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 0 FINAL D DRAFT STATUS: [ 1 { 1 I 1 [ 1 A- Pending OMB approval B- Pending AA-OSWER approval C- For review &/or comment D- .In development or circulating headquarters REFERENCE (other documents): OSWER OSWER OSWER fE DIRECTIVE DIRECTIVE Di ------- 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. ------- 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 ------- 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 ------- |