United States
            Environmental Protection
            Agency
Office of
Pesticides and Toxic Substances
Washington OC 20460
July 1981
oEPA     Chloramben
           (3 amino 2,5-dichlorobenzoic acid)
           Pesticide Registration
           Standard

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Pesticide Registration Starvtord:  Chlorarober
      (3 amino 2,5-dichlorobenzoic acid)

                 May, 1961
 Office of  Pesticides and Toxic Substances

      Environmental Protection Agency
           401 M Street, S.W.

         Washington, D.C. 21460

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                             Project Support
           Denise M. Keehner
Project Manager  (SPRD)
           Jacob's Engineering Group Inc.    Hazard Evaluation
Technical Oversight:
           David Van Ormer
           Bertram Litt
           John Leitzke
           William Rabert
           Lionel Richardson
           David Severn
           Ram Rakshpal
           Charles Trichilo
           Charles Lewis
           James Yowell
Tfoxicologist  (HED)
Statistician  (HED)
Wildlife Biologist (HED)
Wildlife Biologist (HED)
Environmental Chemist (HED)
Environmental Chemist (HED)
Environmental Chemist (HED)
Residue Chemist (HED)
Plant Scientist (BFSD)
Plant Scientist (BFSD)

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                         TABLE  OF  (TOTEM'S
Chapter One

  How to Register Under  a  Registration  Standard

Chapter Two

  Agency Position on Chloramben

    1.  Introduction
    2.  Description of Chemical
    3.  Regulatory Position
    4.  Regulatory Rationale
    5.  Criteria for Registration Under the Standard
    6.  Acceptable Ranges  and Limits
            A. Manufacturing-use Chloramben
                    1. Tolerance Reassessment
            B. Ehd-Use Products
Paqe Number

   1-1



   2-1

   2-1
   2-1
   2-2
   2-2
   2-4

   2-5
   2-6
   2-7 through 2-14
Chapter Three
  Data Requirements and Data Gaps
   3-1
Chapter Four

  Product Chemistry of Chloramben

   Introduction

   A.  Manufacturing-Use Chloramben
       1.  Product Chemistry Profile
       2.  Data Caps
       3.  Topical Discussions

   B.  Soluble Concentrate Chloramben
       1.  Data Gaps
       2.  Topical Discussions

   C.  Flowable Concentrate Chloramben
       1.  Data Gaps
       2.  Topical Discussions

   D.  Etaulsifiable Concentrate Chloramben
       1.  Data Gaps
       2.  Topical Discussions

   E.  Granular Chloramben
       1.  Data Gaps
       2.  Topical Discussions
   4-1

   4-1

   4-1
   4-1
   4-2
   4-4

   4-7

   4-8

   4-10
   4-10
   4-10

   4-12
   4-12
   4-12

   4-14
   4-14
   4-15

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Chapter Five

  Environmental Fate of Chloramben                            5-1

    Use Profile                                               5-1

    A.  Manufacturing-Use Chloramben                          5-6
        1.  Environmental Fate Profile                        5-6
        2.  Acute Exposure Profile                            5-7
        3.  Data Gaps                                         5-7
        4.  Topical Discussions                               5-8

    B.  Formulations of Chloramben                            5-15
        1.  Exposure Analyses                                 5-15


Chapter Six

    Residue Chemistry  of  Chloramben                          6-1

    A.  Manufacturing-Use Chloramben                          6-1
        1.  Residue Chemistry Profile                        6-1
        2.  Data Gaps                                         6-2
        3.  Topical Discussions                               6-2

    B.  Formulations of Chloramben                            6-16
        1.  Data Requirements                                 6-16


Chapter Seven

    Toxicology of  Chloramben                                 7-1

    A.  Manufacturing-Use Chloramben                          7-1
         1.  Toxicology Profile                                7*-l
         2.  Onccqenic  Risk  Assessment                        7-3
         3.  Data Gaps                                         7-7
         4.  Topical  Discussions                               7-10

     B.   Soluble Concentrate Chloramben                       7-20
         1.  Tbxicology Profile                                7-20
         2.   Data Gaps                                         7-20
         3.  Topical  Discussions                               7-22

     C.   Flowable Concentrate Chloramben                      7-25
         1.   Toxicology Profile                               7-25
         2.   Data  Gaps                                        7-25
         3.   Topical  Discussions                              7-25

     D.   Emulsifiable Concentrate Chloramben                  7-27
         1.   Toxicology Profile                               7-27
         2.   Data Gaps                                        7-27
         3.   Tbpical  Discussions                              7-28

                                       ii

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    E.  Granular Chlorambpn                                   t-31
        1.  Toxicology Profile                                7-31
        2.  Data Gaps                                         7~31
        3.  Ttopical Discussions                               1-32
Chapter Eight

    Ecological Effects of Chloramben                          8-1

    A.  Manufacturing-Use Chloramben                          8-1
        1.  Ecological Effects Profile                        8-1
        2.  Data Gaps                                         8-2
        3.  Topical Discussions                               8-3

    B.  Soluble Concentrate Chloramben                        8-6
        1.  Ecological Effects Profile                        3-6
        2.  Risk Assessment                                   8-6
        3.  Data Gaps                                         8-7
        4.  Ttopical Discussions                               8-8

    C.  Flowable Concentrate Chloramben                       8-10
        1.  Ecological Effects Profile                        8-10
        2.  Risk Assessment                                   8-10
        3.  Data Gaps                                         8-11
        4.  Ttopical Discussions                               8-12

    D.  Emulsifiable Concentrate Chloramben                   8-13
       1.  Ecological Effects Profile                         8-13
       2.  Risk Assessment                                    8-13
       3.  Data Gaps                                          8-14
       4.  Ttopical Discussions                                8-14

    E.  Granular Chloramben                                   8-15
        1.  Ecologial Effects Profile                         8-15
        2.  Risk Assessment                                   8-15
        3.  Data Gaps                                         8-15
        4.  Ttopical Discussions                               8-15


Chapter Nine

    Case Bibliography                                         9-1

    Guide to Use of Bibliography                              9-1

    A.  Section I                                             9a-l
    B.  Section II                                            9b-l
                                      111

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           CHAPTER I:   HOW TO  REGISTER. OTDE? A REGISTRATION STANDARD

    1. Organization  of  Che Standard
    2. Purpose  of  che Standard
    3. Requirement co Re-register  Under che  Standard
    4. "Product  Specific"  Data  and  "Generic" Data
    5. Data Compensation Requirements  under  FIFRA 3(c)(l)(D)
    6. Obtaining Data co Fill  " Data Gaps";  FTFSA 3(c)C2)(3)
    7. Amendments  co che Standard

1.  Organization of  che Standard

This firsc chapter  explains /che purpose  of  a Registration Standard and
summarizes che legal principles involved  in registering or re-registering under
a Standard.  The  second chapter sets  forth  che  requirements chat oust be net to
obtain or  retain  registration  for  products  covered  by this particular
Registration Standard.  In  che remaining  chapters,  the Agency reviews the
available data by scientific discipline,  discusses  the Agency's concerns with
the identified potential  hazards,  and  logically develops Che  conditions and
requirements chat would reduce chose  hazards  to acceptable levels.

2.  Purpose of che Standard

Section 3 of che Federal  Insecticide,  Fungicide,  and  Rodenticide Act (TTJXA)
provides chat "no person  in any State  aay distribute,  sell, offer for sale,
hold for sale, ship, deliver for shipment,  or receive  (and having so received)
deliver or offer Co deliver, Co any person  any  pesticide which is not
registered with che Administrator  [of  EPA]."  To  approve che   registration of a
pesticide, che Administrator oust find, pursuant  to Section 3(c)(5)  chat:

    "(A)  its composition  is such as to warrant  che  proposed claims for it; ,

    (B)  its labeling and other oaterial  required co be  submitted comply
         with che requirements of chis Act;

    (C)  it will perform  ics intended  function  without  unreasonable  adverse
         effects on the environment; and

    (D)  when used in accordance with  widespread and commonly  recognized
         practice it will  aot  generally cause unreasonable  adverse effects
         on che environment."    *

In oaking chese findings,  che  Agency reviews a  wide range  of daca which
registrants are required  Co submit, and assesses che 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  councs:

Firsc, SPA and its predecessor agency, the  United States  Department  of
Agriculture (USDA), routinely  reviewed registration applitations  on  a "product
by  product" basis, evaluating  each product-specific application somewhat
independently.  In che review  of products containing similar components,  chere
was Little opportunity for a retrospective  review of che  full  range  of
pertinent daca available  in Agency files  and in the public literature. Thus che
".product by product" approach  vas ofcen inefficient and  sometimes resulcad in
inconsistent or incomplete regulacory  judgments.

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Second, over the '/ears,  as a  resulc  of  inevitable and continuing advances  in
scientific knowledge, sethodology,  and  policy,  the data base for aany
pesticides case co be considered  inadequate by  current scientific and
regulatory standards.   Given  the  Long history of pesticide regulation in
several agencies,  it  is  even  likely  that  naterials aay have been lost froa the
data files.  When  EPA issued  new  requirements for registration in 1975 (40 CJR
162) and proposed  new guidelines  for hazard testing in 1978 (43 FR 29636, July
10, 1978 and 43 FR 37336,  August  2,  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,  Congress 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 product" approach,  the Agency decided  that a new, more
effective aethod of  review was needed.

A new review procedure  has  been developed.   Under 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 oust
be aet  to obtain or  retain full  registration or reregistration under Section
3(c)(5) of FITRA,  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 FURA Section 3(c)(l)(D).

The Standard will  also  serve  as a tool  for product classification.  As part of
the registration of  a pesticide product,  EPA aay classify each product for
"general use" or "restricted  use" [FITRA Section 3(d)j.  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  pesticide safely,  responsibly, and in accordance with label
directions.  A  restricted-use pesticide can have other regulatory restrictions
 •40 C7R I62.11(c)(5)l  instead of, or in addition to, the certified applicator
requirement.  These  other regulatory restrictions aay include such actions as
seasonal or  regional limitations  on use,  or a requirement for the aonitorlng of
residue levels  af-ter use. A pesticide classified for "general use," or not
classified  at  all, is available for use by any individual TOO 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 C7R 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 seated in the
 second chapter.

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3. Requirement  to Reregister TJr.dar  the  Standard

TITZA Section 3(g), as amended  in  1-973,  directs  EPA to reregister all currently
registered products as expeditiously  as  possible.   Congress also agreed  that
reregistration  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, oust  apply for reregistration.   His application aust contain proposed
labeling that complies with this Standard.

SPA 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  reregistration set  forth in the Guidance Package
which accompanies this Standard.

4. "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, Toxicology, Residue Chemistry,  and Ecological Effects.   These
determinations are based primarily on the data Guidelines proposed in 43 FR
29696, July 10, 1973; 43 FR 37336, August  22, 1978; and 45 FR 72948,  November
3, 1980, 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.   On 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  w«  have found are needed to
evaluate the registrability of  some products covered  by the Standard  aay 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 produc-  categories.  (See the
third chapter.)  The various kinds of data normally required  for  registration
of a pesticide product can be divided into tvo basic groups:

   A. Data that are product specific  , i.e. data  that  relates only to the
      the properties or effects of a  product with- a particular
      composition (or a group of products with closely similar
      composition); and

   3. 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

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registration or reregistration of any  product,  whether it is a sanufacturing-
use or end-use product, and without  regard  to  its intended use pattern, sust
submit or cite enough of  this kind of  data  to  allow E?A to evaluate the
product.  For such purposes, "product  specific" data on any product other than
the applicant's is irrelevant, unless  the ocher product is closely similar in
composition to the applicant's.   (Where  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 aay affect  efficacy and  where failure of efficacy could cause
public health problecs*

All other data needed to  evaluate pesticide  products concerns che 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 ID-50 of the active ingredient in  its  technical or purer grade; see
proposed 40 C7R  163.31-l(a), 43 F*.  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
C7R 163.32-1, 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 aalce end-use products with that use pattern.  Thus, for
example, a subchronic oral dosing study is  needed to evaluate the safety of any
aanufacturing—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  human 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)(3)]  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 tiae  he  reregisters  his product.  An
applicant  for  registration of  a  new product under this Standard nay similarly
request  approval  for only certain use patterns.

5.  2ata- Comoensation Requirements under FTT3A  2(c)(lHD)
 Under FIFSA Section 3(c)(l)(D),  an applicant for registration, reragistration,
 or amended registration sust offer to pay compensation for certain existing
 data  the Agency has used in developing the Registration Standard.  The data for
 which compensation oust be offered is all data which are described by all che
 following criteria:

    A. "he data --ere rirst submitted to i?A (or :o its aredecessor

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      agencies, UST3A  or  FDA),  on  or  after January L, 1970;

   3. The data, vare submitted  to  EPA (or  USDA or FT3A) by some other
      applicant or registant in support of an application for an
      experimental use permit, an amendment adding a new use to a
      registration, or for  registration,  or to support or maintain in
      effect an existing registration;

   C. They are the kind  of  data which are relevant to the Agency's
      decision to register  or  reregister  the  applicant's product
      under the Registration Standard,  taking into account the
      applicant's product's composition and intended use patrern(s);

   D. The Agency has  found  the data  to be valid  and  usable in reaching
      regulatory conclusions;  and

   £. They are not data  for which  the applicant  has  been exempted by
      FIFHA 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 reregistration of an already registered product under this
Standard, or for registration of a new product under this Standard,  accordingly
aust 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  FTFRA
Section 3(c)(l)(D)'.

An applicant would never  be required to offer to  pay for ''product specific"
data submitted by another firm.   In many,  if  not  in  aost cases,  data which is
specific to another firm's product will not suffice  to  allow EPA to  evaluate
the applicant's product,  chat is, will not  be useful  to  the  Agency in
determining whether the  applicant's product is registrable.   There aay be
cases, however, where because of close similarities  between  the  composition of
two or aore products, another  firm's data  aay suffice  co allow EPA co  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 reregistration  of  a  manufacturing—ise
product, and aach applicant for registration  or reregisfration  of  an end-use
product, who is not exempted by FTTSA Section 3(c)(2)(D),  aust  comply  with the
Section 3(c)(l)(D) requirements with respect  co each  item of  "generic'1  data
that relates Co his product's  intended uses.

A detailed description of :he procaduras  an applicant aust follow in applying
for rsregistration (or new  registration)  under this  Standard  is  found  in  the
Guidance Package for  chis Standard.

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5.  Obtaining 3aca :o -ill "T3ata Gaps";  7ITSLA  3(e)(2)(3)

Some of :he 
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amendment  to  Che  Standard, or aay deny  Che  application for registration on  the
grounds  chat  Che  proposed  product would  cause  unreasonable adverse effects  Co
the environment.   In  the former  case, when  additional  data have been
satisfactorily  supplied, and providing  that che data do not indicate the
potential  for unreasonable adverse effects,  the Agency will then amend the
Standard Co cover  che  nev  registration.

Each Registration  Standard is based upon all data  and  information available to
che Agency's  reviewers on  a particular dace  prior  to the publication date.
This "cut-off"  date is stated at the beginning  of  che  second chapter.  Any
subsequent data submissions and  any approved amendments will be incorporated
into che Registration  Standard by aeans  of  addenda,  which are available for
inspection at EPA  in Washington, O.C., or copies of  which aay be requested froa
che Agency.  When  all  che  present "data  gaps" have been filled and the
submitted data have been reviewed, che Agency will revise the Registration
Standard.  Thereafter, when the  Agency determines  that the internally
maintained addenda have significantly altered the conditions for registration
under che Standard, the document will be updated and re-issued.

While Che 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.

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                                   CHAPTER II


                         AGENCY  POSITICN  CN CHLOPAMBEN


  Introduction

This chapter describes  in detail  the Agency's  regulatory position on pesticide
products which contain  chloramben as the  sole  active ingredient.  The
regulatory position  adopted by the Agency incorporates a number of
considerations.  Foremost: among  these considerations is an analysis of the
registrability of chloramben based on the risk criteria found in Section
162.IK a) of Title 40 of the U.S.  Code of Federal  Regulations.   Following the
Aaency's statement on the registrability  of chloramben is the rationale for
this basic determination.

In addition to this decision, standards of  product composition, acute toxicity.
labeling, and use are established.  Applicants  for the registration of
chloramben products must meet these standards  to obtain registration.  The
rationale for establishing a particular standard follows  the  presentation of
the standard.  Regulatory actions  such as reouiring  protective  clothing during
application are prescribed, and additional  data are  requested.   The basis for
any regulatory action can be found by reading  the  rationale for the action,
which follows the chosen regulatory option.

In general, the scientific basis  for any  regulatory  action, including
establishing data requirements, can be found in the  disciplinary chapters.
References to Aoency guidelines for testing are provided  when appropriate.


 Description of Chemical

Chloramben is a herbicide used for the control of  a  variety of  annual grasses
and broadleaf weeds in agricultural and ornamental crops, both  in non-domestic
and domestic settings.  Chloramben is the common name  for 3-amino 2,5-
dichlorobenzoic acid.  Currently registered manufacturing-use products are
limited to Sodium Chloramben (the  sodium salt of chloramben)  and Methyl
Chloramben (the methyl ester of chloramben).

Chloramben formulated products are marketed under  the  trade names Araiben,
Vegiben, Weedone, and Ornamental Weeder.  These products  represent  a  wide  range
of product types (soluble concentrates, flowable concentrates,  emulsifiable
concentrates, and granulars) and contain a variety of  forms of  chloramben
(sodium chloramben, methyl chloramben, ammonium chloramben and  moncroethyl
ammonium chloramben).

Products containing mixtures of chloramben and other active ingredients are not
covered under this Standard.
                                      2-1

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 Regulatory Position for Chloramben

Chloramben, as described in  this Standard  nay be registered for sale,
distribution, reformulation  and use  in  the United States.  Considering all
information available  to the Agency  as  of  October 1, 1980, the Agency finds
that none of the risk  criteria found in Section 162.11(a) of Title 40 of the
U.S. Cede of Federal Regulations were met  or exceeded for Chloramben.

The Agency has determined  that Chloramben  does not cause an unreasonable
adverse effect with proper label directions and precautions.  Chloramben
products currently registered may be reregistered subject to the conditions
imposed.  New products may be registered under this Standard and are subject to
the same requirements.


 Regulatory Rationale  for  Chloramben

Chloramben was referred for  review to the  Rebuttable Presumption Against    *
Registration (RPAR) Program  in October  of  1980.  The referral of this pesticide
to the RPAR Program was based on an  oncogenicity study on technical Chloramben
(3-amino 2,5-dichlorobenzoic acid),  conducted by Gulf South Research Institute
(GSRI) for the National Cancer Institute (NCI).  This study indicates that
Chloramben administration  results in hepatocellular carcinoma in female mice.
The NCI study reports  statistically  significant incidences of hepatocellular
carcinoma in female mice receiving 10,000  and 20,000 ppn dietary doses of
chloramben.

This study was reviewed by the Environmental Protection Agency (EPA) and was
found to contain minor flaws in protocol and study conduct.  The Agency's
review indicates that  although the study is flawed, the NCI results do indicate
a clear positive result at the 20,000 ppm  dose in female mice, and that the,
study is adequate  for  risk assessment purposes.

Additional data were collected and reviewed by the Agency to complete the
assessment of the  oncogenicity of chloramben.  No other studies indicating
chloramben related chronic effects were identified, and an oncogenicity study,
completed  in 1978  by Huntington Research Center, reported no statistically
significant increases  in tumour incidence  in mice receiving dietary doses of
100, 1,000, and 10,000 ppm of chloramben.   In addition, a chronic feeding study
in rats completed  in 1979  by Litton  Bionetics reported no chloramben dose-
related chronic effects  in rats at dietary doses of 100, 1,000, and 10,000
ppm.  Available mutagencity  testing  (Anes  test) utilizing technical chloramben
yielded negative results.

A major concern regarding  any potential long-term exposure in humans to a
pesticide product  is the risk of developing delayed toxic effects, principally
cancer.  The results presented  in  the NCI  bioassay of chloramben are utilized
in the completion  of an oncogenic risk  assessment.  The results of this risk
assessment are  factored  into the decision  to proceed or not to proceed with a
presumption against the registration of chloramben.
                                       2-2

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 In order  to  assess  this  risk for exposure to chloramben, a worst-case  situation
 based on  the conclusions of the NCI bioassay of chloramben is utilized.   using
 die-NCI data as  the 'oasis for a risk assessment, vas obtain a potency of  1.05 x
         Reported  Incidence  of Hepatocellular Carcinoma in Female Mice

                                   Dose (ppm)

                0                  10,000                  20,000
             2/67  (0.03)        7/48  (0.15)              10/50 (0.20)
The dose-response relationship  assumed  in the risk analysis is that of the
linear multi-stage model.  The  lifetime probability of canc§r due to ingesting
chloramben has been determined  to  be  on the order of Ix 10"" (see chapter 7
for detailed determination).

For applicator exposure, a dietary exposure equivalent is calculated for risk
assessment.  Applicator exposure data were  not available on chloramben per se.
However, exposure studies involving pesticides used in a similar manner to
chloramben were available for extrapolation and use in an applicator risk
assessment.

The Agency assumed that the largest segment of die applicator population at
greatest risk dirough exposure  to  chloramben was applicators of
soluble/flowable concentrate products ii» soybeans.  Use of chloramben in
soybeans represents 96% of chloramben usage.   Both granular and
soluble/flowable concentrate products are currently registered for use in
soybeans.  Of these two formulation types,  die liquid  formulations present die
highest potential for significant  exposure.  The lifetime probability of cancer
due to chloramben application in soybeans of soluble/flowable concentrate
products has been determined to be on die order of Ix  10~ (see chapters 5 and
7 for detailed determination).  This  represents a worst-case assessment.
                                                                   _q
The Agency is 95%_confident that these  risk levels (dietary: Ix 10  ; and
applicator: Ix 10  ) will not be exceeded by die dose  (virtually safe dose)
as determined in chapters 5 and 7-

Section 3(c)(8) of die Federal  Insecticide, Fungicide, and Rodenticide Act
(FIFRA) directs die Agency not  to  initiate  a Rebuttable Presumption Against
Registration (REAR) action unless  die action is based  on a validated test or
other sigificant evidence raising  prudent concerns of   unreasonable  adverse
effects to man or die environment.  Human exposure to  pesticides  through any
medium or pathway is a central  issue  in evaluating unreasonable adverse effects
of pesticide products.  It is die  Agency's  policy to attempt to reduce
exposure, whenever possible, to acceptable  levels widiout issuing an RPAR
action.

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The Agency determined that the existing data  base  on chloramben does not
support a Rebuttable.Presumption Against  Registration.  Results from the risk
assessment completed by the Agency, combined  with  the weight of the data base,
indicate that issuing a Rebuttable Presumption Against the Registration of
chloramben at this time would not be  prudent  regulatory policy.

The Agency thus decided to reregister all pesticide products containing
chloramben as the sole active ingredient, provided the conditions are met as
described under the  heading: "Criteria for Registration Under the Chloramben
Standard".  These conditions include  the  submission of applicator exposure data
on a typical liquid  formulation as a  data requirement.


 Criteria for Registration Under the  Chloramben Standard

To be subject to this Standard, chloramben products must:

         1. contain  chloramben as  the sole active  ingredient;

         2. be within acceptable standards of composition as specified;

         3. be within acute  toxicity  limits as specified;

         4. be labelled for  acceptable end-uses as specified; and

         5. bear required labeling as specified.

Manufacturing-use chloramben products must bear label directions for
formulation into acceptable  end-uses.

Applicants for registration  or reregistration of chloramben products under this
Standard must comply with all terms and conditions described in the following
sections,  including  commitment to  fill data gaps on a time schedule specified
by the  Agency and when  applicable  offer to pay compensation to the extent
required by 3(c)(l)(D)  and 3(c)(2)(D) of the Federal Insecticide, Fungicide,
and Rcdenticide Act  (FIFFA), as amended, 7 U.S.C.  136(c)(l)(D) and
136(c)(2)(D).  As discussed  in Chapter I, applicants for the registration of
chloramben products  under this Standard must contact the Agency for specific
instructions,  including updated  information on data requirements and companies
whose data must be cited  and to whom  compensation must be offered.
                                       2-4

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A.  Manufacturing-use Chloramben

   1.  Acceptable Range and Limits


                                 Summary Table

 Product Conposition                   Acute Toxicity        End-Use Patterns
Active Ingredient:                     Acute Oral:            Outdoor
   Any Percentage with appropriate       Category I-IV       terrestrial  uses
   certification of limits.                                   (food or nonfood)
                                       Acute Dermal:
                                         Category I-IV

                                       Acute Inhalation:
                                         Category I-IV

                                       Primary Eye:
                                         Category I-IV

                                       Primary Dermal:
                                         Category I-IV
          a. Product Composition Standards

Currently registered chloramben manufacturing-use products  include  the  sodium
salt of chloramben and the methyl ester of chloramben.  Manufacturing-use
chloramben products with any percentage of sodium or methyl chloramben  are
acceptable under this Standard with appropriate certification of limits.

The Agency has determined that information on the physical/chemical properties
of technical chloramben (3 amino 2,5-dichlorobenzoic acid) cannot be used to
fulfill product chemistry requirements for manufacturing-use sodium chloramben
or methyl chloramben.  Available data indicate that the physical/chemical
properties of sodium and methyl chloramben are different from the
physical/chemical properties of technical grade chloramben.  Information on the
physical/chemical properties of both sodium and methyl chloramben are required
in addition to information on technical grade chloramben (3 amino 2,5-
dichlorobenzoic acid).


          b. Acute Toxicity Limits

Manufacturing-use chloramben products with established acute toxicity category
I-IV ratings for each of the acute effects (acute oral, dermal, and inhalation
toxicity and primary eye and dermal irritation) are acceptable under this
Standard.
                                      2-5

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          c. Use Patterns

Manufacturing-use chloramben products must  be  labeled for formulation into end-
use herbicides intended for outdoor  terrestrial  uses (food or nonfood).

Chloramben is currently registered for  use  in  a  variety of food crops, and for
use in annual and perennial flowers, shrubs, and trees.

Tolerances have been established  for chloramben  use on the following crops:
soybeans, tomatoes, lima beans, corn, peanuts, beans (dry, edible), cantaloupe,
cucumbers, peppers, pumpkin, beans (snap) ,  squash, sunflower, and sweet
potatoes.

The Agency will consider additional  tolerances on food or feed crops provided
that applicants for the registration of the additional crop(s) submit a
petition(s) , supply appropriate residue data,  and demonstrate that the addition
of the tolerance(s) will not result  in  an unacceptable risk to the general
population.  Applicants must also demonstrate  that the. additional food-use
pattern(s) will not result in an  unacceptable  risk to applicators.

The Agency will accept applications  for additional tolerances because available
data indicate that the currently  estimated  dietary intake of chloramben per day
is .09% of the ADI (see Tolerance Reassessment) .

The Agency will consider additional  non-food,  terrestrial outdoor uses of
chloramben provided that applicants  for the registration of the additional
use(s) submit any additional data required  for the registration of the use, and
demonstrate that the use pattern  will not result in an unacceptable risk to
applicators.


   2.  Required Labeling

All manufacturing-use chloramben  products must bear appropriate labeling as
specified in 40 CFR 162.10.

Registrants have the option of  supplying requested rotational crop studies or
of placing the following prohibition on labels of all end-use products
containing chloramben:

                     "Do not rotate  to  other  crops"

   3.  Tolerance Reassessment

Tolerances of 0.1 ppm have been established for  residues of chloramben in all
food crops  for which chloramben is registered.  This level was originally
established at the limit of detectability of  chloramben.  The theoretical
maximum  residue contribution  (TMRC)  of  chloramben to the human diet is .013
mg/day.  This figure is adjusted  for the percentage of chloramben treated crops
to arrive at the maximum estimated chloramben  intake figure of .00022 mgAg/day
 (see Chapter 6 for full dietary exposure analysis).

The "No  Observable Effect Level"  (NOEL) in  dogs  was reported to be 25 mgAg
body weight  (Hazleton Laboratories,  0028).  The  acceptable daily intake (ADI)
calculated  from this figure is  .25 mgAg/day.  The maximum estimated chloramben
 intake per day is  .09% of the calculated ADI.


                                       2-6

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3.  Soluble Concentrate  Chloramben

   1.  Acceptable  Ranges and  Limits


                                  Summary Table

 Product Composition                Acute Toxicity        End-Use Patterns

Active Ingredient:                  Acute Oral:            Outdoor terrestrial
   Any percentage  with appropriate  Category III-IV      food-uses or nonfood
   certification of limits.
                                    Acute Dermal:
Inert Ingredients:                   Category III-IV
  Inert ingredients in food-use
  formulations must be cleared      Acute Inhalation:
  for such use under                 Category III-IV
  40 CFR 180.1001.
                                    Primary Eye:
Currently registered soluble         Category III-IV
concentrate products containing
23.4% Ammonium Chloramben           Primary Dermal:
are substantially  similar.           Category III-IV
         a.  Product Composition Standards

Currently registered chloramben soluble concentrate products  include  several
products containing 23.4% ammonium chloramben and one product containing  15.7%
ammonium chloramben and 47.2% monomethyl-ammonium chloramben.  The Agency has
determined that existing soluble concentrate products containing  the  ammonium
salt of chloramben are substantially similar.  The sole soluble concentrate
product containing a mixture of the ammonium and monomethyl ammonium  salts has
been determined to be unique.

Soluble concentrate chloramben products with any percentage of sodium
chloramben, ammonium chloramben, monanethyl-ammonium chloramben, or methyl
chloramben are acceptable for consideration under this Standard, with
appropriate certification of limits.

Inert ingredients in food-use formulations must be cleared for such use under
40 CFR 180.1001.
         b. Acute Toxicity Limits

Soluble concentrate products with established acute toxicity category III-IV
ratings for each of the acute effects (acute oral, dermal and inhalation
toxicity and primary eye and dermal irritation) are acceptable for
consideration under.this Standard.
                                      2-7

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         c. Use Patterns

Soluble concentrate chloramben products  containing ammonium and/or monomethyl-
ammcnium chloramben can be registered  for  non  domestic or domestic-use in
soybeans, dry beans , peanuts , sunflowers,  corn ,  lima beans, squash, pumpkins,
asparagus (seedling), and sweet potatoes.

Currently registered dosage rates  and  application methods are acceptable (see
page 5-4) pending submission of required residue chemistry data listed in the
manufacturing-use section of chapter III.

Proposed soluble concentrate chloramben  products containing sodium chloramben
or methyl chloramben can also be registered for  non domestic-use or domestic-
use in soybeans, dry beans, peanuts, sunflowers, corn, lima beans, squash,
pumpkins, asparagus  (seedling) , and  sweet  potatoes provided any additional
requested residue data reflecting  the  proposed use of the pesticide on the crop
is submitted and found to be acceptable.

Soluble concentrate chloramben products  can be registered for use in any crop
for which a tolerance  for chloramben (or exemption from a tolerance) , has been
granted.


   2.  Required Labeling

All soluble concentrate chloramben products must bear appropriate labeling as
specified in 40 CFR 162.10.


   3.  Regulatory Rationale

Product  Composition Standards:  The Agency finds no reason to limit soluble
concentrate formulations to  the ammonium or moncmethyl ammonium salts of
chloramben as  the active  ingredients,  provided any additional required data
reflecting the proposed use of  the product on the crop is provided.

The Agency finds no reason  to  limit the  %  active ingredient in formulations as
long as  the amount  of  active  ingredient  applied  per acre does not exceed
acceptable levels and  result  in residues which exceed the tolerance.


Acute  Toxicity Standards:  The Agency  limited acute toxicity to categories III
through  IV because  domestic  use  is acceptable under this Standard.


Use Patterns:  The  Agency  finds no reason  to limit the use of soluble
concentrate products to currently registered crops.  The use of soluble
concentrate chloramben products on other crops (for which a tolerance or
exemption from a  tolerance  has been granted) is acceptable provided any
additional residue  data are  submitted  on the use of the product on the crop.
                                       2-8

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C.
    Flowable Concentrate Chloramben

    1.  Acceptable Ranges and Limits
 Product Conposition

Active Ingredient:
  Any percentage with appropriate
   certification of limits.

Inert Ingredients:
  Inert Ingredients in food-use
  formulations must be cleared
  for such use under
  40 CFR 180.1001.

Currently registered flowable
concentrate products containing
sodium chloramben are sub-
stantially similar.
                                 Summary Table

                                     Acute Toxicity

                                    Acute Oral:
                                    Category III- IV

                                    Acute Dermal:
                                     Category III-IV

                                    Acute Inhalation:
                                     Category III-IV

                                   •Primary Eye:
                                     Category III-IV

                                    Primary Dermal:
                                     Category III-IV
                                                              End-Use Patterns

                                                            Outdoor terrestrial
                                                            food-uses or nonfood
         a. Product Composition Standards

Currently registered chloramben flowable concentrate products contain  21% and
83% sodium chloramben.  The Agency has determined that existing  flowable
concentrate chloramben products are substantially similar.

Flowable concentrate chloramben products with any percentage of  sodium
chloramben, ammonium chloramben, monomethyl-ammonium chloramben, or methyl
chloramben are acceptable for consideration under this Standard, with
appropriate certifica'tion of limits.

Inert ingredients in food-use formulations must be cleared for such use under
40 CFR 180.1001.
         b. Acute Toxicity Standards

Flowable concentrate products with established acute toxicity category III-IV
ratings for each of the acute effects (acute oral, dermal, inhalation toxicity,
and primary eye and dermal irritation) are acceptable for consideration under
this Standard.
         c. Use Patterns

Flowable concentrate chloramben products containing sodium chloramben can be
registered for domestic or non domestic use in soybeans, dry beans, peanuts,
and sunflowers.
                                      2-9

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Currently registered dosage rates  and  application methods are acceptable (see
page 5-4) pending submission of  required  residue chemistry data listed in the
manufacturing-use section of chapter III.

Proposed flowable concentrate  chloramben  products containing ammonium
chloramben, monomethyl ammonium  chloramben,  or methyl chloramben can also be
registered for non domestic or domestic use  in soybeans, dry beans, peanuts/
and sunflowers provided any additional requested residue data reflecting the
use of the pesticide on the crop is submitted and found to be acceptable.

Flowable concentrate chloramben  products  can be registered for use in any crop
for which a tolerance  for chloramben (or  exemption from a tolerance) has been
granted.


    2.  Required Labeling

All flowable concentrate chloramben products must bear appropriate labeling as
specified in 40 CFR 162.10.


    3.  Regulatory Rationale

Product Composition Standards:  The agency finds no reason to limit flowable
concentrate formulations to the  sodium salt  of chloramben as the active
ingredient provided any additional required  residue data reflecting the
proposed use of the product.cn the crop(s)  is provided.

The Agency finds no reason to  limit the % active ingredient in formulations as
long as the amount of  active ingredient applied per acre does not exceed
acceptable levels and  result in  residues  which exceed tolerances.


Acute Tbxicity Standards:  The Agency  limited acute toxicity to categories III
through IV because donestic use  is acceptable under this Standard.


Use Patterns:  The Agency finds  no reason to limit the use of flowable
concentrate products to currently registered crops.  The use of flowable
concentrate products on other  crops (for  which a tolerance or exemption from
tolerance has been granted) is acceptable provided any additionally required
residue data are submitted on  the  use  of  the product on the crop.
                                      2-10

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D.   Smulsifiable Concentrates

    1.  Acceptable Ranges and Limits

                                 Summary Table

 Product Composition                Acute Toxicity           End-Use Patterns

Active Ingredient:                  Acute Oral:              Outdoor terrestrial
   Any percentage with appropriate    Category  III-IV       food uses or nonfood
   certification of limits
                                    Acute Dermal:
Inert Ingredients:                    Category  III-IV
   Inert Ingredients in food-use
   formulations must be cleared     Acute Inhalation:
   for such use under                 Category  III-IV
   40 CFR 180.1001.
                                    Primary Eye:
The currently registered              Category  III-IV
emulsifiable concentrate
product contains 23.2%              Primary Dermal:
methyl chloramben.                    Category  III-IV
         a. Product Composition Standards

The currently registered emulsifiable concentrate chloramben product  contains
23.2% methyl chloramben.

Emulsifiable concentrate chloramben products with any percentage of sodium,
methyl, ammonium, or moncmethyl ammonium chloramben are acceptable for
consideration under this Standard, with appropriate certification of  limits.

Inert Ingredients in food-use formulations must be cleared for such use  under
40 CFR 180.1001.


         b. Acute Toxicity Limits

Emulsifiable concentrate products with established acute toxicity category III-
IV ratings for each of the acute effects (acute oral, dermal and inhalation
toxicity and primary eye and dermal irritation) are acceptable for
consideration under this Standard.
         c. Use Patterns

Emulsifiable concentrate products containing methyl chloramben can be
registered for non domestic-use in snap beans, cantaloupes, and cucumbers.

Currently registered dosage rates and application methods are acceptable  (see
page 5-4) pending submission of required residue chemistry data listed  in the
manufacturing-use section of chapter III.

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Proposed emulsifiable concentrate chloramben products containing sodium,
ammonium or monomethyl ammonium chloramben can be registered for domestic or
non-domestic use in snap beans, cantaloupes, and  cucumbers provided any
additional requested residue data reflecting the  proposed use of the pesticide
on the crop is provided.

Emulsifiable concentrate products can  be  registered for use in any crop for
which a tolerance (or exemption from a tolerance)  has been granted.
    2.  Required Labeling

All emulsifiable concentrate  chloramben products must bear appropriate labeling
as specified in 40 CFR 162.10.


    3.  Regulatory Rationale

Product Composition Standards:   "Hie  Agency finds no reason to limit
anulsifiable concentrate formulations  to the methyl ester of chloramben as the
active ingredient, provided any additional residue data reflecting the proposed
use of the product on the  crop  is  provided, and found to be acceptable.

The Agency finds no reason to limit  the % active ingredient in formulations as
long as the amount of active  ingredient applied per acre does not exceed
acceptable levels and result  in residues above tolerance levels.


Acute Toxicity Standards:  The  Agency  lijnited acute toxicity to categories III-
IV because emulsifiable concentrate  products containing sodium, ammonium, and
monomethyl ammonium chloramben  can be  registered for domestic use.
                                             *

Use Patterns:  The Agency  finds no reason to limit the use of emulsifiable
concentrate chloramben products to currently registered crops.  The use of
flowable concentrate products on other crops (for which a tolerance or
exemption frcm a tolerance has  been  granted) is acceptable provided any
additionally required residue data are submitted on the use of the product on
the crop.
                                      2-12

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E.   Granular Chloramben

    1.  Acceptable Ranges and Limits
                                 Summary Table
 Product Comoosition
Active Ingredient:
   Any percentage with appropriate
   certification of limits.

Inert Ingredients:
   Inert ingredients in food-use •
   formulations must be cleared
   for such use under
   40 CFR 180.1001.

Currently registered granular
products containing ammonium
chloramben are substantially
similar.
Currently registered granular
products containing ammonium and
moncmethyl ammonium chloramben
are substantially similar.
 Acute Toxicity
Acute Oral:
  Category III-IV

Acute Dermal:
  Category III-IV

Acute Inhalation:
  Category III-IV

Primary Eye:
  Category III-IV

Primary Dermal:
  Category III-IV
 End-Use Patterns
Outdoor
terrestrial food
(or non food) uses
       a. Product Composition Standards

Currently registered granular chloramben products contain 1.3%-10.8% ammonium
chloramben, and mixtures of 2.82%-5.4% ammonium chloramben and 8.46%-17.3%
moncmethyl ammonium chloramben.

Granular chloramben products with any percentage of sodium, methyl, ammonium or
moncmethyl ammonium chloramben are acceptable for consideration under  this
standard with appropriate certification of limits.

Inert Ingredients in food-use formulations must be cleared for such use  under
40 CFR 180.1001.
       b. Acute Tbxicity Limits

Granular chloramben products with established acute toxicity category  III-IV
ratings for each of the acute effects (acute oral, dermal, and inhalation
toxicity and primary eye and dermal irritation) are acceptable for
consideration under this Standard.
                                     2-13

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       c. Use Patterns

Granular chloramben products containing  ammonium and roonomethyl ammonium
chloramben can be registered for domestic  or non-domestic use in soybeans, dry
beans, peanuts, sunflowers, com,  sweet  potatoes, transplanted tomatoes and
peppers, lima beans, pumpkins,  squash, asparagus (seedling), and ornamentals.

Currently registered dosage rates  and application methods are acceptable  (see
page 5-4) pending submission of required residue chemistry data listed in
chapter III.

Proposed granular chloramben products .containing scdium or methyl chloramben
can be registered for domestic  or  non-domestic use in soybeans, dry beans,
peanuts, sunflowers, corn, sweet potatoes, transplanted tomatoes and peppers,
lima beans, pumpkins, squash, asparagus  (seedling), and ornamentals, provided
any additional requested residue data reflecting the proposed use of the
product on the crop is provided and  found  to be acceptable.

Granular chloramben products can be  registered for use in any crop for which a
tolerance (or exemption from a  tolerance)  has been granted.
    2.  Required  Labeling

All oranular chloramben  products must bear appropriate labeling as specified in
40 CFR 162.10.
     3.  Regulatory Rationale

Product Composition Standards:   The Agency finds no reason to limit granular
chloramben products to  the  ammonium or monomethyl ammonium salts of chloramben
as  the active  ingredients,  provided any additional residue data reflecting the
proposed  use of  the product on  the crop is provided, and found to be acceptable,

The Agency  finds no reason  to limit the % active ingredient in formulations as
long as the amount of active ingredient per acre does not exceed acceptable
levels and  result in residues above tolerance levels.


Acute Tbxicity Standards:  The  Agency limited the acute toxicity of granular
products  to categories  III-IV because granular products containing ammonium
chloramben, moncmethyl  ammonium chloramben, scdium chloramben and methyl
chloramben  can be registered for domestic use.


Use Patterns:  The Agency finds no reason to limit the use of granular
chloramben  to  currently registered crops.  The use of granular chloramben on
other crops covered by  chis Standard (for which a tolerance or exemption from a
 tolerance has  been granted) is  acceptable provided any additional residue data
are submitted  and found to  be acceptable.
                                      2-14

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                                   CHAPTER III

                         DATA REQUIREMENTS AND DATA GAPS


A.  Manufacturing-use Chloramben


1.  Generic Data Requirements;

Table 3-1, entitled:  Generic Data Requirements and Data Gaps for Manufacturing-
use Products   includes  those data  that  pertain to the properties or effects of
chloramben as  an active  ingredient.  Thus,  these data are relevant to an
evaluation of  the risks  and  benefits of all products containing chloramben.
Providing data to fill  indicated gaps in the data base is the primary
responsibility of the registrant(s) of  manufacturing-use chloramben.
Registrants of end-use products which are not exempted by FIFRA Section
3(c)(2)(D) are also responsible  for the submission of these data.  Applicants
for the registration or  reregistration  of manufacturing-use chloramben products
must acknowledge reliance on existing data  which fill indicated data
requirements under FIFRA Section 3(c)(l)(D).   These data are listed under the
column entitled: Bibliographic Citation in  this table.


                           Environmental  Fate Data

Data on physico-chemical degradation, mobility, metabolism, and accumulaticnare
required on both sodium chloramben and  methyl chloramben.   Requested data on
the fate of sodium chloramben will support  the registrations of all products
containing sodium, ammonium, and monomethyl  ammonium chloramben.  Requested
data on methyl chloramben will support  the  registrations of all products
containing methyl chloramben.

In addition, the Agency  is requiring the  completion of an applicator exposure
study.  The study should be  conducted with a  typical soluble or flowable
concentrate formulation, mixed and then applied by ground  equipment to a
typical (160 acres) soybean  field at recommended  application rates.  This study
is required because the decision not to presume against the registration of
chloramben was based, in part, on the results of  the applicator oncogenic risk
assessment.  The risk assessment used data extrapolated from exposure studies
on pesticides  used in a similar manner  to chloramben.   The Agency is requiring
this study to  verify the exposure estimates  used  in the oncogenic risk
assessment.


                             Product Chemistry Data

Certain data on the physical/chemical properties of technical chloramben (3-
amino 2,5-dichloro benzoic acid) are required for the  registration of both
sodium and methyl chloramben.
                                      3-1

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                                Toxicology  Data

The sodium salt of chloramben has  been determined to be equivalent to
chloramben for the purposes of extrapolating  "generic"  toxicity data.

A summary report in Agency files indicates  that  the methyl ester of chloramben
hydrolyzes to chloramben within days of application to  the soil.  Provided that
evidence is submitted documenting  the breakdown  of methyl chloramben to
chloramben after application, and  provided  an acceptable metabolism study is
submitted on methyl chloramben, all subchronic and chronic toxicology generic
data requirements may be fulfilled for the  methyl ester and sodium salt by
testing with chloramben  (or the sodium salt).


                            Ecological Effects Data

Fish and wildlife  (ecological effects) safety testing must be conducted on
sodium chloramben  ("for'the registration of  products containing sodium
chloramben) and on the methyl ester  (for  the  registration of products
containing methyl chloramben).  Separate  testing is required because data
indicate that the physical/chemical properties (ie. solubility)  of methyl
chloramben and sodium chloramben differ.  These  differences could influence the
acute toxicity of  these  compounds  to  fish and wildlife.


                            Residue Chemistry Data

Data on the storage of PAC between harvest  and sampling are required for the
registration of both sodium and methyl chloramben.
                                       3-2

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 2.  Product Specific  Data Requirements;  Manufacturing-use Chloramben

Table 3-2, entitled:   Product Specific Data Requirements for Manufacturing-use
Products  includes  those  data that  relate  only to the properties or effects of
a product with a specific composition  (or  substantially similar composition) .
Thus, these data are  required of  each  product (or substantially similar
product) to characterize  the product's particular composition and
physical/chemical properties, and to characterize the product's acute toxicity.

Product composition data  are required  for  each manufacturing-use product.
Providing data to fulfill these requirements is the responsibility of each
applicant for the registration or reregistration of a manufacturing-use
chloramben product.   If the Agency  has data which fulfills this requirement for
a particular product(s) then this is indicated in the chart and in the guidance
package accompanying  this Standard.

Data on the physical/chemical properties and acute toxicity of manufacturing-
use products are required for each product or substantially similar product.
Providing data to fulfill these requirements is the responsibility of each
applicant for the registration or reregistration of a manufacturing-use
chioramben product.

Product specific data  need not be acknowledged under FIFRA Section 3(c)(l)(D)
unless the Agency or a registrant has  established that one product is
substantially similar  to  another  product for which the Agency has received
acceptable data.

Existing manufacturing-use chloramben  products, methyl and sodium chloramben,
are not substantially similar for the  purposes of establishing product-specific
testing requirements.
                            Product Chemistry Data

Data requirements 163.61-3 through 163.61-7  (product  composition data)  apply to
 each proposed or currently registered manufacturing-use  chloramben product.

Data requirements 163.61-8(7) through  163.61-8(18)  (physical/chemical
properties data) apply to manufacturing-use  products  which are not the same as
the technical grade of the active ingredient.   These  data  are  required  on both
sodium and methyl chloramben.


                                Toxicology Data

Data requirements 163.81-1 and 163.81-2 (acute oral and dermal toxicity)  apply
to manufacturing-use products which are not  toxicolcgically equivalent to the
technical grade of the active ingredient.  Sodium chloramben has been
determined to be equivalent to chloramben.   Separate  testing on methyl
chloramben must be supplied.

Data requirements 163.81-3 through 163.81-6  apply to  each  manufacturing-use
product or substantially  similar  product.  Testing must be supplied on both
sodium and methyl chloramben.  Methyl  chloramben  is not equivalent to
sodium chloramben for the purposes of  extrapolating  acute  toxicity data.
                                      3-3

-------
B.  End-Use Chlorainben Products

Applicants for the registration of  end-use  products containing chloramben are
advised that if the Agency does not receive commitments,  within the specified
time frame, from manufacturing-use  chloramben registrants to fill data gaps
identified for the manufacturing-use product (Table 3-1) , manufacturing-use
product registrations will be  suspended.  Forraulators must then bear the burden
of supplying these data  if continued availability of the  manufacturing-use
product is desired.


1.  Generic Data Requirements

Table 3-3, entitled:  Generic  Data  Requirements and Data  Gaps for End-use
Products Containing Ammonium Chloramben  includes generic data which are
required for the registration  of  all end-use products containing ammonium or
monomethyl ammonium chloramben.   Ammonium and monomethyl  ammonium chloramben
end-use products are prepared  by  an integrated formulation system.  Certain
product chemistry data are required on technical grade ammonium and technical
grade moncmethyl ammonium chloramben for  tine registration of end-use products
containing these salts.

The Agency has determined that acute oral and dermal toxicity testing on
technical grade chloramben or  sodium chloramben will not  fulfill the
requirements for acute testing on technical grade ammonium and monomethyl
ammonium chloramben.  However, chronic or long term toxicology testing on the
ammonium or moncmethyl ammonium salts  is  not required.

The Agency has determined that fate data  on technical ammonium and monomethyl
ammonium chloramben are  not  required.   Requested data on  sodium chloramben will
suffice.

Because data on the toxicity of sodium or methyl chloramben to fish and
wildlife cannot be used  to assess the  toxicity of end-use products containing
ammonium or monomethyl ammonium chloramben, additional data on these salts are
required.  Because there are no manufacturing-use products which contain
ammonium or monomethyl ammonium chloramben, these data must be supplied by the
producers of end-use ammonium  or  monomethyl ammonium chloramben products.
                                       3-4

-------
2.  Product Specific Data Requirements for End-Use Products

Table 3-4:  Product  Specific  Data  Requirements and Data Gaps for Soluble
Concentrate Chlorambin

Table 3-5:  Product  Specific  Data  Requirements and Data Gaps for Flowable
Concentrate Chloramben"                      *~~

Table 3-6:  Product  Specific  Data  Requirements and Data Gaps for Emulsifiable
Concentrate Chloramben
                                                                             i
Table 3-7:  Product  Specific  Data  Requirements and Data Gaps for Granular
Chloramben
Tables 3-4 through 3-7  include  those data  that  relate only to the properties or
effects of products with a specific composition (or  substantially similar
composition).  Thus, these data are required of each product (or substantially
similar product) to characterize the product's  particular composition and
physical/chemical properties, and to characterize  the products acute toxicity.

Product composition data are required  for  each  end-use product.  Providing data
to fulfill this requirement is  the responsibility  of each applicant for the
registration or reregistration  of an end-use Chloramben product.  If the Agency
has data which fulfills this requirement for a  particular product(s)  then this
is indicated in the chart and in the guidance package accompanying this
Standard.

Data on the physical/chemical properties and acute toxicity of end-use products
are required for each product or substantially  similar product.  Providing data
to fulfill these requirements Is the responsibility  of each applicant for the
registration or reregistration  of an end-use Chloramben product.

Product specific data need not  be acknowledged  under FIFRA Section 3(c)(l)(D)
unless the Agency or a registrant has  established  that one product is
substantially similar to another product for which the Agency  has received
acceptable data.

                        Substantially  Similar Products

Existing Soluble Concentrate Chloramben products (containing 23.4% ammonium
Chloramben) are substantially similar  to each other.

Existing Soluble Concentrate Chloramben products (containii'g a mixture of
ammonium and moncmethyl ammonium salts) are substantially similar to  each other.

Existing Flowable Concentrate Chloramben products  (containing  sodium
Chloramben) are substantially similar  to each other.

Existing Granular Chloramben products  (containing  ammonium Chloramben)  are
substantially similar to each other and to S.C. products  containing ammonium
Chloramben.

Existing Granular Chloramben products  (containing  a  mixture of ammonium and
moncmethyl ammonium Chloramben)  are substantially  similar to each other and to
S.C. products containing ammonium and  moncmethyl ammonium Chloramben.


                                       3-5

-------
                            Product Chemistry Data
Data requirements 163.61-6 through 163.61-7  (product composition data) apply
to each proposed or currently registered end-use chloramben product.
                                Ibxicology Data
Data requirements 163.81-1 through 163.81-6 apply to each end-use chloramben
product or substantially similar product.
                                       3-6

-------
                    RFMERIC IWTA RBOUIRMHTO ANJ1 IWTA fiAPS
                       FOR
(luidolino
Citation
rnmo of Art? Data
TOst Required?
T\r«Rt frtos RPA Ihvo Data to
Substance Partially or Totally
Satisfy Roquirmcnt?
niblioqraphic Must Additional Data be Submitted
Citation under FIFRA 3(c)(2)(B>? rf ro,
dead] ine for nuhminnkm.
FiiviRnMMrarrAT. FAIT
!63.62-7(b)
163.62-7(c)
163.62-R(b)
I63.fi2-R(c)
163.62-R(d)
ir,3.62-R(o)
163.62-9(b)
163.62-9(c)
163.62-9(d)
163.62-9(0)
l63.62-in(h)
163.62-lO(d)
163.62-10(0)
163.62-in(f)
163.62-10(q)
163. 62-11 (h)
163. 62-ll(r)
1*3. 62-1 1M)

Hydrolysis
^otodooradation
Aerobic Roil
Motabol ism
Anaombic Poll
Motabnl inn
Annorol)ic Aquatic
Metabolism
Aorohic Aquatic
nntohollm
toachinq
Volatility
Adsorp./Dnsorp.
Hater Dispersal
•Unrrontrial Fiold
Dissipation
Aquatic Fiold
Dissipation
Terrestrial/
Aquatic Plssip.
Aquntio Tnpacr
Comb. ft Tank Hixos
I/jnq Trrm Study
Rotational Crop
trriqatod Cropn
Finh AwnnilnHon
Appl Ic/itnr
rxfonuro Study
Yes
YOB
Yes
Yos
No
Mr>
Yos
No
YOB
th
Yes
tin
Nr>
fto
1JD
YOB
I*
Yos
Yon
Sodium f. Methyl Partial: SodUm
aUoramhon* No: Mothy.1
Sodiiin f. Metliyl No
ChJoramhon
Sndiim (, Methyl No
Chloramhon
Sorlim ft Methyl Ito
Chlornmhen
Soditm f. Methyl Ho
rhloramhon
Soliim K Methyl No
Chlorambon

Reprosontativo No
Formulations

Formulations

5VxUi«n ft Mothyl Yes: SmUum
Chlornrtion Hn: Mothyl
Typlonl liiqiii'l fr>
FojTmilnt.lon
Union Oirhido, 19R1, 0172 Yos: Hay, 19R3
Yos: May, 1903
Yos: Mny, 19R3
Yos: flay, 19R3
Yes: toy, I9R3
Yon: May, 19R3

Yos: Mny, 19R3

Yos: Mpy, 11IH3

fwfin, 1970, 0020 Yosi: Hay, 19R3
Yon: Hny, 10R2
*  'IV'rlinirnl qrp'lo rti|orap*ion
or porliin rMornrtx^n  r.nit nrl-hyl  rhlornn*v?n.
These data requirements are current as
of M»y, 198}.   Ip^er t.n ruMnnoR iwcknce

for updated  requirements.

-------
                                                               TWJLF-3-1  (con)

                                                      GTNRRTC IWTA IVXIIIRfiMFOTS AND IWA GAPS
                                                          FOR WNUFACnJRItn-USR dll/TRAMBFN
Guideline Name of Am Data Ttst Irtts EPA Have Data to Blblioqrviphic
Citation -msl- Required? Substance Partial ly or Totally Citation
.Satisfy Requirement?
PimKT awns™

I63.61-3(b) Identification Yos "nrch. Grade* Yos
)63.6l-3(c) Cnmrnsition Yos Ttech. Grade Ho
163.61-7 Analytical Yes TYich. Grade Partial! Heed Amchnm, 1972, 0083
Methods » Data data
161.61-8(1) Color Yon Itch. Grade Yes Amchnm Products, 1967,
Amchcm Products, 1959,
Amchnm Products, I960,
163.61-8(2) Odor Yos Itch. Grade Ho
163.6178(3) Mnltinq Point Yes TVjrh. Grade Yes
163.61-8(4) Solubility Yos Tech. Grade Yes
163.61-8(5) Stability YOB Ttech. Grade Ho
163.61-8(6) Octanol/Hnter Yos Iferh. Grade tto

Amnhen Products,
Ainchom Products ,
Amchcm Products,
Annhom Products,
Amchnm Products ,
Amchnm Products,


1967,
1959,
1960,
1%?,
1959,
1960,

Must Additional Dntn ho SitmiM-.od
under FIFRA 3(c)(2)(R)7 If no,
deadline for taitxnission.
No
Yos:
Yes:
0081
0124
0125
Yost
0081
0124
0125
0081
0124
0125
Yos:
Vest
October, 1981
October. 1981
October, 1981


October, 1981
October, 1981
             Partition
             Coofficimt
U.1.61-8P)   Physical Stato   Yos
163.61-8(R)   Dnnsity or       Yos
              Specific Gravity

161.61-8(9)   noirinq Point    Mr.

163.61-8(10)  Vapor Prosnuro   Yos
16?. 61-8(11)  r^l               *""
                                         TVx*. Grade
                                         TVvh. GrarV;
                                         TV?r)». Grndo
                                                               Yes
                                                               fto
Part.in)
                    ftnchom Products,  1967, OOB1
                    Amcliom Products,  1959, 0121
                    Amnhora Products,  1960, 0125
ftnrhom, 1967, 0081
                                                                                                               YOSJ   Ontohor, 1981
Yop:  Octohrr, 1981
Yosi  October, 1<»B1
* 'ly-clinical Grndo Chlornrtvn Acid
                                                                                        These data  requlreaente are current as
                                                                                        of May,  1981.  Defer to guidance package for
                                                                                        updated  requirements.

-------
                                                                        -i (con)
                                                      CENRRIC DATA RFCHIRFmrrR AND IOTA GAPS
                                                          f(V
Citation
•mxicnuxw
163.81-1
163.B1-2
163.B1-7
163.82-1
163.82-2
163.82-3
163.82-4
163.82-5
I63.B3-1
lfi3.R3-2
163.83-3
163.B3-4
163.B4-1-4
163.85-1
Namo of Tt»nt Aro Data
feat Rnqulrod?
Anuto Oral Yon
TVwicity
Arnte normal Yon
TYjxicity
Acute Dnlnyod No
Hnurotoxicity
Sifcchronir Oral Yon
Tnxicity
Suhohronir Yon
(21-dny) normal IViixirlty
Suhnhmnio 90- HD
day normal Tox.
Inhal. IVrx.
Suhrhmnic No
Hnuratoxicity
Chronic Foodinq Yon
Ohoononioity Yoa
Vnrti tnnon io i ty Yon
Rnproflllct ion Yon
Mutaqoniritv Yon
M^tifthoJ ism You
Tent noon RPA Ifcwc Dnta to mhlioqniphic Hunt Mditionnl Dnta ho SuNiittivi
5?i*«tanoo Partially or "totally Citation uvV>r FIFRA 3(c)(2)(n>? If m,
Satisfy Unquiromcfit? rlo.VHino for fntmisnion.
•nrsch. Ora-lo* Yon Ilijiloton, 19S9, 0022 Ms
T*x4\. GrafV: Yos Hazloton, 1959, 0023 Hr>

Tferti. ft-aite Partial: Hx-d Litton, 1979, 0171 Yon: fVrtohor, 19B1
product purity
TVrh. Orarto No Yos: May, 1983



•nrch. Grado Partial: rVxH Litton, 1979, 0171 Yoo: October. 1981
prodiK^ purity
for 0171
•frioh. Crade Partial: NtxYl I1PC, 1978, 0170 Yos: Octohor, 1981
product purity hit ton, 1979, 0171
for 0170,0171 NCT. 1977, 0019
TVoh. (VfKlo Hn Yoa: May, 1983
Trx^h. (Vndo Partial: N"od AMR, 1'156, 0029 Yon: Octohor, 1981
prryluot purity
for 0029
TYxl). (Vndo Partial Amlorpon, 1972, OS02 Yoa: May, 19R3
TVxih. Orado (. th Yon: M*y, 19R3
                                            Hothvl
Ifil.nr.-l     nrmonHc Aninnl tin
             Snfofy TV^tintj
*  TYvhniral Chlorartion ArW or Frrliim (lilor/imhon
•* iv>chnlnnl Oilomrtwin Arid or Bortiim Chlornrtion nrr\ Hothyl Clilor.inhon
These data requirements are current an
of May, 1981.   Refer to guidance package  for
updated requirements.

-------
                                                             FOR
                                                                    TAnU3-3-l(non)

                                                                  IWA RBOUIRfTIETrTR AND DftVA OAPS
Ruirtol Jne
Citation
NiW! of Tlnst Arc Data
Iteat Rrxiulred?
1Y>8t Docs EPA Have Pnta to niblinqraphic Must Additional natn be Ruhmittod
Substance nartially or Trjtal ly Citation under FIFKA 3(c)(2)(n>? If BO,
Rat.infy ncqiiiremnnt? deadline for submission.
ROOUXIICAL EFFECTS
163.71-1

163.71-2




163.71-3

163.71-5


163.72-1


163.72-2


163.72-3


163.72-4
163.72-5
Avian Sinqle Yps
IVec Oral USO
Avian Dietary Yos
t/:so



Mflpuw 1 ifin Acuto fk>
•nnxiniry
r.irauJ. ft Actual tin
FioW 1\Rstinq for
Maranals/Pirds
Finh Acute Yos
IC50

Acute Tbxirity Yes
to Aquatic
Invertohratos
Acute Tbxioit.y No
to Estuarine R
Marine Orqaninns
n*iryo)ntvnf> r. No
Aquatic Organ. tk)
Sodium (, . No Yes: October, 19R1
Mothyl Chloramhen
Sodium ft Yost Sodiim Wild. Intti'l, 1978, OOS9 Yes: October, 19R1
Aff. Mnd. Bras., 1973, 0036
HPthyl ChlorartXHi Partiali Methyl, Aff. Mrd. Rns., 1973, 0039
nood wild water
waterfowl study





Sodiim ft Yes: Sodium U. Carbide, 1978, 0060 YOB: October, 19R1
U. Carbide, 1978, 0061
Methyl ChJonwben tb: Methyl
Sodium ft No Yes: October, 1901
Methyl CMorantwn






ir<3.72-r>
              1V>x. ft
              Studies
              r.inui.  t. Actual
              Fiold TV^Bting for
              Aquatic
1- Tr>nt-.inq rrquirod on both podium find nrhhy) (*iloran*x-n.
                                                                                                 These data requirements are current as
                                                                                                 of May, 19&1.  Refer to guidance package
                                                                                                 for updated requirements.

-------
•BWK-3-1 (st
TVnt

RFSinUR OimiPITO
Motnholifin in Plants















Motfiholinm in Animals
Analytical Hotfmrts






FOR HAMIFACniRTTC-USE OIUWAMBFH

Am nata Tnst ft»s EPA llavo Data to Bihl ioqraphic Must ArWltional Dnl-n bo SiUTinfttoT!
nnepiirorl? .«5iihstnnoc Partially or Ibtally Citation undor FIFRA 3(c)(2)(n>? If no.
SntiBfy Rcquiromnnt?
Yon Rrp. Form.* Yos Swansson,
Amchoni,
Amrhcm,
Arochnro,
Aroohnm,
Anonorn,
Anyndn,
AmohMn,
Arocnom,
Amohcin,
AniCnOITI ,
Ancticni ,
Nnrttrm,
Arachom,
Amnhom,
Amonem,
No
You Rop. Form.* Yos mrtiem,
Atnchnm,
Amohom,
Amohom,
AnRhoni,
Ainchom,
Annhom,
doa^lino for nuhmission.
1966, 0169 Ho
1960, 0127
1063, OOOR
1965, 0076
1961, 0079
1963, 0090
1963, 0106
1961, 0159
1964, 0161
]963, 0162
1963, 0161
1964, 0164
1961, 0154
1961, 0104
1961, 0157
1978, 0101

1963, 015B Nn
1965, 0077
1964, 0107
1978, 0057
196fl, 0085
196?. 0166
1967, 0167

-------
                                                              TAPLT-3-1 (con)
                                                    CFNFPTC IWTA P.Rni>IRrTirfrrS AND DATA OATO
                                                        prm MAMUFArnxmiNTr-iiFE cnrniwnng
flnmo of 1Y>nt-.
TVT.t
Arc tat*
Rnquircil?
TY?st
PuhflbmoQ
Doos EPA llnvo Data to
Partially or TVjtnlly
Sntisfy Roquiromont?
nihl ioqraphic
Citation
Miisfc ArMlMnonl Ititn bn Puhmitto«i
unrtor F1FPA 3»r»r2)«ri? It no.
PRRIHIf! gilTUCTTO (con)
       Datot RAC
  PoyhoanB
YOB
                 . Porm.*
                                  YOB
  Pnnnutn
                           Yos
                           YOB
                           YOB
                                            .' Porm.
                                         Bnp. Porm.
                                            • Form•
                                                             Yes
                                 Yos
                                                             Yes
 ftnrliom, 19fi5,  0071
 Amchom, I960,  00fl4
 Stonffor, 197!) ,  0041
 Amnhom, 1967,  0044
 Rlnnm, 197fl,  0050
•Amchom, 197ft,  0057
 Arorhom, 197B,  0101
 Amchcm, 1%1,  0104
 Amnhom, 1975,  0109
 Amchora, 19fi7,  0120
 Amrhnm, 197fi,  01 in
 Amchom, 196),  0135
 Amchom, 1961,  0136
                                                                              Mo
       ,  1967, 0044
Amrhom,  1965, 0076
Amchoni,  1965, 0077
Amchon,  196R, 0004
Amrhom,  1975, 0109

Amrh?m,  1967, 0044
Amrhom,  1964, 0093
Amrbrm,  1975, 0109
Amchom,  1963, 0162
Amchom,  1964. 0008

Amchom,  1067, 0044
Amrhom.  1961, 0106
Amchom,  1975, 0109
Amohom,  1963, 0102
                                                                                                         Mo
                                                                                                         Ho
                                                                                                         Mo

-------
                                                                TABLE-J-l (con)


                                                      GENERIC DATA REQUIREMENTS  AND DATA GAPS
                                                          FOR MANUFACTURING-USE  CHLORAMBEN
Nama of Test
Teat
Are Data      Test           Does EPA Have Data to     Bibliographic
Required?     Substance      Partially or Totally      Citation
                             Satisfy Requirement?
                        Must Additional Ditn be Submitted
                        under FIFRA J(c)(:i)(B)? it so,
                        deadline Cor submission.
 HES1UUK CHBHlSIHlt (COn)

Hesldue uata> RAC

   Lima Beans                Yes
   Corn                      Yes
   Sweet Potatoes            Yes
   Punpkln, Squash           Yes
              Rep. Form.
              Rep. Form.
              Rep. Form.
              Rep. Form.
                                  Yes
                                                               Yes
                                                               Yes
                                                               Yes
Amchem, 1967, 0044      No
Amchem, 1963, 0098
Amchen, 1963, 0108
Amchem, 1975, 0109

Amchem, 1967, 0044      No
Amchem, 1964, 0080
Amchem, 1975, 0109
Amchem, 1969, 0110

Amchem. 1967, 0044      No
Amchem, 1964, 0078
Amchem, 1975, 0109

Amchem, 1967, 0044      No
Amchem, 1968, 0084
Amchem, 1964, 0164

-------
                                                               TAHLR-3-1  (con)
                                                     fiFNFRIC IOTA RnoniWnniTR AND IWTA RAPS
                                                         pnn MAn»FA(?nmiMn-URR
Hnpr> of "Hr-at
Tnnt
FtRSiniF! CIIFMISlTOf (con)
nnsidiio Data i RAC
IW Hoans
Snap tloaiw
Cucumbers
Unions
Sunflower
St-ornqo l*»ta
Pnsiduo Dntat
Proennsnd FondB
Arc Data
Required?

Yen
Yfifl
Yos
Yon
YOS
Yen

No
TteBt
Substance

pjpp. Frjrm.
Rnp. Fbrn.
Rnp. Form.
Pjop. Form.
Hnp. Form.
Rnp. Form.


Pona FVA llnvn Dnta to
Partially or 1*jtally
Sntiafy Rcquircmont-.?

Yon
Yes
Yen
Yon
Yos
Mo


Bibliographic
Citation

flMmti-r-m \G&'1
/wrnmi $ i "P ' »
/Virhnm, )96fl,
Amnhcm, 1964,
Amchom, 1964,
Antcncffif l9nRf
Anchoin t \ OfiR f
^ronhont f l9f Puhmlttr-H
undor FJFUA 3(p)»2)*n)? If so,
deadline for submission.

004 '. tin
OOR4
oonn
0096
0149
0149 Ho
0149 No
0149 No
0)00 No
Yoa: Mny, 1903


Fraiduw in Meat, Millr,
Poultry, and
                            tin
                                                                                            Data requirements are current as
                                                                                            of May, 1981.  Refer to guidance package
                                                                                            for updated requirements.
* From application of  roproRontntivo  formulations.

-------
                                                                 TAnLE-3-2

                                              pRnnuor-sprciFir IWTA  REquinmFwrs win OATA CAPS
                                                    FOR MAHiiFAonmiNn-iisF, oiiruwmFM pnmicrs
Huiflo] ino
Citation
Harm of Am Data
TVK?t Pjrxplinvl?
Substance
Drvs EPA llavo Data to
Partially or "totally
Satisfy Requirement?*
» nlhl ioqraphic Hunt Additional Data Po Suhmitlo-1
Citation under FIFRA 3(c)(2)(n)V If so,
doadlino for Butiiisnion.
pinrocr CHEMISTRY
163.61-3
Prod. Identity
and Plsclocuro of
Dnncription of
Yos
Yos
Each KIP**
Each MIIP
Yos: Mothyl Chlornmhon
Yos: Po-liin "
Ho
Mo
Yos:
October,

Manufaotiirim Procoss
163.61-5

163.61-6

163.61-7

163.61-0(7)




163.6l-fl  smw an fho
    •IVchnical Crnrto of  Km AcH
-------
                                                                      :--»-2 (ron)
                                                    FDR
                                                               IWTA nrcrmraiiRTrs win WTA OMB
                                                                          nii/uwmw pnonicrs
Ouidoltno
Citation
irwicoi/™
I63.ni-!
Mnmo of
Tfcst
Acute Oral
Tbxicity
Am nnta
Hoquirod?
Yon
TfcBt
Suhotanco
MUP**
f>ios EPA Ibivo Data to
Partially or "mtally
Satisfy Pwniironrnt?*
Partial: Methyl
Sitfmit product purity
nib] ioqraphic
Citation
llazloton, 1959, 0022
llazleton, 1966, 0024
Must Arlditional tttta ho Sirtmlttfvl
indrr FIFKA 3(c)(2)(n)7 Tf no,
dcadlino for submlsnion.
Yos: Octohor, IWl
un.m-2
                    Dnrmal
              Acutft InhfyJ.   Yon
              Trjxlcil-y

              Prim. Eye      Yos
              Irritation****

              Primary !>>rmnl Yos
              Irritation
                             Yon
HUP**


HIP***


MUP***


HIP***


HJP***
Cor 0024
Yon: Sodium Chlorambon

Ftoj Mothyl ailoranhon
Yost
HT.S Hfthyl Chloranbon
YOB i Sort! urn     "

Not Mnthyl Chloromhon
Yosi
Not Mothyl Chloramhon
YOBI Sodium     "

Mo
*    For Currently nrxiistorod ProrliictB.
*•   RtXTiircrt for Manufacturihq-URC PtorturtB vihich are not the anno nfl the
     TYx:hnlcal Ornrto of tho Artivc Inrirodiont.  SaUim Chlomirhon has hccn
     dotonninral to he Mm samp as Tochnlcal Chlorambon Acid.  Mothyl Chlorambon
     Kan boon dnterminod to bo diffomnt.
•**  Kach Mannfacturinc}-uso Product or SiihRtnntial'ly Similar Product.
**** A domonntration of pi! hotwoon 1 and .1, or J2 and 14  or  a domonatration
     of dermal irritability will tr> sufficient to oatroorizc a product aa an
     ocular irritant, and additional testing will not ho roqiiimd.
llnzlotnn,  1959, 0023    Yon:  Octo»>or, 1WU
Cnc Hon.,  1978, OOfiS

Food K l)n«), 1978, 0062 Yos«  Octohor, 19B1
CTC HOB., 197H, 0064    Yoss  October,  19RI
CfC HOB., 197fl, 0061    YOBJ  Octohor, J'JPl
                                                                                                            YOB:   Octnhor, 19BI
                                        Theoe data, requirements  are current as
                                        of May, 198l.   Refer  to  guidance package
                                        for updated requirements.

-------
                                                                   iv\nLF:-3-3

                                                     ORIKRIC rWTA RJXUTnmmrS AMD IWA O\PS
                                            FOR rHD-uflB ojrmwmFw PRODUCTS oowrAiNiNn AMMONIUM
Guide! ino
Citation
Root/Xi i rv\i
163.71-1

J63.71-2

163.71-3

163 .71-S


163.72-1

163.72-2


163 .72-3


lfi.1.72-4

163 .72-5


163 .72-6


Name of Thst Arc Dnta Trflt Dnos EPA llnve Data to nihlioqraphic Must Additional linta ho Fulinjtl
TVMt Required? Substance Partially or Totally Citation under FJFRA 3(c)(2)(n)7 If so.
Satisfy Requirement? deadline For submission.
. EFFRCTS
Avian SinqJo Yos Ammonium and Mono- No
noso Oral U)50 cnet.hyl nimnniun*
Avian Dietary Yes " fb
IC50
Knnn.il inn Acute Mo
•nnxicity
Simul. t, Actual No
Field TYintinq for
Hnmnals/nirds
Fish Acute Yos Annoniiin .ind Mono- No
LC5P methyl amnonlun*
Acute Tbxiclty Yes " Hr>
to Aquatic
Invertebrates
Acute Ibxicity No
to Estuarine &
Marino Orqanisms
Buhryolnrviie r. No
Life-Cycle
Aquatic Orqan. Mo
Tox. ft Residue
Studies
Simul. d Actual Mn
Field Tlnstirtq for
Aquatic Orqanisras
Yes: October, 1901

Yos: October, I9RI






Yos: October, 19R1

Yes: October, 1981













* Tr>ntinii Roquircd on TV>chnicnl Crado Amnnnliim and.Tr-chnleal Rrado MonomothyJ
  Anmnniini Chloramhrn.  Data on TV-rhnicnl Chloramhm Acid, Snrliim Chloran*vn
  or Unthyl rhlornirtwn cnnnot he extrapolated to Ammonium Chlormrtion or
  Monomothyl Aimonium Chloramhrn.
These data requirements are current as
of May 1981.  Refer to guidance package
for updated requirements.

-------
                                                             TAULB-3-3 (con)

                                                    GENERIC DATA KBgUIUB-IENIS AND DATA GAPS
                                           FOIl ENIMJSB CIIUKAMUEN PRODUCTS COOTAININQ AMMONIUM
Glide line
Citation
Niine of Are Data Test
'teat Rxjulred? Substance
Does EPA Have Duta to Bibliographic Must Additional Data be Submitted
Partially or 'totally Citation under FIFRA 3(c)(2)(B)? if 30,
Satisfy Requirement? dsadline for submission.
PROOUCr CHEMISTRY
163.
163.
163.
IJ3.
163.
IbJ.
Io3.
Io3.
163.
163.
163.
163.
163.
163.
61-3(b)
61-3(c)
61-;
61-8(1)
61-8(2)
61-8(3)
61-tl(4)
6l-d(5)
61-8(6)
61-3(7)
61-il(8)
61-3(9)
61-8(10)
61-8(11)
Identification
Composition
Analytical
Methods Si Data
Color
Odor
Meltinj Point
Solubility
Stability
Uctanol/Mater
Partition
Coefficient
Physical State
Density or
Specific Gravity
Balling Point
Vjoor Pressure
(XI
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
143
Yes
Yes
•tech.
•tech.
•tech.
•tech.
•tech.
Tech.
•tech.
Tech.
•tech.
•tech.
•tech.
Tech.
T»ch.
Grade'
Grade
Grade
Grate
Grade
Grade
Grade
Grade
Grade
Grade
Grade
Grade
Grade
(to
(to
to
No
No
No
No
(to
143
Yes
No
No
(to
Yes:
Yes:
Vest
Yasi
Yos:
Yes:
Yes,
Yes:
Yes:
Yes:
Yes:
Yes:
October,
October,
October,
October,
October,
October,
October,
October,
October,
October,
October,
October,
1931
1931
1931
1931
19iU
1931
1931
1981
1981
1931
1981
1981
Teclinic.il Grade Airooniun and Maramethyl  ftmonlum Ghloranben
                                                                                                      These  data  requirements  are  current  as
                                                                                                      of  Hay,  198l.   Refer  to  guidance  package
                                                                                                      for updated requirements.

-------
                                                                TAflLE-3-J (con)


                                                      GENERIC DATA REQUIKEMB«S AND DMA GAPS
                                                FOR END-USE PRODUCTS COHIYUNING AMMONIUM QIUWAMBEN
             Noire of 'teat    API Data      Tteat           Dxs EPA Hava Data to     Bibliographic           Must Additional DUa be Subnitt-jd
Citation      'test           »:^uired?     Substance      Partially or 1btally      Citation                utvter FIFRA 3(c)(2)(U(? If »a,
                                                          Satisfy Requirement?                              deadline Cor submission.


 •lUXtOOUJUV

LbJ.Ul-1     Acute Oral      Yas           Ammonium &               tto                                      Yes:  October, 1981
             'Ibxicity                      nmanetliyl amnonium*

161.U1-2     Acute Dermal    Yes           Amuniun &               Ma                                      Yes>  October, 1981
             •Jbxicity                      ttanomethyl aumoniun*
        on  tectwiical grade ainnoniun and nonoraethyl annoniura chloraifcen                                 "n>eae data requirements are current as
   are retired.  Acute oral and dermal toxlcity testirq on technical                                  of Hay, 1981.  Refer to guidance package
          sodium cliloraraben (or chloranben) will not satisfy tills requirement.                          package for updated requirements.

-------
                                                                   TAIU/:-3-4

                                             PRODUCT-SPECIFIC IWTA  RnouinoiFwrs AND rwm GAPS
                                                FOR sniimtj; conrnwnvm: minwinra ptnniiCTS
Guideline
Citation
Nnroo of Are rvita
Tlnst Required?
Tlnnt fries PPA llavo Data to IHhlioqraphio Must Additional fmtn IV. Bulmifhivl
Substance Partially or Ttotally Citation under FIFRA 3(c)(2)(R)V if no.
Satisfy Requirement.?* deadline for mtfmiosion .
PRODUCT CHEMISTRY
16.1.61-6
ifcclaration
Yes
Each B.C. Product
Ho
Yes:
Octobor,
108 1
of Inqrodiont t.tmitn ' ""
163.61-7

163.61-8(1)
161.61-8(2)
Mil. 61-8(7)
161.61-8(8)

163.61-8(9)
161.61-8(10)
163.61-8(11)
163.61-8( 12)
161.61-8(13)
161.61-8(14)

163.61-8(15)
163.61-8(16)
163.61-8(17)
163.6l-8(ln)

Prorluct Analyt.
Methods and Data
Color
O:V>r
Physical State
Density or
Specific Gravity
Polling Point
Vapor Pressure
P»
Storaqe Stab.
Flaimability
Oxidizinn-or
Roducinq Action
Rxplosivonoss
Miscibility
Viscosity
Corrosion
Characteristics
Yes

Yes
Yes
Yes
Yen

Yes
Yes
Yes
Yes
Yea
YOB

Yes
Yes
Yes
Yes

Each B.C. Product

Each B.C. Product
Each B.C. Product
F.Tch B.C. Product
SC***

SC***
sc**
sc***
BC***
SC***
SC***

sc***
sc***
sc***
sr***

Partial: Nood Data

No
No
Yes
tin

No
No
tb
No
Nn
No

No
No
Nr>
No

Yos:

Yes:
Yen:

YOB:

Yes:
Yea:
Yes:
Yes:
Yen:
Yes:

Yes:
Yes:
Yes:
Yos:

Octobor,

October,
October,

Octobor ,

October ,
Octobor,
Octobor,
October,
Octobor,
Octobor,

October,
Ortohor,
Octobor,
October,

1981

1981
1981

1981

1981
19(11
1981
1981
1981
1981

19111
1981
1981
1981

* For Currently Reql stored Products
** Enrh Soluble f*r»wr>ntrflto Pmdiiot _ • .
*** Rnrh Bnli*>lo Cnncnntrc'tc Prndiict or Suhstantiallv Similar Product
These data requirements are current
as of May. 198l.  Refer to guidance
package for updated requirements.

-------
                                                                         (oon)
                                             PRODUCT-SPECIFIC DATA RFQUIREHFNrS AMD tWTA CAPS
                                                pnn sniunif ontiowiwiT: oir/xwinrri pnnnucrs
Guideline
Citation
Ttwicmxw
163.B1-1
163 .Rl -2
flrane of
Tnst
Acute Oral
Tbxioity
Acute Dermal
Toxioity
Am Data
Required?
Yes
Yes
•tost
Substance
SC"
sc*»
toes EPA llavo Pata to
Partially or Totally
Satisfy Rnquircnrnt?*
Partial t fteod product
purity for 0001, 0024
Mr>s Amnonium Chloranfcon
Partial: Aram. * Mono-
methyl amnoniim, need
product purity for 0002
Bibliographic
Citation
Dioscarch, 1969, 0001
llazleton, 1966, 0024
Biosoarch, 1969, 0002
Must Additional Dnta hr: flu) nit led
indor FIFRA 3(c)(2)(n>? If an,
deadline for submission.
Yes: October, 19B1
Yos: Ontobor, 19RI
163.RI-3


163 .Rl-4





163.ni-5
          Acute Inhnl.   Yna
          Toxicity
                                          nc**
          Prim. Fyo
          Irritation
Ynn
          Prinviry Dermal Yen
          Irritation
                                      ft"
                                    Nb
                           Hoi Ammnniun Chloramhcn
                           Partial: Ann. & Mono-
                           mnthyl nmnoniun, nncri
                           product purity for 0003

                           No: Amnonim Chloramhon
                           P«rtiii]i Amu. t Hnno-
                           mothyl nmnoniun, nnc<1
                           pmrtnrt purity for 0002
Biosparch, 1969, 0003
Yns:  October, I9R1


Yosj  fV;tohor, 19R1
Bioscarch, 1%9, 0002   Yon:  Octohnr, l<»fll
•
**
For Currently Rrjqinterod Products
Raoh 5V5li*>lo Cnnc^ntrato Product or Substantially Similar Prorluct.
Currently Registered Products Containlnt| Ammanim Chloramhon llave Been
Dntonninnd to bn Substantially Similar, and Currently Rogisterod Produrts
Contalnint] Armnniun Chloranhcn and Honomcthylnmnnniini Chlorambm aro
Sifatnntially Similar.  Rrquirrd tostinq is bn he completed on Formulations
containinn 23.4» Ammniiin rhlorambm AT1D 15.7» Ammnniim Chlor.imbro &
47.2» Monomnthyl-ammninn Chloramben riiould hn tested.
                                                                                                              These data requirements are
                                                                                                              current as of May, 1981.
                                                                                                              Refer to guidance package
                                                                                                              for updated requirements.

-------
                                                              IWTA wrnuiRFMnrrs win IWA rj\pr,
                                               FOR FirwMiu: COHCEMTRATK otrnRAfmFii PROPHCTS
Guideline
Citation
N.imr? of
Tr-st.
Are nata
Required?
TV-si-
Substance.
Dies FPA llave Data to
Partially or "totally
Satisfy Requirement?*
nihl iorjraphic
Citation
Host Additional ITata Po fUihmittod
under FtFRA 3(c)(2)(n>? If so,
do.idlinp for suhnission.
PROUJCT QIFWJftnflf
lfil.fil-7

161.61-R(
163.61-R(2)
163.fil-R(0)
Ifi3.fil-n(10)
lfi.1.6 1-8(14)

ifi3.fit-n(is)
Ifi3.61-n(16)
lA3.61-n(17)
             nrxrlarntion     Yos
             of Inqrrrliont r.imitn
             Prodiiot Analyt. Yos
             Nothota nnrl Data
             Color           Yos
             CHor            YOB
             Phyoiral State  Yos
             rv>nnlty cr      You
             Specific Gravity
             Pol ling Point.   Yos
             Vapor Prcssum  Yos
             pi!              Yon
             Storaqo Stab.   Yos
             FlaniiK^ility    Yos
             OxWizinq or    Yos
             Rnduninq Action
             Rxplosivcncss   Yos
             MiRcibility     yes
             Visoosity       Yos
             Corrosion       Yos
             Characteristics
Each F.C. Product**

Each F.C. Product**

Ench F.C. Product.**
Fach P.C. Product**
Rich F.C. Product**
PC***

PC***
FC**
FT***
FT***
PC***
PC***
FC***
FC***
PC***
PC***
    No

Partial: Nrxxl
Data
    No
    Nh
    Yos
    Ho

    No
    Ib
    Ha
    No
    No
    Ho

    No
    No
    Mn
    No
                                                                                                            Yos:  Octohor, 1901
Yes:  October,

Yos:  October, 19H1
Yes:  October, 19R1

Yes:  October, 19RI
Yes:
Yos:
YOB:
Yos:
Yos:
Yos:
Yos:
Yos:
Yos:
Yos:
October ,
October,
October,
October ,
October,
October,
October,
Octohor,
October,
October,
I9!U
1901
1981
19R1
|OR1
1981
19H1
*
**
    For Currently Rnqintored  Products
    Each Flowablc Concentrato Product
*** Each FJowahlo Concentrate Product or  Substantially Similar  Product
                                                                                                      These data requirements are current
                                                                                                      aa of May 198l.  Refer to guidance
                                                                                                      package for updated requirements.

-------
                                                            TABLE-3-5 (con)

                                         PRODUCT-SPECIFIC OYfft RBQUIRFNEWS AND DATA GAPS
                                           FUR FUMAULE CONCENIKATE QILORAMBBN  PRODUCTS
Uuidelitr:
CitJtion
IVWICOUJGY
H>3.31-1
luJ.ai-2
ll>3.ai-3
163.U1-4
16J.81-5
Nims of Arc Dit.i 'lost 0X3 EPA lUve Uita to Bibliographic
1^3 t R>quiroJ/ Substance Partially or Ibtally Citation
Sitiafy Requirement?*
Acute Oral Yes EX.1** Yes
Ibxicity
Acute D>ntul Yos FC" Yea
'Ibxicity
Acute InnjL. Ye3 PC** Yes
•Ibxicity
Prim. Eye Yea PC** Yes
Irritation
Primary lXjnn.il Yes FV:** Yea
Hizleton,
llazleton.
Cue tea.,
1959,
1959,
1978,
U022
0023
0065
Pood & Droj, 1J7U, 0062
CDC Ri3,,
CDC RJS.,
197d,
197U,
0064
0063
Must ftllitional Ulta t>? Submittod
un.ier fIFRA 3(c)(2)(U)i> IE so,
deadline Cor submission.
Mi
(to
rto
No
ito
          Irritation
P.ir Currently Itegistere>1 Products
Bich Plorf.ible Oaiiointrate ProJuct or Substantially Similar Product.
Currently ItegistoreJ Prcxlucts  Containiiv^ GoJiun QilorainbJn llive Been
Dit'jnnined to be Substantially Similar.   'Ibstiiig is to be completed on
Fonnul.itions containing Sodium Qilorjinto.'n or 'Itacimical ailor.nntxjn Acid.
                                                                                                            These data requirements are  current
                                                                                                            as of May, 1981.  Refer to guidance
                                                                                                            package for updated  requirements.

-------
                                        ppnnirr-spnriFic rwm nrouiPFMFirrn wm IWA
                                        FOR nnn.siFiAnu: cnNrornwrE an/uwmpN pnonncrs
Ouidolino
Citntion
Untno oC
TVst
Aro flnta
nrquircd?
TVst
S«ihBtnnco
Dnon BPA llavo Pnta to Bibl lonrnphic
Pnrtlnlly or Totally Citation
Satisfy Hnquiromnnt.?*
Must /VWitioool tota IV Sirtnlttorl
undor PIFRA 3(c)(2)(D)7 If ro,
deadline for submission.
PRODUCT cnmisnw
nnrlarntion       Yos
of Inqrodient. Limits
                                    Rach E.C. Product**
163.61-7

163.M-RU)
I63.61-R(2)
l63.fl-R(7)
163.61-R(fl)

163.f.l-R(9)
163.61-R(in)
163.61-R(1U
163.61-RU2)
I63.61-fl(13)
163.6l-R(14)

163.61-B(1S)
163.I>1-R(16)
163.61-fl()7»
I63.61-fl(in)

Pmduct Analyt. .
Hothods and Dntn
Color
ntor
Physical Rtnto
Dnnnity or
Spocific Oravtty
noilinr] Point
Vapor Pmssurr*
P"
Storaqo RtRb.
FlnniuihiHty
OxicHzim or
Rcduninn Action
Fxpjosiwnofis
Miscibillty
Viscosity
Corrosion
Chnractorist ics
Yos

Yos
Yos
Yos
Yos

Yos
Yes
Yos
Yos
Yos
Yos

Yos
Yos
Yos
•Yos

Rnch

Rnch
Bach
F.icb
BT**«

BC***
BC**
BC**«
BC***
BC***
BC***

BC***
BC***
BC***
BC*«*

                                                              tin
                                                              Yos
                                                              No
                                                              No
                                                              No
                                                              No
                                                              No
                                                              No

                                                              No
                                                              No
                                                              Ho
                                                              No
For Currently DrqistoroH Product.
FVirh nnulnifiablo Concont.ratc Product
Rnch Rnulslfiahlo Conrontrnto Product, or SifetantinJly Similar Product
Yesi  October, 19RI

Yes:  October, 19R1

Yon:  Ontohor, 19R1
Yosi  October, 19R1

Yos:  Octohor, I9R1
                                                                                               Yos:  Octobor,
                                                                                               Yos:  Octohor,  19R1
                                                                                               Yes:  Octohor,  1<»R1
                                                                                               Yoa:  Octohor,  19R1
                                                                                               Yes:  Octohor,  19R1
                                                                                               Yos:  Octobor,  19W

                                                                                               Yos:  Octohor,  19R1
                                                                                               Yos:  Octohor,  1901
                                                                                               Yos:  Ortobor,  19R1
                                                                                               Yos:  October,  19R1
                                                                                               Ttiese data requirements are current as of
                                                                                               Hay,  1991.  Ttefer to guidance package for
                                                                                               updated requirements.

-------
                                           FOR
                                                             TAP.IE-3-6 (onn)
                                                            rwm RBTUiRmrrri'S AND DATA CVSPR
                                                            onucFMrnATE anrwwnm prmiors
Gnirlel jno
Cltntlnn
ToximinnY
lfi3.Bl-l
163.BI-2
ir>3.Ri-3
163.R1-4
ir,3.IU-5
Mctmn of Ano natn iv«»t
iv>j?t nnq\iir(y1? Siihstanro
Acute Oral Yt>s FT**
Toxicity
Aouto pprnp) Yos RC**
IVwirlty
Araito Inhal . Yoa FT**
TYixicity
Prim. Pyo Yon FT**
Irritation
Primary Rnrmnl Yrs FT**
Dnos HPA llavn Pnta hn
Partially or 1r.ta]]y
Satisfy nnqiiircmnnt?*
Partial! Need product
purity for 0024
Partial: Uncrt Pmrt»irt.
purity for 0143
Partial: Unort rrty1llc''
purity for 0144
Partial: Mood product
pirlty for 0143
No
niblionmphir; Must M>Utinnnl rr>ta tn Submit ti*l
Citation iwvlor FIFRA 3(r)(2)(r»)7 1C so,
«!
llazloton, 196n. 0143 YOB: October, 19R1
Yos: Ortcbnr, joni
             Irritation
                                                                                                   These data requirements are current ac
                                                                                                   of May,  19R1.   Refer  to guidance
                                                                                                   package  to updated  requirements.
*   For Currently Rnqistercd Product.
**  Panh Rnulnifiahlp fVinront.rflte Profluot or Substantially Slnilar Product.

-------
                                                                     TAnLn-i-7

                                             pnnraicT-PPECTFTC IV\TA RFttiiRFMEwrs win DATA CAPS
                                                         FOR GRANULAR dllPIWmEN PPOTCJCrS
Giiidol ino
Citation
llmitt of Are Dnta TY>nt toon EPA llavo Mnta to Bibliographic Must AiHitional rtit-o Do Submit! r. I
TV>st Required? Pittance Partially or -totally Citation under FIFRA 3(c)(?-(n)7 If no,
Satlnfy Requirement?* Headline for suhminnion.
PRODUCT aiEMISTRY
163.61-6
mclaration
Yoa
finch GR. Product
tto
Yes:
Ontohor,
1981
of Ingredient Limits
161.61-7

16.1.61-8(1)
163.61-8(2)
163.61-8(7)
163.61-8(8)

163.61-8(9)
161.61-8(10)
161.61-8(11)
161.61-8(12)
16.1.61-8(11)
161.61-8(M)

163.61-8(15)
163.61-8(16)
161.61-8(17)
16.1. 61-8(18)

Product Analyt.
Methods and Data
Color
O/tor
Physical State
Dnnsity or
Spool fi'c Gravity
nailing Point
Vapor Pressure
PH
Storage Stab.
Flanmablllty
Oxidizing or
Reducing Action
ExpJonivenons
Mincihillty
Vinoonity
Corrosion
Characteristics
Yea

Yon
Yen
Yen
Yen

No
Yen
Yen
Yen
Yen
Yes

Yos
Yon
Yen
Yos

Each GR. Product

Each GR. Product
Each GR. Product
Each GR. Product
GR***


GR***
GR***
GR***
GR***
GR***

GR***
GR***
GR***
GR***

No

No
No
Yos
Nn


No
No
tto
tto
No

tto
Nn
Nn
tto

Yon:

Yon:
Yon:

Yen:


Yon:
Y"s»
Yon:
Yes:
Yen:

Yens
Yon:
Yon:
Yon:

Octolx-r,

Octohor,
Octohor,

Octohor,


Octohor,
Octohor,
Octnhor,
October,
Octohor,

Octohor ,
October,
October,
October,

1981

1981
lOfll

1981


191)1
1981
1981
1981
19D1

1981
1981
1981
1981

*   For Currently Rrqlstorod Productn
**  Each Granular Product
*** Each Granular Product or Subst.antla.11y Similar Product.
                                                                                                           IM                  « current as of
                                                                                                     May,  1981.   Refer to guidance package for
                                                                                                     updated requirements.

-------
                                                               TARLE-1-7 (oon)
                                                              WTA imiiRmmrs AMD IOTA CAPS
                                                        FOR GRANULAR aiinwmm PRT«ICTS
Huidelino
Citation
              rtmn of
Aro n.itn
Required?    Subatonoo
                                            nnos EPA Ilivc Data to
                                            Partially or Totally
                                            Satisfy Roqiiirpmont.?*
                                          nihlionraphio
                                          Citation
                                                                                                            Must Additional rv>ta ho
                                                                                                            under FIFRA 3(c)(?)int?
                                                                                                                   10 for submission.
 TCJXICOIjOnY

K.3.R1-1


161.BI-2
 161.BI-4
 ifi.i.ni-s
              Arutc Oral     Yes
              Toxicity
              Acut.o
              1V>xioity
                             YOR
              Acute Inhal.   Yes
              Ttoxicity
Prim. Ryr>
Irritntion
Prim.
Irritntton
                             Yon
                             Yos
HR"


OR**





RR**


OR**





CR**
                                            Partial?  product
                                            purity for nnni, 0021

                                            No: Amnoniim
                                            Partial:  Ann. R Mono-
                                            mf>thy) aaam., nnorl
                                            product purity for
                                            0002

                                                   Hi
                             No: Atmonlum
                             Partial: Ann. (, Mnno-
                             mothyl minon., nocd
                             product purity for
                             0001

                             Nn: Ammnnium
                             Partial: Arm. (• Mnno-
                             mnthy) nmnon., nnotl
                             product purity for
                             0002
                                                       Biosoarch, I960, 0001   You:  October,  1
                                                       Ila7.lnton, 1966, 0024

                                                       niosoaroh, J969,0002    Yns:  Octohor,  19ni
                                                                                              Yea:  Octobor, 19RI
                                                                                    Rioscarch, 1969,0001    Yos:  Ontohi^r, 19ni
                                                                                              , 1969, 0002   Yos:  October, 19R1
     For Currently Rcqistored Products
     Eiwrh Granular Product or Substantially Similar Product.
     Currontly Rcqintorod Products r/mtaininq Annonium Chloramhon llavo
     Dr-torninrd to ho Substantially Similar, and Currontly nrrjlBterod Products
     Contalninn Aimnnium Chloramhon anrl Mononothylamnniim Chlorambon aro
     Substantially Similar.  Tfcstinq  in to ho onmploted on Formulations
     containing 21.4» Aimnnium Chlorambon Affi   15.7% Anrmniim Chloramhon f.
     47.2*  Hrmomot.hyl-aniiioninii CJilorambon should ho tootod.
                                                                                   Itiese data requirements are current as of
                                                                                   tby,  1981.  Refer to guidance packayo for

                                                                                   updated requirements.

-------
                                 CHAPTER IV

                              PRODUCT CHEMISTRY
A.     Introduction
FIFRA  3(c)(2)(A)  requires the Agency to establish guidelines for
registering  pesticides  in the United States.   The Proposed Guidelines
require  registrants  to  provide quantitative data on all added ingredients,
active and inert,  which are  equal  to or greater than 0.1 percent of the
product  by weight.

To establish the  composition of products proposed for registration, the
Agency requires data and information not only 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  active and inert ingredients, or
upper limits only for some unintentional ingredients.  Subpart  D of the
Proposed Guidelines  (40 FR 29696,  July 10,  1978)  suggests specific
precision limits  for ingredients based on the percentage of ingredients and
the standard deviation  of the analytical method.

In addition  to the data on product composition, the Agency guidelines also
require data to establish the physical and  chemical properties  of both the
herbicidal active  ingredient and its formulations.  For example, data are
needed concerning  the identity and physical state of the active ingredient
(e.g., flammability,  corrosiveness or storage stability).  The  Agency uses
these data to characterize each herbicide and to  determine its
environmental and  health hazards.

B.    Chloramben Manufacturing-Use Products

     1.    Product Chemistry Profile

Technical grade chloramben is 3-amino 2,5-dichlorobenzoic acid.

Two manufacturing-use products are currently  registered.  These are the
sodium salt  of chloramben and the  methyl  ester of chloramben.

Some data are available on the physical  and chemical properties of
technical grade chloramben.   (Amchera,  196?, 0081;  Amehem, 1959, 0124;
Amchem, 1960, 0125).  It is  a white  crystalline powder,  melting at about
195°C.   (The pure  material melts at  201  C.)   It has an aqueous
solubility of 700  ppm,  and is easily soluble  in ethanol  (17.3 g/100 ml).
It is 50 percent ionized  at  a pH of  5.6.

Sodium chloramben  is  a  crystalline powder with a  bulk density about three
quarters that of water.   It  is very  soluble in water and insoluble in
aromatic solvents.  It  has no known  oxidizing or  reducing action.  (Amchem,
1974, 0054)
                                    4-1

-------
Methyl chloramben is a crystalline solid only  slightly soluble  in water
(120 ppm) and soluble in organic solvents  (alcohol,  acetone,  ether,  and
aronatic solvents),  (Amchem, 1966, 0037)

Methods for the determination of chloramben  in the technical  grade chemical
have been submitted to the Agency  (Amchem, 1979,  0054;  Amchem,  197?,
0083).  Although these methods are old, they seem adequate for  quality
control and enforcement purposes.

Analytical methods have been supplied both for the assay of manufacturing-
use and formulated products, and for the determination of isomers of
chloramben in low concentration  (Amchem, 1979, 0054;  Amchem,  197?, 0083).
These methods also are adequate  for quality  control  and enforcement
purposes.

     2.    Data Requirements and Data Gaps

Listed below are the Product chemistry data  needed to support adequately
the registration of manufacturing-use chloramben  products. Preceding each
data requirement is the section of the proposed guidelines for  the
registration of pesticides in the United States (43  FR 29696  July 10, 1978)
which describes the type of data required.   Applicants for registration
must submit or cite the following  information, which either has not  yet
been submitted to the Agency, or is insufficient  to  satisfy the
requirements.

-------
                   Data Reouirement
                                  Technical   Manufacturing-
                                  Chloramben  Use Chloramben
                                     Acid     Sodium  Methyl
163. 51-3 Identification of product and
disclosure of ingredients
163.61-4(a) C
imposition of starting and
X XX
163.61-4(b)

163.61-5


163.61-6(a)

163.61-6(b)

163.61-7

       «

163.61-8(c)
 intermediate materials  in
 manufacturing  process

 Detailed  manufacturing  process

 Discussion on  formation of
 unintentional  ingredients

 Declaration of Limits

 Certification  of  Limits

 Analytical methods and  results
                                    (results)
Physical and Chemical properties
color
odor
stability
octanol/water partition coefficient
density
vapor pressure
pH
storage stability
flammability
oxidizing or reducing action
explosiveness
miscibility
viscosity
corrosion characteristics
                                                   X
                                                   X
                                                   X
                                                   X
                                                   X
                                                   X
X

X
X

X
X      X
(results)


X
X
X


•

X
X
X
X
X
X
X
X
X
X
X
                                        4-3

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     3.    Topical Discussions

          a.   Chemical Identity

The Proposed Guidelines require identifying  information  including  chemical
names, product names, and numerical codes of all substances known  or
assumed to be present in pesticide products. (163.61-3)

"Chloramben11 is the common name accepted by  the American National  Standards
Institute (ANSI) for the chemical 3-amino 2,5-dichlorobenzoic  acid.
Chloramben is also known by the trade names  Amiben, Vegiben, and Weedone.
The common name will be used throughout this Standard  in lieu  of other
chemical or trade names.  The Chemical Abstracts number  is 133-90-4, the
EPA Shaughnessy code is 029901 and the molecular formula is
CgH2Cl2(NH2)CCOH.  It has the following structure:
                                  COOH
                                        Cl
                         Cl
The following structures  represent  respectively sodium Chloramben (Chemical
Abstracts number 1954-81-0) and methyl  Chloramben (Chemical  Abstracts
number 7286-84-2):
                     COONa
COOCH,
            Cl
                             Cl
These  are-similar to Chloramben itself except that the carboxylic acid
hydrogen has been replaced by  sodium or by the methyl  group.

          b.   Manufacturing Processes

Because the route by which a pesticide is synthesized  determines the nature
and amount of potentially toxic impurities, a detailed description of the
manufacturing process is  required  (163.61-4).

The details of the process which have  been submitted are  lacking in many
details, including concentrations,  equipment used, the process solvents,
the reaction conditions  (including  temperatures  and periods of time for
elevated temperatures), purification steps, quality control measures, an
indication of whether batch or continuous process  is used, and a
description of materials  used  for packaging.  The  confidential appendix to
this document contains the submitted information on the manufacturing
processes.  This  information is not sufficiently detailed, and does not
provide sufficient data to fulfill  requirements.
                                     4-4

-------
          c.   Formation of  Unintentional Ingredients

Section 163.61-5 of  the Proposed Guidelines requires registrants of_
technical grade, manufacturing-use,  and  formulated products to submit a
theoretical discussion of  the  formation  of unintended substances in the
product.

Available data on known impurities  in  chloramben manufacturing-use products
are summarized in the confidential discussion appendix to this document.  A
discussion of the formation  of these impurities in sodium and methyl
chloramben manufacturing-use products  is required.

Use of the specific  nitrosamine detector in the analysis of "Amiben"
(Amchem, 1978, 0153) indicates that  nitrosamines are not present in this
formulation.  The level of detection was .05 ppm.  Available information on
the manufacturing process does not cause suspicions of nitrosamine
formation.  Additional data  are not  required on nitrosamines.

          d.   Ingredient Limits in  Pesticide Products

The Guidelines require that  upper and  lower limits be established for each
active ingredient and each intentionally added inert in a pesticide product
(163.61-6).  She two manufacturing-use chloramben products contain
approximately 90 percent of chloramben acid equivalent in both cases.
Upper and lower limits have  not been established and certified for
manufacturing-use methyl chloramben.

          e.   Analytical Methods and  Data

The Guidelines require submission of,  or reference to, analytical methods
for measuring each active ingredient and each identifiable impurity in a
pesticide product (163.61-7).

Section 163.61-7 of  the Proposed Guidelines also require that applications
for registration of pesticide  products contain analytical data obtained  by
methods supplied to  the Agency.

Acceptable methods for the determination of chloramben and some impurities
in manufacturing-use chloramben are  contained  in the confidental  discussion
appendix.  Data obtained by the method are not available.

          f.   Physical and Chemical Properties

For every pesticide product, the Proposed  Guidelines require data on
certain physical and chemical  properties  useful  for identification purposes
or for evaluation of hazard potential  (163.61-8).

A small amount of data are available on  the  physical and  chemical
properties of chloramben acid,  sodium  chloramben,  and methyl chloramben.
An outline of the properties of chloramben acid,  sodium chlcramben, and
methyl chloramben was given  in the product chemistry profile earlier in
this chacter.  Sane additional details on  these  comcounds follows:
                                    4-5

-------
Chloramben (Amchem, 196?, 0081; Amchem, 1959, 0124; Amchem, 1960, 0125)

  Color: White
  Melting Point: 200-201°C
  Physical State: Crystalline solid
  Stability: Stable towards oxidation and heat under conventional
             conditions
  Solubility: Water, .07g/100g; ethanol, 17.3g/100g
  Vapor Pressure:  .0007 ran Hg at 100


Sodium chloramben:  (Amehem, 1979, 0054; Amehem, 1979 jacket 264-306)

  Color:  Conflicting data submitted
  Melting Point: 271°C  ,
  Physical State:  Crystalline solid, described as granular hollow sphere
  Stability:  Temperature stable at least up to the melting point.
  Solubility: Very easily soluble in water, insoluble in aromatic solvents


Methyl chloramben:  (Amehem, 1966, 0037)

  Color:  Off white
  Melting Point:  63-64 C
  Physical State:  Crystalline solid
  Stability:  Temperature stable at least up to the melting point.  Stable
              under GC conditions.
  Solubility: Water, 120 ppm; soluble in aromatic solvents (alcohol,
              acetone, ether, aromatic solvents)

-------
C.    Soluble Concentrate Chloramben

In this category there are two basic configurations or  formulations  of
chloramben.  First, there is a formulation in which the ammonium  salt  of
chloramben is the sole active ingredient at a concentration of  23.4
percent.  There is a second formulation in which ammonium chloramben (15.7
percent) and the nonomethyl ammonium salt (47.2 percent) of chloramben are
both ingredients.

These end-use products are produced by an integrated formulation  system.
Product chemistry data are required on technical grade ammonium and
monomethyl ammonium chloramben, as well as on specific end-use products.

No physical or chemical properties were disclosed for ammonium or
monomethyl ammonium chloramben or any end-use formulations.

1.    Data Gaps

Data needed on technical grade ammonium and moncmethyl ammonium
chloramben in soluble concentrate products:

          1)   Identification	163.61-3 (b)
          2)   Composition of material	163.61-3(c)
          3)   Analytical methods and data	163.61-7
          4)   Physical and chemical properties
              a. Color (moncmethyl ammonium chloramben)	163.61-8(c)(l)
              b. Cdor	163.61-8(c)(2)
              c. Melting point	163.61-8(c)(3)
              d. Solubility	163.61-8 (c) (4)
              e. Stability	163.61-8(c) (5)
              f. Octanol/Water particion coefficient	163.61-8(c)(6)
              g. Physical state	163.61-8(c) (7)
              h. Specific gravity or density	163.61-8(c)(8)
              i. Boiling point	163.61-8(c)(9)
              j. Vapor pressure	163.61-8(c) (10)
              fc. pH	163.61-8(c) (11)
Data needed on soluble concentrate end-use products:

          1)  Declaration and certification of limits	163.61-6
          2)  Analytical methods and data	163.61-7
          3)  Physical and chemical properties
              a. Color	163.61-8(c) (1)
              b. Cdor	163.61-8(c) (2)
              c. Density or Specific Gravity	163.61-8(c) (8)
              d. Boiling Point	163.61-8(c) (9)
              e. Vapor Pressure	163.61-8(c)( 10)
              f. pH	.	163.61-8(c) (11)
              g. Storage Stability	163.61-8(c)(12)
              h. Flammability	163.61-8(c)(13)
              i. Oxidizing or Reducing Action	163.61-8(c)( 14)
              j . Explosiveness	163.61-8(c) (15)
              k. Miscibility	163.61-8(c) (16)
              1. Viscosity	163.61-3 (c) (17)
              m. Corrosion Characteristics	163.61-3(c) (18)
                                    4-7

-------
2.    Topical Discussions

The Agency has not received acceptable  product chemistry data for any
soluble concentrate chloramben product  nor  for technical grade ammonium
chloramben or moncmethyl ammonium chloramben.

The following are data required of all  soluble concentrate formulated
products of chloramben.

          a.   Chemical Identity  and  Disclosure of Ingredients

The proposed Guidelines require that  the  technical grade of each active
ingredient in a  formulated product be identified by name and by statement
of formula identifying each reasonably  identifiable substance in the
technical grade  chemical.  Each of these  substances shall be listed as a
percentage or as ppm  (by weight)  of the technical chemical used in the
product.

Data on technical grade ammonium  and  technical grade moncmethyl ammonium
chloramben have  not 'been submitted in sufficient detail.

In addition, the proposed Guidelines  require that applications for
registration of  a formulated  product  shall  contain identifying information
on each substance known to be present in  the product, and those reaction
products and degradation products known or  theorized to be formed in the
pesticide product during its  manufacture  or during its marketable life.

Insufficient data have been submitted.

          b.   Active Ingredient  Limits

For all pesticides, the Guidelines require  that the upper and lower limits
be established for each active and inert  ingredient, and upper limits for
each possible reaction product and degradation product (163.61-6).  Current
registrations of soluble concentrate  chloramben contain 23.4 percent
ammonium chloramben in the case where ammonium chloramben is the sole
active ingredient and 15.7 percent ammonium chloramben and 47.2 percent
moncmethyl ammonium chloramben in the case  where the two salts are mixed.

For neither  soluble concentrate  formulation of chloramben has an upper and
lower active ingredient limit been established for possible reaction
products or  degradation products.

          c.   Analytical Methods and Data

The Guidelines would  require  submission of, or reference to, analytical
methods measuring each active ingredient  in a pesticide product (163.61-
7).  Methods for the  determination of total anionic amino compound present
and for the  determination of  chloramben and its iscmers have been submitted
(Arachem, 1979, 0054;  Amchem,  197?, 0083).  The determination is done in two
steps.  First, all amino compounds are  determined via diazcmetric
titration.   The  chloramben  itself is  determined by methylating the
carboxylic acid  group and determining the methyl ester concentration via
gas chrcmatography.   In this  method  the methyl 3-amino 2,5-dichlorobenzoate

-------
is separated by  the gas  chronatographic technique fron other related amino
compounds  (most  of which are  related  aminodichlorobenzoic esters) and
determined as a  pure  isoner.

Section 163.61-7 of the  Proposed Guidelines requires that applicants for
registration of  pesticide products  submit analytical data obtained by
methods supplied to the  Agency.  Data obtained by the method described
above have not been submitted  for soluble concentrate products.

Section 163.61-7 of the  Proposed Guidelines would also require that
registrants.of the formulated  products produced by the integrated
formulation system (Proposed Guidelines Section 163.61-1) submit methods
not only for the active  ingredient  but for each identifiable impurity
associated with  manufacture of the  technical chemical.  Since the active
ingredients (ammonium and monomethyl  ammonium chloramben) in soluble
concentrate products are not registered manufacturing-use products, the
manufacturing process for these products is  an integrated formulation
system.  Analytical methods, and data obtained from these methods are
required for each identifiable impurity.

Such methods and data have not been submitted for any chloramben
formulation.

          d.   Physical and Chemical  Properties

For every pesticide product the Proposed  Guidelines would require data  on
certain physical and chemical properties useful for identification purposes
or for evaluation of hazard potential.   (163.61-8)

There are no data available except  for the off-white color of ammonium
chloramben.
                                    4-9

-------
D.    Flowable Concentrate Chloramben

In this category are  formulations of  sodium chloramben (a registered
manufacturing-use' chemical) as  the  sole  active ingredient.  The two
registered formulations contain 83  and 21 percent sodium chloramben,
respectively.

1.    Data Gaps

          1)   [Declaration and  certification of limits	163.61-6
          2)   Data from analytical methods	163.61-7
          3)   Physical and chemical  properties
               a.   Color	163.61-8(c) (1)
               b.   Cdor	163.61-8(c)(2)
               c.   Density or  Specific  Gravity	163.81-8(c) (8)
               d.   Boiling Point	163.61-8(c) (9)
               e.   Vapor Pressure	 163.61-8(c) (10)
               f.   pH	163.61-8(0)(11)
               g.   Storage Stability	163.61-8(c) (12)
               h.   Flammability	163.61-8(c) (13)
               i.   Oxidizing or Reducing Action	163.61-8(c) (14)
               j.   Explosiveness	 163.61-8(c)(lS)
               k.   Corrosion Characteristics	163.61-8(c) (18)

2.    Topical Discussions

The product  chemistry of sodium chloramben per se has been dealt with under
Manufacturing-use Products.

          a.  Ingredient Limits in Pesticide Products

For all pesticide products, the Guidelines would require that upper and
lower limits be  established for each  active and inert ingredient, and upper
limits for each  impurity, reaction  product, and degradation product (163.61-
6).

For no flowable  concentrate formulation  of chloramben have limits been
established  for  impurities, reactions products or degradation products.

          b.  Analytical .Methods and Data

The Guidelines would  require submission  of, or reference to, analytical
methods measuring each  active  ingredient in a herbicide product (163.61-7).

Methods for  the  determination of chloramben in flowable concentrate
formulations have been  submitted and  are attached in the Confidential
Appendix.  These methods are similar  to  those outlined under Section C of
this chapter for soluble concentrates of chloramben.

Section 163.61-7 of the Proposed Guidelines would require that applications
for registration of pesticide products contain analytical data obtained  by
methods supplied to the Agency. Data obtained by the methods referred to
above have not been submitted.
                                    4-10

-------
          c.   Physical and Chemical Properties

For every pesticide product/ the Proposed Guidelines require data  on
certain physical and chemical properties useful for identification purposes
or for evaluation of hazard potential (163.61-8).  None of the  required
data have been submitted.
                                  4-11

-------
E.    Emulsifiable Concentrate Chloramben

There is one registered emulsifiable concentrate of chloramben.   Methyl
chloramben is contained as the sole active  ingredient  at  23.2  percent:

1.    Data Gaps

          1)   Declaration and certification of limits	163.61-6
          2)   Analytical methods and data	163.61-7
          3)   Physical and chemical properties
               a.   Color	163.61-8(c)(l)
               b.   Cdor	163.61-8(c)(2)
               c.   Density or Specific Gravity	163.81-8(c) (8)
               d.   Boiling Point	163.61-8(c) (9)
               e.   Vapor Pressure	163.61-8(c) (10)
               f.   pH	  163.61-8(c)(11)
               g.   Storage Stability	163.61-8(c) (12)
               -h.   Flammability	163.61-8 (c)( 13)
               i.   Oxidizing or Reducing Action	163.61-8(c) (14)
               j.   Explosiveness	163.61-8(c) (15)
               k.   Corrosion Gharacteristics	163.61-8(c) (18)

2.    Topical Discussions

The product chemistry of methyl chloramben  per se  has  been described
previously/ under Manufacturing-use products.

          a.   Ingredient Limits  in Pesticide  Products

For all pesticide products, the Guidelines  would require  that  upper and
lower limits be  established for each active and inert  ingredient, and upper
limits for each  impurity, reaction product, and degradation  product (163.61-
6).

Upper and lower  limits have not been established for impurities,  reaction
products or degradation products  in the currently  registered emulsifiable
concentrate product.

          b.   Analytical Methods and Data

The Guidelines would require submission of, or reference  to, analytical
methods measuring each active ingredient  in a  herbicide product  (163.61-7).

Methods for the  determination of chloramben in soluble concentrate
formulations have been submittec  and are  attached  in the  confidential
appendix.  These methods are not readily  adaptable to  the analysis of
chloramben in emulsifiable concentrate formulations, and  hence the lack of
a suitable analytical method is  identified  as  a data gap.

Section 163.61-7 of the Proposed Guidelines would  require that applications
for registration of pesticide products contain analytical data obtained by
methods supplied to the Agency,  No such  data  have been submitted.
                                    4-12

-------
          c.   Physical and Chemical Properties

For every pesticide product, the Proposed Guidelines require  data  on
certain physical and chemical properties useful for identification purposes
or for evaluation of hazard potential  (163.61-8).  None of  the  required
data has been submitted.
                                   4-13

-------
F.    Granular Chlorainben

Granular chloramben exists in two different  forms.  The  first  is  granular
chloramben where 'the sole active ingredient  is ammonium  chloramben.  This
exists in formulations of 1.3 percent, 4.3 percent and 10.8 percent
ammonium chloramben.  The second formulation is one in which ammonium
chloramben is mixed with moncmethyl ammonium chloramben.  This  exists  in
two different concentrations.  One is 5.4 percent ammonium chloramben  plus
17.3 percent moncmethyl ammonium chloramben.  The other  is 2.82 percent
ammonium chloramben and 8.46 percent monomethyl ammonium chloramben.

Granular chloramben products, like soluble concentrate chloramben products,
are produced by  integrated formulation systems.  Consequently,  product
chemistry data are required on the technical grade ammonium and monomethyl
ammonium chloramben in 'addition to data on specific end-use products.

     1.    Data Gaps

Data needed on technical grade ammonium and moncmethyl ammonium
chloramben:

          1)  Identification	163.61-3(b)
          2)  Composition of material	163.61-3(c)
          3)  Analytical methods and data	163.61-7
          4)  Physical and chemical properties
              a. Color (monomethyl ammonium  chloramben)	163.61-8 (c) (1)
              b. Cdor	163.61-8(c)(2)
              c. Melting point	163.61-8(c)(3)
              d. Solubility	163.61-8(c)(4)
              e. Stability	163.61-8(c) (5)
              f. Octanol/Water particicn coefficient	163.61-8(c) (6)
              g. Physical state	163.61-8(b) (7)
              h. Specific gravity or density	163.61-8(c)(8)
              i. Boiling point....,	163.61-8(c)(9)
              j. Vapor pressure	163.61-8(c) (10)
              Ic. pfi	163.61-8(c) (11)
Data needed on granular end-use products:

          1)  Declaration and certification of  limits	163.61-6
          2)  Analytical methods and data	163.61-7
          3)  Physical and chemical properties
              a." Color	163.61-8(c)(l)
              b. Cdor	163.61-8(cM2)
              c. Density or Specific Gravity	163.61-8(c)(8)
              d. Boiling Point	163.61-8(c)(9)
              e. Vapor Pressure	163.61-8(c) (10)
              f. pfl	163.61-8(c)( 11)
              g. Storage Stability	163.61-8(c) (12)
              h. Flammability	163.61-8(c)( 13)
              i. Oxidizing or Reducing Action	163.61-8(c) (14)
              j . Explosiveness	163.61-8(c) (15)
              k. Miscibility	163.61-3(c) (16)
              1. Viscosity	163.61-8 (c) (17)
              m. Corrosion Characteristics	163.61-3(c) (18)
                                    4-14

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2.    Topical Discussions

The Agency has not  received  acceptable product chemistry data for any
granular chloramben product.  Mo  data on technical grade ammonium or
rvonomethyl ammonium chloramben  have  been submitted.

          a.   Chemical  Identity  and Disclosure of Ingredients

The proposed Guidelines  require that the technical grade of each active
ingredient in a formulated product be identified by name and by statement
of formula identifying each  reasonably identifiable substance in the
technical grade chemical.  Each of these substances shall be listed as a
percentage or as. ppm  (by weight)  of  the technical chemical used in the
product.

Data on technical grade  ammonium  and moncmethyl ammonium chloramben have
not been submitted in sufficient  detail.

In addition, the proposed Guidelines require  that applications for
registration of a formulated product shall contain identifying information
on each substance known  to be present in the  product, and those reaction
products and degradation products known or theorized to be formed in the
pesticide product during its manufacture or during its marketable life.

Insufficient data have been submitted.

          b.   Active Ingredient  Limits in Pesticide Produces

For all pesticide products, the Guidelines would require that upper and
lower limits be established for each active and inert ingredient, and upper
limits for each impurity, reaction product, and degradation product (163.61-
5).

For no granular formulation of  chloramben has an upper and lower limit been
established.

          c.   Analytical Methods, and Data

The Guidelines would require submission of, or reference to,  analytical
methods measuring each active ingredient  in a herbicide product  (163.61-
7).  Methods for the determination of chloramben in soluble concentrate
formulations have been submitted, as previously discussed.  It is felt that
these methods may not be suitable for the determination of chloramben in
granular formulations because the prescence of large quantities  of solid
inerts, which are likely to have  adsorptive properties, mate  uncertain
recoveries of chloramben from granular  formulations.

Section 163.61-7 of the Proposed  Guidelines would  require that applications
for registration of pesticide products  contain analytical data obtained by
methods supplied to the Agency.   Such analytical data have not been
submitted.

Section 163.61-7 of the Proposed  Guidelines would  also require that
registrants of formulated products produced by an  integrated  formulation
system (Proposed Guidelines, Section 163.61-1)  submit methods not only for
                                   4-15

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the active ingredient, but for each  identifiable  impurity associated with
manufacture of the technical chemical.   Such  methods have not been
submitted for any chloramben formulation.   Since  the active ingredients
(ammonium and monbmethyl ammonium  chloramben)  in  granular chloramben
products are not registered inanufactur ing-use products,  the manufacturing
process for these products is an integrated formulation  system.  Analytical
methods and data obtained through  the use of  these  methods are required for
each identifiable impurity,

          d.   Physical and Chemical Properties

For every pesticide product, the Proposed Guidelines would require data on
certain physical and chemical properties useful for identification purposes
or for evaluation of hazard potential  (163.61-8).  None  of the required
data has been submitted.
                                    4-16

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                                 CHAPTER V

                     ENVIRONMENTAL FATE  OF CHLORAMBEN

A.   Introduction

Data on the fate of a pesticide once  it  enters  the  environment are required
to predict and estimate any potentially  harmful effects on man and the
environment.  The fate of a pesticide depends on  its  formulation type,
application methods or use patterns and  its chemical, physical/ and
biological behavior in the environment.

Environmental studies from which data are  required  include physical and
chemical degradation, metabolism, field  dissipation,  and  accumulation.

Chloramben is available in four types of formulations: soluble
concentrates, flowable concentrates, emulsifiable concentrates, and
granulars.  These formulations contain a variety of salts and  esters of
chloramben including sodium chloramben, methyl chloramben, ammonium
chloramben, and moncmethyl ammonium chloramben.  Sodium chloramben and
methyl chloramben are registered manufacturing-use products.   The  Agency
has determined that data on the fate of chloramben in the environment are
required on sodium and methyl chloramben.  Data requested on sodium
chloramben will support the registrations of products containing the sodium
salt and products containing the ammonium  and moncmethyl  ammonium  salts.

B.   Use Profile

The herbicide chloramben is used for the control of seedling annual grasses
and seedling broadleaf weeds.  The mechanism of action is the  inhibition of
root development in weed seedlings.  The use of chloramben is  principally
pre-emergent, with some post-emergent use also.

Chloramben is registered for use in dry beans (white, navy, kidney, pinto,
and lima), peanuts, soybeans, sunflowers, corn, sweet potatoes,  squash,
pumpkins, asparagus (seedling), transplanted tomatoes and peppers,
snapbeans, lima beans, cantaloupes, cucumbers, annual and perennial
flowers, shrubs, and trees.

Based on a preliminary quantitative usage analysis (PQJJA) of chloramben
prepared by.Economic Analysis Branch (EAB), about 96 percent of  the
chloramben production is used on soybeans primarily in the north central
states.  This use represents approximately 7 percent of the total  U.S.
soybean acreage.

Of 24 federally registered products, Union Carbide Agricultural  Products,
Inc. is the major producer with seventeen registered products.   There are
four other registrants.  Chloramben is registered as the ammonium  salt/
diethanolamine salt, sodium salt, moncraethyl ammonium salt, and  the methyl
ester.  Table 5-1 presents a complete listing of the chloramben  federal
registrations together with the form and concentration of the active
ingredient(s).  Chloramben' is the sole active ingredient  in 16
                                    5-1

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registrations.  These 16 registrations include soluble concentrates,
flowable concentrates, emulsifiable concentrates, and granular
formulations.  Mot covered under this standard but included in Table 5-1
are eight registered mixtures of chloramben with other herbicides.  Most of
the registered orcducts are designed for general agricultural use.
However, one granular formulation, *264-191 is used primarily by
homeowners.  Table 5-2 gives the registered application rates of chloramben
as indicated on product labels.
                                     5-2

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                                 TABLE  5-1
Registration *
264-138
264-167
264-175
264-178
264-191
264-243
264-251
264-253
264-254
264-256
264-260
264-266
Form'
SC
G
G
SC
G
G
G
WP
WP
EC
EC
SC
                        Chloramben Registrations

                             2
264-274



264-278

264-279

264-305

264-306

449-534


635-630
T

T

PC

EC

FC
  % Active Ingredient

 23.4% ammonium chloramben

 10.8% ammonium chloramben

 10.8% ammonium chloramben

 23.4% ammonium chloramben

  1.3% ammonium chloramben

  4.3% ammonium chloramben

  5.4% ammonium chloramben plus
 17.3% monanethylammonium
 chloramben

 27.7% sodium chloramben  and
 50.0% atrazine

 41.7% sodium chloramben  and
 12.5% linuron

 15.7% diethanolamine
       chloramben and
 30.1% diethanolamine dinoseb

 23.2% methyl chloramben

 15.7% ammonium chloramben  and
 47.2% monanethylammonium
 chloramben

 2.32% ammonium chloramben and
 8.46% monanethylammonium
       chloramben

 98.8% methyl chloramben

 97.2%  sodium chloramben

 83.0% sodium chloramben

 21.0% sodium chloramben

 17.5% ammonium chloramben
12.9% norea

 5.4% ammonium chloramben and
 4.0% norea

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 Registration

635-631


2749-160

2749-202

43142-29


43142-30
                                 TABLE 5-1

                  Chloramben Registrations  - Continued
Form

FC


G

SC

FC
                                               % Active Ingredient

                                             17.5% ammonium chloramben and
                                             12.9% norea

                                             10.8% anmonium chloramben

                                             23.4% ammonium chloramben

                                             17.5% ammonium chloramben and
                                             12.9% norea

                                              5.4% ammonium chloramben and
                                              4.0% norea
1) Source for Table 5-1 was a PRD-1 printout dated June 12, 1980.
2) SC = Soluble Concentrate, G = Granular, WP = Wettable Powder,
   EC = anulsifiable Concentrate, T = Technical, FC = Flowable Concentrate,
                                    5-4

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                                 TABLE 5-2

                REGISTERED APPLICATION RATES FOR CHLORAMBEN
     Formulation Type

Soluble Concentrates

     23.4%-62.9%
                                   Site
                              Soybeans,  dry beans,
                              peanuts, sunflowers
Arolication Rate
                                                                  (1)
                                                  (Ib.  a.i.  per acre)
Flowable Concentrates

     21%-83%
                              Corn

                              Lima beans, squash, pumpkin

                              Asparagus (seedling)

                              Sweet potatoes
                              Soybeans,  dry beans,
                              peanuts, sunflowers
Emulsifiable Concentrate

     23.2%


Granular

     1.3%-22.7%
          2-3


          2

          2-4

          3

          4



          2-3
                              Lima beans, squash, pumpkin   2-4

                              Asparagus (seedling)           3

                              Sweet potatoes                4
                              Snap beans, cantaloupes,      2-3
                              cucumbers
                              Soybeans, dry beans,          2-3
                              peanuts, sunflowers

                              Corn                          2

                              Sweet potatoes                4

                              Ornamentals                   4-6

                              Transplanted tomatoes and     4
                              peppers, lima beans,
                              pumpkins, squash,
                              asparagus (seedling)

(1)   Where  ranges  are given,  the higher rates are for heavy soils.
                                    5-5

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C.  Manufacturing-Use Chloramben

     1.   Environmental Fate Profile

          Sodium Chloramben

Sodium chloramben appears  to be resistant to hydrolysis.   This conclusion
is, however, based on retention of  phytotoxicity rather than actual field
residue data.  Limited studies indicate that there is no loss of
phytotoxicity when aqueous solutions of chloramben are kept in the dark.

Photodegradation of  sodium chloramben  aqueous solutions appears to occur
readily in sunlight.  Total loss of phytotoxicity occurs in two days.  Loss
of phytotoxicity on  dry soil is somewhat slower, being about 30 percent in
48 hours.

Soil bacteria bring  about  a loss of phytotoxicity in sodium chloramben
after several weeks.  It appears that  this is due to a decarboxylation.
The rate of reaction appears to be  independent of soil pH within the range
of 4.3 to 7.5.

Chloramben may have  bactericidal properties towards Rhizobium japonicum.
No other data are available on the  effects of chloramben on other bacteria,
nor on activated sludge.

The mobility of sodium chloramben  is governed principally by its high
solubility in water  and its apparent limited strength of adsorption to soil
particles.  It appears to  easily leach down in most soil types by rainfall.
This factor, together with an apparent slow rate of bacterial degradation,
indicates a potential for  groundwater  contamination.

Probably all plants  grown  in contact with sodium chloramben take up the1
compound.  In some plants  the subsequent movement of compound away from the
roots is very slow,  whereas in others  it readily spreads throughout the
plant.  The fate of  chloramben in  plants includes decomposition, a
detoxifying conjugation which proceeds fairly rapidly, or a detoxifying
conjugation which goes slowly, if  at all.

          Methyl Chloramben

The methyl ester -of  chloramben acid appears to have the expected properties
of a carboxylic acid ester.  It is  apparently not hydrolysed after a short
period  in contact with water at slightly acid pH values (5 to 6).  Bacteria-
mediated hydrolysis  appears to be  quick: approximately 50 percent of the
ester  is converted  to  the  free acid" in about one week when in contact with
wet soil.  A subsequent and slower bacteria reaction, shown by a loss of
phytotoxicity,  is probably a decarboxylation, as with sodium chloramben.

The leaching behavior of the methyl ester is governed 'by its aqueous
solubility, which  is much  lower  than  that of the sodium salt (120 ppm and
250,000 ppm, respectively).  For a  given rainfall the ester seems to leach
down about 15 percent of  the distance  travelled by the sodium salt.

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      2.    Exposure  Profile

Exposure  to persons involved  in  the manufacture, handling, storage or
shipment  of technical or manufacturing-use grade chloramben is possible
through four  pathways; accidental  ocular or dermal exposure, inhalation
exposure,  and repeated dermal exposure.   Due to the scarcity of data on
occupational  exposure of these two grades of chloramben, it is impossible
to quantitatively assess the human and wildlife exposure hazard.

There  is  little  likelihood of oral and ocular exposure occurring unless by
accident,  the low  volatility of flowable and soluble concentrates
indicates  that there is also  little chance of inhalation exposure under
normal circumstances.  The granular chloramben may present a higher
possibility of inhalation exposure to workers involved in bulk loading,
unloading, and packaging of the substance.   Due to its dry and solid
physical  state,  the chances of it  being  inhaled in these work areas as an
airborne particulate are moderately high.

In addition, repeated dermal exposure to all forms of manufacturing-use and
technical  grade  chloramben present the highest exposure hazard.  This may
occur  in  the manufacturing and shipping  phases of its production but the
greatest repeated exposure is expected during bulk handling operations.

Should significant  amounts of chloramben be spilled, drained, discharged or
disposed of in the  natural environment,  aquatic life in waters affected by
direct drainage  or  leaching are expected to receive high dosages of
herbicide.

     3.    Data Requirements and Data Gaps

Not all the requirements of Section 163.62  (43 FR 29696, July 10, 1978)
need to be fulfilled to support the registration of chloramben as a
manufacturing-use product and as a  formulated product,  because the use
pattern indicates that chloramben  is unlikely to enter the environment in
particular specified ways.

To support the registration of all  chloramben products, it is necessary to
submit or cite the  following data  tested on both sodium and methyl
chloramben.

163.62-7       Physico-Chemical Degradation
               (b)  Hydrolysis
               (c)  Phytodegradation in  water  *
               (c)  Photodegradation in  soil
163.62-8       Metabolism
               (b)  Soil metabolism - aerobic
               (c)  Soil metabolism - anaerobic
163.62-9       Mobility
               (b)  Leaching
               (d)  Adsorption/desorption
163.62-10      Field Dissipation
               (b)  Terrestrial
163.62-11      Accumulation
               (b)  Rotational crops
               (d)  Fish accumulation
                                    5-7

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In addition to the above  listed  requirements,  a field study measuring
applicator exposure  to  liquid  formulations of  chloramben is required.  The
study should be conducted with a typical  soluble or flowable concentrate
formulation, which is mixed  and  then  applied by ground equipment to a
typical (160 acres)  soybean  field at  recommended application rates.  The
Agency is requiring  this  study to verify  the exposure estimates used in the
oncogenic risk assessment.

Data Gaps

Although some data on the environmental fate of chloramben are currently
available, none of the  data  requirements  have  been satisfied sufficiently
with the exception of fish accumulation data on sodium chloramben.

     4.   Topical Discussions

Corresponding to, each of  the Topical  Discussions listed below is the number
of the section in the "Proposed  Guidelines for Registering Pesticides in
the United States"  (43  FR 29696, July 10, 1978) which explains the minimum
data that the Agency requires  in order to adequately assess a pesticide's
Environmental Fate.

All topics related to the Environmental Fate of chloramben as an active
ingredient are discussed  under Manufacturing-Use Chloramben.

          a.   Physico-Chemical  Degradation 163.62-7

These studies should identify  decomposition rates and pesticide residues
which could adversely affect the environment.   They include studies of the
degradation of chloramben in the prescence of  water, and when subject to
the action of light. Studies  already carried  out suggest that there are
three pathways of degradation.  One,  the  formation of free chloramben acid
by ionization of the sodium  salt or the breaking of the ester bond of
methyl chloramben, results in  a  compound  which is fully phytotoxic.  A
second pathway, a loss  of the  carboxylic  acid  group, probably occurs by the
action of some bacteria,  and results  in an apparently non-phytotoxic
compound.  A third degradation pathway occurs  under the influence of
sunlight, and appears to  involve the  loss of a chlorine atom from the
chloramben molecule. This too,  involves  a loss of phytotoxicity.  It
should be noted  that loss of phytotoxicity is  not a suitable measure of the
extent of hydrolysis or photodegradation  as these processes may veil
proceed by way of degradation  products which have some level of
phytotoxicity.

               i.    Hydrolysis

Hydrolysis data are  required to  support the registration of all
manufacturing-use products and end-use formulations of chloramben.

                     Sodium Chloramben

Chloramben free acid and  its salts (sodium, ammonium, etc.) appear to be
resistant to hydrolysis,  judging from data showing the retention of
phytotoxicity after  several  weeks of chloramben in non-sterile moist soils
 (Sheets, 1968, 05107).  More recent data  (Union Carbide, 1980, 0172) show
that when protected  from  light,  chloramben acid undergoes slow degradation


                                     5-3

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in aqueous solution.   Eighty-five  percent or larger amounts of chloramben
initially present were recovered after one year at an acid pH and 25 C.

These studies will partially  satisfy Agency requirements for hydrolysis
data on sodium chloramben.  Data are needed on hydrolysis at other pH's for
sodium chloramben.

                    Methyl Chloramben

The methyl ester is susceptible to hydrolysis by bacterial action in soil
which contains enough  moisture to  support bacterial activity.  An Amehem
document (Amchem, 1966, 0148) showed that the methyl ester gave no
measureable hydrolysis in 48 hours when in contact with well water at a pH
of 5 to 6; however, when soil (and therefore bacteria)  was present in the
water there was a measurable hydrolysis within 48 hours, involving a
cleavage of the ester  bond to yield the free chloramben acid.

The methyl ester is hydrolyzed in  moist soil to the free acid;  however, if
the soil is first sterilized, no breakdown of the ester occurs  (Corbin,
1967, 0586; Talbert, 1970, 05111).

The presumption from these studies is that the methyl ester is  relatively
unaffected by water in the absence  of bacteria;  however, these  data are
inadequate to meet the requirements of the section.  Additional testing on
methyl chloramben are  required.

               ii.  Photodegradation

Photodegradation studies in water  are required to support the registration
of all chloramben formulations for  non-crop uses.  Studies in soil are
required to support the registration of all chloramben  formulations
intended for crop uses.

Several studies have been made of  the effects of sunlight on chloramben.
All these studies are  inadequate in  that the products of photolysis were
not sufficiently identified or characterized.  These studies do provide
insight into the Photodegradation of chloramben.

Chloramben on the surface of field-capacity soil  and irradiated for 48
hours lost 38 percent  of its herbicide activity,  whereas the loss on dry
soil was 30 percent.   There was a  loss of phytotoxicity to oats in 7.5
hours after exposure to sunlight on  the surface of  field capacity soil
(Fickle, 1974, 0589).

An aqueous solution of the sodium  salt became yellow-brown, indicating
chemical change, upon  exposure to sunlight for periods  of up to 14 days.
The products were not  identified except for chloride ions (Crosbv, 1969,.
0587; Plimmer, 1969, 05106).

Two days exposure to sunlight was  sufficient to produce total loss of
phytotoxicity of chloramben aqueous  solutions to  cucumbers.   However,
similar solutions kept' in the dark  showed no change in  phytotoxicity after
2 days (Hahn, 1969, 0594).

There are no data on the extent of  Photodegradation under cloudy
conditions.  Available data on the photolysis of  chloramben are not


                                     5-9

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sufficient to determine the effects of  light on chloramben.  All data are
required on both sodium and methyl chloramben par section 163.62-7.

There are no data to  indicate whether the first products of
photodegradation retain phytotoxic properties, or whether photodegradation
involves an immediate loss of herbicidal properties.

          b.   Metabolism 163.62-8

Data on metabolism are required  to determine the nature of pesticide
residues and their availability  to rotational crops, and to help in the
assessment of potential disposal and  reentry hazards.  Although
preliminarydata presented in the following discussions provide insight into
the metabolism of chloramben, .the data  are inadequate and do not satisfy
the guideline requirements.  The data gaps exist for both methyl and sodium
chloramben.

               i.   Soil Metabolism

Aerobic metabolism studies are required to support the registration of all
formulations.  Anaerobic soil metabolism studies are required to support
the registration of all formulations  intended for field and vegetable crop
uses.

                    Sodium Chloramben

An experiment with pure chloramben showed that phytotoxicity to Italian rye
grass  (8 pern in soil) became negligible after 16 weeks in a sandy loam and
a silty clay loam.  In a clay, however, after 16 weeks only about 60
percent of the control level of  rye grass growth was present (Sheets, 1968,
05107).  These results are probably due to the different levels of
bacterial activity in the soils; however, the Agency cannot rule out ttje
possibility that the  different results  were due to different leaching rates
through the soils.  Another study (Amchem, 1967, 0043) snowed that after a
period of 4-6 weeks a rapid loss of chloramben occurs in soils with a high
organic content, probably due to the  microbial populations reaching a
logarithmic phase  in  their growth cycle at this point.

A study of the effect of pH on loss of  herbicide activity showed a similar
rate of loss at pfi levels of 4.3, 5.3,  6.5, and 7.5, the soil being
unchanged  in respects other than pH  (Corbin, 1967, 0586).

Only minimal data  on  the metabolism of  sodium chloramben are available.
Additional data specified  in Section  163.62-8(b,c) are needed to determine
metabolism of  chloramben  in soil.

                    Methyl Chloramben

Soil bacteria  cause hydrolysis of chloramben methyl ester to the free acid
at a rate directly dependent on  the content of water (Amchem, 1965, 1966,
0148).  Chloramben methyl  ester  is hydrolyzed in wet soil by bacterial
action.  Approximately  50 percent of  the compound is converted to the free
acid  in from 2 to 3 days.  When  the soil was partially dried the rate of
hydrolysis was less,  with about  30 percent being hydrolyzed in 14 days.
If, however,  the soil is  first sterilized, no breakdown of the ester occurs
 (Corbin, 1967, 0586;  Talbert,  1970, 05111).
                                    5-10

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Data provided are  insufficient  to  differentiate between physico-chemical
degradation and rp.icrobial  degradation.   Therefore, all data are required
per section 163.62-3.

          c.   Mobility  163.62-9

Data on mobility are required  to determine pesticide residue movement in
the environment and to assess  the  potential for loss of usable land and
water resources.   Data summarized  below provide insight into the mobility
of chloramben.  These data do not  satisfy Agency requirements.  Mobility
data are needed on both  sodium  and methyl chloramben.

               i.   Leaching

Leaching data are  required to support registration of end-use formulations
intended for terrestrial noncrop and  field/vegetable crop uses.

Basic to an understanding of the leaching properties of the various forms
of chloramben are  their aqueous solubilities  and their ability to bind to
soils.  The salts  all dissolve  freely in water to the extent of about
250,000 ppm; the free acid, about  700 ppm;  and the  methyl ester,  about 120
pern (McLane, 196?, 0147; Amchem, 1965,  0115).  With such solubilities all
fonns of chloramben, at the levels used in  application to soil, should be
conpletely dissolved by 3-inches of rainfall  and readily leach through the
soil.  Therefore.,,  any .failure of the  herbicide to leach down with such rain
would indicate aisorption on soil  particles.   Available data  on  the
leaching characteristics of chloramben  products provide preliminary
indications that a potential groundwater contamination problem could exist
as a result of chloramben uses.

                    Sodium Chloramben

Chloramben free acid and its salts (sodium, ammonium)  are leached  down
typically 8 to 12  inches by a 3-inch  rainfall (Amchem, 1965, 0115;  Pauser,
1963, 0131; McLane, 196?, 0147).   An  experiment involving 2 soils  (a silty
clay loam and a sandy loam) in which  water  was forced upwards by
evaporation frcm the soil surface  showed  that chloramben (initially placed
5-6 inches below the surface) moved upwards through both soils at  a rate
similar to that of other aromatic  acid  herbicides,  and faster than the
rates of all other groups of herbicides tested (substituted ureas,
triazines, thiocarbamates, and toluidines)  (Harris, 1967,  0595).   Virtually
all the chloramben herbicide activity had moved into the top inch  of soil.
Clearly some fraction of the chloramben had been left exposed  on  the soil
surface and was subject to photcdegradation.   It has been noted that the
nature of the photcdegradation products of chloramben is mostly unknown.
(See Topical Discussion on Photolysis).  Movement of chloramben upwards
probably occurs to some extent during any evaporation period such  as that
following rainfall.

                    Methyl Chloramben

The solubility of  the methyl ester of chloramben is about 120  ppm  (Amchem,
1965, 0115; McLane, 196?, 0147).   In contrast to the 8 to 12 inch  leaching
of sodium chloramben by a 3 inch rainfall,  the methyl ester is leached down
only about 1.5 inches (Amchem, 1965,  0115; Pauser,  1963, 0131;  McLane,


                                   5-11

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196?, 0147).  After hydrolysis of  the methyl  ester in soil (a matter of a
few days), the free acid of chloramben  leaches as quickly as the salts of
chloramben (Talbert, 1970, 05111).

These data are insufficient to evaluate the potential for sodium and methyl
chloramben to leach; all studies specified  in 163.62-9 b and d are required.

                 ii.   Adsorption/Desorption

A laboratory study using radioisotopic  or nonradioisotopic analytical
techniques is required  to  support  the registration of all chloramben
formulations intended for  terrestrial uses.  Data summarized below provide
insight  into the adsorptive/desorptive  properties of chloramben.  These
data do  not satisfy Agency requirements.  Data are required on both sodium
and methyl chloramben.

There have been  some studies of  the  nature  of the adsorption process
between  chloramben free acid and a calcium  montmorlllonite clay, which
indicate that the adsorbed form  has  a protonated carboxylic acid group and
a protonated amine group (Berkheiser, 1976, 0541).  Another study on
adsorption to a  silt loam  showed an  increase  in adsorption by decreasing
the pH of the water-soil mixture  (Barter, 1969, 0596).

However, all such studies  confirm  that  although chloramben is adsorbed by
soil colloids, the amount  adsorbed and  the  strength of the adsorption
forces are far less than for many  other herbicides.  This helps to account
for the  uniform  adsorption and leaching behavior of chloramben in various
soil types.

These studies go only a short way  to satisfying the requirements of Section
163.62-9(d).  All data  specified in  the section are needed to determine the
adsorption/desorption behavior of  chloramben.

          d.   Field Dissipation 163.62-10

Field dissipation studies  using  representative formulations under actual
use conditions are required to support  the  registration of all chloramben
formulations intended for  terrestrial uses.  The data summarized below
provide  insight  into the dissipation of chloramben.  These data do not
satisfy  flgency requirements.  Data are  needed on both sodium and methyl
chloramben.

No complete field dissipation study  has been  found in the chloramben
literature.  However, it is possible to build a picture of chloramben
dissipation as a combination of  bacterial breakdown in the upper levels of
oil and  leaching to lower  levels of  soil where bacterial action is
progressively less  (Anchem, 1967,  0043). Probably, chloramben finding its
way down to these levels remains intact and will travel with any movement
of liquid water, with a corresponding dilution.  Some fraction of
chloramben will  move upwards to  the  surface of soil (through
evaporation) ,where photodegradation  will occur given a sufficiently high
intensity of sunlight.

However, no data exists with respect to the formulated products containing
sodium and methyl chloraraben.  Therefore, additional studies as
                                    5-12

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described  in  163.62-10  b  are  needed in crop use areas using representative
formulations  of methyl  and  sodium chloramben.

          e.   Accumulation 163.62-11

Data on accumulation are  required to determine accumulation in food webs
and to assess the potential adverse effects on nontarget organisms.

               i.   Rotational  Crops

Rotational crop studies are required to support the registration of all
chloramben formulations intended  for field/vegetable crops.  Data
summarized below provide  insight  into the accumulation of chloramben in
rotational crops.  These  data do  not satisfy Agency requirements.  Data are
needed on both sodium and methyl  chloramben according to 163.62-11 b.

Registrants have the option of  completing these studies or of placing the
following phrase on labels  of all end-use products containing any salt or
ester of chloramben:

                   "Do  not  rotate to other crops"

Chloramben is readily taken up  by soybean plant roots at a rate
proportional  to its rate  of application on the soil.  Soybean roots cause
decomposition of the carboxylic acid group, releasing carbon dioxide, at
the rate of about 1 microgram chloramben in 8.5 hours per plant (Freed,
1960, 0128).  However,  movement of chloramben away from the roots and
through soybean plants  is very  slow, with no observed tendency to
concentrate in any particular regions (Freed, 1960, 0128).  By contrast, in
barley, chloramben readily  passes into the upper parts of the plant (Freed,
1960, 0128).  One study has shown that chloramben  added to ground soybean
seed is firmly held, and  requires a prolonged extraction for recovery
(Freed, 1960, 0128).  However,  it should not be assumed that uptake of
chloramben by plant roots is  the  only, or even the preferred, path of
uptake.  Green foxtail, for exammple,  undergoes no control when chloramben
is located in the root  zone at  a  soil  concentration of 3 ppm, but is well
controlled when chloramben  is in  the shoot zone at the same concentration
(Knacke, 1967, 05100).

It is wise to assume that the plants grown on soil treated with chloramben
takeup the herbicide, unless  there  is  evidence to  the contrary.  Morning
glory is resistant to chloramben.   In  a •comparison of it with velvetweed,
which is susceptible, it  was  found  that both species take up approximately
equal quantities of chloramben, with the raate of  uptake being faster in
morning glory.  However,  morning  glory quickly detoxifies chloramben to N-
glucosyl chloramben, while  velvetweed  glucosylates chloramben at a far
slower"rate (Stroller,  1969,  05110).

               ii.   Fish Accumulation

A laboratory study employing  radioisotopic or nonradioisotopic analytical
techniques is required  to support the  registration of all chlcramben
formulations intended for terrestrial  noncrop and  field/vegetable, crop uses.
                                   5-13

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A flow-through fish accumulation test, acceptable  in meeting registration
requirements, was performed on Bluegill Sunfish using chloramben  and    C-
chloramben (presumably technical acid) at 1 ppm (Iwan, 1978, 0020).   Edible
and nonedible tissue maximum bioconcentration  factors (BCF's) were  1.14 and
2.19, respectively, early in the exposure phase of the study.  BCF's
declined gradually during exposure and declined rapidly  in  the depuration
phase.  Little potential for significant fish  accumulation  is indicated by
this study.  Testing is needed on methyl chloramben.
                                    5-14

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D.   Chloramben End-Use Formulations

Chloramben end-use products contain four  varieties of the active
ingredient: sodium chloramben, methyl  Chloramben, ammonium Chloramben, and
moncmethyl ammonium Chloramben.  Requested  fate  data on sodium Chloramben
will satisfy Agency requirements for all  products containing sodium,
ammonium, and monomethyl ammonium Chloramben.  Requested data on methyl
chloramben will satisfy Agency requirements for  all products containing
methyl chloramben.

     1.   All Formulations - Exposure  Profile

Chloramben is found in low levels in plants and  crops grown on chloramben-
treated soils.  In some plants it is more or less uniformly distributed
throughout the plant, and in others (e.g. soybean plants)  it tends to
remain in the roots.

Chloramben not taken up by plants will escape microbial attack as it is
leached downwards.  Because of its apparent stability in aqueous solution
it is likely to reach depths at which microbial  activity is low or absent.
This chloramben is likely to enter ground water  or well water or be subject
to underground movement into streams.  Monitoring studies may be required
to define adequately the potential hazard.   Chloramben appears to be
persistent, and therefore poses a potential contamination problem in ground
water.

Because of the lack of data on the environmental fate of chloramben in
soils or on its presence in ground water, it is  not possible to give a
quantitative assessment of human or wildlife exposure to chloramben
fronthese sources.  However, a potential  exists  for it to reach ground
water or well water, and for its movement from soils into streams.

The non-dietary exposure to humans that may arise from the end-use of a
formulated chloramben herbicide is that associated with tank mixing,
dilution, loading, and application operations.   Although there has been to
date no data reported on the non-dietary  exposure of humans to chloramben
as a consequence of these activities, numerous studies have been performed
on exposures resulting from comparable activities with comparable chemical
formulations.  These studies have been reviewed  in order to derive numbers
that would be suitable for estimating dermal and inhalation exposure levels
resulting from mixing, loading, and application  of chloramben.

Available studies indicate that dermal and  respiratory exposures are the
main pathways by which pesticides are absorbed into the human body during
application.  Exposure data available for three  application activities were
reviewed:  1) application of liquid by ground boon, 2)  mixing and loading
of a liquid for either aerial or ground application, 3)  application of a
liquid by fixed-wing aircraft.  Adequate  information on application of a
granular substance by ground equipment and  homeowner application was not
available.

Extrapolation of the existing data on other pesticides to chloramben has
been carried out on the basis that exposure is proportional to
concentration of active ingredient in the spray,  other factors being
equal.  The worst case dermal exposure calculated  in this  way for
chloramben represents a 23% soluble concentrate  chloramben formulation


                                   5-15

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mixed with water and  applied  to soybean fields at the rate of three pounds
active ingredient  per acre.   A closely similar result is obtained if a 2.7
pound a.i. per acre, application of a flowable concentrate is made to
soybean fields.

It was assumed that the  average applicator would spray chloramben on 100
acres per day and  on  a total  of 160 acres per year.  A further assumption
was that dermal exposure (to  liquid formulations) would result in the
absorption into the body of 10% of the active ingredient coming into
contact with the skin, and that respiratory uptake would result in 100
percent absorption.

Since these calculations are  based on applicator exposure to a given
quantity of active ingredient per acre sprayed on a constant number of
acres, variations  in  the time spent spraying will not affect the total
exposure, nor the  results of  the calculations.  Variations in the
percentage of active  ingredient likewise will not affect the calculations,
as more dilute solution  for spraying would necessitate a greater volume of
solution to be sprayed per acre in order to obtain the same rate of
application per acre.

     2.   Soluble  and Flowable Concentrate:  Exposure Profile

                            Ground Application

Ground application is the^ primary means by which soluble and flowable
chloramben concentrates  are applied to crops as a pre-emergence herbicide.
This is usually done  by  the  fanner himself and is typically accomplished
with a tractor or  truck-mounted boon and tank.  There are twenty nozzles on
the boon located approximately 18" to 20" above the ground (Lewis, 1980).
Applicators typically mix, load, and apply the material themselves;
however, in some cases mixer-loaders are employed to perform that function
separately.  Application will take anywhere from six to twelve hours a day.

Miller, et al.  (1980) nave developed data indicating that applicators of
arsenic acid applied  in  a similar manner will be exposed to concentrations
which, when adjusted  for penetration and chloramben a.i. (active
ingredient) concentration convert to levels of 4.31 to 0.16 rag/day (dermal;
4.29-0.15 mg/day,  respiratory: 0.016-0.007 mg/day).  Staiff, et al. (1975)
have developed numbers for the same ground application activites of
paraquat dichloride which, when adjusted for % chloramben concentration and
skin absorption, convert to  levels of 2.84 to 0.01 mg/day (dermal: 2.82-
0.01 mg/day, respiratory: 0.01-negligible mg/day).  These numbers are not
applicable to  levels  of  exposure received from mixing and loading.

The results of  the comparative analyses arte presented in the following
text and in Table  5:3.  All  numbers are presented in units of milligrams
per day penetrated chemical.   The numbers are also presented as worst and
best cases.  The best case reflects the use of adequate protective clothing
including  long-sleeved shirt, hat, and gloves.  The worst case reflects the
employment of minimal protective clothing not including long-sleeved shirt,
hat, or gloves.

Minimum and maximum respiratory exposures reflect the range of field
exposure data.   In all cases  a cautious attitude by the applicator was
assumed and accidental spillage was assumed to be minimal.


                                    5-16

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       TABLE  5.3.   RANGE OF ABSORPTION  LEVELS  FOR FORMULATED CHLORAMBEN
                                                                    ma/day
      ACTIVITY
     DERMAL
Maximum    Minimum
                                                    RESPIRATORY
                        TOTAL
Maximum   Minimum     Maximum   Minimum
1.  Ground Application
    of Soluble and Flowable
    Concentrate
- farmer/planter        4.29

2.  Mixing-Loading
    of Soluble andvFlowable
    Concentrate
    - mixer-loader
(farmer/planter)       16.63

3.  Aerial Application
    of Soluble and Flowable
    Concentrate1
            0.01
 0.016    N
                                     (b)
            0.08
 0.42
0.002
             4.31    0.01
17.05
0.08
- pilot
- flagger
2.62
4.28
0.08
0.17
0.50
3.47
0.005
0.54
3.12
8.75
0.09
0.71
(a)    Miller (1980), Staiff (1975)
(b)    Lower than detection level.
(c)    Peoples (1979), Staiff (1975)

NOTE:  All values on this table have been adjusted for absorption to the body after
exposure and for chloramben concentration (a.i.) during application.  This was done to
develop justifiable comparisons between available data and chloramben applications.

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                            Mixing and Loading

Liquid chloramben  is available  to  field  applicators  in 5-gallon and 30-
gallon containers  (Lewis, 1980, 05116).  These  containers  are mixed with
water in loading tanks, mounted either on  tractors,  trucks,  or planes.  The
method of mixing also varies depending on  the degree of applicator
sophistication.  In some cases, commercial applicators employ enclosed
siphon systems which greatly reduce  the  dermal  exposure observed.   In other
cases, containers  are simply punctured and poured  directly.   For enclosed
systems levels of  exposure have been observed  (Peoples, 1979, 05119) that,
when adjusted  for  chloramben concentration, indicate 17.05-0.59 mg/day
(dermal: 16.63-0.44 trig/day, respiratory: 0.42-0.15 mg/day).   Miller (1980,
05117) indicates,  for the same  application, levels of 2.27-0.08 mg/day
(dermal: 2.27-0.08 mg/day, respiratory:  0.003-0.002  mg/day).  In one
instance, when a direct transfer system  was used,  no gloves  were worn and
the individual mixer-loader was noted as being  careless, levels of 94.54-
22.63 mg/day were  observed  (dermal:  94.44-22.53 mg/day, respiratory: 0.1-
0.1 mg/day).  Approximately 95  percent of  this  exposure is normally
expected to be to  the hands (Wolfe,  1961,  05120).

                            Aerial Application

A very small percentage of the  total chloramben applied is by aircraft
(Lewis, 1980,  05116).  When this method  of application is  employed, dermal
and respiratory exposure occurs during mixing-loading, flying, and flagging
operations.  Levels for combined dermal  and respiratory exposure are
estimated to range from 3.12-0.09 mg/day and 9.75-0,71 mg/day for pilots
and flaggers,  respectively.

Peoples  (1979, 05119) has observed combined levels that, after adjustment
for chloramben concentrations,  are 3.12-0.50 mg/day  for pilots (dermal:
2.62-0.4 mg/day, respiratory:  0.50-0.10  mg/day).   For the  same operations,
Miller  (1980,  05117) has observed penetration to pilots at 1.27-0.09 mg/day
(dermal: 1.26-0.08 mg/day, respiratory:  0.005 mg/day).

                          Annual Exposure  Levels

Presently there is not a great deal  of data available on overall annual non-
dietary exposure.  However, since  this exposure estimate is  based  on
information on the calculated  daily  non-dietary exposure and the annual
application rates  of the herbicide chloramben,  a range of  projections can
be developed.  The following assumption  can be  derived from  the EPA
Chloramben Use Summary Report  (Lewis, 1980, 05116).

The Use  Summary Report  indicates that for  application of a liquid
formulation, a tractor-mounted  applicator  can treat  approximately 80 acres
per ten-hour day while, for the same time  period,  a  skid truck-mounted
applicator may be  able to treat 140  acres.  An  average rate  of 100 acres
treated  per ten-hour day was assumed for annual exposure purposes.

Plots of land  employed for soybean production in the United  States are
assumed  to  range in size from  40 to  400  acres.  Based on information from
University of  Illinois representatives,  the average  soybean  acreage is 160
acres.
                                    5-18

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Chloramben is applied to soybean  crops,  in the liquid form, at a rate of
2.0 to 3.0 pounds a-.i.  (active  ingredient)  per acre.  A rate of 2.5 pounds
a.i. was assuned as an  average.

In view of these assumptions of a 2.5  pound per acre a.i. application rate
and a 4,000,000 pound per year consumption, 1,600,000 acres are treated per
year.  Assuming 160 acre soybean  units,  there are approximately 10,000
persons exposed to chloramben per year.   These persons will be exposed to
estimated doses levels  of between 27.3 and  0.016 milligrams of chloramben
per year, depending upon methods  of application and acreage treated.  The
estimates of annual chloramben penetration  levels for the different methods
of application and acreages treated are  summarized in Table 5-4.

3. Granular Formulations - Exposure Profile

The potential of granular formulations for  forming dusts  represents a
special human inhalation hazard,  particularly during loading
operations.However, total exposure from  granular applications  is assumed to
be minimal in relation  to liquid  formulations since no mixing  operations
are involved.  The granular formulation  for domestic use  involves a shaker
canister and exposure from this application method is also assumed to be
low.
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             TABLE 5-4.  ANNUAL CHLQPAMBEN EXPOSURE ESTIMATES

                     Soluble and Flowable Concentrates

1.
2.
ACTIVITY

Ground Application
- farmer/planter
Mixing-Loading
-mixer /loader
f f a-rmtxr /r»1 am-or- \
Total: Farmer/Planter
Exposure
3. Aerial Application
- pilot
- flagger
mg/daya
Worst "Best"
Case Case
4.31
17.05
21.36
3.12
8.75
0.01
0.08
0.09
0.09
0.17
rog/person/yr
Worst "Best"
Case Case
6.9
27.3
34.2
5.0
14.0
0.016
0.13
0.146
0.14
1.14
a)  Table 5-3.
b)  (mg/day) x (1 day treatment/100 acres possible) x  (160 acres/person/yr).
                                   .5-20

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                                 CHAPTER VI

                             RESIDUE  CHEMISTRY

A.   Introduction

For any pesticide which has uses  that may directly result in residues on
food or feed, the Agency sets an  allowable residue level, or tolerance, for
each conmodity on which it may occur.  A tolerance level for a particular
chemical on a particular conmodity  is a function of the chemical's
toxicity, the percentage of an average  daily diet comprised by the
commodity, and the amount of residue  that can be expected to occur on that
commodity at the maximum directed rate  
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Some measurements on the uptake, distribution,  and  excretion of chloramben
in animals have been made.   It appears  that cows exrete ingested chloramben
in the urine and feces, but  not in  the  milk.  Dogs  also excrete chlorainben
in the urine and feces.  If  dogs store  any part of  the ingested chloramben,
it probably is not more than about  0.2  percent  of the total ingested.

The analysis of low levels of chloramben appears to present no .unusual
difficulty.  The submitted gas chromatographic  method is satisfactory in
itself, and is clearly capable of modification  and  improvement as discussed
in the Topical Discussion on analytical methods.

     2.   Data Requirements  and Data Gaps
                                    •
The proposed guideline? for  residue chemistry have  not been published.
Consequently there are no citations for guidelines  corresponding to the
types of residue chemistry data required to support individual
registrations.  In general,  however, the Agency must have sufficient data
to be assured that the residues of  the  parent chemical and its metabolites
have been identified.

          Data Gaps

The following data are required to  support the  tolerances for chloramben:

1)   Information on the storage of  agricultural material between sampling
     and residue analysis.   Data on the storage conditions, and on the
     stability of the residues during storage are required.

     3.   Topical Discussions

          a.   Use Patterns  and Restrictions

Chloramben  is applied principally as a pre-emergent herbicide used alone or
in combination with other herbicides for the control of weeds and annual
grasses  in  various food crops  and ornamentals.   The varous formulations of
chloramben  are registered for  use on dry beans  (navy, white, kidney, pinto,
and lima) peanuts, soybeans, sunflowers, corn,  sweet potatoes, squash,
pumpkin, asparagus (seedling), transplanted tomatoes and peppers, lima
beans, snap beans, cantaloupes, cucumbers, annual and perennial flowers,
shrubs,  and trees.

Chloramben  is available  in  soluble, flowable, and emulsifiable concentrates
and granular  formulations containing from 1.3%  to 83.0% chloramben.

Formulations  are  applied  at time of planting or immediately following
transplanting; on tomatoes  and peppers chloramben may be applied at layby.
Liquid formulations  are  sprayed  from truck or tractor sprayers or by
aircraft; granular formulations are applied from tractor drawn planter or
broadcast applicators.   Rates  of  application presented in Chapter 4 range
from  2 to 4 pounds active  ingredient per acre for food crops and from 4 to
6 pounds per  acre  for ornamental  uses.  Formulations are applied only once
per season  on agricultural  crops and twice per  season on ornamentals.

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Chloramben formulations  contain  the  following label restrictions.  Granular
and liquid formulations  for  use  on sunflowers have label warnings
prohibiting grazing treated  areas  and  using  treated plants for feed or
forage.  The use on peanuts  is restricted  to Oklahoma and northern Texas.
The use on com is confined  to heavy soils  in Illinois, Indiana, Iowa,
Kansas, Minnesota, Missouri, Nebraska, and Ohio.

With the exception of ornamentals, the uses  of chloramben are for food uses
and are expected to result in residues in  human food and animal feed.

          b.   Uptake, Distribution, and Metabolism in Plants

In addition to what may  remain of  an original application of the chemical,
residues may also consist of the chemical's  metabolites, as  formed by the
plant crop to which it was applied.  The major and minor pathways of the
chemical's absorption, transformation, and distribution can  be deduced
experimentally from the  analysis of  radiolabeled applications.
Applications by various  routes,  for  example  to the roots or  leaves, will
show differences in absorption rates.   The distribution of the chemical and
its metabolites can be examined by measuring the radioactivity present in
various plant fractions.  Isolated metabolites can then be characterized by
cnromatography, partitioning, or electrophoresis.   Metabolic
transformations often result in an increase  of polarity of the foreign
chemical to facilitate elimination.  Metabolites characterized as highly
polar may have undergone conjugation with naturally occurring amino acids,
sugars, or sugar acids.  Further chemical analysis can help  identify the
exact nature of the conjugations.  Other possible major transformations can
occur by hydrolysis, oxidation/reductions, or the breaking of unstable
bonds.  The absorption,  distribution,  and metabolic fate of  the chemical
determine the potential quantity and identity of pesticide residues in
plants used for food or  feed.

Chloramben movement into plants  is a passive diffusion process and does not
require metabolic energy (Stoller, 1969, 0538).   Chloramben  that  enters the
plant tissue undergoes a conversion  to N-glucosyl  chloramben (Swanson,
1966, 0169; Frear, 1978, 0556; Colby,  1965,  0553).   Formation of  N-^lucosyl
chloramben is related to the carbohydrate content of the plant.   Soybeans
depleted of carbohydrate reserves absorb less  chloramben and  produce  less N-
glucosyl chloramben than do  plants under normal  illumination  (Swanson,
1969, 0538).  N-glucosyl chloramben is not phytotoxic  while chloramben is.
The "resistant" plants such  as soybean or morning  glory have  an efficient
glycosylation system in  their tissues.  The  "susceptible"  plants  (e.g.
velvet leaf) do not have an efficient  glycosylation system and chloramben
accumulates to exert its phytotoxic effect (Stoller, 1969, 0538).

In addition to the glycosylation reaction, the decarboxylation type of
reactions have also been reported.  Thus soybean roots when  treated with
* C chloramben (with   CCOH)  evolve    CO, (Anchem,  nd, 0127).
Carrots planted in chloramben treated  soil absorb,chloramben.  Carrot
slices when incubated with   C chloramben evolve    CO-  (Ashton, 1966,
0548).  Attempts to find possible degradation  products of  chloramben,  viz.,
2,5-dichloroaniline and 2,5-dichlorophenol in  lima  bjeans,  peppers,  sweet
potatoes, peanuts and soybeans (Amchem 1963, 0008;  1965, 0076; 1961,  0079;
1963, 0098; 1963, 0106; 1961, 0159; 1964, 0161;  1963,  0162;  1963,  0163;
1964, 0164) grown on cnloramben treated soil were not  successful.
                                    6-J2

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               Pre-emergent Treatment

The movement of chloramben in  the  plants  shows a unique pattern.  Soybeans
placed in ^ C chloramben  solution  take  up chlorainben through their
roots.  Radioautography of these plants revealed very little upward
movement of chloramben  (Amchem, 1960, 0127).   On the other hand, barley,
which is susceptible to chloramben,  transports chloramben into the upper
parts of the plant easily (Amchem, I960,  0127).  The behavior of the root
system may be important,  together  with  glycosylation, in determining
whether a particular species  is susceptible or resistant to chloramben.
                                     14
Soybeans grown in soil  treated with   C chloramben accumulate
chloramben.  Plants that  had  barely  emerged fron soil contained 23 ppm and
50 ppm of chloramben for  a 3  Ibs/A and  6  Ibs/A application respectively
(Amchem, 1961, 0154) .

These levels decreased  markedly with time to  as low as 3.5 percent of the ^
initial level after 56  days.   Chloramben  that had entered the plant was
stored predoninantly as. a conjugate. No  detectable amount of chloramben
was found in mature seeds.  Glycosylation cannot be involved in this
decrease, as radiolabel would  remain.   Metabolic decarboxylation does not
seemingly proceed fast  enough  to account  for  the decrease.

               Post Emergent  Treatment

Though chloramben is used pricipally as a herbicide in pre-emergent
applications, some studies have been made to  investigate the effects of
foliar or post emergence  application, mainly  with a view to find out the
sites where chloramben  would  accumulate at maturity.  Soybean plants grown
under greenhouse conditions were applied  with   C chloranben at a rate of
9 Ibs/A on the surface  of leaves.  The  accumulation of   C was studied in
the various parts of the  plant at  harvest. The seeds contained the least
amount of radioactivity (16 cpm) as  compared  with leaves, stems, and roots
(279, 1253, 740 cpn respectively)  (Amchem, 1961, 0104; 1961, 0157).  The
direction of movement was downwards  from  the  leaves to the roots.  When
chloramben was applied  post emergent to soybean plants 104-132 days before
harvest at a rate of 3  lbs/Af  neither soybean seeds nor hay showed
chloramben residues higher than 0.1  ppm (Anchem, 1978, 0101).

     c.   Metabolism in Animals

The  identity of residues  in animal products used for food may, as with
plants, be largely determined by the metabolic fate of the chemical in the
living organism.  Livestock or poultry  may ingest chemicals through treated
feed or  forage.  Gastrointestinal  absorption, biotransformation, and. body
distribution are usually  studied by  the feeding of animals with the
unlabeled or radiolabeled chemical.   The  degree to which the parent
cattpound and its plant  metabolites are  absorbed or excreted can often vary
with  the forage or  fodder crop on  which the chemical was administered, and
so actual  feeding practices are usually approximated.  Residues in excreta,
bleed, milk, eggs, or tissue  are then measured and characterized.

The majority of crop residue  data  on raw  agricultural commodities
 (RAC)indicate  that detectable residues  would  not occur in the feed items..
Since detectable residues are not  expected to occur in feed items
metabolism data are not required.


                                     6-4

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Studies have been  submitted  which provide insight into the metabolism of
chloramben  in animals.   In order to find out the fate of chloramben  in
animals, an experiment was conducted  where a cow was given chloramben (at  5
pan level)  in feed (St.  John Jr., 1970,  0577).  Milk, urine, and feces were
analyzed for chloramben  content.   Eighty-eight and one-half percent of the
chloramben was excreted  in the  urine  and 4.6 percent in the feces, and no
trace was found  in the milk.

Similar experiments in dogs  have yielded similar results.  Two dogs kept on
a diet of 0.5 mg chloramben  per kilogram body weight per day, six days per
week, for four weeks, showed no detectable levels of chloramben (less than
0.01 ppm) in any of their tissues,  including fat (Amchem, 1967, 0085).
Chloramben levels  in feces and  urine  were measured on pooled samples for
each dog for the last week of the study.  These levels were consistent with
excretion of the major part  of  the  ingested chloramben.  These data
indicate that no more than 0.2  percent of total administered chloramben are
retained in canine tissues after a  28-day experiment.

The data discussed  above, on residues of chloramben in animal tissues/ are
inadequate in that an inadequate  number  of animals were studied.  There are
no data on residues  of chloramben in  poultry and eggs.  The data available
on bovine metabolism leaves  in  doubt  the fate of approximately seven
percent of the fed  chloramben.

          d.   Analytical Methods

There must be available, before a tolerance may be granted, practicable
analytical methods  for the detection  and measurement of the residue and  its
metabolites.  Every commodity considered for a tolerance must have some
applicable method.   Such methods  are  often published and widely used;
others may involve adaptions of common analytical procedures.  In general,
any analytical method suggested  for consideration must be characterized  in
four ways:  first,  there should  be  some  assurance as to the efficiency of
the extraction procedure, so that the analysis is not carried out on
partial samples; second, the method should afford a measure of the 'total
toxic residue', including toxic degradation, metabolic, or other conversion
products; third, the method  must  be thoroughly validated by analyses of
representative samples in comparison  to  blank values significantly lower
than the proposed  tolerance  and;  fourth, the validation should conclude
with an estimate of  sensitivity/  i.e./ the least concentration of pesticide
which can be detected with a reasonable  degree of assurance.

At least one method must be  suitable  as  a regulatory enforcement method,  in
that it does not require the use  of untreated crop samples for blanks, that
it is rapid/ that  it makes use of commonly available equipment and
reagents, and that it is sufficiently specific to identify and measure a
specific pesticide  in the presence of other residues likely to occur on  the
same commodity.

               Method of Analysis of  Chloramben

Since chloramben is  evidently present in a conjugated form/ alkaline
hydrolysis is necessary to free all the  bound chloramben (Amchem/ 1963,
0158).  Two methods  have been used  for chloramben determinations,  one a
colorimetric method  and the  other involving gas liquid  chromatography.   The


                                    6-5

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colorimetric method  involves a diazotizaticn and coupling of chloramben to
N-(l-naphthyi)ethylene diamine dihydrochloride (Amchem, 1964, 0077; 1964,
0107) or to 1-naphthol (Amchem,  1978,  0057), after which the optical
absorbance is measured in a spectrophotcmeter.  The gas chronatographic
method involves conversion of chloramben to the methyl ester form, which is
quantitated in the gas chrcmatograph (Amchem, 1978, 0057; 1968, 0085; 196?,
0166; 196?, 0167).   Further details  of these methods are given:

               Colorimetric Method

Fifty gram portions  of sample are reduced to a fine paste with methanol in
a blender.  The mixture  is warmed on a steam bath after adding sodium
hydroxide to hydrolyse chloramben conjugates.  The mixture is filtered and
the filtrate made strongly acid, and extracted with ethyl ether.  The
ethereal layer is in turn extracted  into an aqueous alkaline solution,
which is then made strongly acid and again extracted into ethyl ether.  The
ether layer is separated and evaporated to dryness.  The residue is
refluxed with methanol and sulfuric  acid to esterify all chloramben free
acid.  Water and toluene are added;  all ester is dissolved in the toluene
layer, which undergoes a conventional  Florisil clean-up.  The methyl
chloramben is eluted in  the 15 percent ethyl ether-hexane fraction.  After
evaporation of all the solvent the ester is diazotized (sodium nitrite-
acid, then ammonium  sulfonate solution) and coupled with N-(l-naphthyl)-
ethylene diamine dihydrochloride. The color intensity is measured at the
absorption maximum  (approximately 528  nm).

The method is sensitive  to 0.1 ppm  (three times background signal) and
gives recoveries of  70^-100 percent.   It has been validated for pepper, dry
beans, punpkins, squash, sweet potatoes, corn, and peanuts.

This method is not suitable for  enforcement purposes because it
necessitates the use of  a "blank", i.e. carrying a sample through the
analytical procedure for comparison  with the crop sample of interest.

          Gas Chrcraatographic Method

Twenty-five gram portions of sample  are finely ground in a blender and
refluxed with raethanolic sodium  hydroxide to hydrolyse conjugated
chloramben.-  The mixture is filtered (after centrifugation if necessary) ,
water is added, and  the  solution is  evaporated.  Addition of water and
evaporation is repeated  until all methanol is eliminated.  The pH is
brought to 1.0 and the solution  is extracted with diethyl ether.  The ether
is in turn extracted by  an aqueous phosphate buffer (pH 5.8).  The aqueous
layer is acidified to pH 1 and again the ether extraction is carried out.
Chloramben in the ether  layer  is esterified with diazcmethane to the methyl
ester,- and the solution  of methyl chloramben is concentrated to exact low
volume  (0.5 ml or 1.0 ml).  This solution is used for injection into a gas
chrgnatograph, fitted with a 6 foot  3  percent Carbowax 20M column at
230  •.  The recommended detector  is a micrccoulometric detector used in
the halogen mode.  Alternatively, an electron capture detector may be
used.  Detention time is about 15 to 20 minutes (50 ml nitrogen carrier gas
per minute).  If a 5 ft. x 1/8 in. 5 percent QF-1 column at 200
isothermal is used,  the  retention time of the methyl ester is about 5
minutes.
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The lower  sensitivity (three  times background)  of this method is about  10
nanograms  of methyl  ester,  which corresponds to 10 ppb chloramben in the
original sample.  The method  has been validated for lima beans, soybeans
and soybean forage,  peanuts,  corn and corn silage, and navy beans.

This method is  suitable  for enforcement purposes, as it has adequate
sensitivity, precision,  and specificity, and does not require the use of a
"method blank".   It  is capable of further improvement, however, notably in
speed and  efficiency of  extraction of residues  from plant materials.

           e.    Residue Data

In addition to  provisions for analytical methodology, a second prerequisite
to the granting of tolerances is the  generation of supporting data.
Residue experiments  generally consist of:

     1)    Data about the stability of extracted residues under storage;
     2)    An examination of raw  consumable commodities for residues  of the
           pesticide  chemical  after treatment corresponding to the proposed
           uses.

Residue data generally disclose:  the  nature of  the residue (i.e., parent
compound or transformation  product);  the level  of the residue as it  occurs
in the whole raw  agricultural commodity, the commodity being  in the  form in
which it moves  in interstate  commerce;  the distribution of the residue  in
the processing of the commodity  for consumption, including washing,
brushing,  trimming,  curing, drying, cooking, or canning.  Some data  may be
available  comparing  various methods for the intentional removal of
residues.  Residue data can be obtained  by field experiments, by animal
treatment  studies, by soil  persistence  studies, or by the monitoring of
actual residues in marketed food  or feed products,  by which tolerances  can
be enforced or reassessed.

Soybeans

The recommended application rate  for  soybeans is 2-3  Ibs/acre.  Soybean
plants of  Harosoy variety treated with  chloramben at  4  and 8  Ibs/acre pre-
emergent, did not show more than  0.1  ppm of chloramben  residues  in the
mature beans (Amchem, 1965, 0071).

Soybeans of Clark 63  variety  treated  with  cloramben pre-emergent at  the
rate of 6  Ibs/A and  harvested after an  interval of  110  days showed a
residue content of less than  0.04 ppm in the mature beans. ' (Amchem, 1968,
0084)

When chlorambRn was  applied (1.5-2.0  Ibs/A)  as  a mixture with vernam TE (2
Ibs/A) pre-emergent,  the residue  levels  in soybeans from three locations
representing two varieties  (Wbodviorth, Williams)  were less than  0.02 ppm
whether bean or forage was  analyzed.   (Amchem,  1979,  0041)

Soybeans of the "Hill" variety were treated  with a  liquid formulation of
chloramben at a rate  of-4 or  8 Ibs per acre.  Analysis  of soybeans at
maturity showed a residue content of  less  than  0.1  ppm  for both  rates of
application.  (Amchem, 1967,  0044)
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Five varieties of mature soybeans  (Clements,  2msoy,  Wayne, Beeson,
Williams) from five  field experiments were  analyzed  for residues of
trifluralin and chloramben, by gas  field  chromatography.  In these tests,
trifluralin and chloramben r*ere  applied as  a  pre-emergent tank mix
combination at 1-2 and  2.5-5.0 Ibs/A, respectively.   Residues of chloramben
ranging from 0.02-0.06  ppm were  measured  in three samples while no
detectable residues  were found in  the two remaining  samples.  (Amchem,
1978, 0050)

Samples of soybeans  and soybean  plants  from either locations representing
six varieties (Amsoy, Adelphia,  Corsoy. Lee,  Dare, Hill) were treated with
a formulated mixture of sodium salt of  chloramben plus Lorax (N-3,4-
dichlorophenyl-N-1-methoxy—N-l methyl urea).   Plants were treated at a rate
of 1 1/2 Ibs. of chloramben plus 1/2 Ib.  of Lorax per acre and also at
twice this rate.  Chloramben  content was  determined  by gas liquid
chromatography.  No  residues  of  chloramben  greater than 0.1 ppm were found
in soybeans or soybean  forage.   The samples taken at a very early harvest
(38 days after treatment) as  well  as samples  treated at twice the normal
rate also showed no  chloramben residues greater than 0.1 ppm.  (Amchem,
1978, 0057)

Soybean and soybean  hay samples  from six  locations were analyzed for
chloramben residues  resulting from post emergence treatment with chloramben
(3 Ibs/A, 104 to 132 days prior  to harvest).   None of the treated or
control samples showed  residues  of chloramben greater than 0.1 ppm when
analyzed by a gas-liquid chromatographic  method.  The recovery of
chloramben from fortified samples  ranged  from 70 percent to 108 percent
with an average of 87 percent.   (Amchem,  1978, 0101)
                                                                      14
In.a greenhouse study soybean seedlings were  treated with chloramben   C
(  C in the carboxyl group) on the leaf surface at a rate of 9 Ibs/A.
The plants were allowed to grow  to maturity.   The leaves were collected
upon abscission.
                                                            14
At harvest roots, stems, pods, and seeds  were analyzed for   C content.
The seeds showed the least amount  of radioactivity,  while the stems and
roots contained the  bulk of radioactivity.   (Amchem, 1961, 0104)

Nine sets of samples from nine locations  representing eight varieties of
soybeans  (Lee 68, Adelphia, XK505, Wells, Williams,  Ansoy 71, Ansoy,
Chippewa 64) treated with 3 Ibs. of active  ingredient of chloramben per
acre, were analyzed  for chloramben and  trifluralin residues.  None of the
samples showed any residue of chloramben  greater than 0.1 ppm nor any
residue of trifluralin  greater than 0.05  ppm.  (Amchem, 1975, 0109A)

In another study, four  sets of samples  from four locations representing
four varieties of soybeans treated with 1 1/2 to 3 Ibs. of active
ingredient of chloramben per  acre  in combination with another herbicide
failed to show chloramben residue  greater than 0.1 ppm.  (Amchem, 1975,
0109A)

Neither of two sets  of  samples  (XK505 and Harosoy) from two locations,
treated with 1.5 Ibs. plus 1.5 Ibs. active  ingredient of chloramben per
acre, nor a sample  (Ansoy 71) treated with  3  Ibs. of active ingredient of
chloramben showed a  residue content higher  than 0.1  ppm on analysis.
 (Amchem, 1975, 0109A)


                                     6-8

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Three varieties of soybeans  (Hill, Clark 63,  and  Amsoy)  at five locations
were treated with both liquid  and granular formulations  containing nixed
amine salt of chloramben, at a rate of  3 and  6  Ibs.  per  acre.  Mature
beans, immature beans and pods,  immature plant  or whole  plant were all
analyzed for chloramben content  and no  residue  greater than 0.1 ppm was
detected.  (Mchem, 1967, 0120)

Ten varieties of soybeans (Clay, Corsoy, Clark  63, Swift, Harosoy 63,
Wayne, Amsoy 71, Teweles 304,  Woodworth, Williams) in 14 locations were
treated with- chloramben as a tank mix with alochlor  at rates ranging from 2-
3.3 Ibs. of chloramben per acre.  None  of the treated samples showed
residues of chloramben equal to  or greater than 0.1  ppm.  (Amchem, 1976,
0118)

The chloramben content of de-oiled soybean cake and  soybean oil from mature
soybeans representing four varieties (Harosoy,  Lindarin, Hill,  and Lee)
treated with chloramben at 8-9 Ibs. per acre  were analyzed.  Except for one
instance of Lindarin soybean cake showing a chloramben content  of less than
0.2 ppm, no residue was found  in other  samples.   (Amchem, 1961, 0135)
                                          14
Soybean plants treated pre-emergent with  C  labeled chloramben at 3 and
6 Ibs. per acre and grown under greenhouse conditions showed  very little
chloramben in the bean pods as compared with  the  other parts  of the plant
which contained the bulk of chloramben.   At a chloramben application rate
of 3 Ibs. per acre, 0.1 ppm was  present in bean pods. The upper, middle,
and lower thirds of the plant  contained 0.47, 0.89,  and  1.39  ppm,
respectively.  When the application rate was  6  Ibs.  per  acre, the bean pods
showed a residue content of 0.2 ppm.  The upper,  middle, and  lower thirds
of the plants showed a residue content  of 0.87, 2.72, and 5.32  ppm,
respectively.  (Amchem, 1961,  0136)

In general, residues of chloramben in soybeans  are below tolerance levels.

Peanuts

Peanuts of the "Starr" variety from five locations were  treated with a
liquid formulation of chloramben at a rate of 6 Ibs/acre (twice the
recommended rate) 18, 72, 95,  141, and  179 days before harvest, and the
residue content of peanuts was analyzed.   All the samples that  had received
treatment 72 to 179 days before  harvest, showed  residues  less  than 0.1 ppm.
The samples that were harvested 18 days  after treatment  with  chloramben
showed a residue content of 0.43 ppm.   (Smchem, 1967,  0044)

Peanut plants treated with chloramben at 6 Ibs/acre  (twice  the  recommended
rate) were harvested and the presence of 2,5-dichloraniline,  a  possible
metabolite of chloramben arising through  a decarboxylation  reaction,  was
measured in the peanut hulls and meat.   The method used  was sensitive to
0.1 ppm and no traces of 2,5-dichloraniline was found  in the  hulls or the
meat portion of peanuts.  (Amchem, 1965,  0076)

Analysis of peanut hulls, foliage, and  nuts collected  95-151  days after
treatment did not show-any residue of chloramben. Foliage  collected  72
days after treatment had less  than 0.1  ppm residue.   Foliage  collected 18
days after treatment showed 0.42 ppm.   (Amchem, 1965  estimated, 0077)
                                    6-9

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Peanuts of the "Starr" variety when  treated  at the rate of 6 Ibs/acre with
chloramben 101 days before harvest showed  a  residue content of less than
0.4 pern.  (Arnchem", 1968, 0084)

Peanuts of "Spanhorima", "Starr", and  "Spancross"  varieties in three
locations were treated with chloramben at  the rate of 3 Ibs/acre 138, 112,
and 162 days before harvest.  The residue  content  of the harvested peanust
was less than 0.1 ppra.   (Amchem, 1975, 0109A)

These data indicate that peanuts treated with reccnmended levels of
chloramben are not likely to contain residues above tolerance levels.

Peppers

The recommended rate of  application  is 4 Ibs/acre.  Peppers of four
varieties (Yellow Wonderr World Beater, California Wonder, Delaware Bell)
in three locations were  treated at 4-16 Ibs/acre 50 to 81 days before
harvest.  In all cases the harvest peppers contained less than 0.1 ppm of
chloramben residue.  (Amchem, 1967,  0044)

Chloramben treated peppers showed less than  0.1 ppm of 2,5-dichloroaniline,
a potential metabolite of chloramben arising from decarboxvlation.  (Bois,
1964, 0093)

Peppers of five varieties (California  Wonder, Bell, Cannoe, Keysonte
Resistant Giant, Yellow Wonder) on eight locations were treated with
chloramben at the rate of 4 Ibs/acre 36, 47, 51, 52, 59, 60, 68, and 77
days before  harvest.  All the peppers analyzed showed residues less than
0.1 ppm.  (Amchem, 1975, 0109A)

Yellow Wonder peppers and World Beater peppers were treated with 11 and 16
Ibs/acre respectively and no traces  of 2,5-dichloroaniline was found using
a method sensitive to 0.1 ppm.  (Amchem, 1963, 0162)  In another study'
Yellow Wonder and World Beater peppers were  treated with chloramben at
rates of 8 and 16 Ibs/acre and were  harvested in two batches one after 50
days of treatment and the other after  70 days of treatment.  Analysis of
the peppers showed less  than 0.1 ppm chloramben residues in all the cases
irrespective of dosage or the interval elapsed before harvest.  (Amchem,
1964, 0008)

These data indicate that chloramben  residues in peppers will not be above
the tolerance level when treated at  the recommended rate.

Tomatoes

The recommended application rate is  4  Ib/acre.  Five varieties of tomatoes
were treated with chloramben at rates  ranging from 6 to 16 Ibs/acre.  The ^
residue content of immature green, mature  green, and mature red tomatoes
was not greater than 0.1 ppm in all  cases  (Amchem, 1967, 0044).

Chloramben residues ranged  from 0.03 to 0.05 ppm in tomatoes treated at a
rate of 4 Ibs/acre.  When the application  rate was 8 Ibs/acre the residue
levels ranged from 0.05  to 0.14 ppm.  (Amchem, 1963, 0106)

Tomatoes of "Heinz 1439", "Campbell  28",  "Marglobe", and "Heinz 1327"
showed chloramben residue content of less  than 0.1 ppm in the mature fruit,


                                   6-10

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when the plants had been  treated  at 4 Ibs/acre.  The time elapsed frcm
treatnent  to harvest  ranged  frcm  25 to 112 days in these studies.   (Amchem,
1975, 0109A)

In a laboratory radiotracer  study,  pure chlorainben labeled in the carboxyl
group with   C was used on tomatoes grown under greenhouse conditions.
Chloramben was used at rates equivalent to 3 or 6 Ibs/acre, 63 days before
harvest.  At an application  rate  of 3 Ibs/acre the fruits contained
residues of 0.06 ppm  but  at  6  Ibs/acre the residues were 0.15 ppm.  Plants
that have received treatnent at layby (22 days before harvest) of 6
Ibs/acre showed a residue content of 0.52 ppm in the fruits (Amchem, 1963,
0102).  Treatnent of  tomatoes  under actual field conditions will not, in
all probability, occur at less than 60 days before harvest.

In general, the data  indicate  that  residue levels in tomatoes will not
exceed tolerances.

Lima Beans

The recommended rate  of application is 2-4 Ibs/acre.  Lima beans from five
locations that had been treated with chloramben at the rate of 6 Ibs/acre
ranging from 73-98 days before harvest, showed less than 0,1 ppm of
chloramben residues.  (Amchem, 1967, 0044)

Lijna beans from two locations where chloramben was applied at twice the
recommended rate showed no residue  of 2,5-dichloroaniline, a potential
metabolite that arises from decarboxylation of chloramben.  (Amchem, 1963,
0098)

In a radiotracer study lima beans grown in a greenhouse were treated with
  C- labeled chloramben at the rate of 3 and 6 Ibs/acre.  Analysis of the
mature bean showed a  residue content of 0.03 ppm when the recommended rate
of 3 Ibs/acre was employed.  At the exaggerated level of 6 Ibs/acre the
residue content was 0.09  ppm.  The  immature beans showed a residue content
of 0.08 ppm at 3 Ibs/acre rate and  0.22 ppm at 6 Ibs/acre rate of
application.  (Amchem, 1963, 0108)

Lima beans from four  locations representing four varieties (Mibres,
Bridgeton, Thergreen, Fordhook Bush)  treated at rates.of 3-4 Ibs/acre, 70-
94 days before harvest failed to  show chloramben residues greater than 0.1
ppm.  (Amchem, 1975,  0109A)

In summary, recommended application rates of chloramben on lima beans
result in residues below  the tolerance  limit.
                                   6-11

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The recommended rate of application  is  2  Ibs/acre.   Corn plants were
treated at 3 Ibs/acre and 9  Ibs/acre.   The  com at  tassel stage and
immature ears were harvested after 41,  66,  and  101  days, respectively after
chloramben treatment and on  analysis showed less than 0.1 ppm of chloramben
residues.  (Amchem, 1967, 0044) ~At  a dosage of 4 Ibs/acre and 16 Ibs/acre
treatment, the silage, mature corn kernels  and  mature corn cob (84, 119,
119 days after treatment, respectively) showed  no greater than 0.1 ppm of
chloramben.  (Amchem, 1967^0044)  Corn treated at  2 and 6 Ibs/acre and
harvested after 139 or 190 days showed  a  residue content less than 0.1
ppm.  (Amchem, 1967, 0044)

Mo residues were  found in silage, corn  kernels, or  corn cobs harvested from
different locations that had been treated as high as 16 Ibs/acre (eight
times the recommended rate).   (Amchem,  1965 estimated, 0080)  Analysis for
the potential metabolite 2,5-dichloraniline was conducted on silage and
kernels collected from the 16 Ibs/acre  treatments and no traces of this
material were found.  .(Amchem, 1965  estimated,  0080)

Corns of different varieties treated with chloramben at 1.5 to 2 Ibs/acre
or in combination with atrazine, did not  show residues greater than 0.1 pm
in corn (samples  consist of  silage,  immature ears,  immature whole plant and
whole plant).  (Amchem, 1975, 0109A)  Corn  samples  from four different
locations representing four  varieties of  corn (PAG  5X7.- Pioneer 3206 and
Agway 800, McCurdy 95) that  had been treated with a formulation of
chloramben plus atrazine 1+2 Ib/A or 2+4.1b/A were  analyzed and no residue
of chloramben greater than 0.1 ppm was  found.  The  atrazine levels were
less than 0.25 ppm in the same samples.  (Hazleton  Labs, 1969, 0110)

These data indicate that residues below tolerances  are found in corn
treated in accordance with label recommendations.

Sweet Potatoes

The recommended rate of application  is  4  Ibs/acre.   Sweet potatoes of
"Georgia Red" and "Tenhoma"  varieties  treated with  a liquid formulation of
chloramben at the rate of 4  or 8 Ibs/acre 145-197 days before harvest did
not show chloramben residue  content  greater than 0.1 ppm (Amchem, 1967,
0044).

Use of either liquid or granular  formulations of chloramben at the rate of
6 Ibs/acre 111 days before harvest did  not  show a chloramben residue more
than 0.1 ppm.  Sweet potatoes  of  "Nemagold" variety were treated with
granular or liquid formulation of chloramben at rates of 8 Ibs/acre (or 9
Ibs/acre  in one case) did not  show residues greater than 0.1 ppm (Amchem,
1967, 0044).

Sweet potatoes of "Centennial" variety when treated with a liquid
formulation of chloramben at 6 or 32 Ibs/acre 117 days before harvest
showed no residues of chloramben greater  than 0.1 ppm (Amchem, 1967, 0044).

In a rate of disappearance study sweet  potatoes of  the "Nemagold" and
"Yellow Sweet Potato" variety  were  treated  with a liquid formulation of
chloramben at 16  Ibs/acre.   Analysis of yellow  sweet potatoes harvested at
                                    6-12

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three stages very  immature  (56 days  after  treatment), immature (97 days
after treatment),  and mature potatoes  (124 days  after treatment)  showed
residues contents  of 2.5 pan, 0.25 ppm, and  less than 0.1 ppm,
respectively.  Analysis of  the "Nemagold"  variety at very immature (61
days), immature  (79 days) and mature (111  days)  stages showed a residue
content of 0.11 ppm, less than 0.1 ppm, and  less than 0.1 ppm, respectively
(Amchem, 1967, 0044).

Sweet potatoes treated at the exaggerated  levels of  32 Ibs/acre did not
show any residue of 2,5-dichloroaniline, a potential metabolite of
chloramben (Amchem, 1965 estimated,  0078).

Two varieties of sweet potatoes  ("Centennial" and "Yellow")  from  four
locations treated  at 4 Ibs/acre  116-125 days before  harvest  did not show
more than 0.1 ppm  of chloramben  residues (Amchem, 1975,  0109A).

Residues of less than the tolerance  level  occur  in sweet potatoes treated
at the recommended application rate.

Pumpkin, Squash

The recommended rate is 2-4 Ibs/acre.  In  a rate of  disappearance study
squash of "Crcokneck" variety were treated at 8-12 Ibs/acre  and the squash
vines, immature fruit, mature fruit  (early harvest), and mature fruit (late
harvest)  were analyzed for chloramben residue content.   All  the samples
showed less than 0.1 ppm residue (Amchem,  1967,  0044).

Seven squash varieties (Table Queen, Buttercup,  Butter Nut,  Yellowneck,
Green Hubbard, Boston Marrow, Zucchini) from seven locations were treated
at the rate of 8 Ibs/acre with a granular  formulation of chloramben and
harvested after 100-144 days of  treatment.  In all the cases the  chloramben
residue content was less than 0.1 ppm (Amchem, 1967,  0044).

Pumpkins of the type "Big Tom" and "Small  Sugar",  treated  at the  rate of 8
Ibs/acre 100-104 days before harvest did not show any chloramben  residue
greater than 0.1 ppm.  "Kentucky Field" pumpkins when treated with a
granular formulation of chloramben at the  rate of 3  Ibs/acre 119  days
before harvest showed residues less  than 0.1 ppm (Amchem,  1967, 0044).

Pumpkins of the Jack-o-Lantern variety showed less than  0.04 ppm  of
chloramben .residues when treated with chloramben at  6 Ibs/acre  111 days
before harvest (Amchem, 1968, 0084).

Squash of four varieties, (Butternut, Golden Summer  Crcokneck,  Yellow
Crcokneck, Golden Hubbard) from six locations treated with chlcramben at a
rate of 2 to 4 Ibs/acre 53-90 days before  harvest  failed  to  show  chloramben
residues greater than 0.05 ppm (Amchem, nd, 0109).

Using a method sensitive to 0.1 ppm, no trace of 2,5-dichloroaniline, free
or bound was found in Big Tom pumpkin, Acorn squash, and Zucchini  treated
at twice the recommended rate of chloramben (Amchem, 1964, 0164).

These data show chloramben applied at the recommended rate gives  residues
below the tolerance limit for pumpkin and  squash.
                                   6-13

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Dry Beans and Snap Beans

The recommended rate of application  is  2-3  Ibs/acre.   Beans  of.five
varieties (Red Kidney, Pinto, Pinto  U.I.  Ill, Navy Beans,  great Northern)
treated with a liquid  formulation of chloramben  at rates of  3-8 Ibs/acre
showed no chloramben residues higher than 0.1 pan  (Amchem, 1967, 0044).

Navy beans of the "Gratiot" variety  treated with chloramben  at the rate  of
3 Ibs/acre showed a chloramben residue  content of  less than  0.04 ppm
(Ainchem, 1968, 0084).

Chloramben treated dry beans showed  less  than 0.1  ppm of 2,5-
dichloroaniline, a potential metabolite of  chloramben (Amchem, 1964,
0093).

"Great Northern" dry beans treated with chloramben at the  rate of 4
Ibs/acre and "Pinto" dry beans treated  at the rate of 8 Ibs/acre failed  to
show 2,5-dichloraniline higher than  0.1 ppm using  a method sensitive to  0.1
ppm (Menem, 1963, 0008).

Beans of different types treated with chloramben at different rates ("Great
"Northern" 3-4 Ibs/acre, "Red Kidney" 3 Ibs/acre,  "Navy" 2 Ibs/acre,
"Pinto" 3-8 Ibs/acre)  did not show a residue of  chloramben higher than 0.1
ppm (Amchem, 1964, 0096).

Four varieties of snap beans (Tender Pot, Black  Valentine  Bush, Blue lake,
Tender Crop Gal Val 50). from four locations treated with chloramben at the
rate of 4-8 Ibs/acre 52-98 days before  harvest,  showed chloramben residues
less than 0.1 ppm (Amchem, 1968, 0149).

These data show that residues below  tolerances result from use of
chloramben on "dry" beans and snap beans.

Cucumber

The recommended rate of application  is  2-3  Ibs/A.  Three varieties of
cucumbers (Crispy Formula 58, Burpee Pickler, Sunnybrcok Slicer)  treated
with chloramben at the rate of 2 to  8 Ibs/acre 69-71  days  before harvest
did not show chloramben residues greater  than 0.1  pan in the fruit
(Anchera, 1968, 0149).

Melons

The recommended rate of application  is  2-3  Ibs/A.  Musk melon ("Samson
Hybrid"), watermelon ("Sugar Baby")  and cantaloupe (Bale's Best Jumbo)
treated at 8, 6 and 6  Ibs/acre, respectively, showed  no detectable
chloramben residues in the fruit (Amchem, 1968,  0149).

Sunflower

The recommended rate of application  is  2-3  Ibs.  per acre.

Sunflower plants (Peredovik, Sun Hybrid 304, and an unknown  variety) were
treated with a Chloramben/trifluralin tank  mix  (3  Ibs/acre chloramben plus
                                    6-14

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1 Ib/acre  trifluralin)  122  to 135  days before harvest.  The whole seeds on
analysis contained  less than  0.01  ppm of chloramben and less than 0.05 pan
of trifluralin  (Amchem, 1979, 0100).

Adequacy of Residue Data

Several crops which may be  treated with chloramben are further processed
after harvesting, in  the course of which may occur a concentration of any
residues of chloramben. These comprise tomatoes (to tomatoe pastes and
purees), soybean  (to  soybean  oil), peanuts (to peanut oil)/ sunflowers (to
sunflower  oil), and corn (to  corn  oil) .

Available  crop residue  data on tomatoes, soybeans,  peanuts, and sunflowers
indicate that, in general, residues do not occur at detectable levels on
the raw agricultural  commodities at harvest.   Therefore,  processing studies
are not required.

Residues in Meat, Milk, Poultry, and  Eggs

For this Section, data  should show whether residues will  result in meat
(muscle, liver, kidney, fat), poultry,  eggs,  or milk.  The  toxicant fed
should correspond to  the aged residues  found  in the item  of feed, which may
or may not be the parent pesticide.  The studies should be  performed at
several dosage levels,  including exaggerated  dosages, preferably threefold
and tenfold.

The bulk of residue data on raw agricultural  commodities  (RAC)  indicate
residues below tolerance levels.   Since data  indicate that  residues are
present below the level of detection, feeding studies are not required.

     4.    Dietary Exposure

The exposure of humans  to pesticide residues  from registered use via the
food chain is a function of several factors:

a)   The established  tolerance for a  commodity (in  ppm)
b)   The percentage of  a commodity in the daily diet.
c)   The percent of that commodity that is treated  with the pesticide (an
     adjustment factor  for total population exposure).
d)   The assumed amount of food consumption by an average person, 1.5 kg
     per day.
e)   The assumed body weight  of an average person,  which  is 60  kg.

When these factors  are  substituted  into a formula  (i.e,  (axbxcxd)
divided by e), the  human exposure  to  those pesticide residues in a
commodity  is found  in terms of mg  of  pesticide  per  kg of  body weight per
day.

This potential daily  exposure is compared with  an 'Allowable Daily Intake1 ,
which is set on the basis of  toxicological 'No  Observable Effect Level1 ,
plus a margin of safety factor of  lOOx, to allow for a  lOx  greater
sensitivity of humans-over test animals,  and  to allow for the possibility
of an individual who  is  lOx more sensitive than the average person.   In
order to determine  the  'No Observable Effect  Level'  for a pesticide
chemical,  the Agency must have adequate acute and chronic studies.
                                   6-15

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The estimates of human dietary exposure  to  chloramben are presented in
Table 5-1 and are based on  tolerance  levels.   The data indiate that dietary
exposures to chloramben will range  from  less  than .0005 to 0.013 mg/day
(0.000008 to 0.00022 mgAg  body weight). Annual dietary exposure is then
estimated at from less than 0.16  to 4.7  mg/person.  The maximum value
reflects the possibility  that a person's diet includes all chloramben-
treated crops, when in actuality  this is unlikely to occur.  Chloramben is
used on only seven percent  of soybean crops,  four percent of tomato crops,
thirteen percent of bean  crops, three percent of peanut crops and less that
one percent of corn crops in the  United  States.  The minimum values (or
adjusted values) in Table 5-1 reflect adjustments for these particular
crops.

C.    Chloramben End-Use  Formulations

     1.    Registration Requirements

There are no residue chemistry data required  for the non-food use of
chloramben.

For future registration of a product  for use  on a food or feed crop not
covered by this Standard, the Agency  must be  provided with a petition for
tolerance, a full range of data  including a validated method for analysis
of residues in or on the  raw agricultural commodity, data on metabolism of
chloramben in plants and  (when appropriate) in animals, and residue data
reflecting the proposed use of the  pesticide  on the crop.
                                    6-16

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                                  TABLE 6-1
                      DIETARY EXPOSURE TO CHLCRAMBEN
Tolerance
ppm
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1

Food
Factor
0.92
2.87
0.19
1.00
0.36
0.31
0.52
0.73
0.12
0.11
0.98
0.11
0.03
0.40

Daily
Intake
mg/dav ma/dav
0.0014
0.0043
0.0003
0.0015
0.0005
0.0005
0.0008
0.0011
0.0002
0.0002
0.0015
0.0002
0.0001
0.0006
0.013
Adjusted
Dietary
Intake
0.0001
0.00015
0.00004
0.0000.2
0.00002
0.00006
o.oooni
0.00001
0.000002
0.000002
0.000002
0.000002
0.00001
0.00001
0.00045
Soybeans
Tomatoes
Lira Beans
Corn
Peanuts
Beans, Dry, Edible
Cantaloupe
Cucumbers
Peppers
Pumpkin
Beans, Snap
Squash
Sunflower
Sweet Potatoes
TOTAL
     When data available, values based on percentage of sites  treated  with
chloramben.  For site where percentage of treatment is unknown, one
percent is assumed.
                                   6-17

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                                   CHAPTER VII

                       TOXICOLOGY  OF CHLORAMBEN PRODUCTS

A.  Introduction

A wide range of chloramben products are  currently registered for use.
Manufacturing-use products consist of  sodium chloramben and methyl chloramben.
End-use formulations contain chloramben  as the  active ingredient/ present as
the sodium salt, ammonium salt, moncmethyl amuonium salt or methyl ester.

Toxicology testing is required for registration of all manufacturing-use
products and end-use formulations  of chloramben.  The majority of tests (acute
and chronic) are to be performed on the  manufacturing-use product or the
technical grade of the active ingredient,  if different.  Acute toxicity testing
of all end-use formulations must also  be conducted.  For purposes of
extrapolating toxicology safety data,  the  sodium salt of chloramben has been
determined to be equivalent to chloramben  (3-amino-2,5-dichlorobenzoic acid).
A summary report in Agency files indicates that the methyl ester of chloramben
hydrolyzes to chloramben acid, through microbial degradation,  within days of
application to soil.  Provided evidence  is submitted documenting this reaction,
all data requirements associated with  the  food-use pattern of  methyl chloramben
may be fulfilled through testing with  chloramben acid or the sodium salt.

A potential RPAR (Rebuttable Presumption Against Registration)  trigger study on
technical chloramben conducted by  the  National  Cancer Institute (NCI) indicated
that chloramben administration resulted  in hepatocellular carcinoma in female
mice.  Three additional chronic feeding  studies, employing a lower dose range  j
than the NCI study do not indicate oncogenic potential.  However, these studies
are of limited value for "measuring the oncogenic potential of  chlpramben since
the MZD (Maximum Tolerated Dose) was not used.   Available mutagenicity testing
is negative.

Toxicological data submitted to date are primarily on technical chloramben.
Some data have been submitted on sodium  and  methyl chloramben  and end-use
formulations containing either methyl  chloramben, ammonium chloramben, sodium
chloramben or an ammonium cnloramcen/moncmethyl  amnonium chloramben mixture.

B.  Chloramben Manufacturing-Use Products

    1.   Toxicology Profile

         a.   Sodium Chloramben

The Agency has determined that data .requirements for sodium chloramben may be
fulfilled by testing with technical chloramben  (3-amino 2,5-dichloro benzoic
acid).  The high acute oral LD5Q of 100% technical chloramben  (5,620 mg/kg)
in male rats suggests a very low acute oral  hazard to human beings.  Gross  *
pathologic changes included congested  lungs,  kidneys,  and adrenals.  Dermal
LD-0 values of 3,160 mg/kg and greater than  5 g/kg> respectively, for


                                       7-1

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technical chloramben  (100 percent purity)  and  sodium chloramben (85 percent
chloramben acid equivalent) administered  to  male and female albino rabbits
indicate a low potential for human dermal  toxicity.   Based on the LC5Q
determination of greater than 200 mg/1  (sodium chloramben) in male and female
rats, a low acute inhalation hazard  is  expected.  Sodium chloramben may
irritate human eyes based on a primary  eye irritation study in albino rabbits.
Mild to moderate conjunctival irritation  persisting  for 7 days was noted in
this study.

No subchronic dermal  or  feeding  studies are  available on either technical
chloramben or sodium  chloramben.  Two-year feeding of technical chloramben (97
percent purity) to male  and female beagles did not result in any toxic
effects.  Slight to slight-to-mcderate  vacuolation of liver cells was noted in
3 of 8 dogs at the high  dose level  (10,000 ppm).  The "No-Observed Effect
Level" (NOEL) for the study is 1,000 ppn  (25 mgAg bcdy weight/day) .

A 1963 chronic feeding study in  albino  rats  will not satisfy Agency
requirements because  of  insufficient test animals, a high incidence of non-
chloramben related mortality, disparity of animal weights, and limited
histopathological reporting.  A  1979 chronic feeding study in rats reported
that chloramben in the diet at concentrations  of 100, 1,000, and 10,000 ppm did
not cause any significant effect.

An oncogenic study on technical  chloramben (90-95 percent purity) by the
National Cancer Institute concluded  that  chloramben  was carcinogenic to female
mice, producing hepatocellular carcinoma. The Agency considers the NCI
Bioassay, although flawed, adequate  for risk assessment.  An eighteen month
oncogenic study of technical chloramben conducted by Huntingdon Research Center
concluded that chronic ingestion of  the compound by  O>1 mice did not result in
any compound-related  tumors at dosages  less  than the maximum tolerated dose
(yfTD).  Primary compound associated  tissue alterations were confined to the
liver in all treated  mice and were compatible  with that observed in enzyme
induction.  No dose-related trends in benign or malignant tumors were
identified in the 1979 chronic feeding  study in rats discussed above.  However,
the dosages employed  in  this study  (100,  1,000, and  10,000 ppm) were also less
than the'MTD.

A sub-mammalian point mutation test  (no metabolic activation) using technical
chloramben (90-99 percent purity) was not mutagenic  to the test organisms.
Further rmtagenicity  testing is  required  as  are teratogenicity studies.

A very limited metabolic study indicated  no  retention of the compound in the
liver, kidney, muscle, fat, and  blood of  dogs  fed chloramben.  Residues in the
urine and feces were  detected.
                                       7-2

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    b.   Methyl Chlorainben

Although the acute  toxicity  properties  of the methyl ester of chloramben are
expected to differ  from  those of  the  sodium salt, the effects of chronic
exposure as a result of  food ingestion  are similar based on the breakdown of
the methyl ester in soil to  chloramben  acid.

The methyl ester of chloramben has  a  higher acute toxicity than does either
technical chloramben or  sodium chloramben.  The acute oral LD-g value of
1,710 mg/kg following administration  of the technical methyl ester to male rats
results in a Toxicity Category III  designation, still indicating a generally
low acute oral toxicity hazard.   Major  necropsy findings include congestion of
the lungs, liver, kidney, and pancreas;  pale-appearing spleen; and
gastrointestinal inflammation.

No other testing was conducted with the technical methyl ester of chloramben.

    2.   Human Risk Assessment Evaluation

         a.   Acute Exposure

The chloramben exposure profile (see  Environmental Fate Chapter) reveals that
persons who handle, store or ship the manufacturing-use products sodium
chloramben and methyl chloramben  will be exposed  principally by the dermal
route.  Without proper precautions, the  compound  may get in the eyes.

Based on the previous toxicological assessments,  single exposure by the dermal
route will likely pose a low acute hazard.  Single exposure to eyes may be
quite irritating based on primary eye irritation  studies conducted with sodium
chloramben and methyl chloramben.  Methyl  chloramben appears to be greater
ocular irritant than sodium  chloramben.   Swallowing a lethal dose of sodium or
raethyl chloramben by accident seems unlikely  based on the relatively high acute
oral LDe0 values resulting from administration  of the two compounds to  rats.
The acute inhalation toxicity hazard  is  also  expected to be low based on the
available toxicology data.

Exposure to chloramben formulations during soil application will be principally
by the dermal route.  Acute dermal testing with chloramben formulated products
to date indicates a low acute dermal  hazard.

    b.   Chronic Exposure

A major concern regarding any potential  long-term exposure in humans to a
pesticide product is the risk of developing delayed  toxic effects,  including
cancer.  In order to assess  this  risk for  chloramben exposure, the reported
conclusions of the National Cancer Institute  (NCI) bioassasy of  chloramben are
utilized.  The NCI study concluded that  administration  of technical chloramben
resulted in hepatocellular carcinoma  in  female  B6C3F1 mice.  No  other
oncogenic, mutagenic, reproductive or teratogenic effects were noted in
submitted studies.
                                      7-3

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The only incidence data  that  lends  itself to risk assessment through fitting a
mathematical ncdel is that of the  female mice with liver hepatocellular
car cinema .

             Female Mice-Liver Hepatocellular Carcinoma Incidence

                                       Dose (ppm)

              0                       10,000             20,000


          2/67  (0.03)                 7/48 (0.15)         10/50 (0.20)

The dose-response relationship assumed in the analysis is that of the linear
multi-stage developed by Crump whereby
                    P(D)  = l

and P is the response  (incidence)  and D is the dose.

The estimation of  the  parameter, q, by the maximum likelihood method yields the
following estimator of oncogenic risk:

                               qj-  1.05 x 10"5

The model utilized (Global 79) also provides the upper and lower confidence
limits  for  the additional risk. For a risk level of 1 x 10 °, the upper
confidence^ limit  is estimated to be 1.59 x 10~ .  The dose producing a risk
of 1 x  10~  and the average 95% confidence limit for this dose (the virtual
safe dose)  are estimated to be .095 ppm and .060 ppm, respectively.

The estimation of  the  oncogenic risk parameter is tentative, however, given
that only two data points could be utilized.

         i.   Dietary  Exposure

3y utilizing the  risk  parameter and determining the level of chloramben
expected in the diet,  the lifetime probability of a cancer due to dietary
exposure can be calculated (P = qX) where X is the ppm in the diet.  Table 7-1
gives the individual risks associated with ingestion of registered crops
treated with chloramben.
                                       7-4

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As discussed in Chapter 6  (Residue Chemistry),  the exposure of humans to
chloramben residues  is a function of several factors:

    a.   the established tolerance of the  crop  (in ppm).
    b.   percentage  of crop  in  the daily diet.
    c.   percent of  crop treated with chloramben.
    d.   average consumption of crop per person per day.
    e.   weight of average person (60 kg).

The estimate of human dietary exposure to  chloramben as presented in Table 5-1
is 0.00045 mg/day.

Lifetime average ppm in the  diet is  therefore  .0003 ppm.

    .00045 = .0003
      1.5

                                   TABLE 7-1

          ONCCGENIC RISK ASSOCIATED WITH THE INGESTION OF  CHLORAMBEN
                                                      Lifetime  Probability or
               Lifetime Average      Estimator of     Cancer Due  to Ingesting
Product         ppm in Diet          Oncogenic Risk        Chloramben
All chloramben
treated crops
3 x 10~4
1.05 x 10~5
3,15
x 10"9
ii. Non-Dietary Exposure

For applicator exposure, a dietary exposure equivalent is calculated  for  risk
assessment.  Non-dietary exposure is calculated for the soluble/flowable
concentrate (refer to the discussion on non-dietary exposure in Chapter 5 -
Environmental Fate).   The following assumptions from Chapter 5 are used in
deriving the occupational risk of chloramben exposure.
                                      7-5

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1)   Potential Exposure Routes and Absorption Data:


    Formulation    Activity
                                    Worst  Case
                                     (ing/year)
    Soluble or
    Flowable
    Concentrate
                   Mixing-Loading
                   (mixer-loader or
                   fanner/planter)
       27.3
                   Ground Application    6.9
     Best Case
     (mg/year)

       0.13
                                                         0.016
TOTAL:
                                       34.2
                        0.146
2)  A lifetime average pern exposure  (as  a dietary equivalent)  is calculated
    based on 40 years of exposure in a 70-year  lifetime.
                                            Worst Case    Best Case
    Soluble/Flowable Concentrate
                                              0.052
                            0.0002
The following table gives the  individual risks  associated  with application of
chloramben formulations based on a worst-case and  best-case  exposure  level.

                                   TABLE 7-2

          CNCCGENIC RISK ASSOCIATED WITH THE CHLORAMBEN  APPLICATIONS
Product
              Lifetime Average
                ppm Exposure
 Estimator of
Oncogenic Risk
Lifetime Probability of
Cancer due to Chloramben
       Application
  (includes dietary)
Soluble/Flowable
Concentrate
Worst Case
Best Case
0.052
0.0002
1.05 x 1Q~1
1.05 x 10
5.46 x 10~g(5.49 x lo"Z)
2.10 x 10~*(5.15 x 10~y)
                                      7-6

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    3.   Data Requirements and Data Gaps

•The following are toxicology data  requirements  for registration of
manufacturing-use products.  Listed after each  requirement is the section in
the Proposed Guidelines of August  22,  1978,  (43 FR, No.  163 37336) that
describes the type of data required.

         a.   Food Use or Non-Food  Use

All applicants, regardless of end-use, must  submit or cite the following data;

Category of Test                                            Guideline Number

    Acute Oral Toxicity (rat)	     163.31-1
    Acute Dermal Toxicity (rabbit)	     163.81-2
    Acute Inhalation Toxicity (rat)	     163.81-3
    Primary Eye Irritation (rabbit)	     163-81-4
     or Demonstration of pH 1-3 or  12-14
     or Demonstration of Dermal Irritation of Category I
    Primary Dermal Irritation (rabbit)	     163.81-5
    Skin Sensitization (guinea pig)	     163.81-6

 Data Gaps

    Sodium Chloramben

The following tests are required for the  reregistration of manufacturing-use
sodium chloramben, regardless of its end-use:

Category of Test                                       Guideline  Number

    Skin                A skin sensitization test
     Sensitization      in the guinea  pig is required       163.81-6

    Methyl Chloramben

The following dataware required for the reregistration of  manufacturing-use
methyl chloramben, regardless of its end-use:

Category of Test                                      Guideline  Number

    Acute Oral          The purity of  the methyl
                        chloramben used in testing          163.81-1
                        male rats must be submitted.

    Acute Dermal        An acute dermal toxicity
     Toxicity           study,  preferably in the
                        albino rabbit, is required.         163.81-2
                                      7-7

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    Acute Inhalation
     Toxicity

    Primary Eye
     Irritation

    Dermal Irritation
    Sfcin
     Sensitization
An acute inhalation study  in
the rat is required.

A primary eye irritation test
in the albino rabbit  is required

A dermal irritation test in the
albino rabbit is required.

A skin sensitization  test
in the guinea pig  is  required.
163.81-3
163.81-4
                                                            163.81-5
163.81-6
         b.   Food Use  (Requires a Tolerance  or Exemption)
All applicants for registration  or  reregistration of technical chloramben
products which are formulated  into  end-use  products intended for use on food
must submit or cite the  following:
Category of Test

    Subchronic Oral Toxicity	
    Subchronic 21-Day Dermal Toxicity.
    Dermal Sensitization	
    Chronic Feeding	
    Oncogenicity	
    Teratology	
    Reproduction	
    Mutagenicity	
    Metabolism in Laboratory Animals..
                                   Guideline Number
                                         163.82-1
                                         163.82-2
                                         163.82-6
                                         163.83-1
                                         163.83-2
                                         163.83-3
                                         163.83-4
                                         163.83-1 to 4
                                         163.85-1
Data Gaps

   Sodium Chloramben

The following  tests are  required  for the reregistration of manufacturing-use
sodium chloramben  intended  for  food  use.
    Subchronic
     dermal  toxicity


    Chronic  feeding



    Onccgenicity
A 21-day dermal  toxicity
study in the albino rabbit
is required.                        T63.82-2

The purity of chloramben used
in the 1979 chronic feeding
study must be supplied.             163.83-1

Compound purity  must be
submitted for the  1979 rat
study and 1978 mouse study.         163.83-2
                                       7-8

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    Teratogenicity      Teratogenicity testing in
                        two mammalian  species is
                        required.                           163.83-3
    Reproduction        Product purity is  required
                        for the exisiting  reproduction
                        study.                              163.83-4
    Mutagenicity        A mammalian in vitro  point
                        mutation test;  a sensitive
                        sub-mammalian  point mutation
                        test  (with metabolic  activa-
                        tion); a primary ENA  damage
                        test; and a mammalian in vitro
                        cytcgenetics test  are required.     163.84-1

    Metabolism          A general metabolism  study
                        in'one mammalian species
                        is required.                        163.85-1

Methyl Chloramben

Provided that evidence is submitted documenting  the  hydrolysis of the methyl
ester to chloramben acid after application to the  soil, data requirements
associated with the food-use pattern of methyl chloramben may be  fulfilled for
the most part through testing with chloramben acid or  the sodium  salt.  The one
exception is that a general metabolism study  on  methyl chloramben must be
submitted.  The data gaps detailed above for  sodium  chloramben pertaining to
food-use must be filled in order to allow reregistration of the methyl ester in
a food-use pattern.

         c.   Non-Food Use (Nondomestic, Outdoors)

All applicants for registration or reregistration of technical products which
are formulated into end-use products intended  for non-food, nondomestic,
outdoor uses must submit or cite the following:

 Data Gaps

Sodium Chloramben

    Teratogenicity      Teratogenicity  testing
                        in two mammalian species
                        is required.                        163.83-3
                                      7-9

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    Mutagenicity        A mamalian  in vitro point
                        mutation test; a sensitive
                        •sub-mammalian point mutation
                        test; a primary DMA damage  test?    163.84-1
                        and a mammalian in vitro            through
                        cytogenetics test are  required.     163.84-4

 Methyl Chloramben

    Metabolism          A general metabolism  is required    163,85-1
                        if not submitted in conjunction
                        with the food-use requirements
    4.   Topical Discussions

         a.   Sodium Chloramben

The following topical discussions  describe  available toxicity data on sodium
Chloramben and state whether  they  are  adequate  for Agency regulatory purposes.

Acute Oral Toxicity

The minimum testing needed on acute  oral  toxicity is one test, in the
laboratory rat, on the technical chemical and on the manufacturing-use product
if different.

The acute oral LD-- of technical Chloramben (100 percent purity)  was 5,620
mg/kg body weight in male rats (Hazleton  Laboratories, 1959, 0022).  Confidence
limits could not be calculated due to  an  "all or none" response.   Toxic effects
included depression characterized  by inactivity and ataxia , labored
respiration, sprawling of limbs, ptosis,  lack of coordination and excessive
urination.  Gross pathologic  findings  included  congested lungs, kidneys and
adrenals.  This is an adequate determination in males, which would place
technical Chloramben in Category 'IV, indicating a very low acute oral hazard.

An acute oral LDen determination using sodium Chloramben (85 percent
Chloramben acid equivalents)  administered to male and female rats suggests a
similarly low acute toxicity  hazard.  The study is not considered to fulfill
Agency requirements because of problems in  determining the actual LDe  value.
No further  testing  is  required  given the valid LD5Q determination for
technical Chloramben.

Acute Dermal Toxicity

The minimum testing needed  on acute dermal toxicity is one test, preferably in
the albino  rabbit,  on  the  technical chemical and manufacturing-use product.
                                      7-10

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The acute dermal LD-0 value  (intact  skin)  for male and female albino rabbits
exposed to technical chloramben  (100 percent purity)  was determined to be
greater than 3,160 ngAg body weight (Hazleton Laboratories, 1959, 0023).

Depression characterized by  inactivity was noted  at highest dose levels.
Little or no dermal absorption of the applied material was noted.  Mild to
moderate erythema and mild edema were observed initially, but subsided within
two days.  This study fulfills Agency requirements for testing on intact skin
and indicates a Toxicity Category III-IV designation.

A dermal LD-Q determination  for manufacturing-use sodium chloramben (85
percent chloramben acid equivalent)  applied  to the intact and abraded skin of
rabbits indicated a value greater than 5 g/kg body weight (CDC Research, 1978,
0065).  No dermal reactions, adverse reactions or mortality were noted over the
study course.  A Toxicity Category IV designation is  indicated.   These two
studies are adequate to fulfill Agency requirements for acute dermal toxicity
testing.  No further tests are required.

Acute Inhalation Toxicity

The minimum data requirement for acute inhalation toxicity is one test,
preferably in the albino rat, on the technical chemical and on each
manufacturing-use product.

No tests on technical chloramben are available.

Acute inhalation testing as conducted with sodium chloramben (82.8  percent
chloramben acid equivalent) resulted in an LC_Q determination of greater than
200 mg/1 to male and female albino rats  (Food  and Drug Research  Laboratories,
1978, 0062).  This value would place sodium  chloramben in Toxicity  Category IV,
indicating a very low acute inhalation hazard.  The study is considered to
fulfill Agency requirements for acute inhalation  testing.   No further testing
is required.

Primary Eye Irritation

The minimum testing needed to evaluate eye irritation potential  is  one  test, in
albino rabbits, on each manufacturing-use  product.  If the test  substance  has a
pH of 1-3 or 12-14, however, it will be judged corrosive,  and an eye  irritation
test is not needed.  Also, if the test substance  has  been  judged  to be  dezmally
corrosive, an eye irritation test is not needed.

The acute eye irritation study on technical chloramben (100 percent purity)
does not meet Agency requirements because  of deficiencies  in protocol.   A
primary eye irritation study en sodium chloramben (85 percent chloramben acid
equivalent) administered to female rabbits is  considered  to fulfill Agency
requirements for this test (CDC Research,  1978, 0064).  Mild  to moderate ocular
irritation was observed at 24 hours  in 6 of 6 rabbits.   Irritation  in all  cases
                                     7-11

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cleared within 7 days.  The results  indicated  a slight acute eye irritation
hazard based on a Toxicity Category  III designation.   No further testing is
required.

Primary Dermal Irritation

The minimum testing needed to  evaluate dermal  irritation potential is one test,
preferably in the albino rabbit, on  each manufacturing-use product.

Sodium chloramben  (85 percent  chloramben acid  equivalent) was very slightly
irritating to intact and abraded rabbit skin at either 24 or 72 hours (CDC
Research, 1978•, 0063).  The study  is adequate  to place sodium chloramben in
Category IV, indicating a very low potential for dermal irritation.  No further
tests are required.

Skin Sensitization

The minimum requirement  for assessing skin sensitization is an intradermal test
in one mammalian species, preferably the guinea pig,  on each manufacturing-use
product.

No testing is available  for either technical chloramben or manufacturing-use
sodium chloramben.  Tests are  therefore  required to assess skin sensitization.

Acute Delayed Neurotoxicity

An acute delayed neurotoxicity evaluation  is not required because chlorainben is
not expected to cause acetylcholinesterase depression, nor is its chemical
structure related  to  that of  substances  that induce delayed neurotoxicity.

Subchronic Oral Toxicity

The minimum  testing needed  to assess subchronic oral toxicity is one test in
each of  two mammalian species, a rodent  and a non-rodent, on the technical
chemical.

No adequate  rodent subchronic (90-day)  oral test of the technical product is
available.  A 28-day dietary  feeding study in male albino rats does not fulfill
Agency  requirements  for  this  test.

A two-year  feeding study in male and female beagles on technical chloramben (97
percent  purity) satisfies  the requirement  .for a non-rodent study.  In this
study,  beagle dogs received chloramben in  the diet at 0, 100, 1,000 and 10,000
ppm  (Hazleton Laboratories,  1963,,  0028).   Both test and control groups
exhibited normal  behavior  and weight gain.  Values for hematological,
biochemical, and  urinary analyses  were within normal ranges.  Organ/body weight
ratios  were  not affected.   Organs  examined histologically revealed no
significant  alterations. Slight to slight-to-moderate vacuolation of liver
cells was  found  in 3 of  8 dogs at the high dose level  (10,000 ppm).  The NOEL
reported  in  the study  is 1000 ppm (25 mgAg body weight/day).


                                      7-12

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Because chronic  testing  in  the mouse and rat is available, additional
subchronic oral  toxicity testing is not required.

Subchronic 21-Day Dermal Toxicity

The minimum requirement  to  assess subchronic 21-day dermal toxicity is one
study, preferably in the albino rabbit, on the technical product.  This study
is required for  all uses of chloramben.

No studies of subchronic dermal toxicity on technical chloramben are
available.  Testing is therefore required.

Subchronic 90-Day Dermal Toxicity

A subchronic 90-day dermal  toxicity test is not required because chloramben is
not purposely applied to skin,  and  its  use will not result in human exposure
comparable to/ for example,  the exposure of swimmers to swimming pool additives
or garment wearers to pesticide-impregnated fabric.

Subchronic Inhalation

A subchronic inhalation  test is not required  on technical chloramben since its
use would not likely result  in  toxic concentrations as determined from the
results of the acute inhalation LC50 value (greater than 200  mg/1)  for sodium
chloramben.

Subchronic Neurotoxicity

A subchronic neurotoxicity evaluation is not  required on chloramben because it
is not expected to induce neuropathy or delayed neurotoxicity,  and  because it
does not have a molecular structure  closely related to that of  a compound  that
is known to induce neuropathy or delayed  neurotoxicity.

Chronic Feeding

A chronic feeding study  is required  in  one mammalian species, preferably the
laboratory rat, using the technical  product.

A chronic oral toxicity  study in albino rats  conducted by Hazleton  Laboratories
(1963; 0027, 0088, 0089)  will not satisfy Agency requirements because of
deficiencies in study protocol  and data reporting.   A recently  submitted
chronic feeding study in Sprague-Dawley rats  (Litton Bionetic,  1979, 0171)  will
fulfill Agency requirements  following receipt of product purity information.
Results of this study indicate  that  administration  of technical chloramben at
dose levels of 100, 1,000 and 10,000 ppm did  not result  in any  dose-related
chronic effects.  The dose levels chosen  were significantly less than the
previously established MTO of approximately 32,000  ppm for rats. Body weight^
food consumption, and survival were  comparable  among test and control animals.
Results of clinical testing were negative.


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Oncogenicity

Oncogenicity tests  using  the  technical material are required in two mammalian
species, normally the rat and  mouse.

A National Cancer Institute  (NCI)  study submitted on technical chloramben  (90-
95 percent purity)  administered  for 80 weeks to Osborne-tMendel rats and B6C3F1
mice concluded  that chloramben was carcinogenic to the female mice, producing
hepatocellular  carcinoma  (National Cancer Institute, 1977, 0019).  The liver in
female mice was the only  site  where the occurrence of carcinoma was reported to
be significant.  The pathologic  findings other than liver cell cancer do not
establish a clear trend.   There  was some evidence that chloramben had a
goitrogenic effect  based  on  the  observed incidence of follicular-cell
hyperplasia of  the  thyroid.   However, insufficient number of controls were
available to draw a firm  conclusion.   The incidence of hemangiomas (blood
vessel tumors)  in male  rats  was  significant at the low-dose level but not the
high-dose level.  This  borderline  positive supports the positive result seen in
female mice.  The incidence  of hemangiomas in female rats was not significant
at either dose  level.
                                 t
The study did contain some flaws in study protocol and study conduct.  Among
the identified  deficiencies were the  following: a high probability of
improperly mixed feed,  improperly designed exhaust vents in mixing rooms, and
improperly cleaned  feed-mixing pots,  and feed-mixing areas.  Although the study
had definite shortcomings, the Agency was able to use this study in an
oncogenic risk  assessment.  The  Agency therefore considers this study adequate
to fulfill requirements for  oncogenic testing in both rats and mice.

The eighteen month  oncogenic study of technical chloramben of unspecified
purity fed to CD-I  male and  female mice will supplement  Agency requirements
for oncogenic testing in  mice  following submission of the detailed composition
of the test chemical (including  minor impurities).  In this study, chloramben
was fed to CD-I mice at levels of 0,  100, 1/000 and 10,000 ppm in the diet
(Hunting-ton Research Center,  1978, 0170).  These doses were considerably below
a previously determined ^^^D  level  of  greater than 30,000 ppm.  Behavior,-
appearance, and survival  were  considered normal and comparable between control
and test animals.   Differences in  body weight and food consumption in treated
group animals were  not  considered  to be compound related.  All organ weight
values were considered  to be within normal ranges and no trends were
established.

Palpable masses were found primarily in male mice (all groups)  and were
considered to be associated  with bacterial infection of the preputial gland.
Primary compound associated  tissue alterations were confined to the liver in
all treated mice.   The  main  hepatocellular reaction -was a histomorphological
alteration compatible with that  observed in enzyme induction.  Changes were
more oauiicn in  treated  mice  than in controls and were generally observed in a
dose-dependent  fashion.  Secondary pathological changes associated with the
compound were reflected by an  increased incidence and severity of amyloidosis


                                      7-14

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in high dose mice when  compared  to controls.  Liver and kidneys fron  low  and
mid-dose mice had incidence  rates  much lower than the controls.  Other  tissue
findings, including benign and malignant neoplasms, were randomly distributed
among the mice at all dose levels.

The 1979 chronic feeding  study discussed above (Litton Bionetics, 1979, 0171)
will supplement Agency  requirements for oncogenic testing in rats, provided
that compound purity is submitted.  The study reported no significant
differences in either neoplastic or nori-neoplastic lesions between control and
test animals fed chloramben  at concentrations of 100, 1,000, and 10,000 ppm
(MTD level approximately  30,000 ppm).   Neoplastic lesions were predominantly
benign and occurred for the  most part  in the pituitary gland (chromophobe
adenoma), adrenal gland (cortical  adenoma),  testes (interstitial cell tumor)
and mammary gland (carcinoma and fibroadenoma).   Spontaneous lesions of note
included telangiectasis in the adrenal cortex (46 percent of these animals also
exhibited cortical adenomas) , degenerative cardiomyopathy, chronic inflammation
of the kidneys, murine  pneumonia and galactostasis and galactocele.

Mo further testing is required.

Teratology

The minimum requirement for  evaluating a pesticide for teratogenicity is
testing in two mammalian species.   It  is required for both food and nonfood
uses of chloramben.  No tests are  available  on chloramben to assess
teratogeniceffects.  Therefore, tests  on two mammalian species  utilizing either
sodium chloramben or technical chloramben (3-amino 2,5-dichloro benzoic acid)
must be submitted.

Reproduction

The minimum requirement for  measuring  effects on reproduction is one test using
the technical chemical  in the rat,  lasting two generations.   This  is required
for all food uses.

Technical chloramben (unspecified  purity) fed to CFE  rats at doses  of 500,
1,500 and 4,500 ppn resulted in a  decrease in weight  gain (at the  25th week)
between the FQ and F^  generations  (AME  Associates, 1966,  0029).   Controls
did not exhibit a change in  weight gain  over the three filial generations.  In
addition, at these dosages,  there  was  also a dose-dependent  trend  in decreased
fertility index (3 generations) and lactation index  (2 generations).
Provisionally, the study does not meet Agency requirements for  a reproduction
test.  It will be judged for adequacy  when the detailed  composition of the test
chemical is provided.
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Mutagenicity

The- following studies represent  the  minimum requirements for data on the
potential heritable effects of chloramben.

1.  A mammalian  in vitro 'point mutation test.
2.  A sensitive  sub-mammalian point  nutation test (Bacteria, fungi, insect).
3.  A primary ENA damage test  (i.e., sister chromatid exchange or unscheduled
    DMA synthesis.
4.  A mannalian  in vitro cytogenetics test.  If this 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.

A sub-mammalian  point mutation test  (Anderson  et al., 1972, 0502) using
technical chloramben  (90-99 percent  purity)  does not fulfill Agency
requirements due to the absence  of a metabolic activation system and is
considered supplemental.

Study results indicated that  "Amiben" was not  mutagenic to histidine-requiring
mutants of Salmonella typhimurium, did not  result in chemically induced
mutations of the rll type  in T,  bacteriophage  and did not result in
reversions to the wild  type in AP72  and N17 rll mutants T4 bacteriophage.

A sub-mammalian  point mutation test  is still required, as well as tests
designed to meet requirements  1, 3 and 4 as noted above.

Metablism in Laboratory Animals

A general metabolism study on  chloramben must  be carried out to fulfill Agency
requirements.

A subchronic feeding study in  dogs provides supplemental information on
chloramben metabolism  (Hazleton  Laboratories,  1967, 0086).  Residues were
measured in tissues and excreta  of dogs fed chloramben for 28 days as a working
mixture of 999 parts lactose and one part Amiben (0.1 percent) prepared on a
weight/weight basis.  Samples  of liver, kidney, muscle, fat, and blood from
control and high-dose  (20  ppm) animals were analyzed by gas chrcmatography.
Residues in liver, kidney, blood, muscle, and  fat were less than 0.02 ppm
chloramben for both controls and high-dose  animals.  Chloramben residues in the
urine and feces  were 0.43  and  0.086  ppm, respectively, in the high-dose animals
as opposed to the 0.02  ppm in  the controls.

This study does  not adequately investigate  mammalian metabolism of chloramben
and will not be  considered to  fulfill Agency requirements.  A valid metabolism
studv must be submitted.
                                      7-16

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Clinical Trials

No clinical studies  in  humans  have  been conducted using chloramben.  None are
presently required by Agency Guidelines.

Emergency Treatment

No information is available on the  prevention and treatment of chloramben
intoxication.

b. Methyl Chloramben

The following topical discussions describe  available toxicity data on the
methyl ester of chloramben and  state whether they are adequate for Agency
regulatory purposes.  With the  exception of a metabolism study, subchronic and
chronic tests required  for'a food-use  registration of manufacturing-use methyl
chloramben may be satisfied by testing on sodium chloramben or technical
chloramben provided that evidence is submitted documenting the breakdown of the
methyl ester to chloramben after application to the soil.  Refer to Section
B.4.a for topical discussions of chronic and subchronic tests performed with
manufacturing-use sodium chloramben.

Acute Oral-Toxicity

The minimum testing needed on acute oral toxicity is one test, in the
laboratory rat, on the  technical chemical and  on the manufacturing-use product
if different.

The technical methyl ester of chloramben administered to male rats as a 30
percent weight/volume suspension in corn oil resulted in an LD5Q value of
1,710 mg/kg (Hazleton Laboratories, 1966, 0024).   Confidence limits were 1260-
2330 mg/kg.  Principal  toxic effects included  depression, gasping, labored
respiration, ataxia, sprawling of limbs, depressed  righting and placement!
reflexes, muscular stiffness, and death  (the latter at doses of 2, 150,  4, 640
and 10,000 mg/kg).  Major necropsy findings  included  congestion of the lungs,
liver, kidneys, and pancreas; pale-appearing spleen and gastorintestinal
inflammation.  These results place manufacturing-use  methyl chloramben in
Toxicity Category III for acute oral toxicity.

This study will satisfy Agency requirements  for an  acute oral toxicity
determination in rats following receipt  of product  purity.

Acute Dermal Toxicity

The minimum testing needed on acute dermal toxicity is one  test, preferably in
the albino rabbit, on each manufacturing-use product.

No tests on the technical methyl ester of chloramben  are available.  Testing  on
acute dermal toxicity must be submitted.
                                     7-17

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Primary Eye Irritation

The minimum testing needed  to  evaluate  eye irritation potential is one test, in
albino rabbits, on each manufacturing use  product.   If the test substance has a
pH of 1-3 or 12-14, however, it  will be judged corrosive, and an eye irritation
test is not needed.   If the test substance has been judged to be dermally
corrosive, an eye irritation test is not needed.

No eye irritation testing has  been performed with methyl chloramben.  Such
testing must be submitted.

Primary Dermal Irritation

The minimum testing method  to  evaluate  dermal irritation potential is one test/
preferably in the albino rabbit, on each manufacturing-use product.

No testing is available on  the methyl ester of chloramben.  Results of such
testing must therefore be submitted.

Skin Sensitization

The minimum requirement for assessing skin sensitization is an intradermal test
in one mammalian species, preferably  the guinea pig, on each manufacturing-use
product.

No skin sensitization test  is  available on methyl chloramben.  Testing is
therefore required.

Acute Delayed Neurotoxicity

An acute delayed neurotoxicity evaluation  is not required because methyl
chloramben is not expected  to  cause acetylcholinesterase depresssion, nor is
its chemical structure  related to that  of  substances that induce delayed
neurotoxicity.

Metabolism in Laboratory Animals

A general metabolism study  on  methyl  chloramben must be carried out to fulfill
Agency  requirements.

No tests are available on  the  metabolism of methyl chloramben.  A metabolic
study of manufacturing-use  methyl chloramben is required in order to determine
its fate  in  the  body and potential metabolites.  Data on plasma elimination
must be included.   Such  information is  necessary to assess applicator exposure
risk.

Clinitoal Trials

No clinical  studies in humans  have been conducted using methyl chloramben.
None are currently  required under Agency Guidelines.


                                  7-18

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Emergency Treatment

No information is available on the prevention  and  treatment of methyl
chloramben intoxication.

    5.   Required Labeling

Precautionary labeling of each product must correspond  to the toxicity
categories determined by five acute toxicity tests.  Acceptable categories of
acute toxicity and the corresponding required  labeling  are discussed in the
Agency Position Chapter of this Standard.
                                     7-19

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C.  Chloramben End—Use Formulations

    1.  Soluble Concentrate Chloramben

       a.  Toxicology Profile

Existing soluble concentrate chloramben end-use products (registration numbers
264-138, 264-178, 2749-202, and  264-266)  contain either ammonium chloramben
(23.4%) or a combination of ammonium chloramben (15.7%) and monomethylammonium
chloramben (47.2%).

For purposes of -chronic and subchronic toxicity testing, the Agency has
determined that ammonium chloramben  and monomethylammonium chloramben are
equivalent to technical chloramben.   Subchronic and chronic testing is not
required on the ammonium or monomethylammonium salts.

The Agency has determined  that technical chloramben acid and sodium chloramben
are equivalent to ammonium and moncmethyl ammonium chloramben for purposes of
subchronic and chronic toxicity  testing.

Available acute toxicity testing on  ammonium and moncmethyl ammonium chloramben
indicate that that these salts appear to be 3 to 4 times as acutely toxic as
chloramben acid.  Therefore, acute oral and dermal toxicity testing on
technical grade ammonium and moncmethyl ammonium chloramben are required.
Acute  testing of end-use products is also required.

Available acutetoxicity data submitted on a soluble concentrate end-use
ammonium salt formulation  indicates  an acute oral LD-Q value of 7.94 ml/kg or
7,940  mg/kg (assuming a density  of 1.0 g/ml) in male albino rats.

Acute  toxicity  testing submitted on  a combination of ammonium chloramben
(10.87%) and monomethylammonium  chloramben (34.5%) indicates an acute oral
LDe0 value of 3.5 ml/kg or 3,500 mg/kg (assuming a density of 1.0 g/ml) in
male albino rats.

A dermal LD-g value  of 8 ml/kg or 8,000 mgAg (assuming a density of 1.0
g/ral)  in male albino rabbits was reported for this same combination of ammonium
chloramben and monomethylammonium chloramben.  This product resulted in slight
conjunctival involvement at 24 hrs.  following a 0.1 ml aliquot administration
in male albino  rabbits.

    b. Data Requirements  and  Data Gaps

The Agency has  determined  that existing soluble concentrate end-use products
containing ammonium  chloramben as the sole active ingredient are substantially
similar to one  another  for the purposes of acute toxicity testing.  Data gaps
identified for  acute testing of  such soluble concentrate products may be
fulfilled through  the submission of  tests on an end-use soluble concentrate
product containing 23.4% ammonium chloramben.
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Acute toxicity tests have been submitted on a chloramben soluble concentrate
formulation containing 10.8% ammonium salt and 34.5% moncmethylammonium salt.
The percents of active ingredient as stated do not correspond  with any of the
registered formulated products containing this mixture.   A decision to accept
this product as representative of formulations containing these salts awaits
submission of further information regarding inerts in  the test substance.

Data Gaps
Generic Data
     Category of Test

     Acute Oral
     Acute Dermal
 Data Requirements

An acute oral toxicity  test
in the rat is required  on
technical grade anmonium and
monomethyl ammonium chloramben

An acute dermal toxicity test
in the rat is required  on
technical grade anmonium and
monomethyl ammonium chloramben
Guideline Number
   163.81-1
   163.81-2
 Product Specific Data

    Category of Test

    Acute Oral
    Acute Dermal
Data Requirements

Test material composition
and density most be submitted
on the anmonium salt and anmonium
(10.8%)/moncmethylammonium
(34.5%) salt soluble concentrates.

An acute dermal toxicity
study, preferably in the
albino rabbit, is required for an
end-use soluble concentrate
product containing 23.4% ammonium
chloramben.  Product data on the
anrncTiiumAcnomethylaninonium
chlorambenm test substance must be
submitted.
Guideline Number

   163.81-1
   163.81-2
                                     7-21

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Primary Eye
 Irritation
Primary Dermal
 Irritation
    Acute Inhalation    An acute inhalation study in             163.81-3
                        the rat is required for an
                        end-use soluble concentrate
                        containing 23.4% ammonium
                        chloramben and an end-use soluble
                        concentrate containing 15.7%
                        ammonium chloramben and 47.2%
                        monomethylammonium chloramben.

                        A primary eye irritation test            163.81-4
                        in the albino rabbit is required
                        for a representative 23.4%
                        ammonium chloramben product unless
                        it has a pH of either 1-3 or 12-14
                        or unless it has been judged dermally
                        corrosive.  If so, it will be
                        regulated as a corrosive substance.
                        Product data on the amroonium/monomethyl-
                        ammonium chloramben test substance must
                        be submitted.

                        A primary dermal irritation              163.81-5
                        test, preferably in the albino
                        rabbit, is required for an end-use
                        soluble concentrate containing 23.4%
                        ammonium chloramben.  Product data
                        on the ammonium/monomethylammonium
                        test substance must be submitted.

         c.   Topical Discussions: Soluble Concentrate Products

Acute Oral Toxicity

The minium testing needed on acute oral toxicity is one test in  the  laboratory
rat on each soluble concentrate end-use product.

The acute oral LD-- of an ammonium salt formulation of chloramben
(unspecified concentration) was determined to be 7.94 ml/kg or 7940 mgAgr
assuming a density of 1.0 g/fal (Hazleton Laboratories, 1966, 0024).  Confidence
limits were 5.84 to 10.8 ml/kg.  Principal toxic effects following
administration of doses up to 21.5 ml/kg in male albino rats included
depression, gasping, labored respiration, ataxia, sprawling of the limbs,
depressed righting and placement reflexes, muscular stiffness and death (the
latter at 10.0 and 21.5 ml/kg).  Compound related necropsy findings  included
congestion of the lungs, kidneys, adrenal, and pancreas; pale appearing spleen;
and inflammation of the diaphragm, peritoneum, and pyloric portion of the
stomach.  Based on these results, the product is placed in Toxicity Category IV.
                                 7-22

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This study will be considered an- adequate  determination of oral toxicity of an
ammonium chloramben  formulated  product in  male and female rats following
identification of the specific  test  product,  including product density.

The acute oral LD-Q of  the  formulated  ammonium (10.8 percent)/monomethy1-
ammonium (34.5 percent) product administered  to male albino rats is 3.5 mlAg
or 3,500 ing/kg assuming a density of 1.0 g/ml (Biosearch Inc., 1969, 0001).
Confidence limits were  calculated at 2.4 to 5.2 mlAg.  Animal mortality
occurred at least two hours following  dosing  and was preceded  by weaJcness and
lassitude.  Data submitted  separately  indicate that the 3.5 mlAg value
corresponds to 1,900 mgAg  of salt and 1,680  mgAg of acid.  The high LDc0
value places the compound in Toxicity  Category III, indicating a low acute oral
hazard.  This study will be considered sufficient for testing  the acute oral
toxicity of the formulation in  rats  if evidence is submitted showing that the
test material is representative of the registered ammonium/monomethylammonium
compound.  Product density must also be submitted.

Acute Dermal Toxicity

The minimum testing needed  on acute  dermal toxicity is one test, preferably in
the albino rabbit, on each  soluble concentrate end-use product.

No studies on the acute dermal  toxicity of soluble concentrate end-use products
containing 23.4% ammonium chloramben have  been submitted.

A soluble concentrate end-use product  containing 10.8% ammonium chloramben and
34.5% moncmethylammonium chloramben  has been  tested on the intact and abraded
skin of male albino rabbits at  levels  up to 8 mlAg or 8,000 mgAg> assuming on
a density of 1.0 g/ml (Biosearch, Inc., 1969, 0002).   There was no evidence of
skin irritation at any  time.  Given  the very  high LD5Q value a Toxicity
Category IV designation is appropriate.  This study will be judged for adequacy
as an acute dermal determination for the registered ammonium chloramben/
monomethyl ammonium chloramben  soluble concentrate product following submission
of composition and density of the test material.

Acute Inhalation Toxicity

An acute inhalation toxicity test is required on a soluble concentrate
formulation if it causes a respirable  vapor.-  or if 20% or  more of the
aerodynamic equivalent  is composed of  particles not larger than 10 microns.  No
vapor pressure data are available on chloramben products.   Until  data are
submitted which indicate otherwise,  a  test will be needed  on each
representative chloramben soluble concentrate formulation.

Primary Eye Irritation

The minimum testing needed  to evaluate eye irritation protential  is one test,
in albino rabbits, on each soluble concentrate product.  If the test substance
has a pfi of 1-3 or 12-14, however, it  will be judged  corrosive, and an eye
                                     7-23

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irritation test is not needed.  If  the  test substance has been judged dermally
corrosive, the test substance will  be judged to be corrosive to the eye and an
eye irritation test is not needed.

No studies on primary eye irritation have  been submitted on a soluble
concentrate product containing  23.4% ammonium chloramben.  Such testing must be
submitted.

A soluble concentrate product containing 10.8% ammonium/34.5% methylammonium
chloramben was not considered to be an  ocular irritant based on a 0.1 ml
aliquot adminstered in male  albino  rabbits (Biosearch, Inc., 1969, 0003).
Slight conjunctiva! involvement was noted  at 24 hours but was negative at 48
hours.  No other signs of eye irritation were noted throughout the 14-day
observation period.  The study  is adequate to place this formulated product in
Toxicity  Category III, indicating a low eye irritation potential.  In order to
satisfy Agency requirements  for testing of the ammonium/monomethylammonium
chloramben soluble concentrate, product composition of the test material cited
above must be submitted.

Primary Dermal Irritation

The minimum testing needed to evaluate  dermal irritation potential is one test,
preferably in the albino rabbit, on each soluble concentrate end-use product.

Testing on soluble concentrate  formulations containing ammonium chloramben is
not available and must therefore be submitted.

The previously cited study of dermal  toxicity of a 10.8% ammonium/34.5% methyl-
ammonium  chloramben product  (Biosearch  Inc., 1969, 0002) will be judged for
adequacy  as a dermal irritation test of the registered ammonium/monanethyl-
ammonium  chloramben soluble  concentrate product following submission of test
material  composition.  No evidence  of skin irritation was noted after
application of the test material to either the intact or abraded skin of male
albino rabbits.

Skin Sensitization

A dermal  sensitization study is not required because use of the formulated
product will not result in repeated human  skin contact.
                                      7-24

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    2.  Flowable Concentrate Chloramben

        a.  Toxicology Profile

Two flowable concentrate end-use  products,  containing 83.0% sodium chloramben
(registration number 264-305) and 21.0% sodium chloramben (registration number
264-306), respectively, are currently registered.   The Agency has determined
that acute toxicity tests submitted on manufacturing-use sodium chloramben
and/or chloramben  (3-amino-2,5-dichlorobenzoic acid)  may be used to fulfill
acute toxicity testing requirements on these  flowable concentrates.  Refer to
the Toxicology Profile and Topical Discussions on  manufacturing-use sodium
chloramben for a summary of existing  toxicolcgical data on either sodium
chloramben or chloramben.

         b. Data Requirements and Data Gaps

None identified for flowable concentrates containing  sodium chloramben.

         c.  Topical Discussions

Acute Oral Toxicity

The minimum testing needed on acute oral toxicity  is  one test in the laboratory
rat on each formulated flowable concentrate product.

No tests on flowable concentrate  formulations  containing sodium chloramben are
available.  Acute toxicity testing on  technical chloramben will fulfill test
requirements on the flowable concentrate formulations.   Refer to Section
B.4.a. (Topical Discussions - Sodium Chloramben).

Acute Dermal Toxicity

The minimum testing needed on acute dermal  toxicity is  one test, preferably in
the albino rabbit, on each formulated  flowable concentrate end-use  product.

No acute dermal tests are available on flowable concentrate chloramben.  A
dermal LD-. test on sodium chloramben  meets Agency requirements. Refer to
Section B.4.a.  No further testing is  required.

Acute Inhalation Toxicity

An acute inhalation toxicity test is required on a flowable concentrate
formulation if it causes a respirable  vapor, or if 20%  or  more  of the
aerodynamic equivalent is composed of  particles not larger than 10  microns.  No
vapor pressure information on a chloramben product is available. Until such
data are supplied, a test will be needed on flowable  concentrate chloramben.
                                     7-25

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No tests of acute  inhalation  toxicity are available on this formulation type.
However, available acute  inhalation testing with sodium chloramben (refer to
Section B.4.a) may be used  to fulfill this test requirement for flowable
concentrate end-use products.

Primary Eye Irritaiton

The minimum testing needed  to evaluate eye irritation potential is one test, in
albino rabbits, on each formulated  flowable concentrate end-use product.

Testing on flowable concentrate formulations containing sodium chloramben is
not available.  A dermal  irritation study using manufacturing-use sodium
chloramben will  fulfill Agency requirements for the flowable concentrate
formulations.  Refer  to Section B.4.a.

Skin Sensitization

Dermal  sensitization  testing is not required because use of these products are
not expected  to  result  in repeated  human skin contact.
                                      7-26

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     D.   Bnulsifiable  Concentrate Chloramben

         a.  Toxicology Profile

A  single end-use  product,  containing 23.2% methyl chloramben (registration
number  264-260),  is registered  in this category.

Acute toxicity  tests  have  been  conducted en a methyl chloramben emulsifiable
concentrate  (unspecified composition).  Based on an LD-^ determination of
5.01 ml/kg or 5,010 mg/kg  (assuming  a  density of 1.0 g7ml)  in male rats, a low
acute oral hazard is  expected.

Dermal  testing  of the formulated methyl chloramben product in rabbits at doses
up to 3.16 ml/kg  of body weight or 3,160 mg/kg (assuming a density of 1.0 g/ml)
did  not result  in animal mortality.  Gross signs of dermal irritation included
moderate  to marketed  erythema at all doses on both abraded  and  intact skin,
slight  to moderate edema,  and blanching.

Exposure  in male  and  female rats to  an aerosol of a formulated  methyl
chloramben product "at a concentration  of 2.0  mg/1 did not cause any animal
deaths.   Based  on a probable Toxicity  Category III designation, a low acute
inhalation hazard in  human beings is expected.

Acute eye irritation  was noted  after a single application of the formulated
methyl  chloramben end-use  products.  Irritation in unrinsed eyes consisted of
moderate or marked conjunctival  redness, chemosis, and discharge; slight or
moderate  corneal  opacity,  slight iritis, and  corneal vaacularization and
sloughing of epithelium.   Based  on these findings, the methyl chloramben end-
use compound can  be expected to represent an  eye irritation hazard in humans.

No further tests were  submitted  on an  emulsifiable concentrate  containing
methyl  chloramben.

    b.  Data Requirements  and Data Gaps

Provided  that evidence is  submitted  indicating that the  test substance
described above is equivalent to the emulsifiable  concentrate (23.2% methyl
chloramben) currently  registered, existing acute toxicity tests on the compound
will be acceptable.    The  density of the test substance  must also be
submitted.  The following data gaps remain.

Data Gaps

None identified for the currently registered  product.
                                     7-27

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         c.  Topical Discussions

Acute Oral Toxicitv

The minimum testing needed on  acute  oral  toxicity is one test in the laboratory
rat on the emulsifiable concentrate  end-use  product.

The LD5p value for the formulated methyl  chloramben emulsifiable concentrate
administered to rale albino rats is  5.01  ml/kg  or 5,010 mg/kg (assuming a
density of 1.0 g/taL) with confidence levels  from 5.84 to 10.8 ml/mg (Hazelton
Laboratories, Inc., 1966, 0024).  Toxic effects included depression, gasping,
labored respiration, ataxia, sprawling  of limbs, depressed righting and
placement reflexes, muscular stiffness, bloody  crust around eyes and nose,
salivation and excessive urination.   The  necropsy findings consisted of
congestion of the lungs, kidneys, adrenals,  and pancreas; pale-appearing
spleen? and inflammation of the diaphragm, peritoneum and pyloric portion of
the stomach.  This study will  be considered  to  fulfill Agency requirements for
acute oral toxicity testing in male  and female  rats following characterization
of the compound.

No further testing is required.

Acute Dermal Toxicity

The minimum testing needed on  acute  dermal toxicity is one test, preferably in
the albino rabbit, on the emulsifiable  concentrate end-use product.

Dermal .testing of the formulated methyl chloramben product in rabbits at doses
up to 3.16 ml/kg of body weight did  not result  in animal mortality (Hazleton
Laboratories, 1968, 0143).  Principal toxic  effects included slight depression
and labored respiration in the majority of animals.  One animal exhibited rapid
respiration and hyperactivity. Gross signs  of  dermal irritation consisted of
moderate to marked erythema at all doses  on  both abraded and intact skin,
slight to moderate edema and blanching.  Atonia and slight or moderate
desquamation developed predominantly in the  highest dose group during the
course of the study and were all still  present  on two animals at termination.
Assuming a density of 1.0 g/ml, the  LDe0  value  (>3,160 mgAg) is designated
Toxicity Category III-IV.  Information  chacterizing the test substance
(including product density) must be  submitted.

Acute Inhalation Toxicity

An acute inhalation toxicity test  is required on an emulsifiable concentrate
product if it causes a respirable vapor,  or  if  20% or more of the aerodynamic
equivalent is composed of particles  not larger  than 10 microns.  No vapor
pressure data are available on chloramben products.  Until such data are
supplied, a test will be needed on the  emulsifiable concentrate containing
mehtyl chloramben.
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 Exposure  in male  and  female  rats  to an aerosol of the methyl chloramben end-use
 product at a  concentration of 2.0 mq/1 of air did not cause any animal deaths
 (Hazleton Laboratories,  1968, 0144).  Toxic effects noted after initial
 exposure were restlessness,  inactivity, shallow breathing and puffy and glassy
 eyes.  Abnormalities  observed upon gross necroposies included red spots, brown
 spots, and clear  tan  spots in the lungs, massive consolidation in the lungs,
 dark kidney medulla and  discolored cervical glands.  Red spots, clear tan
 spots, and dark brown spots  were  noted in the lungs of control animals.  The
 study cannot  be considered to fulfill  Agency requirements for an acute
 inhalation toxicity determination until the product is completely characterized.

 Primary Eye Irritation

 The minimum testing needed to evaluate eye irritation potential is one test, in
 albino rabbits, on the emulsifiable concentrate end-use product.  If the test
 substance has a pH of 1-3  or, 12-14, however, it will be judged corrosive, and
 an eye irritation test is  not needed.   If the test substance has been judged to
 be dermally corrosive, it  will also be considered corrosive to the eye and an
 eye irritation test is not needed.

 Acute eye irritation  was noted in rabbits after a single application of 0.1 ml
 of the formulated methyl chloramben product (Hazleton Laboratories,  1968,
 0143).  Principal toxic  effects included blinking, preening and/or phonation
 immediately following  dosage.   Terminal weight loss was noted in  one animal.
 Irritation in nonirrigated eyes consisted of moderate or marked oonjunctival
 redness, chemosis and discharge;  slight or moderate corneal opacity (persisting
 in one case beyond 7 days);  slight iritis;  and  corneal vascularization and
 sloughing of  epithelium  (1 animal).  Slight conjunctival irritation  was
 observed in a few of  the rinsed eyes.   Based on these data, the compound  is
 placed in Toxicity Category'II.

 A complete characterization  of the test product must be provided before  this
 study can be considered  to fulfill Agency requirements.

 Primary Dermal Irritation

The minimum testing needed to  evaluate  dermal irritation potential is  one  test,
 preferably in the albino rabbit, on  the  formulated  emulsifiable concentrate.

 Dermal irritation effects were noted during  the acute dermal toxicity testing
of the emulsifiable concentrate product  (Hazleton  Laboratories, 1968,  0143).
Gross signs of dermal  irritation  consisted  of moderate to marked erythema  at
 all doses on both abraded and  intact skin,  slight  to moderate  edema  and
 blanching.  Atonia and slight  to moderate desquamation developed predominantly
 in the highest dose group during  the course of  the  study and were  still present
 in two animals at termination.  These data  indicate a slight dermal  irritation
 hazard based on a probable Toxicity Category  III designation.  No  further
 testing is required.
                                     7-29

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Skin Sensitization
                                                              *
Deraal sensitization testing  is not  required  because the use pattern indicates
that repeated human skin contact  is  unlikely  under conditions of use.
                                      7-30

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     4.  Granular
        a.  moxicity Profile

Seven qranular chlorarbon end-use  products  arp currently reaisteroH .  Five
products consist of either  1.3%, 4.3%, or 10.8% ammonium chloranben
"(registration numbers 264-167,  264-175,  264-191,  264-243, and 2749-169).  T\*D
products are a mix of ammonium  chloramben and  moncme thy 1 ammonium chloramben at
either a 5.4% and 17.3% level or 2.82% and  8.46%  level, respectively,
(registration numbers 264-251 and  264-274).

For purposes of chronic and subchronic toxicity testinq, the Agency has
determined that ammonium chloramben and  monanethylammonium chlorannen are
equivalent to technical chloramben acid.

Acute oral and dermal toxicity  testina is reauired on  technical  qrade ammonium
and moncmethyl ammonium chloramben in addition to testinq on end-use  products.

No tests are available to assess either  the acute toxicity or possible skin or
eye effects of granular chloramben end-use  formulations.  However,  the Agency
has determined that granular products containing  the ammonium salt  of
chloramben are substantially similar to  soluble concentrate products  containina
this salt.  Likewise, granular  products  containing a mixture of  the ammonium
and moncmethyl ammonium salts have been determined to be substantially similar
to soluble concentrate products containing  these  salts.   Data aaps  identified
for soluble concentrate products are directly  applicable to granular  products.

    b.  Data Requirements and Data Gaps

The Agency has determined that existing granular  end-use products containing
ammonium chloramben are substantially similar  to one another and to soluble
concentrate chloramben products containing this salt for the purposes of  acute
toxicity testing .  In "the same respect , granular end-use products containing a
mixture of ammonium chloramben and moncmethylammonium chloramben are  considered
to be substantially similar to each other and  to soluble concentrate  products
containing this salt.  Data gaps identified for acute toxicity testing of
soluble concentrate products apply also to granular chloramben products.  See
the Soluble Concentrate portion of this chapter for details.
                                     7-31

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    c.  Topical Discussions
Sere Topical Discussions for Soluble Concentrate  products.
                                      7-32

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                                  CHAPTER VIII

                        ECOLOGICAL EFFECTS OF CHLORAMBEN

A.  Introduction

In order to evaluate  the  ecological effects of chloramben, various toxicity
tests are required.   Depending on the  characteristics and uses of chloramben
end-use formulated products,  data requirements for wildlife and aquatic
organisms can be completely or primarily satisfied with tests for chloramben
manufacturing-use products.   However,  for some end-use formulations which
include active  ingredients different from those in the manufacturing-use
products, the technical grade of  each  active ingredient must be used in
toxicity testing.  Additional tests with end-use formulations can be required
if testing for  manufacturing-use  products is insufficient to make an adequate
hazard evaluation.  An evaluation of hazard to wildlife and aquatic organisms
requires the assessment of'risk to potentially affected non-target organisms,
taking into consideration the environmental chemistry and toxicological
characteristics of chloramben and its  end-use formulations.

The discussion  in this chapter relating  to the ecological effects of chloramben
is divided into two sections. In the  first section the manufacturing-use
products of chloramben are discussed with an ecological effects profile, a
review of data  requirements and gaps,  and a topical review of pertinent
studies.  In the second section,  the formulated end-use products of chloramben
are grouped into generic categories which are then also discussed with
ecological effects profiles,  reviews of  data requirements and gaps, and topical
reviews.  An additional feature of the second section is the application of
worst-case risk assessments where adequate toxicity data permit comparisons of
toxicity levels with  worst-case estimates of environmental concentration
levels.  These  risk assessments were incorporated  into the appropriate
ecological effects "profiles.

B.  Chloramben iManuf acturing-Use  Products

    1.   Ecological Effects Profile: Sodium and Methyl Chloramben

         a.   Sodium Chloramben

Currently available data indicate that manufacturing-use sodium chloramben is
of low acute toxicity to most terrestrial  wildlife.   A test employing the
Bobwhite Quail  and the Pekin  Duck found  dietary LCgn's to be greater than
3,160 ppm active ingredient for each species using a technical material
containing 97.2 percent sodium salts of  chloramben.  Another test, using the
Mallard Duck, found the dietary LC5Q to  exceed 4,650 ppm active ingredient
with a technical material containing 91.6  percent  sodium chloramben.   No avian
acute oral toxicity testing results  are  available  for sodium chloramben.   Tests
with rats and dogs indicate a lack of  acute dietary toxicity of technical
chloramben to levels of 10,000 ppm (see  Chapter VII).   In addition, the acute
oral LD50 for male rats was found to be  5,620 mgAg for technical chloramben.

Currently available data also indicate that manufacturing-use sodium chloramben
is of low toxicity to fish.   Acute  toxicity tests  with Bluegill Sunfish and
Rainbow Trout demonstrate 96-hour LC5Q's exceeding 1,000 mg/1 using a
technical material containing 91.6 percent sodium  chloramben.   Fish
accumulation tests (see Chapter V)  indicate that little potential exists for


                                       8-1

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significant bioaccumulation of  chloramben or the sodiun chloramben
T.anufacturing-use product.  >fo  studies  are available on the acute toxicity of
sodium chloramben to' aquatic  invertebrates.

         b.   Methyl Chloramben

Less data for toxicity  to wildlife  are  available for the methyl chloramben
manufacturing-use product than  for  the  sodium chloramben manufacturing-use
product.  One test employing  the  Bobwhite Quail and the Pekin Duck found
dietary ^^'s  to be greater  than 3,160 ppm active ingredient for the
technical methyl chloramben test  material (98.8% active ingredient).  No avian
oral toxicity testing results or  other  dietary data are available.  Only one
oral or dietary study on mammals  is available.  In this study the acute oral
LD_n to rats was found  to be  1,710  mgAg, indicating a greater toxicity for
thi methyl ester (see Chapter VII).

No studies have been submitted  detailing aquatic toxicity tests for the methyl
chloramben manufacturing-use  products.   However,- limited data based on a letter
and a memorandum, indicate that methyl  chloramben may be moderately to highly
toxic to aquatic organisms.   Reported results include a 96-hour LC.Q of 4 ppm
for a 20 percent material with  Bluegill and an indicated 24-hour l£cfl of
between 2 and 16 ppm for "amiben  ester" at 2 Ibs/gallon with the Fathead
Minnow.  The test material for  these reported results is assumed to have been
the methyl chloramben formulated  product (Registration No. 264-260).  No other
data is available for fish, invertebrates, or fish accumulation.

    2.   Data Requirements and  Data Gaps: Sodium and Methyl Chloramben

The following fish and  wildlife studies testing the effects of the technical
grades of sodium and methyl chloramben  are required for the registration of
chloramben manufacturing-use  products:

         Required Test                                      Guidelines Section

         Avian  Single-Cose Oral LD^                            163.71-1
         Avian  Dietary  LC-0 (2  tests)                            163.71-2
         Fish Acute LC5Q ?2 tests)                               163.72-1
         Acute  Toxicity to Aquatic  Invertebrates                163.72-2

         a.   Sodium Chloramben

Acceptable studies have been  submitted  for the Avian Dietary
Acute LC-0  tests.   Data gaps exist for the following required tests:

         Required  Test Data Gap                       Reason for Data Gap

         Avian  Single-Dose  Oral LD-Q                 Non-submission of study.
         Acute  Toxicity to  Aquatic Invertebrates      Non-submission of study.

Submission  of studies  to fill the  required test data is required for completion
of registration requirements for sodium chloramben manufacturing-use products.

         b.  Methyl Chloramben

There are no acceptable studies which have been submitted for the methyl
chloramben  manufacturing-use product  except for the avian dietary test with an


                                       8-2

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 upland game  species.   Therefore/ acceptable studies for all of  the  required
 tests  for  manufacturing-use products must be submitted for registration  of the
 methyl chloraraben  manufacturing-use products, except that the avian dietary
 test need  only provide data for the wild waterfowl species (preferably the
 Mallard Duck).

    3.   Topical Discussions:  Sodium and Methyl Chlorainben

         a.    Sodium Chloraraben

 Birds

 Birds may  be exposed to pesticides  by feeding on pesticide granules,
 contaminated plants, or insects, and by dermal contact and/or inhalation when
 close  to outdoor sprays and dust.  To assess the impact of a pesticide on
 birds, the Agency  requires  certain  avian toxicity tests to support  the
 registration of pesticides. For registration of every manufacturing-use
 product and  formulated product for  outdoor application, avian acute oral LD^g
 and avian dietary  EC-0 tests are required.  According to Proposed Guidelines
 Section 163.71-2,  the  avian dietary test should be conducted  with an upland
 game bird species  (preferably  the Bobwhite Quail)  and a wild  waterfowl species
 (preferably the Mallard Duck) .  The avian single-dose Oral LD5Q test is to be
 performed on one of the two species used in the avian dietary test  (Proposed
 Guidelines Section 163.71-1).

 An acceptable  study meeting the requirements of the guidelines has been
 submitted for a test with the  Mallard  Duck (Wildlife Int'l, 1978, 0059).   This
 study found a dietary  LC-0  in  excess of 5,620 ppm (5,150  ppm  active
 ingredient) for a  sodium chloramben test material  containing  an active
 ingredient level of 91.6% sodium chloramben.  No toxic symptoms or deaths are
 reported at test concentration levels  up to 5,620  ppm (5, 150 ppm active
 ingredient).  An additional  acceptable study (Affiliated  Medical Research,
 1973, 0036) found  dietary LC-0's in excess of 3,160 (3,070 ppm active
 ingredient) for both the Bobwnite Quail and Pekin  Duck.  The  test material in
 this study contained the sodium salt of chloramben (97.2  percent)  as the  active
 ingredients.  No acute oral  LD5Q  study has been submitted for sodium
 chloramben.

 Freshwater Fish

The minimum data required for  establishing the acute toxicity of manufacturing-
 use sodium chloramben  for fish are  determinations  of 96-hour  LCen's -  the
 fish acute LC5Q tests  (Proposed Guidelines Section 163.72-1).   Tne fish acute
I£-Q test is co be performed with a coldwater species  (preferably the  Rainbow
Trout)  and a warmwater species  (preferably the Bluegiil Sunfish) .

Acceptable studies meeting guidelines  requirements have been  submitted  for
 tests with both the coldwater  and warmwater fish species.  The study featuring
 the coldwater species  (Rainbow Trout)  demonstrated a 96-hour  LCeQ  in excess
of 1,000 mg/1  (916 mg/1  active  ingredient)  for the sodium  chloramben test
material containing an  active  ingredient  level  of  91.6  percent sodium
chloramben (Union Carbide, 1978,  0061).   No  mortalities were observed at  up to
 the 1,000 mg/1 concentration level  and  the 96-hour h^-observed-effect  level
 (NOEL)  was 100 mg/1 (91.6 mg/1 active  ingredient).  The study  featuring the
warmwater species  (Bluegiil Sunfish) demonstrated  a 96-hour LC-0  also  in
excess  of 1,000 mg/1 (916 mg/1 active  ingredient)  for  the  same3test  material


                                       8-3

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(Union Carbide, 1978, 0060).   In  this  test,  no mortalities were observed at up
to the 1,000 mg/1 concentration level  and  the 96-hour NOEL was 180 mg/1 (165
mg/1 active ingredient).

Aquatic Invertebrates

A determination of  the  48-hour EC50  for an aquatic invertebrate species is
required to support the registration of all manufacturing-use products and for
all formulated products intended  for outdoor application (Proposed Guidelines
Section 163.72-2).   Nb  study  on toxicity to aquatic invertebrates has been
submitted.

Other Organisms

Several other published reports on chloramben toxicity were reviewed, but
conclusions about levels of toxicity cannot be verified since the test material
was inadequately described.   These reports include the following studies.

Published literature reported low levels of toxicity of chloramben and
chloramben sodium salt  to  honeybees—low mortality and little effect on
reproduction  (Morton and Moffett, 1972, 0535; and Morton et al., 1972, 0536).
Another study reported  chloramben to be non-toxic to earthworms when injected
with 100 rogAg  (Chio and Sanborn, 1978, 0524).  A review article (Butler, 1977,
0549) indicates that toxic effects on  algae occur at concentrations of 15-3000
ppm, with chloramben and its  ammonium  salt less toxic than the methyl ester.

         b.   Methyl Chloramben

Birds

As discussed  in greater detail for the sodium chloramben manufacturing-use
product, to assess  the  potential  impact of a pesticide on birds, the Agency
requires certain avian  toxicity tests  to support the registration of
pesticides.  The avian  dietary LC_fl test should be conducted with an upland
game bird species  (preferably the Bobwhite Quail) and a wild waterfowl species
(preferably the Mallard Duck). The avian single-dose oral LC5Q test is to be
performed on one of the two species used in the avian dietary test.

A study  (Affiliated Medical Research/  1973, 0039), acceptable in meeting
guidelines requirements for testing on an upland game bird, found dietary
LC-0's in excess of 3,160  ppm methyl chloramben for both the Bobwhite Quail
ana Pekin Duck.  The level of active ingredient in the test material,
identified as Aniben Methyl Ester, was 98.8 percent.

Freshwater Fish

The minimum data required  for establishing the acute toxicity of manufacturing-
use methyl chloramben  for  fish are determinations of 96-hour LC~Q'S—the fish
acute LC-0 test (Proposed  Guidelines Section 163.72-1).  The fish acute
LC__ test:  is  to be  performed' with a coldwater species (preferably the Rainbow
TrSut) and a  warmwater  species (preferably the Bluegill Sunfish).

Amchem Products, Inc.  factory correspondence (Otten, 1970, 0146a) reports
testing  results on  Fathead Minnows showing that after 24 hours -all test fish
were alive at 2 pern and all were  dead  at 16 ppm.  The test material is
described as  Pmiben Ester  (2  Ib/gal active ingredient as methyl ester).  In


                                       8-4

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addition, a letter  (Hughes, 1970, 0146b)  reported  a 96-hour LCc0 of 4 pan for
a test material identified as Amiben Ester  (as  a 20 percent material).  The
test fish were Bluegill, and all fish were  killed  in 24  hours at 15 ppn.  These
reports are unacceptable in meeting guidelines  requirements because technical
materials were not  used and the data are  very limited.

Aquatic Invertebrates

A determination of  the 48-hour EC-0 or LC5Q  for an  aquatic  invertebrate
species is required to support the registration of  all manufacturing-use
products and for all formulated products  intended  for outdoor application
(Proposed Guidelines Section 163.72-2).   No  study on toxicity to aquatic
invertebrates has been submitted.

Other Organisms

An unverified review article (Butler, 1977,  0549) reported  that  toxic effects
on algae occur at concentrations of 15-3000  ppm, with the methyl ester more
toxic than chloramben or amnonium chloramben.
                                      3-5

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C.  Chloramben Formulated Products  (for  End-Use  Application)

    1.   Soluble Concentrates

Currently registered soluble concentrate chloramben products  include the
following listed products.

         Registration No.                              Active  Ingredients

         264-138                                       23.4% Ammonium Chloramben
         264-178                                       23.4% Ammonium Chloramben
         2749-202                                      23.4% Ammonium Chloramben
         264-266                                       15.7% Ammonium Chloramben
                                                       and 47.2% Monomethyl-
                                                       ammonium Chloramben
         a.   Ecological Effects Profile  and  Risk Assessment:
              Soluble Concentrates
Profile
The data previously described  for the  chloramben manufacturing-use products are
not directly applicable to the  toxicity and  hazard  evaluation of soluble
concentrate products since these  products  contain ammonium chloramben and
moncmethyl ammonium chloramben  as active ingredients.   No studies have been
submitted on tests using technical grades  of these  two active ingredients.

However, some test data on ammonium  chloramben  formulations (containing 23.4
percent active  ingredient) serve  to  indicate low toxicity to wildlife and
fish.  In an avian dietary test with the Mallard Duck, an LOg of greater
than 4,650 ppm  (1,090 ppm active  ingredient)  was found for a test material
containing 23.4 percent ammonium  salts of  chloramben and related
aminodichlorobenzoic acids.  In an avian acute  oral toxicity test with the
Bobwhite Quail, an LDc0 of 7.7  ml/kg was found  for  the same test material.
Very brief fish acute coxicity testing reports  indicate, in one test, a 24-hour
LCSO greater than 50 ppm with  the Fathead  Minnow and another test a 96-hour
LC_Q greater than 250 ppm with  Bluegill Sunfish.

In a preliminary report on testing with a  test  material containing 10.8
percentammonium chloramben and  34.5  percent  moncmethyl ammonium chloramben, 96-
hour LCen's greater than 1000 ppm, 1000 ppm, and 750 ppm for Fathead Minnow,
Bluegill Sunfish, and Rainbow  Trout, respectively,  are reported.

Risk Assessment

Only one study  on the toxicity of one  of the active ingredients -in the soluble
concentrates is of sufficient quality  for  use in risk analysis.  A dietary
LC-0 and a no-observed-effects  level (NOEL)  of  over 1090 ppm active
ingredient in the Mallard Duck was found.  Assuming a maximum broadcast
application rate of 4.0 Ib.  active ingredient per acre (EPA's Use Pattern
Summary Report  for Chloramben)  an environmental concentration is estimated
for short rangegrass application  as  a  hypothetical  worst-case for residues on
vegetation.  The following table  portrays  the vorst-case risk analysis which
applies to the  soluble concentrates  containing  only ammonium chloramben as the
active ingredient:
                                       8-6

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Environmental    Worst-Case     Toxicity (pan)    No Effect Ratio  Hazard Patio
                 Residue       VDEL     L£5r       (Residue/       (Residue/
Feature/         Cone,  (ppm)  active  ingredient       NOEL)          —5&1
Species

Short Range Grass  960
  Mallard Duck                >1090     >1090        <0.38             <0.38

Since the No-Effect Ratio and Hazard  Ratio which  were calculated are less than
one, the ammonium chloramben soluble  concentrate  does not pose a likely
significant risk of acute toxicity to waterfowl at current application rates.

         b.   Data Requirements and Data Gaps:  Soluble Concentrates

The following fish and wildlife studies testing the effects of technical grade
ammonium chloramben and technical grade monomethyl ammonium chloramben are
required as a minimum for the registration of chloramben formulated products
containing these salts:

         Required Test                                      Guidelines Section

         Avian Single-Dose Oral LD-n                             163.71-1
         Avian Dietary LC5Q (2 tests)                            163.71-2
         Fish Acute LC5Q T2 tests)                               163.72-1
        .Acute Toxicity to Aquatic Invertebrates                 163.72-2

In addition to the above-listed minimum testing requirements,  additional tests
can be required for registration of formulated  products depending on the use
pattern/ mobility, persistence, toxicity, bioaccumulation, and other
characteristics of the formulated product or its  active ingredients.  One or
more of the following tests could be  required;  the criteria used for
requirement determination are listed  in the designated section of the Proposed
Guidelines of July 10, 1978:

Potentially Required Test                                   Guidelines Section

Mammalian Acute Toxicity                                         163.71-3

Avian Reproduction                                               163.71-4

Simulated and Actual Field Testing
  for Mammals and Birds                                          163.71-5

Acute Toxicity to Estuarine and
  Marine Organisms                                               163.72-3

Sonbryolarvae and Life-Cycle Studies of
  Fish and Aquatic Invertebrates                                 163.72-4

Aquatic Organism Toxicity and Residue Studies                    163.72-5

Simulated or Actual Field Testing for Aquatic Organisms         163.72-6

Depending on certain conditions (see Guidelines Sections 163.72-1 and 163.72-
2), the Fish Acute LC-- and the Acute Toxicity  to Aquatic Invertebrates tests
could require the testing of the formulated product as well as the technical


                                      S-7

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grade of the active chloramben  ingredient for the registration of the
respective formulated  product.

For soluble concentrate  products  containing only ammonium chloramben, data gaps
exist for every one of the  six  minimum required tests.  For each of these
tests, the technical grade  -of the ammonium chloramben active ingredient is to
be used as the test material.  Submission of these required tests is required
for registration of these -products.

For soluble concentrate  products  containing monomethyl ammonium chloramben as
an active ingredient,  additional  data gaps exist for every one of the six
minimum required tests of  this  additional active ingredient.  For each of these
additional tests,  the  technical grade of the mononethyl ammonium chloramben
active ingredient  is to  be  used as the test material.  Submission of these
required tests is  necessary for registration of this product.

Due to insufficient product chemistry, environmental fate/ and toxicity
information, the need  for any of  the additional potentially required tests
which have been listed cannot be  determined.  Following submission of studies
covering the minimum registration requirements, the Agency will determine if
any of the potentially required tests are necessary.

         c.   Topical  Discussions: Soluble Concentrates

Birds

As discussed in greater  detail  for the sodium chloramben manufacturing-use
product, to assess the potential  impact of a pesticide on birds, the Agency
requires at a minimum  certain avian toxicity tests to support the registration
of pesticides.  The avian dietary LCeg test should be conducted with an
upland game bird species (preferably the Bobwhite Quail) and a wild waterfowl
species  (preferably the  Mallard Duck).  The avian single-dose oral LD^Q test
is to be performed on  one of the  two species used in the avian dietary test.
These tests are to be  performed using the technical grade of each active
ingredient.

No studies have been submitted  which are acceptable in meeting these minimum
requirements for registration.   However, supplemental testing data (which is,
however, unacceptable  in meeting  minimum registration requirements) is
available  for birds.   In a good avian dietary LC-- test on the Mallard Duck
with an ammonium chloramben formulation (Registration No. 264-138), an NOEL and
an LCe0 of greater than  4,650 ppm (1990 ppm active ingredient) were found
(Truslow Farms, 1974,  0049).  An  avian single-dose oral LD,0 study found an
LD_n of 7.1 ml/kg  in testing on Bobwhite Quail with the same test material
(GaJsriel, 1969; ID Mo. 0145).  The latter study is of limited value because
only five male birds were  tested  per level .and little test data were reported.

Freshwater Fish

Several unpublished reports on chloramben toxicity to fish were reviewed, but
conclusions about  toxicity cannot be verified, because the test procedures and
test material  identity were unavailable.

Amchem Products, Inc.  factory correspondence (Otten, 1970, 0146a) indicates a
24-hour LC.Q exceeding 50  ppm for a soluble concentrate product (2 Ib/gal
active ingredient  as chloramben ammonium salt) using Fathead Minnows.  In
addition, a letter (Hughes, 1970, 0146b) indicates a 96-hour LCSO in excess

                                       8-8

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of 250 pan for "Amiben" (composition unspecified) using Bluegill Sunfish.  A
preliminary report (Bionomics, 1970, 0051) indicates 96-hour LQjnS exceeding
1,000 ppm, 1,000 ppm, and 750 ppm for the Fathead Minnow, Bluegill Sunfish, and
Rainbow Trout, respectively.  The test material, "Amiben Concentrate,"
contained lO.Spercent ammonium chloramben and 34.5 percent and mononethyl
ammonium chloramben.
                                     8-9

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    2.   Flowable Concentrates

Currently registered  flowable concentrate  chloramben products include the
following listed formulated products:

         Registration No.                              Active Ingredients

         264-305                                       83.0% Sodium Chloramben
         264-306                                       21.0% Sodium Chloranben

         a.   Ecological Effects  Profile and Risk Assessment:
              Flowable Concentrates

Profile

Since the active ingredient  in  flowable concentrate chloraraben products is
sodium chloramben,  the toxicity to wild organisms for both may be estimated
from tests for manufacturing-use  sodium chloramben (see the Ecological Effects
Profile for sodium  chloramben manufacturing-use product).

Risk Assessment

In the following vorst-case  assessment of  risk to wildlife and aquatic
organisms for both  flowable  concentrates,  values for maximum hypothetical
environmental concentrations of the  active ingredient of the flowable
concentrate products  are compared with the toxicity data for various tested
species.  Assuming  a  maximum broadcast application rate of 4.0 Ib/acre (EPA's
Use Pattern Summary Report for  Chloramben), environmental concentrations are
estimated for direct  application  to  water, for field runoff water, and for
short range grass  (as hypothetical worst-case situations for residues of the
flowable concentrate  products).  The No Observed Effects Levels (NOEL'S) and
LC   's for various  fish and  wildlife are  taken from valid studies described
previously for  the  sodium  chloramben manufacturing-use product.  The following
table portrays  the  worst-case risk analysis which applies to both the flowable
concentrate products:
                                      3-10

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Environmental  Worst-Case   Toxicity (pom)     No Effect Ratio  Hazard  Ratio
Feature/        Residue                           (Residue/
Species        Cone,  (pom)   NOEL(ai)  LC5Q(ai)    NOEL)

Water Receiving
Direct Application*
    Bluegill
     Sunfish       2.94        165      >916       0.018               <0.0032
    Rainbow
     Trout         2.94        91.6      >916       0.032               <0.0032

Runoff Water**
    Bluegill
     Sunfish       1.77        165      >916       0.011               <0.0019
    Rainbow
     Trout         1.77        91.6      >916       0.019               <0.0019

Short Range Grass
    Mallard Duck   960         >5150     >5150       <0.19               <0.19
    Bobwhite
     Quail         960         N.A.      >3070        N.A.               <0.31
N.A. = Not available.
*    = Assumes ccraplete mixing  in a six  inch  layer of standing water.
**   = Assumes 10% of application in one  inch of  runoff water.

Since the No-Effect Ratios and Hazard Ratios  which were calculated are
substantially less than one, sodium chlcramben  flowable concentrates do not
pose a likely significant risk of acute  toxicity  to fish or birds at current
application rates of 4 pounds active ingredient per acre.  Based on
toxicological testing with manuals (see Chapter VII), the hazard to mammals is
also judged to be insignificant.  There are no  data available to evaluate the
hazard to aquatic invertebrates.  Data described  in Chapter V for chloramben
(acid form) indicate little potential for significant bioaccumulation in fish.

         b.   Data Requirements and Data Gaps:  Flowable Concentrates

The minimum required tests and potentially required  tests for registration of
flowable concentrates are the same as for all formulated pesticide products and
have been discussed already for the soluble concentrates.  Since flowable
concentrate products contain only sodium chloramben as active ingredient, tests
submitted and described for the sodium chloramben manufacturing-use product
also serve to fulfill the minimum testing requirements for flowable
concentrates.

Therefore, the data gaps in the minimum testing requirements for flowable
concentrates containing sodium chloramben are the same as for the sodium
chloramben manufacturing-use product:

         Required Test Data Gap                        Reason for Data Gap

         Avian Single-Dose Oral ID.Q                Non-submission of study.
         Acute Toxicity to Aquatic invertebrates       Non-submission of study.


                                     8-11

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Submission of tests to fill  in  these  data  gaps  is required for registration of
the flowable concentrate products.  IXie  to insufficient product chemistry,
environmental fate,, and toxicity  information,  the need for any of the
additional potentially required tests cannot be determined.  Following
submission of studies covering  the minimum registration requirements, the
Agency will determine if any of the potentially required tests are necessary.

         c.   Topical Discussions: Flowable Concentrates

See the Topical Discussions  section  for  the sodium chloramben manufacturing-use
product for topical discussions relevant to the flowable concentrate products.
No studies have been submitted  for the flowable concentrate products per se.
                                      8-12

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    3.    Emulsifiable Concentrate

The currently registered emulsifiable concentrate chloramben product  is  the
following formulated  product:

          Registration No.                             Active Ingredients

          264-260                                       23.2% Methyl Chloramben
         a.    Ecological  Effects  Profile and Risk Assessment:
               Emulsifiable  Concentrates
Profile
Since the active  ingredient  in the  chloramben emulsifiable concentrate product
is methyl chloramben,  the  tpxicity  to  wild  organisms may be estimated from
tests for the manufacturing-use methyl chlorainben (see the Ecological Effects
Profile for methyl chloramben  manufacturing-use product).

Risk Assessment

With the exception of  the  dietary data on an avian upland game species,
Bobwhite Quail, no data were available on the toxicity of methyl chloramben for
a risk assessment.  In the following worst-case assessment of risk to wildlife,
for the emulsifiable concentrate, the  value for maximum hypothetical
environmental concentrations of the active  ingredient of the emulsifiable
concentrate product is compared with the  toxicity for the avian upland game
species.

Assuming a maximum broadcast application  rate of 3.0 pounds active ingredient
per acre (EPA's  Use Pattern Summary Report for Chloramben ), environmental
concentrations are estimated for short range  grass (as the hypothetical worst-
case situation for residues of  the  emulsifiable concentrate product).   T^e NOEL
and LC^Qfor Bobwhite Quail are  taken from the valid  study described
previously for the methyl  chloramben manufacturing-use product.  The following
table portrays the worst-case risk  analysis which applies  to the emulsifiable .
concentrate product:
                                     8-13

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Environmental Worst-Case
Feature/
 Species
Residue
Cone* ocm
Short Range Grass  720
   Bobwhite
    Quail
   Toxicity        No Effect Ratio
   NOEL  LC5Q        (Residue/
active ingredient       NOEL)
              >3120   >3120
                       <0.23
  Hazard Ratio
(Residue/
    <0.23
Since the No-Effect Ratio and Hazard  Ratio which were calculated are
substantially less than one, methyl chloramben emulsifiable concentrate does
not pose a likely significant risk of acute toxicity to birds at current
application rates of 3 pounds active  ingredient per acre.  Based on
toxicological testing with mammals (see  Chapter VII), the hazard to mammals is
also judged to be insignificant.   There  are no data available to evaluate the
hazard to fish or aquatic invertebrates.

         b.   Data Requirements and Data Gaps: Emulsifiable Concentrate

The minimum tests and potentially  required tests for registration of
emulsifiable concentrates are the  same as for all formulated pesticide products
and have been discussed already for the  soluble concentrates.  Since the
emulsifiable concentrate products  contain only methyl chloramben as the active
ingredient, tests submitted  for registration of the methyl chloramben
manufacturing-use product would also  serve to fulfill the minimum testing
requirements for the emulsifiable  concentrates.

With the exception of an acceptable avian dietary LCeQ with an upland game
bird species, no acceptable  studies have been submitted for the methyl
chloramben manufacturing-use product. Therefore the data gaps in the minimum
testing requirements for the emulsifiable concentrates are the same as for the
raethyl chloramben manufacturing-use product.  Submission of tests to fill in
these data gaps is required  for registration of the emulsifiable concentrate
products.

Due to insufficient product  chemistry, environmental fate, and toxicity
information, the need for any of the  additional potentially required tests
cannot be determined.  Following the  submission of studies covering the minimum
registration requirements, the Agency will determine if any of the potentially
required tests are necessary.

         c. Topical Discussions: Emulsifiable Concentrate

See the Topical Discussions  section for  the methyl chloramben manufacturing-use
product for topical discussions relevant to emulsifiable concentrate products.
                                      8-14

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    4.   Granular Chloramben

Currently registered granular  Chloramben products include the following listed
formulated products:

         Registration No.          Active Ingredients

         264-167                   10.8% Ammonium Chloramben
         264-175                   10.8% Ammonium Chloramben
         264-191                    1.3% Ammonium Chloramben
         264-243                    4.3% Ammonium Chloramben
         2749-169                  10.8% Ammonium Chloramben
         264-251                    5.4% Ammonium Chloramben and 17.3%
                                         Monomethyl  ammonium Chloramben
         264-274                    2.82% Ammonium Chloramben and 8.46%
                                          Monomethyl ammonium Chloramben
         a.   Ecological Effects Profile  and Risk Assessment
              Granular
Profile
Since granular Chloramben products  contain  ammonium Chloramben or ammonium
Chloramben with monomethyl ammonium Chloramben as  active ingredients (as do the
soluble concentrate formulated products), the ecological effects profile of the
soluble concentrates is directly applicable to granular products and will not
be repeated here.  Granular products, however, can pose a unique hazard to
birds.  Birds may selectively pick  up granules as  food  or as grit for
incorporation into their gizzards.  An evaluation  of this hazard cannot be
made, however, without the required toxicity data  for birds.

Risk Assessment

There are insufficient toxicity data for any sort  of risk assessment for
wildlife or aquatic organisms.

         b.   Data Requirements and Data Gaps: Granular

The minimum data requirements for granular  products are the  same as  those for
the soluble concentrates.  Fulfillment of data gaps which have been  identified
for the soluble concentrates will serve to  fulfill the  minimum data
requirenents for the granular products at the same time.  Testing is required
on technical grade ammonium and technical grade moncmethyl ammonium  Chloramben.

However, due to insufficient product chemistry, environmental fate,  and
toxicity information, the need for any of the additional potentially required
tests cannot be determined.  Following the  submission of studies covering
minimum registration requirements,  the Agency will determine if any  of  the
potentially required tests are necessary.

         c.   Topical Discussions: Granular

Refer to the Topical Discussion section for the soluble concentrates for
topical discussions relevant to the granular products.
                                     3-15

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TD USE OF BIBLIOGRAPHY

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                       Guide  Co Use of This Bibliography

    Cor.cer.c  of  Bibliography.  This bibliography concains  citations of all
    -he studies  reviewed by EPA in arriving ac the  positions and conclusions
    stated elsewhere  in  this  standard.  The bibliography  is divided into
    3 sections:  (1) citations that contributed information useful to the review
    of the chemical and  considered to be part of the  data base supporting
    registrations  under  the standard, (2) citations examined and judged to be
    inappropriate  for use  in  developing the standard,  and (3) standard
    reference aaterial .  Priaary sources for studies  in this bibliography have
    been the body  of  data  submitted to EPA and its  predecessor agencies in
    support  of  past regulatory decisions, and the  published technical
    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,  the  Agency has  sought to identify documents at a level parallel to
    a published  article from within the typically larger volumes  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.  The Agency
    has attempted also to  unite basic documents and commentaries  upon them,
    treating them as  a single study.
f.'l1.uS'en^ifiCa5ig!L4 Entries •   The entries in this bibliography  are sorted by
author, date of the document and title.   Each entry bears,  to the  left of the
                                         preceeded  by a colon (ie.  :0039).  At
                                bibliography is an  alpha-numeric identifier
              H                                                          .
SSfi^  £h~  •? *?? °f *iS bibli°9raPhy is an alpha-numeric  identifier  (5s
a citit>oT'Me iTflnfi^oT5 ^^ to 2mplete ** identification number  for
* Cltat-on ((,le- GS~0086:0039).  These numbers are called  "Temporary Record '
^ri'rSuSs:3'^ ^ ^ * -d at «* "-^y^
    ?ora of the Entry,   in  addition to the Temporary Becord Identifier (TRID) ,
    each entry consists  of  a  bibliographic citation containing standard
    elements followed,  in the-case of materials submitted  to EPA, by a
    description of the  earliest known submission.   The  bibliographic
    conventions used reflect  the  standards for the American National Standards
    Institute (ANSI),  expanded  to provide for certain special needs.  Some
    explanatory notes  of specific elements follow:

      a. Author.   Whenever the Agency could confidently identify one,
         the Agency has  chosen  to show a personal  author.  When no individual
         was identified, the  Agency has shown an identificable laboratory or
         testing facility as  author.  As a last resort, the Agency has shown
         the first known submitter as author.

      b. Document Date.    When  the date appears as four digits with no
         question marks, the  Agency took it directly from  the document.  When a
         four-digit date is followed by a question nark, the bibliographer

-------
   deduced che dace from evidence  in  che document.   When  che  dace
   appears as (19??), che Agency was  unable  co  deceraine  or escioace che
   dace of che document.

c. Tide.  This is che Chird element  in che  cicacion.   In some  cases it
   has been necessary for che Agency  bibliographers  Co  create or enhance
   a document cicle.  Any such edicorial insertions  are contained
   between square brackets.

d. Trailing Parenthesis.  For studies  submitted  co us  in  che  past,  the
   trailing parenthesis include (in addition  Co  any  self-explanatory
   cext) che following elements describing che  earliest known submission.

        (1)  Submission Date.  Immediately following the  word
             'received' appears che 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)  Submitter.  The third element is the submitter,  following
             the phrase 'submitted by'.  When authorship  is defaulted Co
             the submitter, this element is  omitted.

        (4)  Volume Identification.   The final  element  in the crailing
             parenthesis identifies Che EPA accession number  of  the
             volume in which the original submission of the study
             appears.  The six-digit accession number follows che symbol
             'CDL', standing for "Company Data Library".   This accession
             number is in turn followed by an alphabetic  suffix which
             shows the relative position of  che  study within  che  volume.
             For example, within accession number 123456,  the first
             study would be 123456-A; che second, 123456-B; the  26th,
             123456-Z; and che 27th 123456-AA.
                                  .-3

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   OFFICE OF PESTICIDE PROGRAMS



PESTICIDE DOCUMENT MANGEMENT SYSTEM



         CASE HELICGRAPHy
                9.4

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                  OFFICE OF PESTICIDE PROGRAMS
              PESTICIDE DOCUMENT MANAGEMENT SYSTEM
                        CASE BIBLIOGRAPHY

Section 1: Citations Considered to be Part of the Data Base
           Supporting Registrations Under the Standard .


 I .P.*                  Citation

GS-0086:

:0039 Affiliated Medical Research (1973) Subacute toxicity of
      Amiben methyl ester in the diet of two wild fowl species -
      Bobwhite Quail and Pekin Duck.  (Unpublished report
      received 8-17-73 under 264-138; CDL:128274)

:0036 Affiliated Medical Research (1973) Subacute toxicity of
      Amiben sodium salt in the diet of two wild fowl species -
      Bobwhite Quail and Pekin Duck.  (Unpublished report
      received 11-20-73 under 264-138; CDL:132340)

:0124 Amchem Products, Incorporated (1959) Chemical and physical
      properties of amiben and dinoben.  (Unpublished study
      received 10-19-59 under 264-138; CDL:002082)

:0127  Amchem Products, Incorporated (1960)  Amiben results on
      soybeans, summary.  (Unpublished report received 7-5-60
      under 2.64-138; CDL:002083)

:0125 Amchem Products, Incorporated (1960) Chemical and physical
      properties of chloramben.  (Unpublished study received 7-
      5-60 under 264-138;  CDL:002083)

:0104 Amchem, Products (1961)  Amiben C14 special problem.
      (Unpublished report  received  2-1-62 under 264-Q;
      CDL:121497)

:0136 Amchem Products, Incorporated (1961) C14 Amiben pre-
      emergent tracer study in soybeans.  (Unpublished study
      received 6-13-61 under 264-138;  CDL:002088)

:0154  Amchem Products, Incorporated (1961)  Metabolism of Amiben
      in plants.  (Unpublished study received        under 264-
      138; CDL:  002083)

:0159  Amchem Products Inc., (1961)  Metabolite analysis 2,5
      dichlorophenol in soybeans.  (Unpublished study
      reveiwed 4-3-67 under.7F0591;  CDL: 090758)

:0135 Amchem Products, Incorporated  (1961)  Method of analysis
      for traces of amiben in  de-ciled soybean meal  as developed
      by Dr. V.H.  Freed with minor  modifications by  Amchem
      Residue Lab-in colloboration  with  Dr.  Freed.  (Unpublished
      study received 6-2-61 under  264-138;  CDL:002087)

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:0079  Amchem Products, Incorporated (1961) Separation and
      detection of 2,5-dichlorobenzoic acid, 3-
      arainobenzoic acid and 2,5-dichloro-3-aminobenzoic
      acid (Amiben)  by paper chromatography.
      (Unpublished report received 8-4-61 under 264-138;
      CDL:101235)

:0103  Amchem Products, Incorporated (1963) Addenda to residue
      data on tomatoes.  (Unpublished report received 3-14-63
      under 264-Q; CDL:121515)

:0106  Amchem Products, Incorporated (1963) Amiben analysis in
      tomatoes.  (Unpublished study received 01-01-01 under 264-
      Q;  CDL:121500)

:0098  Amchem Products, Incorporated (1963) Analysis of Araiben
      treated lima bearxs for possible traces of 2,5-
      dichloroaniline.  (Unpublished study received 11-1-63
      under 264-X; CDL:121407)

:0158  Amchem Products, Inc. (1963) 14C-Amiben in lima beans;
      extraction efficiency study, translocation study.
      (Unpublished study received 4-3-67 under 7F0591;
      CDL:090758)

:0102  Amchem Products (1963) Evaluation for NR use of Amiben on
      tomatoes.  (Unpublished review dated 3-15-63;
      CDL:121516)

:0016  Amchem Products, Incorporated (1963) Factory
      correspondence.  Subject:   combined dichloroaniline in
      lima bean plants.  (Unpublished memo received 12-18-63;
      CDL:121521)

:0108  Amchem Products, Incorporated (1963) Lima bean residue
      data and analytical method.  (Unpublished study received
      11-7-63 under 264-Q; CDL:121493)

:0162  Amchem Products, Incorporated (1963) Metabolite analysis
      2 ,5-dichloroaniline in dry beans and peppers.
      (Unpublished study received 4-3-67 under 7F0591;
      CDL:090758)

:0163   Amchem Products, Incorporated (1963) Metabolite analysis
       2,5-dichloroaniline in lima beans. (Unpublished
       study received 4-3-67 under 7F0591; CDL: 090758)

-.0107  Amchem Products, Inc. (1964) Amiben residue analysis on
      lima bean plants.  (Unpublished study received 1-7-
      64  under 264-Q; CDL:121505)

:0093  Amchem (1964)  Amendment to previous evaluations of data
      for NR registrations on dry beans and peppers.
      (Unpublished review dated  3/4/64; CDL:121507)

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:0078 Amchem Products, Incorporated (1964) Analysis of sweet
      potatoes for possible residues of Amiben.  (Unpublished
      report received 6-17-64 under 264-167, 264-138;
      CDL:101242)

:0080 Amchem Products, Incorporated (1964) Analysis of corn for
      possible residues of Amiben.  (Unpublished study received
      8-18-64 under 264-138, 264-167;  CDL:101234)

:0008 Amchem Products, Incorporated (1964) Analysis of dry beans
      and peppers treated with 3-amino-2,5-dichlorobenzoic acid
      for possible traces of 2,5 dichloroaniline .  (Unpublished
      study received 2-28-64 under 264-175; CDL:121513)

:0097 Amchem Products, Incorporated (1964) Lima bean residues,
      letter from Libby,  McNeill , and  Libby.  (Unpublished
      letter received 1-23-64;  CDL:121494)

:0164 Amchem Products, Incorporated (1964) Metabolite analysis
      2,5-dichloroaniline in pumpkin and squash.  (Unpublished
      study rceived 4-3-67 under 7F05991;  CDL:090758)

:0161 Amchem Products, Inc. (1964) Metabolite analysis 2,5
      dichloroaniline in  sweet potatoes (improved
      methodology). (Unpublished study received 4-30-67
      under 7F0591; CDL:  090758)

:0096 Amchem Products, Incorporated (1964) Validation  of
      analysis of Amiben  in dry beans. (Unpublished study
      received 1-30-64 under 264-138,  264-167;  CDL:  121518)

:0076 Amchem Products, Incorporated (1965) Amiben on  peanuts
      supplement  No.  1:   Analysis  of Amiben treated  peanuts  for
      possible presence of 2 ,5-dichloroaniline .  (Unpublished
      report reeceived 4-13-65  under 264-138,  264-167;
      CDL:101240)

:0071 Amchem Products, Incorporated (1965) Improved method for
      determination of residues  in soybeans.   (Unpublished study
      received 10-26-65 under 264-138;  CDL:101238)

:0115 Amchem Products, Incorporated (1965) Information  sheet.
      (Unpublished  study  received  12-1-65  under 264-Q;
      CDL:106953

:0077 Amchem Products, Incorpora :ed (1965) Section  3:   Residue
      analysis; analysis  of peanuts for possible residues  of
      Amiben.  (Unpublished report received  2-24-65 under  264-
      138,  264-167;  CDL:101241)

:0010 Amchem Products, Incorporated (1966) Amiben solubilities.
      (Unpublished  report received 01-01-01  under 264-Q;
      CDL: 1215-14)

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:0140  Amchem Products, Incorporated (1966) Chemical data sheet:
      methyl ester of Amiben.   (Unpublished study received 2-26-
      70  under OF0957; CDL:091633)

:0148  Amchem Products, Incorporated (1966) Rate of hydrolysis of
      various esters of amiben.  (Unpublished report received 01-
      01-01)

:0044  Amchem Products, Incorporated (1967) Analytical methods
      and sample data on drybeans .   (Unpublished report received
      4-3-67 under 7F0591; CDL:090758)

:0045  Amchem Products, Incorporated (1967) Radiotracer and
      metabolism Studies.  (Unpublished report received 4-3-67
      under 7F0591; CDL:090758)

:0043   Amchem Products, Incorporated (1967) Soil residues.
       (Unpublished study received  4-3-67 under 7F0491;
       CDL:090758)

:0085  Amchem Products, Incorporated (1968) Amiben tissue storage
      study.  (Unpublished study rerceived 10-15-68 under
      7F0591; CDL:090759)

:0149  Amchem Products, Incorporated (1968) Analysis of cucumbers
      for Possible residues of Amiben.  (Unpublished study
      received 01/01/01) .

:0084  Amchem Products, Incorporated (1968) Improved methodology
      for the determination of Amiben residues in various
      crops.  (Unpublished study received 10-25-68 under 7F0591;
      CDL:090759)

:0109  Amchem Products, Incorporated (1968) Residue analysis of
      Amiben super 6 liquid and granular.  (Unpublished study
      received 5-23-75 under 264-266; CDL:101106)

:0006   Amchem Products, Incorporated (1969) Analytical methods
       and data for detection  of residues on soybeans.
       (Unpublished study received  10-6-69 under 264-ELR,
       264-ELE; CDL:101237)

:0110  Amchem Products, Incorporated (1969) Residues of Amiben
      and Atrazine in corn.  (Unpublished report received 10-22-
      69 under 264-ELG; CDL.-101220)

:0166  Arachem Products, Incorporated (196?) Gas chromatographic
      method for the analysis  of lima beans for possible
      residues of Amiben.  (Unpublished study received 4-3-67
      under 7F0591; CDL:090758)

:0167  Amchem Products, Incorporated (196?) Gas chromatographic
      method 'for the analysis  of tomatoes for possible residues
      of Amiben.  (Unpublished study received 4-3-67 under
      7F0591; CDL:090758)

-------
:0120 Amchem Products, Incorporated (196-?) Residues on
      soybeans.  (Unpublished report received 01/01/01).

:0081 Amchem Products, Incorporated (196?) The name, chemical,
      identity, composition of Amiben.  (Unpublished study
      received 3-31-67 under 7F0591; CDL.-090879)

:0118 Amchem Products, Incorporated (1976) Amiben/Lasso on
      soybeans chloramben analyses.  (Unpublished report
      received 4-13-76 under 264-138;  CDL:225085)

:0067 Amchem Products, Incorporated (1978) Amiben PKa values.
      (Unpublished study received 6-22-78 under 264-306;
      CDL:234221)

:0056 Amchem Products, Incorporated (1978) Amiben sodium
      salt/corn residues.  (Unpublished study received 6-22-78
      under 264-306;  CDL:234221)

:0057 Amchem Products, Incorporated (1978) Amiben sodium
      salt/soybean residues.  (Unpublished study received
      6-22-78 under 264-306; CDL:234221)

:0101 Amchem Products, Incorporated (1978) Analysis of soybeans
      and soybean  hay (dry vines) for  possible residues of
      chloramben resulting from postemergence treatments with
      Amiben.  (Unpublished report reeceived 4-11-79 under 264-
      138;  CDL:238013)

:0069 Amchem Products, Incorporated (1978) Formulation
      stability.  (Unpublished study received 6-22-78  under 264-
      306;  CDL.-234221)

:0153  Amchem Products, Incorporated (1978)  N-Nitrosamine
      analyses/formulated products.  (Unpublished study received
      7-11-78 under 264-138, 264-244;  CDL.-234361)

:0054 Amchem Products, Incorporated (1979) Physical/chemical
      properties of technical grade sodium Chloramben.
      (Unpublished  study received 4-10-79  under 264-305;
      CDL:238008)

:0083 Amchem Products, Incorporated (197?) Procedure for the
      determination of 3-amino 2,5-dichlorobenzoic acid
      (Chloramben)  in Amiben formulations.  (Unpublished  study
      received 4-10-79 under 264-306;  CDL:238007)

:0029 A.iM.S. Associates (1966)  Reproduction  study in albino rats
      with  Amchem  Products Inc.,  - Amiben  (3-amino-2,5-
      dichlorobenzoic acid).  Project  *200-064.   (Unpublished
      study received  February 28, 1967  under 7F0591 prepared
      for Amchem Products Inc., CDL:090760)

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:0502  Anderson,  K . J .;  Leighty/E.?  Takahashi ,  M.T. (1972)
      Evaluation of herbicides for  possible mutagenic
      properties. Journal of Agricultural and  Food Chemistry
      20(3):  649-656.

:0548  Ashton, P.M.  (1966) Fate of Amiben-14C in carrots. WEEDS
      14(1):55-57.

:0092  Baker,  E.M. (1964)  Addena to  evaluation  for NR use on lima
      beans.   (Unpublished report received 11-1-63 under 264-Q;
      CDL:121504)

:0541  Berkheiser, V.E.; Ahlrichs, J.L. (1976)  UV and IR
      spectral characteristics of chloramben in selected
      environments. Weed  Science 24(1):  107-114.

:0051  Bionomics, Incorporated (1970)  Acute toxicity of Amiben
      concentrate (65-319) to Fathead Minnow,  Bluegill, and
      Rainbow Trout.   (Unpublished  study received 4-9-70 under
      264-ELR, 264-ELE; CDL:100524)

:0002  Biosearch, Incorporated (1969)  Acute dermal toxicity -
      rabbits of Amchem 65-319.  (Unpublished  study received
      October 6, 1969  under 264-ELR,  264-ELE;  prepared for
      Amchem Products, Inc.; CDL:100527)

:0145  Biosearch/ Incorporated (1969)  Acute oral toxicity -
      Bobwhite Quail.   (Unpublished report received 4/70)

:0001  Biosearch, Incorporated (1969)  Acute oral toxicity - rats
      of Amchem 65-319.  (Unpublished study received October 6,
      1969 under 264-ELR, 264-ELE;  prepared for Amchera
      Products, Inc.;  CDL:100527)

:0003  Biosearch, Incorporated (1969)  Draize eye irritation -
      rabbits of Amchem 65-319.  (Unpublished  study received
      October 6, 1969  under 264-ELE,  264-ELR;  prepared for
      Amchera Products, Inc.; CDL:100527)

:0504  Burchfield, H.P.; Storrs, E.E.; Kraybill, H.F. (1975) The
      maximum tolerated dose in pesticide carcinogenicity
      studies. Environ. Qual. Saf .  , Suppl. 3(Pesticides):  599-
      603.

:0549  Butler, G.L.  (1977) Algae and Pesticides.  Pages 19-62,
      Residue Reviews  Residues of Pesticides and Other
      Contaminants in  the Total Environmental-Vol. 66.  Francis
      A. Gunther, Jane Davies Gunther^.  Illustrated.  New York,
      NY:  Springer-Verlag.

:0065  CDC Research Incorporated (1978) Acute dermal application
      (LD50)  in rabbits of sodium chloramben.   (Unpublished
      study received 6/22/78 under 264-305; CDL:234220)

-------
:0063 CDC Research, Incorporated (1978) Primary skin irritation
      in rabbits of sodium chloramben.  (Unpublished study
      received 6/22/78 under 264-305; CDL:234220)

:0064 CDC Research Incorporated (1978) Rabbit Eye Irritation in
      rabbits of sodium chloramben.   (Unpublished study
      received 6/22/78 under 264-305; CDL:234220)

:0524 Chio, Hang; Sanborn, J.R. (1978) The metabolism of
      atrazine, chloramben, dicamba in earthworms (Lumbricus
      terrestris) from treated and untreated plots. Weed Science
      26(4): 331-335.

:0156 Colby, S.R. (1965)  Herbicide metabolism: N-glycoside of
      Amiben isolated from soybean plants.  Science  Vol. 150,
      No. 3696, p. 619.  (Study received 4-3-67 under 7F0591;
      CDL:090758)

:0586 Corbin, Frederick T.; Upchurch, Robert P. (1967)
      Influence of pH on  detoxification of herbicides in soil.
      WEEDS 15(4): 370-377.

:0587 Crosby, D.G.; Leitis, E. (1969)  Photodecomposition of
      chlorobenzoic acids. Journal of Agricultural and  Food
      Chemistry 17(5) 1033-1035.

:0007 Diablo Laboratories (1964) Analysis  of dried beans for
      possible amiben residues (Unpublished study received
      1-31-64 under 264-167;  CDL:121512)

:0033 Dow Chemical Company (1969)  Analytical method for
      determination of Amiben and  Dinoseb  in formulations.
      (Unpublished study  received  12-30-69 under 264-ELA;
      CDL:100736)

:0050 Blanco Products, Incorporated (1978 )^ Trifluralin  and
      chloramben residue  data on soybeans.  (Unpublished report
      received 2-9-78 under 1471-35;  CDL:232828)

:0589 Fickle, J.S. (1974)  Environmental factors  affecting the
      movement and persistence of  chloramben in  solis.
      Dissertation Abstracts  International 34(9):  4160.

:0062 Food  and Drug Research  Laboratories, Incorporated  (1978)
      Inhalation toxicity study of  amiben  sodium  salt #3599  in
      adult Sprague - Dawley  rats.   (Unpublished  study
      received 6/22/78 under  264-305;  CDL:234220)

:0556 Frear, D.S.; Swanson, H.R.;  Mansager, E.R.;  Wien,  R.G.
      (1978) Chloramben metabolism  in  plants:  isolation  and
      identification of glucose ester. Journal of  Agricultural
      and Food Chemistry  26(6):1340-1351.

:0128 Freed, Virgil H. (1960)  Determination of  amiben in soil.
      (Unpublished study  received  8-24-61  under  264-167;
      CDL:120434)

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:0594  Hahn ,  R.R.;  Burnside, O.C.;  Lavy,  T.L. (1969) Dissipation
      and phytotoxicity and dicamba. Weed Science 17(1): 308.

:0595  Harris,  Clare Irving (1967)  Movement of herbicides in
      soil.   WEEDS 15(3):  214-216.

:0596  Harter,  R.D.; Ahlrichs,  J.L. (1969) Effect of acidity on
      preactions of organic acids  and amines with
      montmorillonitic clay surfaces.  Proceedings of the Soil
      Science Society of America.  33(6): 859.

:0023  Hazleton Laboratories, Incorporated (1959) Acute dermal
      application - rabbits of technical grade chloramben.
      (Unpublished study received  February 28, 1967 under
      7F0591;  prepared for Amchem  Products Inc.; CDL:090760

:0022  Hazleton Laboratories, Incorporated (1959) Acute oral
      administration - rats of technical grade chloramben.
      (Unpublished study received  February 28, 1967 under
      7F0591;  prepared for Amchem  Product Inc.; CDL:090760)

:0028  Hazleton Laboratories, Incorporated (1963) Two-Year
      dietary feeding-dogs of  technical  grade chloraraben(?) .
      (Unpublished study received  February 28, 1967 under
      7F0591;  prepared for Amchem  Products Inc.; CDL:090760)

:0024  Hazleton Laboratories, Incorporated (1966) Acute oral
      administration - Rats of ammonium salt, technical methyl
      ester, and formulated methyl ester.  (Unpublished study
      received February 28, 1967 under 7F0591; prepared for
      Amchem Products Inc.; CDL:090760)

:0143  Hazleton Laboratories, Incorporated (1968) Acute dermal
      application - rabbits, acute eye application - rabbits  of
      65-81-B.  (Unpublished study received 01/01/01)

:0144  Hazleton Laboratories, Incorporated (1968) Acute
      inhalation exposure - rats of 65-81-B (Technical Grade
      Methyl Ester).  (Unpublished study received 01/01/01)

:0146   Hughes, J.S. (1970) Letter  dated  January 26, 1970 to John
       E. Gallagher/ Amchem Products, Inc. (Unpublished;
       prepared by Louisiana Wildlife and Fisheries
       Commission)

:0170  Huntington Research Center (1978)  Eighteen (18) month
      oncogenic study following prolonged oral administration in
      Crl: COBS CD-I mice of amiben acid technical/ volumes I
      and II.  (Unpublished study  received July 9, 1980 under
      7F0591;  prepared for Union Carbide Agricultural Products
      Division; CDL:242821)

:05100 Knake, Ellery L.; Appleby,  Arnold P.; Furtick, William R.
       (1967)  Soil incorporation and site of uptake of
       preemergence herbicides.  WEEDS 15(3): 228-232.

-------
: 05116 Lewis, C. (1980)  Use Pattern Summary Report for
       Chloramben.  U.S.   Environmental Protection Agency, Plant
       Sciences Branch,  Benefits and Field Studies Division.

:0171 Litton Bionetics,  Incorporated (1980) Two-Year
      carcinogenesis study in rats of technical grade
      chloramben.  (Unpublished study received 1/15/80 under
      7F0591; prepared for Union Carbide Agricultural Products
      Divison; CDL:241603)

:0147 McLane, S.R.;  Parkins, M.D. (196?) Biological and physical
      attributes of  several amiben derivatives.  (Unpublished
      study received 01/01/01)

:05117 Miller, C.S.; Hoover, W.L.; Culver (1980)  Exposure of
       pesticide applicators to Arsenic Acid.  Arch. Environ.
       Contain. Toxicol.  9: 281.

:0536 Morton, H.L.;  Moffett, J.O. (1972) Toxicity of herbicides
      to newly emerged honey beees.  Environmental Entomology
      1(1): 102-104.

:0019 National Cancer Institute (1977)  Bioassay of chloramben
      for possible carcinogenicity (Study received December 15,
      1977; prepared by  Gulf South Research Institute for NCI;
      CDL:233410)

:0146a Otten, R.J.  (1970)  Factory Correspondence.  Subject:
       Amiben - fish toxicity-   (Unpublished;  submitted by
       Amiben Products,  Inc.)

:05119 Peoples, S.A.; Maddy, K.; Datta, P.R.;  Johnston, L.;
       Smith, C.; Conrad,  D.; Copper, C. (1979)  Monitoring of
       potential exposures of mixer loaders, pilots and flaggers
       during application  of Tributyl Phosphorotrithioate (DEF)
       and  Tributyl  Phosphorotrithioite (Foloex)  to cotton
       fields in the San Joaquin Valley of California in  1979.
       California Department of Food and Agriculture  :  45-676.

:05106 Plimmer, J.R.; Hummer, B.E. (1969)  Photolysis  of amiben
       (3 amino-2 5-dichloro benzoic acid) and its methyl ester.
       Journal of Agricultural  and Food Chemistry 17(1):  83-85.

:0131  Rauser, W.E.; Switzer, C.M. (1063)  Effects of  leaching on
      the persistence of Amiben toxicity in various soils.
      (Unpublished study received 2-17-64  under 264-138;
      CDL:002092)

:0570  Samosvat, L.S.; Voynova, I.V. (1975) Colorimetric  method
      of determination of  amiben in  air, water and  soil.
      National Technical Information Service,  Dept. of  Commerce.

:05107 Sheets, T.J.;  Smith,  J.W.;  Kaufman, D.D.  (1968)
       Persistence of benzoic and phenyl acetic acids in  soils,
       Weed Science  16(2):  217-222.

-------
:05118  Staiff,  D.C.;  Comer, S.W.;  Armstrong, J.F.;  Wolfe, R.R.
       (1975)  Exposure to the herbicide Paraquat. Bull.
       Environ.  Contam.  Toxicol.

:0041 Stauffer Chemical Company (1979)  Summaries and analytical
      reports  for tank mixes containing Vernam 7E.   (Unpublished
      reported  received 6-20-79 under 476-2155; CDL:238641)

:0577  St.  John, L.E. Jr.;  Lisk, D.J. (1970) Excretory pathway
       of amiben in a lactating cow. Journal of Agricultural and
       Food Chemistry 18(3): 482-484.

:05110  Stoller, E.W.  (1969) Kinetics of amiben absorption and
       metabolism as  related to species sensitivity. Plant
       Physiology 44(6):, 854.

:0538  Stoller, E.W.  (1970) Mechanism for the differential
       translocation  of Amiben in plants. Plant Physiology
       46(5):  732-737.

:0169 Swanson, C.R.;  Kadunce, R.E.; Hodgson, R.H.;  Frear, D.S.
      (1966) Amiben Metabolism in Plants I.  Isolation and
      identification  of an N-glucosyl complex.  Weeds.  Vol.
      14, No.  4.  pp. 319.  (Study received 4-3-67  under 7F0591;
      CDL:090758)

:05111 Talbert, R.E.; Runyan, R.L.; Baker, H.R. (1970) Behavior
       of amiben and  dinoben derivatives in Arkansas soils.
       Weed Science 18(1):  10-15.

:0539  Torstensson, Lennart; Stade, Eva (1976) Effects of some
       herbicides on  soil microorganisms and on the rhizobium-
       leguminosae symbiosis. Sweedish Weed Conference        J
       (Proceedings)  17(Weeds Weed Control): K2-K7.

:0049 Truslow  Farms (1974)  Mallard Duck LC50 of ammonium
      chloramben - 23.4%.  (Unpublished report received 7/20/74
      under 264-Q; CDL:132485)

:0020 Union Carbide Environmental Services (1978) Bluegill
      sunfish  bioconcentration study.  (Unpublished report
      received 8-30-78 under 264-138; CDL:235264)

:0018 Union Carbide Environmental Services (1978) Channel
      catfish bioconcentration study.  (Unpublished report
      received 8-30-78 under 264-138; CDL:235265)

:0060 Union Carbide Environmental Services (1978) The acute
      toxicity of Amiben sodium salt to Bluegill Sunfish.
      (Unpublished study received 6/22/78 under 264-306;
      CDL:234221)
                               10

-------
:0061  Union  Carbide  Environmental  Services  (1978)  The  acute
      toxicity of  Amiben  sodium salt to the Rainbow Trout.
      (Unpublished study  received  6/22/78  under 264-306;
      CDL:234221)

:0172  Union  Carbide  (1981)   Fate of  chloramben.  (Unpublished
      study  received  2/3/81  under  264-306;  CDL:         )

:0157  Warren,  L.C.;  Behrens ,  R.  (1961)  C14  Amiben  study in
      soybeans post-emergence application.   (Unpublished  study
      received 4-3-67  under  7F0591;  CDL.-090758)

:0059  Wildlife International, Limited  (1978)  Eight  day dietary
      LC50 Mallard Duck of Amiben  sodium salt.   (Unpublished
      study  received  6/23/78  under 264-305;  CDL:234220)

; 05115  Wildung,  Raymond Earle;  Chesters, Gordon; Armstrong,
       David E.  (1968) Chloramben  (amiben)  degradation in soil.
       Weed  Research  8(3): 213-225.

 05120  Wolfe,  H.R.; Durham, W.F.;  Batchelor,  G.S.  (1961) Health
       hazards of  some dinitro  compounds, effects  associated
       with  agricultural  usage  in  Washington  State.
 0048  Zweig , G.; Sherma,  J.  (1972) Analytical Methods  for
      Pesticides and  Plant Growth  Regulators.   Volume  VI:  Gas
      Chromatographic Analysis.  (Report received  01-01-01
      under  3125-277; CDL:225408)
                              11

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                  OFFICE OF PESTICIDE PROGRAMS
              PESTICIDE DOCUMENT MANAGEMENT SYSTEM
                        CASE BIBLIOGRAPHY

Section 2: Citations Examined and Judged to be Citations
           Inappropriate for Use in Developing the Standard
                        Citation
:0518 Altman, J.; Campbell, C.L. (1977) Effect of herbicides on
      plant diseases. Annual Review of Phytopathology Vol. 15:
      pp. 499-

:0013 Amchem Products, Incorporated (1960) Call report:  Factory
      correspondence.  Subject:  soybean plant residues.
      (Unpublished study received 01/01/01 under 264-Q;
      CDL:121514)

:0012 Amchem Products, Incorporated (1960) Phytotoxicity of
      Amiben (appendix VIII).   (Unpublished study submitted
      under 264-Q? CDL:121514)

:0047 Amchem Products, Incorporated (1960) Residue Program for
      Soybeans.  (Unpublished  study received 3-15-60 under 24-
      EX013; CDL:127038)

:0017 Amchem Products, Incorporated (1961) Procedure for the
      determination of traces  of 3-amino-2,5-dichlorobenzoic
      acid  in tomatoes.  (Unpublished study received 3-11-61
      under NR8970-4; CDL:126195)

:0152 Amchem Products, Incorporated (1964) Analysis of pumpkin
      and squash for possible  residues of Amiben.  (Unpublished
      study received 3-25-64 under 264-175, 264-178; CDL:002148)

:0138 Amchem Products, Incorporated (1965) Section 3 Residue
      Analysis:  Analysis of peanuts for possible residues  of
      amiben.  (Unpublished study received 2-24-65 under 264-
      138;  CDL:002097)

:0038 Amchem Products, Incorporated (1966) Amiben toxicity
      summary:  a formulation  comparison*  (Unpublished study
      received under c957;  CDL:098715)

:0046 Amchem Products, Incorporated (1967) Methods of residue
      analysis.  (Unpublished  study received 4-3-67 under
      7F0591;  CDL:090758)

:0087 Amchem Products, Incorporated (1968) Analysis of forage
      samples for possible  residues of amiben.   (Unpublished
      study received 10-25-68  under 7F0591;  CDL:090759)

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:0031  Amchem Products,  Incorporated (1968)  Soybean residue
      data.   (Unpublished study received 5-7-73 under 7F0591;
      CDL:008500)

:0099  Amchem Products,  Incorporated (196?)  Method for the
      determination of  amiben liquid or granular formulations.
      (Unpublished study received 01-01-01  under 264-Q;
      CDL:121347)

:0068  Amchem Products,  Incorporated (1978)  Physical chemistry of
      sodium salt  of Amifaen.   (Unpublished  study received 6-22-
      78 under 264-306; CDL:234221)

:0100  Amchem Products,  Incorporated (1979)  Chloramben and
      Trifluralin  analyses of sunflowers treated with Amiben and
      Treflan tank mix  PPI .  (Unpublished report received 3-7-79
      under 264-138; CDL:238153)

:0519  Ashton, F.M.S; DeVilliers, O.T.;  Glenn, R.K.; Duke, W.B.
      (1977) Localization of  metabolic sites of action of
      herbicides.   Pesticide  Biochemistry and Physiology 7(2):
      122-141.

:0072  Baker, R.S.  (1960) Leaching and adsorption.  (Unpublished
      study received 8-24-61  under 264-167; CDL:106953)

:0112  Baron, P.O.  (1968) Review of toxicology data.
      (Unpublished review dated 8/8/68; CDL:106948)

:0004  Biosearch, Incorporated (1969) Acute  inhalation toxicity -
      rats of Amchem 65-319.   (Unpublished  study reeceived
      October 6, 1969 under 264-ELR, 264-ELE; prepared for
      Amchem Products,  Inc.;  CDL:100527)

:0145  Biosearch, Incorporated (1969) Acute  oral toxicity -
      Bobwhite Quail.  (Unpublished report  received 4/70)

:0001  Biosearch, Incorporated (1969) Acute  oral toxicity - rats
      of Amchem 65-319-  (Unpublished study received October
      6,  1969 under 264-ELR, 264-ELE; prepared for Amchem
      Products, Inc.; CDL:100527)

:0003  Biosearch, Incorporated (1969) Draize eye irritation -
      rabbits of Amchem 65-319.  (Unpublished study received
      October 6, 1969 under 264-ELE, 264-ELR; prepared for
      Amchem Products,  Inc.;  CDL:100527)

:0094  Bois, H. (1964) Evaluation of data for NR registration for
      Achemm Amiben Granular on soybeans and dry beans.
      (Unpublished review dated 2-12-64; CDL:121510)

:0095  Bois, H. (1964) Memorandum of conference.  Subject:  NR
      Registration for Amchem Amiben Granular on dry beans and
      peppers.  (Unpublished  memo dated 2-13-64; CDL:121509)

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:0520 Burgis, D.S. (1972) Herbicide tests on pepper transplants
      and seeded peppers.  Proceedings of the Florida State
      Horticultural Society 84: 183-186.

:0168 Burnside, O.G. (1965) Longevity of Amiben, Atrazine, and
      2,3,6-TBA in incubated soils.  Weeds.  Vol. 13, No. 3,
      page 274.  (Study received 4-3-67 under 7F0591; CDL.-090758

:0584 Burnside, O.C.; Schultz, M.E. (1978) Soil persistence of
      herbicides for corn, sorghum, and soybeans during
      the years of application.  Weed Science 26(2): 108-115.

:0550 Carey, A.E.; Wiersma , G.B.; Tai , H; Mitchell, W.G. (1973)
      Organo chlorine pesticide residues in soils and crops of
      the corn belt region USA 1970. Pesticide
      Monitoring Journal 6(4)  369-376.

:0521 Carney, A.N.; Stephenson, G.R.; Ormrod, D.P.; Ashton,
      G.C. (1973)  Ozone-herbicide interactions in crop plants.
      Weed Science 21(6):508-511.

:0014 Caswell, R.I. (1963) Addenda to review of residue data on
      tomatoes.  (Unpublished  review dated 4-30-63; CDL:121525)

:0015 Caswell, R.I. (1964) Review of sweet potato residue data.
      (Unpublished review dated 7/27/64; CDL:121527)

:0066 CDC Research Incorporated (1978)  Acute oral LD50 in rats
      of sodium chloramben.   (Unpublished study received 6/22/78
      under 264-305;  CDL:234220)

:0522 Chang, Fa-Yan;  Smith,  Leon W.; Stephenson,  Gerald  R.
      (1971)  Insecticide inhibition of  herbicide  metabolismin^
     .leaf tissues. Journal  of Agricultural  and  Food Chemistry
      19(6):  1183-1186.

:0523 Chen, M.L.;  Chen, V. K-H. (1977)  Electrical measurement
      of membrane  properties change of  conductance of  soy
      lecithin membranes by the herbicide chloramben.
      Proceedings  of  the American Phytopathological Society  4:
      135.

:0551 Chow, Paul N.P.  (1975) Absorption of herbicides  by wheat
      as influenced by  the phenoxy compound. Journal of
      Agricultural and  Food  Chemistry 23(4):  730-736.

:0542 Coffey, David L.; Warren, George  F. (1969)  Inactivation
      of herbicides by  activating  carbon and other absorbents.
      Weed Science 17(1):  16-19.

:0525 Colby,  S.R.  (1966)  The mechanism  of selectivity  of
      Amiben. WEEDS 14(3):  197-201.'

:0073 Colby,  S.R.;  Baker,  R.S.; Warren,  G.F.  (1962)  Residue  of
      C14 Amiben in greenhouse  tomatoes.   (Unpublished  study
      received 3-11-63  under NR-7532; CDL:120695)

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:0552  Colby,  S.R.;  et al (1964)  Fate of Amiben in tomato
      plants. Journal of Agricultural and Food Chemistry 12:
      320-321.

:0155  Colby,  S.R.;  Warren, G.F.;  Baker, R.S. (1964)  Fate of
      amiben  in tomato plants.  Agricultural and Food
      Chemistry.  Vol. 12, No. 4, p. 320.  (Study received
      4-3-67  under 7F0591; CDL:090758)

:0585  Cooke ,  A.R. (1966) Controlled studies on the interaction
      of rainfall and preemergence herbicide activity.
      Mededelingen van de Rijksfaculteit Landbouwwetenschappen
      te Gent 31(3):  1165-1170.

:0586  Corbin, Frederick T.; Upchurch, Robert P. (1967)
      Influence of pH on .detoxification of herbicides in soil .
      WEEDS 15(4):  370-377.

:0505  Crouch, E.;- Wilson, R. (1979) Interspecies comparison of
      carcinogenic potency. Journal of  Toxicology and
      Environmental Health 5(6):  1095-1118.

:0113  Dale, L.B. (1970) Review of toxicity data.  (Unpublished
      review dated 2/9/70; CDL:106950)

:0005  Dale, L.B. (1969) Review of acute toxicity data for Amchem
      65-319.  (Unpublished report completed December 1, 1969
      under 264-ELE,  264-ELR; CDL:100533)

:0555  Doll, J.D.; Penner, D.; Meggit, W.F. (1970) Herbicides
      and phosphorous influence  on root absorption of amiben
      and atrazine.  Weed Science 18(3): 357-359.

:0032  Dow Chemical Company (1969) Acute toxicological prope-rties
      of Premerge 21  Weed Killer.  (Unpublished study received
      12/30/69 under 464-GIG; prepared  for Dow Chemical Company;
      CDL:003598)

:0111  EPA (1967) Review of data on technical grade chloramben.
      (Unpublished review dated  1/17/67; CDL.-106947)

:0583  Eshel, Yael; Warren, George, F. (1967) A simplified
      method for determining phytotoxicity, leaching  and
      adsorption of herbicides in soil. WEEDS 15(2):  115-118.

:0526  Fabacher, D.L.; Chambers,  H. (1974) Resistance  to
      herbicides in mosquitofish. Environmental Letters 7(1):
      15-20.

:0590  Frear, D.S. (1976) The Benzoic Acid Herbicides. Pages 541-
      607, In Herbicides. Chemistry, Degradation, and Mode of
      Action  (Vol.2). Kearney, P.C. and D.D. Kaufman.
      Illustrated. New York, N.Y. Marcel Decker.

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:0165 Freed, V.H. (1961) Old colorimetric method for Amiben
      residue analysis in soybean meal and soybean oil.
      (Unpublished study received 4-3-67 under 7F0591;
      CDL:090758)

:0591 Freed, V.H.; Chiou, C.T = ;  Hague, R-. (1977) Chemodynamics
      transport and behavior of  chemicals in the environment a
      problem in environmental  health.  Environmental Health
      Perspectives  20:55-70.

:0558 Geshtout, Yi3 N.; Zharasov, Sh U. ;Bainazarova, Kh E. ;
      Kostutinov, E.;  Baranovskii, M.F. (1973) Herbicides in a
      fallow/cereals/row crop rotation. Vestnik
      Sel'skokhozyaistuennoi Nauki Kazakhstana 16(12): 30-34.

:0506 Gram, T.E.; Litterst, C.L.; Mimnaugh,  E.G. (1974)
      Enzymatic conjugation of  foreign chemical compounds by
      rabbit lung and  liver. Drug Metabolism and Disposition
      2(3): 254-258.

:0593 Greig, James, K.;  Motes, J.E. (1966)  Persistence of
      preemergent herbicides in  controlling  weeds in sweet
      potato plantings.   Proceedings of the  North Central Weed
      Control Conference 20: 25-26.

:0597 Hailing, C.S. (1971)  Pesticide mobility in soils.
      Proceedings of  the Soil Science Society of America.  35(5)
      737.

:0528 Harrison, G.W.;  Weber, J.B. (1975)  Comparative
      phytotoxicities  of five herbicides  in  ten North Carolina
      soils. Proceedings 28th Annual Meeting Southern Weed
      Science Society:  283-291.

:0026 Hazleton Laboratories, Incorporated (1959)  Acute eye
      application - rabbits of technical  grade chloramben.
      (Unpublished study received February 28, 1967  under
      7F0591; prepared for  Amchem Products  Inc.;  CDL:090760)

:0025 Hazleton Laboratories, Incorporated (1959)  Twenty-Eight
      day dietary feeding-rats of technical  grade chloramben.
      (Unpublished study received February 28, 1967  under
      7F0591; prepared for  Amchem Products  Inc.;  CDL:090760)

:0114 Hazleton Laboratories (1961)  Progress  report  (26-week
      dietary feeding  -  rats; seven week  dietary  feeding dogs.
      (Unpublished study data 6/22/61 under  7F0591;  CDL:106951)

:0116 Hazleton Laboratories (1963)  Summary report -  two year
      dietary feeding  -  dogs. (Unpublished  study dated 5/15/63
      under 7F0591; CDL:106955)

:0028 Hazleton Laboratories, Incorporated  (1963)  Two-Year
      dietary feeding-dogs  of technical grade  chloramben(?) .
      (Unpublished study received February 28,  1967  under
      7F0591; prepared  for  Amchem Products Inc.;  CDL:090760)

-------
:0027  Hazleton Laboratories, Incorporated (1963) Two-Year
      dietary feeding-rats of technical grade chloramben(?).
      (Unpublished study received February 28, 1967 under
      7F0591; prepared for Amchem Products Inc.; CDL:090760)

:0088  Hazleton Laboratories, Incorporated (1967) Supplement to
      final report (1963) - two year dietary feeding - rats of
      technical grade chloramben(?)  (Unpublished study
      received 8/19/67 under 7F0591)

:0086  Hazleton Laboratories, Incorporated (1967) 28-Day oral
      administration - dogs of technical grade chloramben.
      (Unpublished study received 10/25/68 under 7F0591;
      CDL:090759)

:0150  Hazleton Laboratories, Incorporated (1973) Analysis of
      amiben and trifluraln residues in soybeans (Beans) .
      (Unpublished study received 8-20-73 under 264-138;
      CDL:008803)

:0598  Holloman, M.E.; Hutto, Fay Y.; Kennedy, M.V.; Swanson,
      C.R. (1976) Thermal degradation of selected herbicides.
      Journal of Agricultural and Food Chemistry 24(6): 1194-
      1198.

:0529  Houghton, J.N. (1974) Ecological changes in weed
      populations as a result of crop rotations and herbicides.
      Dissertation Abstracts International 34(9): 4160-4161.

:0508  Hubbeling, N; Chaudhary, K.C.  Basu (1970) Mutagenic
      effect of a herbicide on Verticillium dahlia^. Meded .
      Fac. Landbouwwetensch Rijksuniu Gent 35(2):' 627-635.

:0009  Hughes, R.E.; Freed, U.K.  (1960) Physical/chemical
      properties and analytical method for Amiben.  (Unpublished
      study received 01/01/01 under 264-Q; CDL:121514)

:0509  Iden, D.L.; Schroeter, A.L. (1977) Allergic contact
      dermatitis to herbicides. Archives of Dermatology 113(7):
      9-83.

:0599  Ivie, G.W.; Casida, J.E. (1971) Sensitized
      photodecomposition and photosensitizer activity of
      pesticide chemicals exposed to sunlight on silica gel
      chromatoplates. Journal of Agricultural and Food Chemistry
      19(3): 405-409.

:0561  Kapusta , George; Rouwenhorst, D.L. (1973) Interaction of
      selected pesticides and Rhizobium jabonicum in pure
      culture and under field conditions. Agronomy Journal
      65(1): 112-115.

:0562  Knake, Ellery L.; Wax, Loyd M. (1968) The importance of
      the shoot of giant foxtail for uptake of preremergence
      herbicides.  Weed Science  16(3) :~ 393-395.

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:05101 Kune,  F. (1975) Control of pesticide persistence in soil
       with special respect to microbial activity. Zbl. Bakt.
       Abt. II 130(1) : 82-103 .

:0531 Lee, O.P. (1973) Studies on the mode of action of 3-amino-
      2,5- dichlorobenzoic acid on tobacco callus tissue in
      vitro.   Dissertation Abstracts International 34(2): 483.

:0532 Linscott, J.J.  (1969) Phytotoxicity and movement of
      amiben  derivatives in soil.  Weed Science 17(2): 170-174.

:0533 McCorkle, P.M.;  Chambers, J.E.; Yarbrough,  J.D. (1977)
      Acute toxicities of selected herbicides to  Fingerling
      channel catfish, Ictalurus punctatus. Bulletin of
      Environmental Contamination and Toxicology  18(3): 267.

:0563 Melville, D.R.;  Oakes,  J.Y. (1976) Residual effects of
      herbicides in cotton, corn and soybean rotations.
      Louisiana Agriculture 19(3): 8-9.

:0564 Miller, J.C.  Jr.;  Penner, D.;  Baker, L.R. (1973) Basis
      for variability  in the  cucumber for tolerance to
      chloramben methyl  ester. Weed  Science 21(3): 207-211.

:0565 Moody,  Keith; Kust, Cyril A.;  Buchholtz ,  Kenneth P.
      (1970)  Uptake of herbicides by soybean roots in culture
      solutions.  Weed Science 18(5): 642-647.

:0566 Moomaw, R.S.; Burnside, O.C. (1979) Corn  residue
      management and weed control in close-drilled soybeans.
      Agronomy Journal 71(1): 78-80.

:0534 Morton, H.L.; Moffett,  J.O. (1972) Effects  of herbicides
      on honeybees. Proceedings of the Western  Society of Weed
      Science 25:  15-16.

:0535 Morton, H.L.; Moffett,  J.O. (1972) Ovicidal and
      larvacidal effects of certain  herbicides  on honeybees.
      Environmental Entomology 1(5): 611-614.

:0567 Olumbe, Johnes W.K.;  Veatch, Collins (1969)  Organic
      matter-amiben interaction on nodulation and growth  of
      soybeans.  Weed  Science 17(2): 264-265.

:0082 Otten,  R.J.  (1969) Memo presenting isomer content of
      material used in Hazleton chronic feeding study.
      (Unpublished  communication received 9/25/72 under 7F0591;
      CDL:026765)

:0568 Phillips, R.E.;  Egli, D.B.; Thompson,  L.J.  (1972)
      Absorption of herbicides  by soybean seeds and  their
      influence on-emergence  and seedling growth.  Weed  Science
      20(5):  506.

-------
:0545  Purkayastha,  R. (1969)  Direct detection of ionizable
      herbicides by electrophoresis. Bulletin of Environmental
      Contamination and  Toxicology 4(4):  246-255.

:0569  Rieder, G.; Buchholtz,  K.P.; Kust,  Cyril A. (1970)  Uptake
      of herbicides by soybean seed. Weed Science 18(1):  101-105

:0514  Robens, J.F.  (1978)  Tests for possible carcinogenicity of
      20 pesticides in Osborne Mendel Rats and B-6C-3F-1  Mice.
      Toxicology and Applied  Pharmacology 45(1) 236.

:0571  Samosvat, L.S.; Voinova, I.V. (1973) Contribution to the
      determination of residues of herbicides and their
      metabolites in food  products by TLC. Vopros Pitaniia 32(1)
      11-78.

:0573  Sarpe, N.; Pyrzhol,  L.; Beliano, I. (1975) The influence
      of various herbicides on the physiological and biochemical
      changes in soybeans  and weed plants under conditions of
      irrigation.  Trudy Usesoyuznogo Nauchno-Issledova tel'
      skogo Instituta Zashchity Rastenii  43: 60-72.

:0574  Schrader, John W.; Doll, Jerry D.;  Meggit, William F.
      (1968) Injection of  herbicides for  soil placement and to
      study site of uptake in the field.  Proceedings of North
      Central Weed  Control Conference 23: 51-53.

:0160  Segal, H.S. (1961) Metabolite analysis 2,5-dichloroaniline
      in soybeans.   (Unpublished study received 4-3-67 under
      7F0591; CDL:090758)

:0105  Shaughnessy,  J.A. (1964) Evaluation of data for NR
      registration  for Amiben on corn.  (Unpublished study
      received 8-28-64; CDL:121499)

:0576  Sherma/ J.; Touchstone, J.C. (1975) Quantitative thin-
      layer chromatography of chloramben  herbicide using
      densitometry.  Chromatographia 8(6): 261-264.

:0130  Slife, F.W. (1964) The translocation of amiben in plants.
      (Study received 2-17-64 under 264-138; CDL:002092)

:0537  Stephenson, G.R.; Phatak, S.C.; Makowski, R.I.; Bouw,
      W.J.  (1980) Phytotoxic interactions involving  metribuzin
      and other pesticides in tomatoes. Canadian Journal  of
      Plant Sciences 60(1): 167-175.

:0578  Stoller, E.W.; Wax,  L.M. (1968) Amiben herbic  metabolism
      and selectivity. Weed Science 16(3): 283-288.

:0517  Stupnikov, A.A. (1977)  Prophylaxis  of animal poisoning
      with herbicides and  arboricides.  Veterinariya (Moscow) 6:
      89-91.
                                8

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:0074Sutherland, M.L. (1961) C14 Aniben ore-emerged  tracer
      study in soybeans.   (Unpublished study  received  7-26-61
      under 264-138; CDL:101239)

:0129 Sutherland, M.L.; Segal, H.S.  (1964) Araiben  residues in
      food crops.  (Study received 2-17-64 under 264-138;
      CDL:002092)

:0580 Swanson, C.R.; Hodgson, R.H.;  Kadunce,  R.E.; Swanson,
      H.R. (1966) Amiben metabolism  in plants II physiological
      factors in N-Glucosyl amiben formation. WEEDS  14(4):  323-
      327.

:0582 Taylor, T.D.; Warren, G.F. (1970) Movement of  several
      herbicides through excised plant tissue. Weed  Science
      18(1): 64-68.

:0581 Taylor, T.D.; Warren, G.F. (1970) The effect of  metabolic
      inhibitor.s on herbicide movement in plants. Weed Science
      18(1): 68-74.

:0090 U.S. Laboratories, Incorporated (1968) Recovery  of Amiben
      from dry lima beans, sweet corn, sweet corn forage,  sweet
      potatoes and soybeans.  (Unpublished report received
      10/25/68 under 7F0591; CDL:090759)

:0091 U.S Laboratories, Incorporated (1968) Recovery of Amiben
      from tomatoes, bell peppers, and summer squash.
      (Unpublished report received 10/25/68 under 7F0591;
      CDL:090759)

:0132 Warren, G.F. (1963) Adsorption of Amiben in soils.
      (Unpublished study received 2-17-64 under 264-138;
      CDL:002092)

:05113 Weber, J.B. Jr.  (1970)  Behavior of herbicides in soils.
       Beltwide Cotton  Production Research Conferences
       (Proceedings)  :35-36.

:0583  Welker,  W.V. Jr.; Brogdon, J.L. (1972)  Effects of
       continued  use of herbicides in asparagus  plantings.  Weed
       Science 20(5):  428.
                                              *ll S GOVERNMENT PRINTING OFFICE: 1981 341-085/4470

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