RBREGISTRATION ELIGIBILITY DOCOMENT

     ALUMINUM TRIi (fi-ETHYLIHOSIHONATE)
         (REFERRED TO AS FOSETYIi-Al J
                   LIST A
               DECEMBER 1990
      EKVIROKMENfAL PROTECTION AGENCY
       OFFICE OF PESTICIDE PR08RAHS
SPECIAL REVIEW AND RIREGISTRAtlON DIVISION
            WASHINGTON, D.C.

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                        TABLE OF CONTENTS

                                                             PAGE
GLOSSARY OF TERMS AND ABBREVIATIONS

EXECUTIVE SUMMARY


X.   INTRODUCTION                                               1

II.  ACTIVE INGREDIENTS COVERED BY THE REREGISTRATION DECISION  2
     DOCUMENT

     A.   IDENTIFICATION OF ACTIVE INGREDIENT                   2

     B.   USE PROFILE                                           2

     C.   REGULATORY HISTOBY                                    3

III. AGENCY ASSESSMENT OF ACTIVE INGREDIENT                     3

     A.   PRODUCT CHEMISTRY ASSESSMENT                          4

     B.   HUMAN HEALTH ASSESSMENT                               4

          1.   TOXICOLOGY DATA                                  4

               a.   ACUTE TQXICITY
               b.   CHRONIC TOXICITY
               c*   ONCOGENICITY
               d.   DEVELOPMENTAL TOXICITY AND REPRODUCTION
               e.   MUTAGENICITY
               f.   METABOLISM

          2.   DIETARY EXPOSURE                                 8

               a.   RESIDUE DATA
               b.   REFERENCE DOSE
               C.   TOLERANCE REASSESSMENT

          3.   NON-DIETARY EXPOSURE                            12

     C.   ENVIRONMENTAL ASSESSMENT                             13

          1.   ENVIRONMENTAL FATE ASSESSMENT                   13

          2.   ECOLOGICAL EFFECTS ASSESSMENT                   13

               ft.   ECOLOGICAL EFFECTS DATA
               b.   ECOLOGICAL EFFECTS RISK ASSESSMENT

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                        TABLE Of CONTENTS

IV.  REREGISTRATION DECISION TOR FOSETYL-A1                    IS

     A.   DETERMINATION OF ELIGIBILITY                         15

     B.   ADDITIONAL GENERIC REQUIREMENTS                      16

     C.   LABELING REQUIREMENTS                                17

V.   PRODUCT REREGISTRATIQN                                    18

     A.   DETERMINATION OF ELIGIBILITY                         18

     B.   PRODUCT-SPECIFIC DATA REQUIREMENTS                   18

     C.   LABELING REQUIREMENTS                                18

VI.  APPENDICES

     A.   GUIDE TO APPENDICES A i B                            20

     B.   APPENDIX A - GENERIC DATA REQUIREMENTS FOR
          REREGISTRATIQN OF FOSETYL-AL AND DATA CITATIONS
          SUPPORTING REREGISTRATION

               1. PRODUCT CHEMISTRY                            22
               2. ECOLOGICAL EFFECTS                           23
               3. TOXICOLOGY                                   24
               4. PLANT PROTECTION                             26
               5. NONTARGET INSECT-TESTING                     26
               6. ENVIRONMENTAL FATE                           2i
               7. RESIDUE CHEMISTRY                            27

     C.   APPENDIX B - PRODUCT SPECIFIC DATA REQUIREMENTS FOR
          PRODUCTS CONTAINING FOSETYL-AL AND DATA CITATIONS
          SUPPORTING REREGISTRATION OF MANUFACTURING AND END-USE
          PRODUCTS

               FOR MANUFACTURING-USE PRODUCTS
               1. PRODUCT CHEMISTRY                            30
               2. TOXICOI^GY                                   31

               FOR END-USE PRODUCTS
               1. PRODUCT CHIMISfRY                            33
               2. TOXICOLOGY                                   35

     D.   APPENDIX C - BIBLIOGRAPHY

               1. GUIDE TO APPENDIX C                          37
               2. BIBLIOGRAPHIC CITATIONS                      39
                              ii

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 ADI



 a. i.

 ARC

 CAS


 CSF

 EEC




 EP

 EPA

 FIFRA


 FFDCA

 HDT

 K+CWHR

 LC50
LD50
LDT


LEL


MP


MPT
      GLOSSARY OF TERMS AND ABBREVIATIONS

 Acceptable Daily Intake.   Also known as the Reference
 Dose or RfD.

 Active Ingredient

 Anticipated Residue Contribution

 Chemical Abstracts  Service

 Confidential  Statement of  Formula

 Estimated Environmental Concentration.   The estimated
 pesticide concentration in an  environment,  such as  a
 terrestrial ecosystem.

 End-Use Product

 U.S.  Environmental  Protection  Agency

 Federal Insecticide, Fungicide,  and  Rodenticide Act

 Federal Food,  Drug,  and Cosmetic Act

 Highest Dose  Tested

 Kernel  plus Cob  with Husk  Removed

 Median  lethal  concentration -  a  statistically derived
 concentration  of a substance that can be expected to
 cause death in 50% of test animals.  It  is  usually
 expressed  as  the weight of substance per weight or
 volume  of  water  or feed, e.g., mg/1  or ppm.

 Median  lethal  dose - a  statistically derived single
 dose that  can  be expected  to cause death in 50% of  the
 test animals,  when administered  by the route indicated
 (oral,  dermal, inhalation).  It  is expressed as a
weight  of  substance per unit weight  of animal,  e.g.,
»g/kg.

 Lowest  Dose Tested

Lowest  Effect  Level

Manufacturing Use Product

Maximum Permissible Intake
                               ill

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            GLOSSARY  OF  TERMS AND ABBREVIATIONS  CONT'D
MRID      Master Record Identification (number).  EPA's system of
          recording and tracking studies submitted to the Agency.
NPDES     National Pollutant Discharge Elimination System
NOEL      No Observed Effect Level
OPP       Office of Pesticide Programs
PADI      Provisional Acceptable Daily Intake
ppn       Parts per Million
RfD       Reference Dose
RS        Registration Standard
TMRC      Theoretical Maximum Residue Contribution
                               iv

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                        EXECUTIVE SUMMARY


     Fosetyl-Al is a fungicide registered in the United States
for use on almonds, asparagus, avocados, eaneberries, citrus,
ginseng, pome fruits, pineapples, stone fruits and ornamental
plants, lawns and turf.  There are two registered products;  95%
technical product and 80% wettable powder,  Products which
contain fosetyl-al as an active ingredient are eligible for
reregistration for the uses mentioned above.

     A registration standard entitled, "Guidance for the
Reregistration of Pesticide Products containing aliette as the
active ingredient" (pb 84-206564), was developed in 1983 in
conjunction with the initial reregistration of the chemical. A
draft revised registration standard for fosetyl-Al was issued for
public comment in December 1986, and issued in final in February
1988.  The registration standards summarized the available data
supporting the registration of fosetyl-Al and required additional
data to assure that the proper use of the pesticide poses no
potential adverse effects to human health or the environment.

     Recently, the Agency conducted a thorough review of the
scientific database and all relevant information supporting the
reregistration of fosetyl-Al, including the data submitted in
response to the registration standards.  The data base consists
of toxicology, residue and product chemistry, environmental fate,
ecological effects, and non-dietary exposure data (refer to
appendix a).  No further generic or product-specific data are
required.  The established tolerances are set at the appropriate
levels and no new tolerances are required to cover the existing
uses for the registered products.

     The data are sufficient to allow the Agency to conduct a
reasonable risk assessment for all registered uses of fosetyl-Al.
The Agency has determined for all registered uses that fosetyl-Al
can be used according to label directions without resulting in
unreasonable adverse effects.  Based on the data reviewed,  the
agency has determined that fosetyl-Al poses no unreasonable
adverse effect to human health and the environment and declares
that^products containing fosetyl-Al as an active ingredient are
eligible for reregistration and will be reregistered when
appropriate labels are submitted.

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I.    INTRODUCTION

          In 1988,  the Federal Insecticide,  Fungicide,  and
     Rodenticide Act (FIFRA)  was amended to   accelerate the
     reregistration of products with active  ingredients
     registered prior to November 1, 1984.   The amended Act
     provides a schedule for the reregistration process to be
     completed in nine years.  There are five phases to the
     reregistration process.   The first four phases of the
     process focus on identification of data requirements to
     support the reregistration of an active ingredient and the
     generation and submission of data to fulfill the
     requirements.   The fifth phase is a review by the U.S.
     Environmental Protection Agency (referred to as "the
     Agency") of all data submitted to support reregistration.

          Section 4 (g) (2)  (A) of FIFRA states that in Phase 5
     11 the Administrator shall determine whether pesticides
     containing such active ingredient are eligible for
     reregistration" before calling in data  on products and
     either reregistering products or taking "other appropriate
     regulatory action."  Thus, reregistration involves a
     thorough review of the scientific data  base underlying a
     pesticide's registration.  The purpose  of the Agency's
     review is to reassess the potential hazards arising from the
     currently registered uses of the pesticide; to determine the
     need for additional data on health and  environmental
     effects? and to determine whether the pesticide meets the
     "no unreasonable adverse effects" criterion of FIFRA.

          This document presents the Agency's decision regarding
     the reregistration of fosetyl-Al.  The  document consists of
     five sections.  Section I is this introduction.  Section II
     describes fosetyl-Al, its uses and regulatory history.
     Section III discusses the human health  and environmental
     effects assessment based on the data available to the
     Agency.  Section IV discusses the reregistration decision
     for fosetyl-Al and Section V discusses  product
     reregistration.  Additional details concerning the Agency's
     review of available data are available  on request.
          EPA's reviews of specific reports and information on the
          set of registered uses considered for EPA's analyses may
          be obtained from the OPP Public Docket, Field Operations
          Division  (H7506C),  Office of  Pesticide Programs,  EPA
          Washington, D.c.  20460.

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II.   ACTIVE INGREDIENTS COVERED BY THIS REREGISTRATIQN DECISION
     DOCUMENT
     A.   IDENTIFICATION OF ACTIVE INGREDIENT

               The following active ingredient is covered by this
          Reregistration Eligibility Document:

          Chemical Name: Aluminum tris (o.-ethylphosphonate)
                         (Referred to hereafter as fosetyl-Al)

          Common Name:   None2

          CAS Number:     39148-24-8

          Office of Pesticide Programs
          Chemical Code Number:     123301

          Empirical Formula:  A1(H6C203P}3

          Trade Name:     Aliette*

          Pesticide Chemical Code:  123301

          Case Number:   0646

          Basic Manufacturer: Rhone-Poulenc

     B,   USE PROFILE

          Type of Pesticide:  Systemic fungicide

          Pests Controlled:    Oomyceteous fungi causing damping-
                              off and rot of roots,  stems and
                              fruit.
          For the  purposes  of  this  document,  the name fosetyl-Al,
          is  used  rather than  Aluminum tris  (o_-ethylphosphonate).

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     Registered Use Sites:
          Terrestrial,  Foo(|
                               almonds (non-bearing)
                               asparagus
                               avocados (non-bearing)
                               caneberries
                               citrus   (bearing and non-
                                        bearing)
                               ginseng
                               pome fruits (non-bearing)
                               pineapples
                               stone fruits (non-bearing)

          Terrestrial,  Non-Food
                               ornamental herbaceous plants
                               ornamental lawns and turf

     Formulation Types Registered:  Technical - 95 percent
                                           active ingredient

                                   Formulation - 80 perc.ent
                                             wettable powder

     Methods of Application:       dip treatment; pre-plant
                                   soil incorporation?
                                   foliar; drench

C,   REGULATORS HISTORY

          Fosetyl-Al was first registered by the Agency in
     1983 for use on pineapples,  ornamentals and turf.  The
     uses of fosetyl-Al for foliar application to pineapple
     and to citrus were added in 1985 and 1986,
     respectively.  A Registration Standard was developed in
     1983 in conjunction with the initial registration of
     the chemical.  A draft revised Registration Standard
     for fosetyl-al was issued for public comment in
     December 1986.  No comments were received on this draft
     document.  This draft document was issued in final in
     February 1988 and listed the following data as required
     for reregistration;

          171-4     Storage Stability of Residues in
                    Pineapples and Citrus

          132-1     Foliar Dissipation

          122-2     Aquatic Plant Growth

          141-1     Honeybee Acute Contact LD50

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               Product chemistry and acute toxicity data on the
          formulated end-use product were also required to be
          submitted.

               Since 1988,  six new uses have been registered:
          avocados,  asparagus, pome fruits, stone fruits, almonds
          and caneberries.

III. AGENCY ASSESSMENT

          The Agency has conducted a thorough review of the
     scientific data base for fosetyl-Al.  Based on the
     evaluation of these data, the Agency has no reason to change
     the major findings made in the 1988 document "Guidance for
     the Reregistration of Pesticide Products Containing Fosetyl-
     Al."  These findings are summarized below:

     A.   Product Chemistry Assessment


               Fosetyl-Al is a white odorless powder that rael-ts
          with decomposition at temperatures greater than 200°
          celsius.  The solubility of fosetyl-al in water at 20°
          celsius is 120 grams per liter.  The chemical is stable
          under normal storage conditions.

     B.   Human Health Assessment

          1,   Toxicology Data Base

                    All toxicology data requirements are
               satisfied.  No further data were required in the
               1988 Guidance Document and no additional data have
               been submitted.  The results of the review of the
               toxicology data base are presented below;

               a.   Acute and Subchronic Toxicitv

                    The LD50 from the acute oral rat study  is  5.4
               g/kg and the LD50 from an acute dermal rabbit study
               is >2 g/kg.  The LC50 for  a rat  inhalation study
               is >1.73 mg/l.  The acute oral rat and primary
               dermal irritation studies indicate category IV
               toxicity.  A guinea pig dermal sensitization study
               shows fosetyl-Al is not a skin sensitizer.  The
               primary eye irritation study in rabbits shows
               fosetyl-Al to be an eye irritant with Category I
               toxicity.

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     A 21-day dermal study in rabbits showed mild
to moderate skin irritation and a No Effect Level
(NOEL) of 1.50 g/kg/day.  A 90-day feeding study
in rats showed a NOEL of >5000 ppm? the Lowest
Effect Level (LEL) was 25,000 ppm with
extramedullary hematopoiesis in the spleen.  A 90-
day dog feeding study showed a NOEL of 10,000 ppm
and a LEL at 50,000 ppm, at which the test animals
had a lower serum potassium level than untreated
animals.

b.   Chronic Toxicity

     Fosetyl-Al was fed to dogs for 2 years at
doses up to 40,000 pptn.  The NOEL was 10,000 ppm,
equivalent to 250 mg/kg/day. The LEL was 20,000
ppm based on a slight degenerative effect on the
testes.  These testicular changes, as well as a
few scattered clinical changes, were seen in the
high dose dogs.

c.   OncogervJcity

Rat

Oncogenic effects were noted in the rat chronic
feeding/oncogenicity study.  In this study,
Charles River CD rats were dosed with fosetyl-Al
at levels of 0, 2,000, 8,000, and 40,000/30,000
ppm {0, 100, 400, and 2,000/1,500 mg/kg bwt/dayj ,
The 40,000 ppm dose was reduced to 30,000 ppm
after 2 weeks following observations of staining
of the abdominal fur and red coloration of the
urine at 40,000 ppm (2,000 mg/kg bwt/day).

     The highest dose level of the chemical tested
in the male Charles River CD-I rats (2,000/1,500
mg/kg bwt/day)  in this study appears to be
adequate for assessing the carcinogenic potential
based on the finding of urinary bladder
hyperplasia at this dose.  Similarly the dose
level appeared to be adequate in the female
Charles River CD-I rats at the high-dose level of
2,000 ng/kg bwt/day during the first 2 weeks of
the oncogenicity/chronic feeding study, before the
dose level was reduced to 1,500 mg/kg bwt/day.

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     The study demonstrated a significant increase
of urinary bladder tumors (adenomas and carcinomas
combined) at the highest dose level tested
(2,000/1,500 mg/kg) in male Charles River CD-I
rats.  The tumors were mainly seen in surviving
males at the time of terminal sacrifice.  The
original pathological diagnosis of these tumors
was independently confirmed by another consulting
pathologist, who also reported an elevated
incidence of urinary bladder hyperplasia in high-
dose male rats.  No increase of urinary bladder
tumors was observed in female rats.

     Based on the diagnosis of the pathologist at
the test laboratory where the study was performed,
fosetyl-al appeared to produce a statistically
significant elevated increase of adrenal
pheochromocytomas  (adenomas and carcinomas
combined) at the middle  (400 mg/kg) and high
(2,000/1,500 »g/kg) dose levels in the male
Charles River CD-I rats.  The elevated
pheochromocytoma increase was primarily due to an
increase in the adenomas.  This diagnosis was not
confirmed by two other pathologists who
reevaluated the data.  The consulting pathologists
reread the adrenal gland slides and did not find
statistically significant dose-related increases
in the incidence of pheochromocytomas for the male
rats.  The Agency  attributes the difference in
pathological diagnoses to the fact that a high
degree of variability exists in the interpretation
of adrenal medullary neoplasia compared to adrenal
medullary hyperplasia in identifying
pheochromocytomas.  None of the three pathologists
reported a statistically significant increase in
the combined incidence of the three types of
adrenal medullary  lesions  (i.e., adenomas,
carcinomas, and hyperplasia).

     Based on the  available  information, the
Agency has concluded that fosetyl-Al did not
produce  a compound-related increase in adrenal
pheochromocytomas  in the high-dose male rats.  No
adrenal  gland tumors were produced in female rats.

     An  oncogenicity feeding study with monosodium
phosphite, which is a metabolite of fosetyl-Al,
was conducted in rats.   There was no evidence of
oncogenicity in this study.

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Mouse

     In a chronic oncogenicity study in mice,
fosetyl-Al was fed at levels up to 20,000/30,000
ppm.  Although this dose was extremely high and
may have approached a level that affected
nutrition, it produced no oncogenicity or other
toxic changes.

Classification of Oncogenic Potential

     The Agency has concluded that the available
data provide limited evidence of the oncogenicity
of fosetyl-Al in male rats and has classified the
pesticide as a category C oncogen (possible human
carcinogen with limited evidence of
carcinogenicity in animals) in accordance with
Agency guidelines, published in the Federal
Register of September 24, 1986 (51 FR 33992).  The
Agency has determined that a quantitative human
risk assessment using a low dose linear
extrapolation model is not appropriate for the
following reasons:

1.  The oncogenic response observed with this
chemical was confined solely to the high dose
males at one site (urinary bladder)  in rats.

2.  The tumor response was primarily due to an
increase in benign tumors,

3,  The tumors were seen only in surviving animals
at the time of terminal sacrifice.

4.  The oncogenic effects were observed only at
unusually high doses which exceed the commonly
used limit dose of 1 g/kg/day recommended as an
upper-limiting dose for bioassays.

5.  The chemical was not oncogenic when
administered in the diet to Charles River CD-I
mice at dose levels ranging from 2,500 to 30,000
ppm (357 to 4,286 mg/kg bwt/day).

6.  Fosetyl-Al was not mutagenic in eight well
conducted genotoxicity assays.

     The Agency concludes that data do not
demonstrate developmental or reproductive effects
of concern.

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<3.    Developmental Toxicity

Rat Teratology

      A teratology study  in rats showed a
developmental NOEL of  1,000 ing/kg.  At 4,000 rag/kg
there was maternal toxicity, as evidenced by
effects  on animal weights, maternal deaths,
increased resorptions, and delayed fetal
ossification,

Rabbit Teratology

      A rabbit teratology study showed no toxic
effects  at oral doses  up to 500 mg/kg.

Rat Reproduction

      A three generation rat reproduction study had
a NOEL of 6,000 ppm.   The LEL at 12,000 ppm showed
effects  on animal weights in some groups and
urinary  tract changes  in some groups.

MUTAGENICITY

      Eight mutagenicity tests performed with
fosetyl-Al were negative.  The tests included two
Antes  tests with S. typh iamrium, two phage
induction tests using  E. coli, two mieronucleus
tests in Swiss mice and CD-I mice, one DNA repair
test  using E_, coli.  and one saccharomyces
cereviseae assay.  Fosetyl-Al is not a routagen.

e.    METABOLISM

      Rat metabolism studies showed that most of
the radiolabel rapidly appeared in exhaled carbon
dioxide.  There was also some radio-label excreted
in the urine as phosphite, along with a smaller
amount as the unchanged parent compound.  It
appears that fosetyl-Al is essentially completely
absorbed after ingestion and extensively
hydrolyzed to carbon dioxide which is exhaled.
The phosphite is excreted in the urine without
further oxidation to phosphate.

DIETARY EXPOSURE

     All residue chemistry data retirements have
been satisfied.
                 8

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     a.   Residue Data

          Tolerances have been established in 40 CFR
          180.415 for residues of fosetyl-Al in or on
          the following raw agricultural commodities:

          Commodity                     Tolerance(ppmj

          Asparagus                       0.13
          Caneberries                     0,1
          Citrus                          0.5
          Ginseng root, fresh             0.1
          Pineapple                       0.1
          Pineapple Fodder                0.1
          Pineapple Forage                0.1

          There are no Codex (international) tolerances
          for fosetyl-Al.  The Agency has evaluated the
          residue data supporting the established
          tolerances.  These data are summarized below:

          Metabolism Data

               The metabolism of fosetyl-Al is
          adequately understood.  Adequate data on the
          nature of the residues in both plant and
          animals, including identification of major
          metabolites and degradates of fosetyl-Al are
          available.  The major residues were fosetyl-
          Al, phosphorous acid, and ethanol.  The
          tolerances are established for the parent
          only, that is, fosetyl-Al.

               There is no reasonable expectation of
          residues occurring in milk and meat of
          livestock and poultry,  A statement on the
          label prohibits the grazing of livestock in
          treated citrus groves and feeding forage from
          treated groves.  Accordingly, tolerances in
          meat, animal by products, and milk are not
          necessary.
These   tolerances   are   associated   with   regional
registrations as  defined  in 40 CFR Section  180.1 (n) .
Fosetyl-Al is registered  for use on asparagus  only  in
California? and on ginseng in Wisconsin only.

                      9

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     Radio labeled studies on the uptake,
translocation and metabolism of fosetyl-Al in
plants show that the chemical proceeds
through hydrolytic cleavage of the ethyl
ester, with phosphorous acid and most likely
ethanol as the major plant metabolites.

Analytical Methodology

     There are two analytical methods
acceptable for determining the levels of
residues of fosetyl-Al in plants:  a gas
chromatography method for pineapples with an
analytical sensitivity of 0.1 ppra and a
phosphorous specific flame photometric gas
chromatography method for citrus with an
analytical sensitivity of 0.02 ppm.

     The only additional residue data
required in the 1988 Guidance Document were
storage stability of residues in pineapples
and citrus.  These data are currently under
development but are not essential to the
reregistration decision on these commodities
for the following reasons:

1.   No detectable residues of fosetyl-Al
     have been observed in any of the residue
     trials performed on pineapples.  Some of
     these trials reflected exaggerated
     application rates and Pre-Harvest
     Interval (PHI's) as short as 90 days.

2.   Pineapples spiked with fosetyl-Al and
     stored at -18°C showed a 66 to 90%
     decrease of residues of this chemical
     within 1 to 2 months.  It is the
     Agency's judgement that residues of
     fosetyl-Al would decrease at even faster
     rates at higher temperatures, especially
     during a 90 day PHI, thus making the
     possibility of observing any detectable
     residues on pineapples extremely remote,

Magnitude of the Residue

     There are adequate residue studies to
support the existing tolerances.
            10

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b»   Tolerance,. Reassessment

          The data submitted have been evaluated
     and adequately support the existing
     tolerances established on fosetyl-Al as
     listed in Section 2b of this document.  The
     established tolerances are  set at the
     appropriate levels and no new tolerances are
     required to cover the existing uses for the
     registered product.

c.   Reference Dose and Dietary Risk Assessment

          The following data were considered for
     establishing the Reference Dose (RfD) for
     fosetyl-Al:

     Study                              Species

Chronic Toxicity (2 year)               Dog
Chronic Toxicity/Oncogenicity           Rat
3-Generation leproduction               Rat
Teratology                              Rat
Teratology                              Rabbit

     Using a 100-fold safety factor to account for
inter - and intra-species differences and the NOEL
of 250 mg/kg bwt/day determined by the 2-year dog
feeding study, the RfD is 3.0 mg/kg bwt/day
(rounded to the nearest whole number).   The effect
observed in the chronic dog study was a slight
degeneration of the testes.  This study is
acceptable along with all of the other studies
considered in establishing the RfD.  Therefore,
the RfD is given a high confidence rating.
                11

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     The Theoretical Maximum Residue Contribution
(TMRC) from the established  tolerances is
0.000274 mg/kg/bwt/day and utilizes less than i.o
percent of the RfD based on the average American
dietary intake.  The dietary exposure of subgroups
(e.g., children and infants) also did not exceed
the RfD.  Therefore, the dietary risK from
fosetyl-Al is very low.

Non-Dietary Exposure

     Fosetyl-Al is a systemic fungicide registered
for use on several raw agricultural commodities
and ornamentals.  Methods of application include
foliar application to pineapples and citrus and
thus, fieldworker exposure can be expected.
Fosetyl-Al is a severe eye irritant but does not
produce dermal irritation.  In addition, fosetyl-
Al exhibits a low degree of oral, dermal, and
inhalation toxicity.  Reentry data (foliar
dislodgeable residue dissipation) were required by
the 1988 Fosetyl-Al Reregistration Guidance
Document.

     In support of reregistration of fosetyl-al,
the registrant submitted a foliar dislodgeable
residue dissipation study.  The study was reviewed
and found to be unacceptable to fulfill the
guideline requirement.  However, the Agency has
reevaluated the reentry data requirements based on
the toxicity data for fosetyl-Al.  Reentry data
are required to determine the correlation between
foliar dislodgeable residue levels and dermal
exposure to fieldworkers.  Since eye irritation is
the toxicological end point of concern for
fosetyl-Al and dermal exposure is not a concern,
reentry data are not required to support the
reregistration of fosetyl-Al.

     Label requirements for products containing
fosetyl-Al are specified in Section IV C and V C.
                12

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C.   ENVIRONMENTAL ASSESSMENT

          All environmental fate and ecological effects data
     requirements have been satisfied.   No further environmental
     fate data were required in the 1988 Guidance Document.
     Additional ecological effects data were required in the 1988
     Guidance Document.

               122-2     Aquatic Plant  Growth

               141-1     Honey Bee Acute Contact LD50

          These studies have been submitted, reviewed,  and
     determined to be acceptable.  The  results are discussed
     below.

     1.   Environmental Fate Assessment

               The potential for groundwater and/or surface water
          contamination by fosetyl-Al and its degradates is
          expected to be very low, in most cases, due to the
          rapid degradation of the compound in soil to non-toxic
          degradates under both aerobic and anaerobic conditions.
          Data have shown that fosetyl-Al is much more persistent
          on vegetation than in soil.  Therefore, when applied
          foliarly to vegetation, may be available for wash off
          followed by dissolved runoff to surface water for a
          much longer period than might be predicted based upon
          its rapid degradation in soil.  In addition,  due to its
          high aqueous solubility, susceptibility to leaching,
          and stability to abiotic hydrolysis, fosetyl-Al may
          possibly leach to ground water (in porous areas with
          extremely shallow unconfined aquifers or outcroppings)
          in cases where an unexpected heavy rainfall closely
          succeeds application.

     2.   Ecological Effects Assessment

          a.   Ecological Effects Data

                    In the 1988 Guidance Document, the ecological
               effects data base was reviewed and determined to
               be essentially complete except for two guideline
               data requirements:  honey bee acute contact LD50
               and aquatic plant growth.  These studies which are
               discussed below, have been submitted, reviewed and
               determined to be acceptable.
                                13

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Non-target Insects

     An acute contact toxicity test with honey bees was
conducted, the LD50 for the honey bee is greater than
100 ug/bee, the highest concentration tested for
technical fosetyl-Al (95% a.i.).  Fosetyl-Al is
practically non-toxic to honey bees,

Aquatic Plant Growth

     Five aquatic plant growth studies were performed
with technical fosetyl-Al (95% a.i.)-  The^ECgo values
for the following five species were determined to be;

          SPECIES                       EC,D VALUE

NAVICULA PELLICULOSA                         8.93 MG/L
LEMMA GIBBA                                 56.13 MG/L
SKELETONEMA COSTATUM                         0.84 MG/L
ANABAENA FLOS-AQUAE                          7.24 MG/L
gELENASTRUM CAPRI.CORNUTUM                    4,99 MG/L

b.   Ecological Effects Risk, Assessment

          For the 1988 Guidance Document, all available
     data were reviewed and no risk to non-target
     species was identified from the registered uses of
     fosetyl-Al.

          In the intervening time from 1988 to the
     present, six new uses for fosetyl-Al have been
     registered:  avocados, asparagus, apples and
     pears, stone fruit, almonds and caneberries.  No
     additional testing is required for the new
     registered uses.  An assessment of the new uses is
     presented belows

     1.   A review of the caneberry use indicates no
          risk to non-target species.

     2.   Because of similar application rates and
          similar uses previously approved, the use on
          asparagus and avocados should not present a
          risk to non-target species.

     3.   A risk assessment on stone fruit  (apple/pear)
          and almonds indicate that fosetyl-Al poses no
          risk to non-endangered species,* but a concern
          is raised for endangered freshwater mussels
          resulting from a biological opinion about
          other pesticides used on apples and pears.
                      14

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                    The estimated environmental concentration
                    from run off into adjacent ponds is 122
                    ppb which is larger than 1/20 (95 ppb) of the
                    oyster/embryo larvae EC50 of 1900 ppb.
                    Therefore, the endangered species level of
                    concern was exceeded for the apple/pear use.

                    The above consideration constitutes a "May
                    Effect" finding for the endangered mussel.
                    In accordance with the Memorandum of
                    Understanding with Fish and Wildlife Service
                    (FW.S), the Agency has formally consulted the
                    FWS regarding the reregistration of fosetyl-
                    Al on pome fruits, as required by Section 7
                    of the Endangered Species Act.  As part of
                    this consultation, the Agency has provided
                    the FWS with the data and analysis upon which
                    the "May Effect" determination was based.

                    The FWS will decide whether the use of
                    fosetyl-Al will pose jeopardy to the
                    endangered mussels and, if so, what actions
                    the Agency must take to avoid jeopardy.  At
                    this time,  the FWS has not made a
                    determination on this issue.  If the FWS
                    determines jeopardy, it also will indicate
                    the geographic areas in which any label
                    restrictions will apply.  At that time, EPA's
                    Endangered Species Protection Program will
                    implement the appropriate actions needed to
                    protect endangered species,

                    Except for the endangered mussel concern, the
                    Agency believes that currently registered
                    uses of fosetyl-Al will not adversely affect
                    non-target species.  Data required in the
                    1988 Guidance Document were received and
                    indicated no new potential risk and the
                    ecological effects data base is complete.  No
                    changes in labeling will be required with the
                    exception of possible endangered species
                    restrictions.
IV.  REREGISTRATION DECISION FOR FOSETXL-A1
     A.   DETERMINATION OF ELIGIBILITY FOR REREGISTRATION

               Section 4 (g)(2)(A)  of FIFRA calls for the Agency
          to determine, after submission of relevant data
          concerning an active ingredient,  whether products

                               15

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    containing the active ingredient are eligible for
    reregistration.  The Agency has previously identified
    and required the submission of all the generic (i.e,..,
    active-ingredient specific) data required to support
    reregistration of products containing fosetyl-Al as an
    active ingredient.  The Agency has completed its review
    of these generic data, and has determined that the data
    are sufficient and complete to support reregistration
    of products containing fosetyl-Al and support the
    existing tolerances established on fosetyl-Al.
    Appendix A identifies the generic data requirements
    that the Agency reviewed as part of its determination
    of reregistration eligibility of fosetyl-Al, and lists
    the submitted studies that the Agency found acceptable.

         The data identified in Appendix A were sufficient
    to allow the Agency to conduct a reasonable risk
    assessment for all registered uses of fosetyl-Al and to
    determine for all such uses that fosetyl-Al can be used
    without resulting in unreasonable adverse effects on
    the environment.  The Agency therefore finds^hat all
    products containing fosetyl-Al as an active ingredient
    are eligible for reregistration.  The reregistration of
    particular products is addressed in Section V of this
    document  ("Product Reregistration").

         The Agency made  its reregistration eligibility
    determination based upon the target data base required
    for reregistration, the current guidelines for
    conducting acceptable studies to generate such data,
    and the data  identified in Appendix A.  Although the
    Agency has found that products containing fosetyl-Al
    are eligible  for reregistration, it should be
    understood that the Agency may take appropriate
    regulatory action, and/or  require the  submission of
    additional data to support registration of products
    containing fosetyl-Al,  if  new  information comes to the
    Agency's  attention or if the data requirements  for
    registration  (or  the  guidelines  for generating  such
    data)  change.

B.  Additional Generic Data Requirements

          The  generic  data base supporting  the
     reregistration of products containing  fosetyl-Al has
    been reviewed and determined  to  be  complete.   No
     further generic data  are  required to  support
     reregistration.
                           16

-------
C.   labeling Requirements for Manufacturing-Use Products
     Containing Fosetyl-Al

     1.   The labels and labeling of all products must
          comply with EPA's current regulations and
          requirements as outlined in the Product
          Reregistration Handbook.

     2.   Based on the reviews of the generic data, the
          following additional label statements are
          required:

          a.   All manufacturing-use products must state
               that they are intended for formulation into
               end-use products for which the use pattern is
               supported for reregistration.

          b*   In the directions for use, the following
               statement must appear:

               "Formulators using this product are
               responsible for obtaining EPA registration of
               their formulated products.11

          c.   In the directions for use, the following
               statement regarding acceptable use patterns
               must appears

               "For formulation into end-use fungicide
               products intended only for (list acceptable
               sites)."

          d.   If detailed instructions for formulating are
               not provided on the labelt the following
               statement roust appear:

               "Refer to attached Technical Bulletin for
               formulating and other information."

               NOTE:  The technical bulletin roust be
               submitted with the product label for Agency
               review.

          e.   "Do not discharge effluent containing this
               product into lakes, streams, ponds,
               estuaries, oceans or public waters unless
               this product is specifically identified and
               addressed in an NPDES permit.  Do not
               discharge effluent containing this product to
               sewer systems without previously notifying
               the sewage treatment plant authority.  For
                           17

-------
                    guidance contact your State Water Board or
                    Regional Office of the EPA."

                    "Pesticide Handlers:   Daring mixing,  loading,
                    or formulating of this product,  wear long
                    pants (or coveralls), long sleeved shirt,
                    shoes,  socks,  goggles or face shield,  and
                    chemical/water resistant gloves."
V.   PRODUCT REREGISTRATIQN

     A.   Determination of EligibilitY

               All products currently registered containing the
          active ingredient fosetyl-Al are eligible for
          reregistration.  The Agency may require submission of
          additional data before establishing any new uses.
          Section 4(g)(2)(B) of FIFRA calls for the Agency to
          obtain any needed product-specific data regarding the
          pesticide by use after a determination of eligibility
          has been made.  No such data is needed at this time,

               The Agency has previously identified and required
          the subaittal of all product-specific data required to
          support the reregistration of products containing
          fosetyl-Al as an active ingredient.  The Agency has
          completed its review of the product-specific data and
          has determined that the data are sufficient to support
          the reregistration of the one currently registered
          product containing fosetyl-Al.

     B.   Product Specific Data Requirements

               There are no additional product-specific data
          required.

     C.   Labeling Requirements., for End-Use Products Containing
          Fosetyl-Al

          1.   The labels and labeling of all products must
               comply with EPA's current regulations and
               requirements.  Follow the instructions in the
               Product Reregistration Handbook with respect to
               labels and labeling.

          2.   Based on the reviews of the generic data the
               following additional label statements are
               required.

               a,   "Do not apply directly to water, swamps,
                    bogs, marshes, and potholes.  Do not

                                18

-------
          contaminate water when disposing of rinsate
          or equipment washwaters.11

     b.    "Do not enter into treated areas for 24 hours
          after application.  During early reentry into
          treated areas to perform hand labor tasks,
          wear long pants (or coveralls),  long-sleeved
          shirt, shoes, socksr chemical/water resistent
          gloves,' goggles or face shield."

3,   End-use products labelled for use on citrus are to
     bear the following statements

          "Do not graze livestock in treated citrus
          groves.  Do not feed forage from treated
          groves."

     Labels of currently registered products must be
     amended to include this statement and must be
     submitted within 8 months of issuance of this
     document as described in the Product
     Reregistration Handbook.
                      19

-------
                   GUIDE TO APPENDICES A AND B

     Appendix A contains listings of data requirements which
support the reregistration for the pesticide covered by this
Reregistration Eligibility Document.

     Appendix A contains generic data requirements that apply to
     the pesticide in all products, including data requirements
     for which a "typical formulation" is the test substance.

     The data table are generally organized according "to the
following formatj

     1.   Data Requirement (Column 1).  The data requirements are
listed in the order in which they appear in 40 CPR Part 158.  The
reference numbers accompanying each test refer to the test
protocols set out in the Pesticide Assessment Guidelines, which
are available from the National Technical Information Service,
5285 Port Royal Hoad, Springfield, VA  22161.

     2.   Use Pattern (Column 2),  This column indicates the use
patterns to which the data requirement applies.  The following
letter designations are used for the given use patterns:

     A    Terrestrial food
     B    Terrestrial feed
     C    Terrestrial non-food
     D    Aquatic food
     E    Aquatic non-food outdoor
     F    Aquatic non-food industrial
     G    Aquatic non-food residential
     H    Greenhouse food
     I    Greenhouse non-food crop
     J    Forestry
     K    Residential
     L    Indoor food
     M    Indoor non-food
     K    Indoor medical
     O    Indoor residential

     Any otner designations will be defined in a footnote to the
table.

     3.   Bibliographic citation  (Column 3).  If the Agency has
acceptable data in its files, this column lists the identifying
number of each study.  This normally is the Master Record
Identification (MRID) number, but may be a GS number if no MHID
number has been assigned.  Refer to the Bibliography Appendices
for a complete citation of the study.
                                20

-------
                APPENDIX  A

Generic Data Requirements for Reregistration
      of  Fosetyl-Al and Data  Citations
         Supporting Reregistration
                     21

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-------
 APPENDIX C




BIBLIOGRAPHY
     36

-------
                       GUIDE TO APPENDIX C

1.   CONTENT OF BIBLIOGRAPHY.   This bibliography contains
     citations of all studies considered relevant by IPA in
     arriving at the positions and conclusions stated elsewhere
     in the Seregistration Eligibility Document.  Primary 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.  Selections from other sources
     including the published literature, in those instances where
     they have been considered, will be included,

2.   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 the
     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.

3.   IDENTIFICATION OF ENTRIES.  The entries in this bibliography
     are sorted numerically by Master Record Identifier," or MRID
     number.  This number is unique to the citation, and should
     be used at any time specific reference is required.  It is
     not related to the six-digit ''Accession Number" which has
     been used to identify volumes of submitted studies,* see
     paragraph 4(d)(4) below for further explanation.  In a few
     cases, entries added to the bibliography late in the review
     may be preceded by a nine-character temporary identifier.
     These entries are listed after all MRID entries.  This
     temporary identifier number is also to be used whenever
     specific reference is needed.

4.   FORM OF ENTRY.  In addition to the Master Record Identifier
     (MRID), each entry consists of a citation containing
     standard elements followed, in the case of material
     submitted to EPA, by a description of the earliest known
     submission.  Bibliographic conventions used reflect the
     standards of the American National Standards Institute
     (ANSI), expanded to provide for certain special needs.

     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 identifiable laboratory or testing  facility as
          author.  As a last resort, the Agency has shown the
          first submitter as author.

                                37

-------
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 mark the bibliographer deduced the date
     from evidence in the document.  When the date appears
     as (19??), the Agency was unable to determine or
     estimate the date of the document.

c.   Title.  In some cases, it has been necessary for^Agency
     bibliographers to create or enhance a document title.
     Any such editorial insertions are contained between
     square brackets.

d.   Trailing parentheses.  For studies submitted to the
     Agency in the past, the trailing parentheses include
      (in addition to any self-explanatory text) the
     following elements describing the earliest known
     submission:

      (1)  Submission date.  The date of the earliest known
          submission appears immediately following the word
          "received."

      (2)  Administrative number.  The next element,
          immediately  following the word "under," is^the
          registration number, experimental use 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  to the submitter, this
          element  is  omitted.

      (4)  Volume Identification  (Accession Numbers).  The
           final element  in the trailing  parentheses
           identifies  the  EPA  accession number  of  the  volume
           in  which the original  submission of  the study
           appears.  The  six-digit  accession  number follows
           the symbol  "CDL," standing  for "Company Data
           Library."   This accession number  is  in  turn
           followed by an  alphabetic suffix which  shows  the
           relative position of  the study within the volume.
           For example, within accession  number 123456,  the
           first  study would be  123456-A?  the second,  123456-
           &',  the  26th, 123456-Z,'  and  the 27th, 123456-AA.
                           38

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00098325 Rhone-Poulenc Chemical Company (1981)  Product Chemistry:
            [Fosetyl- all.   Includes method LS  74.783  dated
            Jul 7,  1980,  method dated May 7, 1981 and  undated
            method RE-ie-81.   (compilation| unpublished study
            received Apr  5,  1982 under 3f9-70i? CDLJ2471S9-A)

00098326 Bertrand,  A, (1981)  Fosetyl-ali  Composition of the
            Technical Grade  Industrial Product  (Analysis of S
            Typical latches)* Refs  AG/CRLD/An Al/SV Ii4.
            Includes method  P-286-06-80 and method
            P.306.03.81,   (Unpublished study received  Apr S, 1982
            under 359-705; prepared by Ihone-Poulenc Agrochimie,
            France, submitted by Rhone-Paulenc  Chemical Co.,
            Monmouth, Junction, N.J.; CDL:247159-B)

 00098327 Rhone Poulenc-Agrochimie  (1980}  Fosetyl-al ex ca
            (O-ethyl Phosphonate Salts of Aluminium or Calcium)
            Lodometric Determination in the Technical  Compounds
            and Formulations.  Method P-286-06-80 dated Jul 17,
            1980.  (Translation? unpublished study received
            Apr S,  1982 under 359-705; submitted by Rhone-Poulenc
            Chemical Co., Monmouth  Junction, N.J.; CDLJ247159-C)

00058328 Rhone-Poulenc Agrochimie (19??)  Fosetyl-al Technical
            Stability to  Heat, Inflammability Ixplosivityt
            AG/RD/DARGOIRE SRPH JD/NC/177.  (Unpublished study
            received Apr  S,  1982 under 359-705j submitted
            by Rhone-Poulenc Chemical Co., Monmouth Junction,
            N.J.f CDLJ247159-D)

00098330 Pasguet, J.; Mazuret, A.;  Maratrat, 7; et al. (1977) LS
            74-783  (Aluminium Ithyl Phosphite;  32 S4i  R.P.,
            Aluminium Salt):  Acute  Toxicity in  the Rat and
            Rabbit: R.P./R.D./C.N.S. No.  19 143-E.  (Translation?
            unpublished study received Apr S, 1982 under 359-705;
            prepared by Rhone-Poulenc, France,  submitted by
            Rhone-Poulenc chemical  Co., Monmouth Junction, N.J.;
            CDLS247160-B)
                               39

-------
00098331 Pasguet,  J.J Mazuret,  A.I  Kalifat,  R. f  et al.  (1981)
            Fosetyl-al (32 545  R.F.,  Aluminium Salt)! Acute
            Percutaneous foxicity in  the Rabbit: Reference C.R.
            vitry/C.K.S. Ho.  21 162-E.   (Translation; unpublished
            study received Apr  5, 1982  under 359-705; prepared by
            Rhone-Poulenc industries, France, submitted by
            Rhone-Poulenc Chemical Co., Monmouth Junction, N.J.;
            CDL:247160-C)

00098332 Coombs, D.W.I Clarle, 6.C.  (1977) Acute  Inhalation
            Toxicity in Ratss Four Hour Exposure to the Dust of
            LS 74.783 (Technical):  RHP 79/77546.  (Unpublished
            study received Apr  S, 1982 under 359-705j  prepared by
            Huntingdon Research centre, England, submitted by
            mhone-Poulenc Chemical Co., Monmouth Junction, N.J.;
            CDLJ247160-D)

00098333 Pasquet, J.; Mazuret,  A.; Maratrat, ?;  et al.  (1981)
            Fosetyl-al  (32 54S  R.P.,  Aluminium Salt)J  Primary Eye
            irritation in the Rabbits Reference C.R, Vitry/C.N.G.
            Ho. 21 163-B.  (Translation; unpublished study   .
            received Apr 5, 1982 under 319-705;  prepared
            by Rhone-Poulenc Industries, France, submitted by
            Rhone-Pouleno Chemical Co., Monmouth Junction, N.J.;
            CDLS247160-E)

00098334 Pasquet, J.; Mazuret,  A.j Maratrat, fl  et al.  (1981)
            Fosetyl-al  (32 545 R.P.,  Aluminium Salt):  Primary
            SJcin Irritation in the Rabbits Reference C.R.
            vitry/C.N.G. Ho. 21 164-E.   (Translation;  Unpublished
            study received Apr 5, 1982 under 359-705;  prepared
            by Rhone-Poulenc Industries, France, submitted by
            Rhone-Potilenc Chemical Co., Monmouth Junction, H.J.?
            CDL:247160-F)

00098335 Elliott, P.H.;  Beaber, J.A.  (1979) Screening Test for
            Delayed  Contact Hypersensitivity with Efosite-al  (LS
            74_783)  in  the Albino Guinea Pig: 79443D/RNP/168.
            (Unpublished study received Apr  i,  1982 under
            359-705; prepared by Huntingdon Research Centre,
            England, submitted by Rhone-Poulenc Chemical  Co.,
            Monmouth Junction, N.J.? CDL:247160-S)

00098336 Coquet, B.; Guyot, D.; Galland, L.; et al. (1977) LS
            74783! 3 Month Oral Toxicity study  in the Rats IFR1B
            R 770359.   (Translation; unpublished study received
            Apr 5, 1982  under  359-705; prepared by  Institute
            Francais de Recherches et  Essais Biologigues,
            France,  submitted  by Rhone-Poulenc  Chemical Co.,
            Monmouth Junction, K.J.? CDLS247161-A)
                                40

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000§8337 Coquet, B.I Glair, M.  (1977)  LS 74783 {aluminium
            Ethylphosphite) s 3  Month oral Toxicity Study in the
            Dogs 1FREB-R 712110.   A translation of: LS 74783
            (Ithylphosphite D1Aluminium)! Toxicite a Terme (3
            Mois) par Voie Orale  Chez le Chiem IPREB-R 709235.
            (Unpublished study  received Apr I, 1982 under
            359-705? prepared by  Institut Franeais de Reeherehes
            et Issais Biologicpies, France, submitted by
            Rhone-Poulenc chemical Co., Monmouth Emotion, H.J.?
            CDLJ247161-B)

 00098331 Kynoch, S.R.t Lloyd,  G.K.i Mallard, J.R.? et al, (1979)
            The Effect of Repeated Applications of LS 74783
            Technical to the Skin of Rabbits for Twenty-one Days:
            RHP/123/79314.  (Unpublished study received Apr 5,
            1982 under 319-705? prepared by Huntingdon
            Research Centre, England, submitted by Rhone-Poulene
            Chemical Co., Monmouth, H.J.? CDL:247161-C)

 00098339 Spicer, E.J.F.? Trumbull, R.R.? Blanchard, G.L.? et al.
            (1981) Chronic Toxicity (2 Year) and Carcinogenicity
            Study in Ratss 347-016.   (Unpublished  study received
            Apr  S, 1982 under 359-705? prepared by international
            Research and Development Corp., submitted by
            Rhone-Poulenc chemical Co., Monmouth Junction, H.J.j
            CDLt247162~A? 247164; 247165? 247166)

 0009S340 Spicer, B.J.F.i Phillips, L.M.,' Richter, w.R.f at al.
            (1981) Two-year Dietary Toxicity Study in Dogs! IRDC
            Study No* 347-023. (Unpublished study  received Apr  5,
            1982 under 359-705| prepared by international
            Research and Development Corp., submitted by
            Rhone-Poulenc Chemical Co,,  Konmouth Junction, K.J.?
            CDLS247167-A)

 00098343 Bouanchaud, D.H.I  Cartier, J.R.»* Vessieres, ?  (1981)
            Fosetyl-al  (32  S4S R.P., Aluminum  Salt)s
            Supplementary  studies of Mutagenesis  in
            Microorganisms! C.R.  Vitry/C.N.G.  M'os 21  212.
             (Unpublished  study received  Apr  5,  1982  under
            359-705? prepared by  Rhone-Poulenc industries,
            Prance,  submitted by  Hhone-Foulenc Chemical Co.,
            Monmouth Junction, N.J.t  CDLs247l?3-B)

 00098345 Cordier, A.I  Fournier, 1.? Viziere,  ? (1981)  Fosetyl-al
             (32 Sys R.P.,  Aluminium  Salt): Micronuoleus Test in
            the Mouse  by the Oral Routes  Reference C.R.
            Vitry/C.N.G.  Ho. 21  186-E.   (translation,  unpublished
            study received Apr 5, 1982  under 359-705?  prepared by
            Rhone-Poulenc industries,  France,  submitted by
            Rhone-Poulenc Chemical  Co.,  Monmouth  Junction,  N.J.?
            CDL:247173-D)

                                41

-------
00098347 Pasquet, j.f Le Bail, R.j Cegeral, ? (Ii7«) Compound LS
            74-783? Oral Teratogenicity Study in the Rabbits
            Report R.P./R.D./C.N.G, No. 18917-F.  (Translation?
            unpublished study received Apr 5, 1S82 under 359-705?
            prepared by Rhone-Poulene, France, submitted by
            Rhone-Poulenc Chemical Co., Monmouth Junction,
            N.J.? CDL:247174-A)


00098348 Palmer, A.X.? Bottomley, A.M.? Barton,  S.J.j at al.
            (1981) Effect of LS 74-783 on Reproductive Function
            of Multiple Generations in the Rat:  RNP/89/80745.
            {Unpublished study received Apr 5, 1982 under
            359-705? prepared by Huntingdon Research centre,
            England, submitted by Rhone-Poulenc Chemical Co.,
            Monmouth Junction, N.J.; CDL:247174-C)

00098352 epicer, E.J.P.; Phillips, L.M.j Blanchard, G. f et al.
            (1981) Life-time Chronic Toxicity and Carcinogenicity
            Study in Satss IRDC Study No. 347-022.  (Unpublished
            study received Apr 5, 1982 under 359-705? prepared by
            International Research and Development Corp.,
            Submitted by Rhone-Poulenc Chemical  Co., Monmouth
            Junction,  N.J.? CDLJ247176-A? 2471771 247178? 247179?
            247180; 247181; 247182)

00098353 Spicer, E.J.r.i Phillips, L.K.I Richter, W.R.j et al,
            (1981) 24-month Careinogenieity study in Micej
            347-021.  (Unpublished study received Apr S, 1982
            under 359-705; prepared by international Research and
            Development Corp., submitted by Rhone-Poulenc
            Chemical Co., Monmouth Junction, N,J.? CDL:247168-R;
            247169? 2471701 247171)

 00098358 Caillard, C.G.? Deregnaucourt, J.? Garret, C.? et al.
            (1980) Monoethylphosphonic Acid, Aluminium Salt (LS
            74 783 = 32 545 R.P., Aluminium Salt): Effects in a
            Number of  Pharmacological Testss R.P./R.D./C.N.G. No.
            20 680-E.   (Translation? unpublished study received
            Apr 5, 1982 under 359-705? prepared  by Rhone-Poulene,
            France, submitted by Rhone-Poulenc Chemical Co., Mon-
            mouth Junction, N.J.? CDL:247183-E)

00098360 Roberts, N.L.; Phillips, C.N.K. (1981)  The Acute Oral
            Toxieitv (LD550") of LS 74.783 to the Bobwhite Quails
            RNP 189 WL/81148. Final rept.   (Unpublished study
            received Apr 5, 1982 under 359-705?  prepared by
            Huntingdon Research Centre, England, submitted
            by Rhone-Poulenc Chemical Co., Monmouth Junction,
            N.J.; CDL:247184-B)
                               42

-------
00098362 Roberts, N.L.? Phillips, C.H.K.f Almond, R.H. (1982)
            Subaetite Dietary Toxicity (LCsSQ'J of LS 74.783 to
            the Bobwhite Quail:RHP 190 WL/81699.  Final rept.
            (Unpublished study received Apr sf 1982 under
            359-7051 prepared by Huntingdon Research Centre,
            England, submitted by Rhone-Poulenc Chemical Co.,
            Honmouth Junction, N.J,; CDL:247184-D)

00098363 Roberts, N.L.I Phillips, C.N.K.; Almond, R.H. (1981) The
            Bubacute Dietary Toxicity (LCsSQ*) of LS 74.783 to
            the Mallard Duck: RNP 191 WL/81716.  Final rept.
            (Unpublished study received Apr 5, 1982 under
            359-705; prepared by Huntingdon Research centre,
            England, submitted by Rhone-Poulene Chemical Co.,
            Monmouth Junction, N.J.J CDLf247184-E)

00098368 Rhoderick, J.C.; Spare, W.C.; Rutchinson, C. {1981} The
            Acute Toxicity of Aluminum-ethyl-phosphonate to Grass
            Shrimp,"Palae"i-;~monetes pugio'is Project No. 381-2.
            (Unpublished study received Apr 5, 1982 under
            359-705? prepared by Biospherics, Inc., submitted by
            Rhone-Poulenc Chemical Co.,  Monmouth Junction,
            N.J.; GDZ.S247184-J)

00098370 Buys, M.i Bertrand, A.; Giraud, J.I. (1981J Fosetyl-al
            (Aluminium Tris-Q-ethylphosphonate) Hydrolysis itudyj
            Raf. AG/CRtD/An/AB/MB/JFG/CB/il3,81.  (Unpublished
            study received Apr 5, 19S2 under 359-705? prepared by
            Rhone-Foulenc Agrochemie S.A., France,
            submitted by Rhone-Poulenc chemical Co., Monmouth
            Junction, N.J.,* CDL:247185-B}

 00098371 Bertrand, A. (1981J Fosetyl-als uv Absorption
            Characteristics?  Ref. No. AG/CRLD/An/Al/DB/324/81.
            (Unpublished study received Apr 5, 1982 under
            359-705; prepared by Rhone Poulenc Agrochimie,
            France, submitted by Rhone-Poulenc chemical Co.,
            Monmouth Junction, N.J.; CDL:247185-C)

 00098372 Hascoet, M.? Jamet, P. (1978}  Aluminium Ethylphosphite
            Degradation in the Soil.  (Translation? France,
            Ministere de 1'Agriculture,  institut National de la
            Recherche Agronomicpie, Laboratoire de
            Phytopharmacie; unpublished study; CDL:247185-D)

00098375 Buys, M.; Giraud, J.P. (1982} Fosetyl-al (AluminuBi
            Tris-0-ethyl-phosphojiate)  Soil Leaching studies: Ref.
            AG/CRLD/An/AB/MB/JPG/CB/025.82.  (Unpublished study
            received Apr 5, 1982 under 359-705; prepared by
            Rhone-Poulenc Agrochimie,  France, submitted by
            Rhone-Poulenc Chemical Co.,  Monmouth Junction, N.J.;
            CDL-247185-G)

                               43

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00103249 Broekelsby, e.j Catehpole, A.| Crouch, R. (1977)
            Fungicides: Aluminum Ethyl Phosphite  (LS 74.783 or
            Aliette)i studies with the 14C-labelled Compound in
            Viness AR/1257.  (Unpublished study received Jun 8,
            1982 under 359-706; prepared by May i Baker Ltd.,
            Eng., submitted by Rhone-Poulenc, Inc., Monmouth
            Junction, KJ; CDL:247647-B)

 00103250 Laurent, M. ? Chabassol, Y. (1982) Fosetyl-al (32 545
            R.P., Aluminum Salt).  Pineapple Metabolism study:
            Report C.8. Vitry/CNG-An No. 4412-E.  (Translation?
            unpublished study received Jun 8, 1982 under 359-706;
            submitted by Rhone-Poulenc, Inc., Monmouth
            Junction, NJ; CDL:247647-C)

 00106018 Buys, K.I Giraud, J.; Alix, M.i et al.  (1982)
            Fosetyl—AL (Aluminum-0-ethylphosphonate): ioil
            Metabolism Study: Ref. AG/CRLD/An/262.82.
            (Unpublished study received Jul 13, 1982 under 359-
            705; prepared by Shone-Poulene Agroehimie S.A.,
            Fr.,submitted by Rhone-Poulenc, Inc., Monmouth
            Junction, HJ; CDLS247820-A)

00106019 Bertrand, A.; Buys, M. (1982)  Fosetyl-Al—soil Sorption
            Studies?  Ref. AG/CRLD/An/163.82,  (Unpublished study
            received Jul 13, 1982 under 359-70S? prepared by
            Rhone-Poulenc Agrochimie S.A.,  Fr., submitted by
            Rhone-Poulene, inc., Honmouth Junction, HJ?
            CDL:247820-B)

 00114091 Palmer, A.? James, ». (1977)  Effect of LS74-783 en
            Pregnancy of the Rats  RNP/33/7€939.  (Unpublished
            study received Apr 5,  1982  under 359-705?  prepared by
            Huntingdon Research Centre, Ing,, submitted by
            Rhone-Poulenc, inc., Monmouth Junction,  NJi CDL;
            247174-B)

 00119§2« Spare, W. ? Hutchinson, C.  (1982) The Acute Toxicity of
            Fosetyl-Al to the Bluegill  Eunfish ...$  Project No.
            82-E-380-B.   (Unpublished study received Oct 2i, 1982
            under 359-701,* prepared by  Biospherics,  Inc.,
            submitted by Rhone-Poulenc, Inc., Konmouth
            Junction,  KJ;  CDL:248674-A)
                               44

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 001227S1 Pasojuet, J.f Hazuret, A.; Gaildrat, P.; et al.  (1981)
            Fosetyl-Al (32 545 R.P., Aluminium Salt)? Aliette WP
            80%  (Wettable Powder Containing 80% Fosetyl-Al);
            Acute Oral Toxicity in the Rat: Reference C.R.
            Vitry/C.N.G. No. 21 165-E.   (Translation; unpub-
            lished study received Apr 5, 1982 under 359-706;
            prepared by Centre Nicolas Grillet, Fr., submitted by
            Rhone-Poulenc, Inc., Monmouth Junction, NJ;
            CDL;247186-B)

00122782 Pasquet, J.; Mazuret, A.; Kalifat, R.; et al.  (19S1)
            Fosetyl-Al (32 S45 R.P., Aluminium Salt); Aliette wp
            80%  (Wettable Powder Containing 80% Fosetyl-Al);
            Acute Percutaneous Toxicity in the Rabbit: Reference
            C.R. Vitry/C.N.G. No, 21 166-E.   (Translation;
            unpublished study received Apr 5, 3.982 under 359-706;
            prepared by Centre Nicolas Grillet, Fr., submitted by
            Rhone-Poulenc, Inc., Monmouth Junction, SJj
            CDL5247186-C)

00122783 Owen, P.; Blackett, N. (1981} Aliette (80% Fosetyl-Al)t
            Acute Inhalation Toxicity study—LC50 in Rats  (4 "
            Hours Exposure)!  Report No. 2771-198/1,
            (Unpublished study received Apr 5, 1§82
            under 359-706? prepared by Hazleton Laboratories
            Europe, Ltd., Eng., submitted by Rhone-Poulenc, Inc.,
            Monmouth Junction, NJj CDLi247iS6-D>

 001227S5 Pascjuet, J.i Mazuret, A. i Maratrmti et al. (1981)
            Fosetyl-Al (32 545 R.P., Aluminum Salt)i Aliette WP
            80%  {Wettafale Powder Containing 80% Fosetyl-Al)«
            Primary Skin Irritation in the Rabbits Report C.R.
            Vitry/C.N.G.  No.  21 168-E of 2.11.81.
            (Translation? unpublished study received Apr 5, 1982
            under 359-706; prepared by Centre Nicolas Grillet,
            Fr,, submitted by Rhone-Poulenc,  Inc., Monmouth
            Junction,  NJ| CDL:247186-F)

00126757 international Research and Development Corp.  (1983)
            Addendum i to the Final Report, Fosetyl-Al Chronic
            Toxicity (2 Year)  Carcinogenic!ty Study in Ratss
            347-016.   (unpublished study received Apr 12, 1983
            under 359-705;  submitted by Rhone-Poulenc,  Inc.,
            Monmouth Junction,  NJj CDLs249898-A)

 00128233 International Research and Development  Corp.  (1981)
            Chronic Toxicity (2 Year)  and Carcinogencity Study  in
            Ratss [Fosetyl-Al!s 347-016.   (Unpublished study
            received Apr  5,  1982  under 359-705;   submitted by
            Rhone-Poulenc,  Inc.,  Monmouth Junction,  NJj  CDLs
            247163-A)
                               45

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 00128S43 Spare,  W.j  Gottfried,  G.  (1983)  The Acute Toxieity of
             Fosetyl-Al to Daphnia  aagna Straus:  Biospherics
             Project  NO.  82-E-380DMR.  (Unpublished study received
             Jun  17,  1983 under  359-705; prepared by Biospherics,
             Inc.,  submitted by  Rhone-Poulene,  Inc.,  Monmouth
             Junction,  NJ? CDI.5250499-A)

 00128944 Conzelmann,  P. i Brady,  s.  (1983) Acute  Toxieity
             Bioassay testing Fosetyl-AL on  Rainbow Trout!  GSRI
             Project  No,  413-B45-41,   (Unpublished study received
             Jun  17,  1983 under  359-705? prepared by
             Gulf South Research Institute,  submitted by Rhone
             Poulenc,  Inc.,  Monmouth Junction,  NO"; CDL:250499-B)

 00139527 Rhone- Poulenc,  Inc.  (1983) Residue Data in/on  Pineapple
             Resulting  from Allette Dip  and/or  Foliar Treatments,
             (Compilation? unpublished study received May 12, 1983
             Under  2F2702; CDL;Q71491-A! 071592)

 00147359 Hard, G.  (1985)  Acute  ToKicity of  Fosetyl-Al to Embryos
             and  Larvae of the Eastern Oyster (Crassostrea
             virginica) s  BSE No.  85-314-0200-2130.  Unpublished
             study  prepared  by Environmental  Science
             and  Engineering, inc.  17 p.

 00147360 suprenant, D.  (1985) Acute Toxieity  of Fosetyl-Al  to
             Sheepshead Minnow (Cyprinodon variegatus) j  Bionomics
             Report #BW-85-5-l777. Unpublished  study  prepared by
             springborn Bionomics, Inc.  55 p.

 00147361 Chabassol, ¥.  (1984) Anaerobic Aquatic Metabolism
             Study 8 Fosetyl-Als Ref. No. AG/CRIiD/An/241.84.
             Unpublished  study prepared by Rhone-Poulene
             Agrochimie.   57 p.

 00147569 Rhone-Poulenc Inc.  (1984)  tResidue Data of Aliette:.
             Unpublished  study.  56 p.

 00148290 Rhone-Poulenc  Inc. (1985) : Residue of Fosetyl-Al in
            Citrus Fruits.  Unpublished compilation.  273 p.
 00148619 Hylin, J,; Yanagihara, R. (iggs) Residue Data in/on
            Pineapple Resulting from Aliette Dip and/or Foliar
            Treatments,  unpublished study prepared by University
            of Hawaii.  3 IS p.

00165341 Rhone Poulenc Inc. (19??)  Determination of Residues of
            Fosethyl and Phosphorus Acid in Pineapples (Analysis
            by Gas- liquid Chroma tography) s AG/RD/An,AB/SV
            -283.82.  Unpublished study,  21 p.
                               46

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40131101 Auletta, C.; Hogan, 6.; Lamb, c. (1982) Eye Irritation
            study of Rabbits with Aliete 80 WP: Lab Project ID;
            4090-82.  unpublished study prepared by Bio/dynamics,
            Inc.  17 p.

40285600 interregional Research Project Ho. 4.  (1987) Submission
            of Residue Chemistry Data in Support of the Proposed
            Tolerance for Aliette on Ginseng.  Transmittal of I
            study.

40285601 Guyton, C. (1987) Aliette--Magnitude of Residue on
          Ginseng, Including a Description of the analytical
          Method Used; Ref. No. 87/BHL/1S3/AO5 Report No. ASD
          87/229.  unpublished study prepared by Rhone-Poulenc,
          Inc.  87 p.

40600800 Interregional Research Project No. 4 (1988) Submission
            of Residue Data to Support the Fosetyl-aluminum
            Petition.  Transmittal of 1 study.

40600801 Gemma, A.? Chow* W.j Biehn, w (1988) Fosetyl-aluminum
            —in/on Ginseng, (Amendment—IR-4 Petition 7E 35S6,
            MRID 40285601, Rci/EPA 4 Kov 87 Response Letter)i
            Project No. 781R14; IR-4 PR 13001.  Unpublished study
            prepared by Rhone-Poulene Ag Co.  16 p.

40625101 Auletta, C. (1988) Eye Irritation Study in Rabbits with
            Aliette HP* project Mo.  4778-S8.  Unpublished study
            prepared by Bio/dynamics Inc.  17 p.

406S4300 Mobay Corp. (1988) Submission of Toxieity Data to
            Support the Registration of Dylox S% Granular.
            Transmittal of 6 studies.

40654301 Eigenberg, D, (1988) Acute  Oral Toxieity of a Dylox 5%
            Formulation in Albino Rats: Study No.  87-011-06;
            95692.   Unpublished study prepared by Mobay Chemical
            Corp.  20 p.

40676301 Hinken, C.I Dinglefline, J.? Jaber,  M. (1986)  Fosetyl-Als
            An Acute Contact Toxicity Study with Honey Bees:
            Froj. Ho.  171-110.   Unpublished study prepared by
            Wildlife International Ltd.  15 p.

40676401 Smith, 8. (1986) Dermal Sensitization Study in Guinea
            Pigs with Aliette 80WP:  Study 480-2461.  Unpublished
            study prepared by American Biogenics Corp.   28 p.
                               47

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40747701 Guyton, c.f Chow, w, (1988) Fosetyl-Al Residues in
            Caneberries Resulting from Multiple Applications of
            Aliette 80 WP: Project Ho. 781R10.  Unpublished study
            prepared by Rhone-Poulenc in cooperation with
            Rhone-Poulenc Ag Co.  151 p.

40833100 Interregional Research Project Mo. 4 (1988) Submission
            of Data fo Support Registration of Fosetyl-aluminum:
            Residue Chemistry Data.  Transmittal of 1 study.

 40833101 Gemma, A.? chow, w.; Biehn, W. (1988)  Fosetyl-Aluminum
            —in/on Ginseng (... RCB/EPA 13 Jul 88 Response
            Letter)! Project No. 781R14I File Ho. 40263; IE-4 PS
            Ho. 3001.  Unpublished study prepared by
            Rhone-Poulenc Ag Co.  20 p.

40901601 Scarborough, D. (1988)  Section A:  The Names, Chemical
          Identity, and Composition of Aliette Fungicide: Project
          ID: 781C10? File No. 40424.  Unpublished study prepared
          by Rhone-Poulenc Ag Co.  14 p*

40901602 Guyot, c.? Scarborough, D, (1988)  Fosetyl-Al Technical!
            Product chemistry: Project ID:  781C10? File Mo.
            40408.  Unpublished study prepared by Rhone-Poulenc
            Agroehimie.  4 p.

41001701 Gemma, A. y Chow, W. (1988) Residues of Fosetyl-Al in/on
            Citrus Fruit Resulting from Multiple Applications of
            Aliette SO WP: Laboratory Project ID 781 R14.
            unpublished study prepared by Rhone-Poulenc, Inc.
            221 p.

41034500 Rhone-Poulenc Ag Co. (1989) Submission of Data To
            Support Registration Petition for Fosetyl-Al: Product
            Chemistry Data.  Transmittal of 1 study.

 41034501 Rhoads, w. (1988) Determination of the Characteristics
            of Fbsetyl-Al when Subjected to Analysis by the
            United States Food and Drug Administration (FDA)
            Multi-Residue Protocols I,II,III and ivs
            Project No, Rbone-Poulenc 1087.  Unpublished study
            prepared by Colorado Analytical Research &
            Development Corp.  114 p.

41036301 Scarborough, D. (2.989)  Certification of Ingredient.
            Limits for Aliette Fungicide: Section A: Project File
            No. 40521.  Unpublished compilation prepared by
            Rhone-Foulenc ng Co.  17 p.
                               48

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41049901 White, 8. (1989}  Final Report for Dissipation of
            Dislodgable Fosetyl-Al (Aliette)  Residue Applied to
            Citrus in California: Project ID Nos:  Study No. 1068?
            WRLA Protocol  NO. 1321-87-44-03-01A-03.  Unpublished
            study prepared by Colorado Analytical  in
            cooperation with Research for Hire.   139 p.

 41128601 Hughes, J.  (1989) The Toxicity of Fosetyl-Al to
            Savicula pellieulosas Proj. ID 1163-01-1100-3.
            Unpublished compilation prepared in cooperation with
            Malcolm Pirnie, inc. and Biospherics Inc. 4 p.

41128602 Hughes, j. (1989) The Toxicity of Fosetyl-Al to Anabaena
            flosaguae:  Proj. ID 1163-01-1100-2.   Unpublished
            compilation prepared in cooperation with Malcolm
            Pirnie/ Inc. and Biospherics Inc.  42  p*

 41128603 Hughes, J,  (1988) The Toxicity of Fosetyl-Al to Lemna
            gibba 83:  Proj. ID 1163-01-1100-S.   Unpublished
            compilation prepared in cooperation with Malcolm
            Pirnie, Inc. and Biospherics Inc.  40  p.

 41128604 Hughes, J.  (1989} The Toxicity of Fosetyl-Al to
            Selenastrum capricornutum: Proj.  ID 1163-01-1100-1.
            Unpublished compilation prepared in cooperation with
            Malcolm Pirnie, Inc. and Biospherics Inc.  41 p.

 41128605 Hughes, J,  (1989} The Toxicity of Fosetyl-Al to
            SXeletonerna costaturn: Proj* ID 1163-01-1100-4.
            Unpublished compilation prepared in cooperation with
            Malcolm Pirnie, Inc. and Rhone-Poulene Ag Co.  30 p.


 41133001 Stumpner, J.i Predmore, L. (1987) Metabolism of Carbon
            14 Fosetyl-Al  in Lactacting Dairy Goats:  Projects ID
            No. ABC 32637.  Unpublished study prepared by ABC
            Laboratories.   873 p.

41286401 Helfant, L,  (1989) Fosetyl-Al Corrosion Characteristics
            of Aliette  Brand Fungicide: Series 63; Guideline
            63-20: Lab  project Number: 781 CIO:  40670: 9426-8.
            Unpublished study prepared by Rhone-Foulenc Ag Co.
            and Midwest Research Institute, Contract
            Laboratory/Corrosion Evaluation.   69 p.
                               49

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