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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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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