vv EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9444.03(84)
TITLE: Toxicity of 2,4-D Waste
APPROVAL DATE: 4-10-84
EFFECTIVE DATE: 4-10-84
ORIGINATING OFFICE: Office of Solid Waste
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REFERENCE (other documents):
OSWER OSWER OSWER
fE DIRECTIVE DIRECTIVE Di
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PART 261 SUBPART D - LISTS
DOC: 9444.03(84)
Key Words:
Regulations
Subj ect:
Addressee:
Source Doc:
Originator:
Date:
Summary:
Toxicity of 2,4-D Waste
40 CFR 261.24, 261.33
Toxicity of 2,4-D Waste
•John D. Nalewaja, President, Weed Science Society of America
c/o Agronomy Department, North Dakota State University, Fargo,
ND 58105
#9444.03(84)
John H. Skinner, Director, Office of Solid Waste
4-10-84
2,4-D and its salts are listed under the hazardous waste identification
regulations because 2,4-D is toxic to mammals and exhibits acutely toxic
effects at the mg/1 level in a variety of aquatic species.
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Mr. John D. Nalevaja, President x RE: SMBASC1A32
weed Science Society of Anerica
c/o Agronomy Department
North Dakota State University
Pargo, NO 58105
Dear Mr. Nalewajat
I an writing in response to your letter of March 20, 1984,
and the resolution of the Weed Science Society of America
requesting the removal of 2,4-D waste from regulation undsr
the Resource Conservation and Recovery Act (RCRA).
The toxic properties of 2,4-D were evaluated by the RPA's
Office of Drinking Water as part of the process leading to
the development of the National Interia Primary Drinking
Water Standards (MIPDWS). Inclusion of 2,4-D in the list of
toxicants regulated under 40 CPR 261.24 and 261.33 of the RCRA
regulations was based on the evaluation th-it was conducted
in support of the ttlPDW!?.
The HIPDWS for 2,4-D was derived assuming that the lowest
long term levol with minimal or no effects for the rat and the
dog is 50 and 8 mg/kg/day respectively. Based on these value*,
a "safe level" for man was derived of 1.12 rag/nan/day. .{See
National Intoria Primary Drinking Water Regulations, EPA-
570/9-76-003* Environmental Protection Agency, Office of Water
Supply). Verschueren (Handbook of Environmental Data on
Organic Chemicals, Van Noatrand Roinhold, New York, NY, 1583)
indicates that 2,4-0 la significantly toxic to namnals (i.e.,
oral rat LD50 300-1000 mg/kg, oral mouse LD50 375-521 wg/kg,
oral dog LD50 100 sag/kg). In addition* 2,4-D exhibits acutely
toxic effects at the mg/1 level in a variety of aquatic Apecias
which indicates that its uncontrolled release into the environ-
ment can also affect the ecological balance. . for the above
reasons, 2,4-D and its salts have been listed under the hazardous
waste identification regulations.
WH-562aiDPRIEDMAN:l3:S248:33?.4770:WSM Disk ASC1A32
AX400797
DUB DATEx 4/9/84
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You nay petition the Arjtjncy to Changs its regulations?
foe OSW to ronove 2,4-0 froa regulation underHtCRA, you must
demonstrate that the chemical would not pose a hazard to
human health or the environment even if iraproperly disposed
of. For acre information, please contact David Friedman of
my staff '(202-332-4770). Requests or inquiries related to th«»
NIPDWS ami their rationale should oe directed tot
Dr« Joseph Cotruvo
Director
Criteria and Standards Division
Office of Drinking Water, WH-550
401 H Street* SW
Washington, DC 20460
(202)332-7575
Sincerely yours,
John H. Skinner
Director
Office of Solid waste (WK-5623)
cet J. Cotruvo
Dec: AX
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