-A)

Ciba-Geigy Corporation (1974) Section A, CGA-24705: Name, Chemical Identity and
   Composition of CGA-24705. (Unpublished study? received Sep 26, 1974 under
   100-EUP-44; CDL:96505:A)

Ciba-Geigy Corporation (1975a) CGA-24705 Efficacy and Crop Safety Summary;  1973-
   1974. (Unpublished  study that  includes efficacy and crop safety reports  1-51
   and rotational bioassay reports 52-71; received Mar 27, 1975 under 5F1606;
   CDL; 94383-A,  94384)
                                                        TM
Ciba-Geigy Corporation (1975b) Biological Summary: Dual    6EC Applied Alone.
   (Unpublished study  that includes reports 1-99; received Nov 25, 1975
   under 100-EUP-43; CDL:94832-A; 94831)


Ciba-Geigy Corporation (1975c) Biological Summary: Dual 6EC + Lorox Tank Mix.
   (Unpublished study  that includes reports 1-21; received Nov 25, 1975 under
   100-EUP-43; CDL:94832-B; 94829)

Ciba-Geigy Corporation (1975d) Biological Summary: Dual 6EC + Sencor  50% W.P.
   or Lexone Tank Mix. (Unpublished study that includes reports 1-49; received
   Nov 25, 1975 under  100-EUP-43; CDL:94832-C; 94830)
                                    155

-------
   Ciba-Geigy Corporation (1975e)  Efficacy and Crop Safety Summary GA-2-686 15G
      Herbicide  for Corn. (Unpublished study including summary tables and
      efficacy tests 1-6, 8-14L;  received Feb 9, 1976 under 100-EUP-44;
      CDL:96496-B)

   Ciba-Geigy Corporation (1975f)  Name, Chemical Identity and Composition of CGA-
      24705,  (Unpublished study received Nov 25, 1975 under 100-EUP-43;
      CDL:94879-A)
                                                 TM             1M
   Ciba-Geigy Corporation (1975g)  Results of Dual   6E and Cycle   SOW
      Experimental  Permits.  (Unpublished study; received Dec 29, 1975 under 100-
      EUP 36; CDL:95053-A)

*  Ciba-Geigy Corporation (1975?h)  Section A, CGA-24705: Name, Chemical Identity
      and composition of  CGA-24705. (Unpublished study; received Nov 25, 1975
      under 6G1708;  CDL:96439-A)

*  Ciba-Geigy Corporation (1976a)  CGA-24705: Name, Chemical Identity and
      Composition of CGA-24705. (Unpublished study received Nov 23, 1976 under 100-
      587;  prepared by Ciba-Geigy Corp., Greensboro, N.C.: CDL:226955-A)
                                                                 »
   Ciba-Geigy Corporation (1976b)  Aerial Application. (Unpublished study that
      includes reports Dual/PPI,  Dual/PRE, Dual & Lorox, III.l - III.10; received
      Jan 19, 1977  under  100-583;  CDL:95738-E;  95757)
                                      / o \          / -p \
   Ciba-Geigy Corporation (1976c)  Dual    + Sencor    Pre-emergence.
      (Unpublished  study  that includes reports I.I - 1.78 with a summary,  II.1 -
      11.62 with a  summary and III.l - III.33 with a summary, and received Jan 19,
      1977 under 100-583; CDL:95738-C:95744; 95765;  95756; 95769; 95741)
                                      / -p \            I TD \
   Ciba-Geigy Corporation (1976d)  Dual    6E + Lorox    Pre-emergence.
      (Unpublished  study  that includes reports I.I - 11.27 with a summary, and
      III.l - III.28 with a summary; received Jan 19, 1977 under 100-583;
      CDL:95738-D;  95740; 95760;  95759;  95758)

   Ciba-Geigy Corporation (1976e)  Dual^R)  6E Preemergence. (Unpublished study
      that includes reports  I.I -  1.139 with a summary, II.1-II.94 with a summary,
      and III.l  - III.33  with a summary; received Jan 19, 1977 under 100-583;
      CDL;95738-B;  95742; 95766;  95743;  95752;  95751; 95762;  95761)

   Ciba-Geigy Corporation (1976f)  Dual(R'  6E Preplant Incorporated. (Unpublished
      study that includes reports  I.I - 1.40 with a summary,  II.1-II.21 with a
      summary and 111.1-111,19 with a summary;  received Jan 19, 1977 under
      100-583; CDL:95738-A;  95755;  95754;  95753)

   Ciba-Geigy Corporation (1976g)  Compatibility of Dual^R) 6E with Fertilizers
      and Other  Herbicides.  (Unpublished study received Jan 19, 1977 under 100-
      583;  CDL:95738-H)

   Ciba-Geigy Corporation (1976h)  Liquid Fertilizer. (Unpublished study that
      includes reports Dual/PPI,  I.I - 1.8, III.1-III.5; Dual/PRE, I.I -1.4,
      III.l - III.5: received Jan  19, 1977 under 100-583; CDL:95738-F; 95746)
                                      156

-------
   Ciba-Geigy Corporation  (19761)  Rotational  Crops.  (Unpublished  study that
      includes reports  Dual/PRE,  I.  -  1.48 with  a summary;  DUAL/PPI,  I.I  - I.11
      with a summary; Dual  + Sencor/PRE,  I.1-1.9 with  a  summary;  Dual + Lorox/PRE,
      I.I - 1.5 with a  summary; received  Jan  19, 1977  under 100-583;  CDL:95738-G;
      95745; 95739)

*  Ciba-Geigy Corporation  (1977a)  Aerial  Application.   (Unpublished study that
      includes reports  ID-9D with a  summary?  received  Feb 18,  1977 under  100-
      583; CDL:228101-F;228122)

*  Ciba-Geigy Corporation  (1977b)  Aerial  Application.   (Unpublished study
      containing reports ID - 10D with a  summary;  received  Jun 20, 1977;
      CDL:230672-D, 230683)

   Ciba-Geigy Corporation  (1977c)  Aerial  Application.   (Unpublished study
      received Nov  8, 1977  under  100-EUP-59;  CDL:232194-G)

   Ciba-Geigy Corporation  (1977d)  Application in Liquid  Fertilizers.   (Unpublished
      study that includes reports 1-18 with a summary; received Feb 18, 1977 under
      100-583; CDL:228101-E; 228121)

   Ciba-Geigy Corporation  (1977e)  Application in Liquid  Fertilizers.   (Unpublished
      study containing  reports 1-9 with a summary,  ID  -  4D  with a summary;
      received Jun  20,  1977 under 100-590; CDL:230672-C, 230682)

   Ciba-Geigy Corporation  (1977f)  Application in Fertilizers.  (Unpublished  study
      received Nov  8, 1977  under  100-EUP-59;  CDL:232194-F)

   Ciba-Geigy Corporation  (1977g)  Application in Fertilizers.  (Unpublished  study
      received Nov  14,  1977 under 100-EUP-61;  CDL:96624-C)

   Ciba-Geigy Corporation  (1977h)  Application-to-Planting interval.   (Unpublished
      study received Nov 1,  1977  under 100-583;  CDL:232134-BB)

   Ciba-Geigy Corporation  (19771)  Ciba-Geigy  Rating System.  (Unpublished study
      received Nov  1, 1977  under  100-583; CDL:232134-C)
                                       ( R}            (Rl
   Ciba-Geigy Corporation  (1977J)  Dual   6E  + AAtrexv  —Preemergence.
      (Unpublished  study that includes reports 1-35 with a  summary and 1C-32C with
      a summary; received Feb 18,  1977 under  100-583;  CDL:228101-C;  228114?  228115)

   Ciba-Geigy Corporation  (1977k)  Dual(R) 6E  + AAtrex(R) —Preplant
      Incorporated.   (Unpublished study that  includes  reports 1-96 with a summary,
      1C-32C with a summary, and  1D-10D with  summary;  received Feb 18, 1977 under
      100-583; CDL:228101-D;  228116;  228117;  228118; 228119; 228120)

   Ciba-Geigy Corporation  (19771)  Dual 6E Alone  —Preemergence.  (Unpublished
      study that includes reports 1-139 with  a summary,  1C-70C with  a summary,  and
      1D-12D with summary;  received  Feb 18,  1977 under 100-583; CDL;228101-A:
      228102; 228103; 228104;  228105;  228106;  228107;  228108)
                                         157

-------
Ciba-Geigy Corporation (1977m) Dual^ ^  6E Alone — Preplant Incorporated.
   (Unpublished study that includes reports 1-82 with a summary, 1C-52C with  a
   summary, and 1D-11D with summary; received Feb 18, 1977 under 100-583;
   CDL:228101-B; 228109;  228110; 228118; 228111; 228112; 228113)
                                    ( R}             ( R}
Ciba-Geigy Corporation (1977n) Dual    8E + AAtrex^    4- Paraquat or
   Roundup.  (Unpublished study containing reports 1-22 with a summary, 1C-27C
   with a summary;  received Nov 8, 1977 under 100-EUP-59; CDL:232194-D, 232200,
   232201)

Ciba-Geigy Corporation (1977o) Dual(R)  8E -t- AAtrex(R) Early Post.
   (Unpublished study containing reports 1-47 with a summary, 1C-15C with a
   summary; received Nov 8, 1977 under 100-EUP-59; CDL:232194-E, 232202, 232203)
                                    (R)
Ciba-Geigy Corporation (1977p) Dual    8E Alone.  (Unpublished study
   including reports 1-43 with a summary; received Nov 8, 1977 under 100-EUP-
   59; CDL:232194-A, 232195)
                                    (R)
Ciba-Geigy Corporation (1977q) Dualv '8E Alone.  (Unpublished study that
   includes reports 1-32 with a summary; received Nov 14, 1977 under 100-EUP-
   61; CDL:96624-A; 96618)
                                    (R ]
Ciba-Geigy Corporation (1977r) Dual   /Atrazine Prepack: Chemistry Data
   Section.  (Unpublished study; received June 20, 1977 under 100-590;
   CDL:230686-A)

Ciba-Geigy Corporation (1977s) Dual    8E + Banvel(   .  (Unpublished study
   containing reports 1-21, with a summary, 1C-9C with a summary; received
   Nov 8, 1977 under 100-EUP-59; CDL:232194-C, 232198, 232199)

Ciba-Geigy Corporation (1977t) Dual(R)  8E + Bladex^R).  (Unpublished study
   containing reports 1-37 with a summary, 1C-10C; received Nov 8, 1977 under
   100-EUP-59; CDL:232194-B, 232196, 232197)

Ciba-Geigy Corporation (1977u) Dual + Lorox PRE. (Unpublished study received
   Nov 1, 1977 under 100-583; CDL:232134-P)

Ciba-Geigy Corporation (1977v) Dual + Lorox — Soybeans Preemergence:  Phyto
   Summary or 1/13/77 Submission.   (Unpublished study received Nov 1, 1977
   under 100-583; CDL:232134-Q)

Ciba-Geigy Corporation (1977w) Dual + Lorox — Soybeans Preemergence: Phyto
   Summary of 1/13/77 Submission.   (Unpublished study; received Nov 1, 1977
   under 100-583; CDL:232134-R)

Ciba-Geigy Corporation (1977x) Dual + Lorox PRE Yield Data.   (Unpublished
   study; received Nov 1, 1977 under 100-583; CDL:232134-T)

Ciba-Geigy Corporation (1977y) Dual Preemergence.  (Unpublished study; received
   Nov 1, 1977 under 100-583; CDL:232134-D)
                                    158

-------
Ciba-Geigy Corporation  (1977z) Dual(R) PRE Yields.   (Unpublished study;
   received Nov 1, 1977 under 100-583; CDL:232134-G)

Ciba-Geigy Corporation  (1977aa) Dual PRE Yield Data  (1977).   (Unpublished
   study; received Nov  1, 1977 under 100-583; CDL:232134-H)

Ciba-Geigy Corporation  (1977ab) Dual(R) PRE Yield Questions.   (Unpublished
   study; received Nov  1, 1977 under 100-583; CDL:232134-I)

Ciba-Geigy Corporation  (1977ac) Dual(R) + Lorox(R) Yields.   (Unpublished
   study; received Nov  1, 1977 under 100-583; CDL:232134-S)

Ciba-Geigy Corporation  (1977ad) Dual + Lorox Yields.   (Unpublished study;
   received Nov 1, 1977 under 100-583; CDL:232134-U)

Ciba-Geigy Corporation  (1977ae) Dual Preplant Incoroporated .   (Unpublished
   study; received Nov  1, 1977 under 100-583; CDL:232134-J)

Ciba-Geigy Corporation  (1977af) Dual(R)PPl Yields.   (Unpublished study;
   received Nov 1, 1977 under 100-583; CDL:232134-M)

Ciba-Geigy Corporation  (1977ag) Dual PPI Yield Data.   (Unpublished study;
   received Nov 1, 1977 under 100-583; CDL:232134-N)

Ciba-Geigy Corporation  (1977ah) Dual^R' PPI Yield Questions.   (Unpublished
   study; received Nov  1,1977 under 100-583; CDL:232134-O)

Ciba-Geigy Corporation  (1977ai) Dual + Sencor PRE.   (Unpublished study;
   received Nov 1, 1977 under 100-583; CDL:232134-V)

Ciba-Geigy Corporation  (1977aj) Dual + Sencor/Lexone —  Soybeans Preemergence :
   Phyto Summary of 1/13/77 Submission.  (Unpublished  study;  received Nov 1,
   1977 under 100-583; CDL:232134-W)

Ciba-Geigy Corporation  (1977ak) Dual + Sencor/Lexone —  Soybeans Preemergence:
   Phyto Summary of 1/13/77 Submission.  (Unpublished  study;  received Nov 1,
   1977 under 100-583; CDL:232134-X)

Ciba-Geigy Corporation  (1977al) Dual + Sencor PRE Yield  Data.  (Unpublished
   study; received Nov  1, 1977 under 100-583; CDL:232134-Z)
                                                 ( R)
Ciba-Geigy Corporation  (1977am)  Dual^    + Sencor  Yields.   (Unpublished
   study; received Nov  1, 1977 under 100-583;  CDL:232134-Y)
                                     / T5 \          f ~D\
Ciba-Geigy Corporation  (1977an)  Dual^    + Sencorv  'Yields.   (Unpublished
   study; received Nov  1, 1977 under 100-583;  CDL:232134-AA)

Ciba-Geigy Corporation  (1977ao)  Dual - Soybeans  Preemergence  Phyto and Yield
   review of 1/13/77 Submission.   (Unpublished study;  received Nov 1, 1977
   under 100-583; CDL:232134-E)
                                      159

-------
Ciba-Geigy Corporation (1977ap)  Dual - Soybeans Preemergence Phyto and Summary
   of 1/13/77 Submission.  (Unpublished study; received Nov 1, 1977 under 100-
   583; CDL:232134-F)

Ciba-Geigy Corporation (1977aq)  Dual — Soybeans Preplant Incorporated: Phyto
   Summary of 1/13/77 Submission.   (Unpublished study; received Nov 1, 1977
   under 100-583; CDL:232134-K)

Ciba-Geigy Corporation (1977ar)  Dual — Soybeans Preplant Incorporated: Phyto
   Summary of 1/13/77.  (Unpublished study; received Nov 1, 1977 under 100-
   583; CDL:232134-L)

Ciba-Geigy Corporation (1977as)  Foxtail Millet.  (Unpublished study that
   includes 3, 7, 8, 19, 35,  and 52 with a summary; received Nov 1, 1977 under
   100-583; CDL:232134-A)

Ciba-Geigy Corporation (1977at)  M+A 4.5L - Preemergence.  (Unpublished study
   containing reports 1-71 with a summary, 1C-12C with a summary, and ID -16D
   with a summary; received Jun 20, 1977 under 100-590; CDL:230672-A, 230673,
   230674, 230675, 230676).

Ciba-Geigy Corporation (1977au)  M+A 4.5L - Preplant Incorporated.  (Unpublished
   study containing reports 1-50 with a summary, 1C-9C with a summary, and 1D-
   12D with a summary; received Jun 20, 1977 under 100-590; CDL:230672-B,
   230678, 230679, 230680, 230681)

Ciba-Geigy Corporation (1977av)  Response to EPA Comments,Concerning Marginal
   Soybean tolerance to Dual^   PPI or PRE, Dual + Dorox^    or Dual +
   Sencor     Application.  (Unpublished study; received Nov 1, 1977 under
   100-583; CDL:232134-B)

Ciba-Geigy Corporation (1977aw)  Rotational Crops.  (Unpublished study
   containing reports 1-13 with a summary; received Jun 20, 1977 under 100-590;
   CDL:230672-E 230684)

Ciba-Geigy Corporation (1977ax)  Rotational Crops.  (Unpublished study including
   reports Vol. 2 - Report 40 and Vol. 9 - Report 46; received Nov 8, 1977
   under 100-EUP-59; CDL:232194-H, 232195, 232202)

Ciba-Geigy Corporation (1977ay)  Tank Mixtures.  (Unpublished study; received
   Nov 14, 1977 under 100-EUP-61; CDL:96624-B)

Ciba-Geigy Corporation (1977az). Rotational Crops.   (Unpublished study that
   includes reports 1-49 with a summary, 1-39 with a summary; received Feb 18,
   1977 under 100-583; CDL:228101-G; 228123; 228124)

Ciba-Geigy Corporation (1977ba)  Section A General Chemistry.  (Unpublished
   study; received Jan 19, 1977 under 7F1913; CDL:95764-A)

Ciba-Geigy Limited  (1973?) CGA 24 705 Feeding Study in Milk Cows: Methods.
   (Unpublished study; received Sep 26, 1974 under 5G1553; CDL:94216-G)
                                      160

-------
Ciba-Geigy Limited  (1973?) CGA  24  705  Feeding  Study  in  Milk  Cows:  Methods.
   (Unpublished study prepared  by  Ciba-Geigy Ltd.; St.  Aubin, Switzerland;
   received Nov 14,  1977 under  8G2019;  CDL:96626-C)

Ciba-Geigy Limited  (1974) CGA 24705: Hydrolysis of CGA-24705 under Laboratory
   Conditions. AC 2.53/NB/cr; SPR  2/74.   (Unpublished study; received  Mar  27,
   1975 under 5F1606; CDL:94376-J)

Ciba-Geigy Limited  (1976a) Dominant  Lethal  Study  on  CGA 24705 Technical: Mouse
   (Test for Cytotoxic or Mutagenic  Effects on Male  Germinal Cells)  PH 2.632.
   (Unpublished study including Addendum; received Jan  18, 1978 under  7F1913;
   CDL:96717^2; 96717-D)

Ciba-Geigy Limited  (1976b) Reproduction Study  CGA 24705 Tech.: Rat:  Seg. II
   (Test for Teratogenic or  Embryotoxic Effects)  PH  2.632.   (Unpublished study
   including Addendum; received Jan  18,  1978 under 7F1913; CDL: 96717-A; 96717-
   B)

Ciba-Geigy Limited  (1977) Skin  Sensitizing  (Contact  Allergenic) Effect in
   Guinea Pigs of Technical  CGA 24705:  Siss 5726.   (Unpublished study; received
   Jan 18, 1978 under 7F1913; CDL:96717-E)

Coquet, B.; Galland  L.; Guyot,  D.; Fouillet, X.;  Rouaud, J.L.  (1974a)  Essai  de
   Toxicite de 3 Mois chez Le Chien  par Voie Orale du Produit CGA 24 705.
   [Three-Month Oral Toxicity Trial  of  CGA  24  705 in Dog]: IC-DREB-R-740119.
   (Unpublished study received  Sep 26,  1974 under 5G1553; prepared by  the
   Oncins Research and Breeding Center  for  Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:94223-B)

Coquet, B.; Galland  L.; Guyot,  D.; Fouillet, X.;  Rouaud, J.L.  (1974b)  Essai  de
   Toxicite de 3 Mois chez Le Rat  par Voie  Orale  du  Produit  CGA 24 705.  [Three
   month oral Toxicity Trial of CGA  24  705  in  Rats]: IC-DREB-R-740120.
   (Unpublished study received  Mar 1,  1974  under  5G1553; prepared  by the Oncins
   Research and Breeding Center for  Ciba-Geigy Corp., Greensboro,  N.C.;
   CDL:94219-B)

Coquet, B.; Galland  L.; Guyot,  D.; Fouillet, X.;  Rouaud, J.L.  (1974c)  Three-
   Month Oral Toxicity Test  of  CGA 24  705 in Dog. A  translation of:  Essai  de
   Toxicite de 3 Mois chez Le Chien  par Voie Orale du Produit  CGA 24 705:  IC-
   DREB-R-740119.   (Unpublished study  received Sep  26,  1974  under 5G1553;
   prepared by the Oncins Research and  Breeding Center  for Ciba-Geigy  Corp.,
   Greensboro, N.C.; CDL;94223-A)

Coquet, B.; Galland, L.; Guyot, D.;  Fouillet,  X.; Rouaud, J.L.  (1974d) Three-
   Month Oral Toxicity Test  of  CGA 24  705 in Rats. A translation  of: Essai de
   Toxicite de 3 Mois chez Le Rat  par  Voie  Orale  du  Produit  CGA 24 705: IC-DREB-
   R-740120.  (Unpublished study received Mar  1,  1974 under  5G1553; prepared by
   the Oncins Research and Breeding  Center  for Ciba-Geigy  Corp.,  Greensboro,
   N.C.; CDL:94219-A)
                                     161

-------
Counselman,4C.J.; Roger, J.C. U973) Biological Report, Goat Metabolism Study
   with f6~~  C-CGA-24705 and 
-------
*   Dupre,  G.D.  (1974a)  Abbreviated Anaerobic Metabolism of   C-CGA-24705  in
       Silt Loam Soil under Greenhouse Conditions:  Report No.  73019-3.
       (Unpublished study received Sep 26,  1974 under 5G1553;  prepared  by
       Bio/dynamics Inc. for Ciba-Geigy Corp.,  Greensboro,  N.C.  CDL:94222~B)

    Dupre,  G.D.  (1974b)  Leaching Characteristics of 14C-CGA-24705  and its
       Degradation Products Following Aging in Sandy Loam Soil under Greenhouse
       Conditions: Report no. 73021-6.  (Unpublished study received by  Sep 26..  1974
       under 5G1553;  prepared by Bio-dynamics Inc.  for Ciba-Geigy  Corp.,
       Greensboro, N.C.; CDL:94222-C)

    Dupre,  G.D.  (1974c)  Runoff Characteristics of 14C-CGA-24705  Applied to
       Sandy Loam Soil under Greenhouse Conditions: Report no. 73022-1.
       (Unpublished study received Sep 26,  1974 under 5G1553;  prepared  by  Bio-
       dynamics  Inc.  for Ciba-Geigy Corp.,  Greensboro,  H.C.; CDL:94222-D)

    Elkins, D.M.;  Vandeventer, J.W.; Briskovich, M.A. (1977).  Effect of chemical
       growth retardants on turfgrass morphology.  Agronomy Journal 69(3):  458-461.

*   Ellegehausen,  H.  (1976a) Project Report 48/76:  A Model system  for Estimating
       the  Uptake, Transfer and Degradation of Agrochemicals by  Aquatic Organisms.
       AC 2.52.   (Unpublished study received Feb 6, 1978 under 100-583; prepared  by
       Ciba-Geigy Ltd.,  Basle, Switzerland; CDL:232789-B)

*   Ellegehausen,  H.  (1976b) Project Report 4/76: Degradation  of CGA 24 705 in
       Aerobic,  Anaerobic and Autoclaved Soil.  AC 2.52. (Unpublished study received
       Feb  6, 1978 under 100-583; prepared  by Ciba-Geigy Ltd., Basle, Switzerland;
       CDL:232789-D)

*   Ellegehausen,  H.  (1976c) Project Report 5/76: Addendum to  Project Report 4/76:
       Degradation of CGA 24 705 in Aerobic, Anaerobic and Autoclaved Soil.  AC
       2.52.   (Unpublished study received Feb 6, 1978 under 100-583; prepared by
       Ciba-Geigy Ltd.,  Basle, Switzerland; CDL:232789-E)

*   Ellegehausen,  H.  (1977) Project Repor^Project Report 32/77: Uptake, Transfer
       and  Degradation of CGA 24705 (Dual1  j) by Aquatic Organisms. AC  2.52*
       (Unpublished study received Feb 6, 1978 under 100-583;  prepared  by  Ciba
       Geigy Ltd., Basle, Switzerland; CDL:232789-C)

    Environmental  Protection Agency (1977)  2-Chloro-N-(2-ethyl-6-methylphenyl)-K-(2-
       methoxy-1-methylethyl-acetamide):  Extension of Temporary Tolerances.
       Federal Register 42 (67):  18426.

*   Ercegovich,  C.D.; Bogus, E.R.; Buly, R.L. (1978) The Effects of 5,  25, and  125
       PPM  of Metolachlor, [2-Chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy~l-
       methylethyl) acetamide] on Actinomycetes, Bacteria and  Fungi in Laboratory
       Culture Tests. E-2/1-CG78. received  Feb 6, 1978 under 100-583;  (Unpublished
       report received Feb 6, 1978 under 100-583; prepared by Pesticide Research
       Lab.,  Pennsylvania State University  for Ciba-Geigy Corp., Greensboro, N.C.;
       CDL:232789-F)

*   Ercegovich,  C.D.; Vallejo, R.P.; Bogus, E.R. (1978) The Effects of 5,  25, and
       125  PPM of Metolachlor, [2-Chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy-l-
       methylethyl) acetamide], on Soil Nitrification.  E-3/2-CG78.   (Unpublished
       study received Feb 6,  1978 under 100-583; prepared by  Pesticide Research
       Lab., Pennsylvania State University  for  Ciba-Geigy Corp.,  Greensboro, N.C.;
       CDL:232789-G)
                                        163

-------
Eschiapati, D.; Dachler, C. (1976) Metetilachlor + Atrazine, a new herbicide
   for corn crops.  Resumes XI Seminario Brasileiro de Herbicidas e Ervas
   Daninhas, Londrma, 1976: 44-45.

Fink, R. (1974a) Eight-Day Dietary LCSQ — Mallard Ducks Technical CGA-24705:
   Project No. 108-111.  Received Sep 26, 1974 under 5G1553.  (Unpubli
   report Truslow Farm Inc. for Ciba-Geigy Corp., Greensboro, N.C.;
   CDL: 112840-0)

Fink, R. (1974b) Eight-Day Dietary LCSO~ Bobwhite Quail Technical CGA-24705:
   Project No. 108-111.  (Unpublished Study received Sep 26, 1974 under
   5G1553.; Truslow Farm Inc. for Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:112840-P)

Fink, R. (1976) Acute Oral LD,n - Mallard Duck: CGA-24705 Technical: Final
   Report.  (Unpublished study received Nov 23, 1976 under 100-587; prepared  by
   Truslow Farms Inc. for Ciba-Geigy Corp., Greensboro, N.C.; CDL:226955-D)

Fink> R- (1978a) ..  Qie-Generatiorr Reproduction. Study - Bobwhite- Quail
    CGA-24750 technical Final Report; received 12-13-78 under 100-587,
    (Unpublished report prepared by Wildlife- International Ltd.. for; Ciba-Geigy
    Corp.,. Greensboro,. N.C,,- CDEi236620)

Finkv R_ (1978b) »  One-Generation- Reproduction Study — MaHard Dude
    CG&-24705 technical Final Report; received 12.-13-78 under 100-587,
    (Unpublished, report prepared by Wildlife: International. Ltd- for Coba-Gsigy
        .r- Greensboro r N.C.? CHLi23662Cl)
Frans, R.E.; Richardson, J.T.; Gordon, E.C.  (1977) Herbicide  Field  Evaluation
   Trials on Field Crops, 1976.   Fayetteville, Ark.: University of Arkansas,
   Department of Agronomy.  (Arkansas Agricultural Experiment  Station,
   Mimeograph Series 249)

Frans, R.E.: Blythe, T.O.;  Richardson,. J.T.  (1976). Herbicide Field Evaluation
   Trials on Field Crops, 1975.   Fayetteville, Ark.: University of Arkansas,
   Department of Agronomy.   (Arkansas Agricultural Experiment Station,
   Mimeograph Series, 240)

Fritz, H. (1976) Reproduction Study CGA 24705 Tech. Rat:  Seg.  II:  (Test for
   Teratogenic or Embryotoxic Effects): PH 2.632.  (Unpublished study received
   Jan 19, 1977 under 7F1913; prepared by Ciba-Geigy Ltd.,  Basle,  Switzerland;
   CDL:95768-A)

Gerber, H.R.; Mueller, G.;  Ebner, L. (1974)  CGA 24705, A  new  grasskiller
   herbicide. Pages 787-794, In Proceedings  of the 12th British Weed Control
   Conference; Nov 18-12, 1974 Brighton, England.  Begbroke Hill, Oxford,
   England: ARC Weed Research Organization.

Gesme, J.; Albanese, E.; Marias, A.J. (1977) Report to Ciba-Geigy Corporation:
   Carcinogenicity Study with CGA-24705- Technical in Albino Mice:  IBT No.  622-
   07925  (8532-07925).  (Unpublished study received Jan 18, 1978 under  7F1913;
   prepared by Industrial Bio-Test Laboratories, Inc. for Ciba-Geigy Corp.;
   including Validation report prepared by Ciba-Geigy Corp.,  Greensboro, N.C.;
   CDL:96719-A; 96720-A; 96720-B)
                                     164

-------
Gfeller, W.  (1974) Tolerability Trial  in Milk Cows with CGA 24  705:  14,  21 and
   28 day Feeding Study: AC  9.26; T73/23.   (Unpublished study received Sep 26,
   1974 under 5G1553; prepared by Ciba-Geigy Ltd., St. Aubin, Switzerland;
   CDL:94216-F)

Gold, B.; Kahrs, R.A. (1975a) DC-200:  An Alternate Gas Chronatographic Column
   for the Determination of  CGA-37913: GAAC-75026.   (Unpublished study received
   Mar 26, 1975 under 5F1606; prepared by  Ciba-Geigy Corp.,  Greensboro,  N.C.;
   CDL:94380-X)

Gold, B.; Kahrs, R.A. (1975b) Freeezer Storage  Stability of CGA-24705 Residues
   in Corn Fodder and Grain: GAAC-75062.   (Unpublished study received Nov 25,
   1975 under 6G1708; prepared by Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:94877-


Gross, D. (1974a) Project  Report No. 8/74:  Uptake, Translocation and
   Degradation of CGA 24 705 in Corn Grown under  Controlled Conditions.
   (Unpublished study received Sep  26, 1974 under 5G1553; prepared by Ciba-
   Geigy Corp., Greensboro,  N.C.; CDL:94217-F)

Gross, D. (1974b) Project  Report No. 13/74: Addendum to Project Report No. 8/
   74: Uptake, Translocation and Degradation of CGA  24 705  in Corn Grown under
   Controlled Conditions:  AC 2.52.   (Unpublished  study received Mar  26,  1975
   under 5F1606; prepared  by Ciba-Geigy Ltd., Basle, Switzerland; CDL:94378-H)

Guth, J.A. (1974) CGA 24705: Total  Residues in  Chicken Tissues  and Eggs, 1974:
   AC 2.53;  RVA 88/74.  (Unpublished study  received Sep 26,  1974 under 5G1553;
   prepared  by Ciba-Geigy  Ltd., Basle, Switzerland;  CDL:94216-D)

Hack, H., Schmidt, R.R.  (1976).  Use of Metamitron in weed  control systems
   in sugar  beets.   Pages  197-204,  _In Proceedings  1976 British Crop
   Protection Conference,    Bayer AG,  Pflanzenschutz Anwendunstechnik,
   Leverkusen, Federal  Republic of  Germany.

Hambock, H.  (1974a)  Project  No. 7/74:  Metabolism  of  CGA 24  705  in the Rat.
   (Status of Results Gathered up  to June  10, 1974): AC 2.52.   (Unpublished
   study received Sep 26,  1974 under 5G1553; prepared by Ciba-Geigy  Ltd.,
   Basle, Switzerland;  CDL:94217-L)

Hambock, H.  (1974b)  Project  Report  12/74:  Addendum  to Project Report 7/74:
   Metabolism of CGA 24  705  in the  Rat: AC 2.52;   (Unpublished  study received
   Nov 25, 1975 under 6G1708; prepared by  Ciba-Geigy Ltd.,  Basle, Switzerland;
   CDL:94984-P)

Hambock, H.  (1974c)  Project  Report  No. 1/74:  Distribution,  Degradation  and
   Excretion of CGA  24  705 in the Rat. (Unpublished  study  received  Sep  26, 1974
   under 5G1553; prepared  by Ciba-Geigy Ltd., Basle, Switzerland; CDL:94217-K)

Harrison, W.A.; (1975)  Report to Ciba-Geigy Corporation: Acute  Toxicity Studies
   with CGA  24705 +  Atrazine: IBT No.  601-07539.   (Unpublished  study received
   Dec 29, 1975 under 100-EUP-45; prepared by  Industrial Bio-Test Laboratories,
   Inc., For Ciba-Geigy Corp., Greensboro, N.C.;  CDL:224074-B;  231913)
                                     1 6 5

-------
    Harvey, R.G.; Baker, C.R.  (1974?) Annual Weed Control  in  Corn Study:  Project
       No. 755.  (Unpublished  study received Feb 9,  1976 under  100-EUP-44;  prepared
       for Ciba-Geigy Corp., Greensboro, N.C.; CDL:96496-C)

    Heinrichs, L. (1975) Determination of CGA-24705  and Procyazine in GA-2-686  15G
       by Gas Chromatography:  Method PA-71 T dated  Oct 9, 1975.   (Unpublished
       study received Feb 9, 1976 under 100-EUP-44;  prepared  by Ciba-Geigy  Corp.,
       Greensboro, N.C.; CDL:96496-A)
                                                                  / TJ \
    Heinrichs, L. (1976) The Determination of Metolachlor  in  Dual     6E  by Gas
       Liquid Chromatography.  Method PA-9A dated Dec 16,  1976.   (Unpublished study
       received Nov 14, 1977 under 100-EUP-61; prepared by Ciba-Geigy Corp.,
       Greensboro, N.C.; CDL:96623-A)

*   Helseth, J.; Cole, G. (1973) The Determination of CGA-24705 in Emulsifiable
       Concentrates by Gas Liquid Chromatography.  Method  PA-9 dated  Nov  14, 1973.
       (Unpublished study received Sep 26, 1974 under 5G1553; prepared by Ciba-
       Geigy Corp., Greensboro, N.C.; CDL:96666-A)

    Hermes, P. (1970) Extraction of Radioactive Metabolites from  Sorghum  Treated
       with   C GS-13529.  Method AG-141 dated Jun 23, 1970.  (Unpublished  study
       received Mar 26, 1975 under 5F160; prepared by Ciba-Geigy  Corp., Greensboro,
       N.C.; CDL:94380-A)

*   Hermes, P. (1972) Biphasic Extraction of Radioactive Metabolites  from Treated
       Biological Material.  Method AG-214 dated Aug 15, 1972.  (Unpublished study
       received Sep 26, 1974 under 5G1553; prepared  by Ciba-Geigy Corp.,  Ardsley,
       N.Y.; CDL:94216-M)
                                    14
    Hermes, P. (1973) Radioassay of   C in Biological Materials by Combustion
       using the Harvey Biological Material Oxidizer (BMO).  Method AG-252  dated
       Aug 14, 1973.  (Unpublished study received Sep 26,  1974 under  5G1553.;
       prepared by Ciba-Geigy Corp., Ardsley, N.Y.;  CDL:94216-R)

    Higgins, E.R.; Schnappinger, M.G.; Pruss, S.W. (1975)  Yellow  nutsedge control
       with CGA-24705 in corn and soybeans.  Pages 9-16,   In  Proceedings of the
       Twenty-Ninth Annual Meeting of the Northeastern Weed Science Society;
       Jan 7-9, 1975; New York City.   Salisbury, Md.: University of  Maryland,
       Vegetable Research Farm.

    Higgins, E.R.; Schnappinger, M.G.; Pruss, S.W. (1976)  CGA-24705 plus  atrazine
       yellow nutsedge control in corn.  Pages 65-70,  Jin  Proceedings of  the
       Thirtieth Annual Meeting of the Northeastern  Weed Science  Society; Jan 6-8,
       1976; Boston, Massachusettes.   Salisbury, Md.: University of  Maryland,
       Vegetable Research Farm.

    Hofberg, A.; Balu, K. (1972a) Preparation of a Model System to Study  Aqueous
       Solution Photolysis in a Laboratory Environment.  Method AG-208 dated Aug
       11, 1972.  (Unpublished study received Sep 26, 1974 under  5G1553;  prepared
       by Ciba-Geigy Corp., Ardsley, N.Y.; CDL:94216-L)
                                        166

-------
Hogenboom, P.M.  (1976) Metetilachlor - a  new grass herbicide. Resumas XI
   Seminario Brasileir de Herbicidas e Eruas Daininhas, Londrina,  1976: 127-
   128.

Holliday, W.K.  (1975) Report  to  Ciba-Geigy  Corporation: Acute Aerosol
   Inhalation Toxicity Study  with CGA-24705 + Atrazine  (2.5:2.0) 4.5F in Albino
   Rats: IBT No. 633-07540.   (Unpublished study received Dec 29, 1975 under 100-
   EUP-45; prepared by Industrial Bio-Test  Laboratories, Inc., for Ciba-Geigy
   Corp., Greensboro, N.C.; CDL:224074-C)

Hermann, W.D.;  Guth, J.A.; Formica, G.; Schenker, M.  (1974) CGA 24705: Gas
   Chromatographic Determination of Total Residues in Material of  Animal
   Origin.  (Provisional): AC 2.53; REM 5/74.  (Unpublished study  received Sep
   26, 1974 under 5G1553; prepared by Ciba-Geigy Ltd.,  Basle, Switzerland;
   CDL:94216-E)

Houseworth, L.D. (1973?a) Effect on CGA-24705 on Microbial Populations in Two
   Soils: Report No. 2.   (Unpublished study received  Sep 26, 1974  under 5G1553;
   prepared by  University of  Missouri—Columbia, Department of Plant Pathology
   for Ciba-Geigy Corp., Greensboro, N.C.;  CDL:94222-F)

Houseworth, L.D. (1973?) Report  on Parent Leaching Studies for CGA-24705:
   Report No. 1. (Unpublished study received Sep 26,  1974 under 5G1553;
   prepared by  University of  Missouri—Columbia, Department of Plant Pathology
   for Ciba-Geigy Corp., Greensboro, N.C.;  CDL:94222-E)

Houseworth, L.D. (1977) Residues of Metolachlor and Atrazine in or on Corn
   Grain Resulting from Preemergence and  Preplant Incorporated Application of a
   Liquid Prepack Formulation of Metolachlor and Atrazine with and without
   Liquid Fertilizer.  (Unpublished study including reports AG-A-3298 II,
   III, AG-A-3325 II, AG-A-3326  II, AG-A-3372 II, AG-A-3406 II, AG-A-3674 II,
   III, AG-A-3745 I, II, III,  with a summary ABR-77028; received Jun 20, 1977
   under 100-590; prepared by Ciba-Geigy  Corp.; Greensboro, N.C.;  CDL:230685-A)

Houseworth, L.D. (1977) Residues of Metolachlor and Dicamba in or  on Corn Grain
   Resulting from Preemergence Tank Mix Applications: ABR-77071.   (Unpublished
   study containing reports AG-A 4253, AG-A 4264, AG-A  4270 received Nov 8,
   1977 under 100-EUP-59; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:232192-A)

Houseworth, L.D.; Rolla, H. (1976) Residues from Metolachlor Alone and in Tank
   Mix with Linuron, Metribuzin  and Liquid  Fertilizer in Soybeans: ABR-76077.
   (Unpublished  study received Jan 19, 1977 under 7F1913; prepared by Ciba-
   Geigy Corp.,  Greensboro, N.C.; CDL:95767-A)

Houseworth, L.D.; Rolla, H. (1977a) Residues of Metolachlor and Atrazine in or
   on Corn Grain Resulting from  Tank Mix  Applications with and without Liquid
   Fertilizer-Preplant Incorporated and Preemergence  Applications: ABR-77017.
   (Unpublished  study that includes studies AG-A-3325 II, AG-A-3406 II, AG-A-
   3672 II-III,  AG-A-3673 I,  II, III, AG-A-3704 I, II,  AG-A-3735 I, II, III, AG-
   A-3799 II, III, AG-A-3858  with a summary; received Feb 18, 1977 under 100-
   583; prepared by Ciba-Geigy Corp., Greensboro, N.C., CDL:228126-A)
                                    167

-------
Houseworth, L.D.; Rolla, H. (1977b) Residues of Metolachlor in or on Sorghum
   Resulting from Preplant Incorporated and Preemergence Applications: ABR-
   77086.  (Unpublished study, that includes studies AG-A-4413, AG-A-4418, AG-A-
   4503, and AG-A-4753, received Nov 14, 1977 under 8G2019; prepared by  Ciba-
   Geigy Corp., Greensboro, N.C.; CDL:96625, 96626-A, 96626-B, 96626-C,  96626-D)

Iggo, G.A. (1975) Results of screening preemergence herbicides for sugarcane.
   Pages 11-14,  _ln Proceedings of the South African Sugar Technologists'
   Association Forty-Ninth Meeting; Jun 30-Jul 4, 1975; Durban, South Africa.
   Durban, South Africa: Hayne and Gibson Ltd. for the Society and the South
   African Sugar Association Experiment Station:

Industrial Bio-Test Laboratories, Incorporated (1975) Report to Ciba-Geigy
   Corporation: Acute Dust Inhalation Toxicity Study with CGA-24705 + CGA-18762
   (1:1) 15G(FL-751873) in Albino Rats: 1ST No. 663-07826.  (Unpublished study
   received Feb 9, 1976 under 100-EUP-44; prepared for Ciba-Geigy Corp.,
   Greensboro, N.C.; CDL:96495-B)

Industrial Bio-Test Laboratories, Incorporated (1975) Report to Ciba-Geigy
   Corporation: Acute Toxicity Studies with CGA-24705 + CGA-18762 (1:1) 15G:
   IBT No. 601-07825.  (Unpublished report received Feb 9, 1976 under 100-EUP-
   44; prepared for Ciba-Geigy Corp., Greensboro, N.C.; CDL:96495-A)

Jagschitz, J.A. (1976) Response of Kentucky bluegrass to growth retardant
   chemicals.  Pages 327-333, In Proceedings of the Thirtieth Annual Meeting of
   the Northeastern Weed Science Society; Jan 6-8, 1976; Boston,
   Massachusettes.   Salisbury, Md. University of Maryland, Vegetable Research
   Farm.

Jordan, L.; Harvey, G. (1976) Comparison of acid aralid herbicides for canning
   pea weed control.  Page 30, In Proceedings of the North Central Weed
   Control Conference; December 9-11, 1975; Milwaukee, Wisconsin.   Omaha,
   Neb.; by Stauffer Chemical Company for the North Central Weed Control
   Conference.

Jooste, J. v.d. W.; Van Biljon, J.J. (1976).  Metolachlor + Atrazine a
   combination pre-emergence herbicide for broad spectrum weed control in
   maize. Gewasproduksie/crop production 5:85-90.

Kahrs, R.A. (1977) Tank Mixes of Metolachlor Plus Atrazine Plus Paraquat -
   Corn: No and Minimum Tillage Applications: Summary of Residue Data: ABR-
   77074.  (Unpublished study containing reports AG-A-4167 II, AG-A-4187 II,
   III, AG-A-4198 II, III, AG-A-4247 II, III, AG-A-4288 I, II received Nov 8,
   1977 under 100-EUP-59; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:232192-H)

Kaiser, F. (1974) Soil Degradation Study of Ciba-Geigy 14C-CGA-24705.
   (Unpublished study received Mar 27, 1975 under 5F1606; prepared by
   Analytical Biochemistry Laboritories, Inc., Submitted by Ciba-Geigy Corp.,
   Greensboro, N.C.; CDL: 94376-A)
                                    16

-------
    Karlhuber, B.; Ramsteiner, K.  (1973) CGA  24705: Gas Chromatographic Residue
       Determination in Plant Material, Grains and Soil.   (Provisional): AG 2.53;
       REM 2/73.   (Unpublished study received Sep 26, 1974 under 5G1553; prepared
       by Ciba-Geigy Ltd., Basle,  Switzerland; CDL:94222-G)

    Keezer, W. (1971) Ion-Exchange Characterization of Metabolites of Radioactive
       Pesticides.  Method AG-156 dated Mar 3, 1971.  (Unpublished study received
       Mar 26, 1975 under 5F1606; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
       CDL:94380~C)

*   Kennedy, G.L.  (1975) 28-Day Mouse Pilot Study with CGA-24705 (Technical).
       dated Nov 21. 1975; IBT No. 622-07857.  (Unpublished study received Feb 16,
       1978 under  100-583; prepared by Industrial Biotest Laboratories, Inc. for
       Ciba-Geigy  Corp., Greensboro, N.C.; CDL-232855-B)

*   Kennedy, G.L.  (1976a) Letter  [dated Dec 10, 1976, relative to the results of
       the first generation of a three generation reproduction study in albino rats
       with the chemical CGA 24705 (IBT No. 8533-07928)] to George Rolofson.
       (Unpublished study received Jan 19, 1977 under 7F1913; prepared by
       Industrial  Bio-Test Laboratory, Inc.,  for Ciba-Geigy Corp., Greensboro,
       N.C.; CDL:95768-E)

 *   Kennedy, G.L.  (1976b) Letter  [dated Dec 13, 1976, interim report on IBT No.
       8531-07926, 2 year chronic  toxicity of CGA 24705 in albino rats] to George
       Rolofson.   (Unpublished study received Jan 19, 1977 under 7F1913; prepared
       by Industrial Bio-Test Laboratory, Inc. for Ciba-Geigy Corp., Greensboro,
       N.C.; CDL:95768-D)

 *   Kennedy, G.L.  (1976c) Letter  [dated Dec 13, 1976, relative to the 2 year
       carcinogenicity study of CGA 24705 in albino mice (IBT No. 8531-07925)] to
       George Rolofson.  (Unpublished study received Jan 19, 1977 under 7F1913;
       prepared by Industrial Bio-Test Laboratories, Inc., for Ciba-Geigy Corp.,
       Greensboro, N.C.; CDL:95768-C)

    Knaak, J.B.; Tallant, M. J.; Bartley, W.J.; Sullivan, L.J. (1965) The
       metabolism  of carbaryl in the rat, guinea pig, and man. Journal of
       Agricultural and Food Chemistry. 13(6): 537-542. (Also In unpublished
       report received Sep 26, 1974 under 5G1553; prepared by Ciba-Geigy Corp.,
       Greensboro, N.C.; CDL:94221-C)

    Kurtz, L.; Stroube, W. (1976).  Control of yellow nutsedge by various
       herbicides.  Page 59, _In Proceedings of the North Central Weed Control
       Conference; December 9-11,  1975; Milwaukee, Wisconsin.   Cmaha, Neb.; by the
       Stauffer Chemical Company for the North Central Weed Control Conference.

    Lazzara, K.; Paa, H. (1975) Report to Ciba-Geigy Corporation: Acute Dermal
       Toxicity Study with 1:4 Aqueous Suspension of CGA-24705 + Atrazine  (2.5:2.0)
       4.5L in Albino Rabbits: IBT No. 601-08061.   (Unpublished study received Jun
       20, 1977 under 100-590; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
       CDL:230687-B)
                                         169

-------
Lee, T,; Kaldon, H. (1974)  [Tank-Mix Compatabilities Test Report for CGA-24705-
   GE. GA-2-621, with other Herbicides]: AG Request No. 4349.   (Unpublished
   study received Mar 26, 1975 under 5F1606; prepared by Ciba-Geigy Corp.,
   Greensboro, NoC.; CDL:94384-A)

Lcrensi, H.J. (1976J).  Herbicide tests on corn crops.  Resumes XI Seminario
   Braslieiro de Herbicidas e Eruas Daninhas, Londrina, 1976: 38:39

naher, 0\; Heinrichs, L. (1975a) Analysis of Atrazine and CGA-24705 in GA-2-622
   4,5 L Formulation.  Method Pa-72-T dated Oct 9, 1975.  (Unpublished study
   received Dec 29, 1975 under 100-EUP-45.; prepared by Ciba-Geigy Corp.,
   Greensboro, N.C.; CDL:224074-A)

Maher, J.^-Heinrichs, L. (1975b) Analysis of Atrazine and CGA-24705 in
   Ultrex   4.5L Formulation by Gas Chromatography. Method PA-72-T dated Oct
   9, 1975.  (Unpublished study received Jun 20, 1977 under 100-590; prepared
   by Ciba-Geigy Corp., Greensboro, N.C.; CDL:230686-B)

Marco, G. (1974) Summary of Section D: CGA-24705-Corn: Residues Observed and
   Metabolism Data Including the Analytical Methods Used: GAAC-74062.
    (Unpublished study that includes reports AG-A-2929, AG-A-2969, AG-A-2973, AG~
   A-3105, AG-A-3133; received Sep 26, 1974 under 5G1553; prepared by Ciba-
   Geigy Corp., Greensboro, N.C. CDL:94217-A; 94222)

Marco, G, (1975) Sumtnary of Section D: CGA-24705 Corn: Residues Observed and
   Metabolism Data Including the Analytical Methods Used: GAAC-75001.
    (Unpublished study received Mar 26, 1975 under 5F1606; prepared by Ciba-
   Geigy Corp., Greensboro, N.C.; CDL:94378-A)

Mattson, A.M. (1969) Quantitative Determination of Triazine Herbicides in Soils
   by Chemical Analysis: GAAC-69014.  (Unpublished study received Feb 18, 1977
   under 100-583; prepared by Ciba-Geigy Corp., Greensboro, N.C.; CDL:228125-B)

Mattson, A.M. (1974) CGA-24705 Residues in Milk, Meat, Eggs and Chickens
    (Three Level Feeding Studies): GAAC-74064.  (Unpublished study received Sep
   26, 1974 under 5G1553; prepared by Ciba-Geigy Corp., Greensboro, N=C«;
   CDL:94216-8)

Mattson, A»M. (1975) CGA-24705 Residues in Milk, Meat, Eggs and'Chickens
    (Three Level Feeding Studies): GAAC-75059.  (Unpublished study received Nov
   25, 1975 under 6G1708; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:94878-A)

Mattson, A.M.; Kahrs, R.A. (1969) Quantitative Determination of Triazine
   Herbicides in Soils by Chemical Analysis: GAAC-69014.  (Unpublished study
   received ttov 8, 1977 under 100-EUP-59; prepared by Ciba-Geigy Corp.,
   Greensboro, N.C.; CDL:232193-H)

Mattson, A.M.; Kahrs, R.A. (1975a) Procyazine — Corn: Tank Mixes with CGA-
    24705 with and without Fertilizers, Preemergence and Preplant Incorporated
   Applications: Procyazine Plus CGA-24705-15% Granule: GAAC-75077.
                                    17 0

-------
    (Unpublished  study that includes reports AG-A-3638,  AG-A-3671,  AG-A-3716, AG-
    A-3731,  AG-A-3741, AG-A-3798,  AG-A-3703, AG-A-3726,  AG-A-3784,  AG-A-3817;
    received itov  26,  1975 under 4G1469;  prepared by Ciba-Geigy Corp.,
    Greensboro, N.C.  CDL:95190-A)

Mattson,  A.M.; Kahrs, R.A. (1975b)  Residues in Field Grown Corn Following Use
    of  CGA-24705  Determined as CGA-37913 and CGA-49751:  GAAC-75015.
    (Unpublished  study that includes reports AG-A-2967,  AG-A-2982,  AG-A-3255, AG-
    A-3289,  AG-A-3299, AG-A-3328,  AG-A-3383, AG-A-3501,  AG-A-3005,  AG-A-3153, AG-
    A 3446;  received  Mar 26,  1975  under  5F1606;  prepared by Ciba-Geigy Corp.,
    Greensboro, N.C.  CDL:94379-B)

Mattson,  A.M.; Kahrs, R.A. (1975c)  Summary of Residue Data CGA-24705TAtrazine
    Combinations  as Corn Herbicides  Tank Mixes-Dual   6EC Plus AAtrex^  '  SOW
    or  AAtrex    4L Flowable Combination Formulation-GA-2-6-622 4.5L
    Preemergence  and  Preplant Incorporated Applications:  GAAC-75081.
    (Unpublished  study including reports AG-A-2974; AG-A-3057; AG-A-3070;  AG-A-
    3288;  AG-A-3298;  AG-A-3325;  AG-A-3326; AG-A-3372;  AG-A-3406;  received  Dec
    29,  1975 under 100-EUP-45; prepared  by Ciba-Geigy Corp.,  Greensboro, N.C.;
    CDL:224074-D)

Mattson,  A.M.; Rolla, H. (1975) Summary of Section D: CGA-24705-Soybeans:
    Residues Observed and Metabolism Data Including the  Analytical  Methods  Used:
    GAAC-75057.   (Unpublished study  that includes reports AG-A-3268,  AG-A-3466,
    AG-A-3523, AG-A-3570, AG-A-3650  I &  II,  AG-A-3702, AG-A-3724, AG-A-3743,  AG-
    A-3776,  AG-A-3780, AG-A-3803;  received Nov 25,  1975  under 6G1708; prepared
    by  Ciba-Geigy Corp.,  Greensboro, N.C. CDL;94984-A; 94878)

Mattson,  A.M.; Kahrs, R.A.;  Schneller,  J. (1965)  Use  of Microcoulonetric gas
    chromatograph for triazine herbicides. Journal  of  Agricultural  and  Food
    Chemistry 13(2):  120-122. (Also  In  unpublished study received  Feb  18,  1977
    under  100-583;  prepared by Ciba-Geigy Corp.,  Greensboro,  N.C.;  CDL:228126-K)

McCohen,  L.L.; Tiedje,  J.M.  (1978).  Metabolism of two  new acylanilide
    herbicides, Antor Herbicide (H-22234) and Dual (Metolachlor)  by the soil
    fungus Chaetomium globosum.   Journal of Agricultural and  Food Chemistry
    26(2):414-419.

McGahen,  L.L.; Tiedje,  J.M.  (1978).  Metabolism of two  new acylanilide
    herbicides, Antor Herbicide (H-22234) and Dual (Metolachlor)  by the soil
    fungus Chaetomium globosum.   Journal of Agricultural Food Chemistry 26(2):
    414-419.

Mclaughlin,  J.P.;  Hartwig, N.L. (1976)  Yellow nutsedge  control in  conventional,
   minimum,  and  no-tillage corn,  Pages 711-76,   In  Proceedings of the
   Thirtieth Annual  Meeting  of the  Northeastern Weed Science Society?  Jan 6-8,
    1976;  Boston, Massachusettes.    Salisbury, Md:  University of  Maryland,
   Vegetable Research Farm.

Michieka, R.W.;  Ilnicki, R.D.;  Somody,  J. (1976).   The  response  of corn and
    annual weeds  to some  new  herbicides  used alone and in combination with
    atrazine  or alachlor. Pages  46-47, _In Proceedings of the Northeastern  Weed
    Science  Society.
                                     171

-------
Michieka, R.W.: Ilnicki, R.D.: Somody, J. (1977).  Weed control in potatoes
   wiuh preplant incorporated herbicides applied alone, in combination,  and
   with follow-up preemergence herbicides.  Pages 197-198 _In Proceedings of  the
   Northeastern Weed Science Society.

Miyazaki, S. (1976) Gas Chromatographic Residue Determination of CGA-24705 in
   Soil. Method AG-303 dated Oct 15, 1976.  (Unpublished study received  Jan  19,
   1977 under 100-583; prepared by Ciba-Geigy Corp., Greensboro, H.C.;
   CDL:95763-B)

Miyazaki, S. Kahrs; R.A. (1974) Specificity of the Residue Determination of
   CGA-24705 Metabolic Residues in Corn (AG-265): GAAC-74063.  (Unpublished
   study received Sep 26, 1974 under 5G1553; prepared by Ciba-Geigy Corp.,
   Greensboro,  N.C.; CDL:94216-J)

Miyazaki, S.; Kahrs, R.A. (1975) Specificity of the Residue Determination of
   CGA-24705 Residues in Corn (AG-277): GAAC-75014.  (Unpublished study
   received Mar 26, 1975 under 5F1606; prepared by Ciba-Geigy Corp.,
   Greensboro,  N.C.; CDL:94380-W)

Murphy, H.J.; Gajewski, T. (1977).  Effect of several herbicides applied
   preemergence, at drag-off and layby on weed control in white potatoes.
   Pages 176-179, _In Proceedings of the Northeastern Weed Science Society.

Murphy, H.J.; Goven, M.J. (1976).  A comparison of AC 92,553, CGA-24705, and
   FMC 25213 in combination with metribuzin for weed control in potatoes.
   Pages 256-261, _In Proceedings of the Northeastern Weed Science Society.

Nham, Dan; Harrison, W.A. (1977a) Report to Ciba-Geigy Corporation: Acute Oral
   Toxicity Study with Dual1 ; 8E in Albino Rats: IBT No. 8530-10822.
   (Unpublished study received Nov 8, 1977 under 100-EUP-59; prepared by
   Industrial Bio-Test Laboratories, Inc. for Ciba-Geigy Corp., Greensboro,
   N.C., including Addendum A — Validation by Ciba-Geigy Corp.; CDL:232191-A)

Nham, Dan; Harrison, W.A. (1977b) Report to Ciba-Geigy Corporation: Acute
   Dermal Toxicity Study with Dual1 ' 8E in Albino Rabbits: IBT 8530-10822.
   (Unpublished study received Nov 8, 1977 under 100-EUP-59; prepared by
   Industrial Bio-Test Laboratories, Inc. for Ciba-Geigy Corp., Greensboro,
   N.C.; including Addendum B—Validation by Ciba-Geigy Corp; CDL:232191B)

Noll, C.J.(1976).  Chemical weed control on snap beans.  Pages 202-204,  _In
   Proceedings of the Itortheastern Weed Science Society 30:202-204.

Norton, J.A. (1978) Letter Sent to George LaRocca data Aug 28, 1978. Dual 8E
   Herbicide [Request for Acceptance of Finished Labeling to Allow Use on Corn
   Grown for Grain, Excluding Popcorn.] Received May 1978 under 100-597.
   (Submitted by Ciba-Geigy Corp., Greensboro, N.C.)
                                   (R}
Norton, J.A. (1978)  [Letter on Dual^   6E Herbicide -EPA Reg. No. 100-583
   Ciba-Geigy follow-up to requests from Mr. James Skaptason, Metolachlor
   Generic Standard] to Mr. Henry M. Jacoby, dated Feb 21, 1978.   (Unpublished
                                    172

-------
      letter from the files of the Office of Pesticide Programs, Technical
      Services Division.  Received Feb 22, 1978 under 100-583 prepared by Ciba-
      Geigy Corp., Greensboro, N.C; CDL:232898)

   Norton, J.A. (1977) Letter sent to Henry Jacoby dated May 20, 1977. [Relative
      to the May 17, 1977, meeting between H. Craven, R. Felthausen, and H. Jacoby
      of EPA and J. Barnett, L. Newly, and J. Norton of Ciba-Geigy.  Conclusions
      reached on text protocols, data requirements, and timetables relating both
      to Ciba-Geigy's petition for residue tolerances for metolachlor in soybeans
      and to its application for registering Dual 6E for selective weed control].
      (Submitted by Ciba-Geigy and on file in Generic Standards Branch, OPP)

   Norton, J.A. (1978) Letter sent to Henry Jacoby dated March 23, 1978.  [Dual 6E
      Herbicide - Follow-up to questions raised by Mr. Harry. Craven, Efficacy and
      Ecological Effects Branch, During Reviews for Metolachlor Generic Standard.]
      Received May 1978 under 100-583.  (Submitted by Ciba-Geigy Corp.,
      Greensboro, N.C., and on file in Generic Standards Branch, OPP)

   Norton, J.A. (1978) Letter sent to Henry Jacoby dated February 3, 1978.  [Dual
      6E Herbicide - Binomial Nomenclature - Channel Catfish.] Received Feb 27,
      1978 under 100-583.   (Submitted by Ciba-Geigy Corp., Greensboro, N.C. and on
      file in Generic Standards Branch, OPP)

   Norton, J.A. (1978) Letter sent to Henry Jacoby dated March 8, 1978. [Dual 6E
      Herbicide - Regarding Norton's February 3, 1978 Letter on Binomial
      Nomenclature for Channel Catfish]. Received Mar 1978 under 100-853.
      (Submitted by Ciba-Geigy Corp., Greensboro, N.C. and on file in Generic
      Standards Branch, OPP)

*  Oncins Research and Breeding Center (1974) Three-Month Dietary Feeding Study in
      Rats:  CGA 24 705.  A translation of: Toxicite de 3 Mois chez le Rat par Voie
      Orale du Produit CGA 24 705, translated by F- Roulet: IC-DREB-R 741009.
      (Unpublished study received Mar 26, 1975 under 5F1606; prepared by
      Ciba-Geigy Corp., Greensboro, N.C.; CDL:94377-B)

   Paa,  H. (1976a) Report to Ciba-Geigy Corporation: Acute Dermal Toxicity Study
      with an Aqueous Herbicide,Use Dilution Containing a Combination of Dual
      6EC (FL-760205) and Lorox1 ' 50 W (FL-761533) in Albino Rabbits: IBT No.
      8530-09780.  (Unpublished study received Jan 19, 1977 under 7F1913; prepared
      by Industrial Bio-Test Laboratories, Inc. for Ciba-Geigy Corp., Greensboro,
      N.C.;  CDL;95768-G)

   Paa,  H. (1976b) Report to Ciba-Geigy Corporation: Acute Dermal Toxicity Study
      with an Aqueous Herbicide Use Dilution Containing a Combination of Dual
      6EC (FL-760205) and Sencor(   SOW (FL-761088) in Albino Rabbits: IBT No.
      8530-09781.  (Unpublished study received Jan 19, 1977 under 7F1913; prepared
      by Industrial Bio-Test Laboratory Inc. for Ciba-Geigy Corp., Greensboro,
      N.C.;  CDL:95768-H)

   Parker, C.; Dean, M.L. (1976) Control of wild rice  in rice. Pesticide Science
      7(4):403-416.
                                        173

-------
Parochetti, J.V. (1975) Weed control in soybeans with rrtetribuzin  and
   combinations with other herbicides. Pages 28-35, _In Proceeding  of  the  Twenty-
   Ninth Annual Meeting of the Northeastern Weed Science Society;  Jan 7-9,
   1975; New York City.  Salisbury, Md: University of Maryland, Vegetable
   Research Farm.

Parochetti, J.V. (1977).  Herbicides for no-tillage double  cropped soybeans,
   Pages 54-60, In Proceedings of the Northeastern Weed Science Society.

Parochetti, J.V. (1977).  Residual herbicides on no-tillage corn  in a rye
   cover crop.  Pages 24-29 _In Proceedings of the Northeastern Weed Science
   Society.

Parochetti, J.V. ; Burt, G.W. ; Bell, A.W. (1976).  Triazines, acetanilides, and
   several other herbicides for weed control in corn. Pages 48-54, In
   Proceedings of the Thirtieth Annual Meeting of the Northeastern Weed  Science
   Society; Jan 6-8, 1976; Boston, Massachusettes .   Salisbury, Md.:  University
   of Maryland Vegetable Research Farm.
                       ( R)
Peek, J. W. (1976)  Dual    Experimental Use Permit for Weed Control in
   Sorghum Grown for Seed.  (Unpublished report received Dec 14,  1976 under 100-
   EUP-54; prepared by Ciba-Geigy Corp., Greensboro, N.C. that includes  reports
   1-38 with sunmary; CDL:229062-A; 229063)

Peek., J.W. (1977X,Biological Research Report on Herbicide Efficacy and Crop
   Safety: Bicep   4.5 L Experimental Use Permit for Weed Control  Evaluation
   in Grain Sorghum.  (Unpublished study received Nov 8, 1977 under 100-EUP-60;
   prepared by Ciba-Geigy Corp., Greensboro, N.C.; including studies  1-8  with a
   summary; CDL:96615-A, 96616)

Peters, R.A. ; Dest, W.M. (1975) Evaluation of herbicides for use  on no-tillage
   corn in a rye cover crop.  Pages 74-77, _In Proceedings of the  Twenty-Ninth
   Annual Meeting of the Northeastern Weed Science Society; Jan 7-9,  1975; New
   York City.   Salisbury, Md: University of Maryland, Vegetable  Research Farm.

Pillai, G.G.P., Davis, D.E. (1975) Mode of action of CGA-18762, CGA-17020, and
   CGA-24705.  _In Proceedings of the Twenty-Eighth Annual Meeting  of  the
   Southern Weed Science Society.

Pillai, C.G.P., Davis, D.E., Truelove, B. (1976) CGA-24705 effects on
   germination, growth, leucine uptake, and incorporation: Abstract.   Page 403,
    _In Proceedings of the Twenty-Ninth Annual Meeting of the Southern Weed
   Science Society; Jan 27-29, 1976; Dallas, Texas.   Raleigh, N.C.;  Glover
   Printing for the Southern Weed Science Society.

Pillai, G.G.P., Davis, D.E., Truelove, B. (1977) Site of uptake and mode  of
   action of metolachlor: Abstract.  Page 367,  _In Proceedings of  the Thirtieth
   Annual Meeting of the Southern Weed Science Society; Jan 19-21, 1977;
   Dallas, Texas. Raleigh, N.C.; Glover Printing for the Southern  Weed Science
   Society.
                                             .
    Plant Sciences Branch, BFSD, EPA. Contract No. 68-01-5155

                                     174

-------
Pruss, S.W.; Higgins, E.R.; Schnappinger, M.G.  (1976).  CGA-24k705 plus
   triazine herbicides for annual grass and broadleaf weed control in corn.
   Pages 40-45r  _ln  Proceedings of  the Thirtieth Annual Meeting of the
   Northeasten Weed  Science Society; Jan  6-8,  1976; Boston, Massachusettes.
   Salisbury, Md.: University  of Maryland Vegetable Research  Farm.

Ramsteiner, K; Karlhuber,  B. (1975) CGA-24705:  Determination  of Total Residues
   in Material of Animal Origin: AC 2.53; REM  2/75.   (Unpublished study
   received Mar  26,  1975 under 5F1606; prepared by Ciba-Geigy Ltd., Basle,
   Switzerland;  CDL:94379-1)

Remos, M.  (1976).  Chemical weed control  in growing soybeans  planted with
   minimum soil  preparation.   Resumes XI  Seminario Brasileiro de Herbicidas  e
   Ervas Daninhaus,  Londrina,  1976: 91-92.

Richter, W.; Alt, K.O.; Blum,  W.; Winkler, T.  (1974)  Structure Elucidation of
   'Metabolite X', a Degradation Product  of CGA 24705: AC  2.53.   (Unpublished
   study received March 26, 1975 under 5F1606;  prepared by Ciba-Geigy Ltd.,
   Basle,  Switzerland; CDL: 94380-S.)

Robbins, J.D.; Bakke, J.E. (1967) Sheep4and goat metabolism unit  for the
   collection of excreta  and expired C  0 . Journal of Animal Science
   26(2):  424-429.  (Also  In unpublished report received Sep 26, 1974 under
   5G1553; prepared  by Ciba-Geigy Corp.,  Greensboro,  N.C.; CDL:94221-E)
                                                       14
Roger, J.C.  (1973) Addendum  to AG-218 —  Total Organic   C Contents in
   Rumen and Intestinal Wash Using  Lindberg Combustion Furnace. Method AG-251
   dated Aug 16, 1973.   (Unpublished study received Mar 26, 1975 under 5F1606;
   prepared by Ciba-Geigy  Corp., Greensboro, N.C.; CDL:94380-K)
                                                                     14
Roger, J.C.; Cassidy, J.E. (1974a)  Metabolism  and Balance  Study of fir-  C-
   CGA-24705 in  a Lactating Goat: GAAC-74020.    (Unpublished  study received  Sep
   25, 1974 under 5G1553;  prepared  by Ciba-Geigy  Corp., Greensboro, N.C.;
   CDL:94217-G)
                                                                     14
Roger, J.C.; Cassidy, J.E. (1974b)  Metabolism  and Balance  Study of $-  C-
   CGA-24705 Corn Biosynthesized Metabolites  in a Goat: M6-68-2A: GAAC-74046.
   (Unpublished  study received Sep  26,  1974  under 5G1553;  prepared by  Ciba-
   Geigy Corp.,  Greensboro, N.C.; CDL:94217-I)
                                    14
Roger, J.C.  (1973?)  Radioassay of  C  02  by Acid Neutralization and
   Subsequent Counting by Liquid  Scintillation. Method AG-250 undated.
   (Unpublished  study received Sep  26,  1974  under 5G1553;  prepared  for Ciba-
   Geigy Corp.,  Ardsley,  N.Y.; CDL:94216-QJ
                                                                 14
Roger, J^C.; Counselman,  C.J.  (1973)  Goat Metabolism Study with   C-CGA-24705
   and   C-CGA-17020.  (Unpublished study received  Mar 26, 1975 under 5F1606;
   prepared by Ciba-Geigy Corp.,  Greensboro, N.C.;  CDL:94378-J)
                                                                 14
Roger, J.C.; Counselman,  C.J.  (1973)  Goat Metabolism Study with   C-CGA-
   24705 and   C-CGA-17202.   (Unpublished study received Sep 26,  1974 under
   5G1553; prepared  by Ciba-Geigy Corp.,  Greensboro,  N.C.; CDL:94217-H)

Ross, J.A.;  Balasubramanian,  K.  (1975)  Validation of Method AG-277 for the
   Determination of  Corn  CGA-24705  Metabolites as CGA-37913 and CGA-49751: GAAC-
                                      175

-------
   75013.  (Unpublished study received Mar 26, 1975 under 5F1606; prepared  by
   Ciba-Geigy Corp., Greensboro, N.C.; CDL:94380-V)

Rowe, G.R.; O'Connor, B.P.; Patterson, T.M.  (1976).  Metolachlor  for  control  of
   'summer grasses' in maize.  Pages 135-137, _In Proceedings of the Twenty-
   Ninth New Zealand Weed and Pest Control Conference; Aug 3-5, 1976;
   Chnstchurch, New Zealand.   Hamilton, N.Z.: Ruakura Agricultural  Research
   Center for the Ifew Zealand Weed and Pest Control Society, Inc.

Ruscoe, A. W.; Harvey, R. G. (1976) Annual weed control in sweet  corn.  Page
   182, In Proceedings of the North Central Weed Control Conference;  December
   9-11, 1975; Milwaukee, Wisconsin.   Cmaha, Neb.; by the Stauffer Chemical
   Company for the North Central Weed Control Conference.

Ruttunan, J.; Gfeller, W. (1974) Tolerability Trial in Laying-Hens with CGA 24'
   705: 28 Day Feeding Study: AC 9.26/9.24; LH 10 CRA.  (Unpublished  study
   received Sep 26, 1974 under 5G1553; prepared by Ciba-Geigy Ltd., St. Aubin,
   Switzerland; CDL:94216-H)

Sachsse, K. (1973a) Irritation of Technical CGA-24705 in the Rabbit Eye:
   Project No. Siss 2979.   (Unpublished study received Sep 26, 1974 under
   5G1553; prepared by Ciba-Geigy Ltd., Basle, Switzerland; CDL:112840-G)

Sachsse, K. (1973b) Skin Irritation in the Rabbit after Single Application  of
   Technical CGA-24705: Project No. Siss 2979.  (Unpublished study received Sep
   26, 1974 under 5G1553; prepared by Ciba-Geigy Ltd., Basle, Switzerland;
   CDL:112840-1)

Sachsse, K. (1977) Skin Sensitizing (Contact Allergenic) Effect in Guinea Pigs
   of Technical CGA-24705. Project No. Siss 5726.   [Unpublished  study received
   Oct 17, 1977; prepared by Ciba-Geigy Ltd., Basle, Switzerland]

Sachsse, K.;  Ullinan, L (1974a) Acute Inhalation Toxicity of Technical CGA-24705
   in the Rat: Project No. Siss 3516.   (Unpublished study received Sep 26,
   1974 under 5G1553; prepared by Ciba-Geigy Ltd., Basle, Switzerland;
   CDL:112840-L)

Sachsse, K.;  Ullman, L. (1974b) Acute Toxicity to Rainbow Trout,  Crucian Carp,
   Channel Catfish, Bluegill, and Guppy of Technical CGA-24705: Project No.
   Siss 3516.  (Unpublished study received Sep 26, 1974 under 5G1553; prepared
   by Ciba-Geigy Ltd., Basle, Switzerland; that includes a cable  from Ciba-
   Geigy Corp., Greensboro, N.C. on fish name change;  CDL:112840-N)

Sarpe, N.; Tomoroga, P.;  Segarceanu, 0.; Apostol, V. (1975).  The effect of
   Triflurolin, Butylate, Nitroaniline (Profuralin) and Metetilachlor combined
   with Metribuzin, Chlorbromuran and other herbicides in controlling weeds in
   soybeans and sunflowers.  Compte Rendu de la 8th Conference du Columa
   1975:599-610.

Schenker, M.  (1974) CGA 24705:  Total Residues in Milk and Tissues of Swiss
   Cows: Switzerland 1973:  AC 2.53 RVA 81/74.  (Unpublished study received Jan
   19, 1977 under 7F1913; prepared by Ciba-Geigy Ltd., Basle, Switzerland;
   CDL:95747-F)
                                   176

-------
Schenker, M.  (1975a) CGA 24705:  Determination of the Degradation Product CCA
   49751 in Chicken Liver:  Switzerland 1973:  RVA 02/75.   (Unpublished study
   received Jan 19, 1977 under 7F1913; prepared by Ciba-Geigy Ltd., Basle,
   Switzerland; CDL:95747-1)

Schenker, M.  (1975) CGA 24705: Determination of the Degradation Product CGA
   49751 in Cow Tissues and Milk: Switzerland 1973: AC 2.53; RVA 01/75.
   (Unpublished study received Jan 19, 1977 under 7F1913; prepared by Ciba-
   Geigy Ltd., Basle, Switzerland; CDL:95747-H)

Schnappinger, M.G.; Higgins, E.R.; Pruss, S.W. (1975) Annual grass and
   broadleaf  control in corn and soybeans with CGA-24705. Pages 44-48, In
   Proceedings of the Twenty-Ninth Annual Meeting of the Northeastern Weed
   Science Society; Jan 7-9, 1975; New York City.   Salisbury, Md.: University
   of Maryland, Vegetable Research Farm.

Schnappinger, M.G.; Pruss, S.W.; Higgins, E.R. (1976). CGA-24705 combinations
   for annual grass and broadleaf weed control in soybeans.  Pages 7-12, In
   Proceedings of the Northeastern Weed Science Society.

Schroter, R.  (1963) Reductions with Raney nickel catalysts.  Translated and
   revised by I. Salminen.  In Newer Methods of Preparative Organic Chemistry.
   New York:  Interscience Publishers, pp. 61-101.  (A translation of: Neuere
   Methoden der Praparativen Organischen Chemie.  Weinheim,  [Germany]:  Verlag
   Chemie.)  Also In unpublished report received Mar 27, 1975 under 5F1606;
   Prepared by Ciba-Geigy Corp., Greensboro, N.C.; CDL:94382-G)

Scibor,,G. (1977a) Report to Ciba-Geigy Corporation: Eye Irritation Tests with
   Dual^ 8E in Albino Rabbits: IBT No. 8530-10822.   (Unpublished study
   received Nov 8, 1977 under 100-EUP-59; prepared by Industrial Bio-Test
   Laboratories Inc., for Ciba-Geigy Corp., Greensboro, N.C.; including
   Addendum D — Validation by Ciba-Geigy Corp.; CDL:232191-D

Scibor, G. (1977b).Report to Ciba-Geigy  Corporation:  Primary Skin Irritation
   Test with  Dual l  '8E in Albino Rabbits: IBT No. 8530-10822.   (Unpublished
   study received Nov 8, 1977 under 100-EUP-059; prepared by Industrial Bio-
   Test Laboratories, Inc. for Ciba-Geigy Corp., Greensboro, N.C., including
   Addendum E — Validation by Ciba-Geigy Corp.; CDL:232191-E)

Sein, A.L.; Jennings, V.M. (1976).  Soybean herbicide evaluations across Iowa
   in 1975.   Pages 54-58, In Proceedings of the North Central Weed Control
   Conference; December 9-11, 1975; Milwaukee, Wisconsin.    Omaha, Neb.; by  the
   Stauffer Chemical Company for the North Central Weed  Control  Conference.

Selleck, G.W.; Sanok, W.J. (1977).  Herbicides for weed  control  in sweet corn
   and cabbage.  Pages 256-260, In Proceedings of  the Thirty-First Annual
   Meeting of the Northeastern Weed Science Society; Jan 4-6;  Baltimore,
   Maryland.   Salisbury, Md.
                                     177

-------
Selleck, G.W.; Weber, L.E. (1976).  Herbicide trials for yellow nutsedge  in
   potatoes on Long Island.   _In Proceedings of the Thirtieth Annual Meeting of
   the Northeastern Weed Science Society; Jan 6-8, 1976; Boston, Massachusettes

Selleck, G.W.; Weber, L.E.; Sanok, W.J.  (1977).  Herbicides for control of
   yellow nutsedge in potatoes,  _In Proceedings of the Thirty-First Annual
   Meeting of the Northeastern Weed Science Society; Jan 4-6; Baltimore,
   Maryland, Salisbury, Md.

Sunoneaux, B. (1972a) Extraction of CGA-10832 Residues from Soil.  Method AG~
   219 dated Oct 5, 1972.  (Unpublished study received Jan 19, 1977 under
   7F1913; prepared by Ciba-Geigy Corp., Ardsley, N.Y.; CDL:95748-H)
                                                   14
Srmoneaux, B. (1972b) Measurement of Total Organic   C in soils by
   Combustion.  Method AG-218 Dated Oct 5, 1972.  (Unpublished study received
   Jan 19, 1977 under 7F1913; prepared by Ciba-Geigy Corp., Ardsley, N»Y.;
   CDL:95748-G)

Simoneaux, B.; Hermes, P. (1973a) Extraction of CGA-10832 Residues from Soil.
   Method AG-254 dated Aug 10, 1973.  (Unpublished study received Kov 25, 1975
   under 6G1708; prepared for Ciba-Geigy Corp., Ardsley, N.Y.; CDL:94877-M)

Simoneaux, B.; Hermes, P. (1943b) Extraction of Triazine Residues from Soil.
   Method AG-255 Dated Aug 10, 1973.  (Unpublished study received Sep 26, 1974
   under 5G1553; prepared for Ciba-Geigy Corp., Ardsley, N.Y.; CDL:94216-S)

Simoneaux, B.; Roger, J.C. (1972) Blending of Soils and Homogenization of
   Biological Materials for Radioassay and Extraction.  Method AG-223 dated Oct
   5, 1972.  (Unpublished study received Sep 26, 1974 under 5G1553; prepared
   for Ciba-Geigy Corp., Ardsley,N.Y.; CDL:94216-P)

Skipper, H.D.; Gossett, B.J.; Smith, G.W. (1976) Field evaluation and soil
   residual characteristics of CGA-24705 and Alachlor.  Pages 418-422, In
   Proceedings of the Twenty-Ninth Annual Meeting of the Southern Weed Science
   Society; Jan 27-29, 1976;  Dallas, Texas.   Raleigh, N.C. Glover Printing for
   the Southern Weed Science Society.

Smith, K.S. (1977) Report: Catfish Bioaccumulation Study Following Exposure to
     C-Metolachlor in a Soil/Water/Fish Ecosystem. 7E-6506;   (Unpublished
   study received Feb 6, 1978 under 100-583; prepared by Cannon Laboratories,
   Inc. for Ciba-Geigy Corp., Greensboro, N.C.; CDL:232789-U)

Smith, S.H.; Adler, G.L. (1978) Final Report to Ciba-Geigy Corporation: Three-
   Generation Reproduction Study with CGA-24705 Technical in Albino Ratss  IBT
   No. 8533-07928.  (Unpublished study received Jan 18, 1978 under 7F1913;
   prepared by Industrial Bio-Test Laboratories, Inc. for Ciba-Geigy Corp.;
   including Audit Report No. 6 prepared by Ciba-Geigy Corp., Greensboro, N0C.,°
   CDL:96718-A; 96718-B)

Studt, D.M.; Jennings, V.M. (1976).  Corn herbicide evaluations across Iowa in
   1975.  _ln Proceedings of the North Central Weed Control Conference; "Dec 9-
   11, 1975; Milwaukee, Wisconsin.  Cmaha, Neb.; by the Stauffer Chemical
   Company for the North Central Weed Control Conference: Vol 30: 146-150.
                                    178

-------
Sumner, D.D.  (1978a) Audit Report  Dated Ifov  21, 1975:  28-Eay Mouse Pilot  Study
   with CGA-24705  (Technical).   (Unpublished study received Feb 16,  1978  under
   100-583; IBT No. 622-07857; prepared by Ciba-Geigy  Corp., Greensboro,  N.C.;
   CDL:232855-C)

Sumner, D.D.  (1978b) Addendum  to Audit Report Dated Jan 12, 1978:
   Carcinogenic Study with CGA-24705 Technical in Albino Mice.  (Unpublished
   study received  Feb 16, 1978 under 100-583;IBT No. 622-07925; prepared  by
   Ciba-Geigy Corp., Greensboro, N.C.; CDL:232855-A)

Sumner, D.D.  (1974) Extraction of  Humic Acid and Fulvic Acid Fractions from
   Soil Containing Non-extractable  C - Residues.  Method AG-268 dated Aug
   13, 1974.  (Unpublished study received Mar 26. 1975 under 5F1606; prepared
   by Ciba-Geigy Corp.> Greensboro, N.C.; CDL:94385-Y)

Sumner D.D.;  Cassidy, J.E. (1974a) A Comparison of ^14C-CGA-24705 Corn    ,.
   Biosynthesized  Metabolites with Those in  the Excreta of Goats Fed the   C-
   CQrmGAAC-74055.  (Unpublished  study received Jan 19, 1977 under 7F1913;
   prepared by Ciba-Geigy Corp., Greensboro, N.C.; CDL:95750-D)

Sumner, D.D.; Cassidy, J.E.  (1974b) The Metabolism of CGA-24705 in Corn:  GAAC-
   74050.  (Unpublished study received Jan 19, 1977 under 7F1913; prepared by
   Ciba-Geigy Corp., Greensboro, N.C.; CDL:95750-C)

Sumner, D.D.; Cassidy, J.E.  (1974c) The Uptake and Distribution of 014C-
   CGA-24705  from  Soil in Greenhouse Grown Corn: GAAC-74015.  (Unpublished
   study received  Jan 19, 1977 under 7F1913; prepared by Ciba-Geigy Corp.,
   Greensboro, N.C.; CDL:95750-A)
                                                                     14
Sumner, D.D.; Cassidy, J.E.  (1974d) The Uptake and Distribution of fi-  C-
   CGA-24705  in Field Grown  Corn:  GAAC-74022.  (Unpublished study received Mar
   26, 1975 under  5F1606; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:94385-C)

Sumner, D=D,; Cassidy, J.E.  (1974e) The Uptake of £-14C-CGA-24705 and Its
   Aged Soil  Degradation Products  in Rotation Carrots: GAAC-74112.
   (Unpublished study received Mar 26, 1975  under 5F1606; prepared by Ciba-
   Geigy Corp,, Greensboro,  N.C.;  CDL:94385-K)
                                                    14
Sumner, D.Dc,- Cassidy, J.E.  (1974f) The Uptake of fi-  C-CGA-24705 and Its
   Aged boil  Degradation Products  in Rotation Oats: GAAC-74085.  (Unpublished
   study received  Mar 26, 1975 under 5F1606; prepared  by Ciba-Geigy Corp.,
   Greensboro? N.C.; CDL:94385-I)

Sumner, D.D,? Cassidy, J.E.  (1974g)  The Uptake of ;z$-14C-CGA-24705 and Its
   Aged Soil  Degradation Products  in Rotation Soybeans:  GAAC-74113.
   (Unpublished study received Mar 26, 1975  under 5F1606; prepared by Ciba-
   Geigy Corp., Greensboro,  N.C.:  CDL:94385-L)
                                    179

-------
Sumner, D.D.;  Cassidy, J.E.  (1974h)  The Uptake of £-  C-CGA-24705 and Its
   Aged Soil Degradation Products in Rotation Wheat:  GAAC-74071.
   (Unpublished study received Mar 26, 1975 under 5F1606; prepared by Ciba-
   Geigy Corp., Greensboro, N.C.; CDL:94385-H)

Sumner. D.D.;  Cassidy J.E. (19741) Uptake of Nonextractable Soil Metabolites of
   0-  C-CGA-24705 by Carrots:  GAAC-74057.  (Unpublished study received
   Mar 26, 1975 under 5F1606; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:94385-F)

Sumner. D.D.;  Cassidy J.E. (1974J) Uptake of Nonextractable Soil Metabolites of
   0-  C-CGA-24705 by Soybeans:  GAAC-74056.  (Unpublished study received
   Mar 26, 1975 under 5F1606; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:94385-E)

Sumner. D.D.;  Cassidy J.E. (1974k) Uptake of Nonextractable Soil Metabolites of
   0-  C-CGA-24705 by Winter Wheat:  GAAC-74058.    (Unpublished study
   received Mar 26, 1975 under 5F1606; prepared by Ciba-Geigy Corp.,
   Greensboro, N.C.; CDL:94385-G)

Sumner, D.D.;  Cassidy, J.E.  (1975a) The Degradation of CGA-24705 in a Field
   Soil:  GAAC-75022.  (Unpublished study received Mar 26, 1975 under 5F1606;
   prepared by Ciba-Geigy Corp., Greensboro, N.C.; CDL:94385-N)
                                                                      14
Sumner, D.D.;  Cassidy, J.E.  (1975b) The Uptake and .Distribution of 0-  C-
   CGA-24705 from Soil in Greenhouse Grown Soybeans:  GAAC-75039.
   (Unpublished study received Nov 26, 1975 under 6G1708; prepared by Ciba-
   Geigy Corp., Greensboro, N.C.; CDL:94984-G)

Sumner, D.D.,  Szolics, I.M.; Cassidy, J.E. (1976) Degradation of CGA-24705 In
   Soil Report No. ABR-76057, Biochemistry Dept. Agricultural Chem. Division,
   Ciba-Geigy Corp., Greensboro, N.C., Issue Date: Oct 15, 1976.

Sumner, D.D.,  Szolics, I.M.; Cassidy, J.E. (1976) Degradation of CGA-24705 in
   Soil. ABR-76057.   (Unpublished study received Feb 6, 1978 under 100-583;
   prepared by Ciba-Geigy Corp., Greensboro, N.C.; CDL:232789-V)

Sumner, D.D.;  Thomas, R.D.; Cassidy, J.E. (1975) Structure Elucidation of the
   Metabolites of CGA-24705 in Corn: GAAC-75012.  (Unpublished study received
   Mar 26, 1975 under 5F1606; prepared by Ciba-Geigy Corp., Greensboro, N.C.;
   CDL:94378-F)

Taylor, T.D. (1974) Duration of Biological Activity of CGA-24705.
   (Unpublished study received Mar 27, 1975 under 5F1606; prepared by Ciba-
   Geigy Corp., Greensboro, N.C.; CDL:94376-D)

 [Texas A & Mj  Cottonseed Products Research Laboratory (1966) Description of
   Bench Scale Solvent Extraction Process for Soybeans.   (Unpublished study
   received Nov 26, 1975 under 6G1708; prepared by the Texas Engineering
   Experiment Station, College Station, Tex.; for Ciba-Geigy Corp., Greensboro,
   N.C.; CDL:94877-U)
                                    180

-------
         pson, L. Jr. (1976).  New herbicides.  Weeds Today 7(1): 27-28.
           v   *: Jr''' Taylor' T-D. (1976).  CGA-24705 plus procyazine— a new
        Centr i  u°n tOr Weed contro1 in CO"1-  Page 153, In Proceedings of the North
                     c°ntrol Conference; December 9-11, 1975; Milwaukee, Wisconsin.
         ma    wn
        r«ni-a'i ^  I by the stauffer Chemical Conpany for the North Central Weed
        control Conference .
                         L. (1975)  Complete Analysis of CGA-24705 Technical by Gas
        r                Method pA-69 dated Sep 23, 1975.  (Unpublished study
        received NOV 23' 1976 under 100-587; prepared by Ciba-Geigy Corp.,
        Greensboro, N.C.; CDL:226955-B)

     Pruslow Farms Incorporated (1974a)  Eight-Cay Dietary LC_— Bobwhite Quail
        iechnical CGA-24705:   Project No.  108-110.  (Unpublished study received Sep
        ™  TT-,n^nder 5G1553' Prepared  for Ciba-Geigy Corp.,  Greensboro, N.C.;
        CULi: 11/840— P)
    Truslow Farms Incorporated (1974b)  Eight-Day Dietary LCcn— Mallard Ducks
        iechnical CGA-24705:   Project No.  108-111.   (Unpublished study received Sep
              "         5G1553; P^P31^  for Ciba-Geigy Corp.,  Greensboro,  N.C.;
    Tryzna,  E.;  Paa, H.  (1976)  Report to Ciba-Geigy Corporation:   Acute  Dermal
       Toxicity  Study with CGA-24705 6E (1:10 dilution)  in Albino  Rabbits:   IBT
       8530-0859.   (Unpublished study received Jan 19,  1977 under  7F1913; prepared
       by  Industrial Bio-Test Laboratory,  Inc. for Ciba-Geigy  Corp.,  Greensboro,
       N.C.;  CDL:95768-F)

*   Tweedy,  B.B.  (1974)  CGA-24705-Corn:  Summary of Residues Observed and
       Analytical  Methods  Used:   GAAC-74061.   (Unpublished study that includes
       tests  number AG-A 2967,  AG-A 2982.   AG-A 3132, AG-A 2972, AG-A 3057,  AG-A
       3005,  AG-A  3083,  AG-A 3153,  AG-A 3141,  AG-A 3103, AG-A  3137, AG-A 3070,  AG-A
       3255,  AG-A  2974,  AG-A 3057 II, AG-A 3288,  AG-A 3289,  AG-A 3327, AG-A  3328;
       received  Sep 26,  1974 under 5G1553;  prepared by  Ciba-Geigy  Corp.,
       Greensboro,  N.C., CDL:94216-A)

*   Tweedy,  B.C.;  Mattson,  A.M.  (1974)  CGA-24705:   Corn Summary of Residues
       Observed and Analytical  Methods  Used:   GAAC-74067.   (Unpublished  study  that
       includes studies  AG-A-2967,  AG-A-2972,  AG-A-2982, AG-A-3057, AG-A-3103,  AG-A-
       3132,  AG-A-3137, AG-A-3141,  AG-A-3255,  AG-A-3289, AG-A-3299, AG-A-3327,  AG-A-
       3005,  AG-A-3083, AG-A-3153,  AG-A-2974,  AG-A-3057  II,  AG-A-3070, AG-A-3288,
       AG-A-3298, AG-A-3325,  AG-A-3326,  AG-A  3406;  received Mar 26, 1975 under
       5F1606; prepared by  Ciba-Geigy Corp.,  Greensboro, N.C.  CDL:94379-A)

    Ueda, A.  (1976).  The use of  Metetilachlor-Metribuzin  in soybean  cultivation.
       XI Seminario  Brasileiro  De Herbicides  E Ervas Daninhas, Resumes,  Londrina,
       Parana, 1976: 81-82.

o   U.S.  Department  of Agriculture  (1941)  Climate  and Man. Washington, D.C.  U.S.
       Government Printing Office.
                                        181

-------
o  U.S. Department of Agriculture's  Statistical  Reporting Service (1972) Usual
      Planting and Harvesting Dates. Washington,  D.C.:  U.S.  Government Printing
      Office.  (Report contains  information  on usual  planting and harvesting dates
      for major field and  seed  crops.)

o  U.S. Department of Agriculture  (1975)  Control of  Water Pollution from Cropland:
      Vol. I. A Manual for Guideline Development.  By the Agricultural Research
      Service. Washington, D.C.: U.S. Government Printing Office.

o  U.S. Food and Drug Administration (1975)  Paraquat:   1,1'dimethyl
      4,4'bipyridinium ion.  _In Pesticide Analytical Manual:  Vol.  II:  Methods
      for Individual Pesticides Residues.  [Rockville,  Md.]:  U.S.  Department of
      Health,Education, and Welfare.  Sec.  180.205 (Also In  unpublished report
      received Nov 8, 197.7 under 100-EUP-59  prepared by Ciba-Geigy  Corp.,
      Greensboro, N.C.; CDL:  232192-Q)

   Vengris, J. (1975) Annual Weed  control in field corn 1974:   Abstract.  Pages 68-
      70, Ir\ Proceedings of the Twenty-Ninth Annual  Meeting  of the  Northeastern
      Weed Science Society; Jan 7-9, 1975;  New York  City.   Salisbury, Md:
      University of Maryland, Vegetable Research Farm.

   Vengris, J. (1977a) Annual weed control  in alfalfa new seedlings.  Pages 99-103,
       _In Proceedings of the Thirty-First Annual Meeting of  the Northeastern Weed
      Science  Society; Jan 4-6, 1977; Baltimore,  Maryland.    Salisbury, Md.

   Vengris, J.  (1977b) Annual  weed  control  in field corn.   Pages 1-5, In
      Proceedings of the Thirty-First Annual Meeting of the  Northeastern Weed
      Science  Society; Jan 4-6, 1977; Baltimore,  Maryland.    Salisbury, Md.

   Venturella, L.R.C.; Filho, O.R.; Davis, G.G.  (1976).   Various herbicides tested
      for control of weeds with soybeans  (Glycine maxmerril).  XI Seminario
      Brasileirio De Herbicides E  Erauas  Danimhas, Resumos,  20-22 July 1976,
      Londrina, Parana: 71.

   Vial, J.; Ostrousky, V; Metz, F.X. (1975).  Weed  control  in maize  fields,
      combination of Metetilachlor + Atrazine -  a new solution to the problem of
      controlling Graminacae and dicotyledons in maize  fields.  Compte Rendu de la
      8e Conference du Columa,  1975: 487-497 (comite francais  de lutte contre las
      mauvaises herbes).

*  Vilkas, A.G.  (1976) Acute Toxicity of CGA-24705  Technical  to the  Water Flea
      Daphnia  magna.  Received  Nov 23, 1976  under 100-587.   (Unpublished study
      prepared by Aquatic  Environmental Sciences,  Union Carbide Corp. for Ciba
      Geigy Corp., Greensboro,  N.C.; CDL:226955-C)

*  Vogel, C.;  Aebi, R., inventors; Ciba-Geigy Corp., Assignee  (1976).  Plant
      growth regulating agent.  U.S. patent  3, 937,  730.  Feb 10: 8 p. Int. CI ,
      C07C 103.34.

*   Vogel, C.;  Aebi, R; inventors;  Ciba-Geigy Corp.,  Assignee (1973)
      Haloacetanilides acting on plant growth.   German  patent 2, 328, 340.  Dec
      20: 50 p. Int. CI. C07C 103.38.
                                       182

-------
WatschJce, T.L.; Waddington,  D.V.;  Forth,  C.L.  (1975)   Growth regulation in tall
   fescue.  Pages  397-402,  In Proceedings of the Twenty-Ninth Annual Meeting of
   the Northeastern Weed  Science  Society;  Jan 7-9,  1975;  New York City.
   Salisbury, Md.:  University of Maryland,  Vegetable Research Farm.

Watschke, T.L.; Wehner, D.J.;  Duich,  J.M.  (1976) Pre  and  postemergence
   crabgrass control  in turf.   Pages  358-366;  In Proceedings of the Thirtieth
   Annual Meeting  of  the  Northeastern Weed Science  Society;  Jan 6-8, 1976;
   Boston, Massachasetts.   Salisbury, Md:  University of Maryland.  Vegetable
   Research Farm.

Watts, R.  (July 1976)  Memo from Chemist,  Chemistry  Branch, RD, OPP, to
   Cumnings, J., Chief, Chemistry Branch,  RD,  OPP,  concerning Method Trial for
   Metabolites  of  Metolachlor and Their Hydrolytic  Products CGA-37913 and CGA-
   49751  in Corn and  Beef Liver [PP#5F1606]  July 28,  1976.

Wills, G.D.  (1976) Effect of soil incorporated herbicides on cotton and purple
   nutsedge. Pages 110-114,  _In Proceedings of the Twenty-Ninth Annual Meeting
   of  the Southern Weed Science Society;  Jan 27-29, 1976; Dallas, Texas.
   Raleigh, NC; Glover Printing for the Southern Weed Science Society.

Wolf,  M.  (1974) [Letter on Synthesis of £-14C-CGA-37913]  to Dr. J.A. Ross,
   Dated  Jun 3, 1974. (Unpublished letter received  Feb 6, 1978 under 100-583;
   CDL:232789-W)

Wolf,  M.;  Sumner,  D.D. (1974a) Statistical Methods  in the Measurement of
   Radioactivity.  Method AG-276 dated Jan 31, 1974.   (Unpublished study
   received Mar 26,  1975  under 5F1606; prepared by  Ciba-Geigy Corp.,
   Greensboro,  N.C.;  CDL:94380-<2)

Wolf,  M.:  Sumner,  D.D. (1974b) Statistical Methods  in the Measurement of
   Radioactivity.  Method AG-260 dated.   (Unpublished study prepared by Ciba
   Geigy  Corp., Greensboro, N.C.; CDL:94380-0)
                                                *U S GOVERNMENT PRINTING OFFICE: I960 341-085/3949
                                      18 3

-------