United States       Prevention, Pesticides     EPA738-R-98-016
         Environmental Protection   And Toxic Substances     December 1998
         Agency	(7508C)	
&EPA  Reregistration
         Eligibility Decision (RED)

         1,3-Dichloropropene

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         \         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
         uJ
         /                          WASHINGTON, D.C. 20460
                                                                     OFFICE OF
                                                           PREVENTION, PESTICIDES
                                                            AND TOXIC SUBSTANCES
CERTIFIED MAIL
Dear Registrant:

       I am pleased to announce that the Environmental Protection Agency has completed its
reregistration eligibility review and decisions on the pesticide chemical case [0328] which includes
the active ingredient 1,3-Dichloropropene (or trade name Tel one). The enclosed Reregistration
Eligibility Decision (RED), which was approved on September 30, 1998,  contains the Agency's
evaluation of the data base of this chemical, its conclusions of the potential human health and
environmental risks of the current product uses, and its decisions and conditions under which
these uses  and products will be eligible for reregistration.  The RED includes the data and labeling
requirements for products for reregistration.  It also includes requirements for additional data
(generic) on the active ingredient to confirm the risk assessments.

       To assist you with a proper response, read the enclosed document entitled "Summary of
Instructions for Responding to the RED." This summary also refers to other enclosed documents
which include further instructions. You must follow all instructions and submit complete and
timely responses  The first set of required responses is due 90 days from the receipt of this
letter.  The second set of required responses is due 8 months from the date  of this letter.
Complete and timely responses will avoid the Agency taking the enforcement action of suspension
against your products.

       Please note that the Food Quality Protection Act of 1996 (FQPA) became effective on
August 3,  1996, amending portions of both the pesticide law (FIFRA) and the food and drug law
(FFDCA). This RED takes into account, to the extent currently possible, the new safety standard
set by FQPA for establishing and reassessing tolerances.  However, it should be noted that in
continuing to make reregistration determinations during the early stages of FQPA implementation,
EPA recognizes that it will be necessary to make  decisions relating to FQPA before the
implementation process is complete.  In making these early case-by-case decisions, EPA does not
intend to set broad precedents for the application  of FQPA. Rather, these early determinations
will be made on a case-by-case basis and will not bind EPA as it proceeds with further policy
development and any rulemaking that may be required.

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       If EPA determines, as a result of this later implementation process, that any of the
determinations described in this RED are no longer appropriate, the Agency will pursue whatever
action may be appropriate, including but not limited to reconsideration of any portion of this
RED.

       If you have questions on the product specific data requirements or wish to meet with
 the Agency, please contact the Special Review and Reregi strati on Division representative
Karen Jones (703) 308-8047. Address any questions on required generic data to the Special
Review and Reregi strati on Division representative, Lisa Nisenson (703) 308-8031.

                                                       Sincerely,
                                                       Lois A. Rossi, Director
                                                       Special Review and
                                                        Reregi strati on Division
Enclosures

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               SUMMARY OF INSTRUCTIONS FOR RESPONDING TO
              THE REREGISTRATION ELIGIBILITY DECISION (RED)

1  DATA CALL-IN (PCI) OR "90-DAY RESPONSE"-If generic data are required for
reregi strati on, a DCI letter will be enclosed describing such data.  If product specific data are
required, a DCI letter will be enclosed listing such requirements.  If both generic and product
specific data are required, a combined Generic and Product Specific DCI letter will be enclosed
describing such data. However, if you are an end-use product registrant only and have been
granted a generic data exemption (GDE) by EPA, you are being sent only the product specific
response forms (2 forms), the RED Fact Sheet, and the Acute Toxicity Batching Tables.
Registrants responsible for generic data are being sent response forms for both generic and
product specific data requirements (4 forms).  You  must submit  the appropriate response
forms (following the instructions provided) within 90 days of the receipt of this RED/DCI
letter;  otherwise, your product may be suspended.

2  TIME EXTENSIONS AND DATA WAIVER REOUESTS-No time extension requests
will be granted for the 90-day response. Time extension requests  may be submitted only with
respect to actual data submissions. Requests for time extensions for product specific data should
be submitted in the 90-day response. Requests for data waivers must be submitted as part of the
90-day response. All data waiver and time extension requests must be accompanied by a full
justification. All waivers and time extensions must be granted by EPA in order to go into effect.

3  APPLICATION FOR REREGISTRATION OR "8-MONTH RESPONSE"-You must
submit the following items for each product within eight months of the date of this letter
(RED issuance date).

       a. Application for Reregistration (EPA Form 8570-1).  Use only an original application
form. Mark it "Application for Reregistration."  Send your Application for Reregistration (along
with the other forms listed in b-e below) to the address  listed in item 5.

       b. Five copies of draft labeling which complies with the RED and current regulations
and requirements. Only make labeling changes which are required by the RED and current
regulations  (40 CFR 156.10) and policies.  Submit any other amendments (such as formulation
changes,  or labeling changes not related to reregi strati on) separately.  You may, but are not
required to, delete uses which the RED says are ineligible for reregi strati on. For further labeling
guidance, refer to the labeling section of the EPA publication "General Information on Applying
for Registration in the U.S., Second Edition, August 1992" (available from the National Technical
Information Service, publication #PB92-221811; telephone number 703-487-4650).

       c. Generic or Product Specific Data. Submit all data in a format which complies with
PR Notice 86-5, and/or submit citations of data already submitted and give the EPA identifier
(MRID) numbers. Before citing these studies, you must make sure that they meet the
Agency's acceptance criteria  (attached to the DCI).

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       d  Two copies of the Confidential Statement of Formula (CSF) for each basic and
each alternate formulation.  The labeling and CSF which you submit for each product must
comply with P.R. Notice 91-2 by declaring the active ingredient as the nominal concentration.
You have two options for submitting a CSF: (1) accept the standard certified limits (see 40 CFR
§158.175) or (2) provide certified limits that are supported by the analysis of five batches. If you
choose the second option, you must submit or cite the data for the five batches along with a
certification statement as described in 40 CFR §158.175(e).  A copy of the CSF is enclosed;
follow the instructions on its back.

       e.  Certification With Respect to Data Compensation Requirements. Complete and
sign EPA form  8570-31 for each product.

4  COMMENTS IN RESPONSE TO FEDERAL REGISTER NOTICE-Comments
pertaining to the content of the RED may be submitted to the address shown in the Federal
Register Notice which announces the availability of this RED.

5  WHERE TO SEND PRODUCT SPECIFIC PCI RESPONSES (90-DAY) AND
APPLICATIONS FOR REREGISTRATION (8-MONTH RESPONSES)

By U.S. Mail:

       Document Processing Desk (RED-SRRD-PRB)
       Office of Pesticide Programs (7504C)
       EPA, 401 M St. S.W.
       Washington, D.C. 20460-0001

By express:

       Document Processing Desk (RED-SRRD-PRB)
       Office of Pesticide Programs (7504C)
       Room 266A, Crystal Mall 2
       1921 Jefferson Davis Hwy.
       Arlington, VA 22202

6.  EPA'S REVIEWS—EPA will screen all submissions for completeness; those which are not
complete will be returned with a request for corrections. EPA will try to respond to data waiver
and time extension requests within 60 days. EPA will also try to respond to all 8-month
submissions with a final reregi strati on determination within 14 months after the RED has been
issued.

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REREGISTRATION ELIGIBILITY DECISION




     1,3-DICHLOROPROPENE (1,3-D)




                LIST A




              CASE 0328

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                             TABLE OF CONTENTS


REREGISTRATION ELIGIBILITY DECISION TEAM                              i

GLOSSARY OF TERMS AND ABBREVIATIONS                                  ii

EXECUTIVE SUMMARY                                                       iv

I.     INTRODUCTION                                                         1

II.    CASE OVERVIEW                                                       2
      A.    Chemical Overview  	2
      B.    Use Profile                                                         2
      C.    Estimated Usage of Pesticide	4
      D.    Data Requirements and Regulatory History	5

III.   SCIENCE ASSESSMENT                                                  6
      A.    Physical and Chemical Properties Assessment  	6
            1.     Identification of Active Ingredient	6
            2.     Manufacturing and End-Use Product Chemistry                  7
            3.     Conclusions	8
      B.     Human Health Assessment	8
            1.     Hazard Assessment	8
                   a.     Acute Toxicity                                          8
                   b.     Subchronic Toxicity  	9
                   c.     Chronic Toxicity/Carcinogenicity	11
                   d.     Developmental Toxicity	13
                   e.     Reproductive Toxicity                                   13
                   f.      Mutagenicity                                           14
                   g.     Metabolism                                            15
                   h.     Dermal Absorption 	15
                   i.      Epidemiological Data                                   15
            2.     Dose-Response Assessment	16
                   a.     Determination of Susceptibility to Infants and Children      16
                   b.     Acute Dietary                                          17
                   c.     Chronic Reference Dose (RfD)	17
                   d.     Classification of Carcinogenic Potential                    18
                   e.     Occupational and Residential Exposure                    19
            3.     Dietary Exposure Assessment	23
                   a.     Dietary Exposure from Food Sources                      23
                   b.     Dietary Exposure from Drinking Water	25
      C.    Occupational and Residential Exposure                                34
            1.     Summary of Use Pattern and Application Methods                34
            2.     Exposure Mitigation Measures in Effect	35

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             a.     Workers	35
             b.     Residents/Bystanders                                    35
      3.     Factors Influencing 1,3-D Exposure	36
      4.     Exposure Monitoring Studies	36
             a.     Worker Monitoring Studies  	36
             b.     Resident/Bystander Monitoring Studies                   37
      5.     Exposure Estimates Used for Risk Assessment	40
D.     Risk Assessment  	43
      1.     Dietary Risk and Characterization                              43
             a.     Food Source	43
             b.     Drinking Water Source	43
             c.     Dietary Risk Characterization  	48
             d.     Occupational and Residential/Bystander Inhalation Risk
                   Characterization	49
             e.     Uncertainties in the Risk Assessment and Risk
                   Characterization Summary for 1,3-D	54
E.    Environmental Assessment  	56
      1.     Environmental Fate and Transport	56
             a.     Environmental  Fate Assessment of 1,2-D	56
             b.     Degradation                                            56
             c.      Mobility  	57
             d.     Field Dissipation  	59
      2.     Water Resources                                              59
             a.     Ground Water                                          59
             b.     Modeling and Occurrence of 1,3-D in Surface Water	64
             c.     Drinking Water Exposure Assessment	65
      3.     Ecological Assessment	65
             a.     Toxicity to Terrestrial Animals	65
             b.     Terrestrial Field Testing                                 67
             c.     Toxicity to Freshwater Aquatic Animals	67
             d.     Toxicity to Estuarine and Marine Animals  	69
             e.     Toxicity to Aquatic and Terrestrial Plants                 70
             f.     Toxicity of Degradation Products and Manufacturing
                   Impurities  	70
      4.     Exposure and Risk Characterization	71
             a.     Explanation of the Risk Quotient (RQ) and the Level of
                   Concern (LOC)                                        71
             b.     Field Data Used for Risk Assessment                      73
             c.     Exposure and Risk to Non-target Terrestrial Animals  	73
             d.     Exposure and Risk to Non-target Freshwater Aquatic
                   Animals  	76
             e.     Exposure and Risk to Estuarine and Marine Animals  	78
             f.     Exposure and Risk to Non-target Plants  	79
             g.     Endangered Species  	79

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IV.   RISK MANAGEMENT AND REREGISTRATION DECISION                 79
      A.     Determination of Eligibility	79
      B.     Determination of Eligibility Decision  	80
             1.     Eligibility Decision                                            80
      C.     Regulatory Position                                                  80
             1.     Summary of 1,3-D's Carcinogenicity	80
             2.     Summary of EPA's Approach to the 1,3-D Risk Assessment	81
                   a.     Tolerances, Codex Harmonization and Dietary Risk         81
                   b.     Aggregate and Cumulative Risk                          82
                   c.     Effects to the Endocrine System                          82
             2.     Summary of 1,3-D's Benefits  	83
             3.     Summary of Risk Management Decisions	83
                   a.     Human Health                                          83
                   b.     Environmental/Ecological Effects	87
                   c.     Restricted Use Classification                             89
                   d.     Endangered Species Statement                            89
                   e.     Labeling Rationale                                      90

V.    ACTIONS REQUIRED OF REGISTRANTS                                 93
      A.     Amendments to Current 1,3-D Registrations	93
      B.     Requirements for 1,3-D Products  	93
             1.     Additional Generic Data Requirements	93
                   a.     Studies to be performed as a result of modified terms and
                         conditions of registration  ~ Studies on 3-chloroacrylic acid
                         and 3-chloroallyl alcohol	93
                   b.     Studies to be performed as a result of modified terms and
                         conditions of registration - 1,3-D  	94
                   c.     Studies to be performed as a result of modified terms and
                         conditions of registration with tiered requirements - Run-off
                         Study and Studies on Ecotoxicity                         95
                   d.     Product Chemistry Requirements  	95
             2.     Formulation Changes	95
             3.     Time frames  	95
             4.     Labeling Requirements for End-Use Products 	95
      C.     Existing Stocks                                                      97

VI.   APPENDICES                                                            99
      A.     Table of Use Patterns Subject to Reregistration	100
      B.     Table of the Generic Data Requirements and  Studies Used to Make the
             Reregistration Decision  	101
      C.     Citations Considered to be Part of the Data Base Supporting the
             Reregistration Decision  	Ill
      D.     Product Specific Data Call-In                                        131
             1.     Chemical Status Sheets                                       144

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      2.     Product Specific Data Call-In Response Forms (Insert A) Plus
             Instructions	145
      3.     Product Specific Requirement Status and Registrant's Response
             Forms (Insert B) and Instructions	147
      4.     EPA Batching of End-Use Products for Meeting Data Requirements
             for Reregistration	154
      5.     List of All Registrants Sent This Data Call-in (insert) Notice  .... 157
E.    List of Available Related Documents and Electronically Available Forms 159

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REREGISTRATION ELIGIBILITY DECISION TEAM
Office of Pesticide Programs:
Biological and Economic Analysis Assessment
John Faulkner
Richard Michell
Margaret Cogdell
Economic Analysis Branch
Biological Analysis Branch
LUIS Representative
Environmental Fate and Effects Risk Assessment
Kevin Poff                             Ecological Effects Branch
Estella Waldman                        Fate and Monitoring Branch
Jim Carleton                            Fate and Monitoring Branch
James Felkel                            Ecological Hazard Branch
John Eisenman                          Environmental Risk Branch I
Health Effects Risk Assessment
Nancy McCarroll
Christina Scheltema
Catherine Eiden

Registration Support Risk Assessment
Terri Stowe

Risk Management
Lisa Nisenson

FEAD
Susan Acree
Toxicology Branch II
Risk Characterization and Analysis Branch
Risk Characterization and Analysis Branch
Fungicide-Herbicide Branch
Special Review Branch
Communications Branch
Office of General Counsel:
Andrea Medici
Office of General Counsel
Office of Stratospheric Ozone Protection:

Bill Thomas

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GLOSSARY OF TERMS AND ABBREVIATIONS
ADI

ADD
AADD
AE
a.i.
ARC
CAS
CI
CNS
CSF
DFR
ORES
DWEL
EEC
EP (or EUP)
EPA
FAO/WHO

FDA
FIFRA
FFDCA
FQPA
FOB
GLC
GM
GRAS
HA
HOT
LADD
LC5n
LD50
LDlo
LEL
LOC
LOD
Acceptable Daily Intake.  A now defunct term for reference
dose (RID).
Average Daily Dose
Annual Average Daily Dose
Acid Equivalent
Active Ingredient
Anticipated Residue Contribution
Chemical Abstracts Service
Cation
Central Nervous System
Confidential Statement of Formula
Dislodgeable Foliar Residue
Dietary Risk Evaluation System
Drinking Water Equivalent Level (DWEL)  The DWEL
represents a medium specific (i.e. drinking water) lifetime
exposure at which adverse, non carcinogenic health effects
are not anticipated to occur.
Estimated Environmental Concentration.  The estimated
pesticide concentration in an environment, such as a
terrestrial ecosystem.
End-Use Product
U.S. Environmental Protection Agency
Food and Agriculture Organization/World Health
Organization
Food and Drug Administration
Federal Insecticide, Fungicide, and Rodenticide Act
Federal Food, Drug, and Cosmetic Act
Food Quality Protection Act
Functional Observation Battery
Gas Liquid Chromatography
Geometric Mean
Generally Recognized as Safe as Designated by FDA
Health Advisory (HA). The HA values are used as informal
guidance to municipalities and other organizations when
emergency spills or contamination situations occur.
Highest Dose Tested
Lifetime Average Daily Dose
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, air or
feed, e.g.,  mg/1, mg/kg 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., mg/kg.
Lethal Dose-low. Lowest Dose at which lethality occurs.
Lowest Effect Level
Level of Concern
Limit of Detection

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LOEL
MATC
MCLG
mg/L
MOE
MP
MPI
MRID

NAWQA

NTP
N/A
NOEC
NOEL
NOAEL
OP
OPP
Pa

PADI
PAG
PAM
PD
PHED
PHI
ppb
PPE
ppm
PRN
Q*i

RBC
RED
REI
RfD
RS
RUP
SLN
TC

TD

TEP
TGAI
TLC
TMRC
torr

WPS
Lowest Observed Effect Level
Maximum Acceptable Toxicant Concentration
Maximum Contaminant Level Goal (MCLG) The MCLG is
used by the Agency to regulate contaminants in drinking
water under the Safe Drinking Water Act.
Micrograms Per Gram
Micrograms per liter
Milligrams Per Liter
Margin of Exposure
Manufacturing-Use Product
Maximum Permissible Intake
Master Record Identification (number). EPA's system of
recording and tracking studies submitted.
National Water Quality Assessment - USGS Water sampling
Program
National Toxicology Program
Not Applicable
No Observable Effect Concentration
No Observed Effect Level
No Observed Adverse Effect Level
Organophosphate
Office of Pesticide Programs
pascal, the pressure exerted by a force of one newton acting
on an area of one square meter.
Provisional Acceptable Daily Intake
Pesticide Assessment Guideline
Pesticide Analytical Method
Position Document related to a Special Review
Pesticide Handler's Exposure Data
Preharvest Interval
Parts Per Billion
Personal Protective Equipment
Parts Per Million
Pesticide Registration Notice
The Carcinogenic Potential of a Compound, Quantified by the
EPA's Cancer Risk Model
Red Blood Cell
Reregistration Eligibility Decision
Restricted Entry Interval
Reference Dose
Registration Standard
Restricted Use Pesticide
Special Local Need (Section 24 © of FIFRA)
Toxic Concentration. The concentration at which a substance
produces a toxic  effect.
Toxic Dose. The dose at which a substance produces a toxic
effect.
Typical End-Use Product
Technical Grade Active Ingredient
Thin Layer Chromatography
Theoretical Maximum Residue Contribution
A unit of pressure needed to support a column of mercury 1
mm high under standard conditions.
Worker Protection Standard
                                                 ill

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EXECUTIVE SUMMARY

Overview

       The U.S. Environmental Protection Agency has completed its reregi strati on eligibility
decision for the pesticide 1,3-dichloropropene (1,3-D, or trade name Telone). This decision
includes a comprehensive reassessment of the required target data and the use patterns of
currently registered products. 1,3-D is a soil fumigant used to control nematodes and certain soil
diseases.  1,3-D is registered for use on soils to be planted with all food and feed crops. 1,3-D is
classified as a non-food use pesticide when used as a pre-plant soil fumigant and thus there are no
tolerances or exemptions from the requirement of a tolerance (for pineapples, 1,3-D is applied at-
plant, however there are no residues in food since fruit are not borne until the third year of
growth). 1,3-D is a restricted use pesticide and as such can only be applied by certified
applicators.  There are no homeowner uses of 1,3-D.

       1,3-D products are sold in bulk or mini-bulk (1000 gallon) containers and require no
mixing prior to loading.  All 1,3-D product labels require closed loading systems for transfers
between the bulk containers and the specialized application rig, which is tractor-drawn. Most
1,3-D use involves injecting the fumigant into soil at depths from 12-18" deep, followed by soil
sealing such as compaction,  a water seal or tarp.  The soil seal is used to minimize the amount of
1,3-D which volatilizes into the atmosphere after application.  There are also four state
registrations (known as SLN's) for 1,3-D  application through drip irrigation, which is also applied
pre-plant.

       1,3-D was placed in EPA's Special Review process in 1986 based on cancer concerns for
workers. The potential for ground water contamination and residues in crops grown in treated
soils were also cited as concerns to be investigated. In 1991, the Special Review of 1,3-D
incorporated risks to residents who live in the vicinity of treated fields for inhalation exposures.
Since 1991, the registrant of 1,3-D, Dow AgroSciences,  has modified 1,3-D registrations to
address worker and residential concerns as detailed below.

       The Agency has concluded that 1,3-D, when labeled and used as specified in this
Reregi strati on Eligibility Decision (RED) document, will not cause unreasonable risks to human
health or the environment and that all labeled uses are eligible for reregi strati on. The Agency is
requiring data on two  degradates, 3-chloroallyl alcohol and 3-chloroacrylic acid, to confirm the
Agency's assumption  that the acid and alcohol are of equal or less toxicity than 1,3-D.

Recent Label Modifications for Risk Mitigation

       In 1992 and in 1996, Dow AgroSciences, requested label changes to  reduce levels of
1,3-D which volatilize into the atmosphere during fumigant transfers, application and the post-
fumigation time  period. Measures added to 1,3-D labels were shut-off valves to prevent 1,3-D
from spilling at row turns, closed loading, soil sealing, a  300-foot no-treatment buffer from
occupied structures, improved product stewardship, a phase-out of drum delivery, and reduced

                                            iv

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application rates.  These measures reduced the largest sources of 1,3-D exposures, specifically,
the pooling of 1,3-D at row turns when the application "knives" were lifted out of the ground and
spills during loading.  These measures reduced exposures not only for workers, but for anyone in
the vicinity of treated fields.

       On September 30, 1998, Dow AgroSciences requested modification of the terms and
conditions of 1,3-D registrations to include use prohibition in certain northern tier states (ND,
SD, MN, NY, ME, NH, VT, MA, UT, MT, WI) based on ground water concerns, a 100-foot no-
treatment buffer around drinking water wells, prohibition of use in areas  overlying karst geologies
and additional monitoring to confirm that use of 1,3-D does not pose unreasonable risks when
used according to product labels. These measures reduce risks for anyone who drinks water from
wells in the vicinity of treated fields.

Risk Concerns - Human Health

       1,3-D is classified as a B2 carcinogen by both the oral and inhalation routes of exposure.
The  1,3-D risk assessment presents aggregated risks for both routes of exposure. Because EPA
does not have toxicity data on the alcohol and acid degradates, EPA assumed carcinogenic and
toxicological equivalence to the parent, thus oral exposure and risk estimates are comprised of
1,3-D plus the degradates (unless specifically noted).

       Due to 1,3-D's carcinogenicity, environmental fate and use patterns, EPA has concerns
that use could result in exposure to residues in air and/or water.  EPA's cancer risk estimates for
workers who follow label restrictions are in the 10"5 to 10"6 range. For residents who live near
treated fields, lifetime cancer inhalation risk estimates are in the  10"5 to 10"8 range taking into
account a  300 foot no-treatment buffer, but not taking into account other measures (e.g.,
lowering application rates by 30-65%,  soil sealing measures) which were not amenable to
quantification under the highly variable field study conditions.

       For reregi strati on, EPA required a prospective ground water study in Wisconsin, which
was believed to be highly vulnerable to ground water contamination from 1,3-D use. The
registrant  also submitted to the agency the results of a prospective ground water study conducted
in Florida.  Based on the results of these studies and other sampling programs, EPA believes that
exposures from well water near treated fields vary depending on factors  such as depth to ground
water, temperature, soil permeability, and distance from the treated field.  Lifetime cancer risk
estimates from the Florida study are 4 x 10"6 (on-site wells which do not account for the 100 foot
buffer). In Wisconsin, lifetime cancer risks for all age groups, and chronic non-cancer risks for
infants and children, were unacceptably high. Cancer risks associated with levels from on-site
wells were in the 10"3 range. As noted above, the September 30, 1998 modification includes a use
prohibition for northern tier states with characteristics similar to the Wisconsin site and will be
added to 1,3-D labels as of August 1, 1999.

       Both prospective ground water monitoring studies included limited monitoring in off-site
wells located down gradient from the treated fields.  In the Florida study, time weighted average

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(TWA) concentrations of 1,3-D plus its degradates in the on-site wells (10' deep) were 1.15 ppb.
TWA concentrations of 1,3-D plus degradates measured in wells located 100 feet down gradient
from the treated field were 0.074 ppb.  In the Wisconsin study, on-site wells yielded TWA
concentrations of 1,3-D  and its degradates of 357 ppb while concentrations in a well 65' down
gradient from the treated field were 26.6 ppb. Although neither of these studies was designed to
quantify offsite exposures; results in both studies indicate that exposures were considerably lower
with increasing distance from treated field.

       Dow AgroSciences has agreed as a condition of reregi strati on to conduct tap water
monitoring studies to better estimate current concentrations of 1,3-D and degradates in drinking
water.  Sampling will be targeted to high-use areas and will be initiated once the new labels are in
effect in August of 1999. Should residues of 1,3-D and/or the alcohol or acid degradates  be
detected at levels  exceeding the Office of Water Health Advisory of 0.2  ppb, Dow AgroSciences
has included, as part of the sampling program, risk reduction measures which would be in place
before the next use season.  EPA expects to use the results of the sampling program to better
characterize risks with the 100' setback and to also see if the sampling program results can be
extrapolated in order to  characterize risks in other 1,3-D use areas.

       The drinking water risk estimates using 1,3-D labels eligible for reregi strati on is 4  x 10"6,
calculated using on-site wells from the Florida study; the inhalation risk is 6 x 10"6 (using an
average of levels monitored from NC, WA and AZ study sites at the 300 foot buffer).  Thus the
calculated aggregate risk estimate is 1 x 10"5. This risk estimate does not take into account
mitigation from lower application rates, soil sealing measures, increased depth of application, soil
moisture and temperature requirements or potential reduction in exposure from the 100 foot
drinking water well setback. EPA believes the risk estimates are likely to be in the 10"6 range and
that risk concerns have been addressed when all of the mitigation measures as specified in this
reregi strati on decision are taken into account.

       EPA's risk assessment shows no short-term or acute risks of concern based on current
1,3-D use patterns and that there are no unacceptable developmental or  reproductive effects.
Infants and children do not appear to have heightened susceptibility to 1,3-D, thus, EPA has
determined the extra 10X safety factor is not warranted. EPA looked at whether risks from 1,3-D
should be cumulated with risks of a contaminant found in  Tel one products, 1,2-dichloropropane
(1,2-D).  For purposes of this reregi strati on action, EPA has assumed that 1,3-D and 1,2-D do
not share a common mechanism of toxicity.

Risk Concerns -  Environmental

       EPA has received and reviewed all of the data required in the 1986 Registration Standard
to assess the environmental risks posed by applications of  1,3-D. 1,3-D  is a highly volatile
compound, and once in soils, is mobile.  1,3-D's persistence appears to be inversely related to
temperature (i.e. high persistence  at low temperatures). EPA does not believe there are risks to
birds or non-target insects, though there could be risk to aquatic invertebrates and fish,
particularly if run-off were to occur. Models suggest that 1,3-D can be  transported through run-

                                             vi

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off, however, these models are not designed to track volatile soil fumigants. EPA is requiring
additional data on the degradates, on estuarine environments and a study to see if 1,3-D enters
surface water through runoff.

       Based on the results of retrospective ground water monitoring studies and the two
prospective studies, EPA believes that the conditions most likely to result in 1,3-D treatment-
related ground water contamination are shallow water tables, cold temperatures and high soil
permeability, though the studies do not provide enough information to rank these factors.  In
addition to the ground water monitoring studies, EPA reviewed the results of other sampling
programs in 1,3-D use areas and the U.S. Geological Survey's recent water resource monitoring
program  results. The U.S.G.S. monitoring found no detections of 1,3-D, but did not look for
3-chloroallyl alcohol and 3-chloroacrylic acid.

Other Activities Related to 1,3-D's Reregistration

       EPA will be reviewing new information on the carcinogenicity of 1,3-D, specifically,
whether EPA will regulate 1,3-D as a non-linear carcinogen. EPA expects this review will take
place sometime in 1999; however, no change in EPA's risk assessment, if needed, can take place
until the Agency implements final policies on regulation of non-linear carcinogens.  EPA also
intends to issue a Position Document 2 (PD2) proposing to close out the Special Review for
1,3-D before the end of 1998.

       Before reregistering products containing 1,3-D, the Agency is requiring that product
specific data, revised Confidential Statements of Formula (CSF) and revised labeling be submitted
within eight months of the issuance of this document.  These data include product chemistry for
each registration and acute toxicity testing.  After reviewing these data and any revised labels and
finding them acceptable in accordance with Section 3(c)(5) of FIFRA, the Agency will reregister a
product.  1,3-D products which also contain chloropicrin will be eligible for reregi strati on only
when chloropicrin has been found to be eligible for reregi strati on.
                                            vn

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I.      INTRODUCTION

       In 1988, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended to
accelerate the reregi strati on of products with active ingredients registered prior to
November 1, 1984. The amended Act provides a schedule for the reregi strati on process to be
completed in nine years. There are five phases to the reregi strati on process.  The first four phases
of the process focus on identification of data requirements to support the reregi strati on 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" or
"EPA") of all data submitted to support reregi strati on.

       FIFRA Section 4 (g)(2)(A) states that in Phase 5 "the Administrator shall determine
whether pesticides containing such active ingredient are eligible for reregi strati on" before calling
in data on products and either reregistering products or taking "other appropriate regulatory
action."  Thus, reregi strati on involves a thorough review of the scientific data base supporting 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.

       On August 3, 1996, the Food Quality Protection Act of 1996 (FQPA) (Public Law 104-
170) was signed into law.  FQPA amends both the Federal Food, Drug, and Cosmetic Act
(FFDCA) 21 U.S.C. 301 et seq., and FIFRA 7 U.S.C. 136 et seq.  The FQPA amendments went
into effect immediately.  As a result, EPA is embarking on an intensive process, including
consultation with registrants, States, and other interested stakeholders, to make decisions on the
new policies and procedures that will be appropriate as a result of enactment of FQPA.  This
process will include a more in-depth analysis of the new safety standard, and how it should be
applied to both food and non-food pesticide applications. FQPA did not, however, amend any of
the  existing reregi strati on deadlines in section 4 of FIFRA. Therefore, the Agency will continue
its ongoing reregistration program while it continues to determine how best to implement FQPA.

       This document presents the Agency's decision regarding the reregistration eligibility of the
registered uses of 1,3-D, including risk to infants and children for any potential dietary, drinking
water, dermal, or oral exposures, and cumulative effects as stipulated under FQPA.  The
document consists of six sections. Section I is the introduction. Section II describes 1,3-D, its
uses, data requirements and regulatory history.  Section III discusses the human health and
environmental assessment  based on the data available to the  Agency. Section IV presents the
reregistration decision for  1,3-D. Section V discusses the reregistration requirements for 1,3-D.
Finally, Section VI contains the Appendices which support this Reregistration Eligibility Decision.

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II.     CASE OVERVIEW

       Commercial 1,3-dichloropropene is a mixture of approximately equal proportions of the
cis- and trans- isomers.  The Telone II formulation contains 94% 1,3-dichloropropene and 6%
inert ingredients. The Telone C-17 formulation, which is formulated with 16.5% chloropicrin,
contains 77.9%  1,3-dichloropropene and 5.6% inert ingredients. A contaminant, 1,2-
dichloropropane may also be present in small quantities (<0.1%).

       A.    Chemical Overview

       The following active ingredient is covered by this Reregi strati on Eligibility Decision:

       Common Name:             1,3-Dichloropropene

       Chemical Name:             1,3-Dichloropropene

       Trade and Other Names:      1,3-D, Telone®, Trilone, Pic-Clor, Tri-Form

       Chemical Family:            Chlorinated Hydrocarbon

       CAS Registry Number:       542-75-6

       OPP Chemical Code:         029001

       Empirical Formula:           C3H4C12

       Basic Manufacturer:         Dow AgroSciences

       Multiple active ingredient products contain:  081501 (chloropicrin)

       Registered "Me Too" Products Not Included in Appendix A: 8536-8; 8536-21; 8536-22;
       11220-1; 11220-15; 11220-20; 11220-21; 11220-22

             B.     Use  Profile

       The following is general information on the current registered uses with an overview of
use sites and application methods. A detailed table of these uses of 1,3-D is in Appendix A.
Although the Appendix A information only reflects the basic manufacturer's products (i.e.
DowAgro Sciences' Telone II and Telone C-17), the 1,3-D uses and use rates for the "me too"
products are the same as those of the basic manufacturer's single and multiple active ingredient
products, respectively.

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TYPE OF PESTICIDE FOR SINGLE ACTIVE INGREDIENT:

Nematicide; Fungicide; Insecticide; Herbicide

MODE OF ACTION:

Soil fumigant, contact poison

USE SITES:

1,3-D is registered for use on all crops to be planted on 1,3-D-treated soils. Thus,
the use sites include all vegetable, fruit and nut crops, all forage crops (grasses,
legumes and other non-grass forage crops), tobacco, all fiber crops and all nursery
crops (ornamental, non-bearing fruit/nut trees and forestry crops).

1,3-D is classified as a non-food use pesticide (and thus there are no tolerances or
exemptions from the requirement of a tolerance).

TARGET PESTS FOR SINGLE ACTIVE INGREDIENT:
Plant-Parasitic Nematodes: all types

Plant Diseases:  bacterial canker of peaches, sugar beet rhizomania, fusarium wilt
of cotton, verticillium wilt of mint

Invertebrates: symphylans (garden centipedes), wireworms

Weeds: Canada thistle, field bindweed  (perennial morning glory), quackgrass, and
certain other deep-rooted perennial weeds in cropland

TYPES/FORMULATIONS REGISTERED:
   End Use Products -

       Liquid-Ready to Use - 78.3 to 94.0% (78.3%, and 94.0% multiple and
       single active ingredient products, respectively)

       Note:  single and multiple active ingredient "me too" products containing
       37.6 to 94.0% 1,3-dichloropropene are also currently registered.

METHODS AND RATES OF APPLICATION:

Types of Treatment:  Soil fumigation, broadcast and/or row treatments, and
individual  tree planting site treatments

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              Equipment:  Soil injection equipment (chisel, Nobel plow, or plow-sole); Deep
              drip irrigation (6 or more inches deep)

              Timing: Preplant (all crops); at planting (pineapple)
              Application Rates:  See rates listed in Appendix A for the Dow AgroSciences
              products (62719-12, 62719-32), which reflect the maximum rates of 1,3-D in
              single and multiple ingredient (i.e., with chloropicrin) formulations, respectively.
              Maximum rates for uses on vegetable and field crops varies with the soil type.
              Maximum rates for a given crop are typically slightly higher for the multiple active
              ingredient product than the single active ingredient product.

              USE PRACTICE LIMITATIONS (APPLIES TO ALL 1,3-D PRODUCTS):

              1,3-D is a restricted use pesticide (certified handlers only).  Label statements
              include a 300 foot no-treatment buffer zone between treated fields and occupied
              structures, a five-day restricted entry interval for workers, closed loading,  soil
              sealing immediately  following application. In addition, labels suggest waiting at
              least one week for every gallon of 1,3-D applied before planting due to
              phytotoxicity.

              See section IV.  C. (3) for a list of detailed restrictions.

       C.     Estimated Usage of Pesticide

       This section summarizes the best estimates available for the pesticidal uses of 1,3-D.
These estimates are derived from a variety of published and proprietary sources available to the
Agency,  The estimates presented in Table 1 are primarily from  a 1991 Data Call-In for use and
usage.

       All 1,3-D is used on agricultural crops; there are  no residential uses.  The following table
estimates 1,3-D use by site:

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Table 1. Major 1,3-D Usage Sites
Crop
Crucifers
Peppers
Cucurbits
Sugar Beets
Cotton
Tobacco
Irish Potato
Sweet Potato
Peanut
Fruit/Nut
Trees and
Grape Vines
Onions
Tomato
Carrots
Pineapple
Strawberries
Acres Treated (000)
weighted
average
10
5
13
45
85
80
80
N/A
12
27
5
2
2
5
1
estimated
maximum
22
10
27
55
150
102
95
N/A
25
54
10
5
4
7
4
% Crop Treated
weighted
average
4
4
2
3
1
11
6
N/A
1
6
5
0
2
14
1
estimated
maximum
8
8
4
4
1
15
7
N/A
2
13
10
1
4
19
3
Ibs a.i. applied (000)
weighted
average
2000
400
600
4000
2000
7200
1350
N/A
700
2400
1000
200
150
1300
80
estimated
maximum
3500
800
1200
5500
6000
9000
1700
N/A
1900
5000
2000
800
250
2600
170
States where
most usage
occurs
AZ,TX,GA,
SC, NC,CA
NM,NC,CA
TX,AZ,SC,
NC,GA,CA
NE,WY,CO,
ID
AZ,NC,GA,
FL,CA
NC,SC,GA
WA,ID,OR,
CO,ND,MI
NC, GA, SC
AL,GA,TX
CA,SC,NC,
AZ,GA,NJ
OR,WA,ID
GA,FL,AL
CA,WA,TX
HI
CA,FL,NJ
Usage data covers 1990-1995 for most sites and as early as 1987 for other sites, primarily using data from the 1991 Use Usage and Product
Performance DCI. California data is only available for 1994 and 1995 due to the 1991-1993 use permit suspension and limited re-entry program.
"Weighted average" weights the more recent years' estimates because they tend to be more reliable estimates than for possibly outdated earlier
estimates.
        D.     Data Requirements and Regulatory History

        1,3-D was first registered in 1954 in the United States.  A Registration Standard was
issued in  1986, along with a Position Document announcing initiation of a Special Review (51 FR
36160) based on cancer concerns for workers.  The Standard evaluated the available data with

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other relevant information on 1,3-D and required the submission of additional data to maintain the
existing registrations and to further refine the risk assessment for the Special Review.

       On April 13, 1990, California suspended use permits for 1,3-D because unacceptably high
levels of airborne 1,3-D were detected through its air monitoring program.  After California
suspended the  1,3-D use permits, EPA looked more closely at the risk posed to residents who live
in the vicinity of treated fields. In 1992, Dow AgroSciences (at that time DowElanco), agreed to
label measures to reduce the amount of  1,3-D that volatilizes into the atmosphere, including
closed loading, shut-off valves to prevent 1,3-D from spilling at row turns, improved product
stewardship, a phase-out of drum delivery, and reduced application rates. DowElanco also agreed
to conduct studies to determine the mitigation value of these and other measures.

       In  1996, other measures, including the Worker Protection Standard requirements for
Personal Protective Equipment (PPE), were added to 1,3-D labels, including soil sealing, a 300-
foot no-treatment buffer from occupied  structures and other requirements designed to minimize
the  amount of  1,3-D that volatilizes (Gibson, 1996). These measures reduced exposures for both
workers and anyone else who lives or works in the vicinity of treated fields.

       On September 30, 1998,  Dow AgroSciences requested modification of the terms and
conditions of 1,3-D  registrations to include use prohibition in certain northern tier states (ND,
SD, MN, NY, ME, NH,  VT, MA, UT, MT, WI), a 100-foot no-treatment buffer to drinking
water wells, prohibition of use in areas overlying karst geologies and additional monitoring to
confirm that use of 1,3-D does not pose unreasonable risks when used according to product labels
(Roby, 1998).  The benefits of these measures are to reduce risks for anyone who drinks water
from wells in the vicinity of treated fields, particularly wells in unconfmed aquifers.

       Dow AgroSciences is developing confirmatory data for reregi strati on, to include tap water
monitoring in certain 1,3-D use areas, a  run-off study and data on the toxicity and environmental
fate data for 3-chloroacrylic acid and chloroallyl alcohol.

       This Reregi strati on Eligibility Decision reflects an assessment of the data which were
submitted in response to the 1986 Registration Standard and the 1991, 1992 and 1996 DCFs.

III.    SCIENCE ASSESSMENT

       A.     Physical  and Chemical  Properties Assessment

              1.     Identification of Active Ingredient

       The active ingredient 1,3-dichloropropene (1,3-D, or Telone) is a soil fumigantused
preplant to control root-knot nematodes and other soil pests and diseases.   1,3-D is a mixture of
isomers; in the figures below, the trans isomer is on the left, and cis on the right.

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                                              H C
                                                 ^Cl
       Empirical Formula:          C3H4C12

       Molecular Weight:          110.98

       Physical State: liquid under pressure, volatile

       Odor:               sweet, pungent, penetrating

       Water Solubility:      2,180 mg/L for cis isomer
                           2,320 mg/L for trans isomer

       Vapor Pressure:      34.3 mmHg for cis isomer at 25°C
                           23.0 mmHg for trans isomer at 25°C

       Boiling Point:        104°C for cis isomer
                           112.6°C for trans isomer

       Specific Gravity:      1.209 g/mL at 25°C

             2.     Manufacturing and End-Use Product Chemistry

       A search of EPA's Reference Files System conducted on September 9, 1998 identified no
1,3-D manufacturing-use products (MPs) under Shaughnessy No. 029001. Although the 1985
1,3-D Reregi strati on Standard dated identified a single 94% formulation intermediate registered
to Dow Chemical Company (EPA Reg. No. 464-511), the product has since been transferred to
Dow AgroSciences (EPA Reg. No. 62719-32) and is currently registered as an end-use product
(EP).  The product jackets for 1,3-D EPs confirms that the Dow AgroSciences  94% EP/MP is
the source product for other formulations; therefore, generic (TGAI) and product-specific (MP)
data are required to support its use as an MP. Dow AgroSciences has submitted an application to
also market their 94% 1,3-D product as a manufacturing use product to reformulators; this
application is under review.

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              3.
      Conclusions
       All pertinent generic data requirements are satisfied for the 1,3-D TGAI except for the
new data requirement concerning UV/visible absorption (OPPTS GLN 830.7050). All product-
specific data requirements are satisfied for the 94% EP/MP; however, the ingredient certifications
(OPPTS GLN 830.1750) must be submitted on EPA Form 8570-4.  The data requirements for
product chemistry are presented in Appendix D. In addition, the registrant must certify that the
suppliers of beginning materials and the manufacturing processes have not changed since the last
comprehensive product chemistry review or submit a complete updated product chemistry data
package.
       B.
Human Health Assessment
              1.
      Hazard Assessment
       All toxicology guideline studies are fulfilled and the data base for 1,3-D is adequate to
support reregi strati on eligibility. Across the battery of toxicology studies, the Tel one test
products contained various amounts of 1,3-D depending on the formulation available at the time
of testing. Because of this, the toxicity tests were performed with varying percentages of the a.i.
EPA does not believe the variations in levels warrants additional testing.

                    a.     Acute Toxicity

The acute toxicity values and categories for 1,3-D are summarized below:
Table 2. Acute Toxicity of 1,3-Dichloropropene
OPP
Guideline
No.
81-1
81-2
81-3
81-4
81-5
81-6
81-8
OPPTS
Guideline
No.
870.1100
870.1200
870.1300
870.2400
870.2500
870.2600
870.6200
Study Type
Acute Oral
Acute Dermal - Rabbit
Acute Inhalation
Primary Eye Irritation
Primary Skin Irritation
Dermal Sensitization
Acute Neurotoxicity
MRID #(S).
40220901
40220902
40220903
40220904
40220905
40220906
none
Results
LD50 = 300 mg/kg (M)
224 mg/kg (F)
LD,0 = 333 mg/kg
LC50 = 3.88mg/L(M)
4.1mg/L(F)
Intermediate irritant
Slight irritant
Sensitizer
None required
Toxicity
Category
II
II
IV
II
III
	
~

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       The oral LD50 in the rat was 300 mg/kg in males and 224 mg/kg in females (Toxicity
Category II).  Clinical signs included diarrhea, lacrimation, chromodacryorrhea, palpebral closure,
facial/perineal soiling, labored respiration and rough hair coat.  Gross necropsy revealed gastric
hemorrhage, watery contents and mucus in the cecum, thickened stomach wall and adhesions
between the stomach  and abdominal wall  (MRID 40220901).

       The dermal LD50 in the rabbit was 333 mg/kg.  Animals exhibited restlessness, squealing,
lethargy, transient anorexia, labored respiration and diarrhea. Skin findings were erythema,
edema, necrosis and scabs. Gross necropsy revealed mottled skeletal muscles in hind limbs,
multifocal erosions and/or ulcers of the stomach and fecal soiling of the perineal area (MRID
40220902).

       The inhalation LC50 in the rat was  3.88-4.69 mg/L in males and 4.1 mg/L in females
(Toxicity Category IV). Animals exhibited tremors, convulsions, salivation, lacrimation, diarrhea
and lethargy.  Gross necropsy revealed hemorrhaging in multiple lung lobes (MRID  40220903).

       Instillation of Telone II (94% a.i.)  in rabbit eyes resulted in intermediate irritation
(Toxicity Category II). By day 14, all evidence of corneal opacity, iris irritation, conjunctival
redness, chemosis and discharge had disappeared (MRID 40220904).

       In a rabbit dermal irritation study,  very slight erythema and edema were noted (Toxicity
Category III). At 72 hours, 5 of 6 animals had well-defined erythema,  1 of 6 exhibited very slight
erythema, 2 of 6 exhibited slight edema and 2 of 6 had very slight edema (MRID 40220905).

       Telone II (94% a.i.) was a sensitizer in guinea pigs (MRID 40220906).

                    b.     Subchronic Toxicity

                           (i)     Oral

       Telone II (96.0% a.i.) was administered to Fischer 344 rats (10/sex/group) at dietary
levels of 0, 5, 15, 50 or 100 mg/kg/day for 13 weeks. Body weights and weight gains, as well as
food consumption, were reduced at 50 and 100 mg/kg/day in both sexes (questionable reduction
in male body weights/gains at 5 and 15 mg/kg/day). Doses of 15, 50 and 100 mg/kg/day caused
hyperkeratosis and/or basal cell hyperplasia in the nonglandular portion of the stomach of both
sexes.  The NOEL was 5 mg/kg/day. The LOEL was 15 mg/kg/day based upon hyperkeratosis
and/or basal cell hyperplasia in the nonglandular portion of the stomach of both sexes (MRID
42954802).

       In a subchronic study, Telone II (96.0% a.i.) was administered  to BgCjFj mice
(10/sex/group) at dietary levels of 0, 15, 50,  100 or 175 mg/kg/day for 13 weeks.  Body weights
and weight gains were lower than the controls in males and females at  50, 100 and 175 mg/kg/day
(27, 36, 39 and 58% in males and 7, 22, 30 and 32% in females).  The NOEL was 15 mg/kg/day.

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The LOEL was 50 mg/kg/day based on lower body weights and body weight gains compared with
controls in males and females (MRID 42954801).

       The data requirement for a subchronic dog study was waived because a one-year study
had been conducted.

                           (ii)    Inhalation

       In a 30 day inhalation study, Fischer 344 rats (10/sex/group), were exposed to Telone II
("production grade" - no percentage of a.i. presented) at concentrations of 0, 3, 10 or 30 ppm (0,
0.0136, 0.045 or 0.136 mg/L), 6 hours/day, 5  days/week for 4 weeks. There was no mortality at
any dose level. Body weights of male rats at all concentrations were similar to that of the
controls.  Females exhibited a slight decrease in body weights.  There was an increase in the
incidence of enlarged peribronchial lymph nodes in males at 3 and 10 ppm, but not at 30 ppm; the
incidences were 1, 5, 6 and 2 at 0, 3, 10 and 30 ppm, respectively. Because there was no dose-
response as well as lack of an effect on peribronchial lymph nodes at 30 ppm, the NOEL was
considered to be 30 ppm (0.136 mg/L, highest dose tested) and the LOEL was > 30 ppm (0.136
mg/L) (MRID 00039685).

       In a 30 day inhalation study, CD-I mice (10/sex/group), were exposed to Telone II
("production grade"- no percentage of a.i. presented) at concentrations of 0, 3, 10 or 30 ppm (0,
0.0136, 0.045 or 0.136 mg/L), 6 hours/day, 5  days/week for 4 weeks. There was no mortality at
any dose level. There were no test article related findings at any dose. The NOEL was 30 ppm
(0.136 mg/L,  highest dose tested) and the LOEL was > 30 ppm (0.136 mg/L) (MRID 00039685).

       In a subchronic toxicity study, Fischer 344 rats (10/sex/group) were exposed to Telone II
(90.9% a.i.) at concentrations of 0, 10, 30, 90 or 150 ppm (0, 0.045, 0.136, 0.408 or 0.680
mg/L), 6 hours/day, 5 days/week for 13  weeks.  Both sexes at 90 and 150 ppm exhibited a
significant decrease in body weights while rats at 30, 90 and 150 showed treatment-related
histopathological lesions in the nasal turbinates. The NOEL was 10 ppm (0.045 mg/L) and the
LOEL was 30 ppm (0.136 mg/L) (MRID 00146461).

       In a subchronic toxicity study, BgCjFj  mice (10/sex/group) were exposed to Telone II
(90.9% ai) at  concentrations of 0,  10, 30, 90 or 150 ppm (0, 0.045, 0.136, 0.408 or 0.680 mg/L),
6 hours/day, 5 days/week for 13 weeks.  Both sexes at 90 and 150 ppm exhibited a significant
decrease in body weights while females  showed epithelial degeneration and hyperplasia of the
nasal turbinates.  The NOEL was 30 ppm (0.045 mg/L) and the LOEL was 90 ppm (0.136 mg/L)
(MRID 00146461).
                                          10

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                    c.     Chronic Toxicity/Carcinogenicity

                           (i)     Oral

       In a chronic toxicity/carcinogenicity study, Telone II (96% a.i.) was administered as
microcapsules by dietary admix to Fischer 344 rats (60/sex/group with 10/sex/group sacrificed at
12 months) at levels of 0, 2.5, 12.5 or 25 mg/kg/day for two years.  Body weight gains were
decreased for males (8 and 21%) and females (15 and 25%) at 12.5 and 25 mg/kg/day compared
to controls. Food consumption was decreased in females at 25 mg/kg/day. There was an increase
in liver masses/nodules in males only at 12.5 and 25 mg/kg/day. There was an increased incidence
of basal cell hyperplasia of the nonglandular mucosa of the  stomach of both sexes at the 12- and
24-month sacrifices at 12.5 and 25 mg/kg/day. For chronic toxicity, the NOEL was 2.5
mg/kg/day  and the LOEL was 12.5 mg/kg/day based on a decrease in body weight gain
compared with controls and an increase in the incidence of basal cell hyperplasia of the
nonglandular mucosa of the stomach. There was evidence of carcinogenicity.  The incidences of
rats with primary hepatocellular adenomas were as follows  respectively (0, 2.5, 12.5 or 25
mg/kg/day): males = 2/50,  1/50, 6/50 and 9/50; females = 0/50, 0/50, 0/50 and 4/50.  These data
indicate that exposure to 1,3-D increases the incidence of these tumors in males at the two highest
doses and in females at the highest dose. The highest dose tested in this study (25 mg/kg/day)
was considered adequate to assess the carcinogenic potential of 1,3-D in rats (MRTD 43763501).
The results of this study were used to establish the oral reference dose (RfD).

       In a study reported by the National Toxicology Program (NTP) in 1985, 1,3-D (89.0%
a.i.) was administered in corn oil (with  1.0% epichlorohydrin) by gavage to Fischer 344 rats
(52/sex/group) at doses of 0,  25 or 50 mg/kg/day three times per week for 104 weeks. Basal cell
or epithelial hyperplasia of the forestomach was reported. At 0, 25 and 50 mg/kg/day, squamous
cell papillomas of the forestomach (1/52, 1/52 and 9/52 in males respectively;  0/52, 2/52 and 3/52
in females respectively), squamous cell carcinomas of the forestomach (0/52, 0/52 and 4/52 for
males) and neoplastic nodules of the liver (1/52, 6/52 and 7/52 for males respectively ; 6/52, 6/52
and 10/52 for females respectively) were seen. The NTP concluded that there was "clear
evidence of carcinogenicity" for males and "some evidence" of carcinogenicity for females (MRTD
00146469).

       In a two-year toxicity/carcinogenicity study in B6C3F1 mice (50/sex/group), Telone II
(95.8% a.i.) was administered as microcapsules by dietary admix at levels of 0, 2.5, 25 or 50
mg/kg/day. There were no test article effects on clinical signs, mortality, ophthalmology,
hematology parameters, organ weights, macroscopic pathology or microscopic pathology. For
chronic toxicity, the NOEL was 2.5  mg/kg/day.  The LOEL was 25 mg/kg/day for both sexes
based on lower body weights and a decrease in weight gains compared with controls.  There was
no evidence of carcinogenicity (MRTD 43757901).

       In a study with B^Fj mice (50/sex/group) reported by NTP in 1985, Telone II (89.0%
ai) was administered in corn oil (with 1.0%  epichlorohydrin) by gavage at doses of 0, 25 or 50
mg/kg/day three times per week for 104 weeks.  The study in males was not considered to be

                                           11

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adequate because of the mortality of controls at weeks 48-51 (25/50, myocarditis) and the 104-
week survival for males (8/50, 28/50 and 31/50).  Squamous cell papillomas of the forestomach
(0/50, 1/50 and 2/50 for females), squamous cell carcinomas of the forestomach (0/50, 0/50 and
2/50 for females), transitional cell carcinomas of the urinary bladder (0/50, 8/50 and 21/48 for
females) and alveolar/bronchiolar adenomas (0/50, 3/50 and 8/50 for females) were seen. In
males, the study was considered to be inadequate for carcinogenicity (due to mortality of
controls). For females, there was "clear evidence of carcinogenicity" (MRID 00146469).

       In a chronic toxicity study, beagle dogs (4/sex/group) were administered Telone II (95.8%
a.i.) as a dietary admix at levels of 0, 0.5, 2.5 or 15 mg/kg/day for one year. At 15 mg/kg/day,
there was: decreased body weight gain; hypochromic, microcytic anemia (increase in erythrocytes
along with decreases in hemoglobin, hematocrit, mean corpuscular volume and mean corpuscular
hemoglobin); hematopoietic activity in bone marrow and spleen;  and a possible increase in
absolute liver weights  in males. For chronic toxicity, the NOEL was 2.5 mg/kg/day and the
LOEL was 15 mg/kg/day based on a decrease in body weight gain compared with controls,
microcytic anemia and an increase in hematopoietic activity.  The study results also suggested a
test-article related increase in absolute liver weights in males compared with controls at the LOEL
(MRID 42441001).

                           (ii)    Inhalation

       In a chronic toxicity/carcinogenicity study, Fischer 344 rats (50/sex/group plus
10/sex/group to 6- and 12-month exposure groups) were exposed by whole-body inhalation to
Telone II (92.1% a.i.)  at aerosol concentrations of 0, 5, 20 or 60 ppm (equivalent to
approximately 0, 0.023, 0.091 or 0.272 mg/L), 6 hours/day, 5 days/week for a total of 509 days
over a two-year period. There was no effect of exposure to 1,3-D on the survival of males or
females.  Slight (approximately 5% in 60 ppm males and females, as well as 3% in 20 ppm males)
decreases in body weight gains were observed (statistically significant, p<0.05) but generally only
during the first year of the study.  The olfactory region of the nasal cavity appeared to be the
target tissue as determined by histopathological examination.  Males and females having been
exposed to 60 ppm (no evidence reported at lower concentrations of 20 or 5  ppm) showed
decreased thickness and erosions of the epithelium as well as minimal submucosal fibrosis. For
chronic toxicity,  the NOEL was 20 ppm (0.091 mg/L)and the LOEL was 60 ppm (0.272 mg/L)
based on histopathological  changes in nasal tissue as well as the suggestion of decrease in body
weight gain compared with controls during the first year of the study. There was no evidence of
carcinogenicity (MRID 40312201). The results of this study were used to develop an
intermediate residential/bystander inhalation NOEL (see sections III.C.5 and III.D.l).

       In a chronic toxicity/carcinogenicity study, B6C3F1 mice (50/sex/group plus 10/sex/group
to 6- and 12-month exposure groups) were  exposed by whole-body inhalation to Telone II
(92.1% ai) at aerosol concentrations of 0, 5, 20 or 60 ppm (equivalent to approximately 0, 0.023,
0.091 or 0.272 mg/L) 6 hours/day, 5 days/week for a total of 510 days over a two-year period.
There was no effect on survival (at least 80% in each group). There was a statistically significant
decrease in body weight gain in 60 ppm males (3-9%) and females (2-11%).  Urinary bladder

                                           12

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effects were noted primarily in females at 20 and 60 ppm (slight, moderate or marked roughened,
irregular and opaque surfaces were reported in 20/50 at 20 ppm and 30/49 at 60 ppm compared
with 3/50 slight in the control group). Hypertrophy and hyperplasia of the nasal respiratory
mucosa  (very slight/slight) were observed in most 60 ppm mice of both sexes and in 20 ppm
females. Degeneration of olfactory epithelium (very slight/slight) was noted in most 60 ppm mice
of both sexes. Hyperplasia of the epithelial lining of the nonglandular portion of the stomach was
observed in 60 ppm males (0, 5, 20 and 60 ppm: males =  0, 3, 1 and 8; females = 0, 0, 0 and 2
respectively). For chronic toxicity, the NOEL was 5 ppm (0.023 mg/L) and the LOEL was 20
ppm (0.091 mg/L) based on urinary bladder hyperplasia and hypertrophy/hyperplasia of the nasal
respiratory mucosa. Hyperplasia of the epithelial lining of the nonglandular portion of the
stomach was observed in a higher incidence compared with controls in 60 ppm males and, to a
lesser extent, 60 ppm females.  There was evidence of carcinogenicity. Bronchioloalveolar
adenomas appeared in a higher incidence in 60 ppm males only compared with controls (0, 5, 20
and 60 ppm = 9/50, 6/50, 13/50 and 22/50 respectively).  Although the lung tumors noted in this
mouse inhalation study were benign, the tumor induction was dose  dependent, the tumor
incidence was outside the range of historical controls and the tumor type was also seen in the
mouse oral  bioassay (MRID 40312300).

                    d.     Developmental Toxicity

      In a developmental toxicity study, Fischer 344 rats (30 females/group) were exposed
during gestation days 6 through 15 to aerosol concentrations of Telone II (90.1% a.i.) at 0, 20, 60
or 120 ppm (equivalent to approximately 0, 0.091, 0.272 or 0.545 mg/L) 6 hours/day. The
maternal NOEL was < 20 ppm (< 0.091 mg/L). The maternal LOEL was 20 ppm (0.091 mg/L)
based on decreased body weight gains and food consumption compared with controls during the
exposure days. The developmental NOEL was 60 ppm (0.272 mg/L). The developmental LOEL
was 120 ppm (0.545 mg/L) based on increase in delayed ossification of the vertebral centra. No
1,3-D-related malformations were reported (MRID 00152848).

      New Zealand rabbits (17-24 females/group) were exposed to aerosol concentrations of
Telone II (90.1% a.i.) at 0,  20, 60 or 120 ppm (equivalent to approximately 0, 0.091, 0.272 or
0.545 mg/L), 6 hours/day during gestation days 6 through 18.  The  maternal NOEL was 20 ppm
(0.091 mg/L).  The maternal LOEL was 60 ppm (0.272 mg/L) based on decreased body weight
gains compared with controls.  The developmental NOEL was 120  ppm (0.545 mg/L). The
developmental LOEL was >120 ppm (> 0.545 mg/L, HDT). No 1,3-D related malformations
were reported (MRID 00152848).

                    e.      Reproductive Toxicity

      In a two-generation inhalation reproduction study, Fischer 344 rats (F0 adults, 30 males
and 40 females/group) were exposed to aerosol concentrations of Telone II (91.2% a.i.) at 0, 10,
30 or 90 ppm (equivalent to approximately 0, 0.045, 0.136  or 0.408 mg/L) 6 hours/day.  The
durations of exposure (6 hours/day) were as follows: F0 males and females 5 days/week prior to
breeding and 7 days/week during breeding at weeks 11 to 13, then during gestation and lactation;

                                          13

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Fla and Flb generations, dams from gestation day 20 until postpartum day 5; Fx male and female
parents, after weaning (about week 32 of the study) and continued for 12 weeks, but for 5 days
per week, 6 hours/day; and F0 to Fx until adults were sacrificed. Pregnant females were not
exposed to 1,3-D from gestation day 20 to postpartum day 4. Pups were not exposed to 1,3-D
(dams separated from pups for 6 hours of exposure/day during lactation days 5 to 28). For
parental/systemic toxicity, the NOEL was 30 ppm (0.136 mg/L). The LOEL was 90 ppm (0.408
mg/L) based on a decrease in body weight gain compared with controls, as well as microscopic
nonglandular stomach lesions (mainly mucosa) and hyperplasia of the nasal respiratory epithelium
with focal degeneration of the olfactory tissue. No reproductive toxicity was seen. For
reproductive toxicity, the NOEL was 90 ppm and the LOEL was >90 ppm (HOT) (MRID's
40312401 and 40835301).

                    f.     Mutagenicity

       There was a positive effect in the Salmonella assay in strains G46, TA98, TA100 and
TA1535 with and without activation and in  strains TA1538 and TA1537 with activation.
Responses up to approximately lOOx and lOx background in strains TA1535 and TA100,
respectively, were seen (MRTD 00039688).  1,3-D, in the absence of metabolic activation, was
positive in the B. subtilis rec-assay only at 1,250 jig/well (MRTD 00039688).  Up to a toxic
concentration of 1,000 jig/plate, no positive results were reported in the E. coli reversion test
with or without activation (MRTD 00039688). A mouse host-mediated assay with Salmonella
typhimurium strain G46 was negative. However, the oral gavage dosing of the mice up to 60
mg/kg may not have been high enough as adequate toxicity was not reported (MRID 00039680).
Non-reproducible increases (just at 2x background) were reported in the nonactivated phase of
the Chinese hamster ovary (CHO/HGPRT) gene mutation assay at  100, 150, 200, and 250 \M
(MRID  00159679).  1,3-D was  negative in an unscheduled DNA synthesis (UDS) assay with
primary rat hepatocytes up to consistently cytotoxic doses (> 10"4 M) (MRID 00146467).

       Data from the open literature also indicate that 1,3-D is mutagenic in Salmonella and
cultured mouse lymphoma cells and induces chromosomal aberrations, sister chromatid exchange,
and DNA strand breaks in several mammalian cell lines in vitro. Overall, the data from somatic
cell assays are indicative of a mutagenic concern for 1,3-D and support the weight-of-the-
evidence evaluation for carcinogen!city.

       1,3-D was also positive  for the induction of sex-linked recessive lethal mutations but not
reciprocal translocations in Drosophila melanogaster (MRID 00146469). To confirm the results
of the Drosophila sex-linked recessive lethal assay, a Data Call In (DCI) was issued for an in vivo
alkaline elution assay in testicular cells (following inhalation  administration) on June 17, 1996.
The Registrant chose to perform an inhalation dominant lethal assay, which is an acceptable
substitute. 1,3-D tested negative in this assay.  Results from this study show that  1,3-D,
administered by inhalation at concentrations up to 150 ppm («682 mg/m3) 6 hours/day, 7
days/week for 10 weeks did not induce a dominant lethal effect in male rat germinal  cells (MRTD
44302801). The negative findings of this study lessen the concern for germ cell effects; therefore,
no further mutagenicity testing is required. Dow AgroSciences is conducting additional

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mutagenicity studies for the alcohol and acid degradates; for purposes of this reregi strati on, EPA
is assuming equivalent mutagenic potential to the parent.

                     g.      Metabolism

       An oral pharmacokinetics study was conducted in Fischer 344 rats and B6C3F1 mice.  For
the non-protein sulfhydryl studies, the following single oral non-radioactive doses were
administered: 0,  1, 5, 25, 50 or 100 mg/kg.  Single oral 14C Tel one II doses of 0, 1, 50 or 100
mg/kg were administered for the binding studies. The primary route of excretion for both species
was the urine. The two major urinary metabolites were identified as 1,3-DCP-mercapturic acid
and its sulfoxide (or sulfone) derivative. Following oral administration, most of the radio label
was found in the stomach and gastrointestinal tract with lesser amounts in the kidneys, liver,
urinary bladder, skin, fat, blood and carcass.  Oral administration also depleted the non-protein-
sulfhydryl contents of several tissues including the non-glandular stomach (both time- and dose-
dependent). Dose-related increases in macromolecular bindings were noted in several organs with
the highest binding sites being found in the non-glandular stomach (MRTD  00155846).

       In another study with Fischer 344 rats, gavage administration of Telone II at 5 mg/kg/day
for 14 days resulted in rapid absorption from the gastrointestinal tract with  distribution to all
tissues examined.  Highest concentrations appeared in the non-glandular stomach and urinary
bladder.  There was rapid elimination in the urine, feces, and as carbon dioxide in expired air.
Nine metabolites were isolated from urine with two being identified as 1,3-D-mercapturic acid
and the sulfoxide derivative.  No parent compound was present in the urine (MRTD 40959801).

                     h.      Dermal Absorption

       No dermal  absorption studies were required.  A waiver was granted for the 21-day dermal
toxicity study. The current use-pattern does not indicate a concern for potential dermal exposure.

                     i.       Epidemiological Data

The following data bases have been consulted for the poisoning incident data on the active
ingredient 1,3-dichloropropene.

                            (i)    OPP Incident Data System (IDS)

       The incident data system contains reports of incidents from various sources, including
registrants, other federal and state health and environmental agencies, and individual  consumers,
submitted to OPP since 1992.  Reports submitted to  IDS represent anecdotal reports or
allegations, unless  otherwise stated. Typically, no conclusions can be drawn implicating the
pesticide as a cause of any of the reported health effects. Nevertheless, with enough cases and/or
enough documentation risk mitigation measures may be suggested. No specific information  on
1,3-D was found.
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                           (ii)    California Department of Food and Agriculture
                                  (superseded by the Department of Pesticide Regulation
                                  in 1991)

       California has collected uniform data on suspected pesticide poisonings since 1982.
Physicians are required, by statute, to report to their local health officer all occurrences of illness
suspected of being related to exposure to pesticides. The majority of the incidents involve
workers. Information on exposure (worker activity), type of illness (systemic, eye, skin,  eye/skin
and respiratory), likelihood of a causal relationship, and number of days off work and  in the
hospital are provided.

                           (iii)   National Pesticide Telecommunications Network
                                  (NPTN)

       NPTN is a toll-free information service supported by OPP.  A ranking of the top  200
active ingredients for which telephone calls were received during calendar years 1984-1991,
inclusive has been prepared.  The total number of calls was tabulated for the categories human
incidents, animal incidents, calls for information, and others.

                           (iv)   Summary/Conclusions of Epidemiology Data

       From the review of California data on suspected 1,3-D poisonings, it appears that a
majority of incidents involved illnesses or injuries to workers who applied 1,3-D as a soil fumigant
in fields.  A large proportion of the cases occurred when workers were preparing, operating,
cleaning, or repairing application equipment; however, label changes since 1992 have been
adopted which may  have prevented reported exposures.  Some individuals with inhalation
exposures have reported symptoms such as headache, chest pain, fatigue, irritability or difficulty
concentrating, persisting for as  long as two years after initial exposure.

       Accidental ingestion of 1,3-D (concentration and amount unknown) has led to  one
reported fatality. In a cluster episode, two of nine firemen developed lymphoma six years after
exposure to a 1,3-D spill.  Other data or evidence from other epidemiologic studies would be
needed before an association can be supported.

              2.     Dose-Response Assessment

                    a.     Determination  of Susceptibility to Infants and Children

       Under the Food Quality Protection Act (FQPA), P.L. 104-70, which was promulgated in
1996 requires the EPA to "ensure that there is  reasonable certainty that no harm will result to
infants and children" from aggregate exposure to a pesticide chemical residue.  The law further
states that in the case of threshold effects, for purposes of providing this "reasonable certainty of
no harm," an additional tenfold margin of safety for the pesticide chemical residue and other
sources of exposure shall be applied for infants and children to take into account potential pre-and

                                            16

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post-natal toxicity and completeness of data with respect to exposure and toxicity to infants and
children. Notwithstanding this requirement for an additional margin of safety, the Administrator
may use a different margin of safety for the pesticide residues only if, on the basis of reliable data,
such margin will be safe for infants and children.

       1,3-D is a non-food use pesticide and therefore no tolerances or exemptions from the
requirement of a tolerance are required. Although the FQPA's requirements are  directed towards
tolerance actions, the Agency has reviewed the requirements of FQPA as  if 1,3-D were
undergoing a tolerance review.

       There are no data gaps for the assessment of increased susceptibility to infants and
children from exposure to 1,3-D. The Agency has reviewed acceptable prenatal developmental
toxicity studies in rats and rabbits and an acceptable two-generation reproduction study in rats
following inhalation exposures. The data provided no indication of increased susceptibility in rat
or rabbit fetuses following in utero exposure to 1,3-D.  No developmental toxicity was observed
at the highest concentration tested in the pre-natal developmental toxicity studies in rats and
rabbits tested. No offspring toxicity was seen at the highest concentration tested  in two
generation reproduction toxicity study.

       The Agency has determined that the 10X  additional safety factor for the protection of
infants and children (as required by FQPA) is not warranted and has been removed based on the
following factors:

              i.      No evidence of developmental toxicity was seen in the prenatal studies in
                     rats and rabbits and no offspring toxicity was seen in the postnatal toxicity
                     study in rats following inhalation exposure to 1,3-D;

              ii.      There was no evidence of abnormalities in the development of the fetal
                     nervous system in the pre/post natal studies submitted to the Agency;

              iii.     The toxicology database is complete;

              iv.     There is adequate data to conduct exposure assessments.

                     b.     Acute Dietary

       EPA has reviewed the available toxicological data for 1,3-D and concluded that the data
do not indicate any evidence of significant  oral toxicity from a single exposure event. Therefore,
the acute dietary risk assessment for a single event high end dietary exposure is not required.

                     c.      Chronic Reference Dose (RfD)

       An RfD of 0.025 mg/kg/day was determined based on the NOEL of 2.5 mg/kg/day
established in a 2-year dietary admix (microcapsules) study in rats (MRTD 43763501) and using

                                            17

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an uncertainty factor of 100.  The LOEL of 12.5 mg/kg/day was based on a decrease in body
weight gain and an increase in the incidence of basal cell hyperplasia of the nonglandular mucosa
of the stomach.

       Once a study has been evaluated and the observed effect has been determined to be a
threshold effect, EPA generally divides the NOEL from the most appropriate study by an
uncertainty factor (usually 100) to determine the RfD.  The RfD is a level at or below which daily
aggregate exposure over a lifetime is not expected to pose appreciable risk to human health.  An
uncertainty factor (formerly called "safety factor") of 100 is commonly used since it is assumed
that people may be up to 10 times more sensitive to pesticides than  the test animals, and also, that
one person or subgroup of the population (such as infants and children) could be up to 10 times
more sensitive than other individuals or subgroups. In addition, EPA assesses the potential risks
to infants and children based on the weight of the evidence of the studies and determines whether
an additional uncertainty factor is warranted.  An aggregate daily exposure to a pesticide residue
at or below the RfD (expressed as  100 percent or less of the RfD) is generally considered
acceptable by EPA. Table 9 presents the aggregate exposure and percent RfD.

                     d.      Classification of Carcinogenic Potential

       EPA classifies 1,3-D as a Group B2 (probable human) carcinogen based on oral  and
inhalation animal  studies. This classification was based on NTP studies showing increased tumors
in both sexes of rats (Fischer 344) and mice (B6C3F1) after oral administration of 1,3-D  (MRTD
00146469). Tumor types noted included forestomach, liver, mammary, thyroid, adrenal, urinary,
and lung. The carcinogenic potency factor (Qt*) for humans via the oral route is 1.22 x 10"1 using
the Multistage Model based on the incidence of combined forestomach, liver, adrenal, and thyroid
tumors in male rats and using the 3/4 interspecies scaling factor (Fisher 1994).

       EPA has also developed a potency factor (Qt*) for humans via the inhalation route.  This
Qj* is 5.33 x  10"2 based on increased bronchioloalveolar adenomas in male B6C3F1 mice from
inhalation studies using the linearized low dose extrapolation model and a 3/4 interspecies scaling
factor (Fisher 1994; MRID's 40312201, 40312300).

       The registrant submitted information as a rebuttal to a draft  RED on January 15, 1998
proposing that 1,3-D should be regulated as a non-linear carcinogen (i.e., that there is a
"threshold" dose below which there is no risk). While EPA does not believe it is appropriate to
delay this reregistration decision, EPA has agreed to reconvene the Carcinogenicity Peer Review
Committee sometime in 1999 to consider new information Dow AgroSciences submitted in 1998,
particularly that related to whether 1,3-D should be regulated as a non-linear carcinogen.  EPA is
currently developing policies on regulating non-linear carcinogens and no change to the risk
assessment can take place until those polices are officially adopted.
                                            18

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                     e.     Occupational and Residential Exposure

       EPA has identified the dose/end points to be used in the risk assessment for occupational
and residential exposures.  The current use-pattern does not result in exposure through foods
grown in 1,3-D-treated soils; however, due to the potential contamination of ground water and
consequently drinking water, the Committee has identified doses and endpoints for use in risk
assessments for potential ground/drinking water exposures.  The current formulations and
application methods indicate a potential for occupational or residential exposure primarily via the
inhalation route. Little dermal exposure is expected when 1,3-D is used according to label
directions, and therefore dermal exposure is not a concern at this time.  Doses and endpoints
identified are for both drinking water and inhalation exposures (occupational and
resi denti al/by stander).

                           (i)     Dermal Absorption

       No dermal absorption studies were required. A waiver was granted for the 21-day dermal
toxicity study.  The current use-pattern does not indicate potential dermal exposure.

                           (ii)    Inhalation Absorption

       1,3-D has been tested extensively by the inhalation route.  Therefore, inhalation endpoints
are available for risk assessment and route to route extrapolation is not necessary. For this risk
assessment, EPA assumes inhalation absorption to be 100 percent.

                           (iii)   Acute Dietary

       EPA has reviewed the available toxicological data for  1,3-D and concluded that the data
do not indicate any evidence of significant oral toxicity from a single exposure event. Therefore,
the acute dietary risk assessment for a single event, high-end dietary exposure is not required.

                           (iv)   Short Term Occupational/Residential

       EPA has reviewed the available 30-day inhalation studies for 1,3-D and concluded that the
data do not indicate any evidence of significant toxicity from repeated exposure of up to  4 weeks
duration. No effects were seen in either a rat or a mouse study.  Therefore, no endpoint  was
identified. The short-term occupational/residential risk assessment for  1,3-D is not required.

                           (v)    Intermediate Term Occupational and
                                  Residential/Bystander  (1 week to several months)

       For inhalation, the NOEL of 0.091 mg/L (20 ppm) will be used and is based on
histopathological lesions in the olfactory region of the nasal cavity at the LOEL of 0.272 mg/L
(60 ppm) in a 2-year  combined chronic toxicity/carcinogenicity inhalation study in F344 rats
(MRTD 40312201). The 90-day (MRTD 00146461) and 2-year inhalation studies were used in

                                            19

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conjunction to determine this endpoint. For intermediate term exposures, 90-day tests are
generally used; however, the dose selection from the 90-day study (10 ppm, 30 ppm, 90 ppm, 150
ppm) did not allow for selection of an appropriate NOEL when compared to NOEL's seen in
other studies.  EPA concluded that had the 20 ppm dose been used in the 90-day study, this
would likely have been the NOEL, and thus selected the NOEL of 0.091 mg/L (20 ppm)
established in the 2-year chronic study.

                           (vi)    Chronic - Occupational and Residential/Bystander

       No chronic inhalation exposure is expected for 1,3-D. The current use pattern results in
exposure for no more than 3 weeks at a time, generally only once a year.  Therefore, no chronic
non-cancer endpoint was selected and this risk assessment is not required.

                           (vii)   Office of Water Health Advisory for 1,3-D

       EPA's Office of Water has established a Health Advisory for 1,3-D at 0.2 ppb. This is the
level that can be consumed daily over a lifetime that is associated with a 1 x 10"6 cancer risk.  The
Health Advisory, however, is only advisory in nature and is not enforceable.  There is no
Maximum Contaminant Level (MCL) for 1,3-D.

                           (viii)   Risk Assessment Endpoints for 1,2-Dichloropropane
                                  (Impurity)

       1,2-Dichloropropane (1,2-D) is of interest because it is an impurity found in Tel one
products (0.06 to 0.1% by weight) and has been shown to migrate to ground water and persist for
many years.  EPA has not conducted a formal evaluation of the toxicology database for 1,2-D at
this time because 1,2-D is no longer registered as a pesticide. However, 1,2-D has been
evaluated by the Office of Research and Development (ORD) to support development of the
Drinking Water Criteria Document for the Office of Water (USEPA  1987). ORD evaluated the
limited available database for 1,2-D and concluded that the liver was the principal target organ of
toxicity. ORD also found effects from acute exposures; the effects were seen  in the lungs, liver,
kidneys central nervous system and eyes.  A more detailed description is on EPA's IRIS data
base.

       Subchronic oral exposure to 1,2-D resulted in liver congestion, hepatic fatty changes, and
liver necrosis  in rats receiving 1000 mg/kg/day, 5 days/week for 13 weeks. Mice showed slightly
depressed body weight after treatment with 500 mg/kg/day 1,2-D for 5 days/week for 13 weeks.

       EPA's Office of Water has established a 10-day health advisory for children of 0.09 mg/L.
This health advisory is based on the following assumptions: 10 kg child, consumption of one
L/day of water,  all exposure comes from water (i.e., no ambient inhalation exposure), and  a health
advisory value based on 7-30 days of exposure.  There is also a Maximum Contaminant Level of 5
ppb established by EPA's Office of Water.
                                           20

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       1,2-D has been classified as a Group B2, probable human carcinogen, with a Qt* of 3.69
xlO"2 (mg/kg/day)"1 based on the statistically significant increased incidence of hepatocellular
adenomas and carcinomas in male and female BgCjFj mice.  In addition, a dose-related trend in
mammary adenocarcinomas was noted in female F344 rats.  This is considered significant because
F344 rats have a relatively low background incidence of these tumors (FR 56(20):3540 (January
30,1991).  In addition,  1.2-D was mutagenic in the Salmonella and in Aspergillus nidulans. 1,2-
D also induced sister chromatid exchange and chromosome  aberrations in Chinese hamster ovary
cells.

                            (ix)   Endpoints for Degradates

       Two degradates of 1,3-D have been found in groundwater: 3-chloroallyl alcohol and 3-
chloroacrylic acid.  EPA has determined that the degradates 3-chloroallyl alcohol and 3-
chloroacrylic acid should be considered to have toxicological equivalence to the 1,3-D parent in
the absence of toxicology data for the degradates (Abbotts 1997).  For the water cancer risk
assessment, the 1,3-D oral Qt* will be used to estimate risk for combined exposure to parent and
degradates. In addition, the levels of the degradates found in the ground water studies will be
combined with 1,3-D levels to calculate non-cancer risks. The oral Qt* for 1,2-D will be used to
calculate cancer risk for this contaminant, but 1,2-D risks will not be added to 1,3-D risks to
develop a cumulative risk assessment. A summary of toxicological endpoints for 1,3-D and its
degradates of toxicological concern are presented below in Table 3.
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Table 3. Summary of Toxicological Endpoints for 1,3-dichloropropene and Related Compounds
1,3-D
Exposure Scenario
Intermediate
Residential/Bystander
Inhalation Exposure
Chronic Drinking Water
Exposure
Lifetime Inhalation (Cancer)
Lifetime Drinking Water
(Cancer)
Toxicological
Endpoint for Risk
Assessment
Inhalation NOEL =
0.091 mg/L
RfD = 0.025 mg/kg/day
Q!* = 5.33 X lO'2
(mg/kg/day)"1
Q!* =1.22X10-'
(mg/kg/day)-1
Endpoint
Histopathological lesions of nasal
cavity (olfactory region)
Decreased body wt gain and
increased incidence of basal cell
hyperplasia of nonglandular
mucosa of stomach
Lung bronchioloalveolar adenoma
tumor rates in male mice, 3/4
scaling factor, Multistage model
Combined forestomach, liver,
mammary, thyroid, adrenal, urinary,
lung tumors, Multistage Model, 3/4
scaling factor
Study
2-year combined chronic/
carcinogenicity inhalation
study in F344 rats MRID
40312201
2-year combined chronic
/carcinogenicity study in F344
rats (dietary admix,
microencapsulated
Telone)MRID 43763501
2-year combined chronic/
carcinogenicity inhalation
study in mice MRID
40312300
2-year combined chronic/
carcinogenicity study in F344
rats
MRID 00146469
Degradates: 3-chloroallyl alcohol and 3-chloroacrylic acid
Acute Dietary
Lifetime Drinking Water
(Cancer)
None
In lieu of data for
degradates, assume
potency equivalent to
parent, Qj* =1.22 X
10-1 (mg/kg/day)-1
None
Based on combined forestomach,
liver, mammary, thyroid, adrenal,
urinary, lung tumors, Multistage
Model, 3/4 scaling factor
None
2-year combined chronic/
carcinogenicity study in F344
rats
MRID 00146469
1,2-Dichloropropane (Impurity)
10-Day Health Advisory for
Children
MCL (adults)
Lifetime Drinking Water
(Cancer)
0.09 mg/L
0.005mg/L
Q!* =3.69 X 10-2
(mg/kg/day)-1
Office of Water Value
Based on incidence of hepatocellular
adenomas and/or carcinomas in
male mouse, Multistage Model, 3/4
scaling factor
Office of Water Value
2-year carcinogenicity study in
mice and rats, B2 Carcinogen
(described in EPA 1990)
22

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              3.      Dietary Exposure Assessment

                     a.      Dietary Exposure from Food Sources

                            (I)     Directions for Use

       All 1,3-D end-use products are registered for use as a preplant soil fumigation for soils to
be planted to all vegetable crops, field crops, and fruit and nut crops. Broadcast applications for
control of nematodes and garden symphylans can be made at rates up to 332.5 Ib a.i./A for
vegetable and field crops and up to 344.4 Ib a.i./A for fruit and nut crops. Banded applications
are permitted at rates not exceeding the per acre broadcast rate. Dow AgroSciences has applied
for a new registration for 1,3-D application via sub-surface drip irrigation systems; this application
is under review. Special Local Need Registrations (SLN's) OR940038 and WA940038 permit
application to potatoes at a maximum rate of 380 Ib a.i./A.  The worker restricted entry interval
(REI) is five days.

       A tabular summary of the residue chemistry science assessments for reregistration of 1,3-
D is included in Appendix B. The conclusions listed in Appendix A regarding the Reregistration
eligibility of 1,3-D uses are based on the use patterns registered by the basic producer, Dow
AgroSciences.
                            (ii)   Nature of the Residue in Plants

       The qualitative nature of the residue in plants is adequately understood based on soybean,
tomato, and sugar beet metabolism studies, and consists of natural plant biochemicals.  In studies
with tomatoes and soybeans, no residues of the parent, 3-chloroallyl alcohol, or 3-chloroacrylic
acid metabolites were detected.

                            (iii)    Nature of the Residue in Livestock

       The qualitative nature of the residue in animals is adequately understood based on
adequate goat and poultry  metabolism studies. The levels of radioactivity observed in tissues and
milk at high dosing levels are negligible and suggest that it is unlikely that detectable levels of 1,3-
D residues would occur in meat, milk, or eggs. Therefore, no feeding studies or tolerances are
required for meat, milk and eggs when 1,3-D is used as a pre-plant soil fumigant in soils planted
to feed crops.

                            (iv)    Residue Analytical Methods

       No tolerances are to be established for 1,3-D residues in/on plant or animal commodities.
As a result of this determination, there is no requirement for the development of enforcement
analytical methods for plant or animal commodities.
                                            23

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                           (v)     Multiresidue Method Testing

       Because tolerances are not required for soil fumigation uses of 1,3-D, the requirement for
multiresidue method testing is waived.

                           (vi)    Storage Stability Data

       Because tolerances are not required for soil fumigation uses of 1,3-D, the requirement for
storage stability data is waived.

                           (vii)    Magnitude of the Residue in Crop Plants

       Because metabolism data show ultimate breakdown of 1,3-D to non-toxic degradates and
subsequent re-incorporation into natural plant constituents, tolerances are not to be established
for plant commodities and residue data are not required for use as a preplant soil fumigant (Miller
1995).

                           (viii)   Magnitude of the Residue in Processed Food/Feed

       Because tolerances are not required for soil fumigation uses of 1,3-D, the requirement for
processing studies is waived.

                           (ix)    Magnitude of the Residue in Meat, Milk, Poultry, and
                                   Eggs

       No tolerances have been established for 1,3-D residues in animal commodities. The
requirements for ruminant and poultry feeding studies have been waived.

                           (x)     Magnitude of the Residue in Water, Fish, and Irrigated
                                   Crops

       1,3-D is presently not registered for direct use on potable water and aquatic food and feed
crops; therefore, no residue chemistry data are required under these guideline topics.

                           (xi)    Magnitude of the Residue in Food-Handling
                                   Establishments

       1,3-D is presently not registered for use in food-handling establishments; therefore, no
residue chemistry data are required under this guideline topic.

                           (xii)    Confined Accumulation in Rotational Crops

       An acceptable confined rotational crop study was conducted with wheat, lettuce, and
carrots and radishes.  The results were in agreement with those from primary plant metabolism

                                           24

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studies, showing extensive incorporation of radiolabelled residues into natural plant biochemical
constituents.  No plant-back restriction is required.

                            (xiii)   Field Accumulation in Rotational Crops

       Given the results of the confined study, field rotational crop studies are not required for
1,3-D.

                            (xiv)   CODEX Harmonization

       No Codex MRLs are in effect for 1,3-D residues. Therefore, there are no questions
regarding the compatibility of U.S. tolerances and Codex MRLs.

                            (xv)   Conclusions

       As noted above, all Reregistration data requirements for residue chemistry have been
satisfied, and tolerances are not required for 1,3-D use as a pre-plant soil fumigant. No 1,3-D
residues are expected to occur in plants.

              b.      Dietary Exposure from Drinking Water

                            (i)     Factors Influencing Drinking Water Exposure

       The amount of 1,3-D found in either ground or surface water is related to its physical and
chemical properties, as well as a number of local environmental conditions, including soil
temperature,  soil type,  and depth to ground water.  1,3-D, once applied,  migrates through the soil
profile. Transport can take 1,3-D down to ground water, laterally through the soil profile or up
from the point of application through volatilization.  1,3-D that is not transported either degrades
or is metabolized by soil bacteria.

       1,3-D's mobility in soil is measured by soil adsorption coefficients (Kd's) which range
from 0.23 in loamy sand to 1.09 in clay.  1,3-D has a low adsorption coefficient in a range of soils
and tends to partition preferentially into water over soil  (USEPA 1997).  1,3-D is considered to
be a mobile chemical.

       For this assessment, the half life of  a chemical in the environment is presented as two
different measurements: (1) the dissipation  half-life, which reflects physical transport (i.e.
volatilization) and  degradation, and (2) the  degradation half-life,  which reflects degradation via
biological and chemical mechanisms only.  These measurements  can be conducted in both the lab
and field.

       For 1,3-D, field dissipation studies  show half-lives of 1 to 7 days, but laboratory
measurements of aerobic soil metabolism show half-lives of up to 54 days. (Because of 1,3-D's
high volatility, the  aerobic soil metabolism  is likely a more accurate measurement of 1,3-D's

                                            25

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degradation half-life in soil.) Hydrolysis studies of 1,3-D show that hydrolysis is independent of
pH, but extremely variable with temperatures; longer half-lives are seen with low temperatures
(USEPA 1997).

       The major degradates of 1,3-D in soil are 3-chloroallyl alcohol and 3-chloroacrylic acid,
both of which were detected in the prospective ground water monitoring studies (USEPA 1997).
Information on the physical and chemical properties of 1,3-D's degradates, 3-chloroallyl alcohol
and 3-chloroacrylic acid, are limited; however,  the degradates are not expected to be as volatile as
1,3-D.

       1,3-D can migrate to ground water under certain conditions. Extensive ground water
monitoring has been conducted for 1,3-D, and detections have been reported from several states.
However, no information about past 1,3-D usage is available to correlate with retrospective
ground water monitoring data. Results of the Florida ground water prospective monitoring study
suggest that 1,3-D may also migrate to surface  water via atmospheric transport, i.e., dissolution
of 1,3-D vapors in  surface waters. Surface water modeling suggests 1,3-D can migrate to surface
water via runoff as well. Because of 1,3-D's volatility, it is not expected to persist in surface
waters at high concentrations. The stability  and persistence of its degradates in surface waters is
unclear, but they are likely to be substantially less volatile than the parent, and therefore may be
more persistent.

       The contaminant 1,2-D has a different environmental fate profile than 1,3-D.  1,2-D is
stable and highly persistent in the environment.  The degradation of 1,2-D is not temperature
dependent, unlike 1,3-D.  Laboratory studies also indicate that 1,2-D is also very mobile, and that
mobility is inversely proportional to the amount of soil organic matter.

                            (ii)    Drinking Water Standards

       1,3-D is not currently regulated under the Safe Drinking Water Act, however a Health
Advisory level (HA) of 0.2 ppb has been established for 1,3-D. Because the HA is advisory in
nature, public water supply systems  are not required to sample and analyze for 1,3-D.  The 0.2
ppb represents the level of daily consumption over a lifetime associated with a 1 x 10"6 cancer risk.

       The Office  of Pesticide Programs has developed drinking water Levels of Comparison
(DWLOC's) to capture risk associated with exposure  to pesticides in drinking water.  A
DWLOC, which is not an enforceable standard, is the concentration  of a pesticide in drinking
water that would be acceptable as an upper limit in light of total aggregate exposure to that
pesticide from food, water, and residential uses (if any). The DWLOC came about as part of
EPA's review of pesticides under the 1996 passage of FQPA, which required EPA to develop a
risk assessment tool to take into account these various exposures.

       For 1,3-D, EPA has calculated two DWLOC's. For residents who live near treated fields,
defined at the 300 feet buffer, the DWLOC for  cancer is zero because the inhalation risk estimates
are at or greater than 1 x 10"6 for this population. While the cancer risk estimates at distances

                                            26

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between 300 feet up to 800 meters are presented as greater than 1 x 10"6 (see Table 13), EPA
believes these risks are overstated because the value of all mitigation measures has not been
factored into the assessment, and thus a DWLOC of zero may be overly conservative.

       For the general population, defined as residents who live at distances greater than 300 feet
from 1,3-D treated fields, the DWLOC for cancer has been calculated to be 0.3, which is the level
of daily consumption of a pesticide over a lifetime is associated with a 10"6 risk (see section vi of
this chapter for detailed information on how this number was calculated and its relevance to the
1,3-D risk assessment).

       The discrepancy between the Office of Water's  HA of 0.2 ppb and OPP's DWLOC of 0.3
ppb is explained by the two offices different approaches to risk assessment. In general, the Office
of Water assumes a different exposure level and a higher cancer potency estimate for 1,3-D.  In
addition,  the DWLOC was generated using cancer data which was developed since the
establishment of the 1987 HA.  OPP, OW and EPA's  Office of Research and Development are
planning  to share the information developed from the  Cancer Peer Review (planned for 1999) in
order to coordinate reviews based on the best and most up-to-date data on 1,3-D. OPP has,
however, decided to use the 0.2 ppb HA as the trigger for implementation of risk mitigation in the
tap water monitoring program because it is an established reference point and because it affords
an extra level of protection should the monitoring program detect 1,3-D and/or the degradates.

       The contaminant 1,2-D is regulated under the  Safe Drinking Water Act.  It has a
maximum contaminant level (MCL) of 5 ppb, and a maximum contaminant level goal (MCLG)
of 0 because it is a B2 carcinogen (USEPA 1990). In addition, the Office  of Water has
established a Health Advisory for 1,2-dichloropropane: the 10-day Health Advisory for a 10-kg
child is 0.09 mg/L. The drinking water concentration associated with a 10"6 cancer risk for a 70-
kg adult is 0.06 mg/L (USEPA 1996).

       The Office of Water did not establish a 1-day health advisory for 1,2-D because there
were insufficient toxicological data on acute effects.  In 1979, the National Academy of Sciences
recommended an acceptable level of 0.3 mg/L for a 70 kg adult exposed to 1,2-D for a week.

                           (iii)    Groundwater Monitoring

       EPA has reviewed available groundwater monitoring data for 1,3-D (USEPA 1997).  The
Pesticides in Groundwater  Database (EPA 1992) indicates detections of 1,3-D in Florida, New
York, and Washington following normal field use. This database also reports detections in
California due to point source pollution,  and 1,3-D has also been detected in California following
normal use. Small scale retrospective monitoring conducted by the registrant showed detections
in studies conducted in Nebraska, but not in California or North Carolina.  There was an
unverified detection in a Washington study and a fifth study in Florida was terminated after a sink
hole collapsed near the study site. More information on the Pesticides in Groundwater Database
                                           27

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and the retrospective studies can be found in section III. E.2.  EPA believes that the best
information for assessing human exposure through contaminated ground water is derived from
two prospective ground water studies from Wisconsin and Florida, which are discussed below.

       Prospective ground water study sites are located where a pesticide has never been used
and follows a pesticide's movement from application forward in time through the unsaturated
zone into ground water at a study site.  The advantage over retrospective studies is that one can
rule out detections from prior treatments and that application and environmental conditions can be
tracked and evaluated against any detection (or lack of detection).

              Wisconsin Site — In Wisconsin, results show that 1,3-D was detected in an aquifer
used for drinking water at concentrations ranging from 0.05 to 579 ppb.  The Wisconsin study
was still in progress as of printing of this RED, thus levels are presented up to 337  days following
1,3-D application of the two year study. In the Wisconsin study, ground water monitoring was
conducted in on-site wells and one offsite well cluster following application of Telone II at a rate
28 gal/acre (283 Ibs a.i./acre, typical rate).  Depth to ground water ranged from 15-22 feet from
the surface throughout the first 337 days of the study.

       The study tracked results from eight on-site wells and the off-site well located 65 feet
downgradient.  The registrant requested that a 100 foot buffer from drinking water wells be added
to labels after the  study was well underway, therefore, the Agency was not able to  modify the
study to include how this buffer would affect human exposures with the 100 foot buffer.
Although there was one off-site well,  these levels can only be used as indicative of a trend, but
cannot be used for quantitative risk assessment.  For on-site wells, the peak 1,3-D  concentration
was 579 ppb, the time-weighted concentration (over an 11 month sampling period) was 134 ppb
for 1,3-D alone and 357 ppb with 1,3-D plus the two degradates.  The peak level of 1,3-D found
in the downgradient offsite well was 173 ppb and a time-weighted average of parent plus
degradates in this well was 26.6 ppb (Carleton 1998, Eiden 1998).  The contaminant 1,2-D was
found in all of the onsite shallow and deep  wells at concentrations up to 3.9  ppb, and in the offsite
well at concentrations up to 0.9 ppb.

              Florida Site — The Registrant volunteered to conduct small scale monitoring in
southern Florida because of concerns for groundwater contamination due to the high water table
and soil porosity,  and in order to assess whether Telone products could be used without causing
unreasonable adverse effects as an alternative to methyl bromide.

       The Florida study design also  evaluated on-site and off-site shallow and deep wells.  In
Florida, the majority of residents obtain drinking water from public supplies, which tap into the
deep Floridian aquifer. However, approximately 20 percent of the population in Florida (up to
80% in certain Florida counties) tap private wells into the shallow, unconfmed aquifers.

       1,3-D was detected in the Florida prospective study at concentrations ranging from 0.05
to 21.6 ppb in shallow wells (screened at a 10 feet depth) not used for drinking water and up to
one ppb in wells that tap into a confined aquifer (screened at a 70 feet depth) which could be

                                            28

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used for drinking water. In Florida, total 1,3-D residues (parent + degradates) in ground water
were detected up to 43.9 ppb in the shallow wells (10 feet deep), and up to 8.9 ppb in the deeper
wells (70 feet deep).  The time-weighted averages (1,3-D plus degradates) were  1.15 ppb in wells
at 10 feet from the surface and 0.17 ppb in wells 70 feet from the surface.  For off-site wells, the
time weighted average (1,3-D plus degradates) was 0.074 ppb.

                           (iv)    Surface Water

       Limited surface water monitoring data are available for 1,3-D.  Ambient  surface water
monitoring was conducted concurrent with the Florida prospective ground water study.
Monitoring was performed at four sampling sites along two perimeter ditches around a 1,3-D-
treated field.  1,3-D was detected above a detection limit of 0.05 ppb in 14 of 20 samples
collected from the two ditches in the first five days post-application (prior to the first runoff
event). Concentrations ranged from 0.07 to 1.8 ppb.  The maximum concentration of 1.8 ppb
was the only detection > 1 ppb.  No 1,3-D was detected in samples collected from the ditches
after five days post-application.  The degradate, 3-chloroacrylic acid, was detected in four of the
20 samples collected from the two ditches in the first five days post-application at concentrations
ranging from 0.09 to 0.15 ppb.  The degradate, 3-chloroallyl alcohol, was detected at a
concentration of 0.78 ppb in one sample collected from the north ditch nine days post-application.
No detections were noted after the first rainfall event. No rainfall events of sufficient magnitude
to generate runoff occurred during the ditch water monitoring.

       EPA believes that the 1,3-D found in surface water might have resulted from dissolution
of volatilized compound from the air.  A second possible pathway is that the levels in surface
water resulted from a ground water-surface water interaction.

       EPA also used computer modeling to see if 1,3-D use could contaminate surface water
through runoff.  EPA used Tier 2 (PRZM/EXAMS) modeling to estimate concentrations of
1,3-D, 3-chloroallyl alcohol, and 3-chloroacrylic acid in surface water  in a small  pond one hectare
by 2 meters deep, adjacent to a 10-hectare field.  EPA assumed that 1,3-D was incorporated to a
depth of 25 cm below the soil surface.  The model simulation included a decay rate from the
parent compound (1,3-D) to the  alcohol and acid degradates.  Because the environmental fate
data on the degradates is incomplete, EPA used assumptions based on 1,3-D's environmental fate
in generating estimates in surface water through modeling.

       EPA compared a variety of modeled and monitored results to test the veracity of the
model. The maximum reported concentrations of 1,3-D, 3-chloroallyl alcohol, and 3-
chloroacrylic acid detected in the Florida ground water monitoring study were: 21.6 ppb, 13.5
ppb, and 8.79 ppb, respectively.  Maximum surface water concentrations of 1,3-D and 3-
chloroallyl alcohol/ 3-chloroacrylic acid (combined) estimated from the PRZM/EXAMS model
were: 1390, and 24 ppb, respectively.  The average annual surface water concentrations (based on
a 36 year mean) of 1,3-D and its degradates estimated from the PRZM/EXAMS model were
0.801 and 0.340 ppb, respectively. Average annual concentrations of  1,3-D and its degradates in
                                           29

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ditch water from the Florida small-scale prospective monitoring study could not be calculated
from the limited monitoring duration (the maximum concentration of 1,3-D was 1.8 ppb).

       The discrepancy between model estimates of the maximum concentrations in surface water
and the monitoring data reflect, in part, the fact that they address different transport pathways.
However, the larger problem with the models is that they are not well-suited to track volatile soil
incorporated fumigants through the soil to air and water resources.  Based on the data base as a
whole, EPA believes once 1,3-D enters surface water, it degradess rapidly due to its chemical
properties.  Thus, the fate and concentrations of the degradates become of primary concern.  EPA
does not have a complete data base to determine whether run-off is a significant pathway, and
thus Dow AgroSciences is conducting a run-off study to track whether 1,3-D is available for run-
off. It should be noted that concentrations of the material in the ditch water fell below detection
limits within five days after application in the Florida study; however, the presence of 1,3-D in the
ditches was not reflective of the run-off process, since no run-off generating rainfall events
occurred prior to its appearance in the ditch water.

                           (v)     Drinking Water Exposure Estimates

       EPA is using the results of the Florida and Wisconsin studies to derive ground water
concentrations to quantify exposure to 1,3-D and its degradates in drinking water.  EPA has
estimated dietary exposure to 1,3-D via drinking water using these study results and a daily water
consumption value of 2 L/day for adult males and females with bodyweights of 70 kg and 60 kg,
respectively, and 1 L/day  consumption for infants and children with a 10 kg body weight. The
following equation used to estimate exposure to 1,3-D through drinking water for adult males is
provided as an example of how EPA calculated exposure to 1,3-D and its degradates in drinking
water:

Exposure (mg/kg/day)         =  (conc'n. |ig/L)(2 L/day)( 0.001 mg/|ig)
(Adult male)                              70 kg adult body weight

       Chronic exposure estimates for 1,3-D, its degradates and 1,2-D based on time-weighted
mean concentrations detected in ground water from small-scale prospective studies are provided
in Table 4 below.
                                           30

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Table 4. Chronic Exposure Estimates for 1,3-D, Degradates, and 1,2-D based on Time- Weighted Mean Concentrations (TWMC) from Prospective Ground Water
Studies. Exposures are presented in mg/kg/day.
Populations




Adult males
Adult females
Infants &
Children
Adult males

Adult females
Infants &
Children
Adult males

Adult females
Infants &
Children
Adult males

Adult females

Infants &
Children
Adult males
Adult females
Infants &
Children
Compound




1,3-D



3-chloroacrylic




3-chloroacrylic
acid



1.3-D +
Degradates




1,2-D



FLORIDA PROSPECTIVE STUDY (365 days)


10-ft wells
TWMC
0.30



0.31




0.54




1.15





0.22



Exposure
8.6xlO-6
1 x ID"5
3xlO-5

S.SxlQ-6

1 x 10-5

3xlO-5
1.5xlO-5

l.SxlO-5
5.4xlO-5

3.3xlO-5

3.8xlO-5

1.2xlO-4

6.3 xlO-6
7.3 xlO-6
2.2 xlOJ

70-ft wells
TWMC
0.04



0.11




0.03




0.17





0.06



Exposure
l.lxlO-6
1.3xlO-6
4xlO-6

3.1xlO-6

3.6xlO-6
1 x ID"5

8.6xlO-7

1 x ID"6
3xlO-6

4.9 xlO-6

5.6xlO-6



1.7xlO-6
2xlO-6
6xlO-6

1 0-ft wells, 1001 off-site
TWMC
0.026



0.025




0.023




0.074





NA



Exposure*
























WISCONSIN
PROSPECTIVE STUDY
(after 337 days, on-site wells)
shallow aquifer (15-22 ft)
TWMC
134



87




136




357





1.69



Exposure
3.8xlOJ
4.5 xlOJ
1.3xlO-2

2.5 xlOJ

2.9 xlOJ
8.7xlOJ

3.9xlOJ

4.5xlOJ
1.4xlO-2

1 x ID"2

1.2xlO-2

3.6xlO-2

4.9 xlO-5
5.6xlO-5
1.7xlO-4

* - note these wells were not used for risk assessment purposes, therefore, TWMC values are only presented to compare to levels found in other wells.

       Limited surface water monitoring data from the Florida prospective study suggest that
1,3-D may migrate to surface water by transport pathways other than run-off However, because
information regarding potential 1,3-D migration to surface water is limited, and because 1,3-D is a
volatile fumigant not well suited to the PRZM/EXAMS model, the concentrations of 1,3-D and
its degradates derived from the model will be compared to drinking water levels of comparison.
That is, they will  not be used to quantify a drinking water risk associated with residues of 1,3-D
and its degradates in surface water.

       As noted previously, the Office of Pesticide Programs developed drinking water Levels of
Comparison (DWLOC's) as a way to evaluate the concentration of a pesticide in drinking water
that would be acceptable as an upper limit (i.e. no greater than 1 x 10"6 lifetime cancer risk or
100% RfD)  in light of total aggregate exposure to that pesticide from food, water, and residential
uses (if any). While there are no exposures from food or residential uses, EPA has decided it is
                                             31

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appropriate to aggregate inhalation and oral (drinking water) exposures.  EPA calculated
DWLOC values for chronic (RfD) and cancer (Qt*) endpoints.

                            (vi)   DWLOC/1,3-D plus Degradates

       The RfD for 1,3-D (plus degradates) was used to calculate a Drinking Water Level of
Comparison (DWLOC) for non-cancer, chronic effects.  The DWLOCchronic is the concentration
of 1,3-D in drinking water consumed daily over a lifetime that, as part of the aggregate chronic
exposure from all sources (food, water and residential), occupies no more than 100% of the RfD.
The DWLOCchronic for 1,3-D plus the degradates  is 875 ppb for the total  US population, 750 ppb
for females 13+ years old,  and 250 ppb for children.  Note there is not an inhalation component
because no chronic, non-cancer endpoint was identified and thus no risk  assessment was required.

       The DWLOCchronic for 1,3-D plus degradates was calculated using the following formula:

          DWLOCchlomc = chronic water exposure (1.3-D + degradates) (mg/kg/dav')(bodv weightkg)
                             (water consumption, L/day)(10"3 mg/ug)

where chronic water exposure = RfD (because there is no exposure to 1,3-D via food); water
consumption is  two L/day for adults and one L/day for children; and body weight is 70 kg for
total US population, 60 kg for females 13+ years old, and 10 kg for children 1 to 6 years old.

       The oral Qt* for 1,3-D was used to calculate a DWLOC for cancer effects associated with
exposures to 1,3-D plus the degradates. The DWLOCcancer is the concentration of 1,3-D in
drinking water consumed daily over a lifetime that is associated with a 1  x 10"6 cancer risk from all
exposures. As noted previously in this document, EPA has developed two DWLOC's for 1,3-D
(plus degradates). Because the cancer risk associated with inhalation exposures at the 300 feet
buffer is above  1 x 10"6, the DWLOC for water exposure is zero. Although calculated inhalation
risk estimates for residents who live near treated fields are above 1 x 10"6, EPA believes these
estimates are overstated because all mitigation measures which are on 1,3-D labels have not been
factored into the assessment.

       For the general population (those living more than 300 feet from  treated fields), the
DWLOCcancer for 1,3-D is 0.3 |ig/L (ppb).  Because there is no dietary (food) exposure to 1,3-D,
individuals could be exposed to 8.2 x 10"6 mg/kg/day of 1,3-D in drinking water before EPA's
level of concern (1 x 10"6 cancer risk) would be exceeded. See section HID. iv for an explanation
of how EPA calculated risk estimates for cancer and how levels found in the ground water studies
compare to the DWLOC for cancer. As explained in section III.  B.3 b., there is an Office of
Water Health Advisory of 0.2 ppb which differs from the DWLOC of 0.3 ppb.

       The DWLOCcancer  for 1,3-D was calculated using the following formula:

           DWLOCcmcer = (chronic water exposure (1.3-D + degradates). mg/kg/dav)(bodv weight)
                          (ug/L)(water consumption, L/day)(10"3 mg/ug)


                                           32

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                  where chronic water exposure =
1 X 10'f
                                            oral Qj* of 1.22 X 10'1 (mg/kg/day)'1,
                       water consumption is 2 L/day, and body weight is 70 kg.

                            (vii)   DWLOC/1,2-D

       The oral Qt* for 1,2-dichloropropane was used to calculate a DWLOC for cancer effects
caused by 1,2-D.  The DWLOCcancer for 1,2-dichloropropane is 1 ug/L. The inhalation exposure
studies did not monitor for levels of 1,2-D in air, therefore, the DWLOC only estimates oral
exposures.

       The DWLOCcancer for 1,2-dichloropropane was calculated using the following formula:

                   DWLOCchlomc = (chronic water exposure. mg/kg/dav)(bodv weight)
                    (ug/L)             (water consumption, L/day)(10"3 mg/ug)
                        where chronic water exposure =
      1 X 10'f
                                            oral Qj* of 3.69 X 10'2 (mg/kg/day)'1'

                       water consumption is 2 L/day, and body weight is 70 kg.

       DWLOC's can also be compared to model estimates as a surrogate way to estimate and
characterize risks.  Using PRZM/EXAMS as a model, EPA devised three scenarios to give 36-
year mean concentrations for 1,3-D and its degradates in pond water and compared those to the
DWLOC's for chronic (RfD) toxicity endpoints.  DWLOC values were calculated for chronic
(non-cancer) effects for three subpopulations (U.S. population, adult females, and children and
infants), and calculated for cancer effects for the general U.S. population.  Table 5 below provides
a comparison of the model estimates for three scenarios from Idaho, Mississippi and Georgia to
the DWLOC values for the general population..
Table 5. Estimated Concentrations of 1,3-D, 3-chloroallyl alcohol, and 3-chloroacrylic acid in Pond
Water (PRZM/EXAMS).
Subgroup
US Population
Females
Children &
Infants
DWLOC
chronic
fiio/r^
875
750
250
36-Year Mean (ug/L)
Potatoes (ID)
0.045
0.016
0.061
Tobacco (GA)
0.357
0.081
0.438
Cotton (MS)
0.801
0.340
1.141
       Note the DWLOC for the cancer endpoint is 0.3 ppb, which would be exceeded for all
groups from the MS scenario and for all but females in the GA scenario.
                                            33

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       However, EPA does not expect 1,3-D concentrations to persist in surface waters long
enough to provide chronic exposures and recognizes that PRZM/EXAMS is not well suited to
tracking volatile fumigants. Estimated average concentrations of 1,3-D and its degradates, alone
or in total, are well below the DWLOC's for chronic, non-cancer effects for the subpopulations of
concern.  Estimated concentrations of 1,3-D, per se, are greater than the DWLOC for cancer
effects in two of the scenarios modeled.  EPA has some concern that the degradates, being less
volatile than the parent compound, may persist in surface waters. Dow AgroSciences is
developing environmental fate and run-off data to show whether the degradates persist to pose
chronic risks.

       C.     Occupational and Residential Exposure

              1.      Summary of Use Pattern and Application Methods

       There are no homeowner products containing 1,3-D.  1,3-D is a restricted-use pesticide
and thus only certified handlers are  allowed to load and apply 1,3-D.

       1,3-D is applied by injection below the soil surface at least 12 inches.  The liquid 1,3-D
then diffuses through the soil spaces.  1,3-D may be  degraded while in the soil or it may volatilize
or migrate to groundwater. Occupational and residential/bystander inhalation exposure occurs as
a result of 1,3-D volatilization. Inhalation is the primary route of exposure for workers. The rate
of 1,3-D volatilization is affected by application method, soil sealing method,  soil composition
(e.g, amount of clay and organic matter), and soil moisture, temperature and a variety of other
local environmental factors.

       1,3-D is applied to soil  by two methods: row and broadcast. With both methods, 1,3-D is
injected 12-18 inches below the final sealed soil surface. The broadcast method uses one chisel,
Nobel (sweep) plow or plow-sole application equipment with one or more fumigant outlets.  The
broadcast method requires the formation of a raised bed after the application.  The row method
consists of either one or two  chisels per plant row to treat a band of soil where the crop is to be
planted. The row method involves forming beds at the time of application so that the fumigant is
placed at least 12 inches from the nearest soil/air interface.

       1,3-D products do not require mixing, and are loaded into tanks which are attached to
tractors or application rigs directly from a bulk or mini-bulk container.  Bulk loading from tanker
trucks is the predominant practice where custom applicators are the biggest users (e.g., the Pacific
Northwest).  Mini-bulk systems are portable 1000-gallon "traveler" cylinders with dry disconnects
to prevent 1,3-D leaks. After applying 1,3-D, the user returns the mini-bulk container and any
remaining 1,3-D to the local distributor, who then sells the remainder or returns the mini-bulk
container for cleaning (note: cleaning and maintenance  of bulk and mini-bulk  containers are
regulated by OSHA and are not included in this exposure assessment).
                                            34

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               2.      Exposure Mitigation Measures in Effect

        Since 1992, numerous mitigation measures have been added to all 1,3-D product labels.
Specific mitigation measures for workers and area residents are described below.
                       a.
                              Workers
        The following table presents label measures that are in effect to reduce exposures to
workers through the dermal and inhalation routes of exposure. The largest sources of worker
exposure, through leaks and spills, were addressed by the use of closed loading, equipment to
shut off 1,3-D flow at row-turns and respirators.
Table 6.
Summary of 1,3-D Label Restrictions that Impact Worker Exposures
   Regulatory Action
   (effective date)
                       Label Requirements
   Registration Standard
   (1986)
                       Precautionary Statements; Cancer Hazard Warning; Classification
                       Change to Restricted Use Pesticide; Reentry increased to 72 Hours*;
                       Clothing for Applicators and Handlers (Coveralls*, Chemical-resistant
                       Gloves and Boots, Liquid-proof Hat).	
   1992 Label Amendments
   (1992/1993)
                       Lowered Maximum Rates; Deletion of Selected Use Sites; Revised
                       Respirator Requirements*; Closed Loading Requirements; Technology
                       to Minimize 1,3-D Spillage during Application, Improved Product
                       Stewardship Materials	
   Worker Protection Standard
   (August 1992
   see 57 FR 38102)
                       Coveralls Over Short-sleeved Shirt and Short Pants; Chemical-resistant
                       Gloves and Footwear; Chemical-resistant Apron (for Direct Handlers).
   1995 Label Amendments
   (1996)
                       A Respirator Requirement for All 1,3-D Handlers (Except Those in
                       Certain Closed Cabs); Restricted Entry Increased to 5 Days; Soil
                       Moisture and Soil Sealing Requirements; Modified Application
                       Techniques and Lower Maximum Use Rates.	
* Superceded or modified by later label measures.

                      b.      Residents/Bystanders

        1,3-D labels require a 300 foot buffer zone between treated fields and an occupied
structure where 1,3-D applications are prohibited.  Other measures listed in the table above,
including use of the "traveler" mini-bulk loading system, reduced application rates, increased
injection depth, soil sealing, and soil moisture requirements, are also expected to reduce exposure
to residents and bystanders, although exposure reduction cannot be quantified (Carleton 1996a).
                                                35

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              3.      Factors Influencing 1,3-D Exposure

       The label measures described above reduce, but do not do not completely prevent,  1,3-D
releases into the atmosphere.  EPA believes that the greatest potential for release under current
labels is through the chisel trace that is left as 1,3-D is applied, and through off-gassing that
occurs for several days after application. For this route, local environmental conditions greatly
influence inhalation exposure to agricultural workers and residents/bystanders. Local soil
conditions, such as soil type, moisture, organic content, and soil temperature all influence the rate
of 1,3-D volatilization and subsequent exposure to workers or residents.  1,3-D product
application methods, including soil sealing, injection depth, and placement of injection shanks
influence the volatilization of 1,3-D.  Local meteorological conditions, such as prevailing wind,
also influence air concentrations and exposure potential. Application rates may also influence
1,3-D volatilization, although a quantitative relationship between application rate and air
concentration has not been established.  In addition, 1,3-D air concentrations may vary with time
after application.  Peak 1,3-D volatilization generally occurs over the first 72 hours following
1,3-D application, although detectable levels are still present 14 days following application.1
1,3-D exposure also varies with distance from treated fields.  1,3-D air concentrations measured
125 meters from treated fields were 45 to 72 percent lower than air concentrations measured five
meters from treated fields (Carleton 1996).

              4.      Exposure Monitoring Studies

       Dow AgroSciences performed exposure monitoring studies for both workers and for
residents who live near treated fields. Most of these studies were required by the 1992 DCI. An
additional worker study on 1000 gallon mini-bulk  "travelers" was submitted by Dow
AgroSciences in 1995, which was incorporated into the worker risk assessment, but not the
residential assessment. Studies used for the EPA Worker and Resident/Bystander Risk
Assessments are summarized below.

                     a.     Worker Monitoring Studies

       Personal air monitoring was conducted for product loaders,  applicators, and re-entry
workers (MRID's 42946201,  42845602, and 4880401). Air samples were drawn through
activated carbon sorbent tubes, using battery operated pumps to collect air from the breathing
zones of the workers at a measured flow rate. Samples were subsequently desorbed in an organic
solvent and analyzed by GC-ECD or GC-FID. For the loaders and  applicators, two kinds of
samples were collected: four hour samples, and task-specific short duration (4 to 46 minutes)
samples. The four hour samples provided inherently time-weighted average air concentrations
over a major fraction of a work day, while the task-specific samples measured the air
concentrations associated only with high-contact activities. For product loaders, these activities
were the actual loading events. The 4-hour loader samples included the loading events, and the
  1 In two of three residential exposure studies, peak Telone air concentrations occurred within 72 hours of application.

                                            36

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time spent on site between loading events. In the Ainger, NC worker monitoring study, only
short-term task specific samples were collected. Sampling occurred only when workers were
actively engaged in loading. Worker monitoring studies are described below and the data from
these studies are summarized in Tables 7 and 8.

       >      Moses Lake, WA Worker Study. October and November, 1992.  Tel one II was
              applied at the maximum application rate of 25 gal/acre (252.5 Ibs a.i./acre) on a
              field used for potatoes; soil type was sandy loam. Bulk loading was used, with dry
              disconnects, which are common practice in the region. Application was by the
              broadcast method.

       *•      Buckeye, AZ Worker Study. March 3-10, 1993. Tel one II was applied by the
              row method at the maximum rate of 12 gal/acre (121.2 Ibs a.i./acre) to a field used
              to grow cotton; soil type was loamy sand. Bulk loading was used, with dry
              disconnects. (The study also collected samples without dry disconnects, but these
              data were not used for Reregi strati on because dry disconnects are now a label
              requirement.)

       >      Ainger, NC Worker Study. April 3-5, 1995. Telone C-17 (1,3-D plus
              chloropicrin) was applied by the row method at a rate of approximately  10 gal/acre
              (82 Ibs a.i./acre) to a field used to grow tobacco.  Soil type was not specified. This
              study utilized the mini-bulk delivery system, Dow AgroSciences' portable 1000-
              gallon "traveler" cylinders, which utilize dry disconnects. End row spill control was
              also used in this study.

       Not all available worker monitoring data were used for exposure assessment. Only data
reflecting the label requirements current at the time of testing were used (e.g., respirators, dry
disconnects, end-row spill control).

       Biological exposure monitoring was also conducted on both sedentary human volunteers
(controlled study) and on workers performing typical tasks. Urinalysis was used to detect the
major 1,3-D metabolites (Levy 1993, McMahon 1993). These studies are described in  detail in
the worker exposure assessment for 1,3-D (Mehta 1994b).  The biological monitoring data were
not used in this risk assessment because an accurate correlation between urinary metabolite
excretion and the air monitoring data could not be made to estimate absorbed dose (McMahon
1993).  The biomonitoring data showed 1,3-D absorption in the range of 72-82 percent; these
absorption estimates were determined to be minimum values after comparison with field trial data.
Absorption via the inhalation route was assumed to be 100 percent for the purposes of this risk
assessment.

                     b.     Resident/Bystander Monitoring Studies

       The NC, AZ and WA studies (MRID 42845601) included off-site monitoring to assess
exposures to residents who live near treated fields.  Residential/bystander monitoring studies

                                           37

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involved air sampling for 14 days at various stations 5, 25, 125, 500 and 800 meters from a 1,3-
D-treated field (and additional sampling stations at 1200 and 1600 feet for the AZ site).  Prior to
the initiation of the treatment, baseline air samples were collected at sampling stations located 500
meters from the treatment sites.  The applications were conducted utilizing standard cultural
practices and equipment at the time of the study.  Fields that were selected and treated were
isolated from all other known 1,3-D handling activities. Air sampling was conducted in all four
compass directions. EPA analyzed data for samples taken downwind from treated fields, as well
as for pooled data from all four directions (to account for  shifts in wind direction).  Air sampling
was conducted around the clock to account for day and night exposures. Greater 1,3-D  ambient
air concentrations and volatilization rates were found at night (Mehta 1994a). However, only the
24-hour, time-weighted average air concentrations were used to estimate residential/bystander
exposures, due to a lack of individual time activity data on time spent in and around the house at
day and night.

       Air monitoring was conducted directly above the treated field, and at distances of 5, 25,
125, 500, and 800 meters from the edge of the field, in each of four orthogonal directions (i.e.
N,S,E,W). All samples were taken approximately five feet above the ground, using battery
operated pumps to draw air through activated carbon sorbent tubes at a measured flow rate.
Samples were collected during the 1,3-D application at all sampling locations, except directly
above the fields.  After the application was finished, sampling began at all locations, and  continued
for 14 days post application.  The first 24 hour period following application was divided  into six
4-hour samples. 1,3-D air concentrations were at their peak during  the first 24-hours. The next 48
hours were divided into four 12-hour samples. The remaining 11 day period was divided into
24-hour samples, one for each day.

       At the Washington study  site, the presence of a nearby cattle stockyard prevented the
collection of a sample 800 meters south of the treated  field. However, at the Arizona site,
samples were collected at 1200 and 1600 meters from  the field in all four directions, in addition to
the distances listed above.

       Residential/bystander monitoring studies are described below.

       >     Phase 1. Moses Lake, WA.  October 26 to November 9, 1992.  Air monitoring
             was conducted at 20 monitoring locations  surrounding a 20 acre plot treated with
             Telone II using the broadcast method at the maximum rate of 25 gal/acre (252.5
             Ibs a.i./acre).  Prior to the initiation of the treatment, baseline air samples  were
             collected at sampling stations located 500  meters from the treatment site. The 800
             meter south samples could not be collected because  a cattle stockyard was located
             to the south of the treated field. The soil type was characterized as loamy sand.

       >     Phase 2. Harquahala Valley, AZ. February 16 to March 2, 1993. Telone II was
             applied using the row method at a rate of 12 gal/acre (121.2 Ibs a.i./acre), imitating
             an application for a melon field. Air monitoring was conducted at 28 monitoring
                                            38

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              locations surrounding the 20 acre plot treated with Telone II. The soil type was
              characterized as a sandy loam.

       >      Phase 3. Hookerton, North Carolina. December 7-21, 1992. Air monitoring
              was conducted at 20 monitoring locations surrounding a 12 acre plot that had been
              treated with Telone C-17. Telone C-17 was applied using the broadcast method at
              a maximum label rate of 20 gal/acre (164 Ibs a.i./acre) for tobacco. The soil type
              was characterized as a sandy loam.

       Monitoring data from these studies are summarized in Table 7 below. Off-site monitoring
results are presented at various distances from treated fields.  The monitoring data showed that
1,3-D air concentrations peaked during the first three days following treatment and then declined
over a period of 14 days following treatment, which  was the duration of the  air monitoring.  Data
from the resident/bystander study are presented in a way that captures this peak. Data are
presented as (1) the maximum 4-hour air concentration during the study, measured during the first
few days of treatment, (2) mean 24 hour air concentrations, (3) mean 7-day  air concentrations,
and (4) mean 15-day air concentrations.

       For each sampling station, the time weighted average (TWA) air concentration was
calculated for the appropriate sampling period.  This  consisted of the arithmetic mean of the mean
daily air concentrations. For all except the on-site samples, this calculation included the
concentrations measured during the application process. For each distance from a treated field,
the mean TWA over all four directions (N, S, E, W)  was calculated for the appropriate
monitoring period.  The data for all three sites was then pooled, and an overall average for each
distance was calculated for the entire  data set.
 Table 7. 1,3-D Air Concentration Monitoring Data for Agricultural Workers
                                                              Air Concentration
 Activity       Sample Duration         Study sites      Total reps.     Range     Me£m
 Loading3      4 hr                   WA, AZ        10           177-5932   1,631     623
 Loading3      task only               WA,AZ        10           526-32490  10,833    4,860
 Loading3      task only               NC            12           52-1180    464       442
 Application13    4 hr & task             WA, AZ, NC    28           43-6581    1,359     1,150
3With use of dry disconnects
bWith use of end-row spill control
                                             39

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Table 8. Off site Air Monitoring data
Distance
from treated
field (m)
1600
1,200
800



500



125
Edge of
buffer zone

25



5



onsite



Study Site
AZ
AZ
AZ
WA
NC

AZ
WA
NC

AZ
WA
NC

AZ
WA
NC

AZ
WA
NC

AZ
WA
NC

Max. 4-hour
cone.
(ug/m3)
90.9
157.7
215.9
171.9
63.2

482.2
183.0
92.1

1709.5
521.3
281.0

3575.5
311.7
394.3

1592.6
351.0
671.2

2316.4
351.0
339.9

Max cone.
24 hour TWA
(ug/m3)
23.3
46.0
62.9
79.7
10.8

140.4
91.7
16.0

579.3
278.2
58.0

1807.0
212.2
222.9

1278.2
235.5
343.7

1067.1
266.2
261.9

Mean cone.
7 day (ug/m3)
numbers in
bold indicate
mean levels at
that distance
for the 3
studies
3.2
5.6
9.7
21.0
1.4
10.7
18.6
24.1
2.2
15.0
92.0
55.0
10.4
52.5
196.0
74.9
26.2
99.0
184.8
91.7
38.3
104.9
315.4
151.3
75.6
180.8
Mean cone.
15 day (ug/m3)
numbers in
bold indicate
mean levels at
that distance
for the 3
studies
2.4
3.8
6.5
14.6
1.3
7.5
11.8
17.2
1.5
10.2
55.6
40.2
6.0
33.9
112.4
62.1
15.1
63.2
104.7
73.6
21.7
66.7
171.1
115.5
40.4
109.0
              5.     Exposure Estimates Used for Risk Assessment

       EPA based its risk assessment on 1,3-D air concentrations measured in the monitoring
studies described above. Only inhalation exposure was estimated; dermal exposure is expected to
be negligible because of 1,3-D's volatility and the protective measures on 1,3-D product labels.
                                           40

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       Because the number of monitored replicates at each site was small (5 to 13), EPA pooled
the results from different sites to obtain the largest possible sample sizes for each exposure
scenario. Tables 7 and 8 present a summary of the pooled data on air concentrations from these
studies.

       For intermediate-term worker exposure, the 4-hour samples were used to calculate the
mean air concentrations over all pooled replicates. Separate inhalation exposure estimates are
provided for custom loaders and applicators, because different individuals perform these tasks.
However, for growers, EPA assumed that the same person conducts both loading  and application
of 1,3-D. Since growers presumably spend  most of their work day engaged in application rather
than loading, intermediate-term exposures estimates for growers were based on the air
concentration for application rather than loading. All worker air concentration estimates were
adjusted using a protection factor of 0.10 for respirators.

       For intermediate-term residential/bystander exposure, a time weighted average (TWA) air
concentration was calculated for the first eight days of exposure only (day of application and the
first  seven days of a 14-day study).  These are the mean 7-day air concentrations in Table 8, which
were used to calculate intermediate term MOE's.

       For lifetime  residential/bystander exposure, the TWA air concentration was calculated for
the entire sampling  period for each monitoring  station. This time weighted average was the
arithmetic mean of the mean daily air concentrations. For all but the on-site samples, this
calculation included the air concentrations measured during the application process.  This value
was  normalized over a 24 hour period, and incorporated into an overall 15 day TWA (the day of
application plus the 14 days following).  Since samples were not collected above the fields during
the application process, the on-site TWA covered only the 14 day period after application.

       For each distance from a treated field, the mean TWA over all four directions (N, S, E, W)
was  calculated for the entire monitoring period. The data for all three sites were then pooled, and
an overall average for each distance was calculated for the entire data set.  These values appear in
Table 8 under the heading of "Mean cone.  15 day" air concentrations.  Subsequent cancer
calculations took account of the differing numbers of days used in calculating  the mean  air
concentrations at the different distances, by  assuming 14 days of exposure for the  on-site
concentration, and 15 days for all the others.

       To calculate intermediate-term exposures, a similar calculation was performed, except that
for each distance, a  TWA air concentration was calculated for the first eight days only (day of
application plus the seven days following).  These values appear in Table 8 under the heading of
"Mean cone. 7 day" air concentrations. Intermediate-term MOE's were estimated as the
intermediate-term inhalation NOEL  of 0.091 mg/L (see Table 3) divided by the "mean 7 day"
1,3-D air concentration.

       Exposures to agricultural handlers entering treated fields after the five day REI were also
calculated using the on-site air monitoring data from the residential/bystander studies. For each of

                                            41

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the three monitored sites, the TWA 1,3-D air concentration was calculated for the period
consisting of days 6-14 post-application. The resulting concentration was used to estimate cancer
risks to handlers entering treated fields.

       Chronic, lifetime exposures to workers and area residents were expressed as lifetime
average daily dose (LADD). The LADD of 1,3-D was calculated according to the following
formula:

LADD (mg/kg/day) = [(air concentration, ng/m3)(mg/1000 j^g)(ventilation rate, m3/hr)(hr/day)
                        (days/yryi yr/365 davs)(yrs exposed/70 yrs)1	
                            70 kg body wt

using the following values for workers and residents/ bystanders:

                     Workers               Residents/Bystanders

Ventilation rate         1.74 m3/h (light work)    0.81 m3/h

Lifetime Exposure       30 years, grower,        30 years
                     20 years, commercial

Average Lifetime        70 years               70 years

Exposure Duration       crop specific            16h/day

Exposure Frequency      crop specific            15 days/event, 1 events/yr

       LADD's for commercial "for-hire" handlers were calculated by first estimating average
daily doses (ADD's) in mg/kg/day, from the air concentrations. Information on days per year and
hours per day were obtained for each crop, state by state, from Dow AgroSciences' Use and
Usage Summary Report. However, for loaders, the report lists only the total hours per day spent
actively engaged in loading (0.5 to 1.25 hour/day), not total hours spent on site. To estimate
ADD's, the Agency therefore assumed loaders to be  on site for the same number of hours per day
as the applicators (5  to 10 hour/day,  depending on state and crop).

       LADD's for growers assumed that the majority of the work  day is spent applying 1,3-D,
and only as much time as is required to load the tank is spent engaged in loading.  Therefore, the
4-hour samples were used in the calculation of the portion of the exposure resulting from
application, and the task-specific samples were used to calculate the exposure incurred while
loading (because 4-hour samples were not collected for the mini-bulk study, the Agency made the
assumption that for the use of mini-bulk cylinders, the task-specific  loader air concentrations are
experienced for the duration of a work cycle).  The loading and application exposures were then
added to estimate the total exposure for these individuals. Information on hours per day and days
per year for each activity were obtained from the Dow AgroSciences' Use and Usage Summary
Report. For growers, the Agency assumed that the same person conducts both loading and
application of 1,3-D.
                                             42

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       Exposure estimates for residents/bystanders were based on pooled data to account for
random shifts in wind directions.  For residents/bystanders, the Agency also assumed 16
hours/day spent in and around the house. EPA assumed 1,3-D air concentrations to be the same
indoors and outdoors, in the absence of indoor air monitoring data. Exposure estimates for
residents/bystanders are provided for individuals who remain at a fixed distance from a treated
field.  The LADD for workers was adjusted using a protection factor of 0.10 for respirators.

       D.     Risk Assessment

       EPA expects both occupational and residential/bystander exposure from the use of 1,3-D.
Residents and bystanders near Telone-treated fields are exposed via ambient air.  Dietary
exposure may occur through drinking water, but is not expected from food sources. Exposure
can occur by the inhalation and oral (drinking water) routes, but not is not expected from the
dermal route of exposure based on use patterns and label requirements for 1,3-D use.

              1.      Dietary Risk and Characterization

                    a.      Food Source

       No dietary risk assessment was performed for 1,3-D, because no residues are found in
foods. Telone products are pre-plant fumigants which break down in the soil and thus are not
available for uptake by plants. The at-plant treatment for pineapples shows that the fruit, which
are borne three years later, do not contain  1,3-D treatment-related residues.

                    b.      Drinking Water Source

                           (i)     Acute Drinking Risk

       No acute toxicological endpoints were identified for 1,3-D exposure for acute or
subchronic time duration. Therefore, no acute or subchronic drinking water risk assessment was
conducted.

       For 1,2-D, EPA's Office of Water has a children's  10-day health advisory of 0.09 mg/L
(90 |ig/L or 90 ppb). The maximum concentration of 1,2-D found was 1.3 |ig/L (0.0013 mg/L) in
the Florida study and 3.9 |ig/L (0.0039 mg/L) in the Wisconsin study.  Because the maximum
concentration of 1,2-D found in the prospective ground water monitoring studies does not exceed
the 10-day health advisory for children, it is not considered to be of concern.

       The Maximum Contaminant Level (MCL) for 1,2-D is 0.005 mg/L (5 |ig/L).  The
maximum concentration of 1,2-D in the Florida study on-site wells was 1.3 |ig/L in shallow wells
and in the Wisconsin study was 3.9 |ig/L.  Therefore, the levels of 1,2-D found in the prospective
studies do not exceed the MCL and are not considered to be of concern.
                                           43

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                           (ii)    Short and Intermediate Term Drinking Water Risk

       For 1,2-D, EPA's Office of Water has established a 10-day health advisory; the
concentrations of 1,2-D in the water monitoring studies were compared to the 10-day health
advisory for 1,2-D.  Concentrations of 1,2-D in groundwater did not exceed the 10-day Health
Advisory of 0.09 mg/L or the MCL of 0.005 mg/L and are not of concern.  In the Florida study,
the peak groundwater concentration in on-site wells of 1,2-D was 1.3 |ig/L (0.0013 mg/L). In the
Wisconsin monitoring study, the peak groundwater concentration of 1,2-D was reported to be 3.9
Hg/L (0.0039 mg/L).

                           (iii)   Chronic Drinking Water Risk as  % RfD

       For 1,3-D, EPA has determined that the oral RfD should be 0.025 mg/kg/day, based on a
NOEL of 2.5 mg/kg/day from a 2-year chronic/carcinogenicity study in rats and an uncertainty
factor of 100.

       The chronic  drinking water risk is calculated as a percent of the  RfD taken up by drinking
water.  As stated previously, groundwater is expected to be the only source for chronic drinking
water exposure to 1,3-D.

       The following calculation was used:

% RfD =   ( Drinking Water Exposure, mg/kg/dav^)    X 100%
                RfD of 0.025 mg/kg/day

       Time-weighted average ground water concentrations from the prospective ground water
monitoring studies were used to estimate risk as a percentage of the RfD.  Chronic drinking water
exposure was compared to the RfD for the total U.S. population (as represented by adult males),
adult females, and infants/children. For the exposure scenario using ground water monitoring
data from the Wisconsin prospective ground water monitoring study, chronic exposure to 1,3-D
for the total US population is 40 percent of the RfD, for adult females chronic exposure is 48
percent of the RfD, and for infants/children (the most highly exposed sub-population) chronic
exposure is 144 percent of the RfD. Dietary and drinking water exposures below 100 percent of
the RfD are generally considered not to be of concern. Chronic (non-cancer) risk estimates based
on exposure to 1,3-D in drinking water are presented in Table 9 below.

       Risk estimates for drinking water associated with chronic, non-cancer effects were not
calculated for surface water because the available monitoring information on 1,3-D and its
degradates in surface water is inadequate (does not provide a long-term average concentration
value, i.e., a time-weighted mean concentration or information on whether run-off would
contribute to surface water levels).  No RfD was available for 1,2-D; therefore, a chronic drinking
water risk assessment was not performed.
                                           44

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Table 9- Risk Estimates for Chronic Effects (non-cancer) of 1,3-D and 1,3-D + Degradates as a
%RfD based on Maximum Exposure Calculated from the Wisconsin (up to day 337 from on-site
wells of 2- Year Study) and Florida Prospective Ground Water Study Data.
Wisconsin Prospective Ground Water Study (15-22 feet deep wells)
Populations
Adult males
Adult females
Infants & Children
Compound
Telone + degradates
Exposure (mg/kg/day)
1 x If)'2
1.2xlO-2
3.6 xlO'2
%RfD
40
48
144
Florida Prospective Ground Water Study (10 feet deep wells on site)
Populations
Adult males
Adult females
Infants & Children
Compound
Telone + degradates
Exposure (mg/kg/day)
3.3xlO-5
3.8xlO-5
1.2xlO-4
%RfD
<1.0
<1.0
<1.0
Florida Prospective Ground Water Study (70 feet deep wells on site)
Adult males
Adult females
Infants & Children
Telone + degradates
4.9 xlO'6
5.6 xlO'6
1.7xlO-5
<1.0
<1.0
<1.0
                           (iv)   Carcinogenic Risk from Drinking Water

       The Agency estimated cancer risks associated with dietary exposure to 1,3-D via drinking
water from ground water sources. Appropriate and reliable monitoring data for surface water
were not available.  Cancer risks were estimated for the total US population only, because the
Agency has insufficient information to estimate lifetime drinking water consumption (or cancer
risk) for subpopulations of varying ages and reproductive status.

       Cancer risk estimates were calculated using the following equation:

       Cancer risk = (chronic drinking water exposure, mg/kg/day) x Qj*, (mg/kg/day)"1

       Chronic drinking water exposure values are derived from time-weighted mean
concentrations of 1,3-D, its degradates, and 1,2-D detected in the Wisconsin and Florida
prospective monitoring studies.

       The oral Ot* is 1.22 xlO'1 (mg/kg/day)'1 for 1,3-D and 3.69 x 10'2 (mg/kg/day)'1 for 1,2-D.
Note there is a separate Qx* for 1,3-D via the inhalation route of exposure, which is discussed in
the following section.
                                           45

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       Cancer risk estimates were derived from both the Florida and the Wisconsin study based
on total concentration of 1,3-D and the degradates, 3-chloroallyl alcohol and 3-chloroacrylic acid
(assuming that the degradates have cancer potency equivalent to 1,3-D ).  Lifetime cancer risk
estimates from wells located on-site are estimated to be from 4 x 10"6 (Florida) to 1.2 x 10"3
(Wisconsin).  The new 1,3-D labels prohibit use within 100 feet of a drinking water well, so these
risks are likely overestimates.

       Both prospective ground water monitoring studies included limited monitoring in off-site
wells located down gradient from the treated fields.  The studies were underway when the
registrant proposed the 100' no-treatment buffer from drinking water wells, and as such, the study
could not be modified to assess human exposures with this buffer.  In the Florida study, time
weighted average (TWA) concentrations of 1,3-D plus its degradates in the on-site wells (10'
deep) were 1.15 ppb.  TWA concentrations of 1,3-D plus degradates measured in wells located
100 feet down gradient from the treated field were 0.074 ppb. In the Wisconsin study, on-site
wells yielded TWA concentrations of 1,3-D and its degradates of 357 ppb while concentrations in
a well 65' down gradient from the treated field were 26.6 ppb. Although neither of these studies
was designed to quantify offsite exposures, results in both studies indicate that exposures were
lower with increasing distance from treated field.

       Dow AgroSciences has agreed as a condition of reregi strati on to conduct tap water
monitoring studies to better estimate current concentrations of 1,3-D and degradates in drinking
water.  Sampling will be targeted to high-use areas and will be initiated once the new labels are in
effect in August of 1999. EPA expects the sampling program will  allow better characterization of
risks including the 100' setback required from drinking water wells now required on the label.

       Drinking water cancer risks were not calculated for surface water because the available
monitoring information on 1,3-D and/or its degradates in surface water is inadequate (since it
does not provide a long-term average concentration value, i.e., a time-weighted mean
concentration) for use in a chronic exposure assessment to estimate cancer risks. The Agency
believes that continued chronic exposure to 1,3-D  is unlikely  because 1,3-D is likely to dissipate
rapidly from surface water via volatilization, making chronic  surface water exposure unlikely.
The potential for chronic exposure to the degradates is expected to be greater, since they are
likely to be less volatile than the parent.  As mentioned in the previous section, Dow
AgroSciences is conducting a run-off study to investigate whether there is a potential for
substantial exposures via surface water. Drinking water cancer risk estimates based on ground
water data for the contaminant 1,2-D range from 6.3 x 10"8 to 1.8 x 10"6. Cancer risk estimates
for on-site drinking water wells are summarized in Table 10  below.
                                            46

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Table 10. Chronic Exposures and Cancer Risk Estimates for 1,3-D, its Degradates, and 1,2-D based on Time-Weighted Mean Concentrations from Prospective Ground
Water Monitoring Studies
Compound
1,3-D
3-chloroacrylic alcohol
3-chloroacrylic acid
1,3-D + Degradates
1 ,2-Dichloropropane
Florida Ground water Monitoring Data (on-site wells)
10 ft deep wells
Conc'n,
ug/L
0.30
0.31
0.54
1.15
0.22
Estimated
Exposure,
mg/kg/day
8.57 xlO'6
8.86xlO-6
1.54xlO-5
3.17xlO-5
6.3xlO-6
cancer risk
l.OxlO-6
n/a
n/a
4.0xlO-6
2.3xlO-7
70 ft deep wells
Cone
ug/L
0.04
0.11
0.03
0.17
0.06
Estimated
Exposure,
mg/kg/day
l.lxlO-6
S.lxlO'6
8.6xlO-7
4.9xlO-6
1.7xlO-6
cancer risk
1.4xlO-7
n/a
n/a
5.9x10-'
6.3xlO-8
Wisconsin Ground water Monitoring Data
(on-site wells)
shallow aquifer (15-22 ft)
Cone
Hg/L
134
87
136
357
1.69
Estimated
Exposure,
mg/kg/day
3.8xlO-3
2.5xlO-3
3.9xlO-3
l.OxlO-2
4.8xlO-5
cancer risk
4.7xlO-4
n/a
n/a
1.2xlO-3
l.SxlO-6
*Cancer risk estimates were calculated using the following equation:
 Cancer risk = (drinking water exposure, mg/kg/day) X Ch*,  (mg/kg/day)-l
Where oral Ql * =  1.22 X 10'1 (mg/kg/day)-' for 1,3-D and 3.69 X 10'2 (mg/kg/day)-' for 1,2-D
                                                                               47

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                     c.      Dietary Risk Characterization

       The dietary risk assessment is based solely on exposures through levels in ground water;
no exposure is expected from foods planted in 1,3-D-treated soils and there is insufficient data to
quantify whether surface water could contribute to dietary risk.  Based on the results of the
prospective ground water studies in Florida and Wisconsin, the Agency believes that 1,3-D, its
degradates, and 1,2-D can migrate to ground water under certain conditions.   1,3-D levels can
persist in colder areas and levels of the degradates persist even in warmer areas.  In estimating
cancer risks, the Agency is making the assumption that Telone and its degradates' concentrations
are of equal toxicity (and  carcinogenicity).

       The results of the prospective ground water study in Wisconsin confirmed EPA's
hypothesis that 1,3-D could pose unreasonable risks under certain conditions where temperatures
are low. The Wisconsin site was chosen based on its higher-end vulnerability characteristics
(ground water less than 20 feet from the surface, porous soils and very cold climate).  Levels of
1,3-D plus its degradates in wells located within the field were associated with lifetime cancer risk
estimates of 1 x 10"3 and levels in the off-site well were elevated even after a year. Given this high
estimate, EPA has determined that nothing short of a prohibition will protect areas similar to the
Wisconsin site. As of October 1, 1999, all  1,3-D labels will bear prohibitions in  certain northern
tier states where  ground water is less than 50 feet from the surface and where soils are porous
(Hydrological Type A). Dow AgroSciences has committed to develop tap water monitoring in
Michigan and Connecticut, which are cold  areas, but with vulnerability characteristics that are less
extreme than those at the Wisconsin site.

       EPA believes that areas of Florida are also vulnerable to ground water contamination from
1,3-D use. Based on the prospective ground water study conducted in Florida, EPA believes that
residents who tap wells into shallow aquifers in the vicinity of treated fields are most at risk. The
study results show that on-site wells with levels of 1,3-D and its degradates were associated with
risk estimates of 4 x 10"6to 3 x 10"5 in shallow wells.  The off-site well was located approximately
100 feet from the treated fields and showed levels considerably less than those found in the on-site
wells (1.15 ppb onsite compared to 0.074 ppb  off-site).  To confirm the results of the prospective
ground water monitoring  studies, Dow AgroSciences has committed to conducting tap water
monitoring in two distinct agricultural areas in Florida: northern Florida and in the Biscayne
Aquifer (Dade and Broward counties) once use expands to that area.

       EPA also looked at other sources of ground water monitoring to determine whether
additional prospective ground water monitoring studies  should be required. Based on the EPA
Pesticides in Ground Water database and the USGS NAWQA study, EPA believes that 1,3-D
does not present risk of widespread ground water contamination.  Rather, the data base on
ground water monitoring  supports developing  label restrictions to prevent localized
contamination. Dow AgroSciences is conducting additional tap water monitoring in the Pacific
Northwest, the Southeast, Nebraska and Florida to support 1,3-D registrations under labeling as
specified in this document.

                                            48

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       Based on 1,3-D's chemical properties and pattern of use (i.e. soil injected), exposure from
surface water is not expected to be significant. However, various models, as well as the results of
the Florida study showing detectable levels in nearby ditches, support the need for a run-off study.
Dow AgroSciences is also conducting other data on the environmental fate and ecotoxicity of the
degradates, together with the run-off study to confirm that surface water residues are not a
concern, or to provide data that allows EPA to characterize and address any potential concerns.

       The Agency notes that the models used to estimate surface water levels are not suitable
for tracking volatile soil fumigants through the environment; thus, EPA views the model results as
highly uncertain.  See sections  III.E. 1. and 2. for more details on these models and the water-
related studies assessing 1,3-D  levels in the environment.

                    d.    Occupational and Residential/Bystander Inhalation Risk
                           Characterization

       Estimates of intermediate-term systemic risks and excess individual lifetime cancer risk for
custom operators, growers, and area residents/bystanders are given in Tables  11, 12, and 13.

                           (i)      Risks from Intermediate Term Inhalation Exposure

       For intermediate-term worker MOE's, the 4-hour samples were used to calculate mean air
concentrations over all pooled replicates. Tables 11 and 12 present commercial "for-hire"
handlers and private handler (grower) exposure and risk estimates, respectively, derived using
these values.

       Table 11 presents the exposure and risk estimates for commercial handlers who handle
1,3-D, based upon the air concentration values listed in Table 7. Intermediate-term MOE's for
commercial handlers were calculated as the ratio of the intermediate-term inhalation NOEL to the
mean air concentration (adjusted  by a 90 percent protection factor for wearing a  respirator).

                           (ii)    Cancer Risks from Lifetime Inhalation Exposure

       Cancer risks for commercial "for-hire" handlers were calculated by first estimating average
daily doses (ADD's)  in mg/kg/day, from the air concentrations. Information on days per year and
hours per day were obtained for each crop, state by state, from Dow AgroSciences' Use and
Usage Summary Report. However, for loaders, the report lists only the total hours per day spent
actually engaged in loading (0.5 to 1.25 hour/day), not total hours spent on site.  Therefore, to
estimate their ADD's, the Agency therefore assumed loaders to be on site  for the same number of
hours per day as the applicators (5 to 10 hour/day, depending on state and crop).

       Table 12 presents exposure and risk estimates for growers who handle 1,3-D, based upon
the air concentration values listed in Table 7.  For growers, the Agency assumed  that the same
person conducts both loading and application of 1,3-D products.  Since growers presumably
spend most of their work day engaged in application, rather than loading, intermediate-term risks

                                            49

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(MOE's) for growers were estimated using the air concentration for application rather than
loading.

       Cancer risks for growers assumed that the majority of the work day is spent applying
1,3-D and only as much time as is required to load the tank is spent actually engaged in loading.
Therefore, the 4-hour samples were used in the calculation of the portion of the exposure
resulting from application, and the task-specific samples were used to calculate the exposure
incurred while loading (because 4-hour samples were not collected for the mini-bulk study, the
Agency assumed that the task-specific loader air concentrations are experienced for the duration
of a work cycle).  The loading and application exposures were then added to estimate the total
exposure for these individuals.

       Cancer risk estimates were calculated using the following formula:

Excess cancer risk = Qx* X LADE

where Qt* = 5.3 X 10'2 (mg/kg/day)'1

and LADE = exposure (mg/kg/yr) X 20 (custom) or 30 (grower) years
              365 days/year                70 years

       The excess individual lifetime cancer risk estimates for  occupational exposure range from
7.0 x 10"6 to 6.1 x 10"5 for custom handlers and 5.1 x 10"6 to 5.0 x 10"5for private growers.  These
values may be overestimates because they do not reflect certain mitigation measures which are
expected to reduce risk, but can not be quantified. Generally, the Agency considers risks of 10"6
or lower not to be of concern and carefully examines risks in the range of 10"4 to 10"6 to seek ways
of reducing risks prior to reregistration (Barolo,  1996). Risks that fall closer to 10"4 where no
additional mitigation is available are judged against  the benefits of the pesticide's use. For 1,3-D,
worker risks have been mitigated to extent feasible and are considered to be overestimates given
that some label measures' mitigation value cannot be quantified and included in the risk estimate.
In addition, the Agency considers the benefits of 1,3-D use to be high.  Based on EPA's policy,
the cancer risks of 1,3-D use for workers under current labels are considered to be acceptable.
                                            50

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Table 11. 1
Delivery
Method
Bulk

Bulk

Mini-bulk

,3-D Custom Handler Intermediate-Term and Cancer Risks
Example Crop
Cotton, AZ

Potatoes, WA

Tobacco, NC

Task
Loader
Applicator
Loader
Applicator
Loader
Applicator
Cone.
1631
1359
1631
1359
464
1359
Doses (mg/kg/day)a
hr/d
10
10
8
8
5
5
d/yr
36
20
24
24
10
10
ADD
0
3.4e-02
3.2e-02
2.7e-02
5.8e-03
1.7e-02
AADD
4.0e-03
1.9e-03
2.1e-03
1.8e-03
1.6e-04
4.6e-04
LADD
l.le-03
5.3e-04
6.1e-04
5.1e-04
4.5e-05
1.3e-04
Cancer Int. -Term
Risk MOEa
6.1xlO-5
2.8x lO'5
3.2x lO'5
2.7x lO'5
2.4x lO'6
7. Ox lO'6
560
670
560
670
1960
670
Adjusted for wearing of respirator or use of enclosed tractor cab (PF= 0.1)
Table 12.
Delivery
Method
Bulk
Bulk
Mini-bulk
Mini-bulk
1,3-D Grower Intermediate-Term and Cancer Risks
Example Crop
Cucurbits, TX
Pineapples, HI
Tobacco, NC
Peanuts, GA
Loading
Cone.
10833
10833
464
464
Application:
hr/d
0.25
1.25
0.5
1
Cone.
Hg/m3 hr/d
1,359
1359
1359
1359
6
6
5
3
Doses (mg/kg/day)a
d/yr
15
11
3.5
5
ADD
2.7e-02
5.4e-02
1.7e-02
l.le-02
AADD
l.le-03
1.6e-03
-2
1.5e-04
LADD
6.3e-04
9.3e-04
-10
8.8e-05
Cancer
Risk
3.4xlO-5
S.OxlO-5
S.lxlO'6
4.7xlO-6
Int. -Term
MOEa
670
670
670
670
Adjusted for wearing of respirator or use of enclosed tractor cab (PF= 0.1)
                                                                          51

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       Table 13 presents exposure estimates for residents who live near treated fields.
Table 13.
Distance
from
treated
field (m)
1600
1200
800
500
125
25
5
onsite
Residential/Bystander Exposure
Study
Site(s)
Doses (mg/kg/day)
Cancer Int. -Term
Risk MOE
ADD LADD

AZ
AZ
overall
overall
overall
overall
overall
overall

7.6 e-07
2.9e-05
5.7e-05
7.7e-05
2.6e-04
4.8e-04
5.1e-04
8.3e-04

-3
-1
-2
-3
-1
-2
-2
-4

1.7x ID'8
6.6x ID'7
1.3x ID'6
1.8x ID'6
5.9x 1Q-6
l.lx 1Q-5
1.2x 1Q-5
1.9x 1Q-5

2800
1600
8500
6100
1700
920
870
500
Shading denotes edge of buffer zone required 300 ft from an occupied structure.

       A buffer zone of 300 feet (approximately 125 meters) is required between all occupied
structures and any field where 1,3-D is used to mitigate cancer risks to area residents whose
homes are adjacent to treated fields.

       The residentfoystander cancer risks may  represent overestimates because individuals are
not likely to spend 16 hours/day at a fixed distance for 30 years. Most people in regions where
1,3-D is used are not part of this subpopulation (i.e. do not live at the edge of a buffer zone), and
are therefore presumed to be at somewhat lower risk.  Also, the population of area residents
living at the edge of the  buffer zone is expected to be small, according to limited 1992 population
survey data from Dow AgroSciences (Mehta 1994c). The population survey of states  comprising
95 percent of 1,3-D usage showed that there were approximately 1088 residences in the 17 states
where 1,3-D is used within one mile of 1,3-D treated fields (Mehta 1994c). There are no data on
the number of people actually residing within 300 feet  of treated fields.

       Other risk-mitigation measures, including reduced application rates, increased  injection
depth, mandatory soil sealing, and soil moisture  requirements may also reduce exposure to
residents and bystanders, although the magnitude of this reduction  cannot be quantified and
therefore cancer risk estimates are likely to be overstated.
                                            52

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                            (iii)    Aggregate Exposure and Cumulative Risk

       EPA has aggregated inhalation and oral exposures to  1,3-D. For 1,3-D, the aggregate risk
estimate would be calculated as follows:

cancer risk inhalation exposure + cancer risk water exposure = aggregate lifetime cancer risk

       In calculating aggregate risk, EPA has determined that a reasonable worst-case exposure
scenario would be comprised of the inhalation risk at the 300  foot buffer, derived from the
average of three air monitoring studies, and water exposure risk from the on-site concentrations
from the Florida study. EPA did not use the Wisconsin study values because as of
August 1, 1999, use in areas similar to this site will be prohibited. Thus the aggregate risk
would be:

f\ Y 1 D"6            + 4 Y 1 D"6          = 1 Y 1 D"5
u A i u  inhalation exposure   ^ A *u  water exposure   1 A 1V

       This aggregate cancer risk estimate, however, is based on assessments which contain
numerous uncertainties from both the  inhalation and water routes of exposure.  Those
uncertainties are detailed in section e. below.

       Section 408(b)(2)(D)(v) of the Food Quality Protection Act requires that, when
considering whether to establish,  modify, or revoke a tolerance, the Agency consider "available
information" concerning the cumulative effects of a particular pesticide's residues and "other
substances that have a common mechanism of toxicity." The  Agency believes that "available
information" in this context might include not only toxicity, chemistry, and exposure data, but also
scientific policies and  methodologies for understanding common mechanisms of toxicity and
conducting cumulative risk assessments. For most pesticides, although the Agency has some
information in its files that may turn out to be helpful in eventually determining whether a
pesticide shares a common mechanism of toxicity with any other substances, EPA does not at this
time have the methodologies to resolve the complex  scientific issues concerning common
mechanism of toxicity in a meaningful way. EPA has begun a pilot  process to study this issue
further through the examination of particular classes of pesticides.  The Agency hopes that the
results of this pilot process will increase the Agency's scientific understanding of this question
such that EPA will be  able  to develop and  apply scientific principles for better determining which
chemicals have a common mechanism of toxicity and evaluating the cumulative effects of such
chemicals. The Agency anticipates, however, that even as its  understanding of the science of
common mechanisms increases, decisions on specific classes of chemicals will be heavily
dependent on chemical-specific data, much of which may not  be presently available.

       Although at present the Agency does not know how to apply the information in its files
concerning common mechanism issues to most risk assessments, there are pesticides for which the
common mechanism issues can be resolved. These pesticides include pesticides that are
lexicologically dissimilar to existing chemical substances (in which case the Agency can conclude
                                            53

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that it is unlikely that a pesticide shares a common mechanism of activity with other substances)
and pesticides that produce a common toxic metabolite (in which case common mechanism of
activity will be assumed).

       EPA does not have, at this time, available data to determine whether 1,3-D has a common
mechanism of toxicity with 1,2-D or other substances or how to include this pesticide in a
cumulative risk assessment. For the purposes of this reregi strati on decision, EPA has assumed
that 1,3-D and 1,2-D do not have a common mechanism of toxicity.

                     e.      Uncertainties  in the Risk Assessment and Risk
                            Characterization Summary for 1,3-D

       The Agency estimated cancer risk to growers, custom loaders/applicators, and
residents/bystanders exposed to 1,3-D. Exposures via the dermal route were assumed to be
negligible due to 1,3-D's high volatility and PPE requirements. Inhalation data were available and
deemed appropriate for quantitative risk assessment, and thus, route to route extrapolation was
not necessary for risk assessment. Oral and inhalation exposures were aggregated to develop risk
estimates for residents/bystanders.

       There are numerous uncertainties associated with the studies used to develop exposure
estimates. Although the air monitoring studies were  designed to evaluate exposures under normal
use conditions, the influence of local environmental conditions, such as wind, soil type and
weather patterns coupled with 1,3-D's volatility, resulted in mixed results.  Results varied widely
not only between sites, but also within sites on a day-by-day basis. The inhalation exposure
estimates provided in this assessment are derived from a limited number of monitoring studies per
site, which further increases the uncertainty.

       Where possible, the Agency has incorporated label mitigation measures into the risk
assessment.  However, not all mitigation measures can be quantified.  For example, the following
mitigation measures are likely to further reduce worker and residential exposures to 1,3-D and
associated cancer risk:  reduced maximum application rates by 30-65% depending on the crop,
increased soil injection depth from 10" to  12", soil sealing, and shank placement.  The actual
impact of these specific mitigation measures on reducing risk cannot be quantified with the
available data.

       Some air monitoring data need to be considered carefully,  since the results did not show a
reduction in exposure levels with certain mitigation measures, including use of enclosed cabs and
dry disconnects, measures which are known to reduce exposures.  The monitoring data did not
show enclosed cabs to provide any reduction  in exposure, possibly because applicators frequently
left the enclosed cab to perform various tasks during the application process.  Therefore, the
1,3-D labels were modified to require a respirator if the worker leaves the enclosed cab during
application for any reason.
                                            54

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       Dry disconnects, which are couplers designed to prevent leaks and emissions during
fumigant transfers, appear to offer some exposure mitigation. Exposure reduction with dry
disconnects could be quantified with the short-term sampling data but not with the 4-hour
sampling data. The 4-hour sampling data suggest an increase in exposure with the use of dry
disconnects, which is counter-intuitive.  The reasons are likely due to a low number  of sampling
replicates and inherent variability in the study conditions.

       There are  uncertainties regarding practices of commercial operators.  Exposure and risk
estimates provided assume that commercial operators treat only one crop. Risk may be
underestimated for commercial operators treating specialty crops in the Pacific Northwest.
However, the Agency also believes that custom operators are in a better position to train
personnel and maintain and update equipment, which results in better control over exposures to
1,3-D.

       Some use practices have changed since the early studies were conducted, as  have the laws
governing agriculture. Just as local environmental conditions affect 1,3-D volatilization,
individual growers' decisions on application rate, application method, injection depth, and soil
sealing measures vary.  For example, some growers use different application rates from year to
year depending on the level of nematode infestation. Actual land use is unpredictable, and is
ultimately driven by weather conditions, pests, and market pressures. Therefore, the inhalation
exposure estimates and assumptions used represent a simplification of real world exposures.

       The residential risk assessment is based on an average for the three sites monitored (N.C.,
WA, AZ), though 1,3-D air levels were quite different among the three sites.  In addition, the
monitoring at the N.C. site was conducted using drum loading, which was the predominant use at
the time of the study, but which has since been phased out in favor of mini-bulk containers.  Air
levels with drum loading are expected to be higher than the mini-bulk containers since closed
loading and dry disconnects (to prevent release of vapors) were not used with drums and since
loading 1,3-D into the tractor-drawn tank was more frequent because the 55-gallon  drums were
smaller than the 1000 gallon mini-bulk.  A mini-bulk study was submitted in 1996, but was only
designed to measure worker exposures. Although higher levels were seen at the AZ and WA
sites, EPA expects that the levels from the N.C. site, and thus the average overall, would have
been lower had the mini-bulk system been used in the off-site monitoring.

       For the water exposure component  of the aggregate risk estimate, levels monitored from
on-site wells were used in the assessment.  As of August 1, 1999, however, there will be a 100
foot no-treatment buffer between treated fields and drinking water wells.  The prospective ground
water monitoring studies included limited off-site monitoring, which showed decreasing levels
with increasing distance from 1,3-D treated fields.  However, studies with more sampling and a
study design to look specifically at levels in off-site wells would have to be conducted in order to
quantify any relationship between distance to treated field and levels in wells used for drinking
water.
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       Despite the limitations discussed in this section, EPA believes that the air and ground
water monitoring are suitable for risk assessment. The studies were specifically designed to assess
exposures to 1,3-D, taking into account the unique chemical qualities of 1,3-D, as well as the
specialized 1,3-D loading and application techniques.  However, the influence of a variety of
environmental factors, particularly in the air monitoring studies, confounded many results. Even if
additional data were required to address some of the shortcomings discussed above, EPA believes
it would be unlikely that the additional effort would significantly improve the assessment given
that confounding factors, such as wind and precipitation, could not be controlled under actual
field test conditions.

       E.     Environmental Assessment

              1.     Environmental Fate and Transport

       1,3-D dissipates primarily through volatilization, leaching, abiotic hydrolysis, and aerobic
soil metabolism.  Field volatility studies have shown that approximately 25 percent of the applied
1,3-D volatilizes during the two weeks after an application. Hydrolysis is temperature dependent
and there is an increase in stability at lower temperatures.  At 2°C, for both pH 5.5 and 7.5, the
half-life of the parent was 90 to  100  days.  Under aerobic conditions, half-lives ranging from 12 to
54 days were reported for the parent. The 3-chloroallyl alcohol is expected to be the main
hydrolytic degradation product and 3-chloroacrylic acid the major aerobic metabolite. Laboratory
mobility  data, in addition to ground-water monitoring information, has clearly demonstrated that
1,3-D is highly mobile in soil. The Freundlich adsorption coefficients for 1,3-D were:  Kd= 0.23 in
loamy sand, Kd= 0.32 in sand; and in clay, Kd= 0.42 and 1.09.

                     a.      Environmental Fate Assessment of 1,2-D

       The formulated 1,3-D product contains from  0.1 to 0.06 percent 1,2-D. 1,2-D has a
vapor pressure of 42 mm Hg at 20°C, has a water solubility of 2700 ppm at  20°C, is fairly stable
to hydrolysis with a half-life of 77 days at pH 5.5, and has variable aerobic soil half-lives (41  to 69
days on four soils but stable in a sandy loam and a loam).  With 1,2-D, photoreactions are also
minimal with a half-life of 313 days  with respect to the (OH) radical and stable with respect to
ozone. Mobility studies give a strong indication of the extreme mobility of 1,2-D.  Freundlich
adsorption coefficients for 1,2-D were Kd=0.12, Kd=0.16, Kd=0.05, Kd=0.87 for the Fuquay
loamy sand, Metz sandy loam, Hanford loam, and the Wahiawa sandy clay loam soils,
respectively.  In column leaching experiments using a Fuquay loamy sand with 0.64% organic
carbon, a total of 85.8% of the applied 1,2-D leached from the soil column.  For the Wahiawa
sandy clay loam  column with 2.32% organic carbon,  a total of 73.2% of the applied was found in
the leachate.  Thus, mobility was somewhat inversely proportional to organic matter content.

                     b.     Degradation

       Hydrolysis. In buffered solutions at pH values of 5, 7, 9, the half-life of 1,3-D was 13.5
days at 20°C. A supplemental study at pH's 5.5 and 7.5 showed that the half-life of 1,3-D was 90

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to 100 days at 2°C; 11 to 13 days at 15°C; and 2 days at 29°C. The chloroallyl alcohol is expected
to be the main hydrolytic product (MRID 00158442).

       Another supplemental study gave these results: at pH values of 5, 7, and 9, the half-life of
1,2-D was 51 days at 10°C; 10 to 13 days at 20°C; and 3 to 5 days at 30°C. The chloroallyl
alcohol reached maximum concentrations of 32%, 72%, and 78% at 10°, 20°, and 30°C,
respectively, and appeared to be stable to further hydrolysis. Hydrolysis of 1,3-D is pH
independent and temperature dependent (MRID 00117050).

       Photodegradation in Air. Both cis and trans 1,3-D (purity > 94.8%) at 0.035 to 0.050
//g/ml did not degrade in borosilicate glass vials irradiated continuously for 30 days with a xenon
arc lamp at 25°C and ambient humidity. After 30 days of irradiation, 95% to 98% of the applied
radioactivity was recovered, as 1,3-D and no degradates were detected.  In the dark control at 30
days post-treatment, 86% to 92% of the applied was recovered as  1,3-D and no degradates were
observed.  The study indicates that under these conditions, direct photolysis in air is not an
important degradative mode for 1,3-D (MRID 40390101).

       Reactions of 1,3-D and 1,2-D with ozone (O3) and OH radicals were studied.  The half-
lives of 1,3-D with respect to the OH radical were seven and 12 hours for the trans and cis
isomers, respectively.  The observed degradation products were formyl chloride and
chloroacetaldehyde. The half-lives of the trans and cis isomers of  1,3-D with respect to ozone
were 12 and 52 days, respectively. The observed products were formyl chloride and
chloroacetaldehyde, chloroacetic acid, HCL, CO, CO2 and formic acid.  The rate of photolysis
alone seems insignificant (as was shown in the above 161-4 experiment) relative to the reactions
of 1,3-D with ozone and the OH radicals. For 1,2-D the experiments also indicated that the only
significant loss in the atmosphere would be a reaction with the OH radical. The half-life with
respect to the OH radical was 313 days. A half-life of 313 days for 1,2-D would indicate the
compound is sufficiently stable for worldwide long-distance transport (Tuazon,  1984).

       Aerobic Soil Metabolism.  The reported half-lives were 12 days in Catlin silt loam soil
and 54 days in Fuquay loamy sand soil.  These major nonvolatile degradates were isolated from
the soils: cis/trans-3-chloroprop-2-en-l-ol (3-chloroallyl alcohol) and cis/trans-3-chloroprop-2-
enoic acid (3-chloroacrylic acid). Numerous naturally-occurring carboxylic acids were also
identified as degradates (MRID 42642301).

       Anaerobic Soil Metabolism. In a silty clay loam soil  at 15°C, the half-life of 1,3-D was
reported to be 9.1 days.  In a sandy loam soil at 15°C, the half-life was 7.7 days. In both a silty
clay loam and sandy loam soil, at 25°C, the half-life was 2.4 days.  The observed degradates were
chloroacrylic acid, propionic acid, and an unknown (MRID 40025901)

                     c.      Mobility

       Column Leaching. The calculated Freundlich adsorption coefficients for 1,3-D were:
loamy sand Kd= 0.23; sand Kd= 0.32; clay Kd= 0.42 and 1.09.  The average maximum Koc values

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were 20 for sand, 25 for loamy sand, and 41 and 42 for two clay soils.  In 30-cm columns of sand,
loamy sand, and Florida clay, 1-3-D leached when more than 25 inches of water were applied. A
total of 1.9% to 4.6% of the applied (unaged) radioactivity remained in the soils and 70% to 84%
was found in the leachate (MRID 40538901).

      Aged Column Leaching. Aged (31 days) 1,3-D residues were very mobile, with 25.6%
to 32.0% of the applied radioactivity in the leachates of 30-cm columns of loamy sand soil.  1,3-D
and the degradates 3-chloroallyl alcohol, chloroacrylic acid, and composite carboxylic acids
(including acetic acid, oxalic acid, and propionic acid) were detected in both the leachates and the
upper 2-cm soil segment extracts.

      Batch Equilibrium (1,2-D). Freundlich adsorption coefficients for 1,2-D were 0.12
(n=1.13), 0.16 (n=1.13), 0.05 (n=1.63), and 0.87 (n=1.07), with corresponding Koc,s of 18.8,
23.5, 10.4, 37.5 for the Fuquay loamy sand, Metz sandy loam, Hanford loam, and the Wahiawa
sandy clay loam, respectively.  The Freundlich desorption coefficients were 1.54 (n=0.99), 0.93
(n=1.22), 0.45 (n=1.52), and 3.45 (n=1.13), with corresponding Koc's of 241, 137, 93.8 and 149
for the Fuquay loamy sand, Metz sandy loam, Hanford loam, and Wahiawa sandy clay loam
(MRID 42868501).

      Column Leaching (1,2-D).  The column leaching experiments indicated that for the
Fuquay loamy sand, a total of 85.8% of the applied 1,2-D leached from the soil column.  1,2-D
was distributed evenly throughout the column. For the Wahiawa sandy clay loam column, a total
of 73.2% of the applied was found in the leachate.  1,2-D was not evenly distributed throughout
the column and concentrations were highest near the final soil segment.  Sorption coefficients
estimated from the column leaching studies were 0.09 and 0.43 for the Fuquay and Wahiawa soils
with corresponding Koc's of 14.1 and 18.5 (MRID 42868501).

      Field Volatility. The factors influencing the volatility of 1,3-D from a field plot include,
but are not limited to, soil organic matter, wind speed, soil moisture content, depth of
incorporation-injection, soil temperature and soil porosity.  Approximately 25 percent of the
applied 1,3-D had volatilized by 14 days post-treatment (the final sampling interval). The
volatilization of 1,3-D increased to 35.1 mg/m2-hour by 3 days post-treatment using the
aerodynamic flux method with 33- and 90-cm  sampling levels at the plot center.  Volatilization
ranged from 8.13 to 22.3 mg/m2-hour at 4-6 days,  4.6 to 17.5 mg/m2-hour at 7-9 days, 3.31 to
7.78 mg/m2-hour at 10-12 days, and 1.28 to 4.93 mg/m2-hour at 12-14 days (MRID 42545101).

       1,3-D was soil injected at  12-14 inches at 346 Ib. a.i. per acre into fields of sandy loam,
loamy sand, and muck soils. At six  to 12 hours post-treatment, 1,3-D reached a maximum
concentration of 0.09 to 4.4 ppm at the 0.5-foot height above the soil surface.  1,3-D
concentrations decreased to <  0.03 ppm in all air samples from all locations by seven days post-
treatment. It was not detected above the loamy sand and sandy loam soils by 14 days or above
the muck soil by 21  days. Volatilization rates appeared to be inversely proportional to the amount
of soil organic matter and proportional to soil  porosity  (MRID 41057701).
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       Telone II was applied at approximately 12.8 gallons per acre (121 Ibs a.i./acre) to a fallow
plot in Nevada and monitored over 7 days for airborne concentrations directly above the field and
at locations up to one-half mile away (no MRID, EFGWB #91-0910).  The average value of
1,3-D at a 6-inch height above the field during 7 days was 465.31 |ig/m3; at a 5-foot height at the
edge of the field it was 94.81 |ig/m3; at a 5-foot height 100 feet from the field it was 39.39 |ig/m3;
at a 5-foot height 1/4 mile from the field it was 5.17 |ig/m3; and at a 5-foot height one-half mile
from the field it was 3.88 |ig/m3.  Wind was a major factor in the dispersion of 1,3-D as higher
concentrations were measured at night. During the day, the increase in wind velocity also
increased vapor dispersion and lowered the measurable amount of material (Houtman et al.,
1991).

       In general, it is  difficult to correlate soil moisture content with volatilization but Glotfelty
and Schomberg (1989) and Lyman et al. (1982) suggest that the extreme drying of soil during
drought will greatly decrease volatilization.  Addition of moisture to dry soils will generally
increase volatilization rates to a point beyond which additional moisture may have little effect or
may start to decrease volatilization.  The effect of changes in soil moisture on the volatilization of
organics from soils with intermediate moisture contents is difficult to predict and depends upon
the chemical, soil type, and the initial soil moisture content.  In general, soil chisel incorporation
of 1,3-D is accompanied by capping off the soil injection cores and/or by covering the field with
plastic to minimize volatilization. Deeper injection minimizes the total amount of material that
volatilizes and maximizes the amount of time from injection until volatiles are observed at the
soil/air interface because of the increased soil distance through which the pesticide must diffuse.

                     d.     Field Dissipation

       Terrestrial Field Dissipation.  Cis and trans  1,3-D applied at 345 Ib a.i./A dissipated with
an observed initial half-life of approximately one day and a second half-life of approximately seven
days in the surface 24-inches of a bare-ground loamy sand soil (MRID 40855501).

       1,3-D was applied at 342 Ib a.i./A to a sand soil field plot in California.  1,3-D residues
declined from a maximum of 130,000 ppb in the 0.3- to 0.45-meter layer of soil immediately after
treatment to less than 10 ppb (detection limit) in any soil layer at 71 days.  The degradate 3-
chloroallyl alcohol declined from a maximum of 410 ppb in the 0.66  to 0.81 meter layer of soil at
seven days posttreatment to less than 10 ppb in any soil layer at 71 days (MRID 40403301);
additional data 3/24/89).  The half-life is approximately seven days assuming a linear dissipation
rate.

              2.      Water Resources

                     a.     Ground Water

       High-quality data indicate that 1,3-D leaches to ground water as a result of normal
agricultural use.  The 1986 Registration Standard and Special Review position document both
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noted that the Agency has concerns for the potential for ground water contamination based on
limited ground water monitoring data and laboratory data on the mobility of 1,3-D.

                           (i)     Occurrence of 1,3-D in Ground Water

       Monitoring information collected since 1983 indicates that 1,3-D has been detected in
ground water in seven states in different regions of the U.S. with detected levels up to 800 ppb.
Note from the previous section that the average daily concentration associated with a 10"6 lifetime
risk is 0.3 ppb.  1,3-D has also been detected in ground water in The Netherlands in potato and
flower bulb fields.  Because an MCL has not been established for 1,3-D, no monitoring for this
chemical is required under the Safe Drinking Water Act.

       1,2-D has been detected in ground water in California, Connecticut, Florida, Hawaii,
Massachusetts, Maryland, Nebraska, New York, Oregon, Washington, and Wisconsin. The MCL
for 1,2-D is 5 ppb.  Dow AgroSciences's information indicates an estimated HAL of 1.2 ppb.
This section describes the data base used by EPA in developing its human health and
environmental risk assessment for 1,3-D

                           (ii)    Small-Scale Retrospective Monitoring

       In 1986, the Agency requested that the registrant evaluate the impact of 1,3-D on ground
water in varied environments with different use patterns. From 1989 to 1992, Dow AgroSciences
conducted retrospective ground-water monitoring studies in Grant County, Washington; Merced
County, California; Monterey County, California; Wayne County, North Carolina; and Scotts
Bluff County, Nebraska. A sixth  study in Florida was terminated when a nearby sinkhole
collapsed and interfered with monitoring. Although there were significant problems with the
study designs and sampling, results indicated that  1,3-D can leach to ground water.

Nebraska. 1,3-D concentrations in ground water ranged from 0.23 ppb to 3.86 ppb using a
detection limit of 0.05 ppb.  In this sugar beet study, maximum residues were seen in ground
water eight months after application. The cis isomer was detected fourteen months after the
1,3-D application.

Washington. In the Washington potato study, the cis isomer of 1,3-D was detected at 0.03 ppb
in two ground-water samples from two of the 50-foot wells on the site approximately one month
after application.

North Carolina and California.  No residues of 1,2-D; 1,3-D or its degradates were detected in
ground water in the North Carolina tobacco study, the Merced County, California sweet potato
study or the Monterey County, California carrot study.
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                           (iii)   State Ground-Water Monitoring Studies

       The Pesticides in Ground Water Database (EPA,  1992) indicates detections of 1,3-D in
three states — Florida, New York, and Washington — because of normal field use.  The database
also reports detections of 1,3-D in California because of point source problems (i.e., misuse or a
spill). Additional monitoring in Hawaii, Massachusetts, Mississippi, and Oregon has not yielded
any detections of 1,3-D.

California.  In 1987, 1988, and  1991, 1,3-D was detected in six wells in Del Norte, Fresno,  and
Santa Clara counties. Using a method detection limit of 0.5 ppb, concentrations ranged from 0.89
to 1.9 ppb.  No information is available about the source of the detections.  1,3-D was not
detected in 9,915 wells  sampled  from May 1979 to June 1996 using detection limits ranging from
0.02 to 100 ppb (Bartkowiak, 1997).

In Riverside, California, illegal use of 1,3-D in 1986 and  1987 resulted in six detections in one
irrigation well ranging from 6.8 to 31 ppb (EPA, 1992).

Florida.  From 1987 to 1996, a total of 9,505 wells were monitored for 1,3-D residues. The
present detection limit is 0.0850 ppb, but has varied in the past (Fisher, 1997).  Although 1,3-D
was detected in three wells at concentrations ranging from 0.28 to 8 ppb, these are probably  most
likely 1,2-D detections  (Riotte, 1997).

Hawaii.  The Hawaii Department of Health monitors for 1,3-D in ground water because of its use
as a soil fumigant in the pineapple industry. From 1979 to 1987, samples were analyzed from 54
wells and no residues were found (Giambelluca, 1988).

Massachusetts.  In the summer  and fall of 1985, several  Massachusetts agencies analyzed
samples from 239 wells in tobacco-growing areas. Using a detection limit of 1.0 ppb, no 1,3-D
was found.  No samples were analyzed for degradates  (Massachusetts Interagency Task Force,
1986).

Mississippi.  In Mississippi, a statewide drinking-water ambient monitoring survey was designed
to sample for pesticides. 1,3-D is not widely used in Mississippi (Landreth, 1997), and the
reported monitoring may not have been conducted in areas where 1,3-D has been used.  To date,
348 deep wells have been sampled and analyzed for cis and trans 1,3-D.  No residues have been
detected using a detection limit of 0.10 ppb for the parent.

New York.  Although monitoring for 1,3-D is not usually done by the State, several studies have
been done by researchers to determine the leaching potential of 1,3-D in Suffolk County, New
York. In one of the studies done in 1983, 1,3-D was detected in ground water at concentrations
ranging from 37 to 270 ppb in one well over a period of three months. The detection limit used in
this study was 2 ppb (Loria et al., 1986).  In another study, no 1,3-D was detected in nine wells
located near fields where 1,3-D was applied. The detection limit used here was also two ppb
(Kotcon and Loria, 1987).

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Oregon. In Oregon, a standard analytical screen that includes 1,3-D is performed for every well
that is sampled. Many of these wells are not in agricultural areas or 1,3-D use areas.  Some 1,3-D
has been found using a detection limit of 0.5 ppb.  However, problems with data retrieval make it
impossible to determine how much or how many times 1,3-D has been detected (McLaughlin,
1997).

Washington.  From 1990 through 1996, the Washington State Department of Ecology analyzed
196 wells for cis and trans  1,3-D. The trans isomer was found on April 30,  1991  in three wells at
concentrations of 0.10, 0.11, and 0.11 ppb.  The same three wells were re-sampled in February
1992 (10 months later) and no 1,3-D was detected (Larsen, 1997).

                           (iv)    Small-Scale Prospective Monitoring

       Wisconsin.  The Agency required that Dow AgroSciences conduct a small-scale
prospective ground-water monitoring study in a northern climate because of the concern for
1,3-D persistence in cold climates. Dow AgroSciences conducted site selection in Idaho,
Nebraska,  Wyoming, Michigan, Minnesota, North Dakota and Wisconsin. The site selection
criteria required shallow ground water, porous soils, minimal  slope, no impeding layer (such as a
clay barrier) between the treatment zone and ground water, no prior usage of 1,3-D and no
concurrent usage of 1,3-D in the vicinity of the test site.  Potato-growing areas in these states
were targeted since potatoes are a major use site for 1,3-D use.  The site in Wisconsin met all of
EPA and Dow AgroScience's selection criteria and was thus  selected to represent a vulnerable
site in a northern use area.

       On September 9, 1997, Tel one II was applied to a sugar beet field at 28 gallons per acre
(266 Ib ai/acre). Levels peaked at 579 ppb in on-site wells after one year of monitoring. In the
off-site well located 65 feet down gradient,  1,3-D levels peaked at 173 ppb.

       1,2-D was detected in all eight of the onsite shallow wells and four of the onsite deep
wells at concentrations ranging from trace levels to 3.9 ppb using a quantitation limit of 0.05 ppb.

       Dow AgroSciences also submitted, though with insufficient information to allow formal
EPA review, results to predict 1,3-D levels  at further  distances off-site.  Using the program
ModFlow, which looked at concentrations of 1,3-D only, downgradient concentrations reached
0.3 ppb at 1100 feet after 2.5 years.  The same model predicts a time-weighted concentration at
100 feet downgradient of 8.4 ppb after the first year and  13.4 ppb after the second year.  Given
the levels and trends seen in the modeling and monitoring, EPA does not believe that the 100 feet
buffer alone would provide sufficient mitigation for human health risks.

       Florida. In  1993, Dow AgroSciences initiated a small-scale prospective monitoring study
in southern Florida.  Because of concerns for potential ground-water contamination, EPA and the
State of Florida became involved in the study design and review. On December 13, 1995, Tel one
C-17 was applied to a pepper field at approximately 22.5 gallons per acre. Study results showed

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detections of 1,3-D, 1,2-D and both the 3-chloroacrylic acid and 3-chloroallyl alcohol degradates
in ground water.

       Most Floridian soils are porous with shallow water tables. While most residents of the
state obtain water from public systems which tap aquifers that are not surficial, there are areas
where 20% or more of the residents obtain water from private wells that tap surficial aquifers (in
some counties up to 80%).  Some areas have a spodic horizon between the surficial and deeper
aquifers, while other areas overlay karst geology (highly permeable, rocky soils).  Note that as of
August 1, 1999, the 1,3-D labels prohibit use in areas of karst geology.  In order to support
agriculture in certain areas of Florida,  perimeter ditches are used to either raise the availability of
water serving the field, or to divert excess rainfall. There  can be extensive interaction between
these ditches, surface water and surficial ground water aquifers.  Because of the warmer
temperatures, EPA expected the rate of degradation to be  relatively higher than in areas with
lower temperatures.

       In the uppermost part of the aquifer (one to two foot wells which were not used in the
drinking water assessment) 1,3-D was detected in all eight of the onsite wells.  Detections peaked
at 833 ppb and declined to 0.19 ppb by 110 days after application. These wells also contained 3-
chloroallyl alcohol at concentrations ranging from trace levels to 360 ppb and 3-chloroacrylic acid
at concentrations ranging from trace levels to 424 ppb. 1,2-D was detected at concentrations
ranging from trace levels to 11.5 ppb.  Five offsite wells also contained 1,3-D residues at
concentrations ranging from trace levels to 0.23 ppb.

       At a depth of 10 feet from the  surface, 1,3-D was detected in all eight of the onsite wells.
Concentrations ranged from trace levels (0.05 ppb) to 21.6 ppb.  These wells also contained 3-
chloroallyl alcohol at concentrations ranging from trace levels to 13.5 ppb and 3-chloroacrylic
acid at concentrations ranging from trace levels to 8.79 ppb.  1,2-D was detected  at
concentrations ranging from trace levels to 1.28 ppb.

       Early in the study, 1,3-D was briefly detected in the deep part of the aquifer (70 feet),
however, the concurrent water blanks  from the bailers used to sample the deep wells contained
similar 1,3-D concentrations. Also, the bromide tracer did not reach these deep wells during the
study, suggesting these detections were the result of inadvertent sample contamination. However,
the  information submitted is as follows:  1,3-D was detected in two of the three onsite wells in the
Lower Tamiami Aquifer with concentrations ranging from 0.05 to 1.03 ppb. These wells also
contained 3-chloroallyl alcohol at concentrations ranging from trace levels to 7.85 ppb and
chloroacrylic acid at trace concentrations. 1,2-D was detected at concentrations ranging from
trace levels to 0.07 ppb. No 1,3-D residues were found in the offsite deep well; 1,2-D was
detected in this well at trace levels in all but one sampling event.

                            (v)    The National  Water Quality Assessment Program

       In 1991, the U.S. Geological Survey initiated the National Water Quality Assessment
program (NAWQA) to study national  water quality.  The monitoring, which is being conducted  in

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four parts, will assess more than 50 of the largest river basins and aquifers (study units) and cover
the drinking water sources of about 70 percent of the U.S. population.

       NAWQA included 1,3-D (both isomers) and 1,2-D among the compounds tested.  Areas
of the country with the highest 1,3-D use are covered, at least in part, by 10 study units. None of
the reports released to date have shown detections of 1,3-D in wells or other water resources.
The summary reports, however, do not allow the Agency to assess whether 1,3-D use took place
in the vicinity of water sampling locations and did not sample for the acid and alcohol degradates.

       Nonetheless, the information in the NAWQA reports is useful. Although no information
in the reports directly links 1,3-D use to the monitored wells, the absence of detections suggests
that 1,3-D use does not result in widespread aquifer contamination.

                     b.     Modeling and Occurrence of 1,3-D in Surface Water

       A mixture of the cis and trans isomers of 1,3-D is typically applied at a rate of several
hundred pounds per acre at a depth of approximately one foot below the soil surface. It then
moves through the soil profile, with some escaping up through the treatment zone to the
atmosphere.  One study (MRID 42545101) showed that approximately 25 percent of applied
1,3-D volatilizes, however, environmental and soil conditions will affect the actual amount. The
1,3-D isomers undergo fairly rapid dissipation in soil via volatilization and to a lesser extent
degradation.  Also, only chemical molecules that have diffused into the top one to two  centimeters
of soil at the time a runoff event occurs would likely be  susceptible to runoff.  Such factors should
somewhat limit the runoff potential of the 1,3-D isomers. However, extremely high application
rates of several  hundred pounds per acre coupled with low soil/water partitioning,  indicate some
potential for runoff.

       In addition to runoff, another route of 1,3-D transport to surface water could be by
dissolution of volatilized compound from the air. Dow AgroSciences has proposed this route to
explain 1,3-D residues in perimeter ditches of a treated field in Florida (see previous discussion on
the Florida prospective ground-water monitoring study) prior to any runoff events. Dow
AgroSciences postulates that during conditions of low wind, volatilized 1,3-D will move close to
the ground due to its higher density than air, and that some of the 1,3-D passing over surface
water will be transported from the air to the water and dissolved. Another possibility is that in
Florida, ground water may be contributing to residues in surface water through ground and
surface water interactions. Both the 3-chloroallyl alcohol and 3-chloroacrylic acid were detected
in surface water along with 1,3-D in the prospective ground-water monitoring study in Florida.

       1,3-D will probably undergo rapid rates of dissipation in most surface waters due to
volatilization and, to a lesser extent, by abiotic hydrolysis and possibly biodegradation.
Volatilization rates will be highest for shallow turbulent water and decrease with increasing depth
and decreasing turbulence. Isomer mixture soil/water partition coefficients of 0.23 in a loamy
sand, 0.32 in a sand, 0.42 and 1.09 in two clay soils indicate that the concentration of 1,3-D in
sediment pore water will be comparable to that adsorbed to suspended and bottom sediment.

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Concentrations in the water column will be less than in the sediment pore water, but should still
be somewhat comparable to concentrations adsorbed to sediment.  The low octanol/water
partitioning of 1,3-D indicates that its bioaccumulation potential is probably low.

                     c.     Drinking Water Exposure Assessment

       Please refer back to section III. B.3. for a full discussion of the levels used for the drinking
water exposure and risk assessment.

              3.     Ecological Assessment

                     a.     Toxicity to Terrestrial Animals

                            (i)  Birds, Acute and Subacute

       An acute oral (LD50) study using the technical grade of the active ingredient (TGAI) were
submitted to establish the toxicity of 1,3-D to birds. The result of the Northern bobwhite test is
presented in Table 14.

 Table 14. Avian Acute Oral Toxicity
Species
Northern bobwhite
(Colinus virginianus)

% ai LD50 (mg/kg) Toxicity Category
92 152 moderately toxic

MRID No.
Author/Year
00118938
Wildlife
International
/1982
Study
Classification1
Core

1 Core (study satisfies guideline). Supplemental (study is scientifically sound, but does not satisfy guideline)

       Since the LD50 falls in the range of 51 to 500 mg/kg, 1,3-D is moderately toxic
to avian species on an acute oral basis (MRID 00118938).

       Two subacute dietary studies on the Mallard duck and Northern bobwhite using the TGAI
were submitted to  establish the toxicity of 1,3-D to birds. The avian acute dietary LC50 test is a
subacute, eight-day dietary laboratory study designed to determine the dietary concentration of
toxicant that is likely to cause 50 percent mortality in a test population of birds.  The TGAI is
administered to juvenile birds' diets for five days,  followed by three  days of "clean" diet. Results
of these tests are presented in Table 15.
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 Table 15 Avian Subacute Dietary Toxicity
Species
Northern bobwhite
(Colinus virginianus)
Mallard duck
(Anas platyrhynchos)
LC50
% ai (ppm)
92 >10,000
92 >10,000

Toxicity Category
Practically
Nontoxic
Practically
Nontoxic
MRID No.
Author/Year
STEODI03
Fink, 1975
00120908
Fink, 1975
Study
Classification
Core
Core

       The LC50 is higher than 2,000 ppm.  This toxicity value indicates that 1,3-D is practically
nontoxic to birds on a subacute dietary basis; however, this result is inconsistent with the acute
oral test. The subacute dietary results could be explained by the fact that the length of time to
perform the test is long and, because 1,3-D is highly volatile, it may not remain in the food.
Therefore, the birds may have received an inadequate dose resulting in a low dose response. Field
study data indicate that volatility is the primary route of 1,3-D dissipation with dispersal
increasing to 35.1 mg/m2/hour by three days. Therefore, the weight of evidence indicates that
1,3-D is moderately toxic to birds (LD50 = 157 mg/kg) (MRID's STEODI03 and 00120908).

                            (ii)    Birds, Chronic

       Avian reproduction studies using the TGAI were not required for 1,3-D  in the 1986
Registration Standard.  Since the field dissipation half-life is roughly one week and generally only
one application is made per year, birds are not expected to be exposed to repeated or continuous
residues of 1,3-D.

                            (iii)    Mammals, Acute and Chronic

       The toxicity values for mammals are presented in Table 16 (USEPA, 1997).  Results
indicate that 1,3-D is slightly toxic to toxic to small mammals on an acute oral basis (640 mg/kg)
(MRID #0039693).
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 Table 16. Mammalian Toxicity
Species
Laboratory mouse
(Mus musculus)
Laboratory rat
(Rattus norvegicus)
Laboratory mouse
(Rattus norvegicus)
Laboratory rat
(Rattus norvegicus)

Laboratory rat
(Rattus norvegicus)
Test
Material
Telone II
1,3-dichloropropene
1,3-dichlorpropene
90% ai
cis + trans

96% ai
cis + trans
Test
Type
Acute Oral
Acute Inhalation
Chronic Inhalation
Developmental -
Inhalation

13 Week Feeding
Toxicity
Value
LD50
640 mg/kg (M&F)
LC50
729 ppm/4 hours
NOEL Systemic
730 ppm
NOEL Maternal
20 ppm
NOEL Developmental
60 ppm

NOEL 5 mg/kg/day
LOEL15 mg/kg/day
Affected
Endpoints
Mortality
Mortality
No systemic effects
observed at 730 ppm
Maternal - body weight
loss and reduced food
consumption
Developmental - delayed
ossification of vertebral
centra
Body weight,
hyperkeratosis and/or
basal cell hyperplasia of
the non-glandular portion
of the stomach
MRID No.
00039683
235350
00039685
00144715
00152848

42954802
                             (iv)    Insects

       A honeybee acute contact study using the typical end-use product was not required in the
1986 Registration Standard.  The registered application method via soil injection prior to planting
should not result in honeybee exposure.  However, exposure in adjacent habitats could occur
because of 1,3-D's volatility and the probability of the chemical drifting offsite.

       Results from a study submitted for contact toxicity on honeybees are presented in Table
17, and indicate that 1,3-D is moderately toxic to bees on an acute contact basis (MRID's
00028772 and 00018842).

 Table 17. Non-target Insect Acute Contact Toxicity
Species
Honey bee
(Apis mellifera)
Honey bee
(Apis mellifera)
LD50
% ai (/ig/bee)
TGAI 6.6
Formulation 6.6
Toxicity Category
Moderately toxic
Moderately toxic
MRID No.
Author/Year
00028772/
Atkins/1972
00018842/
Atkins/1969
Study
Classification
Core
Core
                     b.      Terrestrial Field Testing

       Based on the application method and use pattern, terrestrial field testing of 1,3-D has not
been requested or submitted to support reregistration.
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                       c.      Toxicity to Freshwater Aquatic Animals

                              (i)  Freshwater Fish and Amphibians, Acute

        Freshwater fish toxicity studies using the TGAI were submitted to establish the toxicity of
1,3-D to fish and amphibians.  Results of these tests are presented in Table 18. Since the LC50
falls in the range of 1 to 10 ppm,  1,3-D is moderately toxic to freshwater fish on an acute basis.
(MRID's 00039692 and STEODI02).  The registrant is also conducting additional studies on the
degradates as confirmatory data.

 Table 18. Freshwater Fish Acute Toxicity
 Species/
 (Flow-through or Static)       % ai
96-hour
LC50 (ppm)
(measured/nominal)
Toxicity Category
                MRID No.
                Author/Year
Study
Classification
 Walleye                 100         1.08 (measured)        Moderately Toxic
 (Stizostedion vitreum)
 static

 Largemouth Bass           100         3.65 (measured)        Moderately Toxic
 (Microptems salmoides)
 static
                                  40098001/Mayer    Core
                                  & Ellersieck/1986
                                  40098001/Mayer    Core
                                  & Ellersieck/1986
Rainbow Trout 92
(Salmo gairdneri)
static
Fathead Minnow 100
(Pimephales promelas)
static
Rainbow Trout 92
(Salmo gairdneri)
static
Bluegill Sunfish >80
(Lepomis macrochirius)
static
Bluegill Sunfish 92
(Lepomis macrochirirus)
static
Bluegill Sunfish 92
(Lepomis macrochirirus)
static
3.9 (measured)
4.1 (measured)
5.9 (unknown)
6. 1 (nominal)
6. 7 (unknown)
7.1 (measured)
Moderately Toxic 00039692/
Bentley/
1975
Moderately Toxic 40098001/ Meyer
& Ellersieck/ 1986
Moderately Toxic STEODI01
USEPA
1977
Moderately Toxic 0011 7043/
Buccafusco/
1981
Moderately Toxic STEODI02
USEPA
1977
Moderately Toxic 00039692/
Bentley/
1975
Core
Core
Core
Supplemental '
Core
Core
 1   Rated supplemental because the dose levels were not high enough to calculate an LD50.

                              (ii)  Freshwater Fish, Chronic

       Dow AgroSciences will conduct a freshwater fish early life-stage study (72-4) using
Rainbow trout as confirmatory data. As stated previously in this document, EPA believes that
1,3-D will undergo rapid rates of dissipation in most surface waters due to volatilization and, to a
lesser extent, by abiotic hydrolysis and possibly biodegradation. However, given the high acute
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LC50 value and a half-life of 13.5 days, the Agency is interested in comparing the results to the
run-off study to gage possible exposures to freshwater fish on a chronic basis.

                           (iii)    Freshwater Invertebrates, Acute

       Results of the freshwater invertebrate acute studies are presented in Table 19.

 Table 19. Freshwater Invertebrate Acute Toxicity
Species/(Static or Flow-
through) % ai
Waterflea 100
(Daphnia magna)
48-hour LC50/
EC50 (ppm)
(measured/nominal) Toxicity Category
0.09 Highly Toxic
MRID No.
Author/Year
40098001/
Mayer &
Ellersieck/
1986
Study Classification
Core
       Since the LC50/EC50 is less than 0.1 ppm, 1,3-D is considered very highly toxic to
aquatic invertebrates on an acute basis. The guideline (72-2) is fulfilled (MRID 40098001). The
registrant is also conducting the 72-2(a) study on the degradates to compare to the assumption in
the risk assessment that the degradates are of equal or less toxicity to 1,3-D.

                           (iv)  Freshwater Invertebrate, Chronic

       Dow AgroSciences has agreed to conduct a freshwater invertebrate chronic study (72-
4(b)) using Daphnia magna.

       The data at hand on acute levels show that the LC50 for aquatic invertebrates (0.09 ppm) is
less than 0.1 ppm. Also, at all registered application rates, initial, 21-day, and 90-day  surface-
water EECs, as calculated by GENEEC, are less than one percent of the lowest LC50 for
freshwater invertebrates. However, because GENEEC is not suitable for tracking soil  fumigants
and since EPA expects rapid rates of dissipation in most surface waters, EPA is less concerned
about chronic risks than for acute risks for aquatic invetebrates.

                           (v) Freshwater Field Studies

       A freshwater field study using the TGAI is not required for 1,3-D.

                    d.     Toxicity to Estuarine and Marine Animals

                           (i)     Estuarine and Marine Fish, Acute

       The 1986 Registration Standard did not require estuarine and marine studies.  Use of
1,3-D, however, is expected to expand into areas, namely Florida, that could impact estuarine and
marine environments.  The registrant has committed to submit by June 1, 1999 a study on 1,3-D
for acute estuarine and marine fish using the sheepshead minnow.  Studies on estuarine and

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marine fish for the degradates are reserved pending the outcome of this 1,3-D acute study and
other studies.

                            (ii)   Estuarine and Marine Fish, Chronic

       Chronic tests of estuarine/marine fish test using the TGAI are not required for 1,3-D at
this time.  This requirement will be re-evaluated after reviewing the freshwater fish toxicity
information.

                            (iii)   Estuarine and Marine Invertebrates, Acute

       The registrant is conducting confirmatory studies on the mysid shrimp (72-3(c)) and
Eastern oyster (72-3(b)) to test the toxicity of 1,3-D on estuarine and marine invertebrates.  As
noted above, 1,3-D use is expected to increase in areas and could impact estuarine and marine
environments.

                            (iv)    Estuarine and Marine Invertebrate, Chronic

       Chronic tests of estuarine and marine invertebrates using the TGAI are not required for
1,3-D at this time.  This requirement will be re-evaluated after examining the results of the chronic
freshwater invertebrate, acute marine/estuarine  studies and the run-off study.

                            (v)    Estuarine and Marine Field Studies

       A field study in estuarine/marine environments using the TGAI is not required for 1,3-D.

                     e.      Toxicity to Aquatic and Terrestrial Plants

       The registrant has committed to conducting Tier I and Tier II tests for aquatic and
terrestrial plants using the TGAI.  These studies are being conducted because 1,3-D is labeled for
use as an herbicide and has phytotoxicity warnings. The registrant has also committed to
conducting Tier I and Tier II tests for aquatic plants for the degradates (3- chloroacrylic acid and
3-chloroallyl alcohol).

                     f.      Toxicity of Degradation Products and Manufacturing
                            Impurities

       No data were available to conduct a full ecological assessment for 1,2-D, 3-chloroallyl
alcohol  or 3-chloroacrylic acid.  All of these chemicals are considered at least as toxic as the
parent.  As noted throughout this section, the registrant is conducting various environmental fate
and ecotoxicity studies on the degradates.
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              4.      Exposure and Risk Characterization

                     a.      Explanation of the Risk Quotient (RQ) and the Level of
                            Concern (LOC)

       Risk characterization integrates the results of the exposure and ecotoxicity data to
evaluate the likelihood of adverse ecological effects. The quotient method is used to integrate the
results of exposure and ecotoxicity data. In this method, risk quotients (RQ's) are calculated by
dividing exposure estimates by both acute and chronic ecotoxicity values.

       RQ = EXPOSURE/TOXICITY

       RQ's are then compared to EPA's levels of concern (LOC's). These LOC's are criteria
used by EPA to indicate potential risk to non-target organisms and the need to consider
regulatory action. The criteria indicate that a pesticide used as directed has the potential to cause
adverse effects on non-target organisms. LOC's currently address the following risk presumption
categories: (1) acute high - potential for acute risk is high and regulatory action may be
warranted in addition to restricted use classification; (2) acute restricted use - the potential for
acute risk is high but may be mitigated through restricted use classification; (3) acute
endangered species - the potential for acute risk to endangered species is high and regulatory
action may be warranted; and (4) chronic risk - the potential for chronic risk is high and
regulatory action may be warranted.  Currently, the Agency does not conduct assessments for
chronic risk to plants, acute or chronic risks to non-target insects, or chronic risk from
granular/bait formulations to mammalian or avian species.

       The ecotoxicity test values (i.e., measurement endpoints) used in the acute and chronic
risk quotients are derived from the results of required studies. Examples of ecotoxicity values
derived from the results of short-term laboratory studies that assess acute effects are: LC50 (fish
and birds), LD50 (birds and mammals), EC50 (aquatic plants and aquatic invertebrates) and EC25
(terrestrial plants).  Examples of toxicity test effect levels derived from the results of long-term
laboratory studies assessing chronic effects are: LOEC (birds, fish, and aquatic invertebrates),
NOEC (birds, fish and aquatic invertebrates) and MATC (fish and aquatic invertebrates).  For
birds and mammals, the NOEC value is used as the ecotoxicity test value in assessing chronic
effects.  Other values may be used when justified. Generally, the MATC (defined as the
geometric mean of the NOEC and LOEC) is used as the ecotoxicity test value in assessing chronic
effects to fish and aquatic invertebrates. However, the NOEC is used if the measurement
endpoint is reproduction or survival.  Risk presumptions, along with the corresponding RQ's and
LOC's are listed in Table 20.
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 Table 20. Risk Presumptions for Terrestrial Animals
Risk Presumption
Birds
Acute High Risk
Acute Restricted Use
Acute Endangered Species
Chronic Risk
Wild Mammals
Acute High Risk
Acute Restricted Use
Acute Endangered Species
Chronic Risk
RQ

EECVLC50 or LD50/sqft2 or LD50/day3
EEC/LC50 or LD50/sqft or LD50/day (or LD50 < 50 mg/kg)
EEC/LC50 or LD50/sqft or LD50/day
EEC/NOEC

EEC/LC50 or LD50/sqft or LD50/day
EEC/LC50 or LD50/sqft or LD50/day (or LD50 < 50 mg/kg)
EEC/LC50 or LD50/sqft or LD50/day
EEC/NOEC
LOG

0.5
0.2
0.1
1

0.5
0.2
0.1
1
1 abbreviation for Estimated Environmental Concentration (ppm) on avian/mammalian food items
2 mg/ft2 3 mg of toxicant consumed/day
LD50 * wt. of bird LD50 * wt. of bird
Table 2 1 . Risk Presumptions for Aquatic Animals
Risk Presumption
Acute High Risk
Acute Restricted Use
Acute Endangered Species
Chronic Risk
1 EEC = (ppm or ppb) in water
Table 22. Risk Presumptions for Plants
Risk Presumption
Terrestrial and Semi- Aquatic Plants
Acute High Risk
Acute Endangered Species

Acute High Risk
Acute Endangered Species


RQ
EECVLC50 or EC50
EEC/LC50 or EC50
EEC/LC50 or EC50
EEC/MATC or NOEC


RQ

EECVEC25
EEC/EC05orNOEC
Aquatic Plants
EEC2/EC50
EEC/EC05orNOEC


LOG
0.5
0.1
0.05
1


LOG

1
1

1
1
1 EEC = lbsai/A
2 EEC = (ppb/ppm) in water
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       For pesticides applied as nongranular products (e.g., liquids, dusts applied via broadcast
methods, etc.), the EECs on food items following product application are compared to toxicity
values to assess risk (Fletcher et al., 1994).  However, the Agency currently does not have
routinely used methods for predicting EECs for soil fumigants. When available, risk
determinations can be made when actual concentrations have been reported in terrestrial field
dissipation studies or other  studies submitted in support of reregi strati on.

                     b.     Field Data Used for Risk Assessment

       In this assessment, post-application 1,3-D residues detected in soil, water, and air samples
are compared to toxicity values. It should be noted that this risk assessment relies on very little
data, measured or predicted. It should also be noted that the reported field studies were
conducted with lower application rates than allowed on some crops.  1,3-D concentrations in soil,
water, and air will be higher with corresponding higher application rates. However, the risk
quotients calculated from the environmental data do provide information about the potential risk
of 1,3-D application to non-target species. In some instances, extrapolations were made to higher
application rates, however, these levels are a simplification of what actual levels may be.
Environmental fate and air monitoring study results have not established a correlation between the
level of applied product and subsequent levels in the environment.

       Two terrestrial field dissipation studies (MRID's 40403301 and 40855501) provided
1,3-D residue concentrations in treated soil and subsequent dissipation rates. A prospective
ground-water monitoring study in Florida yielded 1,3-D concentrations in water collected from
ditches adjacent to treated fields (MRID 44005201).  Three field volatility studies evaluated
atmospheric concentrations of 1,3-D under field conditions (MRID's 42545101, 41057701 and
EFGWB 91-0910).

                     c.      Exposure and Risk to Non-target Terrestrial Animals

       1,3-D is used on over half a million acres of cropland each year (see Table 1). For
orchard trees and grapevines,  approved rates are as high as 556 Ibs a.i./A.  However, because the
application method reduces terrestrial exposure and because of the relatively low toxicity to
mammals, its use is not expected to result in large incidents of mortality. No avian mortality
incidents have been reported in relation to 1,3-D applications. Tel one C-17 contains chloropicrin,
which is a contact irritant to humans and serves as a warning to applicators. It is assumed this
product could affect birds and wild mammals in the same manner, resulting in avoidance and
thereby reducing the risk of exposure.

       The Agency does not have  a standard protocol for conducting terrestrial risk assessments
on terrestrial organisms when chemicals are applied via soil injection methods.  Instead, in this
risk assessment, animals were assumed to be exposed through dietary intake of contaminated soil.
Beyer et al. (1994) analyzed scat samples from a variety of vertebrate species to determine the
percent of soil in the  diet. His work showed that the quantity of soil in animal diets can range
from less than two percent up to 30 percent. Animals can ingest soil intentionally to provide

                                            73

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missing minerals or unintentionally through preening and grooming activities or by particles
adhering to food items such as roots, tubers or foliage.  Many species of birds also inadvertently
ingest soil when probing soft soils for food. For the purpose of calculating risk quotients, it was
assumed that 100 percent of the soil in an animal's diet comes from the treated field.
                             (i)
Birds
       Because of the application method, 1,3-D use in chemical soil fumigation operations is not
expected to present a significant hazard to avian species.  However, birds could be exposed
through both dietary and inhalation routes. The available toxicity information allowed an acute
risk determination through dietary routes. However, no information is available on acute
inhalation toxicity to birds but the acute risk associated with this type of exposure is probably
insignificant.

       Risk quotients were calculated from the field dissipation residue data submitted to the
Agency in support of reregi strati on. The Northern bobwhite LD50 was  chosen to calculate the
following risk quotients because of the wide range between the avian LD50 and the two avian
LC50's determined for this chemical. The discrepancy between the two endpoints is believed to be
the result of the difficulty of keeping 1,3-D concentrations constant on the test diets considering
1,3-D's volatility. The following equation was used to determine the avian acute risk quotients:
       LD50s/day = EEC * (% daily food consumption * °/
                                  LD-
                  % soil in diet)
                                    '50
The results of these calculations are presented in Table 23.
 Table 23. Risk Quotients for Acute Avian Exposure —based upon an Avian LD50 of 152 mg/kg and a mean and range of soil consumption rates1
 of 10.6% (>2% to 30%) of the total daily food intake and a daily food consumption rate of 18% of total body weight. EECs are taken from a field
 dissipation study submitted to the Agency (MRID 40403301).
Application Rate and
Injection Depth
(MRID #)
EEC (ppm)
342 Ibs ai/acre
(13-15 inches) 130
(404033-01)
Avian LD50
(mg/kg)
152
Daily Soil Ingestion
Rate1
Mean = 10.6%
Range = >2 to 30%
RQ
Mean =0.02
Range = <0.003 to 0.05
1 Soil consumption values are taken from Beyer et al. 1995.

       From Table 20, the LOC's for avian species are: 0.5 (acute high risk); 0.2 (acute
restricted use); 0.1 (acute  endangered species); and 1 (chronic risk)  An evaluation of the
above risk quotients shows that no LOC's are exceeded for avian species. If it assumed that the
concentration in soil is directly proportional to the application rate, the EEC would be 208 ppm at
the highest rate of 556 Ibs a.i./acre.  At this concentration, no LOC's were exceeded. At this soil
concentration, a 100-gm bird with an LD50 of 152 mg/kg would need to consume 72 grams of soil
to attain this equivalent dose.  This evaluation indicates that 1,3-D use should not result in
significant acute mortality to avian species under any application scenario.
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       No avian chronic test data were required to support reregi strati on.  Since 1,3-D is
generally only applied once per growing season and because it has a relatively short field
dissipation half-life, it is not expected to result in long-term exposure or subsequent chronic
effects.

                             (ii)  Mammals

       Because of the application method, the use of 1,3-D in chemical soil fumigation operations
is not expected to present a significant hazard to mammals. However, exposure could occur
through both dietary and inhalation routes.  No incidents of mammalian mortality have been
reported due to the application of 1,3-D.

       Risk quotients were calculated from field dissipation data and laboratory mouse LD50 data
using the following equation:

       LD50s/day = EEC * (% daily food consumption * % soil in diet)
                                  LD
                                     50
The results of these calculations are presented in Table 24.
 Table 24. Risk Quotients for Acute Mammalian Exposure — based upon a mammalian LD50 of 640 mg/kg and a mean and range of soil
 consumption rates1 of 4.4% (>2%to 17%) of the total daily intake and a daily food consumption rate of 95% of total body weight. EECs are from
 a field dissipation study submitted to the Agency (MRID 40403301).
Application Rate and
Injection Depth
(MRID #)
EEC (ppm)
342 Ibs ai/acre
(13-15 inches) 130
(404033-01)
Mammalian LD50
(mg/kg)
640
Daily Soil Ingestion
Rate1
Mean = 4.4%
Range = >2 to 17%
RQ
Mean =0.008
Range = <0.003 to 0.03
1 Soil consumption values are taken from Beyer et al. 1995.
       From Table 20, the LOC's for mammal are as follows: 0.5 (acute high risk); 0.2
(acute restricted use); 0.1 (acute endangered species); and 1 (chronic risk). Evaluation of
the above risk quotients show that no LOC's are exceeded for mammalian species.  If it is
assumed that the concentration in soil is directly proportional to the application rate, the EEC
would be 208 ppm at the highest rate of 556 Ibs a.i./acre. At this soil concentration, a 20-gram
mouse with an LD50 of 640 mg/kg would need to consume 61 grams of soil (three times its body
weight) to attain this equivalent dose.  Therefore, 1,3-D use should not result in significant acute
mortality to mammalian species via dietary exposure under any application scenario.

       Acute inhalation toxicity was assessed by comparing mammalian inhalation data to the
amount of volatilized chemical found above the treated fields. Using an application rate of 346
Ibs a.i./acre, 1,3-D concentrations at a height of 6 inches above the soil surface never exceeded
4.4 ppm.  This value is less than 0.01 percent of the mammalian inhalation LD50 of 713 mg/kg.
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Even if 1,3-D concentrations in the air are directly proportional to the application rate,
atmospheric concentrations are not expected to reach toxic levels.  This result also indicates that
1,3-D use should not result in significant acute mortality to mammalian species via inhalation
exposure under any application scenario.

       Chronic toxicity is normally assessed through dietary routes of exposure and soil can be a
substantial portion of the diet. Using the assumptions of the acute assessment and substituting the
reproductive effect NOEL of > 90 ppm for the LD50, the chronic LOG is not exceeded. Chronic
risk can also be assessed by using the NOEL of 5 mg/kg/day derived in the 13-week rat feeding
study.  The following assumptions are used for this calculation:

       - a mouse weighs approximately 20 grams, so the NOEL per mouse would be 0.1 mg/day;
       - a mouse eats the equivalent of 18 percent of its body weight per day and a maximum of
       17 percent of the diet is soil, which equates to 612 mg of soil per day;
       - if soil 1,3-D concentrations were 208 mg/kg soils at an application rate of 556 Ibs
       a.i./acre, each gram of soil would contain 0.208 mg. 1,3-D; and
       - following these assumptions, a mouse would consume 0.127 mg of 1,3-D per day.

       Using the above scenario, the chronic RQ is 1.3, which exceeds the LOG. However, this
model uses maximum exposure condition. If factors such as the average concentration of 1,3-D
over a 13 week period (32 ppm at a seven day field dissipation half-life) or soil consumption rates
more typical of small mammals are used, the LOG is no longer exceeded.  Since 1,3-D is applied
generally only once per growing season and because it has a relatively short dissipation half-life,
EPA does not expect long-term exposures.

                           (iii)   Terrestrial Insects

       The Agency  currently does not assess risk to non-target insects. Results of acceptable
studies are used for recommending appropriate label precautions.

                    d.     Exposure and Risk to Non-target Freshwater Aquatic Animals

       Exposure of pesticides to aquatic  non-target organisms is possible through surface water
runoff, soil erosion, off-target drift, and movement from ground water to surface water. Risk via
exposure to 1,3-D concentrations in surface-water was assessed by using aquatic EEC's predicted
using the program GENEEC (see Table 21) and from actual residues in ditch water found during
a ground-water study. These estimates of environmental levels were then compared to known
toxicity reference values.

                           (i)     Freshwater Fish

       Acute and chronic risk quotients are presented in Table 25.
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 Table 25. Risk Quotients for Freshwater Fish —Based on a (Walleye) LC50 of 1.08 ppm. Chronic risk quotients could not be evaluated due to the
 lack of chronic toxicity information.
Site/
Application
Method/ Rate in Ibs
ai/A
177
253
354
404
556

LC50
(ppm)
1.08
1.08
1.08
1.08
1.08

NOEC/
MATC
(ppm)
nd
nd
nd
nd
nd

EEC
Initial/Peak
(ppm)
0.685
0.980
1.380
1.570
2.160

EEC
90-Day Ave.1
(ppm)
0.006
0.008
0.012
0.013
0.018

Acute RQ
(EEC/LC50)
0.63
0.91
1.27
1.45
2.00

Chronic RQ
(EEC/NOEC or
MATC)
nc
nc
nc
nc
nc
 1 56 day concentration was not modeled.
 nd  = no data
 nc  = not calculated
       From Table 21, the LOC's for aquatic animals areas follows: 0.5 (acute high risk);
0.1 (restricted use); 0.005 (acute endangered species); and 1 (chronic).  The results of the
GENEEC model indicate that aquatic acute high risk, restricted use, and endangered species
levels of concern are exceeded for freshwater fish at application rates equal to or above 177 Ibs
a.i./acre. Chronic risk could not be determined because of the lack of chronic toxicity data.

       Because GENEEC is not suitable for tracking soil fumigants, EPA believes that actual
residues may be a better indicator of exposure and risk. The freshwater fish LC50 (1.08 ppm) was
compared to actual residues detected in perimeter ditches adjacent to fields treated at an
application rate of 182 Ibs a.i./acre (MRID #44005201). Concentrations ranged from 0.34 ppb to
1.8 ppb. The resulting risk quotient ranges from 0.002 to 0.0003 which does not exceed any
LOG. If residues in ditch water are assumed to be directly proportional to the application rate,
then at 556 Ibs ai/acre, concentrations in ditch water would  reach 5.5 ppb. At this concentration
no LOC's are exceeded.

       Concentrations of 1,3-D in ground water four feet below the surface in Florida reached a
maximum of 833 ppb. At this concentration, the acute high risk LOG for fish would be exceeded
by 1,3-D alone by 1.5 times. This assessment does not account for the additional toxicity
presented by the two degradates that were also found in ground water in Florida. Note that there
can be considerable interaction  between surface and ground water, thus, the  levels found in
ground water are relevant in a discussion of exposures to fish.

                            (ii)    Freshwater Invertebrates

       The acute and chronic risk quotients  are presented in Table 26.
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 Table 26. Risk Quotients for Freshwater Invertebrates —Based on a Daphnia LC50 of 0.09 ppm. Chronic risk quotients could not be evaluated
 due to the lack of chronic toxicity information.
Site/
Application
Method/ Rate in Ibs ai/A
177
253
354
404
556
nd = no data
nc = not calculated

LC50
(ppm)
0.09
0.09
0.09
0.09
0.09



NOEC/
MATC
(ppm)
nd
nd
nd
nd
nd



EEC
Initial/Peak
(ppm)
0.685
0.980
1.380
1.570
2.160



EEC
21 -Day Ave.
(ppm)
0.025
0.035
0.05
0.055
0.080



Acute RQ
(EEC/LC50)
7.61
10.89
15.33
17.44
24.00



Chronic RQ
(EEC/NOEC or
MATC)
nc
nc
nc
nc
nc


       From Table 21, the LOC's for aquatic animals areas follows: 0.5 (acute high risk;
0.1 (restricted use); 0.005 (acute endangered species); and 1 (chronic). The results indicate
that aquatic acute high risk, restricted use, and endangered species levels of concern are exceeded
for freshwater invertebrates at application rates equal to or above 177 Ibs a.i./acre from the
GENEEC model. Chronic toxicity could not be determined due to a lack of toxicity information.

       When the LC50 (0.09 ppm) is compared to actual residues (MRID #44005201) detected in
perimeter ditches adjacent to fields in Florida treated at an application rate of 182 Ibs a.i./acre
ranged from 1.8  ppb to 0.34 ppb.  The resulting risk quotients range from ranges from 0.02 to
0.004, which do  exceed the endangered species LOG.  If residues in ditch water are assumed to
be directly proportional to the application rate,  then at  556 Ibs a.i./acre, concentrations in ditch
water would reach 1.04 to 5.5 ppb.  At concentrations  above 4.5 ppb, endangered species LOCs
are exceeded.

       Concentrations of 1,3-D in ground water four feet below the surface at the application site
in Florida reached a maximum of 833 ppb. At this concentration, the acute high risk LOG for
invertebrates would be exceeded.  This does not account for the additional toxicity presented by
the two degradates that were also found in this  ground water.  Additionally, concentrations
remained at potentially toxic levels for approximately 60 days. In addition to 1,3-D movement in
aquatic environments through ground and surface water interaction, shallow ground water is itself
inhabited by aquatic invertebrates.

                     e.      Exposure and Risk to Estuarine and Marine Animals

       No toxicity information for estuarine and marine animals were required in the 1986
Registration Standard.  Consequently, no risk analysis  could be conducted for these types of
organisms.
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       The registrant is conducting several estuarine and marine studies on 1,3-D. The tests are
estuarine/marine invertebrates with the mysid shrimp (72-3(c)) and the Eastern oyster (72-3(b))
and estuarine/marine fish using the Sheepshead minnow (72-3(a)). Should the results of these
studies and other toxicity studies on the degradates show a potential for ecotoxicity from the
degradates, EPA will also require studies on the degradates for estuarine and marine animals.

                     f.      Exposure and Risk to Non-target Plants

       No toxicity information for non-target plants were required in the 1986 Registration
Standard.  Consequently, no risk analysis could be conducted for these types of organisms.  The
registrant has committed to conducting Tier I and Tier II studies for 1,3-D (aquatic and
terrestrial) and its degradates (aquatic). These studies are scheduled to be submitted by October
1, 2000.

                     g.     Endangered Species

       The Endangered Species Protection Program is expected to be finalized in the future.
Limitations in the use of 1,3-D will be required to protect endangered and threatened species, but
these limitations have not been defined and may be formulation specific. EPA anticipates that a
consultation with the Fish and Wildlife Service will be conducted in accordance with the species-
based priority approach described in the Program. After completion of consultation, registrants
will be informed if any required label modifications are necessary.  Such modifications would most
likely consist of the generic label statement referring pesticide users to use limitations contained in
county bulletins.

IV.    RISK MANAGEMENT AND REREGISTRATION DECISION

       A.     Determination of Eligibility

       Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission of
relevant data concerning an active ingredient, whether products containing the active ingredient
are eligible for reregistration. The Agency has previously identified and required the submissions
of generic (i.e. active ingredient specific) data required to support reregistration of products
containing 1,3-D. The Agency has completed its review of these generic data and has determined
that the data are sufficient to support reregistration of 1,3-D.  Appendix B identifies the generic
data requirements that the Agency reviewed as part of its determination of reregistration eligibility
of 1,3-D, and lists the submitted studies that the Agency found acceptable.

       The data identified in Appendix B were sufficient to allow the Agency to assess the
registered uses of 1,3-D. The Agency has determined that 1,3-D products, when used as
specified in this document (i.e. only pre-plant soil fumigant uses and according to label
requirements to include the pending restrictions listed in Table 31), do not result in unreasonable
adverse effects to human health or the environment. Therefore, the Agency finds that products
containing 1,3-D as the active ingredient are eligible for reregistration. The reregistration of

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particular products is addressed in Section V. of this document.  Note that products which also
contain chloropicrin will not be deemed eligible for reregistration until the reregi strati on of that
active ingredient has been completed.

       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, published scientific literature, etc. Although the Agency has found that all
uses of 1,3-D are eligible for reregistration when used according to specifications in this
document, it should be understood that the Agency may take appropriate regulatory action and/or
require the submission of additional data to support the registration of products containing 1,3-D
if new information comes to the Agency's attention or if the data requirements for registration (or
the guidelines for generating such data) change.  This includes the results of the studies now
underway on the degradates, the run-off study, and the tap water monitoring program.

       B.     Determination of Eligibility Decision

              1.     Eligibility Decision

       Based on the reviews of the generic data for the active ingredient 1,3-D, as well as other
data generated for the 1,3-D Special Review, the Agency has sufficient information on the health
effects of 1,3-D and on its potential for ground water contamination.  The Agency has determined
that  1,3-D products, labeled and used as specified in this Reregistration Eligibility Decision
document, will not pose unreasonable adverse effects to humans or the environment. Therefore,
the Agency concludes that all products containing 1,3-D, when used under the conditions
specified in this document, are eligible for reregistration.

       C.     Regulatory Position

       The following is a summary of the regulatory positions and rationales for managing risks
associated with the use of 1,3-D. Where the registrant has committed to labeling revisions that
are not yet on 1,3-D labels,  specific language is set forth in Section V. of this document.

              1.     Summary of 1,3-D's Carcinogenicity

       EPA has  classified 1,3-D as a B2 carcinogen by both the oral and inhalation routes of
exposure. Dow AgroSciences has submitted information in support of having EPA regulate
1,3-D as  a non-linear carcinogen.  EPA conducted a  preliminary review of the information and
expects to reconvene the Cancer Peer Review sometime in  1999 to consider the information.
EPA will not, however, reconsider the 1,3-D risk assessment until all EPA policies regarding the
regulation of non-linear carcinogens are finalized.
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              2.      Summary of EPA's Approach to the 1,3-D Risk Assessment

                     a.     Tolerances, Codex Harmonization and Dietary Risk

       EPA has determined that 1,3-D, when applied as a pre-plant soil fumigant, is a non-food
use pesticide and therefore, tolerances or exemptions from the requirement of a tolerance, are not
required. (There is one exception for pineapples, which are treated at plant but show no residues
since fruit are not borne until three years later). Therefore, a review of tolerance actions under
the safety standard established under section 408(b)(2)(D) of the Federal Food, Drug and
Cosmetics Act, as amended by FQPA,  is not required. 1,3-D is regulated under the safely
standard established under Section 3 of FIFRA, which requires that no unreasonable adverse
effects to human health or the environment be associated with use of a pesticide. Nonetheless,
EPA has reviewed the data base for 1,3-D to determine whether infants and children are
particularly susceptible to toxic effects from exposures to 1,3-D residues and whether aggregate
and cumulative exposures pose unreasonable risks.

       No tolerances or Codex MRLs have been established; therefore, there are no issues
regarding the compatibility of MRLs and tolerances.

       Although there is no dietary risk from foods, EPA's risk  assessment assumes dietary
exposures to come from water sources (ground water). Results  from the Florida study suggest
that 1,3-D may enter surface water as volatilized residues in the  air, settle into surface water and
then dissolve.  This route, however, is considered insignificant and the registrant is conducting
studies to  confirm that surface water is not a significant source of exposure.

       EPA also looked to see if infants and children have increased susceptibility to the toxic
effects of 1,3-D. In  making its  determination, EPA considered the completeness of the database
for developmental and reproductive effects, the nature of the effects observed and other
information. Based on the current data requirements,  1,3-D has a complete database for
developmental and reproductive toxicity. Therefore, EPA has concluded that an extra uncertainty
factor of 10 is  not warranted in order to protect infants and children.

       No acute toxicological endpoints were identified for 1,3-D exposure for any population
sub-group under labeling as specified in this document.  For 1,2-D, the levels found in the ground
water studies were 20  to 30 times lower than the Office of Water's  10-day Health Advisory for
children.

        Dow AgroSciences is developing data for reregi strati on on the toxicological profile,
including developmental toxicity, for the alcohol and acid degradates.  For purposes of
reregi strati on, the Agency assumed that the degradates possess the same toxicological profile as
the parent.
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                     b.     Aggregate and Cumulative Risk

       EPA considers the main sources of 1,3-D exposure to be inhalation and drinking water
from contaminated wells, especially for residents who live near treated fields.  Aggregated cancer
risks (inhalation plus water) for residents who live near treated fields based only on the
information that allowed quantification of exposure are approximately 1 x 10"5. This estimate
does not include all of the mitigation measures to reduce inhalation risk, nor does it take into
account a 100 foot no-treatment buffer from drinking water wells.  While there are no data to
assess the potential for risk from surface water residues, EPA believes this would be an
insignificant source of exposure.  Based on use patterns,  dermal exposure is considered to be
insignificant.  EPA also looked at whether the Agency  should also provide estimates of
cumulative risks with the contaminant, 1,2-D.  EPA does not have available data to determine
whether 1,3-D has a common mechanism of toxicity with 1,2-D or other substances.  For
purposes of this reregi strati on action, EPA has assumed that 1,3-D and 1,2-D do not have a
common mechanism of toxicity. EPA has determined  that exposures under the current use
patterns meet the safely standards set by FFDCA and FIFRA.

                     c.     Effects to the Endocrine  System

       EPA is required to develop a screening program to determine whether certain substances
(including all active ingredient pesticides and inerts) "may have an effect in humans that is similar
to an effect predicted by a naturally occurring estrogen, or such other endocrine effect."  The
Agency is currently working with interested stakeholders, including other government agencies,
public interest groups, industry and research scientists in developing a screening and testing
program and a priority setting scheme to implement this program. Congress has allowed three
years from the passage of FQPA (August 3, 1999) to implement this program.  At that time, EPA
may require further testing of this active ingredient and end-use products.

       In deciding to continue to make reregi strati on determination during the early stages of
FQPA implementations, EPA recognizes that it will be necessary to make decisions relating to
FQPA before the implementation process is complete.  In making these early case-by-case
decisions, EPA does not intend to set broad precedents for the application of FQPA to its
regulatory determinations.  Rather, these early decisions will be made on a case-by-case basis and
will not bind EPA as it proceeds with further policy development and rulemaking that may be
required.

       EPA may determine, as a result of this later implementation process, that any of the
determination described in this RED are no longer appropriate.  In this case, the Agency will
consider itself free to pursue whatever action may be appropriate including,  but not limited to,
reconsideration of any portion of this RED.
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              2.      Summary of 1,3-D's Benefits

       1,3-D is one of the few remaining registered soil fumigants used to control nematodes.
Nematodes are microscopic soil worms that live in the soil spaces. Nematodes cause damage by
damaging the roots themselves (thereby doing the most damage to root crops such as carrots and
potatoes), by reducing yields and by creating opportunities for other soil pathogens to enter the
plant. 1,3-D is also used to control wireworms and rhizomania. The combination product of
1,3-D and chloropicrin is  also used to treat nematodes and fungi.

       The benefits of 1,3-D use are expected to increase with the phase-out of methyl bromide,
mainly for use on tomatoes and strawberries. Additional research may find alternative uses for
1,3-D, or it is possible that other nematicides are identified or developed to replace both methyl
bromide and 1,3-D.

              3.      Summary of Risk Management Decisions

                     a.      Human Health

                            (i)     Dietary

       The Agency has determined that dietary exposure and risk associated with the use of
1,3-D under current labeling are negligible.

       Exposure through Foods Grown in Treated Soils. Data show that no residues of 1,3-D
or its degradates of toxicological concern are found in crops grown in treated soils, as long as
1,3-D is applied as a pre-plant soil fumigant.  1,3-D labels suggest a waiting period of one week
for every 10 gallons of 1,3-D applied between soil treatment and planting, based on phytotoxicity
concerns. For fall fumigation, 1,3-D is applied several months before planting. 1,3-D either
volatilizes, leaches below the root zone, or breaks down in the soil, and thus is generally not
available for uptake.

       Dow AgroSciences has indicated interest in at- and post-plant applications of 1,3-D to
orchard crops and grapevines. Before acting on these registrations, the Agency will require data
on whether there are residues in treated crops and whether tolerances, or exemptions from the
requirement of a tolerance, will be needed to support these uses.

       Exposure through Water.  Based on ground water monitoring, the Agency has
concluded there can be dietary exposure to  1,3-D through contaminated ground water. 1,3-D is
mobile, and in some areas, persistent, though these properties vary according to environmental
conditions such as temperature, soil type and soil porosity.

       There are numerous ground water data bases available to the Agency, including a survey
of EPA's own monitoring, the USGS NAWQA Program and state data.  The best information for
assessing human health impacts are two prospective ground water monitoring  studies conducted

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in Florida and Wisconsin.  The Agency believes that these two study sites represent vulnerable
environments for ground water contamination from 1,3-D use.

       The Florida site is vulnerable in that the soils are porous and the water table is shallow.
The Agency is particularly concerned about the potential for increased use in these vulnerable
environments because 1,3-D has been identified by USD A as an adequate alternative to methyl
bromide, which is used heavily in Florida tomato production. Dow AgroSciences has agreed to
conduct tap water monitoring in both traditional 1,3-D use areas in the north of the state and in
south Florida once 1,3-D use expands to that region. Risks associated with levels found in
shallow, on-site wells were as high as 4 x 10"6 (though the labels which are to take effect in
August of 1999 will prohibit 1,3-D use within 100' of drinking water wells).

       The Wisconsin site is also vulnerable.  The ground water level is high and soils are porous;
in addition, risk appears to be exacerbated by low soil and water temperatures. In the Wisconsin
study, risks associated with lifetime exposures to levels found in on-site wells were in the 10"3
range, and measurable levels persisted for more than 12 months.

       Both prospective ground water monitoring studies included limited monitoring in off-site
wells located down gradient from the treated fields.  In the Florida study, time weighted average
(TWA) concentrations of 1,3-D plus its degradates in the on-site wells (10' deep) were 1.15 ppb.
TWA concentrations of 1,3-D plus degradates measured in wells located 100 feet down gradient
from the treated field were 0.074 ppb.  In the Wisconsin study, on-site wells yielded TWA
concentrations of 1,3-D  and its degradates of 357 ppb while concentrations in a well 65' down
gradient from the treated field were 26.6 ppb. Although neither of these studies was designed to
quantify offsite exposures; results in both studies indicate that exposures were considerably lower
with increasing distance from treated field.

       Dow AgroSciences has agreed as a condition of reregi strati on to conduct tap water
monitoring studies to better estimate current concentrations of 1,3-D and degradates in drinking
water. Sampling will be targeted to high-use areas and will be initiated once the new labels are in
effect in August of 1999. Should residues of 1,3-D and/or the alcohol or acid degradates be
detected at levels exceeding the Office of Water Health Advisory of 0.2 ppb, Dow AgroSciences
has included, as part of the sampling program, risk reduction measures which would be in place
before the next use season. EPA expects to use the results of the sampling program to better
characterize risks with the 100' setback and to also see if the sampling program results can be
extrapolated in order to  characterize risks in other 1,3-D use  areas.

       The Agency has evidence that degradation of 1,3-D is temperature dependent.  For this
reason, the Agency believes that once  1,3-D contaminates ground water in certain colder areas,
residues can persist for long periods of time at levels that pose unreasonable risks. For this
reason, Dow  AgroSciences amended their labels to prohibit use in  certain northern tier states
where soils are porous and water tables are 50 feet or less. Although 1,3-D is used infrequently,
or not at all in these areas, the Agency believes the label statement is appropriate. Based on the
levels and persistence seen in the Wisconsin study, one application could result in unreasonable

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lifetime risks.  Dow AgroSciences is also conducting tap water monitoring in Michigan and
Connecticut to confirm that the label prohibition to be added as of August 1, 1999 covers all
vulnerable cold environments.

       EPA is also aware of other data bases which show only a few detects out of tens of
thousands of samples nationwide. The NAWQA sampling showed no detections of 1,3-D out of
21 study units, the locations of which coincide with some of the counties with heaviest 1,3-D use.
The main weakness in interpreting these data is that there is no information in the summary
reports to determine whether 1,3-D was used in proximity of tested wells. A second weakness is
that NAWQA did not test for the presence of the two degradates of toxicological concern
(3-chloroacrylic acid and 3-chloroallyl alcohol). Nonetheless, the NAWQA summary reports do
provide a qualitative sense that 1,3-D use does not result in widespread aquifer contamination.

       In summary, the Agency believes it has  mitigated risks in the most vulnerable areas and is
focusing resources now on developing confirmatory data in additional areas of high 1,3-D use.
All 1,3-D labels bear a ground water advisory to alert users to ground water contamination risk
and as of August 1, 1999, there will be a 100 foot buffer between drinking water wells and treated
fields. Although the buffer is expected to provide some protection to drinking water, the actual
mitigation on a site-by-site basis cannot be quantified since this will depend on a variety of local
factors (such as soil type, subsurface hydrogeology, etc.).  The tap water monitoring will be
designed to allow EPA to take further regulatory action if study results indicate a problem.  EPA
is also committed to following trends in usage should 1,3-D use increase significantly, especially
in areas which may be vulnerable.

                            (ii)    Residential Exposure

       The Agency has determined that exposures and risk to residents who live near 1,3-D-
treated fields has been mitigated to the extent feasible.  Data developed for reregi strati on and the
Special  Review show that about 25 percent of applied 1,3-D volatilizes from treated soils into the
atmosphere and that atmospheric levels decrease with increasing distance from treated fields.
These studies were less clear as to the value of a variety of measures added to 1,3-D labels.

       In  1994, 1,3-D labels were modified to  add a 300 foot buffer between occupied structures
and treated fields.  Three  air monitoring studies in different environments show an approximate 30
percent  overall reduction  in air levels at this distance, however, the amount varied by site. In
addition, there are label measures designed to minimize the amount of 1,3-D that volatilizes out of
treated fields, such as soil sealing, engineering controls for loading and application and lowered
rates. As mentioned above, the risk reduction value of several of these measures cannot be
quantified with the data available, and would be difficult to obtain based on numerous
uncontrollable variables that ultimately influence exposure to 1,3-D.

       In addition to not  including (in a quantitative sense) all mitigation measures, there are also
uncertainties related to the data used to derive the residential exposure estimates.  For example,
although levels are generally expected to decrease with increasing distance, at the Washington

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site, levels at 125 meters were approximately 70% higher than at 25 meters (see Table 8).
Although the studies were carefully designed to assess actual exposures, the variety and influence
of local environmental factors (such as wind, soil type, temperature) were quite large. These
factors not only varied from test site to test site, but even day by day at the individual test sites.
In addition, the small number of replicates per site are likely to have contributed to the mixed
results.  The assessment also assumes that a person is 300 feet from the edge of the field for 16
hours a day, 15 days a year for 30 years. EPA believes it is reasonable to use this  as a "worst-
case" exposure scenario, though this is likely to overstate most residents' exposure.

       In addition, a weakness in the residential exposure assessment is in the use of the North
Carolina data using 55-gallon drums of Telone C-17.  While a  later study using the mini-bulk
system was used to replace the worker exposures, that study could not be used for residential
exposure assessment.  The N.C. data was combined with the Washington state and Arizona data
to get an average exposure, so the contribution of the N.C. values is expected to overstate
exposures because of the higher air levels associated with drum loading.

       Dow AgroSciences has indicated interest in developing systems that apply 1,3-D at sub-
surface soil depths, instead of at the 12 inch depth required by  current labels. The Agency believes
that this new method could provide lower exposures since the  delivery system would not leave  a
chisel trace.  This chisel trace is thought to be the main path for 1,3-D movement to the
atmosphere.  The Agency will require air monitoring with any  registration application which
requests depth of application of less than 12 inches.

       There are no residential uses of 1,3-D; thus, there is no exposure from home-based
applications.

                            (iii)    Aggregate and Cumulative Risks

       The calculated drinking water risk estimates using 1,3-D labels eligible for reregi strati on is
4 x 10"6 (using on-site wells from the Florida study); the inhalation risk is 6 x 10"6 (using an
average of levels monitored from NC, WA and AZ study sites at the 300' buffer).  Thus the
calculated aggregate risk estimate is 1 x 10"5. This risk estimate does not take into account
mitigation from lower application rates, soil sealing measures,  increased depth of application, soil
moisture and temperature requirements or potential reduction  in exposure from the 100 foot
drinking water well setback. EPA believes the risk estimates are likely to be in the 10"6 range and
that risk concerns have been addressed when all of the mitigation measures as specified in this
reregi strati on decision are taken into account.  The Agency has not cumulated risks with the
impurity 1,2-D or other chemicals since no determination has been made that these chemicals
share a common mode of toxicity.

                            (iv)    Occupational Exposure

       The Agency has determined that existing label measures are sufficient to mitigate worker
exposures to 1,3-D.  Several label changes have been made since the 1986 Registration Standard,

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including closed loading systems, engineering controls to prevent 1,3-D spillage at row-turns, the
phase-out of drum delivery, respiratory requirements, the use of closed cabs, increasing the
restricted entry interval from three to five days and protective clothing.

        While the data developed for estimating worker risks is of high quality, there are
uncertainties.  From Table 7, the studies used to test the efficacy of dry disconnects (shut-off
valves for closed loading systems) gave mixed results, even suggesting that exposures were higher
with the dry disconnects. Another uncertainty is assessing the potential risk to workers based on
the methyl bromide phase-out. Increased 1,3-D risks would occur if a worker who currently
applies methyl bromide replaces that methyl bromide use with 1,3-D. Based on conversations
with grower groups and  the registrant, this is unlikely since there is very little, if any, tandem use
of the two fumigants.  The phase-out of methyl bromide will likely increase the numbers of
workers who are exposed to 1,3-D, but will not likely increase the lifetime cancer risk of an
individual worker.

       According to data developed for the Special Review and reregi strati on, the risks for
custom applicators, custom loaders and for growers (who are assumed to both load and apply
1,3-D) is in the 10"5 to 10"6 range. Note that  1,3-D is  a restricted use pesticide based on cancer
concerns for worker risks. Because of this there are certain training and reporting requirements.
The 1,3-D product stewardship goes beyond this training to provide manuals, videos and technical
support in the field.

       EPA's policy on worker risk sets a goal of no greater than 10"6 lifetime risks for workers.
If, however, there are not measures available to do so, then risks that are somewhat higher will be
considered acceptable.  Risks that are higher than 10"4 are generally not seen as acceptable unless
extremely high benefits of the use of the pesticide outweigh these risks.

       In summary, the  Agency believes that worker risks have been adequately mitigated with
current label measures and are in accordance with current worker risk policies.  The Agency's
determination takes into account expected increases in usage of 1,3-D with the methyl bromide
phase out.

                     b.     Environmental/Ecological Effects

       The Agency believes that use of 1,3-D as specified in this document will not pose
unreasonable risks to the environment.  However, certain  properties of 1,3-D and its degradates
justify the on-going monitoring program underway to confirm this position.

       Specifically, 1,3-D and its degradates have been detected in both retrospective and
prospective ground water monitoring studies. 1,3-D is considered mobile and persistent, with
these properties varying depending on environmental conditions.  Studies show that the rate of
1,3-D degradation is proportional to temperature, and thus 1,3-D is expected to be more
persistent in colder environments. Limited data suggest that the degradates of 1,3-D, in particular
3-chloroacrylic acid, are more persistent than 1,3-D and the influence of temperature on

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persistence is less than for the parent. For this reason, the registrant is generating data on the
toxicity and environmental fate of the degradates. For this RED, the Agency has assumed that the
degradates' toxicity and exposure parameters are equal to the parent; this is considered a
conservative estimate.

       The results of the prospective studies and information developed by USGS demonstrate
that 1,3-D levels in ground water decrease with increasing distance from treated fields. The
NAWQA found no detections of 1,3-D in any of its 21 Phase 1 monitoring study units around the
country, suggesting that 1,3-D does not pose a widespread contamination risk to aquifers.
Rather, the Agency believes the highest risks to the environment are in localized areas close to
treated fields.  The label statement to prohibit use in areas similar to the Wisconsin study site (i.e.,
cold climates with shallow ground water and permeable soils) is expected to lessen the potential
for environmental risk as well as risks to human health.

       For ecological effects, the available acute toxicity data on the TGAI indicate that 1,3-D is
slightly toxic on an acute oral basis to small mammals, moderately toxic on an acute oral basis to
birds, moderately toxic to acutely toxic to freshwater fish and bees, and very highly toxic to
freshwater invertebrates. Toxicity testing has not been conducted on estuarine or marine
organisms.

       Because 1,3-D degradation appears to be related to temperature, organisms living in
cooler climates (where degradation is slower) would be at greater risk than those in warm
climates. Applications to cool climate crops may pose the greatest acute and chronic risks.
Alternatively, although use in Florida may present a substantial risk to freshwater and estuarine
organisms, the potential for chronic effects may be shortened because of the rapid degradation in
warm climates.

       1,3-D application methods (soil injection and subsurface drip irrigation) greatly reduce the
risk to terrestrial birds.  Since application is primarily to bare fields prior to planting, terrestrial
organisms could be at risk through three routes of exposure:  ingestion of contaminated soil,
ingestion of contaminated water or inhalation of 1,3-D vapors.

       Birds.  Soil residue levels found in field samples were used to estimate risk to birds.
Acute risk quotients did not exceed any LOG even at the maximum application rates.  No data are
available to conduct a chronic risk assessment. However, given the relatively short field
dissipation half-life, chronic exposure is not anticipated.

       Mammals. Using soil and air concentrations from field studies, acute risk quotients did
not exceed any LOG.  These results indicate the use of 1,3-D should not result in significant acute
mortality to mammalian species via dietary or inhalation exposure under any application scenario.
The chronic LOG was not exceeded based on reproductive effects data. It was exceeded slightly
in a rat feeding study, but given 1,3-D's relatively short dissipation half-life and one application
per year, EPA does not expect chronic effects.
                                            88

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       Aquatic Organisms.  Using GENEEC information, application rates equal evaluated (at
or above 177 Ibs. a.i. per acre) exceed the acute high risk LOC's for freshwater fish and
freshwater invertebrates. Using measured residues found in ditch water adjacent to treated fields
at 182 Ibs. ai/acre, the LOG for endangered species was exceeded.  Concentrations in four foot
deep ground water in Florida were higher than the LOG for aquatic invertebrates.  No data were
available to assess chronic risk.

       It should be noted again that the computer model GENEEC is a screening model designed
only to help determine if substantial risks are unlikely.  It should not be used to determine if
substantial risks are likely. The determination of whether risks actually exceed the LOC's depends
on data generated from higher-tier exposure and risk assessments and/or additional monitoring
information.

       Estuarine and Marine Organisms. No estuarine or marine toxicity data were required
for reregi strati on in the 1986 Registration Standard, and as such, no acute or chronic risk analysis
could be conducted.  The registrant is generating acute data for  estuarine and marine organisms
since  1,3-D use is expected to expand to these areas.

       Plants. No toxicity information for non-target plants has been submitted. Consequently,
no risk analysis has been conducted. However, 1,3-D is registered as a herbicide and has
phytotoxicity warnings and, therefore, is a candidate for both terrestrial and aquatic plant testing.

                     c.      Restricted  Use  Classification

       Based on 1,3-D's high acute inhalation toxicity, potential carcinogenicity and its use
patterns, the Agency is maintaining the Restricted Use classification for all 1,3-D products that
are currently so classified.

                     d.     Endangered Species Statement

       The Agency has developed a program  (the "Endangered Species Protection Program") to
identify pesticides which may cause adverse impacts on endangered and threatened species, and to
implement mitigation measures that will eliminate the adverse impacts.  At present, the program is
being implemented on an interim basis as  described in a Federal Register notice (54 FR 27984-
28008, July 3, 1989), and is providing information to pesticide users to help them protect these
species on a voluntary basis. As currently planned, the final program will call for label
modifications referring to required limitations on pesticide uses, typically as depicted in county-
specific bulletins or by other site-specific mechanism as specified by state partners. A final
program, which may be altered from the interim program, will be described in a future Federal
Register notice. The Agency is not imposing label modifications through this RED. Rather, any
requirements for product use modifications will occur in the future  under the Endangered Species
Protection Program.
                                            89

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                     e.     Labeling Rationale

       The Agency is maintaining its current label restrictions and is basing its reregi strati on
eligibility decision on these measures and other label measures that will be added as of
August 1, 1999.  There are on-going studies, reviews and data collection which are being
conducted to confirm the Agency's position that 1,3-D, when used as specified in this document,
does not pose unreasonable adverse effects to humans  or the environment. Should the results of
those confirmatory data provide information to change the Agency's current risk assessment and
position, EPA will consider further label changes to maintain the registration of products
containing 1,3-D.

                     (i)    Labeling Requirements for Handlers (Including Re-Entry)

       The 1992 Worker Protection Standard for Agricultural Pesticides (WPS) and changes to
1,3-D labels in 1992 and 1996 established worker protection requirements to be specified on the
label of all products that contain uses within the scope of the WPS.  Uses within the scope of the
WPS include all  commercial (non-homeowner) and research uses on farms, forests, nurseries and
greenhouses to produce agricultural plants (including food, feed and fiber plants, trees, turf grass,
flowers, shrubs, ornamentals and seedlings). Uses within the scope included not only uses on
plants but also uses on the soil or planting medium the plants are (or will be) grown in.

       The Personal Protective Equipment (PPE) requirements under the WPS, as well as the
process for complying with the WPS are found in PR notice 93-7. For products containing 1,3-D,
a supplement, entitled, "SupplementFour-D, Labeling Guidance for 1,3-Dichloropropene
Fumigant Products" was issued with specific working for all 1,3-D product labels.  A separate
supplement, "Supplement Four-E, Labeling guidance for 1,3-Dichloropropene Plus Chloropicrin
Fumigant Products" was also issued..  Some of the PPE requirements in the WPS were further
refined in 1995.  The requirements for 1,3-D handlers are specified below (note these are
requirements for 1,3-D only):

       Handlers Performing Direct Contact Tasks (e.g., includes equipment repair and
       calibration, fumigant transfers, clean-up of small spills) -
       - Coveralls over short-sleeved shirt and short pants,
       - Chemical-resistant gloves (barrier laminate (EVAL) or viton)
       - Chemical resistant footwear plus socks
       - Face-sealing goggles, unless full face respirator is worn
       - Chemical resistant headgear for overhead exposure
       - Chemical-resistant apron
       - Respirator with organic-vapor-removing cartridge or canister approved for pesticides

       Handlers in Enclosed Cabs
       - Coveralls
       - Shoes and socks
                                           90

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        - A half-face respirator with an organic-vapor-removing cartridge or canister approved for
        pesticides
        - A respirator is NOT required if occupants are within an enclosed cab equipped with a
        vapor-adsorptive filter (activated charcoal).  HOWEVER, PPE for direct handlers must be
        worn if applicator within cab leaves the cab and re-enters.

        Post Application/Re-entry Handlers in Treated Area within REI - Five Days after
        Application
        - Coveralls
        - Chemical-resistant gloves (barrier laminate (EVAL) or viton)
        - Chemical-resistant footwear and socks
        - Respirator with organic-vapor-removing cartridge or canister approved for pesticides

        Handlers Exposed to High Concentrations (e.g., clean-up of large spills)
        - Chemical resistant suit
        - Chemical resistant gloves (barrier laminate (EVAL) or viton)
        - Chemical-resistant footwear plus socks
        - Chemical-resistant headgear
        - Supplied air respirator

        The Agency is  retaining the WPS requirements, as well as all other PPE and engineering
controls which are as follows:

	Table 27.	Summary of 1,3-D Label Restrictions that Affect Worker Exposures	
   Regulatory Action
   (effective date)
Label Requirements
   Registration Standard
   (1986)
Precautionary Statements;  Cancer Hazard Warning; Classification
Change to Restricted Use Pesticide; Reentry increased to 72 Hours*;
Clothing for Applicators and Handlers (Coveralls*, Chemical-resistant
Gloves and Boots, Liquid-proof hat).	
   1992 Label Amendments
   (1992/1993)
Lowered Maximum rates; Deletion of Selected Use Sites; Revised
Respirator Requirements*; Closed Loading Requirements; Technology
to Minimize 1,3-D Spillage during Application, Improved Product
Stewardship Materials	
   Worker Protection Standard
   (August 1992
   see 57 FR 38102)
Coveralls over short-sleeved shirt and short pants; Chemical-resistant
gloves and footwear; Chemical-resistant Apron (for direct handlers).
   1995 Label Amendments
   (1996)
A Respirator Requirement for all 1,3-D handlers (except those in certain
closed cabs); Restricted Entry increased to 5 days; Soil moisture and
soil sealing requirements; Modified application techniques and Lower
                                      maximum use rates.
* - measures which were superceded or modified by subsequent label changes
                                               91

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                     (ii)    Labeling Requirements that Affect Residential Exposure
       There are no residential uses of 1,3-D.  However, the Agency has concerns for inhalation
risks to residents who live near 1,3-D treated fields, and an additional concern for residents who
obtain drinking water from private wells in the proximity of treated fields.

       Residential risks were not included in the 1986 Registration Standard. In 1990, California
suspended 1,3-D use permits based on unexpectedly high levels of 1,3-D in the atmosphere
following treatment.  EPA used the Special Review process to obtain additional data and risk
mitigation (through label amendments) to mitigate inhalation exposures.

       EPA is also retaining requirements for measures to mitigate risks from exposure through
ground water. The following table summarizes label statements which are required for 1,3-D
labels to protect residents who live near treated fields.
Table 28.
Measures to Reduce Risks to Residents who Live Near Treated Fields
                                              Label Measures
 Measures Designed to Reduce Inhalation Risk
                                300' No-treatment Buffer; Lowered
                                application rates; Loading Requirements;
                                Technology to Minimize 1,3-D Spillage
                                during Application, Soil moisture and soil
                                sealing requirements; Modified application
                                techniques
 Measures to Reduce Dietary Risk via
 Potential Ground Water Exposure
                                100' buffer between drinking water wells and
                                treated fields (as of 8/1/99); lowered
                                application rates, ground water advisory;
                                prohibition of use in certain states with
                                shallow ground water and vulnerable soils (as
                                of 8/1/99); prohibition in areas overlying karst
                                geology (as of 8/1/99)
                     (iii)   Other Labeling Requirements

       Because the end-use product Telone II is also reformulated into other products, EPA is
requiring that any product containing 1,3-D bear a label statement to require that all measures on
the Telone label are also required on any other product containing 1,3-D. This measure is
designed to cover all reformulated products, whether the 1,3-D source is Dow AgroScience's
Telone product or from some other producer or reformulator.
                                           92

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V.     ACTIONS REQUIRED OF REGISTRANTS
       A.    Amendments to Current 1,3-D Registrations

       This section specifies the data requirements and responses necessary for the reregistration
of products containing 1,3-D.

       B.    Requirements for 1,3-D Products

             1.     Additional Generic Data Requirements

       On September 30, 1998, Dow AgroSciences requested changes to the terms and
conditions of their 1,3-D registrations to include modified labels and study requirements (Roby,
1998).  All 1,3-D products must be relabeled by August 1, 1999 to include the amended labeling.

       In addition to the label changes, the registrant has agreed to conduct the following studies:

                    a.     Studies to be performed as a result of modified terms and
                          conditions of registration ~ Studies on 3-chloroacrylic acid
                          and 3-chloroallyl alcohol
Table 29 - Study on 3-chloroacrylic
acid and 2-chloroallyl alcohol
Acute oral-rat
Acute dermal toxicity - rabbit/rat
Primary eye irritation - rabbit
Primary dermal irritation
dermal sensitization
mutagenicity (Ames assay)
mouse micronucleus
pharmacokinetics^alance of
metabolism
mouse lymphoma
in vitro chromosomal aberration in
Chinese Hamster lung
developmental toxicology
subchronic 90-day feeding study
aquatic aerobic metabolism
OPP Guideline
Number
81-1
81-2
81-4
81-5
81-6
84-2A
84-2
85-1
84-2
84-2
83-3A
82-1A
162-4
Study Due Date
June 1, 1999
June 1, 1999
June 1, 1999
June 1, 1999
June 1, 1999
October 1, 1999
October 1, 1999
October 1, 2000
October 1, 1999
October 1, 1999
January 1, 2000
January 1, 2000
October 1, 1999
                                          93

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Table 29 - Study on 3-chloroacrylic
acid and 2-chloroallyl alcohol
adsorption/desorption
hydrolysis
vapor pressure
Henry's Law Constant
acute fish toxicity- rainbow trout
acute aquatic invertebrate toxicity-
Daphnia magna
Tier I and Tier II aquatic plant
OPP Guideline
Number
163-1
161-1
68-9
NA
72-1
72-2(a)
122-2/123-2
Study Due Date
October 1, 1999
October 1, 1999
October 1, 1999
October 1, 1999
June 1, 1999
June 1, 1999
June 1, 1999
b.     Studies to be performed as a result of modified terms and
       conditions of registration - 1,3-D
Table 30 - Study on 1,3-D
Freshwater fish early life stage -
rainbow trout
Freshwater aquatic invertebrate life
cycle - Daphnia magna
Estuarine/marine fish LC 50-
sheepshead minnow
Estuarine/marine invertebrate
LC50-mysid shrimp
Estuarine/marine invetebrate
LC50-eastern oyster
Tier I and Tier II aquatic plant
Seed germination and seedling
emergence
Vegetative vigor
Tier I and Tier II terrestrial plants
Aerobic aquatic metabolism
Guideline Number
72-4(a)
72-4(b)
72-3(a)
72-3(b)
72-3(b)
122-2/123-2
122-l(a)
122-l(b)
122-1 and 123-1
162-4
Due Date
October 1, 1999
October 1, 1999
June 1, 1999
June 1, 1999
June 1, 1999
June 1, 1999
October 1, 1999
October 1, 1999
October 1, 2000
October 1, 1999
                      94

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                    c.     Studies to be performed as a result of modified terms and
                           conditions of registration with tiered requirements - Run-off
                           Study and Studies on Ecotoxicity

       Dow AgroSciences will conduct a run-off study to assess whether run-off is a significant
pathway for movement of 1,3-D in the environment. If studies show that 1,3-D and/or its
degradates can enter surface water in unacceptably high amounts as a result of run-off, then the
battery of studies for 3-chloroacrylic acid and 3-chloroallyl alcohol for estuarine/marine animals
(sheepshead minnow, mysid shrimp, eastern oyster) will be required.

       In addition, EPA may require an avian acute oral study on the degradates pending the
results of the environmental fate studies on the degradates. As noted in section E.4.C., the
application method, of 1,3-D is not  expected to result in high exposures to birds.  If, however, the
environmental fate study results show that concentrations of concern may be present, then EPA
will require an acute avian oral  study.

                    d.     Product Chemistry Requirements

       Section 4(g)(2)(B) of FIFRA calls for the Agency to obtain any needed product-specific
data regarding the pesticide after a determination of eligibility has been made. Registrants must
review previous data submissions to ensure that they meet current EPA acceptance criteria and if
not, commit to conduct new studies.. If a registrant believes that previously submitted data meet
current testing standards, then study MRID numbers should be cited according to the instructions
in the Requirement Status and Registrants Response Form provided for each product. The
product-specific data requirements are listed in Appendix D, "Product Specific Data Call-in."

             2.     Formulation Changes

       There are no requirements for formulation changes to products containing  1,3-D at this
time.

             3.     Time frames

       Revised labeling is scheduled to be borne by all products by August 1, 1999.  The time
frames for the additional studies are listed in the Tables 29  and 30 above.

             4.     Labeling Requirements for End-Use Products

       All end-use products should have clear, concise and complete labeling instructions.
Proper labels can improve reader understanding, thereby reducing misuse and the potential for
incidents.  Towards this end, the Agency is requiring the following:
                                           95

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                           Table 31: Summary of Required Labeling Changes for 1,3-Dichloropropene
      Description
                                Required Labeling
  Placement on
      Label
                                     All Products Containing the Active Ingredient 1,3-Dichloropropene
This statement must be
added to 1,3-D labels to
allow reformulation of
the product for a
specific use or all
additional uses
supported by a
formulator or user
group
On labels as of August
1, 1999
FORMULATOR USE OF 1,3-DICHLOROPROPENE: Labeling for end use products
containing 1,3-Dichloropropene that are prepared and sold by formulators must comply with
all labeling for precautionary statements, use precautions, environmental hazards, handling
and protective equipment requirements, maximum application rates, and other exposure
mitigation measures specified in this product labeling.
"Do not apply within 100 feet of any well used for potable water."

"Do not apply in areas overlying karst geology."

"The following restriction applies only in North Dakota, South Dakota, Wisconsin,
Minnesota, New York, Maine, New Hampshire, Vermont, Massachusetts, Utah and
Montana:

       Where ground water aquifers exist at a depth of 50 feet or less from the surface, do
       not apply this product where soils are Hydrologic Group A."
General Use
Precautions in
Directions for Use
                                                              96

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       C.    Existing Stocks

       The existing stocks time frames have been set for products containing 1,3-D. The label changes
which are referred to above in Table 32 are to be on all products which are sold or distributed by Dow
AgroSciences or any reformulator by August 1, 1999.
                                              97

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98

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VI.  APPENDICES
       99

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                Appendix A - Table of Use Patterns Subject to this RED

Appendix A is 23 pages long and is not being included in this RED. Copies of Appendix A are
available upon request per the instructions in Appendix E.
                                         100

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                               GUIDE TO APPENDIX B

  Appendix B contains listings of data requirements which support the reregi strati on for active
ingredients within the case 0328 covered by this Reregi strati on Eligibility Decision Document. It
contains generic data requirements that apply to 0328 in all products, including data requirements for
which a "typical formulation" is the test substance.

  The data table is organized in the following format:

  1.  Data Requirement (Column 1). The data requirements are listed in the order in which they
appear in 40 CFR Part  158.  The reference numbers  accompanying each test refer to the test
protocols set in the Pesticide Assessment Guidelines, which are available from the National Technical
Information Service, 5285 Port Royal Road,  Springfield, VA 22161 (703) 487-4650.

  2. Use Pattern (Column 2). This column indicates the use patterns for which the data requirements
apply.  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
                      J      Forestry
                      K      Residential
                      L      Indoor food
                      M     Indoor non-food
                      N      Indoor medical
                      O      Indoor residential

  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 MRID number has been assigned. Refer to the Bibliography
appendix for a complete  citation of the study.
                                           101

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102

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                 APPENDIX B

Data Supporting Guideline Requirements for the Reregistration of
                  1,3-Dichloropropene
REQUIREMENT
USE PATTERN
CITATION(S)
PRODUCT CHEMISTRY
61-1
61-2A
61-2B
62-1
62-2
62-3
63-2
63-3
63-4
63-5
63-6
63-7
Chemical Identity
Start. Mat. & Mnfg. Process
Formation of Impurities
Preliminary Analysis
Certification of limits
Analytical Method
Color
Physical State
Odor
Melting Point
Boiling Point
Density
all
all
all
all
all
all
all
all
all
all
all
all
40163301
40163301
40163301
40398501
40504201, 40398501
40504201, 40398501
40483801, 40483802, 40483803, 40483804,
40483805, 40483806,40163301
40483801, 40483802, 40483803, 40483804,
40483805, 40483806,40163301
40163301, 40483801, 40483802, 40483803,
40483804, 40483805, 40483806
40163301, 40483801, 40483802, 40483803,
40483804, 40483805, 40483806
40163301, 40163301, 40483801, 404838702,
40483803, 40483804, 40483805, 40483806
40163301, 40163301, 40483801, 40483802,
40483803, 40483804, 40483805, 40483806
                         103

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Data Supporting Guideline Requirements for the Reregistration of
                     1,3-Dichloropropene
REQUIREMENT
63-8
63-9
63-10
63-11
63-12
63-13
63-17
Solubility
Vapor Pressure
Dissociation Constant
Octanol/Water Partition
pH
Stability
Storage stability
USE PATTERN
all
all
all
all
all
all
all
CITATION(S)
40483801, 40483802, 40483803, 40483804,
40483805, 40483806
40483801, 40483802, 40483803, 40483804,
40483805, 40483806
40483801, 40483802, 40483803, 40483804,
40483805, 40483806
40483801, 40483802, 40483803, 40483804,
40483805, 40483806
40483801, 40483802, 40483803, 40483804,
40483805, 40483806
40483804, 40483801, 40483802, 40483803,
40483805, 40483806
00162145
ECOLOGICAL EFFECTS
71-1A
71-1B
71-2A
71-2B
71-3
71-5B
72-1A
72-1B
Acute Avian Oral - Quail/Duck
Acute Avian Oral - Quail/Duck TEP
Avian Dietary - Quail
Avian Dietary - Duck
Wild Mammal Toxicity
Actual Field Study
Fish Toxicity Bluegill
Fish Toxicity Bluegill - TEP
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
261149
waived
00120908
STEOD103
waived
waived
STOD102
waived
                             104

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                Data Supporting Guideline Requirements for the Reregistration of
                                     1,3-Dichloropropene
REQUIREMENT
72-1C
72-1D
72-2A
72-2B
72-3A
72-3B
72-3C
72-4A
122-1A
122-1B
122-2
123-1A
123-1B
123-2
124-1
124-2
141-1
141-2
Fish Toxicity Rainbow Trout
Fish Toxicity Rainbow Trout- TEP
Invertebrate Toxicity
Invertebrate Toxicity - TEP
Estuarine/Marine Toxicity - Fish
Estuarine/Marine Toxicity -
Mollusk
Estuarine/Marine Toxicity - Shrimp
Early Life Stage Fish
Seed Germination/Seedling
Emergence
Vegetative Vigor
Aquatic Plant Growth
Seed Germination/Seedling
Emergence
Vegetative Vigor
Aquatic Plant Growth
Terrestrial Field
Aquatic Field
Honey Bee Acute Contact
Honey Bee Residue on Foliage
USE PATTERN
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
A,B,C
CITATION(S)
00039692
waived
40098001
waived
see footnote
see footnote
see footnote
see footnote
see footnote
see footnote
see footnote
see footnote
see footnote
see footnote
waived
see footnote
00028772
000188423
TOXICOLOGY
                                             105

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                   Data Supporting Guideline Requirements for the Reregistration of
                  	1,3-Dichloropropene	
REQUIREMENT
USE PATTERN
CITATION(S)
81-1        Acute Oral Toxicity - Rat
81-2        Acute Dermal Toxicity - Rabbit/Rat
81-3        Acute Inhalation Toxicity - Rat
81-4        Primary Eye Irritation - Rabbit
81-5        Primary Dermal Irritation - Rabbit
81-6        Dermal Sensitization - Guinea Pig
82-1A      90-Day Feeding - Rodent
82-1B      90-Day Feeding - Non-rodent
82-2        21-Day Dermal - Rabbit/Rat
82-4        90-Day Inhalation - Rat
83-1A      Chronic Feeding Toxicity - Rodent
83-1B      Chronic Feeding Toxicity -
           Non-Rodent
83-2A      Oncogenicity - Rat
83-2B      Oncogenicity - Mouse
83-2B      Oncogenicity - Mouse
83-3A      Developmental Toxicity - Rat
83-3B      Developmental Toxicity - Rabbit
83-4        2-Generation Reproduction - Rat
84-2A      Gene Mutation (Ames Test)
                  40220901
                  40220902
                  40220903
                  40220904
                  40220905
                  40220906
                  42954801, 42954802
                  43763501
                  waived
                  00039685
                  40312201, 40312301
                  42922301, 42441001

                  434653501, 40312201
                  40312301
                  40312301
                  00152848
                  00152848
                  40835301
                  44302801
                                                    106

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                  Data Supporting Guideline Requirements for the Reregistration of
                  	1,3-Dichloropropene	
REQUIREMENT
USE PATTERN
CITATION(S)
84-2B      Structural Chromosomal
           Aberration
85-1        General Metabolism
OCCUPATIONAL/RESIDENTIAL EXPOSURE
133-3      Dermal Passive Dosimetry Exposure
133-4      Inhalation Passive Dosimetry
           Exposure
ENVIRONMENTAL FATE
161-1      Hydrolysis
161-4      Photodegradation
162-1      Aerobic Soil Metabolism
162-2      Anaerobic Soil Metabolism
162-3      Anaerobic Aquatic Metabolism
162-4      Aerobic Aquatic Metabolism
163-1      Leaching/Adsorption/Desorption
163-3      Volatility - Field
164-1      Terrestrial Field Dissipation
164-2      Aquatic Field Dissipation
164-5      Long Term Soil Dissipation
165-1      Confined Rotational Crop
165-2      Field Rotational Crop
                  00259101

                  40959801, 161151

                  waived
                  waived
                  00158442, 262730
                  40330101
                  42642301
                  40025901
                  waived
                  see footnote
                  42868501, 425155501, 40538901
                  42845601, 42845602, 42545101, 42774201
                  41385701, 40155501
                  waived
                  waived
                  43140201
                  waived
                                                   107

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                   Data Supporting Guideline Requirements for the Reregistration of
                  	1,3-Dichloropropene	
REQUIREMENT
USE PATTERN
CITATION(S)
166-1       Ground Water - Small Prospective

166-2       Ground Water - Small
           Retrospective
166-3       Ground Water - Irrigated
           Retrospective
RESIDUE CHEMISTRY
171-4A     Nature of Residue - Plants
171-4B     Nature of Residue - Livestock
171-4C     Residue Analytical Method - Plants
171-4D     Residue Analytical Method -
           Animal
171-4E     Storage Stability
171-4F     Magnitude of Residues - Potable
           H2O
171-4G     Magnitude of Residues in Fish
171-4H     Magnitude of Residues - Irrigated
           Crop
171-41     Magnitude of Residues - Food
           Handling
171-4J     Magnitude of Residues-
           Meat/Milk/Poultry/Egg
171-4K     Crop Field Trials
                  44227701, 44318701, 44258901, 44226901,
                  44270201, 44005201
                  43428301, 42914301, 42452901, 42536401,
                  42354201
                  inapplicable
                  42845401, 42894201, 42784201, 42760801,
                  42709401
                  43083301, 42946401
                  waived
                  waived

                  42354201
                  waived

                  waived
                  waived

                  waived

                  waived

                  waived
                                                    108

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                     Data Supporting Guideline Requirements for the Reregistration of
                                              1,3-Dichloropropene
REQUIREMENT USE PATTERN CITATION(S)
171-4L
171-5
171-6
171-7
171-13
Processed Food
Reduction of Residues
Proposed Tolerance
Support for Tolerance
Analtyical Reference Standard
waived
waived
waived
waived
waived
Note- Requirements for these studies were not included in the 1986 Registration Standard, however, based on expected increases in
usage to sensitive environments, the registrant is conducting these studies, which are to be submitted by October 1, 1999 (except for
122-1 and 123-1, which are due October 1, 2000).
                                                       109

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110

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                                GUIDE TO APPENDIX C

1.        CONTENTS OF BIBLIOGRAPHY.  This bibliography contains citations of all studies
         considered relevant by EPA in arriving at the positions and conclusions stated elsewhere
         in the Reregi strati on 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, are 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 also attempted 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 whenever a 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
         identifying 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 standard of the American National Standards Institute
         (ANSI), expanded to provide for certain special needs.

         a.      Author. Whenever  the author could confidently be identified, 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 the author.
                When  no author or laboratory could be identified, the Agency has shown the first
                submitter as the author.

         b.      Document date.  The date of the study is taken directly from the document.
                When  the date is followed by a question mark, the bibliographer has deduced the
                date from the evidence contained in the document. When the date appears as
                                           111

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       (19??), the Agency was unable to determine or estimate the date of the
       document.

c.      Title.  In some cases, it has been necessary for the 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.  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," which stands 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.
                                  112

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                                BIBLIOGRAPHY
MRID
CITATION
Table 1 - Citations with MRID Numbers Assigned

00030385      Glas, R.D. (1979) Determination of Residues of Cisand Trans
              l,3Dichloropropene in Plant Materials: ACR 79.15.  Method dated Nov 30,
              1979. (Unpublished study received Feb 7, 1980 under 464511; submitted by
              Dow Chemical U.S.A., Midland, Mich.; CDL: 241761-B)

00033255      McKinney, W.J.; Wendt, M.B.; Abbott, R.; et al. (1978) [Residues in
              Sugarbeets]: TTR-24-355-76. (Unpublished study including TTR24-355-76-B,
              received Jun 25, 1980 under 464-511; prepared by Shell Development Co.,
              submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:242726-A)

00033256      McKinney, W.J.; Wendt, M.B.; Fries, F.A.; et al. (1978) [Residues in Cabbage]:
              TIR-24-160-78-A. (Unpublished study including TIR24-195-78B and
              TIR-24-195-78, received Jun 25, 1980 under 464511; prepared by Shell
              Development Co., submitted by Dow Chemical U.S.A., Midland, Mich.;
              CDL:242726-B)

00033257      McKinney, W.J.; Wendt, M.B. (1978) [Residues in Potatoes]: TTR-24172-78-A.
              (Unpublished study including TTR-24-172-78-B, received Jun 25, 1980 under
              464-511; prepared by Shell Development Co., submitted by Dow Chemical
              U.S.A., Midland, Mich.; CDL: 242726-C)

00033258      McKinney, W.J.; Fries, F.A.; Wendt, M.B.; et al. (1978) [Residues in
              Cauliflower]: TTR-24-180-78. (Unpublished study including TIR-24-180-78-B,
              received Jun 25, 1980 under 464-511; prepared by Shell Development Co.,
              submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:242726-D)

00033259      McKinney, W.J.; Fries, F.A.; Wendt, M.B.; et al. (1978) [Residues in Lettuce]:
              TIR-24-191-78A.  (Unpublished study including TTR24-191-78-B,
              TIR-24-192-78A and TIR-24-192-78-B, received Jun 25, 1980 under 464-511;
              prepared by Shell Development Co., submitted by Dow Chemical U.S.A.,
              Midland, Mich.; CDL:242726-E)

00033260      McKinney, W.J.; Fries, F.A.; Bierman, B.; et al. (1979) [Residues in
              Watermelon]: TTR-24-227-78B.  (Unpublished study including TIR-24-227-78,
              TIR-24-244-78-B and TIR-24-244-78, received Jun 25, 1980 under 464-511;
                                        113

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                                BIBLIOGRAPHY
MRID
CITATION
              prepared by Shell Development Co. and others, submitted by Dow Chemical
              U.S.A., Midland, Mich.; CDL: 242726-F)

00033261      McKinney, W.J.; Brown, L.J.; Doern, B.L.; et al. (1979) [Residues in Various
              Crops]: TIR-24-642-78. (Unpublished study including TIR-24-614-79, received
              Jun 25, 1980 under 464-511; prepared by Shell Development Co.,  submitted by
              Dow Chemical U.S.A., Midland, Mich.; CDL:242726-G)

00033262      Dutson, N.J.; Seager, S.V.; Wallace, E.G.;  et al. (1977) Residues of the Major
              Components of D-D and Primary Metabolites in Lettuce from Germany: Group
              Research Report BLGR.0024.77. (Unpublished study received Jun 25, 1980
              under 464-511; prepared by Shell Research, Ltd., submitted by Dow Chemical
              U.S.A., Midland, Mich.; CDL:242726-H)

00033263      Bosio, P.G.; Granier, R. (1977) Residues of D-D in Potatoes from
              France-1976/77 Trials: Group Research Report BEGR.0086.77. (Unpublished
              study received Jun 25, 1980 under 464-511; prepared by Shell Chemie,
              submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:242726-I)

00033264      Sherren, A.J.; Murray, S.M.; Wallace, E.G.; et al. (1978) Residues of the Major
              Components of D-D and Primary Metabolites in Pineapples from South Africa:
              Group Research Report BLGR.0071.78.  (Unpublished study received Jun 25,
              1980 under 464-511; prepared by Shell Research, Ltd., submitted by Dow
              Chemical U.S.A., Midland, Mich.; CDL:242726-J)1

00036894      Osborne, W.W. (1974) Prevent/limit pod rod with two-phase chemical control.
              Peanut Farmer 10(4): 12.  (Also~In~unpublished submission received Sep 13,
              1976 under 400-129; submitted by Uniroyal Chemical, Bethany, Conn.;
              CDL:225604-H)

00039680      Dow Chemical U.S.A. (1980) [Metabolism, Mating Behavior, Fertility and
              Toxicity in Male and Female Rats].  Summary of studies 099515-R and
              099515-S. (Unpublished study received  Jul 22, 1980 under 464-EX-63;
              CDL:099515-G)

00039683      Toyoshima, S.; Sato, R.; Sato, S. (1978)  The Acute Toxicity Test  on Telone II
              in Mice.  (Unpublished study received Jul 22, 1980 under 464-EX-63; prepared
              by Keio Univ., Drug Chemistry Institute, Chemotherapy Div. and Japan
                                        114

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                                BIBLIOGRAPHY
MRID
CITATION
              Experimental Medical Research Institute Co., Ltd., submitted by Dow Chemical
              U.S.A., Midland, Mich.; CDL:099515-J)

00039685      Coate, W.B.; Keenan, D.L.; Hardy, R.J.; et al. (1978) Final Report: TeloneA(R)4
              II (Production Grade): Project No. 174-126. (Unpublished study received Jul
              22, 1980 under 464-EX-63; prepared by Hazleton Laboratories America, Inc.,
              submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:099515-L)

00039688      Sudo, S.; Nakazawa, M.; Nakazono, M.; et al. (1978) The Mutagenicity Test on
              1,3-Dichloropropene in Bacteria Test System: Project No. NRI-78-2819.
              (Unpublished study received Jul 22, 1980 under 464-EX-63; prepared by
              Nomura Sogo Research Institute,  submitted by Dow Chemical U.S.A., Midland,
              Mich.;CDL:099515-P)

00039692      Bentley, R.E. (1975) Acute Toxicity of M-3993 to Bluegill (|i~Lepomis
              macrochirus~|i) and Rainbow Trout (|i~Salmo gaird|i~neri~|i).  (Unpublished
              study received Jul 22, 1980 under 464EX-63; prepared by Bionomics, EG&G,
              submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:099515-T)

00039693      Dow Chemical U.S.A. (19??) Summary of Residue Analyses of
              1,3-Dichloropropenes in Crops Treated Post-plant with Telone II. (Unpublished
              study received Jul 22, 1980 under 464-EX-63; CDL: 099515-W)

00039694      Glas, R.D. (1980) Determination of Resudies [sic] of Cisand
              Trans 1,3-Dichloropropene in Fruit: ACR 80.9. Method dated Jul 9, 1980.
              (Unpublished study received Jul 22, 1980 under 464-EX63; submitted by Dow
              Chemical U.S.A., Midland, Mich.; CDL: 099515-X)

00039695      Glas, R.D. (1980) Determination of Residues of Cisand TransChloroallyl
              Alcohols in Fruit by Gas Chromatography Using and Electrolytic Conductivity
              Detector: ACR 80.10.  Method dated Jul 9, 1980. (Unpublished study received
              Jul 22, 1980 under 464-EX63; submitted by Dow Chemical U.S.A., Midland,
              Mich.; CDL: 099515-Y)

00039696      Lembright, H.W.; Hart, W.; Rough, D. (1980) Residues of
              1,3-Dichloropropenes and Chloroallyl Alcohols in Green Almonds Grown in Soil
              Fumigated with Telone II Soil Fumigant.  (Unpublished study received Jul 22,
                                         115

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                                BIBLIOGRAPHY
MRID
CITATION
               1980 under 464-EX-63; submitted by Dow Chemical U.S.A., Midland, Mich.;
               CDL:099515-Z)

00039697       Glas, R.D.; Turner, G.O. (1980) Analysis of Oranges and Peaches for Residues
               of Dichloropropenes and Chloroallyl Alcohols after Postplant Application of
               Tel one II Soil Fumigant: GH-C  1312. (Unpublished study received Jul 22, 1980
               under 464-EX-63; submitted by  Dow Chemical U.S.A., Midland, Mich.;
               CDL:099515-AA)

00039698       Glas, R.D.; VanGundy, S. (1980) Analysis of Peel, Pulp, Leaves and Soil from
               an Orange Grove for Residues of Dichloropropenes and Chloroallyl Alcohols
               after Post Plant Injection of Telone II Soil Fumigant: GH-C 1308.  (Unpublished
               study received Jul 22, 1980 under 464-EX-63; prepared in cooperation with
               Univ. of California-Riverside, submitted by Dow Chemical U.S.A., Midland,
               Mich.;CDL:099515-AB)

00039699       Glas, R.D.; Turner, G.O. (1980) Analysis of Grapes for Residues of
               Dichloropropenes and Chloroallyl Alcohols after Postplant Application of Telone
               II Soil Fumigant: GH-C 1281. (Unpublished study received Jul 22, 1980 under
               464-EX-63; submitted by Dow Chemical U.S.A., Midland, Mich.;
               CDL:099515-AC)

00039700       Lembright, H.  (1980) Residues of 1,3-Dichloropropenes and Chloroallyl
               Alcohols in Grapes Grown in Soil Fumigated with Telone II Soil Fumigant.
               (Unpublished study received Jul 22, 1980 under 464-EX-63; submitted by Dow
               Chemical U.S.A., Midland, Mich.; CDL:099515-AD)

00040721       Bauriedel, W.R.; Craig, L.F. (1973) A Study of the Residue Present in Sugar
               Beets Grown in Soil Treated with 14C-Labeled~Cis~|iand
               |i~Trans~|i-l,3-Dichloropropene. (Unpublished study received Jul 22, 1980
               under 464-EX-63; submitted by  Dow Chemical U.S.A., Midland, Mich.;
               CDL:099516-L)

00040722       Berry, D.L. (1973) Absorption, Translocation and Metabolism of
               l,3Dichloropropene in Selected  Plants.  Doctoral dissertation, Utah State Univ.
               (Unpublished study received Jul 22, 1980 under 464EX-64; submitted by Dow
               Chemical U.S.A., Midland, Mich.; CDL: 099516-M)
                                         116

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                                BIBLIOGRAPHY
MRID
CITATION
00109291       Shell Development Co. (1981) Residue Determination of the Z and E Isomers of
               3-chloroallyl Alcohol (CAA) in Agricultural Commodities, Soils, and Water:
               Capillary GLC/Hall Electrolytic Conductivity Detector Method: MMS-R-506-2.
               (Unpublished study received Jan 15, 1982 under 201-253; CDL:246671-A)

00109420       Shell Development Co. (1981) Residue Determination of 1,2-dichloropropane
               and the Z and E Isomers of 1,3-dichloropropene in Agricultural Commodities,
               Soil and Water: Capillary GLC/Hall Electrolytic Conductivity Detector Method:
               MMS-R-505-2. (Unpublished study received Jan 15, 1982 under 201-253;
               CDL: 246672-A)

00109672       Shell Chemical Co. (1978) D-D  Crop Residue and Analytic Methods: Volume
               III. (Compilation; unpublished study received Aug 30, 1978 under 201-119;
               CDL:235253-A)

00115214       Dow Chemical U.S.A. (1982) Residue Data, Where Pertinent, on (a) Food or
               Feed Commodities; (b) Non-food Crops Such as Tobacco; and (c) Foliage or
               Other Sites Which May Relate to Worker Hazard or Adverse Effects on the
               Environment. Include a Description of the Analytical Method(s) Used and a
               Summary of the Data. (Compilation; unpublished study received Sep 22, 1982
               under 464-EX63; CDL:248406-B)

00117045       Dow Chemical U.S.A. (1982) [Telone II Chemistry Data].  (Compilation;
               unpublished study received Sep  22, 1982 under 464-EX-63; CDL:248416-A)

00117050       Meikle, R.; Youngson, C. (1980) The Hydrolysis Rates of cisand
               trans-l,3-Dichloropropene, 1,2-Dichloropropane and 2,3-Dichloropropene in
               Dilute Aqueous Solution: Report GS-1659.  Final rept. (Unpublished study
               received Sep 22, 1982 under 464-EX-63; submitted by Dow Chemical U.S.A.,
               Midland, MI; CDL:248417-F)

00118938       Fink, R.; Beavers, J.; Joiner, G.; et al. (1982) Acute Oral LD50-Bobwhite Quail:
               Telone II Soil Fumigant: Project No. 103-207. Final rept. (Unpublished study
               received Sep 22, 1982 under 464-EX-63; prepared by Wildlife International Ltd.,
               submitted by Dow Chemical U.S.A., Midland, MI; CDL:248415-C)
                                         117

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                                 BIBLIOGRAPHY
MRID
CITATION
00144715       John, 1; Kloes, P.; Calhoun, L.; et al. (1983) Telone II: Inhalation Teratology
               Study in Fischer 344 Rats and New Zealand White Rabbits: Report No. HET
               M-003993-006.  Unpublished study prepared by Dow Chemical USA.  37 p.

00146461       Stott, W.; Young, 1; Calhoun, L.; et al. (1984) Telone II Soil Fumigant: A
               13-week Inhalation Study in Rats and Mice. Unpublished study prepared by
               Dow Chemical U.S.A. 65 p.

00146467       Mendrala, A. (1985) Evaluation of Telone II in the Rat Hepatocyte Unscheduled
               DNA Synthesis Assay. Unpublished study by Dow Chemical U.S.A. 14 p.

00146469       US of Public Health Service (1985) Toxicology and Carcinogenesis Studies of
               Telone II  (Technical-grade 1,3-Dichloropropene CAS No. 542-75-6 Containing
               1.0% Epichlorohydrin as a Stabilizer) in F344/N Rats and B6C3F1 Mice
               (Gavage Studies): Nffl Publication No. 85-2525. US Government Printing
               Office.  153 p.

00152848       John, J.; Kloes, P.; Calhoun, L.; et al. (1983) Telone II: Inhalation Teratology
               Study in Fischer 344 Rats and New Zealand White Rabbits: Appendix Tables.
               Unpublished study prepared by Dow Chemical U.S.A.  50 p.

00155846       Dietz, F.;  Hermann, E.; Kastl, E. (1985) 1,3-Dichloropropene:
               Pharmacokinetics, Effect on Tissue Non-protein Sulfhydryls, and
               Macromolecular Binding in Fischer-344 Rats and B6C3F1 Mice following Oral
               Administration.  Unpublished study prepared by Dow Chemical U.S.A. 50 p.

00158442       McCall, P. (1986) Hydrolysis of 1,3-Dichloropropene in Dilute Aqueous
               Solution: GHC-1812. Unpublished study by Dow Chemical U.S.A. 17 p.

00159679       Mendrala, A. (1986) The Evaluation of Telone II Soil Fumigant in the Chinese
               Hamster Ovary Cell/Hypoxanthine (Guanine) Phosphoribosyl Transferase
               (CHO/HGPRT) Forward Mutation Assay.  Unpublished study prepared by Dow
               Chemical  U.S.A. 21 P.

00163030       Loria, R.;  Eplee, R.; Baier, J.; et al. (1986) Efficacy of sweepshank fumigation
               with 1,3-dichloropropene against Pratylenchus penetrants and subsequent
               ground water contamination. Plant Disease 70(l):42-45.
                                         118

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                                BIBLIOGRAPHY
MRID
                                CITATION
00163031      Kotcon, 1; Loria, R. (1986) Fall Fumigation of Potato with
              1,3-dichloropropene: Efficacy against Pratylenchus crenatus, Yield Response,
              and Potential for Groundwater Contamination. Unpublished study prepared by
              Cornell Univ., Long Island Horticultural Research Lab. 14 p.
               Smith, S.; Kelly, I. (1986) Preliminary Report: MITC Derived Residues in
               Tomatoes from Fumigated Soil: Study No. 73D: Report No. METAB/86/29.
               Unpublished study prepared by Schering Agrochemical Limited.  17 p.

               McCall, P. (1986) Anaerobic Soil Degradation of 1, 3-Dichloropropene: Project
               ID; Protocol No. 59-84. Unpublished study prepared by Dow Chemical U.S.A.
               45 p.

               Wichman, K. (1987) Product Chemistry: Tel one II Soil Fumigant. Unpublished
               compilation prepared by Dow Chemical U.S.A. 30 p.

               Jeffrey, M.; Battjes, J.; Lamax, L. (1987) Tel one II Soil Fumigant: Acute Oral
               Toxicity  Study in Fischer 344 Rats: Laboratory Project ID: HET
               M-003993-017A. Unpublished study prepared by Dow Chemical Co.  29 p.

               Jeffrey, M.; Schuetz, D.; Lomax, L. (1987) Telone II Soil Fumigant: Acute
               Dermal Toxicity Study in New Zealand White Rabbits: Laboratory Project ID:
               HETM-003993-017D. Unpublished study prepared by Dow Chemical Co. 25
               P-
40220903       Streeter, C.; Battjes, J.; Lomax, L. (1987) Telone II Soil Fumigant: An Acute
               Vapor Inhalation Study in Fischer 344 Rats: Laboratory Project ID: HET
               M-003993-018. Unpublished study prepared by Dow Chemical Co. 33 p.

40220904       Jeffrey, M. (1987) Telone II Soil Fumigant: Primary Eye Irritation Study in New
               Zealand White Rabbits: Laboratory Project ID: HET M-003993-017C.
               Unpublished study prepared by Dow Chemical Co. 9 p.

40220905       Jeffrey, M. (1987) Telone II Soil Fumigant: Primary Dermal Irritation Study in
               New Zealand White Rabbits: Laboratory Project ID:  HET M-003993-017B.
               Unpublished study prepared by Dow Chemical Co. 9 p.
00164143
40025901
40163301
40220901
40220902
                                         119

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                                 BIBLIOGRAPHY
MRID
CITATION
40220906      Jeffrey, M. (1987) Tel one II Soil Fumigant: Dermal Sensitization Potential in the
               Hartley Albino Guinea Pig: Laboratory Project ID: HET M-003993-017E.
               Unpublished study prepared by Dow Chemical Co. 10 p.

40312201      Lomax, L.; Calhoun, L.; Stott, W.; et al. (1987) Tel one II Soil Fumigant: 2-Year
               Inhalation Chronic Toxicity-Oncogenicity Study in Rats: Laboratory Project
               Study ID: M-003993-009R. Unpublished study prepared by Dow Chemical Co.
               739 p.

40312300      Dow Chemical Co. (1987) Submission of Toxicity Data to Support the
               Reregi strati on of Telone II Soil Fumigant Containing 1,3-dichloropropene as
               Active Ingredient. Transmittal of one study.

40312401      Breslin, W.; Kirk, H.; Streeter, C.; et al. (1987) Telone II Soil Fumigant:
               Two-generation Inhalation Reproduction Study in Fischer 344 Rats: Lab. Proj.
               Study ID M-003993-015. Unpublished study prepared by The Dow Chemical
               Co. 953 p.

40390101      Fontaine, D.; Teeter, D.  (1987) Vapor-phase Photodegradation of
               1,3-Dichloropropene: Laboratory Project ID: GHC-1956. Unpublished study
               prepared by Dow Chemical U.S.A. in cooperation with Analytical Bio-Chemistry
               Laboratories, Inc.  25 p.

40398501      Wichman, K. (1987) Product Chemistry: Telone II Soil Fumigant: Lab. Prtoj. ID
               PC-13D-102287.  Unpublished study prepared by Agricultural Chemistry
               Laboratories.  16 p.

40403301      Oliver, G.; Bjerke, E.; O'Melia, F. (1986) Field Dissipation Study of Telone II
               Soil Fumigant: (Supplementary Information): Laboratory Project ID: GH-C
               1817. Unpublished study prepared by Dow Chemical U.S.A. 21 p.

40483801      Walbroehl, Y. (1987) Determination of Water Solubility  of cis-1,
               3-Dichlororpropane: Project ID: AL 87-70906.  Unpublished study prepared by
               Analytical Laboratories.  13 p.

40483802      Walbroehl, Y. (1987) Determination of Water Solubility  of trans-1,
               3-Dichlororpropene: Project ID: AL 87-70907.  Unpublished study prepared by
               Dow Chemical USA. 13 p.
                                         120

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                                 BIBLIOGRAPHY
MRID
CITATION
40483803       Karris, G.; Downey, J. (1987) Vapor Pressure of cis-l,3-Dichloro-lpropene:
               Project ID: ML-AL 87-40207. Unpublished study prepared by Dow Chemical
               Co. 7 p.

40483804       Karris, G.; Downey, J. (1987) Vapor Pressure of trans-l,3-Dichlorol-propene:
               Project ID: ML-AL 87-40208. Unpublished study prepared by Dow Chemical
               Co. 7 p.

40483 805       Walbroehl, Y. (1987) Determination of the Octanol/Water Partition Coefficient
               of cis-l,3-Dichloropropene: Project ID: AL 87-70908. Unpublished study
               prepared by Dow Chemical USA. 20 p.

40483 806       Walbroehl, Y. (1987) Determination of the Octanol/Water Partition Coefficient
               of trans-l,3-Dichloropropene: Project ID: AL 87-70909.  Unpublished study
               prepared by Dow Chemical USA. 20 p .

40504201       The Dow Chemical Co. (1988) Analytical Method: Telone II Soil Fumigant:
               Laboratory Project ID: DOWM 100368.  Unpublished study. 19 p.

40571801       Bauriedel, W.; Miller, J. (1988) A Metabolism Study of Lettuce and Spinach
               Grown in Soil Treated with [Carbon 14]-l,3-dichloropropenes: Project ID:
               GH-C 2031.  Unpublished study prepared by Dow Chemical U.S.A.  59 p.

40571802       Bauriedel, W.; Miller, J. (1988) A Metabolism Study of Soybeans Grown in Soil
               Treated with  [Carbon 14]-l,3-dichloropropenes: Project ID: GH-C 2032.
               Unpublished  study prepared by Dow Chemical U.S.A. 69 p.

40835301       Breslin, W.; Kirk, H.; Streeter, C.; et al. (1987) Telone II Soil Fumigant:
               Two-Generation Inhalation Reproduction Study in Fischer 344 Rats
               (Supplementary Information): Project Study ID: M-003993-015.  Unpublished
               study prepared by Dow Chemical Co. 14 p.

40855501       Oliver, G.; Bjerke, E.; Woodburn, K.; et al. (1988) Field Dissipation and
               Leaching Study for Telone II Soil Fumigant: Project ID: GH-C 2111.
               Unpublished  study prepared by Dow Chemical U.S.A. 144 p.

40959801       Waechter, J.;  Kastl, P. (1988) 1,3-Dichloropropene: Pharmacokinetics and
               Metabolism in Fischer 344  Rats following Repeated Oral Administration:
                                         121

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                                BIBLIOGRAPHY
MRID
CITATION
               Laboratory Project Study ID: K-6409-(13). Unpublished study prepared by The
               Dow Chemical Co. 65 p.

41055701       Moye, H.; Peterson, 1; Malagodi, M.; et al. (1989) Aerobic Soil Degradation of
               1,3-Dichloropropene: Laboratory Project ID GH-C 2158. Unpublished study
               prepared by University of Florida and Dow Chemical U.S.A. 126 p.

42413201       Barnekow, D.; Becker, G.; Brown, S. et al. (1992) The Nature of the Residue in
               Tomatoes Following a Pre-Plant Application of Uniformly [carbon 14] Labeled
               Cis-and Trans-l,3-Dichloropropene~an Interim Report: Lab Project Number:
               MET91065. Unpublished study prepared by DowElanco. 91 p.

42441001       Stott, W.; Stebbins, K.; Haut, K.; et al.  (1992) Telone II Soil Fumigant:
               One-year Dietary Toxicity Study in Beagle Dogs: Lab Project Number:
               M-003993-024. Unpublished study prepared by The Dow Chemical Co. 292 p.

42489901       Barnekow, D.; Becker, G.; Brown, S. et al. (1992) The Nature of the Residue in
               Soybeans Following a Pre-Plant Application of Uniformly [carbon-14] Labeled
               Cis-and Trans-l,3-Dichlorpropene—an  Interim Report: Lab Project Number:
               MET91066. Unpublished study prepared by DowElanco. 159 p.

42545101       Knuteson, J.; Petty, D.; Shurdut, B. (1992) Field Volatility of
               1,3-Dichloropropene in Salinas Valley California: Lab Project Number:
               ENV91011. Unpublished study prepared by DowElanco. 138 p.

42642301       Batzer, F.; Altscheffel, S.; Balcer, J.; et al. (1993) The Aerobic Soil Metabolism
               of 1,3-Dichloropropene: Lab Project Number: 89077. Unpublished study
               prepared by DowElanco. 162 p.

42760801       Barnekow, D.; Becker, G. (1993) A Comparison of the Magnitude of the
               (carbon 14) Residue in Tomatoes Grown in Sandy Loam and Clay Loam Soil
               Following a Pre-Plant Application of Uniformly (carbon 14)-Labeled Cis-and
               Trans-l,3-Dichloropropene: Lab Project Number: 90109.  Unpublished study
               prepared by DowElanco North American Environmental Chemistry Lab. 71 p.

42784201       Barnekow, D.; Becker, G. (1993) A Comparison of the Magnitude of the
               (carbon 14) Residue in Soybeans Grown in Sandy Loam and Clay Loam Soils
               Following a Pre-Plant Application of Uniformly (carbon 14)-Labeled Cis-and
                                         122

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                                BIBLIOGRAPHY
MRID
CITATION
              Trans-l,3-Dichloropropene: Lab Project Number: 90110. Unpublished study
              prepared by DowElanco North American Environmental Chemistry Lab. 74 p.

42845601      Houtman, B. (1993) Measurement of Off-Site Air Concentrations of
              1,3-Dichloropropene Following Application of Tel one Soil Fumigant.—Phase 3:
              Interim Report: Lab Project Number: ECL92096. Unpublished study prepared
              by Dowelanco North American Environmental Chemistry Lab. 47 p.

42894201      Barnekow, D.; Becker, G.; Brown, S.; et al. (1993) Supplemental Data to: The
              Nature of the Residue in Tomatoes Following a Pre-Plant Application of
              Uniformly 14C-Labeled Cis-and Trans-l,3-Dichloropropene: (MRID No.
              42709401): Lab Project Number: MET91065.01. Unpublished study prepared
              by DowElanco North American Environmental Chemistry Lab. 12 p.

42946401      Hamburg, A.; Byrne, S.; Huskin, M.; et al. (1993) The Nature of the Residue in
              Laying Hens Fed Uniformly (carbon 14)-Labeled 1,3-Dichloropropene: Lab
              Project Number: MET92038: HWI 6397-116: MC 1075.  Unpublished study
              prepared by DowElanco North American Environmental Chemistry Lab and
              Hazleton Wisconsin, Inc. 253 p.

42954801      Haut, K.; Stebbins, K.; Shabrang, S.; et al. (1993) TELONE II Soil Fumigant:
              13-Week Dietary Toxicity Study in B6C3F1 Mice: Lab Project Number:
              M-003993-029.  Unpublished study prepared by The Dow Chemical Co's.
              Toxicology Research Lab. 290 p.

42954802      Haut, K.; Johnson, K.; Shabrang, S.; et al. (1993) TELONE II Soil Fumigant:
              13-Week Dietary Toxicity and 4-Week Recovery Studies in Fischer 344 Rats:
              Lab Project Number: M-003993-028: M-003993-028A. Unpublished study
              prepared by The Dow Chemical Co's. Toxicology Research Lab. 400 p.

43083301      Satonin, D.; Hamberg, A.; Byrne, M.; et al. (1994) The Nature of the Residue in
              Lactating Goats Fed Uniformly (carbon 14)-Labeled 1,3-Dichloropropne: Lab
              Project Number: MET92103. Unpublished study prepared by DowElanco. 319
              P-

43140201      Barnekow, D.; Balcer, J.; Brown, S. et al. (1994) A One-Month Rotational Crop
              Study with Uniformly (carbon 14)-Labeled Cis-and Trans-l,3-Dichloropropene:
                                        123

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                                BIBLIOGRAPHY
MRID
CITATION
               Lab Project Number: MET91067. Unpublished study prepared by DowElanco,
               North American Environmental Chemistry Lab.  451 p.

43757901       Redmond, J.; Stebbins, K.; Stott, W. (1995) Telone II Soil Fumigant: Two-Year
               Dietary Chronic Toxicity/Oncogenicity Study in B6C3F1 Mice—Final Report:
               Lab Project Number: M-003993-032. Unpublished study prepared by The Dow
               Chemical Co.  1244 p.

43763501       Stott, W.; Johnson, K.; Jeffries, T.; et al. (1995) Telone II Soil Fumigant:
               Two-Year Chronic Toxicity/Oncogenicity Study in Fischer 344 Rats: Lab
               Project Number: M-003993-031. Unpublished study prepared by The Dow
               Chemical Co.  1515 p.

44005201       Knuteson, J.; Carver, L.; Dolder, S. (1996) Air,  Surface Water, and Ground
               Water Field Study of 1,3-Dichloropropene in a South Florida Vegetable
               Production System: First Quarterly Interim Report: Lab Project Number:
               ENV94004.01: 369.01: ENV94004.  Unpublished study prepared by
               DowElanco.  267 p. Relates to L0000177.

44302801       Gollapudi, B.; Cieszlak, F.; Lick, S. (1997) Telone II Soil Fumigant (cis/trans
               1,3-Dichloropropene): Inhalation Dominant Lethal Mutagenicity Study in the
               CD (Sprague-Dawley Derived) Rat: (Final Report): Lab Project Number:
               960035.  Unpublished study prepared by The Dow Chemical Co.  152 p.
Table 2 - Citations without MRID Numbers (note Journal article citations may not be included
in the 1,3-dichloropropene docket).

               Abbotts J. 1997. 1,2-Dichloropropene (Telone). Product and Residue Chemistry
               Chapters for the Reregi strati on Eligibility Document (RED). December 12,
               1996.

               Allen R.  1994. Hematologic Malignancies Following Exposure to Soil Fumigant,
               1,3-Dichloropropene (Telone). November 18, 1994.

               Bartowiak, Donna.  1997. Department of Pesticide Regulation, Environmental
               Monitoring and Pest Management Branch, Sacrento, CA., personal
               communication, February 1997.
                                         124

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                                 BIBLIOGRAPHY

MRID                          CITATION
               Barolo, Daniel M.  1996.  Non-Dietary Cancer Risk Policy, EPA Memorandum.
               August 14, 1996, 5 pages.

               Carleton J. 1995a. Revised Worker and Residential Exposure and Risk
               Assessments based on the Data Submitted in Response to the Worker and
               Biomonitoring Data Call-In (March 1993), for the Special Review Chemical: 1,3
               Dichloropropene (Telone). May 31, 1995.

               Carleton J. 1995b.  Personal communication to C. Scheltema regarding duration
               of air sampling in worker study. August 1995.

               Carleton J. 1995c. Revised Worker Exposure and Risk Assessments for workers
               engaged in loading 1,3-Dichloropropene (Telone), reflecting protection provided
               by wearing a respirator.  September 14, 1995.

               Carleton J. 1996a. Updated exposure and risk estimates for workers handling
               1,3-dichloropropene (Telone), reflecting new study data on "traveler" cylinders.
               March 4, 1996.

               Carleton J. 1996b.  Updated exposure and risk estimates for growers handling
               1,3-dichloropropene (Telone), reflecting new information on length of career.
               March 28, 1996.

               Carleton J. 1996c.  Corrected exposure and  risk estimates for [onion] growers
               handling 1,3-dichloropropene (Telone). May 28, 1996.

               Carleton J. 1997a. Occupational and Residential Exposure Assessment and
               Recommendation for the Reregi strati on Eligibility Document for Telone. April
               11, 1997.

               Carleton J. 1997b.  Sections IV and V Addendum to Telone RED Chapter. June
               3, 1997.

               Dearfield K. 1989. Second Peer Review of Telone II [Cancer Peer Review
               Committee Report]. October 30, 1989.

               Eiden, C 1998.  Memo presenting risks from time-weighted average for off-site
               wells in Wisconsin study. September 10,  1998.

                                         125

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                                 BIBLIOGRAPHY

MRID                          CITATION
               Fenner-Crisp P. 1994. Deriving Q^s Using the Unified Interspecies Scaling
               Factor. July 7, 1994.

               Fisher B. 1986. Telone II Risk Assessment. February 21, 1986.

               Fisher B. 1990. Telone II - Quantitative Risk Assessment, Mouse (B6C3F1)
               Inhalation Study. April 3,  1990.

               Fisher B. 1994. Telone II - Revised Qj*, (3/4's Interspecies Scaling Factor),
               Mouse (B^Fj) Inhalation Study. December 19, 1994.

               Giambelluca, Thomas, No date. Hawaii Ground Water Contamination Database,
               Hawaii Department of Health, University of Hawaii at Manoa.

               Glotfelty and Schomber. 1989. Reactions and Movement of Organic Chemicals
               in the Soil, Chapter 8, Sawhney and Brown, eds, SSSA Special Publication
               Number 22, Soil Science Society of America, Inc. and the American  Society of
               Agronomy.

               Hernandez AF et al. 1994. Clinical and Pathological Findings in Fatal
               1,3-Dichloropropene Intoxication. Human and Experimental Toxicology 13:
               303-306.

               Knott S. 1995. Personal Communication to C.  Scheltema regarding Telone
               application rate and air concentration. August 1995.

               Larsen, Art.  1997. Washington State Department of Ecology, personal
               communication.

               Levy A. 1987. Telone II Soil Fumigant: 2-Year Inhalation Chronic
               Toxicity/Oncogenicity Study in Rats. EPA Accession No. 403122-01. December
               18, 1987.

               Levy A. 1988. Telone II Soil Fumigant: 2-Year Inhalation Chronic
               Toxicity/Oncogenicity Study in Mice. EPA Accession No. 403123-00.  February
               5, 1988.
                                         126

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                                BIBLIOGRAPHY

MRID                         CITATION
               Levy A. 1993. Telone II (1,3-Dichloropropene) - Biomonitoring Human Data
               [from] Dow AgroSciences. August 19, 1993.

               Levy A. 1997. Telone II (1,3-Dichloropropene) - Toxicology RED Chapter.
               February 20, 1997.

               McLaughlin, Marvin. 1987. Oregon Department of Chemical Property
               Estimation Methods, McGraw hill.

               McMahon T. 1993. Telone II: Review of Pharmacokinetic and Field Trial Data
               submitted by the Registrant. October 22, 1993.

               Massachusetts InterAgency Task Force. 1986.  1985 Summary report:
               Interagency  Pesticide Monitoring Program, #14653-15-200-12-86-CR.

               Markovitz A and Crosby W. 1984.  Chemical Carcinogenesis: A soil Fumigant,
               1,3-Dichloropropene, as possible cause of hematologic malignancies. Archives of
               Internal Medicine. 144:  1409-1411.

               Mehta A.  1994a. Residential Exposure Assessment Using the Data Submitted in
               Response to the Worker and Biomonitoring Data-Call-in (March 1993), for
               Special Review Chemical  1,3 Dichloropropene (Telone). May 12, 1994.

               Mehta A.  1994b. Worker Exposure Assessment Based on the Data Submitted in
               Response to the Worker Air and Biomonitoring Data-Call-in (March 1993), for
               Special Review Chemical  1,3 Dichloropropene (Telone). June 17, 1994.

               Mehta A.  1994c. Residential/Bystander Risk Assessment of 1,3-Dichloropropene
               During Soil  Applications. July 19, 1994.

               Mehta A.  1994d. Worker Risk Assessment of 1,3-Dichloropropene During Soil
               Applications. October 6, 1994.

               Mehta A.  1994e. Addendum to the Worker Risk Assessment of
               1,3-Dichloropropene During Soil Applications. October 13, 1994.
                                         127

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                                 BIBLIOGRAPHY

MRID                          CITATION
               Mehta A. 1995. Personal Communication to C. Scheltema regarding rationale
               for extrapolation of air concentrations from Tel one monitoring studies to other
               crops.

               Michell R. 1995. Response to 1,3-D Use and Exposure Related Questions. April
               25, 1995.

               Miller D. 1995. Dichloropropene (Telone). (029001) Determination of the Need
               for Tolerances. August 24, 1995.

               Quest JA. 1985. [Carcinogenicity] Peer Review of Telone II. November 10,
               1985.

               Rabiu J,  Zavolta S. 1990. Preliminary Quantitative Usage Analysis of 1,3-DCP.
               September 1990.

               Riotte, Wyndham.  1997.  Florida Department of Agriculture and Consumer
               Sevices,  personal coimmunication.

               Rossi L.  1996. The Revised Risk Assessment and Regulatory Status of
               1,3-Dichloropropene. February 7, 1996.

               Tuazon,  B.C., Atkinson, R., Winer, A.M., and J. N. Pitts Jr. 1984. A study of
               the Atmoshperic Reactions of 1,3-Dichloropropene and Other Selected
               Organochlorine Compounds, Arch Environ.  Contam. Toxicol. 13, 691-700.

               USEPA. IRIS. Integrated Risk Information System Online Database. Reference
               Concentration (RfC) for 1,3-Dichloropropene and 1,2-Dichloropropane.

               USEPA  1996. Drinking Water Regulations and Health Advisories. USEPA,
               Office of Water. February 1996.  EPA 822-822-R-96-001.

               USEPA  1997a. FIFRA Science Advisory Panel Report.  Meeting of February 10,
               1997.

               USEPA  1997b. Environmental Fate and Effects Division Reregi strati on
               Eligibility Decision Document Chapter for Telone. July  1997.
                                         128

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                               BIBLIOGRAPHY

MRID                        CITATION
              USEPA 1997c. Ad Hoc Occupational and Residential Exposure SAC.
              Endpoints and exposure averaging times for Telone risks. August 5, 1997.

              Zavolta S and Michell R. 1996.  Career years for 1,3-Dichloropropene Handlers.
              March 19, 1996.
                                       129

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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                       WASHINGTON, D.C. 20460
                                                                           OFFICE OF
                                                                      PREVENTION, PESTICIDES
                                                                      AND TOXIC SUBSTANCES
                              DATA CALL-IN NOTICE
CERTIFIED MAIL
Dear Sir or Madam:
       This Notice requires you and other registrants of pesticide products containing the active
ingredient identified in Attachment 1 of this Notice, the Data Call-In Chemical Status Sheet, to
submit certain product specific data as noted herein to the U.S. Environmental Protection Agency
(EPA, the Agency). These data are necessary to maintain the continued registration of your
product(s) containing this active ingredient. Within 90 days after you receive this Notice you
must respond as set forth in Section III below. Your response must state:

       1.     How you will comply with the requirements set forth in this Notice and its
             Attachments 1 through 5;  or

       2.     Why you believe you are exempt from the requirements listed in this Notice and in
             Attachment 3, Requirements Status and Registrant's Response Form, (see section
             III-B); or

       3.     Why you believe EPA should not require your submission  of product specific data
             in the manner specified by this Notice (see section III-D).

       If you do not respond to this Notice, or if you do not satisfy EPA that you will comply
with its requirements or should be exempt or excused from doing so, then  the registration of your
                                          131

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product(s) subject to this Notice will be subject to suspension. We have provided a list of all of
your products subject to this Notice in Attachment 2, Data Call-In Response Form, as well as a
list of all registrants who were sent this Notice (Attachment 5).

       The authority for this Notice is section 3(c)(2)(B) of the Federal Insecticide, Fungicide
and Rodenticide Act as amended (FIFRA), 7 U.S.C. section 136a(c)(2)(B). Collection of this
information is authorized under the Paperwork Reduction Act by OMB Approval No. 2070-0107
and 2070-0057 (expiration date 03-31-99).

       This Notice is divided into six sections and six Attachments.  The Notice itself contains
information and instructions applicable to all Data Call-in Notices.  The Attachments contain
specific chemical information and instructions.  The six sections of the Notice are:

       Section I  -  Why You Are Receiving This Notice
       Section II  -   Data Required By This Notice
       Section III -  Compliance With Requirements Of This Notice
       Section IV -  Consequences Of Failure To Comply With This Notice
       Section V  -   Registrants' Obligation To Report Possible Unreasonable Adverse
                    Effects
       Section VI -  Inquiries And Responses To This Notice

The Attachments to this Notice are:

       1 -   Data Call-In Chemical Status Sheet
       2 -   Product-Specific Data Call-In Response Form  (Insert A)
       3 -   Requirements Status and Registrant's Response Form (Insert B)
       4 -   EPA Batching of End-Use Products for Meeting Acute Toxicology Data
             Requirements for Reregi strati on
       5 -   List of Registrants Receiving This Notice

SECTION I. WHY YOU ARE RECEIVING THIS NOTICE

       The Agency has reviewed existing data for this active ingredient and reevaluated the data
needed to support continued registration of the subject active ingredient.  The Agency has
concluded that the only additional data necessary are product specific data. No additional generic
data requirements are being imposed.  You have been sent this Notice because you have
product(s) containing the subject active ingredient.

SECTION II. DATA REQUIRED BY THIS NOTICE

       II-A.  DATA REQUIRED

       The product specific data required by this Notice are specified in Attachment 3,
Requirements Status and Registrant's Response Form (Insert B).  Depending on the results of the
studies required in this Notice, additional testing may be required.

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       II-B.  SCHEDULE FOR SUBMISSION OF DATA

       You are required to submit the data or otherwise satisfy the data requirements specified in
Insert B, Requirements Status and Registrant's Response Form (Insert BX within the time frames
provided.

       II-C.  TESTING PROTOCOL

       All studies required under this Notice must be conducted in accordance with test standards
outlined in the Pesticide Assessment Guidelines for those studies for which guidelines have been
established.

       These EPA Guidelines are available from the National Technical Information Service (NTIS),
Attn: Order Desk, 5285 Port Royal Road,  Springfield, Va 22161 (tel: 703-487-4650).

       Protocols approved by the Organization for Economic Cooperation and Development
(OECD) are also acceptable if the OECD-recommended test standards conform to those specified in
the Pesticide Data Requirements regulation (40 CFR § 158.70).  When using the OECD protocols,
they should be modified as appropriate so that the data generated by the study will satisfy the
requirements of 40 CFR § 158. Normally, the Agency will not extend deadlines for complying with
data requirements when the studies were not conducted in accordance with acceptable standards.
The OECD protocols are available from OECD, 2001 L Street, N.W., Washington, D.C. 20036
(Telephone number 202-785-6323; Fax telephone number 202-785-0350).

       All new studies and proposed protocols submitted in response to this Data Call-In Notice
must be in accordance with Good Laboratory Practices [40 CFR Part 160.3(a)(6)].

       II-D.  REGISTRANTS RECEIVING PREVIOUS SECTION 3(c)(2¥B) NOTICES
             ISSUED BY THE AGENCY

       Unless otherwise noted herein, this Data Call-In does not in any way supersede or change the
requirements of any previous Data Call-In(s). or any other agreements entered into with the Agency
pertaining to such prior Notice.  Registrants must comply with the requirements of all Notices to
avoid issuance of a Notice of Intent to Suspend their affected products.

SECTION III.       COMPLIANCE WITH REQUIREMENTS OF THIS NOTICE

       III-A. SCHEDULE FOR RESPONDING TO THE AGENCY

       The appropriate responses initially required by this Notice for product specific data must be
submitted to the Agency within 90 days after your receipt of this Notice.  Failure to adequately
respond to this Notice within 90 days of your receipt will be a basis for issuing a Notice of Intent to
Suspend (NOIS)  affecting your products. This and other bases for issuance of NOIS due to failure to
comply with this Notice are presented in Section IV-A and IV-B.
                                           133

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       III-B.  OPTIONS FOR RESPONDING TO THE AGENCY

       The options for responding to this Notice for product specific data are: (a) voluntary
cancellation, (b) agree to satisfy the product specific data requirements imposed by this notice or (c)
request a data waiver(s).

       A discussion of how to respond if you chose the Voluntary Cancellation option is presented
below. A discussion of the various options available for satisfying the product specific data
requirements of this Notice is contained in Section III-C.  A discussion of options relating to
requests for data waivers is contained in Section III-D.

       There are two forms that accompany this Notice of which, depending upon your response,
one or both must be used in your response to the Agency.  These forms are the Data-Call-in
Response Form (Insert A), and the Requirements  Status and Registrant's Response Form (Insert B).
The Data Call-In Response Form must be submitted as part of every response to this Notice.  In
addition, one copy of the Requirements Status and Registrant's Response Form (Insert B) must be
submitted for each product listed on the Data Call-In Response Form (Insert A) unless the voluntary
cancellation option is selected or unless the product is identical to another (refer to the instructions
for completing the Data Call-In Response Form(Insert A).  Please note that the company's
authorized representative is required to sign the first page of the Data Call-In Response Form (Insert
A) and Requirements Status and Registrant's Response Form (Insert B), initial any subsequent
pages. The forms  contain separate detailed instructions on the response options.  Do not alter the
printed material. If you have questions or need assistance in preparing your response,  call or write
the contact person(s) identified in Attachment 1.

       1.      Voluntary Cancellation - You may avoid the requirements of this Notice by
requesting voluntary cancellation of your product(s) containing the active ingredient that is the
subject of this Notice.  If you wish to voluntarily cancel your product, you must submit a completed
Data Call-In Response Form (Insert A), indicating your election of this option. Voluntary
cancellation is item number 5 on the Data Call-In Response Form (Insert B). If you choose this
option, this is the  only form that you are required  to complete.

       If you chose to voluntarily cancel your product, further sale and distribution of your product
after the effective date of cancellation must be in accordance with the Existing Stocks provisions of
this Notice which are contained in Section IV-C.

       2.      Satisfying the Product Specific Data Requirements of this Notice There are
various options available to satisfy the product specific data requirements of this Notice. These
options are discussed in Section III-C of this Notice and comprise options 1 through 5 on the
Requirements Status and Registrant's Response Form (Insert A) and item numbers 7a and 7b on the
Data Call-In Response Formdnsert B). Deletion of a use(s) and the low volume/minor use  option are
not valid options for fulfilling product specific data requirements.

       3.      Request for Product Specific Data Waivers. Waivers for product specific data are
discussed in Section III-D of this Notice and are covered by option 7 on the Requirements  Status

                                            134

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and Registrant's Response Form (Insert B). If you choose one of these options, you must submit
both forms as well as any other information/data pertaining to the option chosen to address the data
requirement.

       III-C  SATISFYING THE DATA REQUIREMENTS OF THIS NOTICE

       If you acknowledge on the Data Call-In Response Form (Insert A) that you agree to satisfy
the product specific data requirements (i.e. you select item number 7a or 7b), then you must select
one of the six options on the Requirements Status and Registrant's Response Form (Insert A) related
to data production for each data requirement.  Your option selection should be entered under item
number 9, "Registrant Response."  The six options related to data production are the first six options
discussed under item 9 in the instructions for completing the Requirements Status and Registrant's
Response Formflnsert A).  These six options are listed immediately below with information in
parentheses to guide registrants to additional instructions provided in this Section. The options are:

       (1)     I will generate and submit data within the specified time frame (Developing Data)
       (2)     I have entered into an agreement with  one or more registrants to develop data jointly
              (Cost Sharing)
       (3)     I have made offers to cost-share (Offers to Cost Share)
       (4)     I am submitting an existing study that has not been submitted previously to the
              Agency by anyone (Submitting an Existing Study)
       (5)     I am submitting or citing data to upgrade a study classified by EPA as partially
              acceptable and upgradeable (Upgrading a Study)
       (6)     I am citing an existing study that EPA  has classified as acceptable or an existing study
              that has been submitted but not reviewed by the Agency (Citing an Existing Study)

       Option 1, Developing Data - If you choose to develop the required data it must be in
conformance with Agency deadlines and with other Agency requirements as referenced here in and in
the attachments.  All data generated and submitted must comply with the Good Laboratory Practice
(GLP) rule (40 CFR Part 160), be conducted according to the Pesticide Assessment
Guidelines(PAG), and be in conformance with the requirements of PR Notice 86-5.

       The time frames in the Requirements Status and Registrant's Response Form (Insert A) are
the time frames that the Agency is allowing for the submission of completed study reports. The
noted deadlines run from the date of the receipt of this Notice by the registrant.  If the data are not
submitted by the deadline, each registrant is subject to receipt of a Notice of Intent to Suspend the
affected registration(s).

       If you cannot submit the data/reports to the Agency in the time required by this Notice and
intend to seek additional time to meet the requirements(s), you must submit a request to the Agency
which includes: (1) a detailed description of the expected difficulty and (2) a proposed schedule
including alternative dates for meeting such requirements on a step-by-step basis. You must explain
any technical or laboratory difficulties and provide documentation from the laboratory performing
the testing.  While EPA is considering your request, the original deadline remains.  The Agency will
respond to your request in writing.  If EPA does not grant your request, the original deadline

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remains.  Normally, extensions can be requested only in cases of extraordinary testing problems
beyond the expectation or control of the registrant.  Extensions will not be given in submitting the
90-day responses. Extensions will not be considered if the request for extension is not made in a
timely fashion; in no event shall an extension request be considered if it is submitted at or after the
lapse of the subject deadline.

       Option 2, Agreement to Share in Cost to Develop Data - Registrants may only choose
this option for acute toxicity data and certain efficacy data and only if EPA has indicated in the
attached data tables that your product and at least one other product are similar for purposes of
depending on the same data. If this is the case, data may be generated for just one of the products in
the group.  The registration number of the product for which data will be submitted must be noted in
the agreement to cost share by the registrant selecting this option. If you choose to enter into an
agreement to share in the cost of producing the required data but will not be submitting the data
yourself, you must provide the name of the registrant who will be submitting the data. You must
also provide EPA with documentary evidence that an agreement has been formed. Such evidence
may be your letter offering to join  in an agreement and the other registrant's acceptance  of your
offer, or a written statement by the parties that an agreement  exists. The agreement to produce the
data need not specify all of the terms of the final arrangement between the parties or the mechanism
to resolve the terms.  Section 3(c)(2)(B) provides that if the parties cannot resolve the terms of the
agreement they may resolve their differences through binding arbitration.

       Option 3, Offer to Share  in the Cost of Data Development - This option only applies to
acute toxicity and certain efficacy data as described in option 2 above. If you have made an offer to
pay in an attempt to enter into an agreement or amend an  existing agreement to meet the
requirements of this Notice and have been unsuccessful, you may request EPA (by selecting this
option) to exercise its discretion not to suspend your registration(s), although you do not comply
with the data submission requirements of this Notice.  EPA has determined that as a general policy,
absent other relevant considerations, it will not suspend the registration of a product of a registrant
who has in good faith sought and continues to seek to enter into a joint data development/cost
sharing program, but the other registrant(s) developing the data has refused to accept your offer. To
qualify for this option, you must submit documentation to the Agency proving that you have made an
offer to another registrant (who has an obligation to submit data)  to share in the burden of
developing that data. You must also submit to the Agency a  completed EPA Form 8570-32,
Certification of Offer to Cost Share in the Development of Data, Attachment 7. In addition, you
must demonstrate that the other registrant to whom the offer  was made has not accepted your offer
to enter into a cost sharing  agreement by including  a copy of your offer and proof of the other
registrant's receipt of that offer (such as a certified mail receipt).  Your offer must, in addition to
anything else, offer to share in the  burden of producing the data upon terms to be agreed or failing
agreement to be bound by binding arbitration as provided  by FIFRA section 3(c)(2)(B)(iii) and must
not qualify this offer.  The other registrant must also inform EPA of its election of an option to
develop and submit the data required by this Notice by submitting a Data Call-In Response Form
(Insert A) and a Requirements Status and Registrant's Response Form (Insert B)  committing to
develop and submit the data required by this Notice.
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       In order for you to avoid suspension under this option, you may not withdraw your offer to
share in the burdens of developing the data.  In addition, the other registrant must fulfill its
commitment to develop and submit the data as required by this Notice.  If the other registrant fails to
develop the data or for some other reason is subject to suspension, your registration as well as that
of the other registrant will normally be subject to initiation of suspension proceedings, unless you
commit to submit, and do submit the required data in the specified time frame. In such cases, the
Agency generally will not grant a time extension for submitting the data.

       Option 4, Submitting an Existing Study - If you choose to submit an existing study in
response to this Notice, you must determine that the study satisfies the requirements imposed by this
Notice.  You may only submit a study that has not been previously submitted to the Agency or
previously cited by anyone. Existing studies are studies which predate issuance of this Notice.  Do
not use this option if you are submitting data to upgrade a study. (See Option 5).

       You should be aware that if the Agency determines that the study is not acceptable, the
Agency will require you to comply with this Notice, normally without an extension of the required
date of submission.  The Agency may determine at any time that a study is not valid and needs to be
repeated.

       To meet the requirements of the DCI Notice for submitting an existing study, all of the
following three criteria must be clearly met:

       a.      You must certify at the time that the existing study is submitted that the raw data and
              specimens from the study are available for audit and review and you must identify
              where they are available.  This must be done in accordance with the requirements of
              the Good Laboratory Practice (GLP) regulation, 40 CFR Part 160. As stated in 40
              CFR 160.3(j) " 'raw data' means any laboratory worksheets, records, memoranda,
              notes, or exact copies thereof, that are the result of original observations and
              activities of a study and are necessary for the reconstruction and evaluation of the
              report of that study.  In the event that exact transcripts of raw data have been
              prepared (e.g., tapes which have been transcribed verbatim,  dated, and verified
              accurate by signature), the exact copy or exact transcript may be substituted for the
              original source as raw data.  'Raw data' may include photographs, microfilm or
              microfiche copies, computer printouts, magnetic media, including dictated
              observations, and recorded data from  automated instruments." The term
              "specimens", according to 40 CFR 160.3(k), means "any material derived from a test
              system for examination or analysis."

       b.     Health and safety studies completed after May 1984 must also contain all GLP-
              required quality assurance and quality control information, pursuant to the
              requirements of 40 CFR Part 160.  Registrants must also certify at the time of
              submitting the existing study that such GLP information is available for post-May
              1984 studies by including an appropriate  statement on or attached to the study signed
              by an authorized official or representative of the registrant.
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       c.      You must certify that each study fulfills the acceptance criteria for the Guideline
              relevant to the study provided in the FIFRA Accelerated Reregi strati on Phase 3
              Technical Guidance and that the study has been conducted according to the Pesticide
              Assessment Guidelines (PAG) or meets the purpose of the PAG (both available from
              NTIS). A study not conducted according to the PAG may be submitted to the
              Agency for consideration if the registrant believes that the study clearly meets the
              purpose of the PAG. The registrant is referred to 40 CFR 158.70 which states the
              Agency's policy regarding acceptable protocols. If you wish to submit the study, you
              must, in addition to certifying that the purposes of the PAG are met by the study,
              clearly articulate the rationale why you believe the study meets the purpose of the
              PAG, including copies of any supporting information or data. It has been the
              Agency's experience that studies completed prior to  January 1970 rarely satisfied the
              purpose of the PAG and that necessary raw data are usually not available for such
              studies.

       If you submit an existing study, you must certify that the study meets all requirements of the
criteria outlined above.

       If you know of a study pertaining to any requirement in this Notice which does not meet the
criteria outlined above but does contain factual information regarding unreasonable adverse effects,
you must notify the Agency of such a study.  If such study is in the Agency's files, you need only cite
it along with the notification. If not in the Agency's files, you must submit a summary and copies as
required by PR Notice 86-5.

       Option 5, Upgrading a Study - If a study has been classified as partially acceptable and
upgradeable, you may submit data to upgrade that study.  The Agency will review the data submitted
and determine if the requirement is satisfied. If the Agency decides the requirement is not satisfied,
you may still be required to submit new data normally without any time extension.  Deficient, but
upgradeable studies will normally be classified as supplemental. However, it is important to note that
not all studies classified as supplemental are upgradeable. If you have questions regarding the
classification of a study or whether a study may be upgraded, call or write the contact person listed
in Attachment 1. If you submit data to upgrade an existing  study you must satisfy or supply
information to correct all deficiencies in the study identified by EPA. You must provide a clearly
articulated rationale of how the deficiencies have been remedied or corrected and why the study
should be rated as acceptable to EPA.  Your submission must also specify the MRID number(s) of
the study which you are attempting to upgrade and must be in conformance with PR Notice 86-5.

       Do not submit additional data for the purpose of upgrading  a study classified as unacceptable
and determined by the Agency as not capable of being upgraded.

       This option should also be  used to cite data that has been previously submitted to upgrade  a
study, but has not yet been reviewed by the Agency. You must provide the MRID number of the
data submission as well as the MRID number of the study being upgraded.
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       The criteria for submitting an existing study, as specified in Option 4 above, apply to all data
submissions intended to upgrade studies.  Additionally your submission of data intended to upgrade
studies must be accompanied by a certification that you comply with each of those criteria as well as
a certification regarding protocol compliance with Agency requirements.

       Option 6, Citing Existing Studies — If you choose to cite a study that has been previously
submitted to EPA, that study must have been previously classified by EPA as acceptable or it must
be a study which has not yet been reviewed by the Agency. Acceptable toxicology studies generally
will have been classified as "core-guideline" or "core minimum."  For all other disciplines the
classification would be "acceptable." With respect to any studies for which you wish to select this
option you must provide the MRID number of the study you are citing and, if the study has been
reviewed by the Agency, you must provide the Agency's classification of the study.

       If you are citing a study of which you are not the original data submitter, you must submit a
completed copy of EPA Form 8570-34, Certification with Respect to Citations of Data (in PR
Notice 98-5Y

       Registrants who select one of the above 6 options must meet all of the requirements
described in the instructions for completing the Data Call-In Response Form (Insert A) and the
Requirements Status and Registrant's Response Form  (Insert B), as appropriate.

       III-D.  REQUESTS FOR DATA WAIVERS

       If you request a waiver for product specific data because you believe it is inappropriate, you
must attach a complete justification for the request, including technical reasons, data and references
to relevant EPA regulations, guidelines or policies. (Note: any supplemental data must be submitted
in the format required by PR Notice 86-5). This will be the only opportunity to state the reasons or
provide information in support of your request. If the Agency approves your waiver request, you
will not be required to supply the data pursuant to section 3(c)(2)(B) of FIFRA. If the Agency
denies your waiver request, you must choose an option for meeting the data requirements of this
Notice within 30 days of the receipt of the Agency's decision. You must indicate and submit the
option chosen on the Requirements Status and Registrant's Response Form.  Product specific data
requirements for product chemistry, acute toxicity and efficacy (where appropriate) are required for
all products and the Agency would grant a waiver only under extraordinary circumstances. You
should also be aware that submitting a waiver request will not automatically extend the due date for
the study in question. Waiver requests submitted without adequate supporting rationale will be
denied and the original due date will remain in force.

IV.    CONSEQUENCES OF FAILURE TO COMPLY WITH THIS NOTICE

       IV-A  NOTICE OF INTENT TO SUSPEND

       The Agency may issue a Notice of Intent to Suspend products subject to this Notice due to
failure by a registrant to comply with the requirements of this Data Call-In Notice, pursuant to
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FIFRA section 3(c)(2)(B). Events which may be the basis for issuance of a Notice of Intent to
Suspend include, but are not limited to, the following:

       1.      Failure to respond as required by this Notice within 90 days of your receipt of this
              Notice.

       2.      Failure to submit on the required schedule an acceptable proposed or final protocol
              when such is required to be submitted to the Agency for review.

       3.      Failure to submit on the required schedule an adequate progress report on a study as
              required by this Notice.

       4.      Failure to submit on the required schedule acceptable data as required by this Notice.

       5.      Failure to take a required action or submit adequate information pertaining to any
              option chosen to address the data requirements (e.g., any  required action or
              information pertaining to submission or citation of existing studies or offers,
              arrangements, or arbitration on the sharing of costs or the formation of Task Forces,
              failure to comply with the terms of an agreement or arbitration concerning joint data
              development or failure to comply with any terms of a data waiver).

       6.      Failure to submit supportable certifications as to the conditions of submitted studies,
              as required by  Section III-C of this Notice.

       7.      Withdrawal of an offer to share in the cost of developing  required data.

       8.      Failure of the registrant to whom you have tendered an offer to share in the cost of
              developing data and provided proof of the registrant's receipt of such offer or failure
              of a registrant on whom you rely for a generic data exemption either to:

              a.      inform EPA of intent to develop and submit the data required by this Notice
                     on a Data Call-In Response Formflnsert A) and a  Requirements Status and
                     Registrant's Response Formflnsert B):

              b.      fulfill the commitment to develop and submit the data as required by this
                     Notice; or

              c.      otherwise take appropriate steps to meet the requirements stated in this
                     Notice, unless you commit to submit and do submit the required data in the
                     specified time frame.

       9.      Failure to take any required or appropriate steps, not mentioned above, at any time
              following the issuance of this Notice.
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       IV-B.  BASIS FOR DETERMINATION THAT SUBMITTED STUDY IS
              UNACCEPTABLE

       The Agency may determine that a study (even if submitted within the required time) is
unacceptable and constitutes a basis for issuance of a Notice of Intent to  Suspend.  The grounds for
suspension include, but are not limited to, failure to meet any of the following:

       1.  EPA requirements specified in the Data Call-In Notice or other documents incorporated
       by reference (including, as applicable, EPA Pesticide Assessment  Guidelines, Data Reporting
       Guidelines, and GeneTox Health Effects Test Guidelines) regarding the design, conduct, and
       reporting of required studies.  Such requirements include, but are  not limited to, those
       relating to test material, test procedures, selection of species, number of animals, sex and
       distribution of animals, dose and effect levels to be tested or attained,  duration of test, and, as
       applicable,  Good Laboratory Practices.

       2.  EPA requirements regarding the submission of protocols, including the incorporation of
       any changes required by the Agency following review.

       3.  EPA requirements regarding the reporting of data, including the manner of reporting, the
       completeness of results, and the adequacy of any required supporting  (or raw) data,
       including, but not limited to, requirements referenced or included  in this Notice or contained
       in PR 86-5.  All studies must be submitted in the form of a final report; a preliminary report
       will not be considered to fulfill the submission requirement.

       IV-C  EXISTING STOCKS OF SUSPENDED OR CANCELED PRODUCTS

       EPA has statutory authority to permit continued sale, distribution  and use of existing  stocks
of a pesticide product which has been suspended or canceled if doing so would be consistent  with the
purposes of the Act.

       The Agency has determined that such disposition by registrants of existing stocks for  a
suspended registration when a section 3(c)(2)(B) data request is outstanding would generally not be
consistent with the Act's purposes. Accordingly, the Agency anticipates granting registrants
permission to sell, distribute, or use existing stocks of suspended product(s) only in exceptional
circumstances. If you believe  such disposition of existing stocks of your product(s) which may be
suspended for failure to comply with this Notice should be permitted, you have the burden  of clearly
demonstrating to EPA that granting such permission would be consistent with the Act. You must
also explain why an "existing stocks"  provision is necessary, including a statement of the quantity of
existing stocks and your estimate of the time required for their sale, distribution, and use. Unless you
meet this burden the Agency will not  consider  any request pertaining to the continued sale,
distribution, or use of your existing stocks after suspension.

       If you request a voluntary cancellation  of your product(s) as a response to this Notice and
your product is in full compliance with all Agency requirements, you will have, under most
circumstances, one year from the date your 90  day response to this Notice is due, to sell, distribute,

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or use existing stocks. Normally, the Agency will allow persons other than the registrant such as
independent distributors, retailers and end users to sell, distribute or use such existing stocks until the
stocks are exhausted. Any sale, distribution or use of stocks of voluntarily canceled products
containing an active ingredient for which the Agency has particular risk concerns will be determined
on case-by-case basis.

       Requests for voluntary cancellation received after the 90  day response period required by this
Notice will not result in the Agency granting any additional time to sell, distribute, or use existing
stocks beyond a year from the date the 90 day response was due unless you demonstrate to the
Agency that you are in full compliance with all Agency requirements, including the requirements of
this Notice.  For example, if you decide to voluntarily cancel your registration six months before a 3
year study is scheduled to be submitted, all progress reports and  other information necessary to
establish that you have been conducting the study in an acceptable and good faith manner must have
been submitted to the Agency, before EPA will  consider granting an existing stocks provision.

SECTION V.       REGISTRANTS' OBLIGATION TO REPORT POSSIBLE
                    UNREASONABLE ADVERSE EFFECTS

       Registrants are reminded that FIFRA section 6(a)(2) states that if at any time after a pesticide
is registered a registrant has additional factual information regarding unreasonable adverse effects on
the environment by the pesticide, the registrant shall submit the information to the Agency.
Registrants must notify the Agency of any factual information they have, from whatever source,
including but not limited to interim or preliminary results of studies, regarding unreasonable adverse
effects on man or the environment.  This requirement continues as long as the products are registered
by the Agency.

SECTION VI.      INQUIRIES AND RESPONSES TO  THIS NOTICE

       If you have any questions regarding the requirements and procedures established by this
Notice, call the contact person(s) listed in Attachment 1, the Data Call-In Chemical Status Sheet.

       All responses to this Notice (other than voluntary cancellation requests and generic data
exemption claims) must include a completed Data Call-In Response Form (Insert A) and a completed
Requirements Status and Registrant's Response Form (Insert B) for product specific data) and any
other documents required by this Notice, and  should be submitted to the contact person(s) identified
in Attachment 1. If the voluntary cancellation or generic data  exemption option is chosen, only the
Data Call-In Response Form (Insert A) need be submitted.
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       The Office of Compliance Monitoring (OCM) of the Office of Pesticides and Toxic
Substances (OPTS), EPA, will be monitoring the data being generated in response to this Notice.

                                        Sincerely yours,
                                        Lois A. Rossi, Director
                                        Special Review and
                                         Reregi strati on Division
Attachments
       1  -   Data Call-In Chemical Status Sheet
       2  -   Product-Specific Data Call-In Response Form (Insert A)
       3  -   Requirements Status and Registrant's Response Form (Insert B)
       4  -   EPA Batching of End-Use Products for Meeting Acute Toxicology Data
             Requirements for Reregi strati on
       5  -   List of Registrants Receiving This Notice
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1,3-DICHLOROPROPENE DATA CALL-IN CHEMICAL STATUS SHEET

INTRODUCTION

       You have been sent this Product Specific Data Call-In Notice because you have product(s)
containing 1,3-Dichloropropene.

       This Product Specific Data Call-In Chemical Status Sheet contains an overview of data required
by this notice, and point of contact for inquiries pertaining to the reregi strati on of 0328. This attachment
is to be used in conjunction with (1) the Product Specific Data Call-In Notice, (2) the Product Specific
Data Call-In Response Form (Attachment 2), (3) the Requirements  Status and Registrant's Form
(Attachment 3), (4) EPA's Grouping of End-Use Products for Meeting Acute  Toxicology  Data
Requirement (Attachment 4), and (5) a list of registrants receiving this DCI (Attachment 5).

DATA REQUIRED BY THIS NOTICE

       The additional data requirements needed to complete the database for 1,3-Dichloropropene are
contained in the Requirements Status and Registrant's Response. Attachment 3.  The Agency has
concluded that additional data on 1,3-Dichloropropene are needed for specific products. These data are
required to be submitted to the Agency within the time frame listed.  These data are needed to fully
complete the reregi strati on of all eligible 1,3-Dichloropropene products.

INQUIRIES AND RESPONSES TO  THIS NOTICE

       If you have any questions regarding this product specific data requirements and procedures
established by this Notice, please contact Karen Jones at (703) 308-8047.

       All responses to this Notice for the Product Specific  data requirements should be submitted to:

             Karen Jones
             Chemical Review Manager Team 81
             Product Reregi strati on Branch
             Special Review and Reregi strati on Branch 7508C
             Office of Pesticide Programs
             U.S. Environmental Protection Agency
             Washington, D.C. 20460

             RE:  1,3-Dichloropropene
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     INSTRUCTIONS FOR COMPLETING THE DATA CALL-IN RESPONSE FORM
                     (INSERT A) FOR  PRODUCT SPECIFIC DATA

Item 1-4.     Already completed by EPA.

Item 5.       If you wish to voluntarily cancel your product, answer "yes." If you choose this option,
             you will not have to provide the data required by the Data Call-In Notice and you will
             not have to complete any other forms. Further sale and distribution of your product after
             the effective date  of cancellation must be in accordance  with the Existing  Stocks
             provision of the Data Call-In Notice (Section IV-C).

Item 6.       Not applicable since this form  calls in product specific data only.  However,  if your
             product is identical to another product and you qualify for a data exemption, you must
             respond with  "yes" to Item 7a (MUP) or 7B (EUP) on this form, provide the EPA
             registration numbers of your source(s); you would not complete the "Requirements
             Status and Registrant's Response" form. Examples of such products include repackaged
             products and  Special Local Needs (Section 24c) products which are identical to
             federally registered products.

Item 7a.      For each  manufacturing use  product (MUP)  for  which you wish  to maintain
             registration, you must agree to satisfy the data requirements by responding "yes."

Item 7b.      For each end use product (EUP) for which you wish to maintain registration, you must
             agree to satisfy the data requirements by responding "yes." If you are requesting a data
             waiver, answer "yes" here; in addition, on the "Requirements Status and Registrant's
             Response" form under Item 9, you must respond with Option 7 (Waiver Request) for
             each study for which you are requesting a waiver.  See Item 6 with regard to identical
             products and data exemptions.

Items 8-11. Self-explanatory.

NOTE:      You may provide additional information that does not fit on this form in a signed letter
             that accompanies this form. For example, you may wish to report that your product has
             already been transferred to another company or that you have already  voluntarily
             canceled this product. For these cases, please supply all relevant details so that EPA can
             ensure that its records are correct.
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      sample Part B form page number 2 in the actual Printed version of the Red document
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      INSTRUCTIONS FOR COMPLETING THE REQUIREMENTS STATUS AND
   REGISTRANT'S RESPONSE FORM (INSERT B) FOR PRODUCT SPECIFIC DATA

Item 1-3      Completed by EPA. Note the unique identifier number assigned by EPA in Item 3.
             This number must be used in the transmittal document for any data submissions in
             response to this Data Call-In Notice.

Item 4.       The guideline reference numbers of studies required to support the product's continued
             registration are identified. These guidelines, in addition to the requirements specified in
             the Notice, govern the conduct of the required studies.  Note that series 61 and 62 in
             product chemistry are now listed under 40 CFR 158.155 through 158.180,  Subpart C.

Item 5.       The study title associated with the guideline reference number is identified.

Item 6.       The use pattern(s) of the pesticide associated with the product specific requirements is
             (are) identified. For most product specific data requirements, all use patterns are covered
             by the data requirements. In the case of efficacy data, the required studies only pertain
             to products which have the use sites and/or pests indicated.

Item 7.       The substance to be tested is identified by EPA.  For product specific data, the product
             as formulated for sale and distribution is the test substance, except in rare cases.

Item 8.       The due date for submission of each study is identified. It is normally based on 8 months
             after issuance of the Reregistration Eligibility Document unless EPA determines that
             a longer time period is necessary.

Item 9       Enter only one of the following response codes for each data requirement to show
             how you intend to comply with the data requirements listed in this table.  Fuller
             descriptions of each option are contained in the Data Call-In Notice.

       1.     I will generate and submit  data by the specified due date (Developing Data).   By
             indicating that I have chosen this option,  I  certify that  I will  comply with all the
             requirements pertaining to the conditions for submittal of this study as outlined in the
             Data  Call-In Notice. By the specified due date, I will also submit:  (1) a completed
             "Certification with Respect to Citations of Data (in PR Notice 98-5)" form (EPA
             Form 8570-34) and  (2) two completed  and  signed  copies of the  Confidential
             Statement of Formula (EPA Form 8570-4)

       2.     I have entered into an agreement with one or more registrants to develop data jointly
             (Cost Sharing).  I am submitting a copy of this agreement. I understand that this
             option is available only for acute toxicity or certain efficacy data and only if EPA
             indicates in an attachment to this Notice that my product is similar enough to another
             product to qualify for this  option.   I certify that another party in the  agreement is
             committing to submit or provide the required data; if the required study is not submitted
             on time, my product may be  subject to suspension. By the specified due date, I will also

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       submit: (1) a completed "Certification with Respect to Citations of Data  (in PR
       Notice 98-5)" form (EPA Form 8570-34) and (2) two completed and signed copies of
       the Confidential Statement of Formula (EPA Form 8570-4)

3.      I have made offers to share in the cost to develop data (Offers to Cost Share). I
       understand that this option is available only for acute toxicity or certain efficacy data and
       only if EPA indicates in an attachment to this Data Call-In Notice that my product is
       similar enough to another product to qualify for this option. I am submitting evidence
       that I have made an offer to another registrant (who has an obligation to submit data)
       to share in the cost of that data. I am also submitting a completed "Certification of
       Attempt to Enter into an Agreement with other Restraints for Development of
       Data " (EPA Form 8570-32). I am including a copy of my offer and proof of the other
       registrant's receipt of that offer. I am identifying the party which is committing to submit
       or provide the required data; if the required study is not submitted on time, my product
       may be subject to suspension. I understand that other terms under Option 3 in the Data
       Call-In Notice (Section III-C.l.) apply as well.  By the specified due date, I will also
       submit: (1)  a completed  "Certification  With  Respect To  Data Compensation
       Requirements" form (EPA Form 8570-34) and (2) two completed and signed copies
       of the Confidential Statement of Formula (EPA Form 8570-4)

4.      By the specified due date, I will submit an existing study that has not been submitted
       previously to the Agency by anyone (Submitting an Existing Study). I certify that this
       study will meet all the requirements for submittal  of existing data outlined in Option 4
       in the Data  Call-In Notice  (Section  III-C.l.) and will meet the attached  acceptance
       criteria (for acute toxicity  and product chemistry  data).  I will attach the needed
       supporting information  along with this response.  I also certify that I have determined
       that this study will fill the data requirement for which I have indicated this choice.  By
       the specified due date, I will also submit a completed "Certification With Respect To
       Data Compensation Requirements" form (EPA Form 8570-34) to show what data
       compensation option I have chosen.  By the specified due date, I will also submit: (1) a
       completed "Certification With Respect  To Data Compensation Requirements"
       form  (EPA Form  8570-34)  and  (2) two completed  and signed copies of  the
       Confidential Statement of Formula (EPA Form 8570-4)

5.      By the specified due date, I will submit or cite data to upgrade a study classified by the
       Agency as partially acceptable  and upgradable (Upgrading  a Study).  I will submit
       evidence of the Agency's review indicating that the study may be upgraded and what
       information is required to do so. I will provide the MRID or Accession number of the
       study at the due date. I understand that the conditions for this option outlined Option
       5 in the Data Call-In Notice (Section III-C.l.) apply.  By the  specified due date, I will
       also submit: (1) a completed "Certification With Respect To Data Compensation
       Requirements" form (EPA Form 8570-34) and (2) two completed and signed copies
       of the Confidential Statement of Formula (EPA Form 8570-4)
                                    152

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       6.     By the specified due date, I will cite an existing study that the Agency has classified as
             acceptable or an existing study that has been submitted but not reviewed by the Agency
             (Citing an Existing Study). If I am citing another registrant's study, I understand that
             this option is available only for acute toxicity or certain efficacy data and only if the cited
             study was conducted on my product, an identical product or a product which EPA has
             "grouped" with one or more other products for purposes of depending on the same data.
             I may also choose this option if I am citing my own data. In either case, I will provide
             the MRID or Accession number(s) for the cited data on a  "Product Specific Data
             Report" form or in a similar format.  By the specified due date, I will also submit: (1) a
             completed "Certification With Respect To Data Compensation Requirements"
             form (EPA  Form  8570-34)  and  (2) two completed and signed copies of the
             Confidential Statement of Formula (EPA Form 8570-4)

       7.     I request a waiver for this study because it is inappropriate for my product (Waiver
             Request). I am attaching a complete justification for this request, including technical
             reasons, data and references to relevant EPA regulations, guidelines or policies.  [Note:
             any supplemental data must be submitted in the format required by P.R. Notice 86-5].
             I understand that this is my only opportunity to state the reasons or provide information
             in support of my  request.  If the Agency  approves  my waiver request, I will not be
             required to supply the data pursuant to Section 3(c)(2)(B) of FIFRA.  If the Agency
             denies my waiver request, I must choose a method of meeting the data requirements of
             this Notice by the due date stated by this Notice. In this case, I must, within 30 days of
             my receipt of the Agency's written decision, submit a revised "Requirements Status and
             Registrant's Response" Form indicating the option chosen.  I also understand that the
             deadline for submission of data as specified by the original data call-in notice will not
             change. By the specified due date, I will also submit: (1) a completed "Certification
             With Respect To Data Compensation Requirements" form (EPA Form 8570-34)
             and (2)  two completed and signed copies of the Confidential  Statement of Formula
             (EPA Form 8570-4)

Items 10-13.  Self-explanatory.

NOTE:      You may provide additional information that does not fit on this form in a signed letter
             that accompanies this form. For example, you may wish to report that your product has
             already  been transferred to another company or that  you have already voluntarily
             canceled this product. For these cases, please supply all relevant details so that EPA can
             ensure that its records are correct.
                                            153

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EPA'S BATCHING OF TELONE (1,3-DICHLOROPROPENE) PRODUCTS FOR MEETING
ACUTE TOXICITY DATA REQUIREMENTS FOR REREGISTRATION

       In an effort to reduce the time, resources and number of animals needed to fulfill the acute
toxicity data requirements for reregi strati on of products containing Telone (1,3-dichloropropene) as the
active ingredient, the Agency has batched products which can be considered similar for purposes of acute
toxicity. Factors considered in the sorting process include each product's active and inert ingredients
(identity,  percent  composition and biological activity),  type of formulation  (e.g.,  emulsifiable
concentrate, aerosol, wettable powder, granular, etc.), and labeling (e.g., signal word, use classification,
precautionary labeling, etc.). Note that the Agency is not describing batched products as "substantially
similar" since some products within a batch may not be considered chemically similar or have identical
use patterns.

       Using available information, batching has been accomplished by the process described in the
preceding paragraph. Notwithstanding the batching process, the Agency reserves the right to require,
at any time, acute toxicity data for an individual product should the need arise.

       Registrants of products within a batch may choose to cooperatively generate, submit or cite a
single battery of six acute toxicological studies to represent all the products within that batch. It is the
registrants' option to participate in the process with all  other registrants, only  some  of the other
registrants, or only their own products within a batch, or to generate all the required acute toxicological
studies for each of their own products.  If a registrant chooses to generate the data for a batch, he/she
must use one of the products within the batch as the test material.  If a registrant chooses to rely upon
previously submitted acute toxicity data, he/she may do so provided that the data base is complete and
valid by today's standards (see acceptance criteria attached), the formulation tested is considered by EPA
to be similar for acute toxicity, and the formulation has not been significantly altered since submission
and acceptance of the acute toxicity data. Regardless of whether new data is generated or existing data
is referenced, registrants must clearly identify the test material by  EPA Registration Number. If more
than one  confidential statement of formula (CSF) exists for a product, the registrant must indicate the
formulation actually tested by identifying the corresponding CSF.

       In deciding how to meet the product specific data requirements, registrants must follow the
directions given in the Data Call-In Notice and its attachments appended to the RED. The DCI Notice
contains two response forms which are to be completed and submitted to the Agency within 90 days of
receipt.  The first form,  "Data Call-In Response,"  asks whether the registrant will  meet the data
requirements for each product. The second form, "Requirements Status and Registrant's Response," lists
the product specific data required for each product, including the  standard six acute toxicity tests.  A
registrant who wishes to participate in a batch must decide whether he/she will provide the data or
depend on someone else to do so. If a registrant supplies the data to support a batch of products, he/she
must select one of the following options: Developing Data (Option 1), Submitting an Existing Study
(Option 4), Upgrading an Existing Study (Option 5) or Citing an Existing Study (Option 6). If a
registrant depends on another's data, he/she must choose among:  Cost Sharing  (Option 2), Offers to
Cost Share (Option 3) or Citing an Existing Study (Option 6). If a registrant does not want to participate
in a batch, the choices are Options 1, 4, 5 or 6. However, a registrant should know that choosing not
                                             154

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to participate in a batch does not preclude other registrants in the batch from citing his/her studies and
offering to cost share (Option 3) those studies.
       Ten products were found which contain Telone as the active ingredient. These products have
been placed into four batches in accordance with the active and inert ingredients and type of formulation.
Batch
1
EPA Reg. No.
62719-32
11220-01
% Active Ingredient
94.0
94.0
Formulation Type
LIQUID
LIQUID
Batch
2
EPA Reg. No.
8536-21
11220-20
62719-12
% Active Ingredient
1,3-dichloropropene ... 79.9
chloropicrin ... 15.0
1,3-dichloropropene ... 79.9
chloropicrin ... 15.0
1,3-dichloropropene ... 78.3
chloropicrin ... 16.5
Formulation Type
LIQUID
LIQUID
LIQUID
Batch
3
EPA Reg. No.
8536-22
11220-21
11220-22
% Active Ingredient
1,3-dichloropropene ... 65.8
chloropicrin ... 29.7
1,3-dichloropropene ... 65.8
chloropicrin ... 29.7
1,3-dichloropropene ... 61.1
chloropicrin ... 34.65
Formulation Type
LIQUID
LIQUID
LIQUID
                                              155

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Batch
4
EPA Reg. No.
8536-08
11220-15
% Active Ingredient
1,3-dichloropropene ... 37.6
chloropicrin ... 59.4
1,3-dichloropropene ... 35.3
chloronicrin ... 58.8
Formulation Type
LIQUID
LIQUID
The following summarizes acute data requirement by batch:

•      Registrants with products in Batch 1 need to cite/submit all acute data on one of the subject
       products.
•      Registrants with products in Batch 2 need to cite/submit all acute data on one of the subject
       products.
•      Registrants with products in Batch 3 need to cite/submit all acute data on one of the subject
       products.
•      Registrants with products in Batch 4 need to cite/submit all acute data on one of the subject
       products.
                                             156

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  This page has been inserted as a place marker and is replaced by an electronically generated PDCI
List of Registrants page number 1 in the actual Printed version of the Red document
                                            157

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158

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       LIST OF AVAILABLE RELATED DOCUMENTS AND ELECTRONICALLY
                                 AVAILABLE FORMS
Pesticide Registration Forms are available at the following EPA internet site:
http ://www. epa. gov/opprdOO I/forms/.

Pesticide Registration Forms (These forms are in PDF format and require the Acrobat reader)

Instructions

   1.   Print out and complete the forms. (Note: Form numbers that are bolded can be filled out on your
       computer then printed.)

    2.  The completed form(s) should be submitted in hardcopy in accord with the existing policy.

   3.  Mail the forms, along with any additional documents necessary to comply with EPA regulations
       covering your request, to the address below for the Document Processing Desk.
       DO NOT  fax or e-mail any form containing 'Confidential Business Information'
       or 'Sensitive Information.'

   If you have any problems accessing these forms, please contact Nicole Williams at (703) 308-5551
or by e-mail atwilliams.nicole@epamail.epa.gov.

The following Agency Pesticide Registration Forms are currently available via the internet:
at the following locations:
8570-1
8570-4
8570-32
8570-34
8570-35
8570-36
8570-37
Application for Pesticide
Registration/Amendment
Confidential Statement of Formula
Certification of Attempt to Enter into an
Agreement with other Restraints for
Development of Data
Certification with Respect to Citations of Data
(in PR Notice 98-5)
Data Matrix (in PR Notice 98-5)
Summary of the Physical/Chemical Properties
(in PR Notice 98-1)
Self-Certification Statement for the
Physical/Chemical Properties (in PR Notice
98-1)
http://www.epa.gov/opprd001/forms/8570-l.pdf.

http://www.epa.gov/opprd001/forms/8570-4.pdf.
http://www.epa.gov/opprd001/forms/8570-32.pdf.

http://www.epa.gov/opppmsdl/PR Notices/pr98-5.pdf.

http://www.epa.gov/opppmsdl/PR Notices/pr98-5.pdf.
http://www.epa.gov/opppmsdl/PR Notices/pr98-l .pdf.

http://www.epa.gov/opppmsdl/PR Notices/pr98-l .pdf.

                                           159

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8570-5
8570-17
8570-25
8570-27
8570-28
8570-30
Notice of Supplemental Registration of
Distribution of a Registered Pesticide Product
Application for an Experimental Use Permit
Application for/Notification of State
Registration of a Pesticide To Meet a Special
Local Need
Formulator's Exemption Statement
Certification of Compliance with Data Gap
Procedures
Pesticide Registration Maintenance Fee Filing
http://www.epa.gov/opprd001/forms/8570-5.pdf.

http://www.epa. gov/opprdOO l/forms/8570- 1 7.pdf.

http://www.epa.gov/opprd001/forms/8570-25.pdf.

http://www.epa.gov/opprd001/forms/8570-27.pdf.
http://www.epa.gov/opprd001/forms/8570-28.pdf.

http://www.epa.gov/opprd001/forms/8570-30.pdf.
160

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Pesticide Registration Kit         www.epa.gov/pesticides/registrationkit/.

       Dear Registrant:

       For your convenience, we have assembled an online registration kit which contains the following
pertinent forms and information needed to register a pesticide product with the U.S. Environmental
Protection Agency's Office of Pesticide Programs (OPP):

       1.      The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food,
              Drug and Cosmetic Act (FFDCA) as Amended by the Food Quality Protection Act
              (FQPA)of 1996.
       2.      Pesticide Registration (PR) Notices
              a.     83-3 Label Improvement Program-Storage and Disposal Statements
              b.     84-1 Clarification of Label Improvement Program
              c.     86-5 Standard Format for Data Submitted under FIFRA
              d.     87-1 Label Improvement Program for Pesticides Applied through Irrigation
                    Systems (Chemigation)
              e.     87-6 Inert Ingredients in Pesticide Products Policy Statement
              f      90-1 Inert Ingredients in Pesticide Products; Revised Policy Statement
              g.     95-2 Notifications, Non-notifications, and Minor Formulation Amendments
              h.     98-1 Self Certification of Product Chemistry Data with Attachments  (This
                    document is in PDF format and requires the Acrobat reader.)
              Other PR Notices can be found at http://www.epa.gov/opppmsdl/PR_Notices.
       3.      Pesticide Product Registration Application Forms (These forms are in PDF format and
              will require the Acrobat reader.)
              a.     EPA Form No. 8570-1, Application for Pesticide Registration/Amendment
              b.     EPA Form No. 8570-4, Confidential Statement of Formula
              c.     EPA Form No. 8570-27,  Formulator's Exemption Statement
              d.     EPA Form No. 8570-34,  Certification with Respect to Citations of Data
              e.     EPA Form No. 8570-35,  Data Matrix
       4.      General Pesticide Information (Some of these forms are in PDF format and will require
              the Acrobat reader.)
              a.     Registration Division Personnel Contact List
              b.     Biopesticides and Pollution Prevention Division (BPPD)  Contacts
              c.     Antimicrobials Division Organizational Structure/Contact List
              d.     53 F.R. 15952, Pesticide Registration Procedures; Pesticide Data Requirements
                    (PDF format)
              e.     40 CFR Part 156, Labeling Requirements for Pesticides and  Devices (PDF
                    format)
              f.      40 CFR Part 158, Data Requirements for Registration  (PDF format)
              g.     50 F.R. 48833, Disclosure of Reviews of Pesticide Data (November 27, 1985)

       Before submitting your application for registration, you may wish to consult some additional
sources of information.
       These include:
       1.      The Office of Pesticide Programs' Web Site


                                           161

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       2.      The booklet "General Information on Applying for Registration of Pesticides in the
              United States", PB92-221811, available through the National Technical Information
              Service (NTIS) the following address:
         National Technical Information Service (NTIS)
         5285 Port Royal Road
         Springfield, VA 22161

       The telephone number for NTIS is (703) 605-6000. Please note that EPA is currently in the
process of updating this booklet to reflect the changes in the registration program resulting from the
passage of the FQPA and the reorganization of the Office of Pesticide Programs. We anticipate that this
publication will become available  during the Fall of 1998.
   3.   The National Pesticide Information Retrieval System (NPIRS) of Purdue University's Center for
       Environmental  and Regulatory Information Systems. This service does  charge  a  fee for
       subscriptions and custom searches. You can contact NPIRS by telephone at (765) 494-6614 or
       through their Web site.
  4.   The National Pesticide Telecommunications Network (NPTN) can provide information on active
       ingredients, uses, toxicology, and chemistry of pesticides. You can contact NPTN by telephone
       at 1-800-858-7378 or through their Web site.

  The Agency will return a notice of receipt of an application for registration or amended registration,
experimental use permit, or amendment to a petition if the applicant or petitioner encloses with his
submission a stamped, self-addressed postcard. The postcard must contain the following entries to be
completed by OPP:

      Date of receipt
      EPA identifying number
      the Product Manager assignment

  Other identifying information may be included by the applicant to link the acknowledgment of receipt
to the specific application submitted. EPA will stamp the date of receipt and provide the EPA identifying
File Symbol or petition number  for the new submission. The identifying number should be used
whenever you contact the Agency concerning an application for registration, experimental use permit,
or tolerance petition.

    To assist us in ensuring that all data you have submitted for the chemical are properly coded and
assigned to your company, please include a list of all synonyms, common and trade names, company
experimental codes, and other names which identify the chemical (including "blind" codes used when
a sample was submitted for testing by commercial or academic facilities). Please provide a CAS number
if one has been assigned.
                                            162

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                        Documents Associated with this RED

       The following is a list of available documents for 1,3-Dichloropropene that may further assist
you in responding to this Reregi strati on Eligibility Decision document.  These documents may be
obtained by the following methods:

Electronic
File format:   Portable Document Format (.PDF) Requires Adobe® Acrobat or compatible reader.
             Electronic copies are available on our website at www.epa.gov/REDs, or contact
                    LisaNisenson at (703) 308-8031.

       1.     PR Notice 86-5.

       2.     PR Notice 91-2 (pertains to the Label Ingredient Statement).

       3.     A full copy of this RED document.

       4.     A copy of the fact sheet for 1,3-Dichloropropene.

       The following documents are part of the Administrative Record for 1,3-Dichloropropene and
may be included in the EPA's Office of Pesticide Programs Public Docket.  Copies of these documents
are not available electronically, but may be obtained by contacting the person listed on the Chemical
Status Sheet.

       1.     Health and Environmental Effects Science Chapters.

       2.     Detailed Label Usage Information System (LUIS) Report.

       3.     Appendix A - Table of Use Patterns Subj ect to Reregi strati on

       The following Agency reference documents are not available electronically, but may be obtained
by contacting the person  listed on the Chemical Status Sheet of this RED document.

       1.     The Label Review Manual.

       2.     EPA Acceptance Criteria.
                                           163

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Report  Run  Date:  09/29/98   )   Time  09:54
PRO Report  Date:  01/27/97
LUIS 5.2  - Page:
                                                     APPENDIX A REPORT
                                THE FOLLOWING WERE THE REGISTERED USES AS OF JANUARY 27,1997
                      ALL USES ARE ELIGIBLE FOR REREGISTRATION SUBJECT TO RISK MITIGATION MEASURES

Case 0328  [Telone] Chemical 029001 [1,3-Dichloropropene]
SITE Application Type, Application
  Timing, Application Equipment )
  Surface Type (Antimicrobial only)  & Effica-
  cy Influencing Factor (Antimicrobial only)
                               Form(s)  Min. Appl.     Max. Appl.  Soil Max. # Apps Max. Dose  [(AI  Min.  Re-
FOOD/FEED USES
AGRICULTURAL CROPS/SOILS (UNSPECIFIED)
                                                      Use Group: TERRESTRIAL FOOD+FEED CROP

                                                   404 Ib A  *  NS    NS       NS     NS  NS  NS    OR


                                                   404 Ib A  *  NS    NS       NS     NS  NS  NS    WA

                                                      Use Group: TERRESTRIAL FEED CROP

                                                 363.6 Ib A  *  NS    NS       NS     NS  NS  3d
                                                      Use Group: TERRESTRIAL FOOD+FEED CROP

                                                 1030.2 Ib A  *  NS    NS       NS     NS  NS  3d
                                                      Use Group: TERRESTRIAL FOOD CROP

                                                 1030.2 Ib A  *  NS    NS       NS     NS  NS  3d
                                                      Use Group: TERRESTRIAL FOOD CROP

                                                 363.6 Ib A  *  NS    NS       NS     NS  NS  3d

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Report  Run  Date:   09/29/98    )    Time  09:54
PRO  Report  Date:   01/27/97
LUIS  5.2  -  Page:       2
                                                                APPENDIX A REPORT
Case  0328   [Telone]  Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application        Form(s)  Min. Appl.      Max.  Appl.  Soil Max. # Apps Max. Dose  [(AI   Min.  Re-       Geographic Limitations	  Use
  Timing, Application Equipment  )                Rate (AI un-      Rate  (AI  Tex. @ Max. Rate unless  noted    Interv Entry   Allowed          Disallowed   Limitations
  Surface Type  (Antimicrobial only) & Effica-      less noted    unless  noted Max. /crop /year otherwise)/A]   (days) Intv.                               Codes
  cy Influencing Factor (Antimicrobial only)       otherwise)      otherwise)  Dose cycle      /crop   /year
                                                                                     cycle
FOOD/FEED USES  (con't)
Soil  fumigation, Preplant, Plowsole or    RTU
chisels
BLACKBERRY
BLUEBERRY
BOYSENBERRY
                                                                  Use Group:  TERRESTRIAL FOOD+FEED CROP

                                                            363.6  Ib A   *  NS    NS        NS      NS   NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD+FEED CROP

                                                            363.6  Ib A   *  NS    NS        NS      NS   NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6  Ib A   *  NS    NS        NS      NS   NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6  Ib A   *  NS    NS        NS      NS   NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6  Ib A   *  NS    NS        NS      NS   NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6  Ib A   *  NS    NS        NS      NS   NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6  Ib A   *  NS    NS        NS      NS   NS   3d

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Report  Run Date:   09/29/98   )    Time  09:54
PRO  Report Date:   01/27/97
LUIS 5.2  -  Page:
                                                                APPENDIX  A  REPORT
Case  0328  [Telone]  Chemical  029001   [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type, Application        Form(s)   Min. Appl.      Max. Appl.  Soil Max.  # Apps Max. Dose [(AI   Min.  Re-       Geographic Limitations	  Use
  Timing, Application Equipment  )                Rate (AI un-      Rate (AI  Tex. @ Max. Rate unless noted    Interv Entry  Allowed          Disallowed   Limitations
  Surface Type  (Antimicrobial only) & Effica-      less noted    unless noted  Max. /crop /year otherwise)/A]   (days) Intv.                              Codes
  cy Influencing Factor  (Antimicrobial only)       otherwise)      otherwise)  Dose cycle      /crop    /year
                                                                                     cycle
FOOD/FEED USES  (con't)
BUCKWHEAT
Soil  fumigation, Preplant, Plowsole or    RTU
chisels
CAULIFLOWER
                                                                 Use Group: TERRESTRIAL FEED CROP

                                                            363.6 Ib A   *  NS    NS        NS     NS   NS  3d
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                            363.6 Ib A   *  NS    NS        NS     NS   NS  3d
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                            363.6 Ib A   *  NS    NS        NS     NS   NS  3d
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                            363.6 Ib A   *  NS    NS        NS     NS   NS  3d
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                            363.6 Ib A   *  NS    NS        NS     NS   NS  3d

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Report  Run  Date:   09/29/98    )   Time  09:55
PRO  Report  Date:   01/27/97
LUIS  5.2  -  Page:
                                                                 APPENDIX A  REPORT
Case  0328   [Telone]   Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application       Form(s)  Min.  Appl.       Max. Appl.  Soil Max.  # Apps Max. Dose [(AI   Min.   Re-        Geographic  Limitations	  Use
  Timing, Application Equipment  )                Rate  (AI un-     Rate (AI  Tex. @ Max. Rate unless noted    Interv Entry   Allowed          Disallowed   Limitations
  Surface Type  (Antimicrobial only)  & Effica-      less  noted    unless noted  Max. /crop /year otherwise)/A]   (days)  Intv.                               Codes
  cy Influencing Factor (Antimicrobial only)       otherwise)       otherwise)  Dose cycle      /crop    /year
                                                                                      cycle
FOOD/FEED USES  (con't)
Soil  fumigation, Preplant, Plowsole  or
chisels
Soil  band treatment, Preplant, Chisel
                                                                  Use Group: TERRESTRIAL FOOD+FEED CROP
                                                                    UC
                                                              369 Ib A
                                                                  Use Group: TERRESTRIAL FEED CROP

                                                             363.6 Ib A  *  NS   NS        NS
Soil  fumigation, Preplant, Plowsole  or
chisels
                                                                  Use Group: TERRESTRIAL FOOD CROP
                                                                  Use Group: TERRESTRIAL FOOD+FEED CROP

                                                             363.6 Ib A  *  NS   NS        NS      NS   NS   3d
                                                                  Use Group: TERRESTRIAL FOOD+FEED CROP

                                                             363.6 Ib A  *  NS   NS        NS      NS   NS   3d
Soil  fumigation, Preplant, Plowsole  or
chisels
                                                                  Use Group: TERRESTRIAL FOOD+FEED CROP

                                                             363.6 Ib A  *  NS   NS        NS      NS   NS   3d

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Report Run Date:  09/29/98
PRO  Report Date:  01/27/97
)   Time  09:55
LUIS  5.2  -  Page:
                                                                APPENDIX  A  REPORT
Case 0328  [Telone]  Chemical 029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type, Application
  Timing, Application  Equipment  )
  Surface Type  (Antimicrobial  only) & Effica-
  cy  Influencing Factor  (Antimicrobial only)
                                     Form(s)  Min.  Appl.
                                                           Max.  Appl. Soil Max. # Apps Max.  Dose [(AI   Min.  Re-
FOOD/FEED USES  (con't)
COWPEA/BLACKEYED PEA
Soil  fumigation, Preplant, Plowsole or
chisels
CRANBERRY
DECIDUOUS FRUIT TREES  (UNSPECIFIED)

Broadcast,  Preplant, Plowsole  or chisels  RTU

Soil band treatment, Preplant, Chisel    RTU
                                                                 Use Group: TERRESTRIAL FOOD+FEED CROP

                                                           363.6 Ib A   *  NS    NS         NS      NS   NS  3d
                                                                 Use Group: TERRESTRIAL FEED CROP

                                                           363.6 Ib A   *  NS    NS        NS      NS   NS  3d
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                           363.6 Ib A   *  NS    NS        NS      NS   NS  3d
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                           363.6 Ib A   *  NS    NS        NS      NS   NS  3d
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                           363.6 Ib A   *  NS    NS        NS      NS   NS  3d
                         Use Group: TERRESTRIAL FOOD+FEED CROP

                   373.68 Ib A   *  NS    NS         NS      NS   NS   5 d
                                                           9.748 Ib IK   *  NS    NS         NS      NS   NS  5 d
                                                            linear ft

-------
Report  Run  Date:   09/29/98
PRO  Report  Date:   01/27/97
)   Time  09:55
LUIS  5.2  -  Page:
                                                                 APPENDIX  A  REPORT
Case  0328   [Telone]   Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application       Form(s)  Min.  Appl.      Max. Appl.  Soil Max.  # Apps Max.  Dose [(AI   Min.  Re-        Geographic Limitations	  Use
  Timing, Application Equipment  )               Rate  (AI un-     Rate (AI  Tex. @ Max. Rate unless noted    Interv Entry   Allowed          Disallowed   Limitations
  Surface Type  (Antimicrobial only)  & Effica-     less  noted    unless noted  Max. /crop /year otherwise)/A]    (days) Intv.                               Codes
  cy Influencing Factor (Antimicrobial only)       otherwise)      otherwise)  Dose cycle      /crop   /year
                                                                                      cycle
FOOD/FEED USES  (con't)
Soil  fumigation, Preplant, Plowsole  or
chisels
ENDIVE  (ESCAROLE)
FIELD CROPS (UNSPECIFIED)

Broadcast, Preplant, Plowsole or chisels  RTU

Soil band treatment, Preplant, Chisel     RTU
FILBERT  (HAZELNUT)
                         Use Group: TERRESTRIAL FOOD CROP

                    363.6 Ib A   *  NS    NS         NS      NS   NS   3d


                         Use Group: TERRESTRIAL FOOD CROP

                    363.6 Ib A   *  NS    NS         NS      NS   NS   3d


                         Use Group: TERRESTRIAL FOOD+FEED CROP

                   192.24 Ib A   *  NS    NS         NS      NS   NS   5 d

                   5.012 Ib IK   *  NS    NS         NS      NS   NS   5 d
                     linear ft

                    181.8 Ib A   *  NS    NS         NS
                                                                  Use Group: TERRESTRIAL FOOD  CROP

                                                            1030.2 Ib A  *  NS    NS        NS      NS   NS   3d
                                                                  Use Group: TERRESTRIAL FOOD+FEED CROP

                                                             363.6 Ib A  *  NS    NS         NS      NS   NS   3d

-------
Report Run Date:  09/29/98
PRO  Report Date:  01/27/97
)   Time  09:55
                                  LUIS  5.2  -  Page:
                                                               APPENDIX  A  REPORT
Case 0328  [Telone]  Chemical 029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type, Application
  Timing, Application  Equipment  )
  Surface Type  (Antimicrobial  only)  &  Effica-
  cy  Influencing Factor  (Antimicrobial only)
                                     Form(s)  Min. Appl.
                                                           Max.  Appl. Soil Max. # Apps Max. Dose [(AI   Min.  Re-
FOOD/FEED USES  (con't)
FRUITS  (UNSPECIFIED)

Broadcast,  Preplant,  Plowsole  or chisels  RTU

Soil band treatment,  Preplant, Chisel    RTU
GRAPEFRUIT
GRASS FORAGE/FODDER/HAY
                         Use Group: TERRESTRIAL

                   369.6 Ib A   *  NS    NS
                                                          3.4375 Ib IK   *  NS    NS
                                                            linear ft
                                                           353.5  Ib A   *  NS    NS
                                                                Use Group: TERRESTRIAL

                                                           363.6 Ib A   *  NS    NS
                                                                Use Group: TERRESTRIAL

                                                           363.6 Ib A   *  NS    NS
                                                                Use Group: TERRESTRIAL

                                                          1030.2 Ib A   *  NS    NS
                                                                Use Group: TERRESTRIAL

                                                          1030.2 Ib A   *  NS    NS
                                                                Use Group: TERRESTRIAL

                                                           363.6 Ib A   *  NS    NS
                                                                Use Group: TERRESTRIAL

                                                          1030.2 Ib A   *  NS    NS
FOOD+FEED CROP

   NS      NS

   NS      NS
                                             FOOD CROP

                                                NS      NS
                                             FOOD+FEED CROP

                                                 NS      NS


                                             FOOD+FEED CROP

                                                 NS      NS


                                             FEED CROP

                                                 NS      NS


                                             FOOD CROP

                                                 NS      NS

-------
Report  Run  Date:   09/29/98    )    Time  09:55
PRO  Report  Date:   01/27/97
LUIS  5.2  -  Page:
                                                                APPENDIX A REPORT
Case  0328   [Telone]  Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application        Form(s)  Min. Appl.      Max.  Appl.  Soil Max. # Apps Max. Dose  [(AI   Min.  Re-       Geographic Limitations	  Use
  Timing, Application Equipment  )                Rate (AI un-      Rate  (AI  Tex. @ Max. Rate unless  noted    Interv Entry   Allowed          Disallowed   Limitations
  Surface Type  (Antimicrobial only) & Effica-      less noted    unless  noted Max. /crop /year otherwise)/A]   (days) Intv.                               Codes
  cy Influencing Factor (Antimicrobial only)       otherwise)      otherwise)  Dose cycle      /crop   /year
                                                                                     cycle
FOOD/FEED USES  (con't)
Soil  fumigation, Preplant, Plowsole or    RTU
chisels
HORSERADISH
HUCKLEBERRY
                                                                  Use Group:  TERRESTRIAL FOOD+FEED CROP

                                                            363.6  Ib A   *  NS    NS         NS      NS  NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6  Ib A   *  NS    NS         NS      NS  NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6  Ib A   *  NS    NS         NS      NS  NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6  Ib A   *  NS    NS         NS      NS  NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6  Ib A   *  NS    NS         NS      NS  NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD+FEED CROP

                                                           1030.2  Ib A   *  NS    NS         NS      NS  NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD+FEED CROP

                                                           1030.2  Ib A   *  NS    NS         NS      NS  NS   3d

-------
Report  Run  Date:   09/29/98    )    Time  09:55
PRO  Report  Date:   01/27/97
LUIS  5.2  -  Page:
                                                                 APPENDIX A REPORT
Case  0328   [Telone]   Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application       Form(s)  Min. Appl.      Max.  Appl. Soil Max. # Apps Max. Dose  [(AI   Min.  Re-       Geographic Limitations	  Use
  Timing, Application Equipment  )                Rate  (AI un-      Rate  (AI Tex.  @ Max. Rate unless noted    Interv Entry   Allowed          Disallowed   Limitations
  Surface Type  (Antimicrobial only)  & Effica-      less noted   unless  noted Max.  /crop /year otherwise)/A]   (days) Intv.                               Codes
  cy Influencing Factor (Antimicrobial only)       otherwise)      otherwise) Dose cycle      /crop   /year
                                                                                     cycle
FOOD/FEED USES  (con't)
LESPEDEZA
Soil  fumigation, Preplant, Plowsole or
chisels
LOGANBERRY
MELONS, CANTALOUPE
                                                                  Use Group:  TERRESTRIAL FEED CROP

                                                            363.6 Ib A   *  NS    NS        NS     NS   NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6 Ib A   *  NS    NS        NS     NS   NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD+FEED CROP

                                                            1030.2 Ib A   *  NS    NS        NS     NS   NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                            363.6 Ib A   *  NS    NS        NS     NS   NS   3d
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                             90.9 Ib A   *  NS    NS        NS     NS   NS   3 d   AZ
                                                                  Use Group:  TERRESTRIAL FOOD CROP

                                                             90.9 Ib A   *  NS    NS        NS     NS   NS   3 d   AZ


                                                            363.6 Ib A   *  NS    NS
MELONS, HONEYDEW
                                                                  Use Group:  TERRESTRIAL FOOD CROP

-------
Report Run Date:  09/29/98
PRO  Report Date:  01/27/97
)   Time  09:55
                                                             LUIS  5.2  -  Page:
10
                                                                APPENDIX  A  REPORT
Case  0328  [Telone]  Chemical 029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type, Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only) & Effica-
  cy  Influencing Factor  (Antimicrobial only)
                                     Form(s)  Min.  Appl.
                                                           Max.  Appl. Soil Max. # Apps Max.  Dose [(AI   Min.  Re-
FOOD/FEED USES  (con't)
MELONS, HONEYDEW (con't)
Soil  fumigation, Preplant, Drip
irrigation
MELONS, WATER
Soil  fumigation, Preplant, Drip
irrigation
MILLET  (FOXTAIL)
Soil  fumigation, Preplant, Plowsole or
chisels
                                     RTU

                                     RTU
Soil  fumigation, Preplant, Plowsole or
chisels
     NA

     NA
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                            90.9 Ib A   *  NS    NS        NS
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                            90.9 Ib A   *  NS    NS        NS
                                                                 Use Group: TERRESTRIAL FEED CROP
      Use Group: TERRESTRIAL  FOOD+FEED CROP

 363.6 Ib A  *  NS   NS        NS     NS   NS   3d


      Use Group: TERRESTRIAL  FOOD+FEED CROP

277.92 Ib A  *  NS   NS        NS     NS   NS   5 d

               NS   NS        NS     NS   NS   5 d


                              NS

-------
Report  Run  Date:   09/29/98    )   Time  09:55
PRO  Report  Date:   01/27/97
                                                              LUIS  5.2  -  Page:     11
                                                                 APPENDIX  A  REPORT
Case  0328   [Telone]   Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application       Form(s)  Min.  Appl.      Max. Appl.  Soil Max.  # Apps Max.  Dose [(AI   Min.  Re-        Geographic Limitations	  Use
  Timing, Application Equipment  )               Rate  (AI un-     Rate (AI  Tex. @ Max. Rate unless noted    Interv Entry   Allowed          Disallowed   Limitations
  Surface Type  (Antimicrobial only)  & Effica-     less  noted    unless noted  Max. /crop /year otherwise)/A]    (days) Intv.                               Codes
  cy Influencing Factor (Antimicrobial only)       otherwise)      otherwise)  Dose cycle      /crop   /year
                                                                                      cycle
FOOD/FEED USES  (con't)
Soil  fumigation, Preplant, Plowsole  or    RTU
chisels
NECTARINE
ONION

Broadcast, Preplant, Plowsole or chisels  RTU

Soil band treatment, Preplant, Chisel     RTU
      Use Group: TERRESTRIAL FOOD+FEED CROP

 363.6 Ib A   *  NS    NS         NS      NS  NS   3d


      Use Group: TERRESTRIAL FOOD CROP

1030.2 Ib A   *  NS    NS         NS      NS  NS   3d


      Use Group: TERRESTRIAL FOOD+FEED CROP

 363.6 Ib A   *  NS    NS         NS      NS  NS   3d


      Use Group: TERRESTRIAL FOOD CROP

 363.6 Ib A   *  NS    NS         NS      NS  NS   3d


      Use Group: TERRESTRIAL FOOD CROP

1030.2 Ib A   *  NS    NS         NS      NS  NS   3d


      Use Group: TERRESTRIAL FOOD CROP

267.12 Ib A   *  NS    NS         NS      NS  NS   5 d

6.964 Ib IK   *  NS    NS         NS      NS  NS   5 d
  linear ft
 262.8 Ib A   *

 363.6 Ib A   *  NS    NS         NS
                                                                                           NS      NS   NS

-------
Report  Run  Date:   09/29/98
PRO  Report  Date:   01/27/97
)   Time  09:55
LUIS  5.2  -  Page:
12
                                                                 APPENDIX  A  REPORT
Case  0328   [Telone]   Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application       Form(s)  Min.  Appl.      Max. Appl.  Soil Max.  # Apps Max.  Dose [(AI   Min.  Re-        Geographic Limitations	  Use
  Timing, Application Equipment  )               Rate  (AI un-     Rate (AI  Tex. @ Max. Rate unless noted    Interv Entry   Allowed          Disallowed   Limitations
  Surface Type  (Antimicrobial only)  & Effica-     less  noted    unless noted  Max. /crop /year otherwise)/A]    (days) Intv.                               Codes
  cy Influencing Factor (Antimicrobial only)       otherwise)      otherwise)  Dose cycle      /crop   /year
                                                                                      cycle
FOOD/FEED USES  (con't)
Soil  fumigation, Preplant, Plowsole  or
chisels
PEANUTS  (UNSPECIFIED)

Broadcast, Preplant, Plowsole or chisels  RTU     NA

Soil  band treatment, Preplant, Chisel     RTU     NA
PEAS  (UNSPECIFIED)
                                                                  Use Group: TERRESTRIAL FOOD+FEED CROP

                                                            1030.2 Ib A  *  NS    NS         NS      NS   NS   3d
                                                                  Use Group: TERRESTRIAL FOOD+FEED CROP

                                                             363.6 Ib A  *  NS    NS         NS      NS   NS   3d
                                                                  Use Group: TERRESTRIAL FEED CROP

                                                             363.6 Ib A  *  NS    NS        NS      NS   NS   3d
                         Use Group: TERRESTRIAL FOOD+FEED CROP

                   192.24 Ib A   *  NS    NS         NS      NS  NS   5 d

                   5.012 Ib IK   *  NS    NS         NS      NS  NS   5 d
                     linear ft
                                                  NS


                         Use Group: TERRESTRIAL FOOD CROP

                   1030.2 Ib A   *  NS    NS         NS      NS   NS   3d


                         Use Group: TERRESTRIAL FOOD+FEED CROP

                    363.6 Ib A   *  NS    NS         NS      NS   NS   3d

-------
Report  Run Date:   09/29/98   )    Time  09:56
PRO  Report Date:   01/27/97
LUIS 5.2  -  Page:     13
                                                                APPENDIX A REPORT
Case  0328  [Telone]  Chemical  029001   [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type, Application        Form(s)  Min. Appl.      Max. Appl.  Soil Max.  # Apps Max. Dose [(AI   Min.  Re-       Geographic Limitations	  Use
  Timing, Application Equipment   )               Rate (AI un-      Rate (AI  Tex. @ Max. Rate unless noted    Interv Entry  Allowed         Disallowed   Limitations
  Surface Type  (Antimicrobial only) & Effica-     less noted    unless noted  Max. /crop /year otherwise)/A]   (days) Intv.                              Codes
  cy Influencing Factor  (Antimicrobial only)      otherwise)      otherwise)  Dose cycle      /crop    /year
                                                                                     cycle
FOOD/FEED USES  (con't)
Soil  fumigation, Preplant, Plowsole or    RTU
chisels
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                            363.6 Ib A  *  NS   NS        NS     NS   NS   3d
PERSIMMON
PINEAPPLE
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                            363.6 Ib A  *  NS   NS        NS     NS   NS   3d
                                                                 Use Group: TERRESTRIAL FOOD+FEED CROP

                                                            363.6 Ib A  *  NS   NS        NS     NS   NS   3d
POMEGRANATE
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                           1030.2 Ib A  *  NS   NS        NS     NS   NS   3d
                                                                 Use Group: TERRESTRIAL FOOD+FEED CROP
                                                                   UC  *  NS   NS        NS     NS   NS   5 d
                                                           267.12 Ib A  *

-------
Report Run  Date:  09/29/98
PRO  Report  Date:  01/27/97
)   Time  09:56
LUIS  5.2  -  Page:
14
                                                               APPENDIX A REPORT
Case 0328  [Telone]  Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type, Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only)  &  Effica-
  cy  Influencing Factor (Antimicrobial only)
                                     Form(s)  Min. Appl.
                                                           Max. Appl.  Soil Max.  # Apps Max. Dose  [(AI   Min.  Re-
FOOD/FEED USES  (con't)
POTATO, WHITE/IRISH (con't)

Soil band treatment,  Preplant, Chisel


Soil fumigation, Preplant,  Chisel
                                                                Use Group: TERRESTRIAL FOOD+FEED CROP (con't)
Soil  fumigation, Preplant,  Plowsole or
chisels
RASPBERRY (BLACK, RED)
Soil  fumigation, Preplant,  Plowsole or
chisels
                                     RTU

                                     RTU
                                                           252.5 Ib A   *  NS   NS        NS

                                                                Use Group: TERRESTRIAL FOOD CROP

                                                          1030.2 Ib A   *  NS   NS        NS
                                                                Use Group: TERRESTRIAL FOOD CROP

                                                          1030.2 Ib A   *  NS   NS        NS
                                                                Use Group: TERRESTRIAL FOOD CROP

                                                           363.6 Ib A   *  NS   NS        NS

-------
Report  Run  Date:   09/29/98   )    Time  09:56
PRO  Report  Date:   01/27/97
LUIS  5.2  -  Page:     15
                                                                APPENDIX  A  REPORT
Case  0328   [Telone]  Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application        Form(s)   Min. Appl.      Max. Appl.  Soil Max. # Apps Max.  Dose [(AI   Min.  Re-        Geographic Limitations	  Use
  Timing, Application Equipment  )                Rate (AI un-      Rate  (AI  Tex. @ Max.  Rate unless noted    Interv Entry   Allowed          Disallowed   Limitations
  Surface Type  (Antimicrobial only) & Effica-      less noted    unless noted Max. /crop /year otherwise)/A]    (days) Intv.                               Codes
  cy Influencing Factor (Antimicrobial only)       otherwise)      otherwise)  Dose cycle      /crop   /year
                                                                                     cycle
FOOD/FEED USES  (con't)
Soil  fumigation, Preplant, Plowsole or    RTU
chisels
SAFFLOWER
                                                                 Use Group: TERRESTRIAL FOOD+FEED CROP

                                                            363.6 Ib A   *  NS    NS         NS      NS   NS   3d
                                                                 Use Group: TERRESTRIAL FOOD+FEED CROP

                                                            363.6 Ib A   *  NS    NS         NS      NS   NS   3d
                                                                 Use Group: TERRESTRIAL FOOD  CROP

                                                            363.6 Ib A   *  NS    NS        NS      NS   NS   3d
                                                                 Use Group: TERRESTRIAL FOOD  CROP

                                                            363.6 Ib A   *  NS    NS        NS      NS   NS   3d
                                                                 Use Group: TERRESTRIAL FEED  CROP

                                                            363.6 Ib A   *  NS    NS        NS      NS   NS   3d
                                                                 Use Group: TERRESTRIAL FOOD+FEED CROP

                                                            363.6 Ib A   *  NS    NS         NS      NS   NS   3d
                                                                 Use Group: TERRESTRIAL FOOD+FEED CROP

                                                            363.6 Ib A   *  NS    NS         NS      NS   NS   3d

-------
Report  Run  Date:   09/29/98    )    Time  09:56
PRO  Report  Date:   01/27/97
LUIS  5.2  -  Page:      16
                                                                 APPENDIX A REPORT
Case  0328   [Telone]   Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application       Form(s)  Min.  Appl.      Max. Appl. Soil Max.  # Apps Max. Dose [(AI   Min.   Re-       Geographic Limitations	  Use
  Timing, Application Equipment  )                Rate  (AI un-     Rate (AI Tex. @ Max. Rate unless noted    Interv  Entry   Allowed          Disallowed   Limitations
  Surface Type  (Antimicrobial only)  & Effica-      less  noted    unless noted Max. /crop /year otherwise)/A]   (days)  Intv.                               Codes
  cy Influencing Factor (Antimicrobial only)       otherwise)      otherwise) Dose cycle      /crop    /year
                                                                                      cycle
FOOD/FEED USES  (con't)
Soil  band treatment, Preplant, Chisel
                                                                  Use  Group: TERRESTRIAL FOOD+FEED CROP
                                                            4.289 Ib IK
                                                             linear ft
                   C13,  C46, CAL,  CAU


                   C13,  C46, CAL,  CAU


                   C13,  C46, C92,  CAS
                                                                            TERRESTRIAL FOOD CROP
                                                                                                  NS   NS   3d
SQUASH  (SUMMER)
Soil  fumigation, Preplant, Plowsole  or
chisels
                                                                            TERRESTRIAL FOOD CROP
                                                                            TERRESTRIAL FOOD CROP
                                                                                                  NS   NS   3d
STRAWBERRY
                                                                            TERRESTRIAL FOOD CROP
                                                                                                  NS   NS   3d
Soil  band treatment, Preplant, Chisel
                                                                  Use  Group: TERRESTRIAL FOOD+FEED CROP

                                                                    UC  *  NS   NS        NS      NS   NS
                                                            4.289 Ib IK
                                                             linear ft
                                                             4.211 Ib A

-------
Report  Run Date:   09/29/98
PRO  Report Date:   01/27/97
)   Time  09:56
LUIS 5.2  -  Page:
17
                                                                APPENDIX A  REPORT
Case  0328  [Telone]  Chemical  029001   [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type, Application
  Timing, Application Equipment   )
  Surface Type  (Antimicrobial only) & Effica-
  cy  Influencing Factor  (Antimicrobial only)
                                      Form(s)  Min. Appl.
                                                            Max. Appl.  Soil Max.  # Apps Max. Dose [(AI   Min.  Re-
FOOD/FEED USES  (con't)
SUGAR BEET (con't)
Soil  fumigation, Preplant, Plowsole or    RTU
chisels
SUGARCANE
SWEET POTATO

Broadcast, Preplant,  Plowsole or  chisels   RTU

Soil band treatment,  Preplant,  Chisel     RTU
Soil  fumigation, Preplant, Plowsole or    RTU
chisels
TANGERINES
TREE NUTS

Broadcast, Preplant,  Plowsole or  chisels   RTU
                                                           5.977 Ib IK
                                                             linear ft
                                                            262.8 Ib A
                                 :  TERRESTRIAL FOOD+FEED CROP (con't)

                                  NS    NS        NS     NS   NS   3d


                                 :  TERRESTRIAL FOOD+FEED CROP

                                  NS    NS        NS     NS   NS   3d


                                 :  TERRESTRIAL FOOD CROP

                                  NS    NS        NS     NS   NS   5 d

                                  NS    NS        NS     NS   NS   5 d
                                                                 Use Group:

                                                           1030.2 Ib A  *
                                 :  TERRESTRIAL FOOD+FEED CROP

                                  NS    NS        NS     NS   NS   3d


                                 :  TERRESTRIAL FOOD+FEED CROP

                                  NS    NS        NS     NS   NS   3d


                                 :  TERRESTRIAL FOOD+FEED CROP

                                  NS    NS        NS     NS   NS   3d


                                 :  TERRESTRIAL FOOD+FEED CROP

                                  NS    NS        NS     NS   NS   5 d

-------
Report  Run  Date:   09/29/98
PRO  Report  Date:   01/27/97
)   Time  09:56
                                   LUIS  5.2  -  Page:
18
                                                                APPENDIX A REPORT
Case  0328   [Telone]  Chemical  029001   [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type, Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only) & Effica-
  cy Influencing Factor  (Antimicrobial only)
                                      Form(s)  Min. Appl.
                                                            Max. Appl.  Soil Max.  # Apps Max. Dose [(AI   Min.  Re-
FOOD/FEED USES  (con't)
)))))))))))))))))))

TREE  NUTS (con't)

Soil  band treatment,  Preplant,  Chisel
VEGETABLES (UNSPECIFIED)

Broadcast, Preplant,  Plowsole or  chisels   RTU

Soil  band treatment,  Preplant,  Chisel     RTU
WALNUT  (ENGLISH/BLACK)
Soil  fumigation, Preplant, Plowsole or
chisels
                         Use Group:  TERRESTRIAL

                   9.748 Ib IK   *  NS    NS
                    linear ft
                         Use Group:  TERRESTRIAL

                    363.6 Ib A   *  NS    NS


                         Use Group:  TERRESTRIAL

                    363.6 Ib A   *  NS    NS


                         Use Group:  TERRESTRIAL

                   267.12 Ib A   *  NS    NS

                   6.964 Ib IK   *  NS    NS
                    linear ft
FOOD+FEED

    NS


    NS


FEED CROP

    NS


FOOD+FEED

    NS
                                                                          NS
                                                                               NS
                                                                 Use Group: TERRESTRIAL

                                                            363.6 Ib A  *  NS   NS
                                             FEED CROP

                                                 NS

-------
Report  Run  Date:   09/29/98
PRO  Report  Date:   01/27/97
)   Time  09:56
LUIS  5.2  -  Page:
19
                                                                APPENDIX  A REPORT
Case  0328   [Telone]  Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only) & Effica-
  cy  Influencing Factor  (Antimicrobial only)
                                      Form(s)   Min. Appl.
                                                            Max.  Appl. Soil Max. # Apps Max.  Dose  [(AI  Min.  Re-
FOOD/FEED USES  (con't)
Soil  fumigation, Preplant, Plowsole or
chisels
YOUNGBERRY
                                                                 Use Group: TERRESTRIAL FOOD+FEED CROP

                                                            363.6 Ib A   *  NS    NS         NS      NS  NS   3d
                                                                 Use Group: TERRESTRIAL FOOD CROP

                                                            363.6 Ib A   *  NS    NS         NS      NS   NS   3d
NON-FOOD/NON-FEED
FOREST TREES (ALL OR UNSPECIFIED)
Soil  fumigation, Preplant, Plowsole or
chisels
                                      RTU
ORNAMENTAL AND/OR SHADE  TREES

Broadcast, Preplant, Plowsole or chisels  RTU

Soil band treatment, Preplant, Chisel     RTU
                                      RTU

ORNAMENTAL HERBACEOUS PLANTS

Broadcast, Preplant, Plowsole or chisels  RTU
                                                                 Use Group: FORESTRY

                                                           1030.2 Ib A   *  NS    NS
                         Use Group: TERRESTRIAL NON-FOOD CROP

                    363.6 Ib A  *  NS   NS        NS     NS   NS   3d


                         Use Group: TERRESTRIAL NON-FOOD CROP

                   587.52 Ib A  *  NS   NS        NS     NS   NS   5 d

                   15.32 Ib IK  *  NS   NS        NS     NS   NS   5 d
                     linear ft
                   392.85 Ib A  *
                    555.5 Ib A  *  NS   NS        NS     NS   NS   5 d

                         Use Group: TERRESTRIAL NON-FOOD CROP

                   587.52 Ib A  *  NS   NS        NS     NS   NS   5 d

-------
Report  Run  Date:   09/29/98
PRO  Report  Date:   01/27/97
)   Time  09:57
LUIS  5.2  -  Page:
20
                                                                 APPENDIX A REPORT
Case  0328   [Telone]   Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application
  Timing, Application Equipment  )
  Surface Type  (Antimicrobial only) & Effica-
  cy  Influencing Factor  (Antimicrobial only)
                                      Form(s)  Min. Appl.
                                                            Max.  Appl. Soil Max. # Apps Max. Dose  [(AI   Min.  Re-
NON-FOOD/NON-FEED  (con't)
ORNAMENTAL HERBACEOUS PLANTS (con't)

Soil band treatment, Preplant,  Chisel
ORNAMENTAL LAWNS AND TURF
ORNAMENTAL NONFLOWERING PLANTS

Broadcast, Preplant, Plowsole or chisels  RTU

Soil band treatment, Preplant, Chisel     RTU
ORNAMENTAL WOODY SHRUBS  AND VINES

Broadcast, Preplant, Plowsole or chisels  RTU

Soil band treatment, Preplant, Chisel     RTU
Soil  fumigation, Preplant, Plowsole or    RTU
chisels
                         Use Group: TERRESTRIAL NON-

                   15.32 Ib IK  *  NS   NS
                     linear ft
                   392.85 Ib A  *

                    363.6 Ib A  *  NS   NS
                                                            555.5  Ib A   *   NS    NS

                                                                  Use Group:  TERRESTRIAL NON-
                         Use Group: TERRESTRIAL NON-

                   587.52 Ib A  *  NS   NS

                   15.32 Ib IK  *  NS   NS
                     linear ft
                   392.85 Ib A  *

                    555.5 Ib A  *  NS   NS


                         Use Group: TERRESTRIAL NON-

                   587.52 Ib A  *  NS   NS
                                                            555.5  Ib A   *   NS    NS

-------
Report  Run  Date:  09/29/98
PRO  Report  Date:  01/27/97
)   Time  09:57
LUIS  5.2  -  Page:
21
                                                             APPENDIX A REPORT
Case 0328  [Telone]  Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
SITE Application Type,  Application       Form(s)
  Timing, Application Equipment  )
  Surface Type (Antimicrobial only)  &  Effica-
  cy Influencing Factor (Antimicrobial only)
                                                                                    Disallowed
NON-FOOD/NON-FEED  (con't)
TOBACCO

Broadcast, Preplant, Plowsole or chisels  RTU

Soil band treatment, Preplant,  Chisel     RTU


                                    RTU
                        Use Group: TERRESTRIAL NON-FOOD CROP

                  192.24 Ib A   *  NS   NS        NS      NS   NS   5 d

                                NS   NS        NS      NS   NS   5 d
                  5.012 Ib IK
                    linear ft
                                                                       NS
                                                                            NS
                                                                                                 NS

-------
Report  Run  Date:   09/29/98
PRD  Report  Date:   01/27/97
)   Time  09:57
LUIS  5.2  -  Page:
22
                                                                   APPENDIX  A  REPORT
Case  0328  [Telone]  Chemical  029001   [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444

LEGEND
444444
  Soil  Tex. Max.  Dose
  Max.  # Apps @ Max. Rate
                           :  Minimum Interval between Applications  (days)
                           :  Reentry Intervals
                           :  LUIS  contains all products that  were active or  suspended (and that were available from OPP Document Center) as of this  date.   Some products
                             registered after this date may have data included in this report, but LUIS  does not guarantee that all products registered after this date have
                             data  that has been captured.
  SOIL  TEXTURE FOR MAX APP. RATE
  FORMULATION CODES
  ABBREVIATIONS
           LIQUID-READY TO USE
           As Needed
           Not Applicable
           Not Specified  (on label)
           Unconverted due to lack  of data (on label), or with  one of following units:  bag, bait, bait block, bait pack, bait station, bait station(s), block,  briguet,
           briguets, bursts,  cake,  can, canister, capsule, cartridges,  coil,  collar, container, dispenser, drop, eartag, grains,  lure, pack, packet,  packets,  pad,  part,
           parts,  pellets, piece, pieces,  pill,  pumps, sec,  sec burst,  sheet,  spike, stake, stick, strip, tab, tablet,  tablets, tag,  tape, towelette, tray, unit,  --
  APPLICATION RATE
  DCNC     : Dosage Can Not be Calculated
  No Calc  : No Calculation can be  made
  W       : PPM calculated by weight
  V       : PPM Calculated by volume
  U       : Unknown whether PPM is given by weight or by volume

-------
Report  Run Date:  09/29/98   )   Time  09:57
PRO  Report Date:  01/27/97
LUIS  5.2 -  Page:
23
                                                            APPENDIX A REPORT
Case  0328  [Telone]  Chemical  029001  [1,3-Dichloropropene]
44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444
  APPLICATION RATE (CONT.)
  cwt     : Hundred Weight
  nnE-xx  : nn times  (10 power -xx);  for instance,  "1.234E-04" is equivalent to ".0001234"

  USE LIMITATIONS CODES
  * NUMBER IN PARENTHESES REPRESENTS THE NUMBER OF TIME UNITS  (HOURS,DAYS, ETC.) DESCRIBED IN THE LIMITATION.

  GEOGRAPHIC CODES
  REENTRY INTERVAL ABBREVIATIONS
  UNIT DESCRIPTIONS
  A              : acre
  Ib             : pound
  linear  ft       : linear foot

-------