United States Office of Prevention, Pesticides
                          Environmental Protection and Toxic Substances
                         	Agency (7501C)
Pesticide
Fact Sheet
Name of Chemical:    Aminopyralid
Reason for Issuance:   Conditional Registration
Date Issued:          August 10, 2005


DESCRIPTION OF CHEMICAL

Generic Name:     2-pyridine carboxylic acid, 4-amino-3,6-dichloro-

Common Name:   Aminopyralid

Trade Names:     Aminopyralid Technical
               Milestone™

EPA Chemical Code: 005100

Chemical Abstracts
Service (CAS)
Number:    150114-71-9

Year of Initial
Registration:      2005

Pesticide Type:    Herbicide

Chemical Family:  pyridine carboxylic acid

U.S. and Foreign
Producers:  Dow AgroSciences LLC
          9330 Zionsville Road
          Indianapolis, IN 46268

USE PATTERNS AND FORMULATIONS
                                -1-

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Aminopyralid is a new pyridine carboxylic acid herbicide intended for use in rangeland,
permanent grass pastures, non-cropland areas (rights-of-way, roadsides and
non-irrigation ditch banks), natural areas (wildlife management areas, natural recreation
areas, campgrounds, trailheads, and trails), and grazed areas in and around these
sites, as well as wheat. Aminopyralid provides systemic postemergence broad-spectrum
control of a number of key noxious and invasive annual, biennial and perennial weed
species, as well as agronomic broadleaf weeds. Aminopyralid can also provide residual
weed control activity controlling re-infestations and reducing the need for re-treatment
depending on the rate applied and the target weeds.  Aminopyralid Technical is a 95.3%
manufacturing use product. The aminopyralid end-use product (Milestone) will be
formulated as a soluble liquid containing 2 pounds acid equivalent per gallon and will be
applied by ground or air at rates between 0.03 and 0.11 Ib aminopyralid acid
equivalents (a.e.)/A (30 to 120 grams a.e./ha).  The total amount of Milestone applied
broadcast, as a re-treatment, and/or spot treatment, cannot exceed 7 fl oz per acre
(0.11 Ib a.e./A) per year in rangeland, permanent grass pastures and non-cropland
areas.  The total amount of Milestone used in wheat cannot exceed 0.57 fl oz per acre
(0.009 Ib a.e./A) per growing season.
SCIENCE FINDINGS

SUMMARY SCIENCE STATEMENTS

Acute toxicity data indicate that aminopyralid has low toxicity via oral, dermal and
inhalation routes of exposure.  The technical aminopyralid product is classified in toxicity
category I [DANGER] based on an acute eye irritation study conducted with the free
acid.  The formulated end-use product (Milestone) has low toxicity and is classified in
toxicity category IV [Caution].

In an acute neurotoxicity study in rats with aminopyralid, there were no
treatment-related effects on Functional Observation Battery (FOB), motor activity, or
neuropathological observations.  The systemic No Observed Adverse Effect Level
(NOAEL) was 1000 mg/kg based on transient  clinical observations of fecal soiling in
males and urine soiling in females observed at 2000 mg/kg bw, the highest dose tested
[HOT]. In a chronic neurotoxicity study in rats  the NOAEL was equal to or greater than
1,OOOmg/kg/day[HDT].

Aminopyralid was negative in all mutagenicity  studies, except for an in vitro
chromosome aberration assay utilizing rat lymphocytes.  In this assay,  aminopyralid
induced chromosome aberrations without S9 activation, but only at cytotoxic
concentrations.  The clastogenic response was induced secondary to toxicity.

In a rat developmental study the NOAEL for maternal and developmental toxicity was
equal to or greater than 1,000 mg/kg/day [HOT]. In  a developmental toxicity study in
rabbits with aminopyralid, the NOAEL for maternal toxicity was 250 mg/kg/day and the

                                      -2-

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developmental NOAEL was equal or greater than 500 mg/kg/day.  Maternal toxicity was
observed at 500 and 750 mg/kg/day [HOT] in the form of decreased body weights and
clinical observations of uncoordinated gait.  Ulcers and erosions of the glandular
mucosa of the stomach were observed in the 500 and 750 mg/kg/day dose groups.
Similar toxic effects were also observed in a developmental study  in rabbits with
Milestone, the formulated triisopropanolamine (TIPA) salt of aminopyralid.
Developmental toxicity could not be determined in aminopyralid rabbit study since the
750 mg/kg/day group was removed from the study due to the severity of the clinical
signs (body weight changes, decreased food consumption and a decreased amount of
feces). However, in the rabbit developmental study with Milestone, developmental
toxicity was demonstrated by a decrease in fetal body weights at 520 mg acid
equivalents (ae)/kg/day.  In a 2-generation reproduction study in rats, there was no
evidence of parental, reproductive, or offspring toxicity observed after exposure to
aminopyralid up to 1000 mg/kg/day [HOT].  The developmental toxicity studies and the
2-generation reproduction study did not exhibit quantitative or qualitative susceptibility.

There were no systemic toxic effects observed at 1000 mg/kg/day [HOT] in a 28-day
dermal toxicity study in rats with aminopyralid.  However, dermal toxicity was indicated
by slight epidermal hyperplasia in males at the HOT.

The database on aminopyralid indicates that the stomach, ileum and cecum are targets
for this compound.  In a 90-day toxicity study in dogs the NOAEL was 282 mg/kg/day  for
males and 232 mg/kg/day for females based on slight diffuse hyperplasia and
hypertrophy of the mucosal epithelium of the stomach at 1070 mg/kg/day in males and
929 mg/kg/day in females. In the 1-year chronic toxicity study in dogs, the NOAEL was
99 mg/kg/day for males and 93 mg/kg/day for females based on thickening of the
stomach, slight lymphoid hyperplasia of the gastric mucosa, and slight chronic mucosal
inflammation at the  HOT.  In a 90-day mouse dietary study, no toxicity was observed at
1000 mg/kg/day [HOT].  In a 90-day rat feeding study the NOAEL was 1000 mg/kg/day
[HOT] for females and 500 mg/kg/day for males based on hyperplasia of the mucosal
epithelium of the ileum and the cecum at 1000 mg/kg/day [HOT].

In the mouse chronic feeding study the NOAEL was 1000 mg/kg/day [HOT] for males
and 250 mg/kg/day  for females. In the rat chronic feeding study the NOAEL was 50
mg/kg/day based on cecal enlargement, slight mucosal hyperplasia (males) and slightly
decreased body weights at 500 mg/kg/day.

Aminopyralid has been classified as "not likely" to be carcinogenic to humans.  No
increases in any tumors were found in carcinogenicity studies in rats and mice.

In a metabolism study in rats, aminopyralid was rapidly absorbed,  distributed,  and
excreted following oral administration. Tissue distribution and bioaccumulation were
minimal; <0.73% of administered dose [AD] was recovered in tissues after 7 days for all
dosing groups. The highest levels of radioactivity were found in the skin and carcass.
Aminopyralid was excreted unchanged,  indicating an absence of metabolism.  The AD

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was recovered as parent compound in 100% of the feces and = 96% of the urine.
Three unknown components found in urine (= 4 %) were also detected in similar
quantities in dose formulations, suggesting that they were trace impurities.

Based on aminopyralid's low toxicity, an acute Reference Dose (RfD) for the general
population is not  required.

The chronic RfD for aminopyralid is 0.5 mg/kg/day. This value is based  on the NOAEL
of 50 mg/kg/day in the rat combined chronic toxicity/carcinogenicity study with a
100-fold uncertainty factor to account for interspecies extrapolation (10X) and
intraspecies variability (10X).  An additional safety factor to protect infants and children
is not required, due to the toxicity properties of the material and the conservative nature
of the exposure estimates.

A DEEM chronic  exposure analysis was conducted using the tolerance levels for wheat
grain and meat commodities and assuming 100% of crops treated with aminopyralid.
The estimated exposures to US-population and relevant sensitive sub-population
groups were all at least 3 orders of magnitude below the RfD (< 1 %  RfD).

Based on the PRZM/EXAMS model, the estimated environmental concentrations (EECs) of
for
chronic exposures are estimated to be 1.937 parts per billion (ppb) for surface water and 0.630
ppb for ground water. The chronic estimated water concentrations  derived from surface water
modeling results were significantly higher than the modeled ground water concentrations, and
therefore protective of potential exposures via ground water sources of drinking water when
incorporated into aggregate exposure estimates. The aminopyralid EEC's were  incorporated into
LifeLine™ Version 2.0 to determine aggregate pesticide exposures from pesticide residues in the
diet.

There are no requested uses for aminopyralid that are considered residential and neither handler
nor post-application residential  exposures from uses around homes are expected to occur.
However, the use on campgrounds and other recreation areas to control vegetation has the
potential to result in short-term  post-application incidental oral exposures for infants and
children via hand-to mouth transfer of residues and ingestion of aminopyralid-contaminated
grass and soil. For  children with a 15-kg body weight exposed via  the hand-to-mouth route, the
potential MOE was 150,000.  Post-application  exposure via inhalation is not expected to occur.

The source of human exposure results from dietary exposure from  food and drinking water, and
short term incidential oral exposure, a short term  oral exposure of children to treated
campgrounds.. Aggregating these exposure estimates gives a combined potential level of 0.0033
mg/kg/day, for the  highest exposed group, children 1-2 years of age. The margin of exposure
(MOE) associated with  this Tier I exposure estimate is 32,000, greatly above the acceptable limit
(MOE = 100).  EPA thus concludes that there is reasonable certainty that no harm will come
from aggregate exposure to aminopyralid residues.


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Based on labeled uses, the occupational exposure is expected to be short- to intermediate-term
and no long-term exposure is expected. Based on the available toxicological information,
dermal exposures do not result in any adverse systemic effect; therefore, dermal exposures were
not included into the estimation of occupational risk to workers. Short- and intermediate-term
oral and inhalation exposures are being regulated based on the effects seen in the developmental
rabbit toxicity study, which showed a NOAEL of 104 mg/kg/day.

The highest potential exposure was estimated to Mixer-Loaders working on aerial applications of
0.11 Ib ae/A, for up to 1200 acres applied per day. The corresponding MOE is 40,000.

Dietary tolerances are established for free and conjugated residues in the following crop
food/feed commodities:
Commodity
Grass, forage
Grass, hay
Wheat, bran
Wheat, forage
Wheat, grain
Wheat, hay
Wheat, straw
Aspirated grain fractions
Parts per million
25
50
0.1
2.0
0.04
4.0
0.25
0.2
Tolerances also listed for the parent aminopyralid in or on the following animal commodities:
 Commodity
 Parts per Million
 Cattle, fat
 Cattle, meat
 Cattle, meat byproducts,
 excluding kidney
 Cattle, kidney
 Goat, fat
0.02
0.02
0.02
0.3
0.02
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Goat, meat
Goat, meat byproducts,
excluding kidney
Goat, kidney
Horse, fat
Horse, meat
Horse, meat byproducts,
excluding kidney
Horse, kidney
Milk
Sheep, fat
Sheep, meat
Sheep, meat byproducts,
excluding kidney
Sheep, kidney
0.02
0.02
0.3
0.02
0.02
0.02
0.3
0.03
0.02
0.02
0.02
0.3
In aquatic systems, the primary route of degradation is photolysis, where a laboratory
experiment yielded a half-life of 0.6 days. In addition to C02, oxamic and malonamic
acid were identified as major degradates. Aminopyralid was stable to direct hydrolysis
and in anaerobic sediment-water systems.  In aerobic sediment-water systems,
degradation proceeded slowly, with observed total system half-lives of 462 to 990 days.
The degradation resulted in the formation of non-extractable residues and no other
major products.

Under aerobic conditions, degradation of aminopyralid in five different soils resulted in
the production of C02 and non-extractable residues.  Half-lives ranged from 31.5 to
533.2 days in 5 soils. For risk assessment purposes, EPA used a half-life of 103.5
days.

Aminopyralid  photolyzed moderately slowly on a soil surface. The half-life was 72 days
and C02, non-extractable residues and small amounts of acidic volatiles were the
degradates.

Aminopyralid  is weakly sorbed to soil.  A laboratory Freundlich adsorption isotherm
study with 8 US and European soils yielded 48-hour Kd values of 0.03 to 0.72 mL/g;
adsorption Koc values were 1.05 to 24.3 mL/g.
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Two field dissipation studies were performed (in California and Mississippi).  The results
indicate that aminopyralid is likely to be non-persistent and relatively immobile in the
field.  Half-lives of 32 and 20 days were determined, with minimal leaching below the 15
to 30 cm soil depth.

Aminopyralid has been shown to be practically non-toxic to birds, fish, honeybees,
earthworms, and aquatic invertebrates. Aminopyralid is slightly toxic to eastern oyster,
algae and aquatic vascular plants.  The log Kow is less than 3 and thus aminopyralid is
not expected to bioaccumulate in fish tissue.

There are no acute or chronic risks to non-target endangered or non-endangered fish,
birds, wild mammals, terrestrial and aquatic invertebrates, algae or aquatic plants.
TECHNICAL CHEMICAL CHARACTERISTICS

Empirical Formula: C6H4C12N202

Molecular Weight:  207.016 g/mole

Color;             Off-white

Physical State:     Powder

Odor:             Odorless
Melting Point:

Density:

Solubility:
Vapor
Pressure:
161.75-165.23° C
1.72 (20° C, relative to water at 4° C)
                  Water            212g/L(pH5)
                                    205 g/L (pH 7)
                                    203 g/L (pH 9)
                                    2.48 g/L (unbuffered)
                  Acetone          29.2 g/L
                  Ethyl Acetate      4 g/L
                  Methanol          52.2 g/L
                  1,2-dichloroethane 0.189 g/L
                  Xylene            0.043 g/L
                  Heptane          less than 0.010 g/L
7.14 x10'11 mm Hg at 20° C
                                      -7-

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                  1.92x10-10mm Hg at 25° C
Dissociation
Constant:

Octanol/Water
Partition
Coefficient:
pH:

Oxidizing or
Reducing
Action:
pK,, = 2.56 at 20° C
logP = 0.201 (Unbuffered at 20° C)
LogP = -1.75(pH5at20°C)
LogP = -2.87 (pH 7 at 20° C)
LogP = -2.96 (pH 9 at 20° C)

2.31  (1% w/w solution/suspension)
none
Mobility:           Kd = 0.03 - 0.72

TOXICOLOGY CHARACTERISTICS

Milestone
(formulated end-use product)
Acute Oral
Toxicity
(rats):
Toxicity
Category:
LD50 Males and Females > 5000 mg/kg
IV
Acute Dermal
Toxicity
(rats):
Toxicity
Category:

Acute Inhalation
Toxicity
(rats):
Toxicity
Category:
LD50 Males and Females > 5000 mg/kg
IV
LC50 Males and Females > 5.79 mg/L
IV
Primary Eye

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Irritation
(rabbits):
Toxicity
Category:

Primary Skin
Irritation
(rabbits):
Toxicity
Category:

Dermal
Sensitization
(guinea pigs):

90-day dietary
(rats):
Developmental
Toxicity
(rabbit):
Developmental
Toxicity
(rat):
No irritation
IV
Mutagenicity:
Slight erythema at 24 and 72 hours, resolving by day 7
IV
Not a sensitizer
NOAEL = 1000 mg (TIPA) salt of aminopyralid/kg/day (520 mg acid
equivalents aminopyralid (ae)/kg/day)
LOAEL = not determined
Maternal NOAEL = 200 mg TIPA salt of aminopyralid /kg/day (104
mg ae/kg/day)
Maternal LOAEL = 500 mg TIPA salt of aminopyralid /kg/day (260
mg ae/kg/day) based on severe inanition and body weight loss,
decreased fecal output, and mild clinical observations of
uncoordinated gait

Developmental NOAEL = 500 mg TIPA salt of aminopyralid /kg/day
(260 mg ae/kg/day)
Developmental LOAEL = 1000 mg TIPA salt of aminopyralid/kg/day
(520 mg ae/kg/day) based on decreased fetal  body weights
Maternal NOAEL = 1000 mg TIPA salt of aminopyralid/kg/day (520
mg ae/kg/day)
Maternal LOAEL = not determined

Developmental NOAEL = 1000 mg TIPA salt of aminopyralid/kg/day
(520 mg ae/kg/day)
Developmental LOAEL = not determined

The mutagenicity studies submitted for Milestone satisfy the

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Metabolism
(Non-guideline):
                   mutagenicity test battery.  Milestone was negative in all
                   mutagenicity studies.
14C-Aminopyralid and 14C-aminopryalid TIPA salt, when
administered orally to rats, were bioequivalent in terms of
absorption, distribution, metabolism, and excretion of the
amino-dichloro-picolinate portion of the molecule(s).
Aminopyralid Technical
(manufacturing use product)
Acute Oral
Toxicity
(rats):
Toxicity
Category:
Acute Dermal
Toxicity
(rabbits):
Toxicity
Category:

Acute Inhalation
Toxicity
(rats):
Toxicity
Category:

Primary Eye
Irritation
(rabbits):
Toxicity
Category:

Primary Skin
Irritation
(rabbits):
Toxicity
Category:

Dermal
Sensitization
LD50 Males and Females > 5000 mg/kg
IV
LD50 Males and Females >5000 mg/kg
IV
LC50 Males and Females >5.5 mg/L
IV
Corneal opacity in 1/3 through day 35
I
No irritation
IV
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(guinea pigs):

Acute Neurotoxicity
Screening
Battery
(rat):
Not a sensitizer
90-day dietary
(rats):
90-day dietary
(dogs):
28-day dermal
(rats):
Developmental
Toxicity
(rabbit):
Developmental
Toxicity
(rat):
NOAEL = 1000mg/kg
LOAEL = 2000 mg/kg based on fecal soiling in males and urine
soiling in females
NOAEL Male = 500 mg/kg/day, Female = 1000 mg/kg/day
LOAEL Male = 1000 mg/kg/day based on hyperplasia of the
mucosal epithelium of ileum and cecum, Female = not determined
NOAEL Male = 282 mg/kg/day, Female = 232 mg/kg/day
LOAEL Male = 1070 mg/kg/day, Female = 929 mg/kg/day based on
stomach histopathology (slight diffuse hyperplasia and hypertrophy
of the mucosal epithelium)
Systemic NOAEL = 1000 mg/kg/day
LOAEL = not determined

Dermal NOAEL Male = 100 mg/kg/day, Female = 1000 mg/kg/day
LOAEL Male = 500 mg/kg/day based on histopathological changes
(slight epidermal hyperplasia), Female = no
Maternal NOAEL = 250 mg/kg/day
Maternal LOAEL = 500 mg/kg/day based on decrease in body
weight (GD 7-10), decreased food consumption, clinical
observations of uncoordinated gait and ulcers and erosions of the
stomach

Developmental NOAEL = 500 mg/kg/day
Developmental LOAEL = not determined
Maternal NOAEL = 1000 mg/kg/day
Maternal LOAEL = not determined

Developmental NOAEL = 1000 mg/kg/day

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Two-Generation
Reproduction
(rat):
1 Year Chronic
Feeding
(dog):
                  Developmental LOAEL = not determined
Paternal NOAEL = 1000 mg/kg/day
Paternal LOAEL = not determined

Reproductive NOAEL = 1000 mg/kg/day
Reproductive LOAEL = not determined

Offspring NOAEL = 1000 mg/kg/day
Offspring LOAEL = not determined
NOAEL Male = 99 mg/kg/day, Female = 93 mg/kg/day
LOAEL Male = 967 mg/kg/day, Female = 1038 mg/kg/day based on
thickening of stomach mucosa (females), and stomach
histopathology in all animals (slight diffuse hyperplasia and
hypertrophy of the mucosal epithelium, slight lymphoid hyperplasia
of the gastric mucosa and very slight/slight chronic mucosal
inflammation)
Chronic Neurotoxicity
(rat):
NOAEL = 1000 mg/kg/day
LOAEL = not determined
Chronic Feeding/
Carcinogenicity
(rat):              NOAEL = 50 mg/kg/day
                  LOAEL = 500 mg/kg/day based on cecal enlargement, slight
                  mucosal hyperplasia (males) and slightly decreased body weights
Carcinogenicity
(mouse):
NOAEL Male = 1000 mg/kg/day, Female 250 mg/kg/day
LOAEL Male = not determined, Female = 1000 mg/kg/day based
on increased mortality
Mutagenicity:
The mutagenicity studies submitted for aminopyralid satisfy the
mutagenicity test battery.  Aminopyralid was negative in all
mutagenicity studies, except for an in vitro chromosome aberration
assay utilizing rat lymphocytes. In this assay, aminopyralid induced
chromosome aberrations, but only at cytotoxic concentrations. The
clastogenic response was induced secondary to toxicity.

                   -12-

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Metabolism:        Low dose = 50 mg/kg
                  High dose = 1000 mg/kg
                  Repeated dose = 50 mg/kg/day (unlabeled) for 14 days, 50
                  mg/kg/day (labeled) on day 15
                  Recovery after 168 hrs: 96% in low dose (urine - 50%, feces - 43%,
                  tissues - 0.1%, cage wash -10%), and 95% in the repeated low
                  dose (urine 59%, feces - 33%, tissues - 0.1%, cage wash - 3%).
                  Aminopyralid represented = 96% of administered dose (AD) in urine
                  and 100% AD in feces. Three unknown components (= 4 %) found
                  in urine were also found in dose formulations.

ECOLOGICAL CHARACTERISTICS

Avian Acute Toxicity:
  Bobwhite Quail:        LD50>2250 mg a.e./kg bw
Avian Dietary Toxicity:
  Bobwhite Quail:        5-day LC50 >5556 mg a.e./kg diet
  Mallard Duck:          5- day LC50 >5496 mg a.e./kg diet

Avian Reproduction:
  Bobwhite Quail:        No Observed Effect Concentration
                       (NOEC) = not determined
                       Lowest Observed Effect Concentration
                       (LOEC) = 640 mg a.e./kg diet

Mallard Duck:            No Observed Effect Concentration
                       (NOEC) = 2623 mg a.e./kg diet
                       Lowest Observed Effect Concentration
                       (LOEC) > 2623 mg a.e./kg diet

Acute Mammalian Toxicity:
  Rattus rattus:          LD50 >5000 mg a.e./kg bw

Chronic Mammalian Toxicity:
  Rattus norvegicus:     NOEL >1000 mg a.e./kg bw/day

Freshwater fish and amphibian
Acute Toxicity:
Bluegill Sunfish:          96-hour LC50 >100 mg a.e./L
Rainbow Trout:          96-hour LC50 >100 mg a.e./L
Northern leopard frog:    96-hour LC50 >95.2 mg a.e./L

Estuarine/marine fish

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Acute Toxicity:
Sheepshead minnow:

Freshwater Fish
Early life-stage
Toxicity:
Fathead Minnow:
                     96-hour LC50 >120 mg a.e./L
                     NOEC = 1.36mga.e./L
                     LOEC = 2.44 mg a.e./L
                     MATC**= 1.82 mg a.e./L
Defined as the geometric mean of the NOEC and LOEC
Freshwater Invertebrate
Toxicity:
Daphnia magna:

Freshwater Invertebrate
Life-Cycle Toxicity:
Daphnia magna:
Estuarine/Marine
Invertebrate Acute
Toxicity:
Eastern Oyster:
Mysid:

Non-Target Insects
Toxicity:
Honey  Bee
Acute Contact:
Acute Oral:
                     48-hour EC50 >98.6 mg a.e./L
                     NOEC = 102 mg a.e./L (highest concentration tested)
                     LOEC >102 mg a.e./L
                     48-hour EC50 >89 mg a.e./L
                     96-hour LC50 >100 mg a.e./L
                     LD50 >100 ug a.e./bee
                     LD50 >117 ug a.e./bee
Seedling Emergency and Vegetative Vigor For Milestone:
Seedling Emergence:
Species
Monocot - Barnyardgrass
Monocot - Corn
Monocot - Onion
Monocot - Wheat
Dicot - Cucumber
Dicot - Soybean
Dicot - Sugar Beet
Dicot - Lettuce
                     EC25 (ga.i./ha)
                     >230.8
                     >230.8
                     29.0
                     >230.8
                     >57.7
                     2.7
                     14.0
                     20.0
Most Sensitive Parameter
None
None
Fresh weight (Most Sensitive Monocot)
None
None
Fresh weight (Most Sensitive Dicot)
Fresh weight
Fresh weight
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Dicot - Oilseed Rape
Dicot - Radish

Vegetative Vigor:
Species
      49.0
      >230.8
Fresh weight
None
      EC25 (ga.i./ha)    Most Sensitive Parameter
Monocot - Barnyardgrass  >230.8
Monocot - Corn          >230.8
Monocot - Onion         53.0
Monocot - Wheat         >230.8
Dicot - Cucumber         12.0
Dicot - Soybean          0.75
Dicot - Sugar Beet        8.4
Dicot - Lettuce           3.3
Dicot - Oilseed Rape      >230.8
Dicot - Radish            54.0

Non-target Aquatic Plant Toxicity (Tier II):
                        None
                        None
                        Fresh weight
                        None
                        Shoot length
                        Shoot length
                        Fresh weight
                        Fresh weight
                        None
                        Fresh weight
Vascular Plants
Duckweed
Lemna gibba:
EC50 > 88 mg a.e./L  NOEC = 44 mg a.e./L
Nonvascular Plants
Green algae
Pseudokirchneriella subcapitata:  ErC50 = 30 mg a.e./L NOEC = 23 mg a.e./L
Marine diatom:
Skeletonema costatum:

Freshwater diatom:
Navicula pelliculosa:
      EbC50 = 70 mg a.e./L  NOEC = 13 mg a.e./L


      EC50 = 18 mg a.e./L NOEC = 6 mg a.e./L
Blue-green algae:
Anabaena
Flos-aquae:  not determined
Aminopyralid has been shown to be practically non-toxic to birds, fish, honeybees,
earthworms, and aquatic invertebrates. Aminopyralid is slightly toxic to eastern oyster,
algae and aquatic vascular plants. The log Kow is less than 3, indicating that
aminopyralid is not expected to bioaccumulate in fish tissue.  Tier II seedling emergence
and vegetative vigor studies were conducted using the formulated product, Milestone.
Seedling emergence testing indicated that onion was the most sensitive monocot (fresh
shoot weight EC25 = 29 g  a.i./ha), while soybeans were the most sensitive dicot (fresh
shoot weight EC25 = 2.7 g a.i./ha). Vegetative vigor testing indicated that onion was
                                     -15-

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again the most sensitive monocot (fresh shoot weight EC25 = 53 g a.i./ha).  Similarly,
soybeans were the most sensitive dicot (shoot length EC25 = 0.75 g a.i./ha). Grass
species (barnyardgrass, corn and wheat) were among the least sensitive species tested
in both the seedling emergence and vegetative vigor tests and had EC25 values that
exceeded the maximum application rate tested.  There are no acute or chronic risks to
non-target endangered or non-endangered fish, birds, wild mammals, terrestrial and
aquatic invertebrates, algae or aquatic plants.

ENVIRONMENTAL CHARACTERISTICS

In aquatic systems, the primary route of degradation is photolysis, where a laboratory
experiment yielded a half-life of 0.6 days (corrected for natural sunlight conditions). In
addition to C02, oxamic and malonamic acid were identified as major degradates, along
with a number of minor 2-3 carbon chain length acid amides.  Aminopyralid was stable
to direct hydrolysis and in  anaerobic sediment-water systems.   In aerobic
sediment-water systems, degradation proceeded slowly, with observed total system
half-lives of 462 to 990 days. The degradation resulted in the formation of
non-extractable residues and no other major products.

Under aerobic conditions,  degradation of aminopyralid in five different soils resulted in
the production of no significant degradation products beyond C02 and non-extractable
residues. Half-lives ranged from 31.5 to 533.2 days, although material balance criteria
were not met for 4 of the 5 soils; the soil meeting these criteria yielded a half-life  of
103.5 days.  By the end of the study, C02 accounted for 66 to 73% of the applied
(except in a Barnes Clay Loam soil at 27-30% of applied).  Non-extractable residues
were detected at 0 to 16% of applied radioactivity at the end of the study, except for the
test with a Houston Black  Clay soil, where the non-extractable residues were 23-24% of
applied.

Aminopyralid photolyzed moderately slowly on a soil surface. The half-life was 72 days
(corrected for natural sunlight and soil metabolism)  and C02, non-extractable residues
 and small amounts of acidic volatiles were the degrates..

Aminopyralid is weakly sorbed to soil.  A laboratory Freundlich adsorption isotherm
study with 8 US and European soils yielded 48-hour Kd values of 0.03 to 0.72 mL/g;
adsorption Koc values were 1.05 to 24.3 mL/g.

Two field dissipation studies were performed (in California and Mississippi).  The results
indicate that aminopyralid  is likely to be non-persistent and relatively immobile in the
field.  Half-lives of 32 and  20 days were determined, with minimal leaching below the 15
to 30 cm horizon depth.

The nature of the residue  in plants and animals is well understood. Based on the nature
of residue studies (NOR) on grass and wheat, the tolerance expression in or on grass
forage, grass hay, wheat raw agricultural commodities and wheat processed products is

                                      -16-

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the total parent aminopyralid, both free and conjugated.  Based on the NOR study on
lactating goat, the tolerance expression in milk, meat and meat-byproducts is the
unchanged parent, aminopyralid.
Tolerances are established for residues of aminopyralid as described in the Summary
Science Statements of this Fact Sheet.

AGGREGATE EXPOSURES

As indicated by the Food Quality Protection Act (FQPA), 1996, the potential for
concurrent exposure to aminopyralid via oral, dermal and inhalation routes must be
assessed by EPA. This aggregate exposure considers every possible non-occupational
exposure route,  including residues in food, in drinking water and residential exposure
from indoor/outdoor non-crop uses.
However, based on the available toxicological information, dermal exposures do not
result in any adverse systemic effect; therefore, dermal exposures are not included into
the estimation of aggregate risk for any duration of exposure. Short- and
intermediate-term  oral and inhalation exposures are being regulated based on the
effects seen in the developmental rabbit toxicity study. However, the non-crop uses do
not include any indoor uses; therefore, both handler and post-application inhalation
exposures are expected to be negligible.

1.     From Food and  Feed Uses

Based on aminopyralid's low toxicity profile, an acute Reference Dose (RfD) for the
general population or any  of the population sub-groups is not required.

The chronic Reference Dose (RfD) for aminopyralid is 0.5 mg/kg/day. It is based on the
NOAEL of 50 mg/kg/day from the rat combined chronic toxicity/ carcinogenicity study,
the lowest NOAEL observed in any of the chronic studies. A 100-fold uncertainty factor
to account for interspecies extrapolation (10X) and intraspecies variability (10X) was
applied over the selected NOAEL in order to establish the RfD.

An extra safety factor (SF) to protect infants and children is not needed based on the
following considerations:

      a) the toxicity data showed no increase in susceptibility in fetuses and pups with
      in-utero and post-natal exposure; b) the dietary food exposure assessment was
      done with tolerance-level residues and  100% crop treated for all commodities,
      which results in very high-end estimates of dietary exposure; c) the drinking
      water assessment was based on values generated by models which are
      designed to provide conservative, high-end estimates of water concentrations; d)
      exposures due to recreational activities are based  on default EPA assumptions
      that result in high-end estimates of exposure.

A DEEM chronic exposure analysis was conducted using the tolerance levels for wheat

                                      -17-

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grain and meat commodities and assuming 100% of crops treated with aminopyralid.
The estimated exposures to US-population and relevant sensitive sub-population
groups were all at least 3 orders of magnitude below the level of the RfD (< 1 % RfD).

2.     From Potable Water

Drinking water estimated concentrations were estimated with the SCI-GROW model for
ground water and with the Index Reservoir model for surface water. The set of
assumptions included the maximum seasonal use rate of 0.11  Ib a.e./A, Koc of 1.05 and
a half-life of 38.7 days. Aminopyralid does not have an acute RfD established; therefore,
an acute assessment is not needed for drinking water. A chronic exposure assessment
considering the highest chronic concentrations from surface drinking water has shown
levels of exposure which are four orders of magnitude below the RfD of 0.5
mg/kg-bw/day, both for adults and children 1-6 years of age.
3.     For Non-Dietary Uses

At this time, there are no requested uses for aminopyralid that are considered home
uses and neither handler nor post-application residential exposures from uses around
home are expected to occur. However, the use on campgrounds and other recreation
areas to control vegetation has the potential to result in short-term post-application
incidental oral exposures for infants and children via hand-to mouth transfer of residues
and ingestion of aminopyralid-contaminated grass and soil. Post-application exposure
via inhalation is not expected to occur.

Short-term residential exposure to children with 15 kg body-weight from the three routes
mentioned above was estimated using the HED Draft Standard Operating Procedures
(SOP's) for Residential Exposure Assessments (12/18/97) and the Revisions to the
Standard Operating Procedures (SOP's) for Residential Exposure Assessment (Science
advisory Council for Exposure Policy 12, Revised February 22, 2001) for Hand-to-Mouth
Transfer, Ingestion  of Turfgrass and Ingestion of Soil, from uses on lawn broadcast
application. The lowest MOE was 150,000 for this tier-l post-application residential
assessment  and it corresponds to children exposed via the hand-to-mouth route.

AGGREGATE  RISK CONCLUSIONS

Since the only  source of residential exposure would result from oral exposure, an
aggregate exposure assessment was performed adding the estimated chronic dietary
exposure to the estimated short-term oral residential exposure. Totaling the two oral
exposure estimates gives a combined potential level of 0.0033 mg/kg/day, for the
highest exposed group, children 1-2 years of age. The margin of exposure (MOE)
associated with this Tier I exposure estimate is 32,000 and it is much above the
acceptable limit (MOE = 100).  EPA thus concludes that there is reasonable certainty
that no harm will come from aggregate exposure to aminopyralid residues.

                                      -18-

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CUMULATIVE EXPOSURE TO SUBSTANCES WITH COMMON MECHANISM OF
TOXICITY

Unlike other pesticides for which EPA has followed a cumulative risk approach based on
a common mechanism of toxicity, EPA has not made a common mechanism of toxicity
finding for aminopyralid and any other substances. Furthermore, aminopyralid does not
appear to have a toxic metabolite that is produced by other substances. For the time
being, EPA has assumed that aminopyralid does not have a common mechanism of
toxicity with other substances.  For information regarding EPA's efforts to determine
which chemicals have a common mechanism of toxicity and to evaluate the cumulative
effects of such chemicals, see the policy statements released by the Office for
Pesticides Programs concerning common mechanism determinations and procedures
for cumulating effects from substances found to have a common mechanism on EPA's
website at http: //www/epa.gov/pesticides/cumulative/
OCCUPATIONAL EXPOSURE

Based on labeled uses, the occupational exposure is expected to be short- to
intermediate-term and no long-term exposure is expected. The application of Milestone
to control weeds in wheat, rangeland, pastures, non-cropland areas and natural
recreation areas is recommended by using broadcast treatment with ground and aerial
equipment on wheat and also hand-spray and spot treatments for all other uses.

Based on the available toxicological information, dermal exposures do not result in any
adverse systemic effect; therefore, dermal exposures were not included into the
estimation of occupational risk to workers. Short- and intermediate-term oral and
inhalation exposures are being regulated based on the effects seen in the
developmental rabbit toxicity study, which showed a NOAEL of 104 mg/kg/day.

The highest potential exposure was estimated to Mixer-Loaders working on aerial
applications of 0.11  Ib ae/A, for up to 1200 acres applied per day. The corresponding
MOE is 40,000.
SUMMARY OF DATA GAPS

No major data gaps have been identified with the registrant-submitted data, although
uncertainties were noted in the determinations of soil half-life, chronic effects on birds
and effects upon cyanobacteria.

   1.  Submit completed enforcement method of analysis to show that analytical method
      differentiates between aminopyralid, picloram and clopyralid.
                                     -19-

-------
   2.  The analytical method must be submitted to EPA Fort Meade Laboratory for validation.

   3,  Submit storage stability data for grass forage and hay reflecting up to approximately 15
      months of frozen storage.

   4. Submit a repeated Aerobic Soil Metabolism Study (EPA Guidelines No. 162-1).

   5. Submit a repeated Avian Reproduction study in bobwhite quail (EPA Guideline No. 71-
     4(a).

   6. Submit a repeated Tier II Aquatic Plant Growth: Blue-Green Algae, Anabaena flos aquae
     (EPA Guideline No. 123-2).
PUBLIC INTEREST FINDING

Aminopyralid is a Reduced Risk herbicide that provides reliable control of a broad
spectrum of difficult-to control noxious weeds and invasive plants on rangeland and
pastures, rights-of-way, and wildlife habitat areas. Aminopyralid is particularly effective
for the control of tropical soda apple, musk thistle, Canada thistle, spotted knapweed,
diffuse knapweed, yellow starthistle and Russian knapweed.  Aminopyralid has a
favorable human health toxicity profile when  compared to the registered alternatives for
these use sites and will be applied at a lower rate. Its residual action should alleviate
the need for repeat applications, resulting in  a reduction in the amount of herbicides
applied to the environment for the control of these weeds. Aminopyralid has been
determined to be practically non-toxic to non-target animals at the registered application
rates, compared to the alternatives, and is less likely to impact both terrestrial and
aquatic plants.

GOVERNMENT PERFORMANCE AND RESULTS ACT (GPRA)
Registration of aminopyralid will meet the objectives of GRPA title 3.1.1 by assuring
new pesticides that enter the market are safe for humans and the environment and title
4.1.2 by reducing environmental exposure to herbicides.

CONTACT PERSON AT EPA
Joanne Miller,
Project Manager, Team 23
Herbicide Branch
Registration division (7505C)

E-Mail Address:
miller.joanne@epamail.epa.gov

Mailing Address:
                                      -20-

-------
US Environmental Protection agency
Office of Pesticide Programs (7505C)
Ariel Rios building
1200 Pennsylvania Ave., N.W.
Washington, D.C. 20460

Office Location and Telephone Number
Room 241,  Crystal Mall building #2
1801 south Bell Street
Arlington, VA 22202
(703) 305-6224

Disclaimer:  The information presented in this Pesticide Fact Sheet is for informational
purposes only and may not be used to fill data requirements for pesticide registration
and reregistration.
                                      -21-

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                         Study Information For Ingredient
                        005100 /150114- 71-9 / Aminopyralid
         MRID
        Citation
     Receipt Date
46235600
Dow AgroSciences LLC
(2004) Submission of
Residue and Toxicity Data in
  Support of the
Applications for Registration
of Aminopyralid Technical
and    GF-87 land the
Petition  for Tolerance of
Aminopyralid on Grass
Forage,    Grass Hay,
Wheat Commodities, Milk,
Cattle Meat and Meat
By-Products.    Transmittal
of 37 of 108 Studies.
25-Mar-2004
46235601
Hastings, M. (2003) Method
Validation Report for the
Determination of
Residues of Aminopyralid in
Water by Liquid
Chromatography with
Tandem    Mass
Spectrometry Detection
Using Dow AgroSciences
Method GRMO 1.32.
Project Number: 011159.
Unpublished study prepared
by Dow AgroSciences
LLC. 48 p.
25-Mar-2004
                                       -22-

-------
46235602
Lindsey, A. (2004) Method
Validation Report for the
Determination of
Residues of Aminopyralid in
Soil by Liquid
Chromatography with
Tandem Mass
Spectrometry Detection
Using Dow AgroSciences
Method GRM 02.34. Project
  Number: 021295.
Unpublished study prepared
by Dow Agrosciences LLC.
56   p.
25-Mar-2004
46235603
Brooks, K. (2001) XDE-750:
Acute Oral Toxicity Study in
Fischer 344    Rats. Project
Number: 011115.
Unpublished study prepared
by Dow Chemical    Co. 47
P-
25-Mar-2004
46235604
Wilson, D.; Brooks, K.;
Radtke, B. (2002) GF-871:
Acute Oral Toxicity
Study in Fischer 344 Rats.
Project Number: 021096.
Unpublished study
prepared by Dow Chemical
Co. 44 p.
25-Mar-2004
46235605
Brooks, K.; Yano, B. (2001)
XDE-750: Acute Dermal
Toxicity Study in    Fischer
344 Rats. Project Number:
011116. Unpublished study
prepared by    Dow
Chemical Co. 43 p.
25-Mar-2004
                                      -23-

-------
46235606
Wilson, D.; Brooks, K.;
Radtke, B. (2002) GF-871:
Acute Dermal    Toxicity
Study in Fischer 344 Rats.
Project Number: 021097.
Unpublished    study
prepared by Dow Chemical
Co. 41 p.
25-Mar-2004
46235607
Kiplinger, G. (2001)
XDE-750: Acute Inhalation
Toxicity Study in the
Fischer 344 Rat: Final
Report. Project Number:
011097, WIL/406012.
Unpublished study prepared
by WIL Research
Laboratories, Inc. 106 p.
25-Mar-2004
46235608
Landry, T.; Krieger, S.
(2002) GF-871: Acute Liquid
Aerosol Inhalation
Toxicity Study in Fischer 344
Rats. Project Number:
021061. Unpublished
study prepared by Dow
Chemical Co.  48 p.
25-Mar-2004
46235609
Brooks, K. (2001) XDE-750:
Acute Eye Irritation Study in
New Zealand    White
Rabbits. Project Number:
011118. Unpublished study
prepared by Dow
Chemical Co.  17 p.
25-Mar-2004
46235610
Brooks, K.; Radtke, B.
(2002) GF-871: Acute Eye
Irritation Study in    New
Zealand White Rabbits.
Project Number: 021098.
Unpublished study
prepared by Dow Chemical
Co. 16 p.
25-Mar-2004
                                       -24-

-------
46235611
Brooks, K. (2001) XDE-750:
Acute Dermal Irritation
Study in New    Zealand
White Rabbits. Project
Number: 011117.
Unpublished study prepared
  by Dow Chemical Co.  15 p.
25-Mar-2004
46235612
Brooks, K.; Radtke, B.
(2002) GF-871: Acute
Dermal Irritation Study in
New Zealand White Rabbits.
Project Number: 021099.
Unpublished study
prepared by Dow Chemical
Co. 15 p.
25-Mar-2004
46235613
Wilson, C. (2001) XDE-750:
A Dermal Sensitization Study
in Hartley    Albino Guinea
Pigs: Maximation Design:
Final Report. Project
Number:    3504/155,
011034. Unpublished study
prepared by Springborn
Laboratories,    Inc. 77 p.
25-Mar-2004
46235614
Wilson, C. (2002) GF-871: A
Dermal Sensitization Study
in Hartley   Albino Guinea
Pigs: Maximization Design:
Final Report. Project
Number:    3504/250,
021071. Unpublished study
prepared by Springborn
Laboratories,    Inc. 75 p.
25-Mar-2004
                                       -25-

-------
46235615
Johnson, K.; Dryzga, M.
(2004) XDE-750: Two-Year
Chronic
Toxicity/Oncogenicity and
Chronic Neurotoxicity Study
in Fischer 344 Rats.
Project Number: 011040.
Unpublished study prepared
by The Dow Chemical Co.
2865 p.
25-Mar-2004
46235616
Marable, B.; Andrus, A.;
Stebbins, K. (2002) Revised
Report for:    XDE-750:
Acute Neurotoxicity Study in
Fischer Rats. Project
Number:    011073R,
011073. Unpublished study
prepared by The Dow
Chemical Co. 404   p.
25-Mar-2004
46235617
Maurissen, J.; Andrus, A.;
Johnson, K.; et. al.; (2003)
XDE-750:   Chronic
Neurotoxicity Study in
Fischer 344 Rats. Project
Number: 011049N.
Unpublished study prepared
by The Dow Chemical Co.
495 p.
25-Mar-2004
46235618
Stebbins, K.; Day, S.;
Thomas, J. (2001) XDE-750:
13-Week Dietary
Toxicity Study in CD-I
Mice. Project Number:
001240. Unpublished study
 prepared by The Dow
Chemical Co. 470 p.
25-Mar-2004
                                       -26-

-------
46235619
Liberacki, A.; Marty, M.;
Thomas, J. (2001) XDE-750:
13-Week Dietary
Reproduction Study in CD
Rats. Project Number:
011046. Unpublished study
 prepared by The Dow
Chemical Co. 277 p.
25-Mar-2004
46235620
Stebbins, K.; Baker, P.
(2000) XR-750: 4-Week
Dietary Toxicity Study    in
Beagle Dogs. Project
Number: 001030.
Unpublished study prepared
by The    Dow Chemical
Co. 141 p.
25-Mar-2004
46235621
Dryzga, M.; Stebbins, K.
(2001) Revised Report for
XDE-750: 13-Week
Dietary Toxicity with
4-Week Recovery Study in
Fischer 344 Rats. Project
Number: 001221, 001221R.
Unpublished study prepared
by The Dow Chemical
Co. 737 p.
25-Mar-2004
46235622
Stebbins, K.; Dryzga, M.
(2004) GF-871: 90-Day
Dietary Toxicity Study    in
Fischer Rats. Project
Number: 031140.
Unpublished study prepared
by The    Dow Chemical
Co. 307 p.
25-Mar-2004
                                      -27-

-------
46235623
Stebbins, K.; Baker, P.
(2002) Revised Report for:
XDE-750:  13-Week
Dietary Toxicity Study in
Beagle Dogs. Project
Number: 001239R, 001239.
 Unpublished study prepared
by The Dow Chemical Co.
261 p.
25-Mar-2004
46235624
Yano, B.; Dryzga, M. (2000)
XR-750: 4-Week Repeated
Dose Dietary    Toxicity
Study in CD-I Mice. Project
Number: 001048.
Unpublished study
prepared by The Dow
Chemical Co. 289 p.
25-Mar-2004
46235625
Stebbins, K.; Day, S. (2000)
XR-750: 4-Week Repeated
Dose Dietary    Toxicity
Study in Fischer 344 Rats.
Project Number: 001031.
Unpublished   study
prepared by The Dow
Chemical Co. 313 p.
25-Mar-2004
46235626
Stebbins, K.; Thomas, K.;
Day, S. (2002) XDE-750:
28-Day Dermal    Toxicity
Study in Fischer Rats. Project
Number: 011219.
Unpublished study
prepared by The Dow
Chemical Co. 297 p.
25-Mar-2004
46235627
Stebbins, K.; Day, S. (2003)
XDE-750: One-Year Dietary
Toxicity Study    in Beagle
Dogs. Project Number:
021027. Unpublished study
prepared by The    Dow
Chemical Co. 285 p.
25-Mar-2004
                                      -28-

-------
46235628
Stebbins, K.; Day, S. (2003)
XDE-750: Oncogenicity
Dietary Study in    CD-I
Mice. Project Number:
011163. Unpublished study
prepared by The Dow
Chemical Co. 1416 p.
25-Mar-2004
46235629
Carney, E.; Tornesi, B.
(2001) XDE-750: Oral
Gavage Developmental
Toxicity Study in CD Rats.
Project Number: 011061.
Unpublished study
prepared by The Dow
Chemical Co. 458 p.
25-Mar-2004
46235630
Marty, M.; Liberacki, A.;
Thomas, J. (2002) XDE-750:
Oral Gavage
Developmental Toxicity
Study in New Zealand White
Rabbits. Project Number:
011047, 011047A.
Unpublished study prepared
by The Dow Chemical Co.
755   p.
25-Mar-2004
46235631
Thorsrud, B. (2004) GF-871:
An Oral Developmental
Toxicity Study in
Sprague Dawley Rats: Final
Report. Project Number:
3504/344,031141.
Unpublished study prepared
by Charles River
Laboratories, Inc. 412 p.
25-Mar-2004
                                      -29-

-------
46235632
Carney, E.; Tornesi, B.
(2004) GF-871: Oral Gavage
Developmental    Toxicity
Study in New Zealand White
Rabbits. Project Number:
031142.   Unpublished
study prepared by The Dow
Chemical Co. 335 p.
25-Mar-2004
46235633
Tornesi, B.; Carney, E.;
Thomas, J. (2001) XDE-750:
Developmental    Toxicity
Probe Study in CD Rats.
Project Number: 001234.
Unpublished study
prepared by The Dow
Chemical Co.  134 p.
25-Mar-2004
46235634
Liberacki, A.; Marty, M.;
Thomas, J. (2001) XDE-750:
Oral Gavage
Developmental Toxicity
Probe Study in New Zealand
White Rabbits. Project
Number: 001235.
Unpublished study prepared
by The Dow Chemical Co.
136   p.
25-Mar-2004
46235635
Marty, M.; Zablotny, C.;
Thomas, J. (2003) XDE-750:
Two-Generation    Dietary
Reproduction Toxicity Study
in CD Rats. Project Number:
011205.   Unpublished
study prepared by The Dow
Chemical Co. 1373 p.
25-Mar-2004
                                      -30-

-------
46235636
Mecchi, M. (2004)
Salmonella - Escherichia
coli/Mammalian-Microsome
  Reverse Mutation Assay
Preincubation Method with a
Confirmatory Assay with
XDE-750:  Second Amended
Final Report. Project
Number: 22338/0/422OECD,
   011058,2001/113.
Unpublished study prepared
by Covance Laboratories,
Inc.    37 p.
25-Mar-2004
46235637
Mecchi, M. (2004)
Salmonella-Escherichia
coli/Mammalian-Microsome
  Reverse Mutation Assay
Preincubation Method with a
Confirmatory Assay with
GF-871: Final Report.
Project Number:
25552/0/422OECD, 031150,
2004/7.    Unpublished
study prepared by Covance
Laboratories, Inc. 52 p.
25-Mar-2004
46235700
Dow AgroSciences LLC
(2004) Submission of
Product Chemistry, Residue
  and Environmental Fate
Data in Support of the
Applications for
Registration of Aminopyralid
Technical and GF-871 and
the Petition for    Tolerance
of Aminopyralid on Grass
Forage, Grass Hay, Wheat
Commodities,    Milk,
Cattle Meat and Meat
By-Products. Transmittal of
3 5 of 108   Studies.
25-Mar-2004
                                       -31-

-------
46235701
Ghaoui, L. (2004) Group A:
Product Identity and
Composition,    Description
of Materials Used to Produce
the Product, Description of
the     Production Process,
Discussion of Formation of
Impurities, Certified
Limits, Preliminary Analysis,
and Enforcement Analytical
Methods for
Aminopyralid (XDE-750)
Technical. Project Number:
NAFST759,
DECO/GL/AL/MD/2003/001
969:
DECO/GL/AL/MD/2003/001
968/A1. Unpublished study
 prepared by Dow
Agrosciences, LLC and The
Dow Chemical  Co. 255 p.
25-Mar-2004
46235702
Jensen, J. (2004) Group
A-Product Identity,
Composition, and Analysis
 forGF-871;anEndUse
Product Containing
Aminopyralid. Project
Number:    NAFST763,
DAS/AM/03/002.
Unpublished study prepared
by Dow Agrosciences
LLC and Dow Agrosciences
(New Zealand) Ltd. 69 p.
25-Mar-2004
                                      -32-

-------
46235703
Ghaoui, L. (2003) Group B:
Physical and Chemical
Properties of
Aminopyralid (XDE-750)
Technical. Project Number:
NAFST744,
DOS323/024653,
FAPC/013053. Unpublished
study prepared by Dow
Agrosciences LLC, Dow
Agrosciences (New Zealand)
Ltd. and The Dow Chemical,
Co. 313 p.
25-Mar-2004
46235704
Cathie, C. (2003) Group B:
Determination of Physical
State, Colour,   Odor,
Oxidizing and Reduction
Action, Flammability,
Explodability, pH,
Viscosity and Density of
GF-871, a Liquid End-Use
Product Containing
XR-750 TIPA. Project
Number: 02/070/L.
Unpublished study prepared
by Dow    Agrosciences
(New Zealand) Ltd. 17 p.
25-Mar-2004
46235705
McFarlane, J. (2003) Group
B -Phy si cal/Chemi cal
Properties for GF-871,    A
Liquid End Use Product
Containing XR-750 TIPA.
Project Number: NAFST788:
   GHF/P/2709. Unpublished
study prepared by Dow
Agrosciences, LLC. 5 p.
25-Mar-2004
                                      -33-

-------
46235706
Hamilton, T. (2004)
Amended Report for
Dissociation of XDE-750
Trilsopropanolamine Salt.
Project Number:
DECO/GL/AL/MD/2002/004
418.   Unpublished study
prepared by The Dow
Chemical Company. 21 p.
25-Mar-2004
46235707
Hamilton, T. (2004)
Amended Report for
Dissociation of XDE-750
Potassium Salt. Project
Number:
GL/AL/MD/2002/004397.
Unpublished study
prepared by The Dow
Chemical, Co. 21 p.
25-Mar-2004
46235708
Macpherson, D. (2003) The
Distribution and Metabolism
of (Carbon    14)-XDE-750
in the Lactating Goat. Project
Number: 201893.
Unpublished    study
prepared by Inveresk
Research International. Ill
P-
25-Mar-2004
46235709
Graper, L.; Smith, K.; Hilla,
S. (2003) A Nature of the
Residue Study    with
(Carbon 14)-Labeled
XDE-750 Applied to Spring
Wheat. Project Number:
020022. Unpublished study
prepared by Dow
AgroSciences LLC and
Research    for Hire.  197 p.
25-Mar-2004
                                      -34-

-------
46235710
Magnussen, J.; Balcer, J.
(2004) 14C XDE-750 Grass
Nature of Residue    Study.
Project Number: 010071.
Unpublished study prepared
by Dow   AgroSciences,
LLC.  139 p.
25-Mar-2004
46235711
Magnussen, J. (2004) 14C
XDE-750 Poultry Nature of
the Residue Study.
Project Number: 030009,
379/131. Unpublished study
prepared by Dow
AgroSciences, LLC and
Wildlife International, Ltd.
117 p.
25-Mar-2004
46235712
Reed, R. (2004)Independent
Laboratory Validation of
Dow AgroSciences    LLC
Method GRM 02.31 -
Determination of Residues of
Aminopyralid in
Agricultural Commodities by
Liquid  Chromatography with
Tandem Mass
Spectrometry Detection.
Project Number: 020157,
ML03/1110/DOW.
Unpublished    study
prepared by Morse
Laboratories. 147 p.
25-Mar-2004
                                       -35-

-------
46235713
Reed, R (2004) Independent
Laboratory Validation of
Dow AgroSciences
Method GRM 01.32-
Determination of Residues of
Aminopyralid in Water by
Liquid Chromatography with
Tandem Mass Spectrometry.
Project Number:    030039,
ML03/1111/DOW.
Unpublished study prepared
by Morse Laboratories.
113 p.
25-Mar-2004
46235714
Reed, R. (2004)Independent
Laboratory Validation of
Dow AgroSciences    LLC
Method GRM 03.18-
Determination of Residues of
Aminopyralid in Bovine
Tissues by Liquid
Chromatography with
Tandem Mass Spectrometry.
Project   Number: 030098,
ML03/1122/DOW.
Unpublished study prepared
by Morse    Laboratories.
130 p.
25-Mar-2004
46235715
Reed, R. (2004)Independent
Laboratory Validation of
Dow AgroSciences
Method GRM 02.34 -
Determination of Residues of
Aminopyralid in Soil by
Liquid Chromatography with
Tandem Mass Spectrometry.
Project Number:    020158,
ML03/1102/DOW.
Unpublished study prepared
by Morse Laboratories.
125 p.
25-Mar-2004
                                       -36-

-------
46235716
Rutherford, L.; Hastings, M.
(2003) Method Validation
Report for the
Determination of
Aminopyralid in Bovine
Tissues by Liquid
Chromatography    with
Tandem Mass Spectrometry
Using Dow AgroSciences
LLC Method GRM 03.18.
Project Number: 021327,
GRM/03/18. Unpublished
study prepared by Dow
AgroSciences LLC. 53 p.
25-Mar-2004
46235717
Olberding, E.; Hastings, M.
(2004) Validation Report for
Method GRM    02.31-
Determination of Residues of
Aminopyralid in Agricultural
   Commodities by Liquid
Chromatography with
Tandem Mass Spectrometry
  Detection. Project Number:
021310, GRM/02/31.
Unpublished study prepared
  by Dow AgroSciences
LLC. 61 p.
25-Mar-2004
46235718
Lala, M.; Mollica, J.; West,
S. (2002) PAM I
Multiresidue Protocol
Testing for XDE-750: Final
Report. Project Number:
021197, DOW/1413.
Unpublished study prepared
by Pyxant Labs Inc. 267 p.
25-Mar-2004
                                       -37-

-------
46235719
Lindsay, D. (2004) Frozen
Storage Stability of XDE-750
in Range Land    and
Pasture Grass and Hay and
Wheat Straw and Wheat
Grain - Interim    Report.
Project Number: 030004.
Unpublished study prepared
by Dow    AgroSciences
LLC. 50 p.
25-Mar-2004
46235720
Lindsay, D. (2004) Frozen
Storage Stability of XDE-750
in    Soil—Interim Report.
Project Number: 030002.
Unpublished study prepared
  by Dow AgroSciences
LLC. 41 p.
25-Mar-2004
46235721
Roberts, D.; Schelle, G.;
Knuteson, J. (2004)
Magnitude of the
Residues for XDE-750 in
Wheat Agricultural
Commodities: Amended
Report.    Project Number:
030042. Unpublished study
prepared by Dow
AgroSciences   LLC. 232
P-
25-Mar-2004
46235722
McCormick, R.; Schelle, G.;
Dolder, S. (2004) Magnitude
of Residue of    XDE-750
and 2, 4-D in Rangeland and
Pasture Grasses. Project
Number:    020018.
Unpublished study prepared
by Dow AgroSciences LLC.
202 p.
25-Mar-2004
                                      -38-

-------
46235723
Rosser, S.; Rutherford, L.;
McFarlane, J. (2004)
Magnitude of XDE-750
Residues in Bovine Tissues
and Milk from a 28-Day
Feeding Study. Project
Number: 030061,
208/001/10. Unpublished
study prepared by Dow
AgroSciences     LLC and
Genesis Midwest
Laboratories. 259 p.
25-Mar-2004
46235724
Bargar, E.; Dybowski, J.
(2004) XDE-750 in or on
Grass Forage, Grass    Hay,
Wheat Commodities, Milk,
Cattle Meat and Meat
By-Products: Section E,
F, and G of the Petition for
Permanent Tolerances and
FQPA Assessment.
Project Number: GH/C/5714.
Unpublished study prepared
by Dow Agrosciences,
LLC. 79 p.
25-Mar-2004
46235725
Magnussen, J. (2004) A
Confined Rotational Crop
Study with 14C
XDE-750. Project Number:
030008. Unpublished study
prepared by Dow
AgroSciences LLC and
Research for Hire. 142 p.
25-Mar-2004
46235726
Cook, W. (2003) Hydrolysis
of XDE-750 at pH 5, 7, and
9. Project    Number:
020067. Unpublished study
prepared by Dow
AgroSciences LLC.  45   p.
25-Mar-2004
                                      -39-

-------
46235727
Cook, W. (2003) Aqueous
Photolysis of XDE-750 in pH
5 Buffer Under   Xenon
Light. Project Number:
020066. Unpublished study
prepared by Dow
AgroSciences LLC. 92 p.
25-Mar-2004
46235728
Rutherford, L. (2004)
Photodegradation of
XDE-750 on Soil. Project
Number: 020080.
Unpublished study prepared
by Dow AgroSciences LLC.
80   p.
25-Mar-2004
46235729
Yoder, R.; Smith, K. (2002)
Aerobic Soil Degradation of
XDE-750 in    Five North
American Soils. Project
Number: 010091.
Unpublished study
prepared by Dow
AgroSciences LLC. 106 p.
25-Mar-2004
46235730
Rutherford, L.; Meitl, T.
(2004) Anaerobic Aquatic
Metabolism of    XDE-750.
Project Number: 020052.
Unpublished study prepared
by Dow   AgroSciences
LLC. 73 p.
25-Mar-2004
46235731
Yoder, R.; Smith, K. (2003)
Degradation of XDE-750 in 2
European and 1    US
Sediment and Pond Water
Systems. Project Number:
020062. Unpublished
study prepared by Dow
AgroSciences LLC. 88 p.
25-Mar-2004
                                      -40-

-------
46235732
Rutherford, L. (2002) Soil
Batch Equilibrium
Adsorption/Desorption of
XDE-750. Project Number:
010064. Unpublished study
prepared by Dow
AgroSciences LLC. 128 p.
25-Mar-2004
46235733
Ward, T.; Boeri, R. (2001)
XDE-750: 14 Day Soil
Exposure Acute   Toxicity
to the Earthworm, Eisenia
foetida. Project Number:
2219/DO,    011049.
Unpublished study prepared
by T.R. Wilbury
Laboratories, Inc. 34   p.
25-Mar-2004
46235734
Roberts, D. (2004) Terrestrial
Field Dissipation of
XDE-750 in the    USA.
Project Number: 020032.
Unpublished study prepared
by Dow   AgroSciences
LLC. 158 p.
25-Mar-2004
46235735
Roberts, D.; Schelle, G.
(2004) Terrestrial Field
Dissipation of    XDE-750
in Canada. Project Number:
020031,
ELECTRONIC/COPY.
Unpublished    study
prepared by Dow
AgroScience LLC. 302 p.
25-Mar-2004
                                       -41-

-------
46235800
Dow AgroSciences, LLC
(2004) Submission of
Toxicity, Fate, Risk, and
Exposure Data in Support of
the Applications for
Registration of
Aminopyralid Technical and
GF-871 and the Petition for
Tolerance of
Aminopyralid on Grass
Forage, Grass Hay, Wheat
Commodities, Milk, Cattle
Meat and Meat By-Products.
Transmittal of Studies 36 of
109 Studies.
25-Mar-2004
46235801
Linscombe, V.; Schisler, M.;
Beuthin, D. (2001)
Evaluation of XDE-750
in the Chinese Hamster
Ovary
Cell/Hypoxanthine-Guanine-
Phosphoribosyl
Transferase (CHO/HGPRT)
Forward Mutation Assay.
Project Number: 011037.
Unpublished study prepared
by The Dow Chemical Co. 26
P-
25-Mar-2004
46235802
Linscombe, V.; Jackson, K.;
Schisler, M.; et. al. (2002)
Evaluation of   XDE-750
in an In Vitro Chromosomal
Aberration Assay Utilizing
Rat    Lymphocytes. Project
Number: 011040.
Unpublished study prepared
by The Dow   Chemical
Co. 40 p.
25-Mar-2004
                                       -42-

-------
46235803
Linscombe, V.; Jackson, K.;
Schisler, M. (2004)
Evaluation of GF-871    in
an In Vitro Chromosomal
Aberration Assay Utilizing
Rat Lymphocyte s.    Proj ect
Number: 031134, 2004/11,
2003/175. Unpublished study
prepared by    The Dow
Chemical Co. 34 p.
25-Mar-2004
46235804
Schisler, M.; Linscombe, V.;
Seidel, S. (2004) Revised
Report for:    Evaluation of
GF-871 in the Chinese
Hamster Ovary
Cell/Hypoxanthine-Guanine-
Phosphoribosyl Transferase
(CHO/HGPRT) Forward
Mutation Assay. Project
Number: 031135, 031135R,
2003/175. Unpublished
study prepared by The Dow
Chemical Co. 24 p.
25-Mar-2004
46235805
Spencer, P.; Gorski, T.
(2002) Evaluation of
XDE-750 in the Mouse Bone
  Marrow Micronucleus
Test. Proj ect Number:
Oil 125. Unpublished study
 prepared by The Dow
Chemical Co. 46 p.
25-Mar-2004
46235806
Spencer, P.; Linscombe, V.;
Grundy, J. (2004) Evaluation
of GF-871 in    the Mouse
Bone Marrow Micronucleus
Test. Proj ect Number:
031136.    Unpublished
study prepared by The Dow
Chemical Co. 42 p.
25-Mar-2004
                                      -43-

-------
46235807
Liu, J. (2004)
(Carbon-14)XDE-750:
Absorption, Distribution,
Metabolism, and Excretion in
Male Fischer 344 Rats:
Amended Final Report.
Project Number: 47456,
021200. Unpublished study
prepared by Analytical
Bio-Chemistry Labs, Inc. 134
P-
25-Mar-2004
46235808
Gallagher, S.; Grimes, J.;
Beavers, J. (2001) XDE-750:
An Acute Oral    Toxicity
Study with the Northern
Bob white. Project Number:
379/106,     011046.
Unpublished study prepared
by Wildlife International,
Ltd. 33 p.
25-Mar-2004
46235809
Gallagher, S.; Grimes, J.;
Beavers, J. (2003) XDE-750
Technical: An   Acute Oral
Toxicity Study with the
Northern Bobwhite. Project
Number:     379/130,
031112. Unpublished study
prepared by Wildlife
International,    Ltd. 34 p.
25-Mar-2004
46235810
Gallagher, S.; Beavers, J.;
Martin, K. (2001) XDE-750:
A Dietary LC50    Study
with the Northern Bobwhite.
Project Number: 379/107,
011047.    Unpublished
study prepared by Wildlife
International, Ltd. 51 p.
25-Mar-2004
                                        -44-

-------
46235811
Gallagher, S.; Beavers, J.;
Martin, K. (2001) XDE-750:
A Dietary LC50    Study
with the Mallard. Project
Number: 379/108, 011048.
Unpublished study
prepared by Wildlife
International, Ltd. 50 p.
25-Mar-2004
46235812
Mach, J. (2003) Avian
Reproduction Study with
XDE-750 in Northern
Bobwhite (Colinus
virginianus): Final Report.
Project Number: 011271,
02001. Unpublished study
prepared by Genesis
Laboratories, Inc. 122 p.
25-Mar-2004
46235813
Mach, J. (2003) Avian
Reproduction Study with
XDE-750 in Mallards
(Anas platyrhynchos):
Amended Final Report.
Project Number: 011272,
02002.    Unpublished
study prepared by Genesis
Laboratories, Inc. 124 p.
25-Mar-2004
46235814
Marino, T.; McClymont, E.;
Yaroch, A.;et. al. (2001)
XDE-750    Herbicide: An
Acute Toxicity Study with
the Rainbow Trout,
Oncorhynchus    my kiss
Walbaum. Project Number:
011078. Unpublished study
prepared by The    Dow
Chemical Co. 36 p.
25-Mar-2004
                                       -45-

-------
46235815
Machado, M. (2003)
XDE-750 - Acute Toxicity to
Bluegill Sunfish
(Lepomis macrochirus)
Under Static Conditions.
Project Number: 12550/6162,
   011225. Unpublished
study prepared by Springborn
Laboratories Inc. 47 p.
25-Mar-2004
46235816
Henry, K.; McClymont, E.;
Yaroch, A.; et. al. (2003)
XDE-750: 96-h    Acute
Toxicity to Larval
Amphibians Using the
Northern Leopard Frog, Rana
   pipiens, as a Biological
Model. Project Number:
031030. Unpublished study
 prepared by The Dow
Chemical Co. 34 p.
25-Mar-2004
46235817
Marino, T.; Hales, C.;
McClymont, E.; et. al. (2001)
XDE-750    Herbicide: An
Acute Toxicity Study with
the Daphnid, Daphnia magna
Straus.    Project Number:
011079. Unpublished study
prepared by The Dow
Chemical Co.     35  p.
25-Mar-2004
46235818
Cafarella, M. (2002)
XDE-750 - Acute Toxicity to
Eastern Oysters
(Crassostrea virginica) Under
Flow-Through Conditions.
Project Number:
12550/6189,011268.
Unpublished study prepared
by Springborn Laboratories
 Inc. 53 p.
25-Mar-2004
                                       -46-

-------
46235819
Machado, M. (2002)
XDE-750 - Acute Toxicity to
Mysids (Americamysis
bahia) Under Static
Conditions. Project Number:
12550/6190,011269.
Unpublished study prepared
by Springborn Laboratories
Inc. 46 p.
25-Mar-2004
46235820
Machado, M. (2002)
XDE-750 - Acute Toxicity to
Sheepshead Minnow
(Cyprinodon variegatus)
Under Static Acute
Conditions.  Project Number:
  12550/6191,011270.
Unpublished study prepared
by Springborn Laboratories
 Inc. 47 p.
25-Mar-2004
46235821
Marino, T.; McClymont, E.;
Yaroch, A.; et. al. (2003)
Revised Report    for
XDE-750: Toxicity to the
Early Life Stages of the
Fathead Minnow,
Pimephales promelas
Rafmesque. Project Number:
021029. Unpublished study
 prepared by The Dow
Chemical Co. 55 p.
25-Mar-2004
46235822
Henry, K.; Marino, T.;
Staley, I; et. al. (2003)
XDE-750: 21-Day
Chronic Toxicity with the
Daphnid, Daphnia magna
Straus. Project Number:
021085. Unpublished study
prepared by The Dow
Chemical Co. 51 p.
25-Mar-2004
                                       -47-

-------
46235823
Putt, A. (2002) XDE-750 -
The Full Life-Cycle Toxicity
to Midge    (Chironomus
riparius) Under Static
Conditions. Project Number:
12550/6195,    011277.
Unpublished study prepared
by Springborn Laboratories
Inc. 88 p.
25-Mar-2004
46235824
Aufderheide, J. (2004) Effect
ofGF-871 on Seedling
Emergence and    Growth
of Selected Non-Target
Terrestrial Plants (Tier II).
Project    Number: 48322,
030066. Unpublished study
prepared by Analytical
Bio-Chemistry Labs., Inc. 89
P-
25-Mar-2004
46235825
Aufderheide, J. (2004) Effect
of GF-871 on Vegetative
Vigor of   Selected
Non-Target Terrestrial Plants
(Tier II). Project Number:
48323,    030066.
Unpublished study prepared
by Analytical Bio-Chemistry
Labs, Inc.    90 p.
25-Mar-2004
46235826
Hoberg, J. (2003) XDE-750 -
Toxicity to Duckweed,
Lemna gibba. Project
Number: 12550/6160,
011223. Unpublished study
prepared by Springborn
Laboratories Inc. 64 p.
25-Mar-2004
                                       -48-

-------
46235827
Hoberg, J. (2002) XDE-750 -
Acute Toxicity to the
Freshwater Diatom
(Navicula pelliculosa).
Project Number: 12550/6198,
011278. Unpublished
study prepared by Springborn
Laboratories Inc. 61 p.
25-Mar-2004
46235828
Hoberg, J. (2002) XDE-750 -
Growth Inhibition Test with
Marine Diatom
(Skeletonema costatum).
Project Number: 12550/6200,
011280. Unpublished
study prepared by Springborn
Laboratories Inc. 62 p.
25-Mar-2004
46235829
Hoberg, J. (2002) XDE-750 -
Growth Inhibition Test with
Freshwater   Blue-green
Alga (Anabaena flos-aquae).
Project Number: 12550/6199,
011279.    Unpublished
study prepared by Springborn
Laboratories Inc. 57 p.
25-Mar-2004
46235830
Hoberg, J. (2003) XDE-750
-Toxicity to the Freshwater
Green Alga,
Pseudokirchneriella
subcapitata. Project Number:
12550/6161,011222.
Unpublished study prepared
by Springborn Laboratories
Inc. 66 p.
25-Mar-2004
                                       -49-

-------
46235831
Aufderheide, J. (2001)
XDE-750: Acute Contact
Toxicity Test with the
Honeybee, Apis mellifera.
Project Number: 46595,
011044. Unpublished study
 prepared by Analytical
Bio-Chemistry Labs, Inc. 17
P-
25-Mar-2004
46235832
Aufderheide, J. (2001)
XDE-750: Acute Oral
Toxicity Test with the
Honeybee (Apis mellifera).
Project Number: 46596,
011045. Unpublished
study prepared by Analytical
Bio-Chemistry Labs, Inc. 20
P-
25-Mar-2004
46235833
Domoradzki, J.; Rick, D.;
Clark, A. (2004) XDE-750,
 Triisopropanolamine Salt:
Dissociation and Metabolism
in Male Fischer 344    Rats.
Project Number: 031129,
2004/8. Unpublished study
prepared by The    Dow
Chemical Co. 57 p.
25-Mar-2004
46235834
Havens, P. (2004) Spray
Drift Assessment for
Terestrial and Aquatic
Non-Target Plants from the
Use of Aminopyralid in
Canada. Project Number:
GH/C/5708. Unpublished
study prepared by Dow
AgroSciences LLC. 28 p.
25-Mar-2004
                                       -50-

-------
46235835
Nelson, J.; Jachetta, J.;
Halstvedt, M.; et. al. (2004)
Public   Interest Document
for Aminopyralid . Project
Number: PID/DOW03JN01.
  Unpublished study
prepared by ABG, Inc. 144 p.
25-Mar-2004
46235836
Tiu, C.; Selman, F. (2004)
Estimation of Exposure and
Risk to Workers    from the
Use of Aminopyralid
Herbicide on Range and
Pasture, Industrial
Vegetation Management and
Cereal Crops in Canada.
Project Number:
GH/C/5715. Unpublished
study  prepared by Dow
Agrosciences LLC. 27 p.
25-Mar-2004
46259600
Dow AgroSciences (2004)
Submission of Reduced Risk
Data in Support of    the
Application for Registration
of Aminopyralid Technical.
Transmittal of   1 Study.
29-Apr-2004
46259601
Jachetta, J.; Havens, P.;
Dybowski, J. et. al.  (2004)
Reduced-Risk    Pesticide
Rationale for Aminopyralid
Technical.. Project Number:
JJ042004.    Unpublished
study prepared by Dow
Agrosciences LLC.  523 p.
29-Apr-2004
46434200
Dow AgroSciences LLC
(2004) Submission of
Product Chemistry and
Toxicity Data in Support of
the Application for
Registration of GF-982.
Transmittal of 6 Studies.
27-Dec-2004
                                       -51-

-------
46434202
McFarlane, J. (2004) Group
B -Phy si cal/Chemi cal
Properties for GF-982,    A
Liquid End Use Product
Containing Aminopyralid
and Fluoroxypyr (Revised
Report). Project Number:
NAFST824. Unpublished
study prepared by Dow
AgroSciences LLC. 5 p.
27-Dec-2004
46434203
Smedley, J. (2003) GF-982:
An Acute Oral Toxicity
Study in Fischer 344    Rats
(Up/Down Study Design):
Final Report. Project
Number: 3504/337,
031118. Unpublished study
prepared by Charles River
Laboratories, Inc. 66    p.
27-Dec-2004
46434204
Smedley, J. (2003) GF-982:
An Acute Dermal Toxicity
Study in Fischer    344
Rats: Final Report. Project
Number: 3504/338, 031119.
Unpublished    study
prepared by Charles River
Laboratories, Inc. 53 p.
27-Dec-2004
46434206
Moore, G. (2003) Primary
Eye Irritation Study in
Rabbits: GF-982.    Project
Number: 14300,031123,
P324/DOW. Unpublished
study prepared by
Product Safety Labs. 18 p.
27-Dec-2004
                                       -52-

-------
46434207
Smedley, J. (2004) GF-982:
A Primary Skin Irritation
Study in New    Zealand
White Rabbits: Final Report.
Project Number: 3504/339,
031120.    Unpublished
study prepared by Charles
River Laboratories, Inc. 45 p.
27-Dec-2004
46434208
Merkel, D. (2003) Dermal
Sensitization Study in Guinea
Pigs (Buehler    Method):
GF-982 (XDE-750
Formulation). Project
Number: 13733,031044,
P328/DOW. Unpublished
study prepared by Product
Safety Labs. 25 p.
27-Dec-2004
46434300
Dow AgroSciences, LLC
(2004) Submission of
Product Chemistry and
Toxicity Data in Support of
the Application for
Registration of GF-1004.
Transmittal of 8 Studies.
27-Dec-2004
46434301
Jensen, J. (2004) Group
A-Product Identity,
Composition, and Analysis
 for GF-1004; and End Use
Product Containing
Aminopyralid and 2, 4-D.
Project Number:
NAFST/04/871,
DAS/AM/03/004.
Unpublished study prepared
by    Dow Agrosciences
(New Zealand) Ltd.. 96 p.
27-Dec-2004
                                       -53-

-------
46434302
McFarlane, J. (2004) Group
B -Phy si cal/Chemi cal
Properties for GF-1004,
A Liquid End Use Product
Containing Aminopropyralid
and 2,4-D. Project
Number: NAFST/04/868.
Unpublished study prepared
by Dow AgroSciences LLC.
 5 p.
27-Dec-2004
46434303
Smedley, J. (2003) GF-1004:
An Acute Oral Toxicity
Study in Fischer    344 Rats
(Up/Down Study Design):
Final Report. Project
Number: 3504/340,
031102. Unpublished study
prepared by Charles River
Laboratories, Inc. 69    p.
27-Dec-2004
46434304
Smedley, J. (2003) GF-1004:
An Acute Dermal Toxicity
Study in Fischer    344
Rats: Final Report. Project
Number: 3504/341,031103.
Unpublished    study
prepared by Charles River
Laboratories, Inc. 53 p.
27-Dec-2004
46434305
Landry, T.; Krieger, S.
(2003) GF-1004: Acute
Liquid Aerosol    Inhalation
Toxicity Study in Fischer 344
Rats. Project Number:
031066.    Unpublished
study prepared by Dow
AgroSciences LLC. 66 p.
27-Dec-2004
                                       -54-

-------
46434306
Moore, G. (2003) GF-1004:
Primary Eye Irritation Study
in Rabbits.    Project
Number: 14299,031105,
P324. Unpublished study
prepared by Product
Safety Labs. 16 p.
27-Dec-2004
46434307
Smedley, J. (2003) GF-1004:
A Primary Skin Irritation
Study in New    Zealand
White Rabbits: Final Report.
Project Number: 3504/342,
031104.    Unpublished
study prepared by Charles
River Laboratories, Inc. 45 p.
27-Dec-2004
46434308
Smedley, J. (2003) GF-1004:
A Dermal Sensitization Study
in Hartley    Albino Guinea
Pigs: Modified Buehler
Design: Final Report. Project
Number:     3504/322,
031039. Unpublished study
prepared by Charles River
Laboratories, Inc. 77 p.
27-Dec-2004
46438900
Dow AgroSciences LLC
(2004) Submission of
Product Chemistry and
Toxicity Data in Support of
the Application for
Registration of GF-982.
Transmittal of 2 Studies.
07-Jan-2005
                                       -55-

-------
46438901
Jensen, J. (2004) Group
A-Product Identity,
Composition, and Analysis
 for GF-982; An End Use
Product Containing
Aminopyralid and
Fluroxypyr   Methylheptyl
Ester. Project Number:
NAFST846,
DAS/AM/03/003.
Unpublished    study
prepared by Dow
AgroSciences LLC and Dow
Agrosciences (New Zealand)
  Ltd. 110 p.
07-Jan-2005
46438902
Landry, T.; Krieger, S.
(2003) GF-982: Acute Liquid
Aerosol Inhalation
Toxicity Study in Fischer 344
Rats. Project Number:
031065. Unpublished
study prepared by The Dow
Chemical Co.  67 p.
07-Jan-2005
Total Rows:  132
                                       -56-

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