Reregistration Eligibility Decision (RED) for MCPA (2-methyl-4-chlorophenoxyacetic acid) List A Case 0017 September 30, 2004


Reregistration Eligibility Decision (RED)
for MCPA (2-methyl-4-chlorophenoxyacetic acid)
List A Case 0017
September 30, 2004

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$ A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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its metabolites. The Food Quality Protection Act (FQPA) 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." 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 as to MCPA and
any other substances, and MCPA does not appear to produce a toxic metabolite produced by other
substances. For the purposes of this tolerance action, therefore, EPA has not assumed that MCPA has 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 EPA's Office of Pesticide 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/.

This document contains generic and product-specific Data Call-In(s) (DCIs) that outline further data
requirements for this chemical. Note that registrants of MCPA must respond to DCIs issued by the Agency
within 90 days of receipt of this letter. This RED also contains labeling requirements for MCPA products.
End-use product labels must be revised by the manufacturer to adopt the changes set forth in Section IV of
this document. Instructions for registrants on submitting revised labeling and the time frame established to do
so can be found in Section V of this document.

Should a registrant fail to implement any of the risk mitigation measures outlined in this document, the Agency
will continue to have concerns about the risks posed by MCPA. Where the Agency has identified any
unreasonable adverse effect to human health and the environment, the Agency may at any time initiate
appropriate regulatory action to address this concern. At that time, any affected person(s) may challenge the
Agency's action.

There will be a 60-day public comment period for this document, commencing on the day the Notice of
Availability publishes in the Federal Register.

If you have questions on this document or the proposed label changes, please contact the Special Review and
Reregistration Division representative, Kelly White at (703) 305-8401 or white.kelly@epa.gov. For questions
about product reregistration and/or the Product DCI that accompanies this document, please contact Bonnie
Adler at (703) 308-8523 or adler.bonnie@epa.gov.
Debra Edwards, Ph.D.
Director, Special Review and Reregistration Division
Office of Pesticide Programs

Attachment
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Reregistration Eligibility Decision

for

MCPA
List A

Case 0017
Approved By:
/s/
Debra Edwards, Ph.D.
Director, Special Review and
Reregistration Division
September 30. 2004
Date
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Table of Contents

MCPA Reregistration Eligibility Decision Team i

Glossary of Terms and Abbreviations ii

Executive Summary iv

I. Introduction 1

n. Chemical Overview 2
A. Regulatory History 2
B. Chemical Identification 3
C. Use Profile 4
D. Estimated Usage of Pesticide 5

HI. Summary of MCPA Risk Assessment 6
A. Human Health Risk Assessment 7
1. Dietary Risk from Food 7
a. Toxicity 7
b. FQPA Safety Factor 9
c. Population Adjusted Dose (PAD) 10
d. Exposure Assumptions 11
e. Food Risk Characterization 11
2. Dietary Risk from Drinking Water 11
a. Surface Water 12
b. Ground Water 13
c. Drinking Water Levels of Comparison (DWLOCs) 13
3. Residential Exposure and Risk 15
a. Toxicity 15
b. Residential Handler Risk 16
(1) Exposure Scenarios, Data, & Assumptions 16
(2) Residential Handler Risk Estimates and Risk Characterization/
d. Residential Postapplication Risk 18
(1) Exposure Scenarios, Data, & Assumptions 18
(2) Residential Postapplication Risk Estimates and Risk
Characterization 20
3. Aggregate Risk 21
a. Acute Aggregate Risk Estimates and Risk Characterization
22
b. Short-term Aggregate Risk Estimates and Risk Characterization . 23
c. Chronic Aggregate Risk Estimates and Risk Characterization
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23
4. Cumulative Risk 23
5. Occupational Risk 24
a. Toxicity 24
b. Occupational Handler Exposure 25
c. Occupational Handler Risk 27
d. Postapplication Occupational Risk 29
(1) Data Sources, Assumptions, and Transfer Coefficients
30
(2) Occupational Postapplication Risk Estimates and Risk
Characterization 32
e. Human Incident Data 32
B. Environmental Risk Assessment 33
1. Environmental Fate and Transport 33
2. Water Resource Assessment 33
a. Ground Water 33
b. Surface Water 34
3. Toxicity (Hazard) Assessment 35
a. Avian, Mammalian, and Non-target Insect Toxicity 35
Toxicity to Mammals 36
b. Toxicity to Aquatic Animals 37
c. Toxicity to Plants 38
4. Exposure and Risk Calculations 40
a. Levels of Concern 40
b. Exposure and Risk to Nontarget Terrestrial Animals 40
(1) Exposure to Birds and Mammals 40
(2) Avian Risk 41
(3) Risk to Mammals 42
(4) Risk to Insects 44
5. Exposure and Risk to Nontarget Aquatic Animals 44
a. Exposure and Risk to Nontarget Plants 44
(1) Risk to Terrestrial Plants 44
(2) Risk to Aquatic Plants 45
6. Ecological Incidents 46
7. Endangered Species 47
8. Risk Characterization 47
a. Terrestrial Animal Risk Characterization 47
b. Aquatic Organism Risk Characterization 48
c. Terrestrial and Aquatic Plant Risk Characterization 49

IV. Risk Management, Reregistration and Tolerance Reassessment 50
A. Determination of Reregistration Eligibility 50
B. Public Comments and Responses 51
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C. Regulatory Position 52
1. FQPA Assessment 52
a. "Risk Cup" Determination 52
b. Determination of Safety for U.S. Population 52
c. Determination of Safety for Infants and Children 52
d. Endocrine Disrupter Effects 55
e. Cumulative Risks 55
f. Tolerance Summary 55
(1) Codex/International Harmonization 58
2. Labels 59
3. Mitigation for Agricultural Uses 59
a. Use Cancellations 59
b. Application Rate Reductions 59
D. Regulatory Rationale 60
1. Human Health Risk Management 61
a. Dietary (Food) Risk Mitigation 61
b. Drinking Water Risk Mitigation 61
c. Residential Risk Mitigation 61
(1) Residential Handler Mitigation 61
(2) Residential Postapplication Mitigation 62
d. Aggregate Risk Mitigation 63
(1) Short-term Aggregate Risk 63
(2) Chronic Aggregate Risk 64
e. Occupational Risk Mitigation 64
(1) Handler Risk Mitigation 64
(2) Post-application Risk Mitigation 66
2. Environmental Risk Mitigation 67
3. Other Labeling Requirements 67
a. Endangered Species Statement 67
b. Spray Drift Management 68

V. What Registrants Need to Do 68
A. Manufacturing Use Products 70
1. Additional Data Requirements 70
2. Labeling for Manufacturing Use Products 71
B. End-Use Products 71
1. Additional Product-Specific Data Requirements 71
2. Labeling for End-Use Products 72
C. Labeling Changes Summary Table 72
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MCPA Reregistration Eligibility Decision Team

Office of Pesticide Programs:

Biological and Economic Analysis Assessment

Jihad Alsadek
Steve Jarboe

Environmental Fate and Effects Risk Assessment

Mark Corbin
Christine Hartless
Sidney Abel

Health Effects Risk Assessment

Byong-Han Chin
Timothy Dole
Felecia Fort
Michael Metzger
Whang Phang

Risk Management

Kelly White, Chemical Review Manager
Thomas Brennan
Demson Fuller
Nathan Mottl
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Glossary of Terms and Abbreviations
Agricultural Data Call-In
Acid Equivalent
Active Ingredient
Acute Population Adjusted Dose
Anticipated Residue
Bioconcentration Factor
Code of Federal Regulations
Chronic Population Adjusted Dose
Confidential Statement of Formula
USDA Continuing Surveys for Food Intake by Individuals
Data Call-In
Dietary Exposure Evaluation Model
Dislodgeable Foliar Residue
AGDCI
ae
ai
aPAD
AR
BCF
CFR
cPAD
CSF
CSFII
DCI
DEEM
DFR
DWLOC Drinking Water Level of Comparison.
EC Emulsifiable Concentrate Formulation
EEC Estimated Environmental Concentration
EPA Environmental Protection Agency
EUP End-Use Product
FDA Food and Drug Administration
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FFDCA Federal Food, Drug, and Cosmetic Act
FQPA Food Quality Protection Act
FOB Functional Observation Battery
G Granular Formulation
GENEEC Tier I Surface Water Computer Model
GLN Guideline Number
HAFT Highest Average Field Trial
IR Index Reservoir
LC50 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.
LD50 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.
LOG Level of Concern
LOD Limit of Detection
LOAEL Lowest Observed Adverse Effect Level
MATC Maximum Acceptable Toxicant Concentration
Hg/g Micrograms Per Gram
Hg/L Micrograms Per Liter
mg/kg/day Milligram Per Kilogram Per Day
mg/L Milligrams Per Liter
MOE Margin of Exposure
MRID Master Record Identification (number). EPA's system of recording and tracking studies submitted.
MUP Manufacturing-Use Product
NA Not Applicable
NAWQA USGS National Water Quality Assessment
NPDES National Pollutant Discharge Elimination System
NR Not Required
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NOAEL No Observed Adverse Effect Level
OP Organophosphate
OPP EPA Office of Pesticide Programs
OPPTS EPA Office of Prevention, Pesticides and Toxic Substances
PAD Population Adjusted Dose
PCA Percent Crop Area
PDF USDA Pesticide Data Program
PHED Pesticide Handler's Exposure Data
PHI Preharvest Interval
ppb Parts Per Billion
PPE Personal Protective Equipment
ppm Parts Per Million
PRZM/EXAMS Tier II Surface Water Computer Model
Qj* The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer Risk Model
RAC Raw Agriculture Commodity
RED Reregistration Eligibility Decision
REI Restricted Entry Interval
RiD Reference Dose
RQ Risk Quotient
SCI-GROW Tier I Ground Water Computer Model
SAP Science Advisory Panel
SF Safety Factor
SLC Single Layer Clothing
SLN Special Local Need (Registrations Under Section 24(c)) of FIFRA)
TGAI Technical Grade Active Ingredient
TRR Total Radioactive Residue
USDA United States Department of Agriculture
USGS United States Geological Survey
UF Uncertainty Factor
UV Ultraviolet
WPS Worker Protection Standard
111
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Executive Summary

EPA has completed its review of public comments on the preliminary risk assessments and is issuing its risk
management decision for MCPA. The revised risk assessments are based on review of the required target
data base supporting the use patterns of the currently registered products and additional information received
from the MCPA Task Force Three. After considering the risks identified in the revised risk assessment and
comments and mitigation suggestions from interested parties, EPA developed its risk management decision for
uses of MCPA that pose risks of concern. The decision is discussed fully in this document.

MCPA is an herbicide in the phenoxy or phenoxyacetic acid family that is used post-emergence for selective
control of broadleaf weeds. MCPA is registered for use on alfalfa, barley, clover, flax, lespedeza, oats,
pasture and rangeland grass, peas, rice, rye, sorghum, trefoil, triticale, and wheat, as well as grass grown for
seed, to control a wide spectrum of broadleaf weeds. MCPA is also registered for use on turf, lawns, vines,
rights-of-way, and forestry applications. Residential homeowners may use MCPA on lawns.

Approximately 4.6 million pounds of MCPA active ingredient are applied annually to approximately 12 million
acres (this figure includes both agricultural and non-agricultural use). Approximately 1.2 millions pounds of
active ingredient are used annually on residential and commercial turf. Most of the agricultural use is allocated
to spring wheat (56%), winter wheat (17%), barley (17%), and oats/rye (4%). The remaining usage is
primarily on seed crops, pasture, hay, lots/farmsteads, dry beans/peas, and flax. Crops with a high
percentage of the total U.S. planted acres treated include spring wheat (33%), barley (28%), flax (23%),
summer fallow (9%), oats/rye (8%), and green beans/peas (4%). Most of the usage is in Michigan,
California, Oregon, Idaho, North Carolina, Florida, Ohio, New York, Texas, Minnesota, North Dakota, and
Washington.

There are four active ingredients associated with MCPA: MCPA acid, MCPA sodium salt, MCPA
dimethylamine salt (MCPA DMAS), and MCPA 2-ethylhexyl ester (MCPA 2-EHE). Formulation types
registered include solids, soluble concentrate/solid, water dispersible granules (dry flowable), and wettable
powder. MCPA is usually applied in combination with other phenoxy class chemicals, such as 2,4-D, 2,4-
DB, MCPP-p, and MCPB. MCPA can be applied anytime, but is recommended for best efficacy in early
spring and early fall.

The Food Quality Protection Act (FQPA) 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." 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 as to MCPA and any other substances,
and MCPA does not appear to produce a toxic metabolite produced by other substances. For the purposes
of this tolerance action, therefore, EPA has not assumed that MCPA has 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
IV
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released by EPA's Office of Pesticide 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/.

Dietary Risk

Acute and chronic dietary exposures for food and drinking water do not exceed the Agency's level of
concern; therefore, no mitigation is warranted at this time for any dietary exposure to MCPA.

Residential Risk

Acute residential risks posed by the use of MCPA are of concern to the Agency. However, EPA
believes that those risks can be reduced to acceptable levels with implementation of the application rate
reductions being required through this RED. In addition, the registrants have agreed to conduct a hand-press
study as a condition of reregistration, which should allow the Agency to further characterize the potential for
residential risks.

Short-term residential risks are currently not of concern to the Agency.

Aggregate Risk

Short-term and chronic aggregate risk posed by the use of MCPA is not of concern to the Agency.
No mitigation is required.

Occupational Risk

Occupational exposure to MCPA is of concern to the Agency. However, EPA believes that those
risks can be reduced to acceptable levels with the implementation of the following mitigation measures: (1)
requiring application rate reductions; and (2) cancelling use on rice and grain sorghum.

Ecological Risk

Ecological risks are of concern to the Agency. The mitigation measures of (1) reducing maximum
application rates, (2) cancelling use on rice and grain sorghum, and (3) specifying a required spray droplet size
of "medium to coarse" (i.e., prohibiting "fine" sprays) are expected to lessen, but not eliminate, the risk of
MCPA to wildlife and plants.
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Conclusions

The Agency is issuing this Reregistration Eligibility Document (RED) for MCPA, as announced in a
Notice of Availability published in the Federal Register. This RED document includes guidance and time
frames for complying with any required label changes for products containing MCPA. With the addition of
the label restrictions and amendments detailed in this document, the Agency has determined that all currently
registered uses of MCPA are eligible for reregistration with the exception of rice. In addition, the registrant
has agreed to cancel use on grain sorghum.

The risk assessments for MCPA are based on the best scientific data currently available to the Agency and
are adequate for regulatory decision making. There is a 60-day public comment period for this document.
VI
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I. Introduction

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended in 1988 to accelerate the
reregistration of products with active ingredients registered prior to November 1, 1984. The amended Act
calls for the development and submission of data to support the reregistration of an active ingredient, as well
as a review of all submitted data by the U.S. Environmental Protection Agency (referred to as EPA or "the
Agency"). Reregistration involves a thorough review of the scientific database underlying a pesticide's
registration. The purpose of the Agency's review is to reassess the potential hazards arising from the currently
registered uses of the pesticide; to determine the need for additional data on health and environmental effects;
and to determine whether or not the pesticide meets the "no unreasonable adverse effects" criteria of FIFRA.

On August 3, 1996, the Food Quality Protection Act of 1996 (FQPA) was signed into law. This Act amends
FIFRA to require tolerance reassessment during reregistration. It also requires that by 2006, EPA must
review all tolerances in effect on the day before the date of the enactment of the FQPA, which was August 3,
1996. FQPA also amends the FFDCA to require a safety finding in tolerance reassessment based on factors
including an assessment of cumulative effects of chemicals with a 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 as to MCPA and any
other substances, and MCPA does not appear to produce a toxic metabolite produced by other substances.
For the purposes of this tolerance action, therefore, EPA has not assumed that MCPA has 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 EPA's Office of Pesticide 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/.

This document consists of six sections. Section I contains the regulatory framework for
reregistration/tolerance reassessment. Section n provides a profile of the use and usage of the chemical.
Section m gives an overview of the revised human health and environmental effects risk assessments resulting
from public comments and other information. Section IV presents the Agency's reregistration eligibility and
risk management decisions. Section V summarizes required label changes based on the risk mitigation
measures outlined in Section IV. Section VT provides information on how to access related documents.
Finally, the Appendices list Data Call-in (DCI) information. The revised risk assessments and related
addenda are not included in this document, but are available on the Agency's web page
www.epa.gov/pesticides. and in the Public Docket.
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n. Chemical Overview

A, Regulatory History

MCPA was first registered in the United States in 1973. In the early 1980s, EPA conducted a thorough
review of the scientific data base on MCPA and reassessed the Agency's earlier regulatory position. A
Registration Standard for MCPA was issued in July 10, 1981, and an MCPA Guidance Document was
issued in March 1982. In June 1988, EPA issued the MCPA Final Registration Standard and Tolerance
Reassessment (FRSTR).

This Reregistration Eligibility Decision (RED) reflects a reassessment of all data to date. The RED evaluates
risks from all currently registered uses, including wheat, barley, oats, rye, residential turf, sod farms, golf
courses, pasture-rangeland, and non-cropland rights-of-way. The document also presents EPA's evaluation
of MCPA use on peas and flax, which is supported by the U.S. Department of Agriculture's (USDA's)
Interregional Research Project #4 (TR-4).

In an effort to promote transparency of the reregistation process and include the public in developing
regulatory decisions, EPA has developed a public participation process that is used for pesticide tolerance
reassessment and reregistation. This public participation process was developed in partnership with USDA,
based on EPA's and USDA's experiences with the pilot public participation process used for the
organophosphate pesticides, comments received from the Tolerance Reassessment Advisory Committee and
the public during the public comment period on the proposed process, and EPA's experience with the interim
process used in developing decisions for a number of non-organophosphate pesticides during the past few
years. The public participation process encompasses full and modified versions that enable EPA to tailor the
level of review to the level of refinement of the risk assessments, as well as to the amount of use, risk, public
concern, and complexity associated with each pesticide.

EPA followed a 4-phase, modified public participation process for MCPA. Consistent with this process,
EPA initiated Phase 1 of the process by transmitting the human health and ecological risk assessments to the
technical registrants for a 30-day error-correction review (Phase 1 opened on March 29, 2004). In Phase 2,
EPA considered the errors that were identified by the registrants and made changes in the risk assessments as
appropriate. To initiate Phase 3 of the process, EPA published a Federal Register notice announcing the
availability of the revised risk assessments and supporting documents for a 60-day public review and
comment period (Phase 3 opened on June 23, 2004). EPA received only 3 comments during the comment
period, none of which were specific to the risk assessment or potential risk mitigation measures.

A risk mitigation meeting was held with the MCPA Task Force Three and USDA on August 17, 2004.
Following that meeting, the MCPA Task Force Three provided new information regarding use rates, acreage,
application frequency, etc., which enabled EPA to significantly refine some of the risk assessments. A close-
out conference call was conducted on September 29, 2004, to discuss the risk management decisions and
resulting changes to the MCPA labels.
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B.
Chemical Identification
MCPA is an herbicide in the phenoxy or phenoxyacetic acid family. The basic manufacturers are Nufarm UK
Limited, A.H. Marks & Co. Ltd., and Dow Agrosciences LLC. The following four forms of MCPA are
registered in the United States: acid, dimethylamine salt (DMAS), sodium salt, and 2-ethylhexyl ester (2-
EHE).

The chemical names, structures, empirical formula, molecular weight, CAS registry numbers, and PC Codes
of the registered MCPA forms are depicted in Figure A.

Figure A: Chemical structures of MCPA Forms
l^yc.
CH3 0
I 1 - ^
1 II CH
CH3 0 3
CH3 0
^V^^l CH2CH3
ll^O^^^ff^ ^^^CH2CH2CH2CH3
CH3 O
MCPA acid
Empirical Formula: C9H9C1O3
Molecular weight: 200.6
CAS Registry No. : 94-74-6
PC Code: 030501
MCPA dimethvlamine salt (DMAS)
Empirical Formula: CUH16C1NO3
Molecular weight: 245.7
CAS Registry No.: 2039-46-5
PC Code: 030516
MCPA sodium salt (Na)
Empirical Formula: C9H8ClNaO3
Molecular weight: 222.6
CAS Registry No.: 3653-48-3
PC Code: 030502
MCPA 2-ethvlhexvl ester (2-EHE)
Empirical Formula: C17H25C1O3
Molecular weight: 312.5
CAS Registry No.: 29450-45-1
PC Code: 030564
MCPA acid is a white to light brown solid, flake, or microcrystalline powder with a melting point of 114-119
C, density of 1.18-1.21 g/ml at 20°C, octanol/water partition coefficient (log Kow) of 2.73, and vapor
pressure of 7.7 x 10'6 mbar at 20°C. MCPA is practically insoluble in water (0.03 g/100 g at 20°C) and is
soluble in a range of organic solvents including acetone (91.8 g/100 g), ethyl ether (50.2 g/100 g), chloroform
(5.5 g/100 g), and benzene (3.3 g/100 g).
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MCPA DMAS is a pale yellow or yellowish-white liquid with a boiling point of III °C, density of 1.181 at
20°C, and octanol/water partition coefficient (log Kow) of 1.415 at 25°C. MCPA DMAS rapidly dissociates
in an aqueous medium to form the free phenoxy acid moiety and the dimethyl ammonium ion.

MCPA 2-EHE is an amber to brown liquid with a boiling point of 260-265°C, bulk density of 8.9 Ib/gal
(1.06 g/mL specific gravity), octanol/water partition coefficient (P0w) of 4.29 x 10"6, and vapor pressure of
1.77 x 10'5 mbar at 20°C. MCPA 2-EHE is slightly soluble in water (0.1%, w:w) and is miscible with most
organic solvents and in mineral oils.

Less chemical identification information is available concerning the MCPA sodium salt as compared to the
other three MCPA formulations. MCPA sodium salt is water soluble and under acidic conditions it reverts to
the acid form (see the MCPA acid chemical identification information, above).

C. Use Profile

The following is information on the currently registered uses including an overview of use sites and application
methods. A detailed table of the uses of MCPA eligible for reregistration is contained in Appendix A.

Type of Pesticide

MCPA is an herbicide in the phenoxy or phenoxyacetic acid family that is used postemergence for selective
control of broadleaf weeds. Phenoxy herbicides act by simulating the action of natural hormones and produce
uncoordinated plant growth. MCPA disrupts both seedling emergence and vegetative vigor, and can be used
to control both dicots and moncots.

Use Sites

MCPA is registered for use on alfalfa, barley, clover, flax, lespedeza, oats, grass, peas, rice, rye, sorghum,
trefoil, triticale, and wheat, as well as grass grown for seed, to control a wide spectrum of broadleaf weeds.
MCPA is also registered for use on residential lawns, sod farm turf, golf courses, rights-of-way, pasture, and
rangeland.

MCPA is usually applied in combination with other phenoxy class chemicals, including 2,4-D, 2,4-DB,
MCPP, and MCPB. It can be applied anytime, but is recommended for best efficacy in early spring and early
fall. The maximum application rate that was assessed in the RED is 4 Ib ai/A. The maximum application rate
that is eligible for reregistration is 3 Ib ai/A.

Target Pests

MCPA is labeled for control of a wide variety of weeds.
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Formulation Types

Formulations include granulars, emulsifiable concentrates, soluble concentrate/liquids and wettable powders.

Method and Rates of Application

MCPA may be applied using aircraft, groundboom sprayers, broadcast spreaders, hand-held sprayers, and
hose-end sprayers. Ground applications are made whenever possible due to lower cost and convenience,
while aerial applications are made to rangeland areas where woody weeds are too tall for a tractor.

Typically one application is made per growing season. The recommended application window for small
grains is the four leaf stage up to the boot stage. Applications are not recommended in the boot to dough
stage. Application rates range from 0.25 to 4.0 Ib acid equivalent per acre (ae/acre). The maximum
application rate for wheat, the largest use of MCPA, is 1.5 Ib ae/acre.

Timing of Application

Typically one application is made per growing season, although two applications per year are permitted for
certain crops or application sites.

D. Estimated Usage of Pesticide

Approximately 4.6 million pounds of MCPA active ingredient are applied annually to approximately 12 million
acres (this figure includes both agricultural and non-agricultural use). Most of the acreage is treated with one
pound a.i. or less per application and one pound a.i. or less per year. Approximately 1.2 million pounds of
active ingredient are used annually on residential and commercial turf. Largest markets in terms of total
pounds active ingredient include wheat, barley, turf, pasture, oats, rice, seed crops, flax, dry peas, green peas,
and rye. Data presented by the MCPA Task Force at the 2001 SMART Meeting indicates that crops with a
high percentage treated of total U.S. planted acres include flax (36%), barley (33%), wheat (27%), rice
(22%), seed crops (21%), dry peas (16%), green peas (14%), and oats (14%). Most of the usage is in
Michigan, California, Oregon, Idaho, North Carolina, Florida, Ohio, New York, Texas, Minnesota, and
North Dakota. Table 1 below summarizes the best available estimates for the pesticide usage of MCPA.
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Table 1: MCPA Crop Usage Summary
Site
Alfalfa
Barley
Beans/Peas, Green
Flax
Golf course turf
Hay, Other
[die Cropland
Lawns and Turf
Lots/Farmsteads/et
Oats/Rye
Pasture
Rice
Seed Crops
Setaside Acres
Sod
Sorghum
Summer Fallow
Wheat, Spring
Wheat, Winter
Woodland
Total
Acres
Grown
(000)
23,701
7,326
709
175
-
33,881
7,275
-
24,232
6,184
75,719
2,992
1,516
20,521
152
11,140
28,567
21,311
44,907
62,089

Acres Treated
(000)
Wtd Avg
8
2050
30
40
31
25
15
0.5
8
500
47
110
140
27
2
4
76
7020
2080
2
12,337
Est Max
23
2,781
67
76
60
43
30
1.0
20
794
230
234
280
53
4
18
153
9,327
3,060
6
14,965
% of Crop
Treated
Wtd Avg
0.03%
28.0%
4.2%
22.9%
-
0.1%
0.2%
-
0.03%
8.1%
0.1%
3.7%
9.2%
0.1%
1.0%
0.03%
0.3%
32.9%
4.6%
0.003%

Est Max
0.10%
38%
9%
43%
-
0.13%
0.41%
-
0.08%
13%
0.30%
8%
18%
0.26%
3%
0.16%
1%
44%
7%
0.01%

LB AI Applied (000)
Wtd Avg
3.1
760.0
8.6
13.6
28.0
16.6
13.3
-
6.1
190.0
18.4
73.3
59.9
12.8
1.6
3.1
16.6
2,550.0
770.0
0.4
4,606
Est Max
10.0
1,020.3
15.8
29.8
58.0
34.2
26.3
-
14.1
313.5
108.0
169.7
119.7
25.5
4.0
16.0
48.0
3,386.7
1,146.1
1.9
5,667
Average Application Rate
Ib ai/
acre/yr
0.41
0.37
0.29
0.34
-
0.65
0.88
-
0.77
0.38
0.39
0.67
0.43
0.48
1.00
0.82
0.22
0.36
0.37
0.22

# appl/yr
1.22
1.06
1.00
1.01
-
1.19
1.00
-
1.24
1.03
1.00
1.04
1.00
1.02
1.00
1.00
1.05
1.10
1.00
1.08

Ibai/
A/appl
0.34
0.35
0.29
0.33
-
0.55
0.88
-
0.62
0.37
0.39
0.64
0.43
0.47
1.00
0.82
0.21
0.33
0.37
0.20

States of Most Usage
(% of total Ib ai used on
this site)
WAWYMTIDPA80%
ND MN WA ID 82%
WAORWIUT81%
NDSCMN81%

CA WA OR MT NC ND 83%
SD81%

ND KS UT OR WA CA 66%
ND SD MN PA WI ME 75%
MN MO 80%
CA AR 86%
ORWA 86%
ND WA MN OR 86%
MN 100%
KS 80%
ND SD WA OR ID 84%
ND MN SD 88%
WA ID OR KS MT SD 79%
ID 95%

COLUMN HEADINGS
Wtd. Avg. = Weighted average—the most recent years and more reliable data are weighted more heavily.
Est. Max. = Estimated maximum, which is estimated from available data.
Average application rates are calculated from the weighted averages.

NOTES ON TABLE DATA
Usage data primarily covers 1991 -2000. SOURCES: EPA, USDA , and National Center for Food and Agricultural Policy.

III. Summary of MCPA Risk Assessment

The following is a summary of EPA's human health and ecological risk findings and conclusions for the
herbicide, MCPA, as presented fully in the following supporting risk assessment documents:

MCPA Revised Human Health Risk Assessment for the Reregistration Eligibility Decision (RED)
Document, dated June 4, 2004;
MCPA Revised Human Health Risk Assessment for the Reregistration Eligibility Decision (RED)
Document, dated September 14, 2004; and
-------
Revised EFED Preliminary Risk Assessment for the 2-methyl-4-chlorophenoxyacetic acid (MCPA)
Reregistration Eligibility Decision Document, dated April 14, 2004.

The purpose of this RED document is to summarize the key features and findings of the risk assessment in
order to help the reader better understand the risk management decisions reached by the Agency. While
the risk assessments and related addenda are not included in this document, they are available in the public
docket.
A.
Human Health Risk Assessment
Risks from dietary exposure (food and drinking water), residential exposure, aggregate exposures, and
occupational exposures have been evaluated for MCPA. MCPA has been classified as a "not likely"
carcinogen; therefore, no carcinogenic analysis was conducted.

1. Dietary Risk from Food

a. Toxicity

The Agency has reviewed all toxicity studies submitted and has determined that the toxicity database
supports a reregistration eligibility determination for all currently supported uses. Further details on the
toxicity of MCPA can be found in the June 4, 2004, Revised Human Health Risk Assessment.

Tables 2-5, below, present a summary of the available acute toxicity data on MCPA acid, MPCA
DMAS, MCPA 2-EHE, and MCPA sodium salt. The available data indicate that acute oral, dermal,
inhalation, and primary dermal irritation toxicity of MCPA are generally of low acute toxicity (Category UJ
to IV). In primary eye irritation studies, only MCPA 2-EHE was found to be of low toxicity (Category
IV). MCPA, MCPA DMAS, and MCPA sodium salt are considered to be strong to severe eye irritants
(toxicity category I). Dermal sensitization potential studies showed that only MCPA 2-EHE was a dermal
sensitizer. NOTE: The technical acute toxicity values included in this document are for informational
purposes only. The data supporting these values may or may not meet the current acceptance criteria.

Table 2: MCPA Acid Acute Toxicity
Study Type
Acute Oral (Rat)
Acute Dermal (Rabbit'
Acute Inhalation (Rat)
lye Irritation (Rabbit)
Dermal Irritation (Rabbit)
Dermal Sensitization (Guinea pig)
MRIDNo.
00021972
250090
40053101
250090
250090
43062806
RESULTS
LD50 = 765 mg/kg
LD50 > 2000 mg/kg
LC50 > 6.3 mg/L
Corneal opacity
No dermal effects
Not a skin sensitizer
Toxicity Category
III
III
IV
I
IV
N/A
-------
-------
Table 3: MCPA 2-EHE Acute Toxicity
Study Type
Acute Oral (Rat)
Acute Dermal (Rabbit'
Acute Inhalation (Rat)
lye Irritation (Rabbit)
Dermal Irritation (Rabbit)
Dermal Sensitization (Guinea pig)
MRIDNo.
156458
156459
156460
156522
156456
40352001
RESULTS
LD50 = 1793 mg/kg
LD50 > 2000 mg/kg
LC50> 1.9.mg/L
No eye irritation
No dermal effects
Skin sensitizer
Toxicity Category
III
III
III
IV
IV
N/A
Table 4: MCPA Amine Acute Toxicity
Study Type
Acute Oral (Rat)
Acute Dermal (Rabbit'
Acute Inhalation (Rat)
lye Irritation (Rabbit)
Dermal Irritation (Rabbit)
Dermal Sensitization (Guinea pig)
MRIDNo.
256980
256980
42113103
256980
256980
40352101
RESULTS
LD50 = 1876 mg/kg
LD50 > 2000 mg/kg
LC50>1.69mg/L
Corneal opacity
Slight dermal irritant
Not a skin sensitizer
Toxicity Category
III
III
III
I
III
N/A
Table 5: MCPA Sodium Salt Acute Toxicity
Study Type
Acute Oral (Rat)
Acute Dermal (Rabbit'
Acute Inhalation (Rat)
lye Irritation (Rabbit)
Dermal Irritation (Rabbit)
Dermal Sensitization (Guinea pig)
MRIDNo.
256979
256979
260067
256979
256979
41613003
RESULTS
LD50 = 3105 mg/kg
LD50 > 2000 mg/kg
LC50>1.6mg/L
Corneal opacity
moderate irritation
Not a skin sensitizer
Toxicity Category
III
III
III
I
III
N/A
A brief overview of the studies used for the dietary risk assessment is outlined in Table 6 in this document.
Additional details regarding the dietary risk assessment can be found in the Revised MCPA Acute and
Chronic Dietary Exposure Assessments for the Reregistration Eligibility Decision, dated June 2, 2004.
10
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Table 6: Summary of Toxicological Endpoints and Other Factors Used in the Human Dietary
Risk Assessment of MCPA
Assessment

Acute Dietary
(General
sopulation)
Acute Dietary
(Females, 13 -
50 years old)
Chronic
Dietary

Cancer
Dose
(NOAEL)
(mg/kg/da
y)
50

4.4

Endpoint

Clinical signs of
neurotoxicity

Total litter
resorptions

Hepatotoxicity
and
nephrotoxicity
Study

Developmental toxicity study with
MCPA DMAS in rats at a LOAEL of
150mg/kg/day (MRID 44954102)
Developmental toxicity study with
MCPA 2-EHE in rats at a LOAEL of
120mg/kg/day (MRID 44954101)
Chronic toxicity and carcinogenicity
study in rats with a LOAEL of 17.6
mg/kg/day (MRID 40634101)
Uncertainty
Factor1

l,000x

FQPA
Safety
Factor

PAD
(mg/kg/
day)

0.05

0.04

0.0044

Classification: Not likely to be carcinogenic to humans
'Uncertainty factor of 1,000 is the result of a lOx for interspecies variability, a lOx factor for intraspecies variability, and
lOx to account for the lack of a developmental neurotoxicity study.

b. FQPA Safety Factor

The Food Quality Protection Act (FQPA) directs EPA, in setting pesticide tolerances, to use an additional
tenfold margin of safety to protect infants and children, taking into account the potential for pre- and
postnatal toxicity and the completeness of the toxicology and exposure databases. The statute authorizes
EPA to modify this tenfold FQPA safety factor with a different FQPA factor only if reliable data
demonstrate that the resulting level of exposure would be safe for infants and children.

FQPA Special Safety Factor

The Agency reduced the default 10X FQPA Special Safety Factor for potential special sensitivity in infants
and children to IX after evaluating the hazard and exposure data for MCPA. The toxicity database
includes acceptable developmental and reproduction studies on MCPA, and there is no evidence except in
the developmental toxicity study with MCPA 2-EFffi (quantitative or qualitative) of susceptibility following
in utero exposure to rats. Also, there is a low level of concern and no residual uncertainties for the effects
seen in the developmental toxicity study in rats after establishing toxicity endpoints and traditional
uncertainty factors to be used in the risk assessment. Therefore, the 10X FQPA Special Safely Factor
was reduced to IX.

Database Uncertainty Factor

EPA concluded that a developmental neurotoxicity study is necessary to further characterize the potential
for pre-natal neurotoxicity due to the presence of clinical signs indicative of neurotoxicity in acute and
subchronic studies. The MCPA toxicology database does not include a DNT study. Therefore, the
11
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Agency applied a 10X Database Uncertainty Factor for assessing risks from exposure scenarios expected
for children or pregnant women. The Agency believes that with the application of the Database
Uncertainty Factor, the regulatory endpoints are protective of children despite the need for a DNT study.

Note that based on an analysis of DNT studies previously submitted, the Agency has revised the size of the
Database Uncertainty Factors for all dietary and residential risk scenarios, other than for acute exposures
(see Section IV.C.l.c).

c. Population Adjusted Dose (PAD)

The PAD is a term that characterizes the dietary risk of a chemical and reflects the Reference Dose, either
acute or chronic, that has been adjusted to account for the FQPA safety factor (i.e., RfD/FQPA safety
factor). In the case of MCPA, the FQPA safety factor is 1; therefore, the acute or chronic RfD is equal to
the acute or chronic PAD. A risk estimate that is less than 100% of the acute or chronic PAD does not
exceed the Agency's risk concern.

Acute PAD:

The acute PAD is the dose an individual could be exposed to on any given day and no adverse health
effects would be expected to occur. A rat developmental toxicity study with MCPA DMAS resulted in a
NOAEL of 50 mg/kg/day for the general population based on clinical signs of neurotoxicity. A rat
developmental toxicity study with MCPA 2-EHE resulted in a NOAEL of 40 mg/kg/day for females that
are 13 to 50 years old, based on total litter resorptions. The uncertainty factors selected were lOx for
intra-species uncertainty, lOx for inter-species uncertainty, and lOx to account for the lack of a
developmental neurotoxicity study, for a total uncertainty factor (UF) of l,000x.

General Population:
Acute RfD = 50 mg/kg/day (NOAEL) + 1,000 (UF) = 0.05 mg/kg/day.
Acute PAD = Acute RfD + FQPA Safety Factor (1) = 0.05 mg/kg/day.

Females 13-50 years old:
Acute RfD = 40 mg/kg/day (NOAEL) + 1,000 (UF) = 0.04 mg/kg/day.
Acute PAD = Acute RfD + FQPA Safety Factor (1) = 0.04 mg/kg/day.

Chronic PAD:

A chronic reference dose for all populations was derived from a chronic toxicity and carcinogenicity study
in rats. The study results yielded a NOAEL of 4.4 mg/kg/day based on hepatotoxicity and nephrotoxicity
in rats at a LOAEL of 17.6 mg/kg/day. The uncertainty factors selected were lOx for intra-species
uncertainty, lOx for inter-species uncertainty, and lOx to account for the lack of a developmental
neurotoxicity study, for a total uncertainty factor (UF) of l,000x.
12
-------
Chronic RfD = 4.4 mg/kg/day (NOAEL) - 1,000 (UF) = 0.0044 mg/kg/day.
Chronic PAD = Chronic RfD + FQPA Safety Factor (1) = 0.0044 mg/kg/day.

d. Exposure Assumptions

The acute dietary exposure to MCPA was estimated using DEEM-FCID™, Version 1.30, which
incorporates food consumption data from USDA's Continuing Survey of Food Intake by Individuals
(CSFII), 1994-1996, 1996. An unrefined Tier 1 assessment was conducted. For acute exposure, the
level of residue present on the various commodities was assumed to be the current tolerance levels for
MCPA acid as set forth at 40 CFR §180.339(a), and it was assumed that 100% of the various crops was
treated with MCPA.

Both DEEM™ and Lifeline™ were used to calculate the chronic dietary exposure estimates based on
average consumption for the U.S. population and population subgroups including infants and children. For
the chronic dietary analysis, the level of residue present on the various commodities was assumed to be the
current tolerance levels for MCPA acid as set forth at 40 CFR §180.339(a), and percent crop treated
information was incorporated.

e. Food Risk Characterization

Generally, a dietary risk estimate that is less than 100% of the acute or chronic PAD is not of concern.
The acute dietary risk from MCPA residues on food is below the Agency's level of concern; that is, less
than 100% of the acute PAD is utilized. For the most exposed subgroup, children (1-2 years), the percent
acute PAD value is 36 at the 95th percentile of exposure.

The chronic dietary risk from food alone is not of concern. For the most exposed subgroup, children (1 to
2 years old), the percent chronic PAD value is 87.

2. Dietary Risk from Drinking Water

Drinking water exposure to pesticides can occur through ground water and surface water contamination.
EPA considers both acute (one day) and chronic (lifetime) drinking water risks and uses either modeling or
actual monitoring data, if available, to estimate those risks. Modeling is carried out in tiers of increasing
refinement, but is designed to provide high-end estimates of exposure.

The Office of Pesticide Programs (OPP) adopted an environmental fate strategy for MCPA based on
linking the dissociation of the salts of MCPA and the hydrolysis of the MCPA 2-EHE to its free acid,
MCPA. In a dissociation study, MCPA-dimethylammonium salt completely dissociated to MCPA and
dimethylammonium ion within 1.5 minutes of stirring in deionized water. Therefore, fate studies with
MCPA will provide data regarding the behavior of MCPA-dimethylamine salt.
13
-------
Existing MCPA monitoring data evaluated in this exposure assessment were available from the United
States Geological Survey (USGS) National Water-Quality Assessment (NAWQA) Program, the United
States Environmental Protection Agency (USEPA) STOrage and RETrieval System for Water and
Biological Monitoring Data (STORET), and recently released data from the USGS Pilot Reservoir
Monitoring Study. The data were evaluated for magnitude and frequency of MCPA occurrence. Annual
maximum concentrations and frequency of detection were determined from each data set. Time weighted
annual mean (TWM) concentrations were determined for the NAWQA and STORET data. The
frequency of detection of MCPA from the USGS Pilot Reservoir Monitoring Study was not sufficient to
calculate TWM concentrations from these data. The highest annual maximum concentration of MCPA
detected in surface water is 18.58 ug/1 from the NAWQA (station 4161820) study. The maximum TWM
concentration of MCPA in surface water is 1.49 ug/1 from the NAWQA (station 4161820) study. The
monitoring data were not targeted to MCPA use areas.

Modeling was completed to augment the monitoring data. Surface water concentrations were modeled
using the Tier n PRZM version 3.127 EXAMS version 2.98.04 model and the EFED graphical interface
(PE4.pl dated January 9, 2003). Ground water concentrations were modeled using the Tier I SCIGROW
version 2.2 model. Eight different crop scenarios were modeled to represent all registered uses and
included wheat in North Dakota and Oregon, peas in Oregon, sorghum in Kansas, and
rangeland/pastureland in California, Pennsylvania, and Minnesota. The OPP standard scenario for alfalfa
was used as a surrogate for rangeland/pastureland in California, Pennsylvania, and Minnesota because its
hydrologic and agronomic practices closely match those of pasture/rangeland and OPP does not have a
currently approved pasture/rangeland scenario. The PRZM/EXAMS scenarios selected for modeling
represent all available OPP scenarios for registered MCPA uses.

a. Surface Water

Based on modeling results, the estimated surface water-derived drinking water concentrations for the use
of MCPA are:

47.3 ug/1 for the 1 in 10 year annual peak concentration (acute)
1.9 ug/1 for the 1 in 10 year annual mean concentration (non-cancer chronic)

The PRZM/EXAMS model results were use in the human health risk assessment, rather than monitoring
data, because the monitoring data available for MCPA is not specific to areas of use of MCPA.

The recommended concentrations in surface water were derived from the Pennsylvania pasture scenario.
The predicted surface water-derived drinking water concentrations will vary depending on regional
climate, soil, environmental characteristics, and watershed characteristics. These model estimates are
approximately double the peak (acute) concentration of 18.58 ug/1 detected in the monitoring data and
roughly equivalent to the maximum TWM concentration of 1.49 ug/1.
Rice
14
-------
Although the MCPA Task Force has indicated that the rice use of MCPA will not be supported, an end
use product is currently registered for rice. For that reason, the Agency prepared an assessment to predict
MCPA concentrations in surface source drinking water impacted from rice tail water releases. MCPA
concentrations in surface source drinking water impacted from rice production were estimated using an
interim screening level model developed by OPP. Model simulation of the maximum seasonal MCPA
application rate of 1.25 pounds ae/acre results in a screening level peak and chronic drinking water
concentration of 1222 ug/1. This value is expected to represent bounding concentration for peak and
annual average drinking water concentrations for MCPA because the model represents an edge of paddy
concentration rather than an actual concentration at a drinking water utility. Additionally, the model does
not account for degradation, dilution, and dispersion of MCPA. Although, based on a Kd value or 0.6
ml/g, MCPA is expected to be highly mobile in tailwater from rice paddies, it is expected to degrade
relatively rapidly in soil and be fairly persistent in aquatic environments. As expected, the estimated
MCPA concentration from the interim model is higher than concentrations detected in the surface water
monitoring data evaluated as part of this assessment. The highest concentration of MCPA detected in
surface water was 18.58 ug/1 from the NAWQA data. The highest concentration of MCPA detected in
surface water in several locations within and downstream of California counties for which MCPA was
used on rice was 0.94 ug/1 (from NAWQA data). Rice is grown in areas of California, Arkansas,
Mississipi, Louisiana, and Texas. It is unlikely that there will be concentrations of MCPA as high as the
modeled estimate in surface water source drinking water due to use on rice.

b. Ground Water

The SCI-GROW model estimate of MCPA concentration in drinking water from shallow groundwater
sources is 2.13 ug/1 using the pasture/rangeland application rate of 4 Ibs. ae/acre. MCPA was not
detected in the NAWQA or STORET groundwater monitoring data evaluated for this assessment. The
estimated concentration can be considered as both the acute and chronic value.

Rice

SCI-GROW modeling estimates the acute and chronic concentration of MCPA in shallow groundwater
from use on rice at a rate of 1.25 Ibs ae/acre is 0.59 ug/1.

c. Drinking Water Levels of Comparison (DWLOCs)

Exposure to pesticides through drinking water can occur as a result of groundwater or surface water
contamination. EPA considers both acute (one day) and chronic (multiple year) drinking water risks. To
determine the maximum allowable contribution from water allowed in the diet, EPA first looks at how
much of the overall risk is contributed by food and then determines a "drinking water level of comparison"
(DWLOC). The DWLOC represents the maximum allowable contribution to the human diet that may be
attributed to residues of a pesticide in drinking water after dietary exposure is subtracted from the aPAD
or cPAD. Risks from drinking water are assessed by comparing the DWLOC to the estimated
15
-------
environmental concentrations (EECs) in surface water and ground water. Generally, the Agency has no
risk concerns when the EECs are below the DWLOC.
The results of the Agency's drinking water analysis are summarized in this document. Details of this
analysis are found in the Revised Human Health Risk Assessment, dated June 4, 2004. Table 7, below,
presents the calculations for the acute drinking water assessment, and Table 8 presents the calculations for
the chronic drinking water assessment.

Table 7: MCPA: Summary of Acute DWLOC Calculations
Copulation Subgroup
General U.S. Population
"emales 13-50 yrs
Children 1-2 yr
All Infants
aPAD
(mg/kg/day)
0.05
0.04
0.05
0.05
Food Exposure1
(mg/kg/day)
0.0084
0.0045
0.018
0.011
Available Water
Exposure2
(mg/kg/day)
0.042
0.036
0.032
0.039
DWLOC3
(ugfl)
1455
1066
322
392
1 Food Exposure = aPAD x % aPAD accounted for by food
2 Available water exposure = aPAD - food exposure
3 DWLOC = water exposure x body weight
Liters of water x 10"3
where body weight = 70 kg for U.S. Population, 60 kg for females, 10 kg for infants and children
Liters of water = 2L for Adults and 1L for infants and children
Table 8: MCPA: Summary of Chronic DWLOC Calculations
Population Subgroup
General U.S. Population
Females 13-50
Children l-6yr.
All Infants
cPAD
(mg/kg/day)
0.0044
0.0044
0.0044
0.0044
Food Exposure1
(mg/kg/day)
0.0012
0.00086
0.0038
0.00099
Available Water
Exposure2
(mg/kg/day)
0.0032
0.0035
0.00059
0.0034
DWLOC3
(ug/l)
111
106
5.88
34.08
2 Available water exposure = cPAD - food exposure
3 DWLOC = water exposure x body weight
Liters of water x 10"3
where body weight = 70 kg for U.S. Population, 60 kg for females, 10 kg for infants and children
Liters of water = 2L for Adults and 1L for infants and children

Table 9, below, presents a comparison of the EECs with the DWLOCs. The EECs are below the
DWLOC values, which indicates that the drinking water residue contribution to the acute and chronic
dietary risk from MCPA is not of concern to the Agency.
16
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Table 9: MCPA: Acute and Chronic DWLOC Values Com
Population Subgroup
General U.S. Population
"emales 13-50 yrs.
Children 1-2 yrs.
All Infants
General U.S. Population
"emales 13-50
Children 1-6 yr.
All Infants
Assessment
Type
acute
Chronic
DWLOC (ug/1)
1455
1066
322
392
111
106
5.88
34.08
pared to Modeled EECs
EEC (Surface
Water) (ug/1)
47.3
47.3
47.3
47.3
1.9
1.9
1.9
1.9
EEC (Ground
Water) (ug/I)
2.13
2.13
2.13
2.13
2.13
2.13
2.13
2.13
3. Residential Exposure and Risk

MCPA is registered for use by homeowners in the residential environment to kill weeds on lawns. It is
also used by professional law care operators on residential lawns. Residents may be exposed to MCPA
through mixing, loading, or applying the pesticide, or by entering a treated site after a residential or
commercial applicator (pest control operator and law care operator) has applied MCPA.

Residential risk is measured by a Margin of Exposure (MOE), which measures how close the residential
exposure comes to the NOAEL from animal studies. Generally, MOEs that are greater than 100 do not
exceed the Agency's level of concern (this incorporates the standard uncertainty factors of lOx for
interspecies variability and lOx for intraspecies variability). However, for the MCPA residential exposure
assessment, the level of concern is 1,000 because it also includes a 10X Database Uncertainty Factor to
account for the lack of a developmental neurotoxicity study. Thus, scenarios that yield MOEs below
1,000 may indicate a risk concern.

For more details about the residential risk assessment, see the MCPA Revised Occupational and
Residential Exposure and Risk Assessment, dated June 11, 2004, which is available in the public docket.
A summary of the inputs and results of this risk assessment are presented below.

a. Toxicity

The lexicological endpoints used for the residential risk assessment are provided in Table 10.
17
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Table 10: MCPA Toxicological Endpoints Used for Residential Risk Assessment
exposure Scenario
Dermal - Short and
ntermediate Term
nhalation - Short and
ntermediate Term
Incidental Oral -
Short and
ntermediate Term
Dose or Factor Used
in Risk Assessment
Dermal NO AEL= 100
mg/kg/day
NOAEL = 4.4
mg/kg/day1
NOAEL= 4.4
mg/kg/day2
Study
21 -day dermal toxicity
study in rats
Chronic toxicity and
carcinogenicity study
in rats
Subchronic
neurotoxicity and
chronic toxicity
studies
Toxicological Effects
LOAEL= 1000 mg/kg/day
based on nephrotoxicity and
decrease in body weight gain.
LOAEL = 17.6 mg/kg/day based
on hepatotoxicity and
nephrotoxicity.
Neurotoxicity, renal, and
testicular toxicities
2 The Agency selected the dose of 4.4 mg/kg/day for short- and intermediate-term incidental oral exposure risk
assessments based on the similarity of toxicity seen in the subchronic neurotoxicity studies in rats with the acid, DMAS,
and 2-EHE forms, as well as the toxicity seen following chronic exposure in rats with the acid.
b.
Residential Handler Risk
(1) Exposure Scenarios, Data, & Assumptions

Potential residential exposures can occur as a result of residential application to lawns. The residential
products are typically formulated as dry weed or feed products or as liquids in concentrates or ready to
use sprays. Many of these formulations include other herbicides such as 2,4-D, MCPP-p, and dicamba.
Both spot and broadcast treatments are included on the labels.

The following residential scenarios were evaluated:

(1) Hand application of granules;
(2) Belly grinder application;
(3) Loading/Applying granules with a broadcast spreader;
(4) Mixing/Loading/Applying with a hose-end sprayer (mix-your-own);
(5) Mixing/Loading/Applying with a hose-end sprayer (ready-to-use);
(6) Mixing/Loading/Applying with a hand-held pump sprayer; and
(7) Mixing/Loading/Applying with a ready-to-use sprayer.

The duration of exposure is expected to be short term for broadcast treatments because the label allows
only two broadcast treatments per year. Exposures are also expected to be short term in duration for spot
treatments because the labels recommend repeat applications in two to three weeks for hard-to-kill weeds.
18
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No chemical-specific data were submitted for residential handler risk assessment, so values from the
Pesticide Handler Exposure Database (PHED) and the Outdoor Residential Exposure Task Force
(ORETF) were used. Exposure data for scenarios #1 and 2 were taken from PHED, and exposure data
for scenarios #3, 4, and 5 were taken from the residential portion of the ORETF Handler Study (MRID
44972201). Exposure data for scenarios #6 and 7 were taken from MRID 44459801, another study
owned by the ORETF. A more complete discussion of the ORETF studies from which the exposure
information was derived is provided in the Occupational and Residential Exposure and Risk Assessment
(revised version, dated June 11, 2004).

For all residential scenarios, the exposure estimates assume that individuals wear short pants, short sleeves
and no gloves. It was assumed that broadcast spreaders and hose-end sprayers would be used for
broadcast treatments and the other application methods would be used for spot treatments only. It was
also assumed that an area of 0.5 acres would be treated during broadcast applications, and that an area of
0.023 acres (1,000 square feet) would be treated per application during spot treatments. Further, it was
assumed that the application rate is 2.0 Ib ae/acre.

(2) Residential Handler Risk Estimates and Risk
Characterization

A summary of the short-term risk estimates for residential handlers is presented in Table 11. As noted
previously, risk estimates are expressed in terms of an MOE. Residential application of MCPA products
to lawns resulted in risk estimates that are not a risk concern to the Agency (i.e., total MOE > 1,000) for
all scenarios except mixing/loading/applying with a hose-end sprayer (mix-your-own formulation). The
mix-your-own hose-end sprayer scenario had an MOE of 620, and therefore exceeded the Agency's level
of concern.

Note that based on an analysis of DNT studies previously submitted, the Agency has revised the Database
Uncertainty Factors for all dietary and residential risk scenarios, other than for acute exposures (see
Section IV.C. l.c). Using the revised uncertainty factors, in addition to data from a new dermal absorption
study and lowered application rates, short-term risks to residential handlers are not of concern (see
Section IV.D.l.c.l).
19
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Table 11: MCPA Short-Term MOEs for Homeowner A
Equipment Type
(1) Applying granules by hand or
ihaker can
(2) Loading/Applying granules
with a belly grinder
|3) Loading/Applying granules
with a broadcast spreader
(4) Mixing/Loading/Applying
iquids with a hose-end sprayer
Imix-your-own)
(5) Mixing/Loading/Applying
iquids with a hose-end sprayer
Iready-to-use)
6) Mixing/Loading/Applying
iquids with hand-held pump
sprayer
(T) Mixing/Loading/Applying
iquids with ready-to-use sprayer
Application
Rate
(Ib ae/acre)
2.0
2.0
2.0
2.0
2.0
2.0
2.0
Dermal
MOE (a)
1300
1400
10,000
640
2700
4000
2800
pplication to Lawns
Inhalation MOE
(b)
14,000
110,000
3,400,000
19,000
28000
1,500,000
190,000
Combined MOE
(c) (MOE Level of
Concern = 1000)
1200
1400
10000
620
2500
4000
2800
(a) Dermal MOE = NOAEL (100 mg/kg/day) / Daily Dermal Dose mg/kg/day). The NOAEL is from a dermal study.
Therefore, no adjustment is made for dermal absorption.
(b) Inhalation MOE = NOAEL (4.4 mg/kg/day) / Daily Inhalation Dose (mg/kg/day). An oral NOAEL was
used to calculate the inhalation MOE. Inhalation absorption was assumed to equivalent to oral absorption.
(c) Total MOE = 1 / (1 /MOE dermal + 1 /MOE inhalation).

d. Residential Postapplication Risk
(1) Exposure Scenarios, Data, & Assumptions
Exposure Scenarios
Potential residential postapplication exposures to adults and children may occur as a result of residential
application or professional lawn care operator application of MCPA products. Specifically, adult and
child exposures were evaluated as a result of ornamental, golf course, and recreational turf and home lawn
uses. Guidance from the Agency's Residential SOPs was used to address the exposures of children
contacting recently treated turf. The SOPs use a high contact activity to represent the exposures of an
actively playing child.

The following residential postapplication scenarios were evaluated:

(1) Acute and short-term exposures of toddlers playing on treated turf;
20
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(2)
(3)
Acute and short-term exposures of adults performing yardwork on treated turf;
Acute and short-term exposures of adults playing golf on treated turf.
Data Sources

There were three chemical-specific turf transferable residue (TTR) studies that were submitted by the
Broadleaf Turf Herbicide TTR Task Force. These studies measured the dissipation of several phenoxy
herbicides, including MCPA, using the ORETF roller technique (which is also called the modified
California Roller). The studies have been reviewed by The Agency and were found to meet all of the
series 875 guidelines for postapplication exposure monitoring. The TTR studies are discussed in detail in
Appendix E of theMCPA Revised Occupational and Residential Exposure and Risk Assessment, dated
June 11, 2004. Table 12, below, provides a summary of the TTR data used for the MCPA post
application exposure assessment.

Table 12: Summary of Turf Transferable Residue Data Used for MCPA Post Application
Exposure Assessment
Study MRID
Location
Precipitation
Application Rate
MCPA Form Applied
Maximum TTR
% Maximum TTR
Day 0 Average TTR
% Average TTR
Semi-log Slope Factor
Days to LOQ
44655702
North Carolina
No Rain
1.55
DMAS
0.53
3.1 -Note 1
0.231
1.3
-0.68
7
44655702
North Carolina
No Rain
1.55
2-EHE
0.318
1.8
0.31
1.8 -Note 2
-0.73 -Note 2
7
45033101
California
No Rain
1.47
DMAS Mix
0.26
1.6
0.20
1.2 -Note 2
-0.44 - Note 2
greater than 7
Note 1 - This value was used to derive the TTR for Iday acute exposures.
Note 2 - These values were used to derived the TTR for seven day average short term exposures.
Assumptions

It was assumed that the maximum label application rate of 2.0 Ibs ae/acre was used. Additionally, the
following general assumptions, from the Standard Operating Procedures (SOPs) of December 18, 1997,
and ExpoSAC Policy #12, "Recommended Revisions to the Standard Operating Procedures for
Residential Exposure Assessments of February 22, 2001" were used:
21
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(1) The TTR values were used for calculating dermal exposures on turf because they were
greater than 1.0% of the application rate. The TTR values were adjusted by a factor of
1.33 to account for the label application rate of 2.0 Ib ae/acre vs the TTR study application
rate of 1.5 Ib ae/acre.
(2) An assumed initial TTR value of 5.0% of the application rate is used for assessing hand to
mouth exposures.
(3) An assumed initial TTR value of 20% of the application is used for assessing object to
mouth exposures.
(4) Soil residues are contained in the top centimeter and soil density is 0.67 mL/gram.
(5) Three-year-old toddlers are assumed to weigh 15 kg.
(6) Hand-to-mouth exposures are based on a frequency of 20 events/hour and a surface area
per event of 20 cm2 representing the palmar surfaces of three fingers.
(7) Saliva extraction efficiency is 50 percent meaning that every time the hand goes in the
mouth approximately /^ of the residues on the hand are removed.
(8) Adults are assessed using a transfer coefficient of 14,500 cm2/hour.
(9) Toddlers are assessed using a transfer coefficient of 5,200 cm2/hour.
(10) Golfers are assessed using a transfer coefficient of 500 cm2/hour.
(11) An exposure duration of 2 hours per day is assumed for toddlers playing on turf or adults
performing heavy yardwork.
(12) An exposure duration of 4 hours is assumed for playing golf.

(2) Residential Postapplication Risk Estimates and Risk
Characterization

Table 13, below, presents the residential turf MOEs for toddlers. The total MOE includes the dermal,
hand-to-mouth, object-to-mouth, and soil ingestion pathways. MOEs that are below 1,000 exceed
EPA's level of concern for residents, children, or other non-occupationally exposed individuals. As shown
in bold, the short-term MOE for toddlers was below 1,000, and therefore was of concern. The total short
term MOE using the maximum TTR value was 280. Dermal exposure was the risk driver that caused the
total MOE to be low.

Also, based on the new dermal absorption study and lowered application rates, acute risk estimates are
now significantly lower (total MOE = 940; see Section IV.D.l.c), which only slightly exceeds the
Agency's level of concern. Because the MOE for combined toddler acute exposures may be of concern
to the Agency, the MCPA Task Force has committed to undertake a study to determine the dermal
22
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transfer efficiency of MCPA residues from turf to dry and wetted palms. This hand-press study is intended
to confirm that the transfer coefficient used in the toddler exposure assessment is conservative and
overestimates risk from mouthing behaviors. The Agency believes that the chemical-specific data in this
study will verify that the residue dislodgeable from wet hands is, to some degree, less than the 5% default
used in the assessment. This study must be submitted within the 9-month time period allotted to submit
revised labels for MCPA.
Table 13: Toddler MOEs for Exposure to Turf Treated with MCPA
Residue Time
Segment
Application
Rate
(Ibs ae/acre)
ITR
(ug/cm )
Dermal
MOE
Hand-to Mouth
MOE
Object to Mouth
MOE
Soil
Ingestion
MOE
Total
MOE
Acute Toddler Risks Using the Maximum TTR (North Carolina Trial 1 using MCPA DMAS)
MAX TTR
2.0 J0.685A J350
1700 J6700
Short Term Toddlers Risks Using California TTR Data (MCPA DMAS Mix, No Rain)
AvgofDAT
0 to DAT 6
2.0
0.13B
1100
380
1500
>100000 J280

>100000
380
Short Term Toddler Risks Using North Carolina TTR Data from Trial 1 (MCPA 2-EHE, No Rain)
AvgofDAT
0 to DAT 6
2.0
0.108C
1300
540
2100
>100000
470
A. This value was derived from the maximum TTR of 3.1 percent (0.531 ug/cm at 1.55 Ib ae/acre) which occurred on DAT 1.
3. This value was derived from the initial TTR of 1.6 percent (0.263 ug/cm at 1.47 Ib ae/acre) and the regression slope factor of -
0.44X.
C. This value was derived from the initial TTR of 1.8 percent (0.306 ug/cm at 1.54 Ib ae/acre) and the regression slope factor of -
0.73X.
The MOEs for adult exposures are summarized in Table 14. The acute MOEs were calculated using the
maximum TTR. The short-term MOEs were calculated using the seven-day average TTR from the
California site. As shown in bold, the MOEs for acute exposure during heavy yardwork did not exceed
1000, and therefore were of concern to the Agency.

Table 14: Adult Acute and Short-term MOEs for Exposure to Turf Treated with MCPA
Exposure Scenario
Heavy Yardwork
Playing Golf
Application Rate
(Ibs ae/acre)
2.0
2.0
TTR
(ug/cm2)
0.685A
0.13B
Females 13 to 50
Acute Dermal MOE
400
5800
All Other Adults
Acute Dermal MOE
590
8500
All Adults
Short Term Dermal
MOE
1900
27000
23
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Exposure Scenario
Application Rate
(Ibs ae/acre)
TTR
(ug/cm2)
Females 13 to 50
Acute Dermal MOE
All Other Adults
Acute Dermal MOE
All Adults
Short Term Dermal
MOE
A. This value was derived from the maximum TTR of 3.1 percent (0.531 ug/cm at 1.55 Ib ae/acre) which occurred on DAT 1.
B. This value was derived from the initial TTR of 1.6 percent (0.263 ug/cm at 1.47 Ib ae/acre) and the regression slope factor of -
0.44X.
3. Aggregate Risk

The Food Quality Protection Act amendments to the Federal Food, Drug, and Cosmetic Act (FFDCA,
Section 408(b)(2)(A)(ii)) require "that there is reasonable certainty that no harm will result from aggregate
exposure to pesticide chemical residue, including all anticipated dietary exposures and other exposures for
which there are reliable information." Aggregate exposure will typically include exposures from food,
drinking water, residential uses of a pesticide, and other non-occupational sources of exposure.

The Agency has developed several guidance documents describing the mathematical approaches used in
calculating aggregate risks, the theoretical basis for these calculations, and the interpretation of the Food
Quality Protection Act that requires the Agency to complete these kinds of calculations.l The underlying
approach, regardless of the calculation type, is the same. The overall, allowable risks associated with an
individual chemical is first determined by its hazard database and its associated uncertainty factors or
negligible risks if the concern is cancer (i.e., an exposure limit is defined). Once limits have been defined,
contributions from different sources are then added to obtain aggregate exposures (dietary [food only] and
residential) which are compared to the exposure limit to see if it has been exceeded which would indicate a
risk concern. If the aggregate exposure limit has not been exceeded, the unallocated portion under it,
which is attributed to drinking water by convention as the DWLOC (Drinking Water Level of Concern) is
then compared to environmental water concentration (EEC or Estimated Environmental Concentration) to
see if the EEC exceeds the DWLOC, which would also indicate a risk concern. The Agency would not
have a risk concern if DWLOCs were calculated and EECs were less than the DWLOCs.

MCPA is a food use chemical. Drinking Water Levels of Comparison (DWLOCs) have been calculated,
and there are residential (non-occupational) uses of MCPA. Therefore, the considerations for aggregate
exposure to MCPA are those from food, drinking water, and residential exposure. For MCPA, aggregate
risk assessments were conducted for acute (one day) and short-term (one to thirty days). Intermediate
and chronic aggregate risks were not assessed because there are no expected intermediate and chronic
residential exposures.
1 There are several aggregate risk guidance documents that address both deterministic and probabilistic
risk assessment approaches. The major science policy papers are available at www.EPA.Gov/pesticides. The two
key documents used for this assessment are 1) Updated Interim Guidance For Incorporating Drinking Water
Exposure Into Aggregate Risk Assessments (Stasikowski, 8/1/99) and 2) HED RARC Format and Risk
Characterization Guidance (12/22/00).
24
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a. Acute Aggregate Risk Estimates and Risk Characterization

The acute residential turf exposures were not aggregated with the acute dietary exposures because it is
extremely unlikely that acute turf exposures would occur concurrently with the acute dietary exposures.
The risks of acute turf exposure were based upon high-end exposures from four individual pathways which
include dermal exposure, hand-to-mouth exposure, object-to-mouth exposure, and soil ingestion, while the
risks of acute dietary exposure were based upon high-end estimates of food residues and consumption
patterns. Currently available distributional assessments lend support to the low likelihood of experiencing
concurrent high-end exposures from all of these sources, and if necessary, chemical-specific higher-tier
distributional assessments can be run if there is reason to believe that the assumptions made in the
individual acute assessments will underestimate risks.
25
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b. Short-term Aggregate Risk Estimates and Risk Characterization
An aggregate exposure assessment that quantifies short-term risks from food, water, and residential
sources was not conducted because the Agency had concern regarding short-term risks from residential
exposure alone. Note, however, that based on an analysis of DNT studies previously submitted, the
Agency has revised the Database Uncertainty Factors for all dietary and residential risk scenarios, other
than for acute exposures (see Section IV.C.l.c). Using the revised uncertainty factors, in addition to data
from a new dermal absorption study and lowered application rates, the Agency determined that short-term
residential risks are not of concern (see Section IV.D. 1 .c). See Section IV.C. 1 .d. 1 for a calculation of the
short-term aggregate risks from food, water, and residential sources, which are not of concern to the
Agency.

c. Chronic Aggregate Risk Estimates and Risk Characterization

No chronic residential scenarios have been identified for MCPA. Therefore, chronic DWLOCs for
MCPA were calculated based on tolerance level residues in food alone. These values are presented in
Table 15. Comparison of the chronic DWLOCs with the environmental concentrations of MCPA
estimated using PRZM-EXAMS and SCI-GROW modeling indicates that chronic aggregate risks are not
of concern. The DWLOCs are less than the surface water EEC of 1.9 ppb and the ground water EEC of
2.13 ug/1. Consequently, there is no chronic aggregate concern for drinking water from surface or
groundwater sources.

Table 15: MCPA Summary of Chronic DWLOC Calculations
Population Subgroup
U.S. Population
Females 13-50 yrs
Children 1-6 yr
All Infants
cPAD (mg/kg/day)
0.0044
0.0044
0.0044
0.0044
Food Exposure
(mg/kg/day)
0.001235
0.000859
0.003812
0.000992
Available Water
Exposure (mg/kg/day)
0.003165
0.003541
0.000588
0.003408
DWLOC (ug/1)
110
110
5.9
34
4.
Cumulative Risk
Section 408(b)(2)(D)(v) of the FFDCA 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." 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 as to MCPA and any other
substances, and MCPA does not appear to produce a toxic metabolite produced by other substances.
For the purposes of this tolerance action, therefore, EPA has not assumed that MCPA has 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 EPA's Office of Pesticide Programs concerning common mechanism
determinations and procedures for cumulating effects from substances found to have a common mechanism
on EPA's website at htto://www.eoa.gov/oesticides/cumulative/.
26
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5. Occupational Risk
Occupational workers can be exposed to a pesticide through mixing, loading, and/or applying a pesticide,
or re-entering treated sites. Occupational handlers of MCPA include: workers in agricultural
environments, turf farms, golf courses, and lawn care professionals. Risk for these potentially exposed
populations is measured by a Margin of Exposure (MOE) which determines how close the occupational
exposure comes to a No Observed Adverse Effect Level (NOAEL). In the case of MCPA, MOEs
greater than 100 do not exceed the Agency's level of concern. This MOE level of concern of 100 is
derived from the standard safety factors of lOx for intraspecies variability and lOx for interspecies
variability. The additional FQPA 10X Database Uncertainty Factor for protection of infants and children
that was used for assessing residential risk does not apply to occupational exposures.

a. Toxicity

The acute toxicity profile for MCPA is listed previously in Tables 2-5. Table 16, below, provides the
toxicity endpoints used in the occupational risk assessment for MCPA. An uncertainty factor of 100X,
incorporating factors of 10X for intraspecies variability and 10X for interspecies variability, was used for
assessing occupational risk. The 10X FQPA Database Uncertainty Factor that was used for the
residential risk assessment does not apply to the occupational risk assessment.

Table 16: Toxicity Endpoints for MCPA Occupational Risk Assessment
Exposure
Scenario
Dermal
(Short/Intermediate
Term)
nhalation
Short, Intermediate
and long-Term
Cancer
Dermal Absorption
7actor
Jncertainty Factor
or Occupational
exposures
Dose or Factor Used in
Risk Assessment
Dermal NOAEL = 100
NOAEL = 4.4 mg/kg/dayA
Study and Toxicological Effects
21 -day dermal toxicity study in rabbits
LOAEL= 1 000 mg/kg/day based on
nephrotoxicity and decrease in body weight gain.
Chronic toxicity and carcinogenicity study in rats
^OAEL = 17.6 mg/kg/day based on
lepatotoxicity and nephrotoxicity.
Classification: Not likely to be carcinogenic to humans
30 percent of the oral dose
100
Dermal absorption study in rats with MCPA
DMAS and MCPA 2-EHE.
Includes standard factors of 10X and 10X for
intraspecies variability and interspecies
extrapolation.
A Inhalation absorption is assumed to be equivalent to oral absorption (100 percent default value).
27
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b. Occupational Handler Exposure
Formulation Types

Currently, there are approximately 160 active products of MCPA formulated from 4 different forms. The
acid, DMAS, 2-EHE forms of MCPA have the most products. Most of the products are formulated as
liquids or granules, although two MCPA acid products are formulated as water soluble powders. These
two products are used on turf.

Application Rates, Timing, and Frequency

Typically one application is made per growing season. The label recommended application window for
small grains is the four leaf stage up to the boot stage. Applications are not recommended in the boot to
dough stage. The label required spray volumes for ground applications range from 20 gallons for most
crops to 100 gallons per acre for vine and brush control. MCPA can be applied over the top to the
labeled crops.

The maximum application rates range from 0.375 to 4.0 Ib ae/acre. One application is made to most
crops.

Application Methods

The MCPA labels allow ground and aerial application, however, they do not allow chemigation. Ground
applications are made whenever possible due to cost and convenience, while aerial applications are made
to rangeland areas where woody weeds are too tall for a tractor (MCPA Smart Meeting, 2001).
According to the USDA Crop Profile for Hard Red Spring and Durum Wheats in North Dakota, 93
percent of herbicide applications are made by ground equipment. A listing of application methods and
amounts of acreage treated per 8 hour day is included in Table 17.

Table 17: MCPA Application Methods
Application Method
Large Groundboom
Average Groundboom
Golf Course Groundboom
Fixed Wing Aircraft
Right of Way (ROW) Sprayer
lurfgun
Backpack Sprayer - Mix/Load/Apply
Tractor Drawn Broadcast Spreader
Push Type Broadcast Spreader
Typical Crops Treated
Small Grains, Flax, Peas
Pasture
Golf Course Turf
Small Grains, Flax, Peas, Rice, Rangeland
Weed Control - 20 gallons per acre
Turf
Spot Treatment
Turf
Turf
Treated Area3
200
80
40
1200
50b
5
4C
40
5
28
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Application Method I Typical Crops Treated | Treated Area"
a. Based upon HED Exposac_SOP #9 "Standard Values for Daily Acres Treated in Agriculture", Revised July 5,
2000
b. Based upon 1000 gallons of spray applied per day from SOP #9 divided by an estimated spray volume of 20
GPA.
c. Based upon 40 gallons of spray applied per day from SOP #9 divided by an estimated spray volume of 10 GPA.
Exposure Scenarios

Short- and intermediate-term occupational risks have been assessed. Chronic occupational risks were not
assessed because they are generally not expected for agricultural uses, and because chronic occupational
exposure is particularly unlikely for MCPA. It is typically applied only once per season, and there is a
limited window of time in the growing season during which use of the product is appropriate.

There is potential occupational handler exposure during mixing, loading, and applying products containing
MCPA to agricultural crops and turf. Based on the application methods show in Table 17, the following
exposure scenarios were assessed.

(1) Mixing/Loading Wettable Powder
(2) Mixing/Loading Liquid Formulations
(3) Loading Granules
(4) Aerial Application
(5) Groundboom Application
(6) Turfgun Application
(7) Right-of-Way Application
(8) Broadcast Spreader Application
(9) Mixing/Loading/Applying Liquids with a Backpack Sprayer
(10) Mixing/Loading/Applying Wettable Powder with a Turfgun
(11) Mixing/Loading/Applying Liquids with a Turfgun
(12) Loading/Applying Granules with a Push Cyclone
(13) Flag Aerial Application

For agricultural handlers, the estimated exposures initially are assessed assuming handlers are using
baseline attire (i.e., long-sleeve shirt, long pants, shoes, and socks). If risk estimates exceed the level of
concern for a given scenario with baseline attire, then exposures are assessed with the addition of personal
protective equipment (PPE) (i.e., chemical-resistant gloves, double-layer body protection, and/or a
respirator) as required. In general, the Agency uses the least PPE necessary to achieve risk estimates that
do not exceed the level of concern. If the risk estimates exceed the Agency's level of concern (i.e., if
MOE < 100) for a given scenario even with the addition of PPE, then the risks are assessed with the use
of engineering controls (i.e., closed system mixing/loading and enclosed cabs or cockpits for applying and
flagging).

Handler Exposure Assumptions

29
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The following assumptions and factors were used in order to complete the exposure and risk assessments
for occupational handlers/applicators.

The average work day was 8 hours.
• The daily acreages treated were taken from EPA Science Advisory Council for Exposure
Standard Operating Procedure #9 "Standard Values for Daily Acres Treated in Agriculture,"
Revised July 5, 2000. These values are provided in the ORE Chapter.
The application rates were generally the maximum rates as listed on one or more labels. The lower
Task Force application rate for pasture/rangeland was also used.
• A body weight of 70 kg was assumed because the endpoint is not gender specific.
The inhalation absorption rate is 100%.
Baseline is long sleeve shirts, long pants, shoes plus socks, and no gloves or respirator.
• Single Layer PPE includes baseline PPE with chemical resistant gloves.
• Double Layer PPE includes coveralls over single layer PPE with chemical resistant gloves.
PF5 indicates a filtering facepiece respirator (i.e. a dustmask) with a protection factor of 5 when
properly fitted.
• PF10 indicates a half mask elastomeric facepiece respirator with a protection factor of 10 when
properly fitted and used with appropriate cartridges.
Only closed cockpit airplanes are used for aerial application.
Airplane pilots do not wear chemical resistant gloves.

Handler Exposure Data Sources

Handler exposure data generated by the Outdoor Residential Exposure Task Force (ORETF) were used
for assessing the following lawn care operator scenarios:

• Turfgun Application
Mix/Load/Apply Water Dispersable Granules with a Turfgun
Mix/Load/Apply Wettable Powder with a Turfgun
• Mix/Load/Apply Liquids with a Turfgun
• Load/Apply Granules with a Push Cyclone

The remainder of the exposure scenarios were analyzed using data from the Pesticide Handlers Exposure
Database (PHED). PHED was designed by a task force of representatives from EPA, Health Canada, the
California Department of Pesticide Regulation, and member companies of the American Crop Protection
Association. It is a software system consisting of two parts - a database of measured exposure values for
workers involved in the handling of pesticides under actual field conditions and a set of computer
algorithms used to subset and statistically summarize the selected data. Currently, the database contains
values for over 1,700 monitored individuals (i.e., replicates). The quality of the data and exposure factors
represents the best sources of data currently available to the Agency for completing these kinds of
assessments.
30
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c. Occupational Handler Risk Estimates and Risk Characterization
Non-cancer risk estimates are expressed in terms of the Margin of Exposure (MOE), which is calculated
by dividing the NOAEL by the dose. For occupationally exposed workers, MOEs greater than or equal
to 100 do not exceed EPA's level of concern. Most of the mixer/loader MOEs for MCPA exceed the
MOE level of concern of 100 with single layer PPE, and therefore are not of concern to the Agency. The
MOE for mixing/loading liquids for aerial application to rangeland/pastures is acceptable at the MCPA
Task Force rate of 2.0 Ibs ae/acre with the addition of a PF5 respirator to single layer PPE. With the
exception of the right-of-way (ROW) application, the MOEs for applicators are above 100 and are not of
concern. The ROW applicator scenario requires double layer PPE with PF10 respirators to achieve an
acceptable MOE. The MOEs for the mixer/loader/applicator and flagger scenarios are generally
acceptable with single layer PPE. A summary of the risk estimates for baseline, PPE and engineering
controls is presented in Table 18.

Table 18: MCPA Short/Intermediate Term MOEs for Occupational Handlers
Exposure
Scenario
Crop or Site
Application
Rate
(Ib/ae/acre)
Acres/
Day
Base-
line
Single
Layer and
Gloves
Single
Layer PF5
and Gloves
Single
Layer PF10
and Gloves
Double
Layer PF10
and Gloves
Eng
Control
MOE and
Gloves
Mixer/Loader (M/L)
M/L WP for
Groundboom
M/L Liquids
for Aerial
M/L Liquids
for
Groundboom
M/L Liquids
for ROW
Sprayer
Load Granulars
for Broadcast
Spreader
Golf Courses
Rangeland,
Pastures
Rangeland,
Pastures
Small Grains,
Rice
Flax, Peas
Rangeland,
Pastures
Rangeland,
Pastures
All other
Crops
Golf Courses
Rights of
Way
Golf Courses
2
4
2
1.5
0.375
4
2
0.375 to 1.5
2
4
2
40
1200
1200
1200
1200
200
200
200
40
50
40
19
0.5
1.0
1.3
5.3
3
6
>8
30
12
1900
76
29
58
77
310
170
340
>460
1700
700
1900
240
51
100
140
550
310
620
>820
3100
1200
6000
330
57
120
150
600
340
780
>910
3400
1400
8100
380
72
140
190
770
430
1400
>1200
4300
1700
12000
5700
140
280
370
1500
830
4400
>2200
8300
3300
36000
Applicator
Aerial
Application
All Crops
Above
0.375 to 4.0
1200
ND
ND
ND
ND
ND
>220
-------
Exposure
Scenario
Groundboom
Application
Rights of Way
Application
Broadcast
Spreader
Application
Crop or Site
All Crops
Above
Rights of
Way
Golf Courses
Application
Rate
(Ib/ae/acre)
0.375 to 4.0
4
2
Acres/
Day
40 to
200
50
40
Base-
line
>280
25
2400
Single
Layer and
Gloves
>280
73
2500
Single
Layer PF5
and Gloves
>500
86
6900
Single
Layer PF10
and Gloves
>560
88
8800
Double
Layer PF10
and Gloves
>690
120
13000
Eng
Control
MOE and
Gloves
>1500
ND
12000
Mixer/Loader/Applicator (M/L/A)
M/L/A Liquids
with Backpack
Sprayer
M/L/A
Wettable
Powder with
lurfgun
M/L/A Liquid
Flowables with
lurfgun
Load/Apply
Granules with a
Push Cyclone
Spot
Treatment
Turf
Turf
Turf
4
2
2
2
4
5
5
5
ND
ND
ND
ND
160
330
1300
220
170
690
1400
270
170
790
1400
270
270
1300
2600
420
ND
1100
ND
ND
Flagger
Flag Aerial
Application
Rangeland,
Pastures
Rangeland,
Pasture
All other
Crops
4
2
0.375 to 1.5
1200
1200
1200
77
150
>210
73
150
>190
110
220
>290
110
220
>300
120
240
>330
3800
7600
>10000
Mote - MOEs in bold font are below the MOE Level of Concern of 100, and therefore indicate risks of concern.
d. Postapplication Occupational Risk

Postapplication exposures to MCPA can occur in the agricultural environment when workers enter fields
recently treated with MCPA to conduct tasks such as scouting and irrigation. MCPA is typically applied
once per season and the window of time in the growing season during which applications can made is only
a few weeks long. Therefore, it is anticipated that MCPA postapplication exposures would be primarily
short-term and, more rarely, intermediate term.
32
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Only dermal exposures were evaluated in the postapplication worker assessment. Postapplication
inhalation exposures are not anticipated because of the low vapor pressure of MCPA (7.7e"°6 mbar at 20
C). Postapplication oral exposures were not evaluated because the Agency currently has no policy or
method for evaluating non-dietary oral ingestion by workers due to poor hygiene practices or smoking.

In the Worker Protection Standard, a restricted entry interval (REI) is defined as the duration of time
which must elapse before residues decline to a level so entry into a previously treated area and engaging in
any task or activity would not result in exposures which are of concern. Typically, the activity with the
highest risk will drive the selection of the appropriate REI for the crop.

(1) Data Sources, Assumptions, and Transfer Coefficients

Data Sources

Data from three turf transferable residue studies submitted by the Broadleaf Turf Herbicide Task Force
was used to estimate the risk to workers from the transfer of MCPA from treated turf. These studies are
discussed in Section UI.A.3.C.1 of this document and in the MCPA Revised Occupational and Residential
Exposure and Risk Assessment, dated June 11, 2004.

With the exception of the turf transferable residue data, there were no chemical-specific data submitted to
determine foliar transfer coefficients for MCPA. Therefore, the Dislodgeable Foliar Residue (DFR) was
assumed to be 20% for all crops except turf. This is the standard value used in the absence of chemical
specific data.

Assumptions

The following assumptions were made regarding postapplication occupational exposure.

Risks were assessed using maximum label rates.
• The transfer coefficients, as listed in Table 19, are from an interim transfer coefficient policy
developed by HED's Science Advisory Council for Exposure using proprietary data from the
Agricultural Re-entry Task Force (ARTF) database (US EPA, August 7, 2001).
The transfer coefficients for turf harvesting and maintenance are based upon recently submitted
studies discussed above.
• The initial percent of application rate as Dislodgeable Foliar Residue (DFR) was assumed to be
20% for all crops except turf. These are the standard values used in the absence of chemical
specific data.
The Maximum TTR value (3.1 percent of the application rate) from the DMAS Treatment at the
North Carolina Site was used to assess risks of working on turf in wet growing regions.
• The Maximum TTR value (1.6 percent of the application rate) from the DMAS Combination
Treatment at the California Site was used to assess risks of working on turf in dry growing regions.

33
-------
34
-------
Transfer Coefficients
The exposure scenarios and corresponding transfer coefficients used in the occupational postapplication
assessment are presented below, in Table 19.

Table 19: Post Application Exposure Scenarios and Transfer Coefficients for MCPA
Crop

Flax

Peas

Rice

Small
Grains

Sorghum,
Grain

Turf, Sod
Farm and
Golf Course

Transfer
Coefficient
Group
7ield/row
crop, low/
medium

7ield/row
crop, low/
medium

7ield/row
crop, tall

Turf/Sod

Label Directions

Post Application Exposure Scenarios
Apply when flax is 2 to 8 inches tall. Do not spray once flax
las reached bud stage.

^ow Exposure Scenarios - Irrigation, scouting, immature plants
VIedium Exposure Scenarios - Scouting mature plants
Jse only in the Pacific Northwest. Treat when peas are 4 to 6
inches tall.

^ow Exposure Scenarios - Irrigation, scouting, immature plants
Vlake applications only when weeds are present and where rice
s well established, 6 to 8 inches above water. Make
applications no sooner than 35 and no later than 65 days after
seeding or when crop stems begin to elongate. Water should
not be less than 2 to 3 inches deep. Do not apply after the boot
stage.
^ow Exposure Scenarios - Scouting, immature plants
VIedium Exposure Scenarios - Scouting mature plants
Apply after grain is fully tillered (4 to 8 inches high, but not
brming joints in the stem).
3o not apply in the boot to dough stage
^ow Exposure Scenarios - Scouting, immature plants
VIedium Exposure Scenarios - Scouting mature plants
Apply when sorghum is 6 to 12" tall but before the boot stage.

^ow Exposure Scenarios - Scouting immature plants
7or optimum results, turf should not be mowed for 1 to 2 days
after application

^ow Exposure Scenarios - Mowing
-ligh Exposure Scenarios - Transplanting, hand weeding
Transfer
Coefficient
(cm2/hr)

100
1500

100

100
1500

100

3400
6800
35
-------
36
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(2) Occupational Postapplication Risk Estimates and Risk
Characterization

The highest postapplication exposure risks are for small grains and rice when using the maximum label
application rates. However, label language and usage information indicate that maximum rates are
infrequently employed. The maximum label rate for small grains is used only for emergency control
because it can damage the crop. The maximum label rate for rice is used when only one application is
made as specified by a few of the labels. The remaining labels indicate that if two applications are needed,
they should be made at one-half the maximum rate.

The Worker Protection Standard (WPS) Restricted Entry Interval (RET) for MCPA is 12 hours for the
ester form and 48 hours for the amine and sodium salt forms. There is no REI for the acid form, because
the acid form is used only on non-agricultural sites (such as lawns and golf courses) that are not covered in
the WPS.

A summary of the occupational risks for short and intermediate term postapplication exposures is given in
Table 20, below. All of the short/intermediate term MOEs are above 100 on Day 0 which indicates that
the risks are not of concern.

Table 20: MCPA Postapplication Worker Risks
Crop
7lax
>eas
Small Grains, Rice
Sorghum
Turf
Transfer Coefficient
Group
Field/row crop, low/medium
Field/row crop, low/medium
Field/row crop, low/medium
Field/row crop, tall
Turf - California
Turf - North Carolina
Short/Intermediate Term MOE on Day 0
Application
Rate
(Ib ae/acre)
0.375
0.375
1.5
0.75
2.0
2.0
Low
Exposure
Scenarios*
10000
10000
2600
5200
720
380
Medium
Exposure
Scenarios*
690
NA
170
1300
NA
NA
High
Exposure
Scenarios*
NA
NA
NA
NA
360
190
Task descriptions for each crop and exposure scenario are provided in the ORE Chapter.
e.
Human Incident Data
Relatively few incidents of illness have been reported due to MCPA. Poison Control Center Data (1993
through 2001) indicated that there were relatively few exposures to products containing MCPA as the only
active ingredient. Out of 28 reported exposures, 12 received follow-up to determine final medical
outcome. Final medical outcome was none for three cases, minor for six, and moderate for three cases.
Primary symptoms were dermal including one moderate case who reported bullae, erythema, and rash.
The other two moderate cases reported difficulty breathing in one person and headache, eye irritation and
37
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tearing in the other. This information suggests that MCPA can be a cause of irritative effects to skin, eyes,
and respiratory tract. Similar symptoms of exposure to MCPA were seen in data from California (5
incidents related to MCPA for 1982 - 2002) and in the literature. A literature search showed one fatal
case, characterized as a suicide, involving a 32 year-old male who intentionally ingested 440 mg/kg and
died about 20 hours after the ingestion.

B. Environmental Risk Assessment

A summary of the Agency's environmental risk assessment is presented below. For detailed discussions of
all aspects of the environmental risk assessment, see the Revised Environmental Fate and Effects Division
Preliminary Risk Assessment for the 2-methyl-4-chlorophenoxyacetic acid (MCPA) Reregistration
Eligibility Decision Document (hereafter, the Revised EFED RED Document for MCPA), dated April 14,
2004.

1. Environmental Fate and Transport

As discussed in Section n, four forms of MCPA are registered in the United States: acid, dimethylamine
salt (DMAS), sodium salt, and 2-ethylhexyl ester (2-EHE). A detailed discussion of the environmental
fate, transport, and physical-chemical properties and chemical structures of the four forms is provided in
the Revised EFED RED Document for MCPA (dated April 14, 2004). For this assessment, EPA
developed a bridging strategy based on the fact that MCPA DMAS, sodium salt, and 2-EHE rapidly
convert to MCPA acid. Based on data submitted by the registrant that supported the bridging strategy,
EPA determined that studies conducted with MCPA acid could provide surrogate data for the DMAS,
sodium salt, and 2-EHE forms.

In general, MCPA acid is practically insoluble in water, non-volatile, somewhat lipophilic (log K^ 2.8),
and exists naturally as a solid. MCPA acid does not hydrolyze. MCPA photodegraded very slowly when
applied to soil surfaces and irradiated with natural sunlight (half-life 67 days). In an aerobic soil
metabolism study MCPA acid degraded with a half-life of 24 days. Under aerobic aquatic conditions,
MCPA acid degraded with a total system half-life of >30 days in a water-sandy clay loam sediment
systems. In laboratory batch equilibrium studies, MCPA acid was shown to be extremely mobile.

2. Water Resource Assessment

Water modeling was conducted to determine potential exposure to aquatic animals. The modeling results
are summarized here. Refer to the Revised EFED RED Document for MCPA for an in-depth discussion
of the water models.

a. Ground Water
38
-------
The Agency does not use ground water modeling information to assess exposure to aquatic animals.
Residues in surface water are almost always greater than residues in ground water and therefore use of
surface water models is more protective.

b. Surface Water

The Agency used PRZM-EXAMS to calculate refined Estimated Environmental Concentrations (EECs)
for MCPA. The Pesticide Root Zone Model (PRZM, versions 3.12 and 2.98.04) simulates pesticides in
field runoff, while the Exposure Analysis Modeling System (EXAMS, version 2.97-5) simulates pesticide
fate and transport in an aquatic environment (one hectare body of water, two meters deep). Eight different
crop scenarios were modeled, including wheat in North Dakota and Oregon, peas in Oregon, sorghum in
Kansas, and rangeland/pastureland in California, Pennsylvania, and Minnesota. The standard scenario for
alfalfa was used to represent rangeland/pastureland in California, Pennsylvania, and Minnesota. The alfalfa
scenario was chosen because its hydrologic and agronomic practices closely match those of
pasture/rangeland for which an approved scenario has not been developed. An additional non-crop
scenario was run for turf in Pennsylvania. Finally, a second set of rangeland/pasture scenarios were run
using the MCPA Task Force-supported use rate of 2 Ib ae/acre with 2 applications 30 days apart as
opposed to a single application of 4 Ibs ae/acre which can be found on currently registered labels. These
scenarios were chosen to model the concentration of MCPA in surface drinking water over a
geographically dispersed range of surface water concentrations in areas representative of heavy MCPA
use (i.e. northern Great Plains and northwestern US).
Aquatic EECs for the ecological exposure to MCPA acid were estimated using PRZM 3.12/EXAMS
2.98 employing the small water body scenario, a Tier 2 screening model designed to estimate pesticide
concentrations found in water at the edge of a treated field. As such, it provides high-end estimated values
of the pesticide concentrations that might be found in ecologically sensitive environments following
pesticide application. PRZM-EXAMS is a multi-year runoff model that also accounts for spray drift from
multiple applications. In the ecological exposure assessment, PRZM-EXAMS simulates a 10 hectare (ha)
field immediately adjacent to a one hectare small water body, 2 meters deep with no outlet. The location
of the field is specific to the crop being simulated using site specific information on the soils, weather,
cropping, and management factors associated with the scenario. The crop/location scenario is intended to
represent a high-end exposure site on which the crop is normally grown. Based on historical rainfall
patterns, the small water body receives multiple runoff events during the years simulated. The aquatic
ecological exposure assessment relied on the same modeling scenarios as those used in the human health
drinking water exposure assessment discussed above.

Acute risk assessments are performed using peak EEC values for single and multiple applications. Chronic
risk assessments for invertebrates and fish are performed using the average 21-day and 60-day EECs,
respectively. Table 21 presents the PRZM/EXAMS estimated exposure concentrations (EECs) of
MCPA in surface water for the eight different crop scenarios.
39
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Table 21: Estimated Environmental Concentrations (EECs)
Simulation Scenario
Crop and Location
North Dakota wheat
Oregon wheat
California pasture
California pasture
Pennsylvania pasture
Pennsylvania pasture
Minnesota pasture
Minnesota pasture
Kansas sorghum
Oregon peas
Pennsylvania turf
Application
rate
(ae/acre)
1.5
1.5
4
2
4
2
4
2
0.75
0.375
2.0
# Applications
1
1
1
2
1
2
1
2
1
1
1
EEC (ug ae/L)
l-in-10 year
Peak
11.68
9.94
18.48
14.60
23.02
21.14
16.94
22.35
13.08
4.12
5.69
21 Day
Average
5.38
5.54
11.27
8.64
13.69
12.52
9.18
10.74
6.14
2.53
2.88
60 Day
Average
2.72
2.57
5.60
5.48
6.69
6.53
4.71
5.27
2.61
1.18
1.36
3. Toxicity (Hazard) Assessment
a. Avian, Mammalian, and Non-target Insect Toxicity
Toxicity to Birds
Acute toxicity tests indicate that technical MCPA is "moderately toxic" to "practically non-toxic" to birds
exposed for short periods based on the submitted studies for MCPA acid and MCPA DMAS. No
adverse effects were demonstrated in the avian reproduction toxicity study submitted for MCPA acid.

The acute toxicity of technical grade MCPA to birds was established with two avian single-dose oral
(LD50) studies on the bobwhite quail using MCPA acid and MCPA DMAS and two sub-acute dietary
studies (LC50) on the mallard duck and the bobwhite quail using MCPA DMAS. No avian acute data
were submitted for MCPA sodium salt or MCPA 2-EHE; these studies are not required based on the
bridging strategy discussed in Section m.B. 1. Avian acute toxicity summary data for MCPA are
presented in Tables 22 and 23.

A single avian chronic exposure reproduction effects study was performed for MCPA using MCPA acid
on bobwhite quail (Table 24). No negative effects were observed in this study; therefore, the NOAEC =
1000 mg ae/kg-diet (the highest dose tested) and the LOAEC was >1000 mg ae/kg-diet. No avian
chronic data were submitted for MCPA sodium salt, MCPA DMAS, or MCPA 2-EHE; these studies are
not required based on the bridging strategy discussed in Section in.B.l.
40
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41
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Table 22: Acute Toxicity to MCPA to Birds (oral gavage administration)
PC#
a.i.
030501 -MCPA Acid
030516 - MCPA DMAS Salt
Species
Bobwhite quail
Bobwhite quail
% a.i.
94.6
56.4
LDjo. nig/kg-bw (conf. interval)
a.i.
377
270(173,480)
a.e.a
377(314,452)
221 (142, 394)
Toxicity Classification
(based on a.e.)
moderately toxic
moderately toxic
" Acid equivalency calculated as: 90.3% for MCPA sodium salt, 81.7% for MCPA DMAS, and 64.1% for MCPA 2-EHE.

Table 23: MCPA DMAS Salt Acute Toxicity to MCPA to Birds (dietary administration)
Species
Bobwhite quail
Mallard duck
% a.i.
56.4
56.4
LC50, mg/kg-diet (conf. interval)
a.i.
>5620
>5620
a.e.a
>4608
>4608
Toxicity Classification
(based on a.e.)
practically non-toxic
practically non-toxic
1 Acid equivalency calculated as: 90.3% for MCPA sodium salt, 81.7% for MCPA DMAS, and 64.1% for MCPA 2-EHE.
Table 24: MCPA Chronic Toxicity to MCPA to Birds
Species
Bobwhite quail
% a.i.
94.22
NOAEC (mg/kg-diet)
a.i.
1000
a.e.a
1000
LOAEC (mg/kg-diet)
a.i.
>1000
a.e.
>1000
Effects
None
" Acid equivalency calculated as: 90.3% for MCPA sodium salt, 81.7% for MCPA DMAS, and 64.1% for MCPA 2-EHE.

Toxicity to Mammals

Available mammalian toxicity data on laboratory mammals was used to approximate toxicity to mammalian
wildlife. The portion of that data used for calculating risk quotients is summarized in Table 25.

In general, toxicity tests indicate MCPA is "slightly toxic" to mammals exposed for short periods based on
data submitted for MCPA acid, sodium salt, DMAS, and 2-EHE. The rat two-generation toxicity study
was used for risk calculations. Adverse effects similar to those seen in the two-generation study were also
demonstrated in mammalian subchronic and developmental studies. Detailed discussions of the mammalian
toxicity profile for these and other studies can be found in the June 4, 2004, Revised Human Health Risk
Assessment.

Table 25: Mammalian Toxicity Studies Used for RQ Calculations
42
-------
Test Type

2-generation
reproductive
(rats)

MCPA
Form

MCPA
Acid

% a.i.

94.8

NOAEC
(mg/kg-diet)
a.i.
parental=
150
repro=
150
off spring =
450
a.e.a
parental=
150
repro=
150
offspring=4
50
LOAEC
(mg/kg-diet)
a.i.
parental=
450
repro=
450
offspring>
450
a.e.
parental=
450
repro=
450
offspring
>450
Effects
Parental: Increased absolute and
relative ovary wts (p<0.05; 23-
25% greater than controls)
Repro: decreased pup weight
gain during lactation
Offspring: none observed
Non-Target Insects

Guideline toxicity tests show that MCPA is "practically non-toxic" to honey bees (Table 26).

Table 26: Acute Contact Toxicity of MCPA to Non-target Insects
PC# and a.i.
030516 - MCPA DMAS Salt
030564 - MCPA 2-EHE
Species
Honey bee
Honey bee
% a.i.
63.42
93.9
Toxicity endpoint
a.i.
LD50 > 25 • g/bee
LD50 > 25 • g/bee
a.e,a
LD50>21 • g/bee
LD 50 > 17- g/bee
Toxicity
classification
(based on a.e.)
practically non-toxic
practically non-toxic
" Acid equivalency calculated as: 90.3% for MCPA sodium salt, 81.7% for MCPA DMAS, and 64.1% for MCPA 2-EHE.

b. Toxicity to Aquatic Animals

For fish and invertebrates, most of the toxicity endpoints are within one order of magnitude when restricted
to evaluating the MCPA acid, sodium salt and DMAS. The toxicity of MCPA 2-EHE tends to be two to
three orders of magnitude greater than the toxicity of the acid and salts. EPA believes that the primary
reason for the differences in the levels of toxicity between the ester formulation relative to the salts and acid
is that esters have a greater affinity for uptake through cell wall membranes.

Toxicity to Freshwater Fish

No studies were submitted to the Agency evaluating toxicity of MCPA acid to freshwater fish.
Toxicity studies using an end-use product for the sodium salt show that MCPA sodium salt is 'slightly
toxic' to freshwater fish under acute exposure. Toxicity studies conducted using the technical and an end-
use products (Rhomene) for MCPA DMAS demonstrate it is 'slightly toxic' to 'practically non-toxic' to
freshwater fish under acute exposure. Toxicity tests show technical MCPA 2-EHE is 'highly toxic' to
'moderately toxic' to freshwater fish exposed for short periods of time.

Toxicity to Freshwater Invertebrates
43
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No studies were submitted to the Agency evaluating toxicity of MCPA acid to freshwater invertebrates. A
toxicity study using an end-use product for the sodium salt (Chiptox) shows that MCPA sodium salt is
'practically non-toxic' to freshwater invertebrates under acute exposure. Toxicity studies conducted using
the technical product and an end-use product (Rhomene) for MCPA DMAS demonstrate it is 'slightly
toxic' to 'practically non-toxic' to freshwater invertebrates under acute exposure. Toxicity tests show
technical MCPA 2-EHE is 'highly toxic' to freshwater invertebrates exposed for short periods of time.

One invertebrate life-cycle toxicity study was conducted for MCPA DMAS. The study on daphnids
indicated a NOAEC of 11 mg ae/L and a LOAEC of 22 mg ae/L with the most sensitive parameter of
reproduction.
Toxicity to Estuarine/Marine Fish

A toxicity study conducted using the technical product for MCPA acid demonstrates it is 'practically non-
toxic' to estuarine/marine fish under acute exposure. A toxicity study conducted using an end-use product
(Chiptox) for MCPA sodium salt demonstrates that it is 'practically non-toxic' to estuarine/marine fish
under acute exposure. Toxicity studies conducted using the technical product and an end-use product
(Rhomene) for MCPA DMAS demonstrate it is 'practically non-toxic' to estuarine/marine fish under acute
exposure. Toxicity tests show technical MCPA 2-EHE is 'moderately toxic' to estuarine/marine fish
exposed for short periods of time.

No estuarine/marine fish chronic toxicity studies of MCPA acid, salts, or ester were submitted to the
Agency.

Toxicity to Estuarine/Marine Invertebrates

Toxicity studies conducted using the technical for MCPA acid demonstrate it is 'practically non-toxic' to
estuarine/marine invertebrates under acute exposure. Toxicity studies conducted using an end-use product
(Chiptox) for MCPA sodium salt demonstrate that it is 'slightly toxic' to 'moderately toxic' to
estuarine/marine invertebrates under acute exposure. Toxicity studies conducted using the technical and an
end-use product (Rhomene) for MCPA DMAS demonstrate it is 'moderately toxic' to 'practically non-
toxic' to estuarine/marine invertebrates under acute exposure. Toxicity tests show technical MCPA 2-
EHE is 'highly toxic' to estuarine/marine invertebrates exposed for short periods of time.

No estuarine/marine invertebrate chronic toxicity studies of MCPA acid, salts, or ester were submitted to
the Agency.

c. Toxicity to Plants

Toxicity to Terrestrial Plants
44
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In general, toxicity tests demonstrate MCPA negatively impacts seedling emergence and vegetative vigor
of terrestrial plants based on data submitted for MCPA acid, DMAS, and 2-EHE. Table 27, below,
presents a summary of the endpoints used to assess risk to terrestrial plants.

Table 27: MCPA Toxicity to Terrestrial Plants
Organism Group
Terrestrial monocots emergence
Terrestrial dicots emergence
Terrestrial monocots vegetative vigor
Terrestrial dicots vegetative vigor
MCPA Form
MCPA 2-EHE
MCPA DMAS
MCPA 2-EHE
MCPA DMAS
Endpoint
0.010 EC25, Ibs ae/acre
0.005 EC25, Ibs ae/acre
0.038 EC25, Ibs ae/acre
0.004 EC25, Ibs ae/acre
MCPA acid adversely affects seedling emergence and vegetative vigor of both monocots and dicots. For
seedling emergence, the most sensitive monocot was onion and the most sensitive dicot was cabbage. For
vegetative vigor, the most sensitive monocot was onion and the most sensitive dicots were lettuce and
turnip.

No terrestrial plant studies were submitted to the Agency for MCPA sodium salt.

MCPA DMAS adversely affects seedling emergence and vegetative vigor of both monocots and dicots.
For seedling emergence, the most sensitive monocot was ryegrass. For seedling emergence, the most
sensitive dicot was cabbage. For vegetative vigor, the most sensitive moncot was onion and the most
sensitive dicot was radish.

MCPA 2-EHE adversely affects seedling emergence and vegetative vigor of both monocots and dicots.
For seedling emergence, the most sensitive monocot was oat and the most sensitive dicot was cabbage.
For vegetative vigor, the most sensitive moncot was onion and the most sensitive dicots were lettuce and
radish.

Toxicity to Aquatic Plants

For MCPA acid, the EC50 for the Lemna gibba (freshwater vascular plant) was 0.17 mg ae/L and the
NOAEC was <0.014 mg ae/L. For the three species of freshwater non-vascular plants (i.e., Selenastrum
capricornutum, Naviculapelliculosa, and Anabaena flos-aquae\ the EC50s ranged from 0.63 to 6.7
mg ae/L, and the NOAECs ranged from 0.0089 to 0.47 mg ae/L. For the estuarine/marine non-vascular
plant (Skeletonema costatum\ the EC50 was 0.30 mg ae/L and the NOAEC was 0.015 mg ae/L.

No aquatic plant studies were submitted to the Agency for MCPA sodium salt.

For MCPA DMAS, the EC50 for the Lemna gibba (freshwater vascular plant) was 0.21 mg ae/L and the
NOAEC was <0.4 mg ae/L. For the three species of freshwater non-vascular plants (i.e., Selenastrum
capricornutum, Navicula pelliculosa, and Anabaena flos-aquae\ the EC50s ranged from 0.16 to 99 mg
45
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ae/L, and the NOAECs ranged from 0.005 to 10.4 mg ae/L. For the estuarine/marine non-vascular plant
(Skeletonema costatum\ the EC50 ranged from 1.2 to mg ae/L and the NOAEC ranged from 0.028 to
2.4 mg ae/L.

Toxicity studies were also conducted using the technical for MCPA 2-EHE. For the Lemna gibba
(freshwater vascular plant), the EC50 was 0.02 mg ae/L and the NOAEC was 0.004 mg ae/L. For the
three species of freshwater non-vascular plants (i.e., Selenastrum capricornutum, Naviculapelliculosa,
and Anabaena flos-aquae\ Tier n toxicity tests were conducted. The EC50's ranged from 0.17 mg ae/L
to 1.3 mg ae/L, and the definitive NOAECs ranged from 0.0035 to 0.021 mg ae/L. For the
estuarine/marine non-vascular plant (Skeletonema costatum\ the EC50 was 0.056 mg ae/L, and the
NOAEC was <0.0019 mg ae/L.
46
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4. Exposure and Risk Calculations

a. Levels of Concern

Risk characterization integrates the results of the exposure and ecotoxicity data to evaluate the likelihood
of adverse ecological effects by using risk quotients (RQs). RQs are calculated by dividing exposure
estimates by acute and chronic ecotoxicity values:

RQ = EXPOSURE/TOXICITY

RQs are then compared with OPP's levels of concern (LOCs). These LOCs are used by OPP to analyze
potential risk to nontarget 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 nontarget organisms. Risk
presumptions, along with the corresponding LOCs are summarized in Table 28. The ecotoxicity test
values (measurement endpoints) used in the acute and chronic risk quotients are derived from required
studies.

Table 28: Risk Presumptions for Terrestrial and Aquatic Animals and Plants
Risk Presumption
Acute Risk
There is potential for acute risk; regulatory action may be warranted in addition to
restricted use classification
Acute Restricted Use
There is potential for acute risk, but may be mitigated through restricted use
classification
Acute Endangered Species
Endangered species may be adversely affected; regulatory action may be
warranted
Chronic Risk
There is potential for chronic risk; regulatory action may be warranted
LOG
terrestrial
animals

0.5

0.2
0.1
1
LOC LOC
aquatic _,
. , Plants
animals

0.5

0.1
0.05
1

N/A
1
N/A
b. Exposure and Risk to Nontarget Terrestrial Animals

(1) Exposure to Birds and Mammals

Pesticide concentrations on terrestrial food items from spray applications are based on data by Hoerger
and Kenaga (1972) as modified by Fletcher et al. (1994) that determined residue levels on various
terrestrial items immediately following pesticide application in the field. Specifically, for every 1 Ib ai/acre of
application, the resulting maximum concentration on short grass is 240 ppm, on tall grass is 110 ppm, on
broad-leaved plants/small insects is 135 ppm, and on seeds/large insects is 15 ppm. For every 1 Ib ai/acre
47
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of application, the resulting mean concentration on short grass is 85 ppm, on tall grass is 36 ppm, on
broad-leaved plants/small insects is 45 ppm, and on seeds/large insects is 7 ppm. Pesticide concentrations
on food items following multiple applications are predicted using a first-order residue decline method,
OPP's "FATES" model, which allows determination of residue dissipation overtime incorporating
degradation half-life.

Predicted maximum and mean EECs resulting from multiple applications are calculated from the FATES
program. FATES estimates the highest one-day residue, based on the maximum or mean initial EEC from
the first application, the total number of applications, interval between applications, and a first-order
degradation rate, consistent with OPP policy. For MCPA, the registrant has submitted several studies
under Guideline 860.1500 which allow the estimation of foliar residue half-lives. Half-lives for each study
were estimated using non-linear regression with an exponential decay model and ranged from 1.6 to 5.8
days. The mean residue half-life was 3.0 days and the upper 90th confidence limit for the mean was 3.4
days. EPA will use the upper 90th confidence limit for the mean to calculate residue for multiple
applications.

Birds and mammals may be exposed to granular pesticides when foraging for food or grit. They also may
be exposed by other routes, such as by walking on exposed granules or drinking water contaminated by
granules. The exposure to granules is estimated as milligrams ae per square foot of treated ground using the
maximum application rate of 0.124 Ibs ae/5000 sq. ft (EPA Label # 228-203).

(2) Avian Risk

In the avian acute dietary studies that were submitted to the Agency, no mortalities were observed.
Therefore, RQs based on these dietary studies were not calculated to evaluate the potential acute risks
(i.e., Acute Endangered, Acute Restricted Use, and Acute Risk) to birds because of a high, unqualified
LC50 (> 4608 mg ae/kg-diet). Negative effects were observed in the submitted studies (reduced feed
consumption and body weight gain), and the NOAECs were established at 820 mg ae/kg-diet for the
bobwhite quail and 461 mg ae/kg-diet for the mallard duck. Acute risk based on mortality in the dietary
studies is low.

Since mortality was observed in the acute gavage studies, acute avian RQs were calculated using the acute
gavage studies. The most sensitive LD50 was 221 mg ae/kg-bw (MCPA DMAS for bobwhite quail,
MRID 40019202). The RQ calculations for the maximum labeled application rate (4.0 Ibs ae/acre), the
maximum labeled application rate for wheat (1.5 Ibs ae/acre), and the application rate of 2.0 Ibs
ae/acre/app with two applications 30 days apart are summarized in Table 29.

Assuming maximum application rates (4.0 Ibs ae/acre either as a single or split application) and maximum
residue levels for all weight classes and food stuffs, RQs range from 0.01 to 6.6. Assuming maximum
application rates and predicted mean residues, RQs range from 0.01 to 2.33.
48
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Assuming maximum application rates on wheat (1.5 Ibs ae/acre) and maximum residue levels for all weight
classes and food stuffs, the RQs range from 0.01 to 2.46. Assuming maximum application rates on wheat
and predicted mean residues, the RQs range from <0.01 to 0.88.

Assuming maximum residue levels at the maximum application rate, no Chronic Risk LOCs were
exceeded for short grass, tall grass, and broadleaf forage/small insects. RQs range from 0.1 to 1.00. Since
there were no exceedances at the highest application rate, chronic RQs for lower application rates were
not calculated for this assessment.

Table 29: Avian Acute Risk Quotient Summary (Predicted Mean Residues)
Food Type
short grass
tall grass
broadleaf forage,
small insects
seeds, pods
Weight
Class (g)
20
100
1000
20
100
1000
20
100
1000
20
100
1000
4 Ibs ae/acre
2.33
1.04
0.33
0.99
0.44
0.14
0.89
0.40
0.13
0.04
0.02
0.01
2 Ibs ae/acre/app,
2 apps 30 days apart
1.16
0.52
0.17
0.49
0.22
0.07
0.45
0.20
0.06
0.02
0.01
<0.01
1.5 Ibs ae/acre
0.88
0.39
0.12
0.37
0.17
0.05
0.34
0.1
0.05
0.02
0.01
<0.01
RQ > 0.10 indicates an exceedance of Endangered Species Level of Concern (LOG)
RQ > 0.20 indicates an exceedance of Acute Restricted Use LOG.
RQ > 0.50 indicates an exceedance of Acute Risk LOG.

Assuming maximum granular application rates (1.09 Ibs ae/acre), there were no LOG exceedances as all
calculated RQs were < 0.01. EPA does not currently assess chronic risks to birds from granular
applications.

(3) Risk to Mammals

To evaluate the acute risk to mammals, RQs were calculated using the minimum LD50 obtained from the
acute oral studies (1383 mg ae/kg-bwt, MCPA acid, Ace. 21972) at the maximum labeled rate (4 Ibs
ae/acre) the maximum labeled application rate for wheat (1.5 Ibs ae/acre), and the application rate of 2.0
Ibs ae/acre with 2 applications 30 days apart. To evaluate the chronic risk to mammals, RQs were
calculated using the NOAEC obtained from the 2-generation rat study with MCPA acid (NOAEC=150
mg ae/kg-diet, MRID 400417-01). The RQ values calculated at predicted mean residues are summarized
in Tables 30 and 31.
49
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Assuming maximum residue levels at the maximum single application rate (4.0 Ibs ae/acre) for all weight
classes and food stuffs, acute RQs ranged from < 0.01 to 0.63. Assuming predicted mean residue levels
at the maximum single application rate, the acute RQs ranged from < 0.01 to 0.22. Assuming maximum
residue levels at the application scenario of 2.0 Ibs ae/acre/app for two applications 30 days apart for all
weight classes and food stuffs, acute RQs ranged from 0.32 to < 0.01. Assuming mean residue levels, the
RQs range from < 0.01 to 0.11. Assuming maximum residue levels at the maximum single application rate
for wheat (1.5 Ibs ae/acre) for all weight classes and food stuffs, acute RQs ranged from < 0.01 to 0.24.
Assuming mean residues, RQs ranged from < 0.01 to 0.08.

Assuming the maximum labeled application rate (4.0 Ibs ae/acre) and maximum residue levels for all weight
classes and food stuffs, chronic RQs ranged from 0.40 to 6.40. Assuming mean predicted residues, the
chronic RQs ranged from 0.19 to 2.27. Assuming maximum residue levels at the application scenario of
2.0 Ibs ae/acre/app for two applications 30 days apart for all weight classes and food stuffs, the chronic
RQs range from 0.20 to 3.21. Assuming mean residues, RQs range from 0.09 to 1.13. Assuming the
maximum labeled application rate for wheat (1.5 Ibs ae/acre) for maximum residue levels for all weight
classes and food stuffs, the chronic RQs range from 0.15 to 2.40. Assuming mean residues, chronic RQs
range from 0.07 to 0.85.
Table 30: Mammalian Acute Risk Quotient Summary (Predicted Mean Residues)
Food type
short grass
tall grass
broadleaf forage,
small insects
seeds, pods
Weight class
(g)
15
35
1000
15
35
1000
15
35
1000
15
35
1000
4 Ibs ae/acre
0.22
0.15
0.04
0.09
0.07
0.02
0.09
0.06
0.01
<0.01
0.01
<0.01
2 Ibs ae/acre/app,
2 apps 30 days apart
0.11
0.08
0.02
0.05
0.03
0.01
0.04
0.03
0.01
0.01
0.01
O.01
1.5 Ibs ae/acre
0.08
0.06
0.01
0.04
0.02
0.01
0.03
0.02
0.01
0.01
0.01
O.01
RQ > 0.10 indicates an exceedance of Endangered Species Level of Concern (LOG)
RQ > 0.20 indicates an exceedance of Acute Restricted Use LOG
RQ > 0.50 indicates an exceedance of Acute Risk LOG
Table 31: Mammalian Chronic Risk Quotient Summary (Predicted Mean Residues)
Food type
short grass
tall grass
4 Ibs ae/acre
2.27
0.96
2 Ibs ae/acre/app,
2 apps 30 days apart
1.13+
0.48
1.5 Ibs ae/acre
0.85
0.36
50
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Food type
broadleaf forage, small insects
fruit, large insects, seeds, pods
4 Ibs ae/acre
1.20+
0.19
2 Ibs ae/acre/app,
2 apps 30 days apart
0.60
0.09
1.5 Ibs ae/acre
0.45
0.07
RQ > 1.0 indicates an exceedance of Chronic LOG

Assuming maximum granular application rates (1.09 Ibs ae/acre) there were no LOG exceedances as all
calculated RQs were < 0.01. OPP does not currently assess chronic risks to mammals from granular
applications.

(4) Risk to Insects

OPP currently does not quantify risks to terrestrial non-target insects; therefore, risk quotients are not
calculated for these organisms. Since MCPA is practically non-toxic to honey bees (LD50 of >17
ug/bee), the potential for MCPA to have adverse effects on pollinators and other beneficial insects is low.

5. Exposure and Risk to Nontarget Aquatic Animals

Risks to aquatic fish and invertebrates were assessed using modeling with PRZM/EXAMS to estimate
aquatic exposure due to runoff and spray drift. Overall, drift was a minor component when compared to
runoff. The assessment of runoff and spray drift of MCPA acid and amine salts, showed no exceedances
of any LOG for aquatic fish and invertebrates.

For MCPA ester assessment of runoff with spray drift, there were mixed exceedances of endangered
species LOG with RQs ranging from 0.05 to 0.07 for freshwater invertebrates for the North Dakota
wheat, Oregon wheat, Pennsylvania pasture, and Minnesota pasture scenarios.

a. Exposure and Risk to Nontarget Plants

(1) Risk to Terrestrial Plants

For terrestrial plants, an analysis of the results indicates exceedance of the Acute Risk LOG and the Acute
Endangered Species LOG for all modeled scenarios at the highest application rate (Table 32, below). At
the highest labeled rate for wheat (1.5 Ibs ae/acre), all Acute Endangered Species LOCs were exceeded,
and all Acute Non-endangered Species LOCs were exceeded except for drift to non-target monocots
from ground application. At the highest labeled rate for granular applications (1.09 Ibs ae/acre), all Acute
Endangered Species LOCs and all Acute Non-endangered Species LOCs were exceeded.

Currently, OPP does not perform chronic risk assessments for terrestrial plants.
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Table 32: Summarized Terrestrial Plant Risk Quotients
Scenario (Appl.
rate)
Ground spray
application (4.0 Ibs
ae/acre)
Aerial or chemigation
spray application (4.0
Ibs ae/acre)
Ground spray
application (1.5 Ibs
ae/acre)
Aerial or chemigation
spray application (1.5
Ibs ae/acre)
Granular ground
application (1.0 9 Ibs
ae/acre) a
Plant
Type
Monoco
t
Dicot
Monoco
t
Dicot
Monoco
t
Dicot
Monoco
t
Dicot
Monoco
t
Dicot
Acute Non-endangered RQs
adjacent to
treated
sites
24.00
48.00
32.00
64.00
9.00
18.00
12.00
24.00
5.45
10.90
semi-aquatic
areas
204.00
408.00
140.00
280.00
76.50
153.00
52.50
105.00
54.50
109.00
drift
1.05
10.00
5.26
50.00
0.39
3.75
1.97
18.75
NA
NA
Acute Endangered RQs
adjacent to
treated
sites
40.00
40.00
53.33
53.33
15.00
15.00
20.00
20.00
9.08
9.08
semi-aquatic
areas
340.00
340.00
233.33
233.33
127.50
127.50
87.50
87.50
90.83
90.83
drift
3.08
13.33
15.38
66.67
1.15
5.00
5.77
25.00
NA
NA
a RQs for ground granular applications in this table were calculated for the maximum labeled application rate of 1.09 Ibs
ae/acre. RQs for other application rates are a linear function of the listed RQs. Drift RQs are not applicable for granular
applications.

(2) Risk to Aquatic Plants

Similar to aquatic organisms, risks to aquatic plants were assessed using modeling with PRZM/EXAMS to
estimate aquatic exposure due to runoff with spray drift of MCPA acid, amine salts and ester.

For the first scenario, assessment of runoff with spray drift of MCPA acid and amine salts, there were no
exceedances of any LOG for the non-endangered plants. However, there were exceedances of the acute
endangered freshwater vascular plant for several scenarios, as presented in Table 33, below.

Table 33: Endangered Species Aquatic Plants exposed to MCPA acid and amine salts via runoff
and drift
Scenario
CA pasture
CA pasture
JA pasture
JA pasture
Rate
One application at 4.0 Ibs/acre
Two applications at 2.0 Ibs/acre
One application at 4.0 Ibs/acre
Two applications at 2.0 Ibs/acre
RQ
1.42
1.12
1.77
1.62
52
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Scenario
VIN pasture
VIN pasture
•CS sorghum
lice
Rate
One application at 4.0 Ibs/acre
Two applications at 2.0 Ibs/acre
One application at 0.75 Ibs/acre
One application at 1.25 Ibs/acre
RQ
1.30
1.72
1.01
94
For the second scenario, assessment of runoff with spray drift of the MCPA ester, there were no
exceedances of any LOG for the non-endangered plants. However, there were exceedances of the acute
endangered freshwater vascular plant for several scenarios, as presented in Table 34, below.

Table 34: Endangered Species Aquatic Plants exposed to MCPA ester via runoff and drift
Scenario
ND wheat
OR wheat
C A pasture
PA pasture
PA pasture
MN pasture
MN pasture
PA turf
Rate
One application at 1.5 Ibs/acre
One application at 1.5 Ibs/acre
Two applications at 2.35 Ibs/acre
One application at 2.35 Ibs/acre
Two applications at 1.315 Ibs/acre
One application at 2.35 Ibs/acre
Two applications at 1.315 Ibs/acre
One application at 1.75 Ibs/acre
RQ
3.18
2.43
1.65
2.90
1.45
2.25
1.13
1.40
6. Ecological Incidents

There are several reported incidents in the Environmental Incident Information System (EHS) database
with a terrestrial organism effect. All were crop injury incidents. There are no reported incidents involving
the use of MCPA alone, with the exception of the accidental misuse. All other reported incidents involve
co-formulated products in which the damage may have been caused by MCPA and/or the other active
ingredients in the products.

In North Dakota, Bronate Advanced, co-formulated with MCPA 2-EHE, bromoxynil octanoate, and
bromoxynil heptanoate, was reported to have damaged 880 acres of spring wheat when applied in 2002
(#1013430-023,1013430-024,1013103-029). In North Dakota, DAKOTA, co-formulated with MCPA
2-EHE and fenoxaprop-p-ethyl, was reported to have damaged 150 acres of spring wheat when applied
in 2000 (#1010472-093).

In Canada, Curtail, co-formulated with MCPA 2-EHE and clopyralid, is alleged to have caused crop
injury to 20,000 acres of peas, chick peas, and lentils planted in 2002. This was reported as a carry-over
injury as Curtail had been applied to barley, oats, and wheat that were grown in those fields in 2001
(#1013636-008).
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In Wisconsin, MCPA AMFNE 4, formulated with MCPA DMAS, was reported to have killed 28.8 acres
of alfalfa and oats when applied in excess of the labeled application rate in 2001 (#1012242-001).
54
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7. Endangered Species

The Agency has developed the Endangered Species Protection Program to identify pesticides whose use
may cause adverse impacts on endangered and threatened species, and to implement mitigation measures
that address these impacts. The Endangered Species Act requires federal agencies to ensure that their
actions are not likely to jeopardize listed species or adversely modify designated critical habitat. To
analyze the potential of registered pesticide uses to affect any particular species, EPA puts basic toxicity
and exposure data developed for reregistation eligibility decisions into context for individual listed species
and their locations by evaluating important ecological parameters, pesticide use information, the geographic
relationship between specific pesticide uses and species locations and biological requirements and
behavioral aspects of the particular species. A determination that there is a likelihood of potential impact
to a listed species may result in limitations on use of the pesticide, other measures to mitigate any potential
impact, or consultations with the Fish and Wildlife Service and/or the National Marine Fisheries Service as
necessary.

Based on EPA's screening level assessment, RQs exceed levels of concern for MCPA use sites for
endangered species of mammals, birds, aquatic plants, and terrestrial plants. These findings are based
solely on EPA's screening level assessment and do not constitute "may affect" findings under the
Endangered Species Act. The Agency is requiring application rate reductions and additional mitigation to
minimize these LOG exceedances, and is requiring additional data to further characterize and refine its
ecological and endangered species risk assessments.

8. Risk Characterization

a. Terrestrial Animal Risk Characterization

Using the acute dietary bird toxicity studies, risks for acute lethal concerns to birds are low, as no mortality
was observed at the highest dose. However, based on the acute toxicity studies submitted for birds, there
is a large differential between the acute toxicity when MCPA is administered as a single gavage or when
mixed in the feed. This disparity in mortality between the two studies suggests that the dietary matrix may
have a lowering effect of the toxicity of MCPA. Although the concerns for lethality of MCPA to non-
endangered birds is minimal, it is likely that the current maximum label rates could have adverse non-lethal
effects on birds, especially those consuming short grasses. Risks to endangered bird species including
sublethal effects and lethal effects still exist due to the uncertainty in variability among species sensitivities.
These risks would be greatest in short grass consumers, primarily smaller birds. Risk of adverse chronic
effects to birds is not expected.

Although there were exceedances of the acute LOCs for mammals using predicted maximum residue levels
and predicted mean residue levels at the maximum application rates, the risk assessment and calculated
RQs assume 100% of the diet is relegated to single food types foraged only from treated fields. The
assumption of 100% diet from a single food type may be somewhat more realistic for acute exposures, but
55
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diets are likely to be more variable over longer periods of time depending on size and forage range of the
animals.
Other exposure routes are possible for animals residing in or moving through treated areas. These routes
include ingestion of contaminated drinking water, ingestion of contaminated soils, preening/grooming, and
dermal contact. Preening exposures, involving the oral ingestion of material from the feathers remains an
unquantified, but potentially important, exposure route. If toxicity is expected through any of these other
routes of exposure, then the risks of a toxic response to MCPA is underestimated in this risk assessment.

b. Aquatic Organism Risk Characterization

The predicted peak MCPA acid concentrations based on the PRZM/EXAMS model for the ecological
risk assessment are comparable to the highest annual maximum concentration of MCPA acid (18.58 jig
ae/L) in the surface water monitoring data from NAWQA. The predicted PRZM/EXAMS chronic MCPA
acid concentrations (21-day and 60-day average concentrations) are comparable to the maximum time-
weighted mean concentration of MCPA acid (1.49 jig ae/L) of the surface water monitoring data from
NAWQA. Although the monitoring results support the modeling estimates, it is important to note that none
of the monitoring data was targeted to MCPA usage and no degradates of MCPA are included in the data
that were evaluated.

Of the formulations for which toxicity data are available, the salts and acid form of MCPA ranged from
'practically non-toxic' to 'moderately' toxic to fish and invertebrates. MCPA 2-EHE was 'moderately
toxic' to 'highly toxic' to fish and invertebrates.

Although toxicity categories for the salts and acid form of MCPA ranged from practically non-toxic to
highly toxic, no Acute Risk LOCs were exceeded under any of the modeled scenarios.

Toxicity data for MCPA EHE ranged from 'moderately toxic' to 'highly toxic' to fish and invertebrates.
The Endangered Species LOG for estuarine invertebrates in the California and the Pennsylvania pasture
(single application) scenarios was exceeded in the scenarios modeling MCPA 2-EHE reaching the water
body through drift only in the ester form. However, at this time there are no federally listed endangered
estuarine or marine invertebrates.

However, for scenarios when MCPA 2-EHE is applied and it is assumed that the substance reaches the
water in the 2-EHE form through both runoff and drift, there were several exceedances of the Endangered
Species LOG for freshwater and estuarine invertebrates. Since there are no federally listed endangered
estuarine/marine invertebrates, The Agency does not have concerns for these Endangered Species LOG
exceedances at the present time. However, if MCPA 2-EHE does reach waterbodies through both runoff
and drift, several Endangered Species screening level LOG exceedances could occur for freshwater
invertebrates.

Based on the available information for MCPA, chronic risks to freshwater fish and invertebrates are low.
OPP inferred that chronic risks to estuarine/marine fish and invertebrates would also be low under the

56
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assumption that the acute-to-chronic ratio of toxicity endpoints would hold constant across freshwater and
estuarine/marine organisms.

There are several uncertainties inherent in the aquatic organism risk assessment. Some of these
uncertainties could lead to underestimates of risk, while others could lead to overestimates of risk. These
and other uncertainties are discussed fully in the Revised EFED MCPA RED Document (dated April 14,
2004). One notable uncertainty is that this assessment accounts only for exposure of aquatic organisms to
MCPA, but not to its degradates. The potential toxicity of degradates of MCPA is unknown.

c. Terrestrial and Aquatic Plant Risk Characterization

Risks to Terrestrial Plants

The risk quotient calculations suggest concern for non-target terrestrial plants across all use sites at the
highest application rate (4.0 Ibs ae/acre); the Acute Endangered Terrestrial Plant RQs and the Acute Non-
Endangered Terrestrial Plant RQs exceeded the LOG for all the modeled scenarios. At the highest labeled
rate for wheat (1.5 Ibs ae/acre), the Acute Endangered LOCs and Acute Non-endangered LOCs were
exceeded for all except for drift to non-target non-endangered monocots from ground application.

For MCPA, a total of 60 terrestrial plant studies were submitted using various formulations and species.
Typically, The Agency evaluates risk to non-target terrestrial plants using the EC25s for the most sensitive
species tested from the seedling emergence studies and from the vegetative vigor studies. In order to test
the conservativeness of this approach, The Agency evaluated the full range of EC25 results. The 52
definitive EC25s obtained in all the terrestrial plant studies ranged from 0.004 Ib ae/acre to 2.0 Ibs ae/acre.

If the 75th percentile of the definitive EC25s (0.096 Ibs ae/acre) is used as the toxicity endpoint, to calculate
non-endangered non-granular RQs, all RQs (range from 2.50 to 21.25) exceeded an LOG of 1.0 for
adjacent terrestrial and semi-aquatic non-target plants at an application rate of 4.0 Ibs ae/acre. For drift
from ground spray, the RQ for non-target plants was 0.42 and for drift from aerial application, the RQ for
non-target plants was 2.08. This indicates that although there is a range of plant sensitivities to MCPA, a
majority of the tested species have a high sensitivity to MCPA; therefore, this assessment for terrestrial
plants is not overly conservative.

MCPA uptake is primarily through the foliage and it is translocated throughout the plant in the xylem and
phloem. Uptake also occurs through the roots. Even if only a small surface area of the plant is exposed to
MCPA, or a seedling is exposed to MCPA as it breaks through the soil surface, there is a possibility that
the plant may be severely damaged or die as a result. The resulting damage, even if only minor, may be
sufficient to prevent the plant from competing successfully with other plants for resources and water.

Spray drift is also an important factor in characterizing the risk of MCPA to non-target plants. There is as
much as a 5-fold increase in the RQs when aerial application is used as opposed to ground application.
57
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Concerns have also been raised regarding the higher volatility of the phenoxy esters, relative to the
phenoxy amine salts, as this may increase off-target damage to plants through volatilization and subsequent
drift. Only four of the EC2sS and 13 of the NOAECs from the 60 available plant (seedling and vegetative
vigor) studies for all formulations of MCPA were less than 0.009 Ibs ae/acre, indicating volatilization alone
is not a major factor in non-target plant exposure to MCPA 2-EHE.

The risk assessment for terrestrial plants was based on RQs calculated from toxicity studies using the
technical grade of MCPA acid, salt, and esters instead of TEPs (typical end-use product). Often the TEPs
include surfactants or adjuvants to increase the herbicide's adsorption into the plant, thereby increasing its
efficacy. If the toxicity tests were conducted using a TEP of MCPA at the same rates as the technical
grade, the toxicity endpoints are likely to be much lower.

Risks to Aquatic Plants

There were no acute risk exceedances for aquatic plants. However, several exceedances of the
Endangered Species LOG (freshwater vascular plants only) occurred under the different modeling
scenarios. As with the invertebrates, these RQs were calculated using the maximum labeled application
rates. However, for many crops, the average application rate is much lower than the maximum labeled
rate. For the 2-EHE drift/runoff modeling, the RQs for freshwater vascular endangered plants are below
the Acute Endangered LOCs at an application rates of 0.47 Ibs ae/acre/yr for wheat, 0.81 Ibs ae/acre/yr
for pasture, and 1.25 Ibs ae/acre/yr for turf. The average application rates for wheat and pasture are 0.37
and 0.39 Ibs ae/acre/yr. For the 2-EHE drift only modeling, when the pasture and wheat application rates
were modeled at a single application of 1.4 Ibs ae/acre/yr the RQs for freshwater vascular aquatic plants
were below the Endangered Species LOG.

All the toxicity endpoints on which the RQs were based were estimated from studies in which the technical
form of MCPA was used. Often in many end-use products, surfactants and adjuvants are added to
increase the effect of the active ingredient. If end-use products containing MCPA also contain these
performance-enhancing inert ingredients and these inerts also reach the non-target aquatic plant species,
this quantitative risk assessment may underestimate the risks.
IV. Risk Management, Reregistration and Tolerance Reassessment

A. Determination of Reregistration Eligibility

Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission of relevant data
concerning an active ingredient, whether or not products containing the active ingredient are eligible for
reregistration. The Agency has previously identified and required the submission of the generic (i.e., active
ingredient-specific) data required to support reregistration of products containing the active ingredient
MCPA.
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The Agency has completed its assessment of the dietary, occupational, residential, and ecological risk
associated with the use of pesticide products containing the active ingredient MCPA. Based on a review
of these data and on public comments on the Agency's assessments for the active ingredient MCPA, EPA
has sufficient information on the human health and ecological effects of MCPA to make decisions as part of
the tolerance reassessment process under FFDCA and reregistration process under FIFRA, as amended
by FQPA. The Agency has determined that MCPA products are eligible for reregistration provided that:
(i) current data gaps and confirmatory data needs are addressed; (ii) the risk reduction measures outlined
in this document are adopted; and (iii) label amendments are made to reflect these measures. Label
changes are described in Section V. Appendix A summarizes the uses of MCPA that are eligible for
reregistration. Appendix B identifies the generic data requirements that the Agency reviewed as part of its
determination of reregistration eligibility of MCPA, and lists the submitted studies that the Agency found
acceptable. Data gaps are identified as generic data requirements that have not been satisfied with
acceptable data.

Based on its evaluation of MCPA, the Agency has determined that MCPA products, unless labeled and
used as specified in this document, would present risks inconsistent with FIFRA. Accordingly, should a
registrant fail to implement any of the risk mitigation measures identified in this document, the Agency may
take regulatory action to address the risk concerns from use of MCPA. If all changes outlined in this
document are incorporated into the product labels, then all current risks for MCPA will be adequately
mitigated for the purposes of this determination.

B. Public Comments and Responses

When making its reregistration decision, the Agency took into account all comments received after the
opening of the public docket. Three such comments were received, from the California Regional Water
Quality Control Board, the National Barley Growers Association, and a private citizen. These comments
are available, in their entirety, from the docket (Docket # OPP-2004-0156).

The California Regional Water Quality Control Board's comments recommended that EPA conduct a
cumulative ecological risk assessment for phenoxy herbicides. At this time, however, OPP does not have
a process for quantitatively assessing the cumulative ecological effects of pesticides; the best available
science lacks the supporting data toxicity and exposure tools to conduct cumulative assessments for
pesticides in the ambient environment.

The National Barley Growers Association's comments were in support of the reregistration of MCPA,
specifically noting the importance of the pesticide's use on barley.

EPA did not receive formal comments from the registrants during the public comment period. However,
EPA's response to the comments received from the MCPA Task Force Three during the 30-day
registrant error-only correction period are available in the public docket (Docket # OPP-2004-0156).

C. Regulatory Position

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1. FQPA Assessment

a. "Risk Cup" Determination

As part of the FQPA tolerance reassessment process, EPA assessed the risks associated with MCPA.
EPA has determined that risk from dietary (food sources only) exposure to MCPA is within its own "risk
cup." An aggregate assessment was conducted for exposures through food, drinking water, and residential
uses. The Agency has determined that the human health risks from these combined exposures are within
acceptable levels. In other words, EPA has concluded that the tolerances for MCPA meet the FQPA
safety standards. In reaching this determination, EPA has considered the available information on the
special sensitivity of infants and children, as well as the chronic and acute food exposures. In addition, this
determination is based on a revised database uncertainty factor analysis (described below in Section
IV.C.l.c), in addition to a new dermal absorption study (see Section IV.D) and lower application rates.

b. Determination of Safety for U.S. Population

EPA has determined that the established tolerances for MCPA, with amendments and changes as
specified in this document, meet the safety standards under the FQPA amendments to section
408(b)(2)(D) of the FFDCA, that there is a reasonable certainty of no harm for the general population. In
reaching this determination, EPA has considered all available information on the toxicity, use practices and
scenarios, and the environmental behavior of MCPA. As discussed in chapter 3, the total acute dietary
(food alone) risk from MCPA is below the level of concern as is the chronic risk from food alone. Risks
from drinking water exposures are also not of concern. Risks from residential and occupational exposures
are also not of concern based on rate reduction and other mitigation measures, as well as a reassessment
of the appropriate database uncertainty factor, as described below, and a new dermal absorption study.
(See also additional discussion in Section IV.D.l of this document [Regulatory Rationale, Human Health
Risk Mitigation].)

c. Determination of Safety for Infants and Children

FQPA directs EPA, in setting pesticide tolerances, to use an additional tenfold margin of safety to protect
infants and children, taking into account the potential for pre- and postnatal toxicity and the completeness
of the toxicology and exposure databases. The statute authorizes EPA to replace this tenfold FQPA safety

60
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factor with a different FQPA factor only if reliable data demonstrate that the resulting level of exposure
would be safe for infants and children.

FQPA Special Safety Factor

In determining whether infants and children are particularly susceptible to toxic effects from MCPA
residues, EPA considered the completeness of the database for developmental and reproductive effects,
the nature of the effects observed, and other information. The FQPA Safety Factor for protection of
children and infants was removed for two reasons: (1) there are acceptable developmental and
reproduction studies that have been submitted and reviewed; and (2) there is no evidence of increased
pre- or post-natal susceptibility except in a rat developmental toxicity study with MCPA 2-EFffi.

OPP performed a Degree of Concern Analysis because there was evidence of increased susceptibility of
the young following exposure to MCPA 2-EHE in a rat developmental study. After consideration of the
study design, the Agency concluded that qualitative susceptibility was demonstrated because increased
incidence of decreased fetal body weight, altered growth, and increased litter resorption were found at
doses where maternal toxicity (decreased body weight gain) was also found. However, OPP
characterized the degree of concern for the effects in this study as low, based on consideration of the
doses and endpoints selected for risk assessment and the overall toxicity profile for MCPA. OPP further
noted that the developmental study was well-conducted, that clear NOAELs/LOAELs were established,
that the dose response for the observed effects is well characterized, and that the developmental NOAEL
of 40 mg/kg/day identified in the study was used to establish the acute Reference Dose (aRfD) for the
Females 13-50 population subgroup. Based on all of these considerations, the Agency concluded that the
default Special FQPA Safety Factor is not required.

Database Uncertainty Factor

The Agency has concluded that a developmental neurotoxicity study on MCPA 2-EFffi is necessary to
further characterize the potential for pre-natal neurotoxicity due to the presence of clinical signs indicative
of neurotoxicity in acute and subchronic studies. The MCPA toxicology database does not include a DNT
study, and therefore a Database Uncertainty Factor is necessary to be protective of children. This
Uncertainty Factor is applied only to exposure scenarios that are expected for children or pregnant
women, and thus is not applied to occupational exposure scenarios.

Subsequent to public release of the revised risk assessment for MCPA, the Agency reevaluated the
appropriate size of the Database Uncertainty Factor. The NOAEL from an acceptable reproduction study
was compared to a dose level that the Agency assumes would be the NOAEL from a DNT study, when
completed. The Agency has assumed that if a DNT study were conducted, the NOAEL from that study
would be similar to the lowest dose tested in the reproduction study. The assumption is based on an
analysis of data from DNT studies previously submitted to the Agency which suggests that NOAELs lower
than the lowest dose tested in the reproduction study are unlikely to occur.
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In the case of MCPA, the lowest dose tested in the rat reproduction study (MRID 40041701) is 2.5
mg/kg/day. The Agency therefore assumes that a DNT study on MCPA would yield a NOAEL of
approximately 2.5 mg/kg/day. EPA's determination of the size of the Uncertainty Factor is based on a
comparison between the assumed DNT NOAEL of 2.5 mg/kg/day and the endpoints used in the risk
assessments. The approximate size of the Database Uncertainty Factor is derived by dividing the point of
departure used for each exposure pathway by the assumed DNT NOAEL of 2.5 mg/kg/day.

Applying this dose analysis to MCPA, a 10X Database Uncertainty Factor is required for acute dietary
scenarios (including acute incidental oral exposure), based on a comparison between the developmental
NOAEL of 40 mg/kg/day and the assumed DNT study NOAEL of 2.5 mg/kg/day. A 10X Database
Uncertainty Factor is also required for acute residential dermal scenarios, based on a comparison between
the oral equivalent NOAEL of 40-50 mg/kg/day and the assumed DNT study NOAEL of 2.5 mg/kg/day.
A 3X Database Uncertainty Factor is required for residential short-term and intermediate dermal exposure
scenarios, based on a comparison between an oral equivalent NOAEL of 7 mg/kg/day and the assumed
DNT study NOAEL of 2.5 mg/kg/day. The Agency has determined that a IX Database Uncertainty
Factor is appropriate for chronic dietary exposure, incidental oral exposure, long term dermal exposure,
short- and intermediate-term occupational dermal exposures, and all durations of inhalation exposure
because the endpoints used for these assessments, a NOAEL of 4.4 mg/kg/day, is of the same order of
magnitude of the assumed DNT study NOAEL (2.5 mg/kg/day) and in a similar dose range. Table 35,
below, summarizes the revised Database Uncertainty Factors for MCPA.

The Agency believes that with the application of the Database Uncertainty Factors discussed in this
section, the regulatory endpoints are protective of children despite the need for a developmental
neurotoxicity study. EPA is, however, still requiring the registrants to conduct a DNT study on the MCPA
2-EHE as a condition of reregistration. Results from this study will allow EPA to further characterize the
potential for pre-natal neurotoxicity from the MCPA 2-EHE formulation.

Table 35: Summary of MCPA Revised Database Uncertainty Factors
Exposure Scenario
Acute Dietary
Chronic Dietary
Acute Incidental Oral
Short-term Incidental Oral
Acute Dermal
Short- and Intermediate-term Dermal
Inhalation (short-, intermediate-, & long-term)
Previous Database
,-•• / // ~ ,-• > x
- tJite|rtainty Factor
10X
10X
10X
10X
Residential = 10X
Occupational = IX
Residential = 10X
Occupational = IX
Residential = 10X
Occupational = IX
New Database
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d. Endocrine Disrupter Effects

EPA is required under the FFDCA, as amended by FQPA, to develop a screening program to determine
whether certain substances (including all pesticide active and other ingredients) "may have an effect in
humans that is similar to an effect produced by a naturally occurring estrogen, or other endocrine effects as
the Administrator may designate." Following recommendations of its Endocrine Disrupter Screening and
Testing Advisory Committee (EDSTAC), EPA determined that there was scientific basis for including, as
part of the program, the androgen and thyroid hormone systems, in addition to the estrogen hormone
system. EPA also adopted EDSTAC's recommendation that EPA include evaluations of potential effects
in wildlife. For pesticides, EPA will use FIFRA and, to the extent that effects in wildlife may help
determine whether a substance may have an effect in humans, FFDCA authority to require the wildlife
evaluations. As the science develops and resources allow, screening of additional hormone systems may
be added to the Endocrine Disrupter Screening Program (EDSP).

When the appropriate screening and/or testing protocols being considered under the EDSP have been
developed, MCPA may be subject to additional screening and/or testing to better characterize effects
related to endocrine disruption.

e. Cumulative Risks

The Food Quality Protection Act (FQPA) 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." 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 as to MCPA and any other
substances, and MCPA does not appear to produce a toxic metabolite produced by other substances.
For the purposes of this tolerance action, therefore, EPA has not assumed that MCPA has 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 EPA's Office of Pesticide 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/.

f. Tolerance Summary

Tolerances have been established under 40 CFR §180.339(a) for residues of MCPA (2-methyl-4-
chlorophenoxyacetic acid) per se in/on various plant commodities, and tolerances are established under 40
CFR §180.339(b) for the combined residues of MCPA and its metabolite 2-methyl-4-chlorophenol in
livestock commodities.
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Plant Commodities

OPP has determined that the residues to be regulated for risk assessment purposes in plant commodities
are free and conjugated MCPA and its metabolite 2-HMCPA [(4-chloro-2-hydroxymethylphenoxy)acetic
acid]. In the June 3, 2004, Residue Chemistry Chapter, EPA concluded that the metabolite CCPA [(4-
chloro-2-carboxyphenoxy)acetic acid] should also be regulated for risk assessment purposes. However,
based on additional information submitted by the registrant during risk mitigation discussions in August
2004, OPP concluded that CCPA is not a metabolite of concern. This conclusion is reflected in the
Residue Chemistry Chapter for MCPA, dated September 14, 2004. The residues to be regulated for
tolerance reassessment purposes are MCPA, per se.

The MCPA tolerance expression for plant commodities at 40 CFR §180.339(a) includes several forms of
MCPA that either no longer correspond to registered manufacturing use or end use products or which are
not supported for reregistration. As a result, the following salts and esters will be deleted from the
tolerance expression: ethanolamine salt, diethanolamine salt, triethanolamine salt, isopropanolamine salt,
diisopropanolamine salt, triisopropanolamine salt, isooctyl ester, and butoxyethyl ester. Furthermore, the
2-ethylhexyl ester (2-EHE) form will be added to the tolerance expression. The form 2-ethylhexyl ester
more accurately identifies the isooctyl ester group associated with MCPA, and all but one of the products
previously registered under the active ingredient name MCPA isooctyl ester are now registered as 2-EFIE
products.

It should be noted that the chemical name for MCPA has been presented both as "(2-methyl-4-
chlorophenoxy)acetic acid" and "(4-chloro-2-methylphenoxy)acetic acid." Although both names are
correct, the "(4-chloro-2-methylphenoxy)acetic acid" designation is preferred under current conventions
for naming chemicals.

Accordingly, the tolerance definition listed under 40 CFR § 180.339(a) should be amended to read as
follows:

Tolerances are established for residues of the herbicide 4-chloro-2-methylphenoxyacetic acid from
application of the herbicide in the acid form, in the form of its sodium or dimethylamine salts, or its
2-ethylhexyl ester in or on raw agricultural commodities as follows:

Livestock Commodities

The current tolerance expression for livestock commodities at 40 CFR § 180.339(b) includes MCPA and
its metabolite 2-methyl-4-chlorophenol. Based on limited toxicity data on 2-methyl-4-chlorophenol, a
currently regulated livestock metabolite, EPA expects this metabolite to be significantly less toxic than the
parent compound. Therefore, 2-methyl-4-chlorophenol can be excluded from the tolerance expression,
and only residues of MCPA, per se, will be regulated in livestock commodities. Accordingly, the
tolerance definition listed under 40 CFR § 180.339(b) will be amended to read as follows:

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Tolerances are established for the negligible residues (N) of the herbicide (4-chloro-2-
methylphenoxy)acetic acid in or on the following raw agricultural commodities:

MCPA Tolerances

The MCPA Task Force Three has agreed to voluntarily cancel use of MCPA on rice and grain sorghum.
Therefore, the Agency will commence proceedings to propose the revocation of the corresponding
tolerances.
A summary of the MCPA tolerances is presented in Table 36. A full description of the tolerance
reassessment can be found in the Residue Chemistry Chapter for MCPA (dated June 3, 2004, and
September 14, 2004).

Table 36: Tolerance Summary for MCPA - 40 CFR §180.339(a), (b)
Commodity
Current Tolerance, ppm
Tolerance Reassessent, ppm
[0 CFR §180.339(a) - Tolerances are established for residues of the herbicide 4-chloro-2-
methylphenoxyacetic acid from application of the herbicide in the acid form, in the form of its sodium or
[imethylamine salts, or its 2-ethylhexyl ester in or on raw agricultural commodities as follows:
Alfalfa
Alfalfa, hay
Parley, grain
Parley, straw
Canarygrass, annual, seed
Clover
Clover, hay
rlax, straw
rlaxseed
Grass, canary, annual, straw
Grass, pasture
Grass, rangeland
Grass, hay
^espedeza
Oat, forage
Oat, grain
Oat, straw
'eavines
'eavines, hay
lice, grain
0.1
0.1
0.1 (N)
2
0.1
0.1
0.1
2
0.1 (N)
0.1
300
300
20
0.1
20
0.1 (N)
2
0.1 (N)
0.1 (N)
0.1 (N)
0.1
0.1
0.1 (N)
2
0.1
0.1
0.1
2
0.1 (N)
0.1
300
300
20
0.1
20
0.1 (N)
2
0.1 (N)
0.1 (N)
Revoke
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Commodity
lice, straw
lye, grain
lye, straw
Sorghum, fodder
Sorghum, forage
Sorghum, grain
"refoils
"refoil hay
Vegetables, seed and pod
Vetches
Vetch, hay
Wheat, grain
Wheat, straw
Current Tolerance, ppm
2
0.1 (N)
2
20
20
0.1
0.1
0.1
0.1
0.1
0.1
0.1 (N)
2
Tolerance Reassessent, ppm
Revoke
0.1 (N)
2
20
20
Revoke
0.1
0.1
0.1
0.1
0.1
0.1 (N)
2
40 CFR §180.339(b) - Tolerances are established for the negligible residues (N) of the herbicide (4-
chloro-2-methylphenoxy)acetic acid in or on the following raw agricultural commodities:
Cattle, fat
Cattle, meat byproducts
Cattle, meat
Goat, fat
Goat, meat byproducts
Goat, meat
Hog, fat
log, meat byproducts
log, meat
lorse, fat
lorse, meat byproducts
lorse, meat
Milk
Sheep, fat
Sheep, meat byproducts
Sheep, meat
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
0.1 (N)
* Bolded entries indicate revised tolerance.
(1)
Codex/International Harmonization
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No Codex MRLs have been established for MCPA; therefore, issues of compatibility between Codex
MRLs and U.S. tolerances do not exist. No Canadian or Mexican MRLs have been established for
MCPA. We note that registered food uses of MCPA exist in Canada (for crops such as wheat, barley,
rye, oats, flax, peas, corn, pasture grass, alfalfa, and trefoil); these uses presumably fall under the PMRA
General MRL of 0.1 mg/kg [Regulation B.I 5.002(1) of the Canadian Food and Drugs Regulations (FDR)
establishes 0.1 ppm as the "General Maximum Residue Limit." This regulation states that a food is
adulterated if it contains residues of a pesticide at a level greater than 0.1 ppm unless a specific MRL has
been established in Table n, Division 15 of the FDR]
2.
Labels
Provided the following risk mitigation measures are incorporated in their entirety into labels for MCPA-
containing products, the Agency finds that all currently registered uses of MCPA are eligible for
reregistation except rice and grain sorghum, which are uses that the registrants have agreed to voluntarily
cancel. The regulatory rationale for each of the mitigation measures outlined below is discussed
immediately after this list of mitigation measures.

3. Mitigation for Agricultural Uses

The Agency has identified the following mitigation measures that reduce risks to agricultural workers and
wildlife to levels the Agency considers reasonable:
a.
Use Cancellations
The MCPA Task Force Three has requested the voluntary cancellation of rice and grain sorghum. The
Agency will publish a FIFRA 6(f) cancellation notice in the Federal Register and propose the revocation of
the associated tolerances. As a condition of reregistration, end-use products labeled for these uses must
be amended to remove these use sites.
b. Application Rate Reductions

The MCPA Task Force Three has agreed to the following reductions to the maximum label rates for
MCPA. As a condition of re-registration, end-use products labeled for these uses will be amended to
reflect the new application rates.

Table 37: MCPA Use Rate Reductions
Site
Wheat
Old
Maximum
Rate
1.5 Ib/A
New
Maximum
Rate
0.75 Ib/A
Typical
Rate
0.375 Ib/A
Comments
Pre-boot stage. Maximum rate may be
divided into two applications.
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Site
Parley
Oats
Rye
7lax
lesidential Turf
Sod Farms
Golf Courses
Grass Grown for
Seed
'asture/
rangeland
•vfoncropland,
lights-of-Way
(Broadcast
treatment)
•vfoncropland,
lights-of-Way
(Spot treatment)
Old
Maximum
Rate
1.5 Ib/A
1.5 Ib/A
1.5 Ib/A
0.375 Ib/A
2.0 Ib/A
2.0 Ib/A
2.0 Ib/A
2.0 Ib/A
4.0 Ib/A
4.0 Ib/A
4.0 Ib/A
New
Maximum
Rate
0.75 Ib/A
0.75 Ib/A
0.75 Ib/A
0.25 Ib/A
1.5 Ib/A
1.5 Ib/A
1.5 Ib/A
1.5 Ib/A
1.5 Ib/A
1.5 Ib/A
3.0 Ib/A
Typical
Rate
0.375 Ib/A
0.375 Ib/A
0.375 Ib/A
0.25 Ib/A
1.0 Ib/A
1.0 Ib/A
1.0 Ib/A
1.0 Ib/A
1.25 Ib/A
1.5 Ib/A
2.25 Ib/A
Comments
Pre-boot stage. Maximum rate may be
divided into two applications.
Pre-boot stage. Maximum rate may be
divided into two applications.
Pre-boot stage. Maximum rate may be
divided into two applications.
IR-4 use
Up to 2 applications per year with a
minimum retreatment interval of 21 days.
Up to 2 applications per year with a
minimum retreatment interval of 21 days.
Up to 2 applications per year with a
minimum retreatment interval of 21 days.
Up to 2 applications per year with a
minimum retreatment interval of 21 days.
Up to 2 applications per year with a
minimum retreatment interval of 21 days.
Broadcast treatment - Up to 2 applications
per year with a minimum retreatment
interval of 21 days.
Localized hard-to-kill herbaceous plants,
brush, or woody plants.
D. Regulatory Rationale

Following the release of the MCPA risk assessments, a series of meetings were held with the MCPA Task
Force Three to discuss ways to reduce residential, occupational, and ecological risks to levels below the
Agency's level of concern. In conjunction with those meetings, the task force submitted additional data
and information bearing directly on the risks of concern. In particular, the task force submitted new
information about typical application rates and how the product is used. Furthermore, the task force
submitted a new dermal absorption study. The Agency reviewed the new dermal absorption study, and
concluded that the dermal absorption factor for converting dermal exposures to oral equivalent doses
should be decreased from thirty percent to seven percent.

In July 2004, after the revised MCPA risk assessments were released for 60-day public comment, the
Agency conducted a new dose analysis for determining the need for and size of Database Uncertainty
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Factors to account for the lack of a developmental neurotoxicity (DNT) study. This most recent analysis
was based on new scientific information gained from the Agency's review of several recently-submitted
DNT studies. The change affected the MCPA residential, dietary, and drinking water health risk
assessments. Originally, a 10X Database Uncertainty Factor for the lack of a DNT study was applied for
all routes and durations of residential and dietary exposure. Based on the new analysis, the 10X was
retained for acute dietary, acute incidental oral, and acute residential dermal exposure scenarios.
However, the Database Uncertainty Factor was decreased to 3X for short- and intermediate-term dermal
exposures, and was removed (IX) for all other exposure durations and routes. Please see Section
IV.C.l.c, above, for additional discussion of the Database Uncertainty Factor.

The new application of Database Uncertainty Factors necessitated revisions to the occupational/residential,
dietary, and drinking water health risk assessments. Therefore, the following revised documents are being
released along with this RED document:

• MCPA Revised Human Health Risk Assessment for the Reregistration Eligibility Decision (RED)
Document, dated September 14, 2004;
Second Revised Occupational and Residential Exposure and Risk Assessment for the
Reregistration Eligibility Decision (RED) Document, dated September 7, 2004;
• MCPA Revised Product & Residue Chemistry Chapter for the Reregistration Eligibility Decision,
dated September 14, 2004; and
• Revised MCPA Acute and Chronic Dietary Exposure Assessment for the Reregistration Eligibility
Decision, dated September 15, 2004.

The following is a summary of the rationale for managing risks associated with the use of MCPA. Where
labeling revisions are warranted, specific language is set forth in the summary tables of Section V of this
document.

1. Human Health Risk Management

a. Dietary (Food) Risk Mitigation

Acute and chronic dietary risk from food alone is below the Agency's level of concern. No mitigation is
required.

b. Drinking Water Risk Mitigation

Risk from drinking water is below the Agency's level of concern. No mitigation is required.

c. Residential Risk Mitigation

(1) Residential Handler Mitigation

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Residential handler risk from application of MCPA products at the new lower application rates (as
presented in Section IV.C.3), calculated using the revised dermal absorption value (as discussed in Section
IV.D) and the new Database Uncertainty Factors (as discussed in Section IV.D), resulted in risk estimates
that are below the Agency's level of concern (i.e., the dermal MOEs exceed 300 and the inhalation MOEs
exceed 100). In addition, the Aggregate Risk Index (ARI) for the combined dermal and inhalation
exposures exceeds 1.0, and therefore the combined risks are also not of concern. No additional mitigation
is required. See Table 37, below, for a summary of the revised MOEs and ARIs.

Table 38: Revised MCPA Short-term MOEs for Homeowner Applications to Lawns
Scenario
Application Rate = 1.5 Ib ai/acre)
land Application of Granules
telly Grinder Application
^oad/Apply Granules with a Broadcast
Spreader
Vlix/Load/Apply with a Hose-end Sprayer
(Mix your own)
Vlix/Load/Apply with a Hose-end Sprayer
(Ready to Use)
Vlix/Load/Apply with Hand Held Pump
Sprayer
Vlix/Load/Apply with Ready to Use Sprayer
Treated
Area
(acres/day)
0.023
0.023
0.5
0.5
0.5
0.023
0.023
Dermal MOE
(Target MOE = 300)
1800
1800
14000
850
3600
5300
3800
Inhalation MOE
(Target MOE = 100)
19000
140000
4500000
26000
37000
1900000
250000
ARIA
5.8
6.1
46
2.8
12
18
12
4 ARI = l/((300/Dermal MOE) + ( 1 00/Inhalation MOE))
(2) Residential Postapplication Mitigation

Using the lower application rates (as presented in Section IV.C.3) and the new dermal absorption value
(as discussed in Section IV.D), and applying the new Database Uncertainty Factors (as discussed in
Section IV.D), the individual MOEs for acute exposures to both adults and toddlers are below the
Agency's level of concern (i.e., MOEs are above 1,000). However, when these individual MOEs are
combined across exposure pathways, the MOE for combined toddler acute exposures (from dermal,
hand-to-mouth, object-to-mouth, and soil ingestion exposure) is slightly less than 1,000 (MOE=940), and
therefore exceeds the EPA's level of concern. See Table 38, below, for a summary of the revised acute
MOEs for postapplication turf exposures.

Because the MOE for combined toddler acute exposures may be of concern to the Agency, the MCPA
Task Force has committed to undertake a study to determine the dermal transfer efficiency of MCPA
residues from turf to dry and wetted palms. This hand-press study is intended to confirm that the transfer
coefficient used in the toddler exposure assessment is conservative and overestimates risk from mouthing
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behaviors. The Agency believes that the chemical-specific data in this study will verify that the residue
dislodgeable from wet hands is, to some degree, less than the 5% default used in the assessment. This
study must be submitted within the 9-month time period allotted to submit revised labels for MCPA.
71
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Table 39: Revised Acute MOEs for Turf Exposures*

Population
Subgroup

Toddlers
"emales (age 1 3 to
50)

\ll Utner Adults

Scenario

r'laying
Yardwork
Golfing
Yardwork
Golfing

TTR
iUg/cm )

0.514
0.514

0.514

TC
(cni2/hr)

5200
14500
500
14500
500
IMSFlHSll
MOB
{Target
MOE =
• y
1,000)
2000
2300
33300
3400
49000

Hund-to
Mouth MOI
(Target MQE
= 1*000)

2200
N/A

N/A

Object to
Mouth MOE
(Target MOE =
lrOOO)

8900
N/A

N/A

Soil Ingeition
MOE (Target
faOE= 1,000)

/
670000
N/A

N/A

Total
MOE
(Target
MOE =

1,000)
940
2300
33300
3400
49000
»Jote: Bolded MOEs indicate that the scenario exceeds the Agency's Level of Concern
" Assuming an application rate of 1.5 Ib ae/acre.
The revised MOEs for short-term exposures to adults and toddlers exceed the target MOEs, and the
Aggregate Risk Index (ARI) for toddlers exceeds 1.0. Therefore, the risks for adults and toddler short-
term exposures are not of concern either when considered separately or when combined. No additional
mitigation is required. See Table 39, below, for a summary of the revised MOEs and ARIs.

Table 40: Revised Short Term MOEs and ARI Values for Turf Exposures"
Scenario
Dlaying
Yardwork
Golfing
TTM
(ugfam2)
0.097
0.081
0.097
0.081
0.097
0.081
TC
(cm2/hr)
5200
14500
500
Dermal
MOE (T-arg et
MOE,= '30ffl)
1500
1800
2500
2900
36000
43000
Hand-to Moi|th
MOE
(TfrgetMOE=100)
510
720
Object to Mouth
MOE(Targ«t MOE =
^ 100)
2000
2900
Soil Ingestlpn
MOtf(Target
• MOE = iOtfj*
150000
210000
XK^
2.23
2.91
N/A
L ARI = l/((300/Dermal MOE) + (100/Hand-to-Mouth MOE)+ (100/Object-to-Mouth MOE)+(100/Soil Ingestion
VIOE))
* Assuming an application rate of 1 .5 ae/acre, exposure body weight 1 5 kg for toddlers.
d. Aggregate Risk Mitigation

(1) Short-term Aggregate Risk

Table 40, below, presents the results of a short-term aggregate exposure assessment that quantifies risk
from short-term exposure to food, water, and residential sources. The assessment was conducted with the
revised short-term ARI values, which reflect the lower application rates agreed to by the registrants, the
new dermal absorption value, and the new Database Uncertainty Factors.
72
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Comparison of the short-term DWLOCs with the environmental concentrations of MCPA estimated using
PRZM-EXAMS and SCI-GROW modeling indicate that short-term aggregate risks are not of concern.
The DWLOCs are less than the surface water EEC of 1.9 ppb and the ground water EEC of 2.13 ug/1,
and therefore, the short-term aggregate risks are not of concern. No mitigation is required.

Table 41: MCPA Short-term Aggregate Risks (Expressed as DWLOCs)
Population
Subgroup
U.S. Population
Children 1-2 yr
Body
Weight
(kg)
70
10
Daily Water
Consumption
liter/day)
2
1
Food Exposure
mg/kg/day)
0.0013
0.0038
Food
ARI1
34
12
Turf
ARI2'3
8.3
2.2
Available ARI
For Water
Exposure*
1.2
2.2
Available Water
Exposure
(mg/kg/day)
0.037
0.020
DWLOC6
(ug/1)
1300
200
Notes 1. Food ARI = cPAD/Food Exposure where the cPAD = 0.044 mg/kg/day
2. Turf ARI for children taken from Table 39, above. ARI = l/((300/Dermal MOE) + (100/Hand-to-Mouth MOE)+
(100/Object-to-Mouth MOE)+(100/Soil Ingestion MOE))
3. Turf ARI for adults = Dermal MOE/Target MOE, where dermal MOE = 2500 and Target MOE = 300.
4. Available ARI: 1 = l/((l/Food ARI)+(l/Turf ARI) + (1/X)) where X = Available ARI
5. Available Water Exposure = cPAD/Available ARI for Water Exposure
6. DWLOC = (Available Water Exposure X Body Weight)/(Daily Water Consumption X O.OOlmg/ug)

(2) Chronic Aggregate Risk

No chronic residential scenarios have been identified for MCPA. Therefore, chronic aggregate risks are
based solely on dietary exposure from food and water. Conservative exposure estimates for food and
drinking water indicate that there is no concern for chronic health risks from these pathways. No
mitigation is required.

e. Occupational Risk Mitigation

(1) Handler Risk Mitigation

When assessed at the lower application rates (as presented in Section IV.C.3) and the new dermal
absorption value (as discussed in Section IV.D), all of the occupational handler MOEs exceed target
MOEs with baseline Personal Protective Equipment (long pants, long sleeved shirt, shoes with socks, and
no gloves or respirator) for all scenarios except for the mixing and loading of liquids for aerial,
groundboom, and right-of-way sprayer application, and the mixing and loading of wettable powder to
groundboom application to golf courses. With the addition of chemical resistant gloves, all scenarios
except for mixing/loading liquids for application to rangeland/pastureland do not exceed the Agency's level
of concern (MOEs > 100). The MOE for mixing/loading liquids for rangeland/pastureland application
does not exceed the Agency's level of concern when assessed with single layer PPE and a filtering
facepiece respirator (i.e., dustmask) with a protection factor of five. See Table 41 for a summary of the
revised MOEs.
73
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Table 42 - Revised Short/Intermediate Term MOEs for Occupational Handlers
Exposure Scenario
Vlixer/Loader (M/L)
Applicator
Vlixer/Loader/
Applicator (M/L/A)
Dagger
Formulation/
Application Method
M/L Wettable
Powder for
Groundboom
M/L Liquids for
Aerial
M/L Liquids for
Groundboom
M/L Liquids for
Row Sprayer
Load Granulars for
Broadcast Spreader
Aerial Application
Groundboom
Application
Right of Way
Application
Broadcast Spreader
Application
M/L/A Liquids with
Backpack Sprayer
M/L/A Wettable
Powder with
Lurfgun
M/L/A Liquid
Flowables with
Lurfgun
Load/Apply
Granules with a
Push Cyclone
Flag Aerial
Application
Crop or Site
Golf Courses
Rangeland,
Dastures
5mall Grains
"lax and Peas
Rangeland,
Dastures
All other Crops
Golf Courses
Weed Control
Brush Control
Golf Courses
All Crops Above
All Crops Above
Weed Control
Brush Control
Golf Courses
5pot Treatment
turf
turf
turf
Rangeland, Pasture
All other Crops
Application
Rate
'lb ae/acre)
1.5
1.5
).75
).375
1.5
).375to0.75
1.5
1.5
5.0
1.5
).375to 1.5
).375tol.5
1.5
5.0
1.5
5
1.5
1.5
1.5
1.5
).375to0.75
Acres/
Day
10
1200
1200
1200
>00
>00
10
50
10
10
1200
10 to
>00
50
10
10
1
5
5
5
1200
1200
Baselin
e
25
1.3
2.7
5.3
8
>16
30
32
80
2500
>590
>760
67
170
3100
ND
ND
ND
ND
210
>410
Single
Layer
with gloves
110
77
150
310
460
>920
1700
1900
4600
2600
ND
>760
190
490
3400
220
430
1700
290
190
>390
Single
LayerPFS
with gloves
320
140
280
550
320
>1600
3100
3300
3200
3000
SID
>1300
230
570
9200
230
910
1800
350
290
>570
\Tote - MOEs in bold font are below the target MOE of 100 and indicate risks of concern.
In addition to the required application rate reductions and use cancellations presented in Section IV.C.3,
the following mitigation is required to address risks to occupational handlers.
74
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Single-layer PPE (long pants, long sleeved shirt, shoes, socks, and chemical resistant gloves)
and a PF5 Respirator must be worn when handlers are performing the following tasks:

Mixing/Loading Liquids for aerial application to rangeland/pastures

Single-layer PPE (long pants, long sleeved shirt, shoes, socks, and chemical resistant
gloves) must be worn when handlers are performing the following tasks:

Mixing/Loading wettable powders for groundboom application
Mixing/Loading liquids for aerial application to small grains, flax, and peas
Mixing/Loading liquids for groundboom application
Mixing/Loading liquids using row sprayer
Mixing/Loading/Applying liquids with backpack sprayer
Mixing/Loading/Applying wettable powders with turfgun
Mixing/Loading/Applying liquids flowables with turfgun
Loading/Applying granules with a push cyclone
Applying to rights-of-way for weed control

• Baseline PPE (long pants, long sleeved shirt, shoes, and socks) must be worn by handlers
during the following activities:

Applying aerially, or by groundboom or broadcast spreader
Flagging aerial spray applications

(2) Post-application Risk Mitigation

When assessed at the lower application rates (as presented previously in Section IV.C.3), all of the
short/intermediate term MOEs for post-application occupational exposure to MCPA exceed the target
MOE, which indicates that the risks are not of concern. Chronic post-application occupational
exposure was not evaluated because MCPA is typically applied once per season, and thus chronic
exposure is not expected. See Table 42 for a summary of the MOEs.
Table 43: MCPA Postapplication Worker Risks
Crop
•lax
3eas
imall Grains
Turf
Transfer Coefficient Group
Field/row crop, low/medium
Field/row crop, low/medium
Field/row crop, low/medium
Turf - California
Short/Intermediate Term MOE on Day 0
Application Rate
(Ib ae/acre)
0.375
0.375
0.75
1.5
Low Exposure
Scenarios
10000
10000
5200
960
Medium
Exposure
Scenarios
690
NA
340
NA
High Exposure
Scenarios
NA
NA
NA
480
75
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Table 43: MCPA Postapplication Worker Risks
Crop

Transfer Coefficient Group
Turf - North Carolina
Short/Intermediate Term MOE on Day 0
Application Rate
(Ib ae/acre)
1.5
Low Exposure
Scenarios
500
Medium
Exposure
Scenarios
NA
High Exposure
Scenarios
250
The Restricted Entry Interval (REI) represents the amount of time required for residues to dissipate in
treated areas prior to beginning a job or task in that area such that the resulting exposures do not exceed
the Agency's level of risk concern. In order to determine the REI for a crop, EPA calculates the
number of days that must elapse after pesticide application until residues dissipate and risk to a worker
falls below the target risk level. For a specific crop/pesticide combination, the duration required to
achieve the target risk estimate can vary depending on the activity assessed. The current REIs are 12
hours for the ester form and 48 hours for the amine and sodium salt forms. The current REIs are
sufficiently protective, and thus no modification is required. There is no REI for the acid form because
the acid form is used only on non-agricultural sites (such as lawns and golf courses).

2. Environmental Risk Mitigation

Implementation of the mitigation measures described above - the rate reductions and use cancellations
presented in Section IV.C.3 - has resulted in decreases in exposure values, leading to significantly lower
RQ's for terrestrial and aquatic organisms, as well as terrestrial and aquatic plants. There are a few
scenarios which still show LOG exceedances at the lower application rates, particularly terrestrial plants.
However, most of these exceedances are slight and, therefore, EPA has determined that no further risk
mitigation is necessary for environmental concerns.

An additional mitigation measure that was agreed to by registrants and which will be required on
applicable end-use products is a statement limiting spray droplet size to "medium to coarse," thereby
prohibiting "fine" sprays. This mitigation measure should provide additional protection to wildlife and
plants.

3. Other Labeling Requirements

In order to be eligible for reregistration, various use and safety information must also be placed on the
labeling of all end-use products containing MCPA. For the specific labeling statements, refer to Section
V of this document.

a. Endangered Species Statement

Based on EPA's screening level assessment for MCPA, RQs exceed levels of concern for mammals,
birds, aquatic plants, and terrestrial plants. However, these findings are based soley on EPA's screening
level assessment and do not constitute "may affect" findings under the ESA. The Agency is requiring
application rate reductions and additional mitigation to minimize these LOG exceedances, and is
requiring additional data to further characterize and refine its ecological and endangered species risk
assessments.

b. Spray Drift Management

The Agency is in the process of developing more appropriate label statements for spray and dust drift
control to ensure that public health, and the environment is protected from unreasonable adverse effects.
The Agency will publish final guidance in a Pesticide Registration notice for registrants to use when
labeling their products.
V. What Registrants Need to Do

The Agency has determined that MCPA is eligible for reregistration provided that: (i) additional data that
the Agency intends to require confirm this interim decision; and (ii) the risk mitigation measures outlined
in this document are adopted, and label amendments are made to reflect these measures. To implement
the risk mitigation measures, the registrants must amend their product labeling to incorporate the label
statements set forth in the Label Summary Table in Section V.D (Table 43). The additional data
requirements that the Agency intends to obtain will include, among other things, submission of the
following:

A. For MCPA technical grade active ingredient products, registrants need to submit
the following items.

Within 90 days from receipt of the generic data call-in (DCI):

(1) completed response forms to the generic DCI (i.e., DCI response form and
requirements status and registrant's response form); and
(2) submit any time extension and/or waiver requests with a full written justification.
77
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Within the time limit specified in the generic DCI:

(1) cite any existing generic data which address data requirements or submit new
generic data responding to the DCI.

Please contact Kelly White at (703) 305-8401 with questions regarding generic reregistration and/or the
DCI. All materials submitted in response to the generic DCI should be addressed as follows:
Bv US mail:
Document Processing Desk (DCI/SRRD)
Kelly White
US EPA (7508C)
1200 Pennsylvania Ave., NW
Washington, DC 20460
By express or courier service:
Document Processing Desk (DCI/SRRD)
Kelly White
Office of Pesticide Programs (7508C)
Room 266A, Crystal Mall 2
1801 Bell Street
Arlington, VA 22202
B. For products containing the active ingredient MCPA. registrants need to submit the
following items for each product.

Within 90 days from the receipt of the product-specific data call-in (PDCI):

(1) completed response forms to the PDCI (i.e., PDCI response form and
requirements status and registrant's response form); and
(2) submit any time extension or waiver requests with a full written justification.
Within eight months from the receipt of the PDCI:

(1) two copies of the confidential statement of formula (EPA Form 8570-4);

(2) a completed original application for reregistration (EPA Form 8570-1).
Indicate on the form that it is an "application for reregistration";
(3) five copies of the draft label incorporating all label amendments outlined in Table
43 of this document;
(4) a completed for certifying compliance with data compensation requirements
(EPA Form 8570-34);
(5) if applicable, a completed for certifying compliance with cost share offer
requirements (EPA Form 8570-32); and
(6) the product-specific data responding to the PDCI.
78
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Please contact Bonnie Adler at (703) 308-8523 with questions regarding product reregistration and/or
the PDCI. All materials submitted in response to the PDCI should be addressed as follows:
Bv US mail:
Document Processing Desk (PDCI/PRB)
Bonnie Adler
US EPA (7508C)
1200 Pennsylvania Ave., NW
Washington, DC 20460
By express or courier service:
Document Processing Desk (PDCI/PRB)
Bonnie Adler
Office of Pesticide Programs (7508C)
Room 266A, Crystal Mall 2
1921 Jefferson Davis Highway
Arlington, VA 22202
79
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A. Manufacturing Use Products

1. Additional Data Requirements

The generic database supporting the reregistration of MCPA has been reviewed and determined to be
substantially complete. However the following data requirements are necessary to confirm the
reregistration eligibility decision in this RED.

Toxicology:

• 870.6300 Developmental neurotoxicity study in rats with MPCA EHE

870.3465 Twenty eight (28) day inhalation study in rats (abbreviated 90-day protocol).
The Agency is requiring this study due to the concern for the potential
occupational exposure via this route based on the current use pattern. The
registrant is recommended to follow all the procedures stipulated in the
Subdivision F Guidelines for the 90-day inhalation study (870.3465) except that
the exposure duration can be reduced to 28 days

Environmental Fate:

835.1410 Laboratory volatility study with MCPA EHE

• 835.4100 Laboratory fate data for aerobic soil metabolism for MCPA EHE, preferably
under acid conditions

• 835.1240 Laboratory fate data for a batch equilibrium study conducted with MCPA EHE,
preferably under a range of pHs

Ecological Effects:

850.4225 Seedling Emergence (Tier E) for three formulations of MCPA: (1) either the
acid or sodium salt, (2) DMAS, and (3) EHE, all using a TEP

850.4250 Vegetative Vigor (Tier H) for three formulations of MCPA: (1) either the acid or
sodium salt, (2) DMAS, and (3) EHE, all using a TEP

• 850.4400 Aquatic Plant Growth (Tier n with Lemna sp.) using three formulations of
MCPA: (1) either the acid or sodium salt, (2) DMAS, and (3) EHE, all using a
TEP
80
-------
850.2200 Avian Dietary LC50 Guideline for one species (preferably bobwhite quail) using
MCPAEHE.

Residue Chemistry:

• 860.1300 Metabolism studies on peas

• 860.1340 Residue analytical method: The Residue Chemistry Chapter of the Registration
Standard dated 8/31/81 noted that the PAM Vol I method is adequate for
enforcement of tolerances for residues of MCPA in livestock commodities as-is,
however the Agency is now requiring the method be modified with a hydrolysis
step for enforcement of MCPA tolerances for plant commodities.

860.1380 Storage stability data for wheat grain stored under ambient conditions for 28
days

860.1480 Ruminant feed study

• 860.1500 Four field trials reflecting a 0-day PHI for pasture forage

860.1900 A study detailing confined accumulation in rotational crops planted following
treatment at 1.5 Ib ae/A

Occupational/Residential Exposure:

875.1100 Hand press study

2. Labeling for Manufacturing Use Products

To ensure compliance with FIFRA, manufacturing use product (MUP) labeling should be revised to
comply with all current EPA regulations, PR Notices and applicable policies. The MP labeling should
bear the labeling contained in Table 43 at the end of this section.

B. End-Use Products

1. Additional Product-Specific Data 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

81
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studies. If a registrant believes that previously submitted data meet current testing standards, then the
study MRID numbers should be cited according to the instructions in the Requirement Status and
Registrants Response Form provided for each product.
A product-specific data call-in, outlining specific data requirements, accompanies this RED.

2. Labeling for End-Use Products

Labeling changes are necessary to implement the mitigation measures outlined in Section IV above.
Specific language to incorporate these changes is specified in Table 44.

C. Labeling Changes Summary Table

In order to be eligible for reregistration, amend all product labels to incorporate the risk mitigation
measures outlined in Section IV. The following table describes how language on the labels should be
amended.
82
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Table 44: Labeling Changes Summary Table
In order to be eligible for reregistration, amend all product labels to incorporate the risk mitigation measures outlined in Section IV. The following
table describes how language on the labels should be amended.
Table 44: Summary of Labeling Changes for MCPA
on Lubel
For all Manufacturing Use
Products
"Only for formulation into an herbicide for the following use(s) [fill blank only with
those uses that are being supported by MP registrant]."

"Uses for rice and grain sorghum are canceled. Technical and end-use product labels
must be revised to delete all references to and use-directions for these canceled use
patterns."
Directions for Use
One of these statements may
be added to a label to allow
reformulation of the product
for a specific use or all
additional uses supported by a
formulator or user group
"This product may be used to formulate products for specific use(s) not listed on the
MP label if the formulator, user group, or grower has complied with U.S. EPA
submission requirements regarding support of such use(s)."

"This product may be used to formulate products for any additional use(s) not listed on
the MP label if the formulator, user group, or grower has complied with U.S. EPA
submission requirements regarding support of such use(s)."
Directions for Use
Environmental Hazards
Statements Required by the
RED and Agency Label
Policies
"Do not discharge effluent containing this product into lakes, streams, ponds, estuaries,
oceans, or other waters unless in accordance with the requirements of a National
Pollution Discharge Elimination System (NPDES) permit and the permitting authority
has been notified in writing prior to discharge. Do not discharge effluent containing
this product to sewer systems without previously notifying the local sewage treatment
plant authority. For guidance contact your State Water Board or Regional Office of
the EPA."
Precautionary
Statements
83
-------
,4 ,tTse Products |nteij46d/'f°r Occupational Use
',/' •••" x ^/ / .v ^ '•'.-•' .- x * ,/>••-
PPE Requirements
Established by the RED1
for Liquid Concentrate
Formulations
"Some materials that are chemical-resistant to this product are" (registrant inserts
correct chemical-resistant material). "If you want more options, follow the
instructions for category" [registrant inserts A,B,C,D,E,F,G,or H\ "on an EPA
chemical-resistance category selection chart."

"Personal Protective Equipment (PPE)"
"Mixers, loaders, applicators, flaggers and other handlers must wear:
- Long- sleeved shirt and long pants,
- Shoes plus socks, and
- Chemical- resistant gloves when mixing, loading, or using any hand-held equipment."
Immediately
following/below
Precautionary
Statements: Hazards
to Humans and
Domestic Animals
Additional PPE Requirements
Established by the RED for
Liquid Concentrate
Formulations that contain
directions for use for aerial
application to rangeland, or
pasture land, or noncropland
"Additional PPE requirements for mixers and loaders supporting aerial application to
rangelands, pasture lands, or noncropland. These mixers/loaders also must wear:

- a chemical-resistant apron, and
- a NIOSH-approved respirator with a dust/ mist filter with MSHA/ NIOSH approval
number prefix TC-21C or any N2, R, P, or HE filter."

"See engineering controls for additional requirements."
Immediately
following the handler
PPE statement
specified for liquid
concentrate
formulations
PPE Requirements
Established by the RED1
for Water Dispersable
Granules and for Wettable
Powder Formulations
(including Wettable Powders
formulated in water soluble
packages.)
"Some materials that are chemical-resistant to this product are" (registrant inserts
correct chemical-resistant material). "If you want more options, follow the
instructions for category" [registrant inserts A,B,C,D,E,F,G,or H\ "on an EPA
chemical-resistance category selection chart."

"Personal Protective Equipment (PPE)
Mixers, loaders, applicators, and other handlers must wear:
- Long- sleeved shirt and long pants,
- Shoes plus socks, and
- Chemical-resistant gloves when mixing, loading, or using hand-held equipment."
Immediately
following^elow
Precautionary
Statements: Hazards
to Humans and
Domestic Animals
84
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PPE Requirements
Established by the RED1
for Granular
Formulations
"Personal Protective Equipment (PPE)
Loaders, applicators, and other handlers must wear:
- Long- sleeved shirt and long pants, and
- Shoes plus socks."
Immediately
following^elow
Precautionary
Statements: Hazards
to Humans and
Domestic Animals
User Safety Requirements
"Follow manufacturer's instructions for cleaning/maintaining PPE. If no such
instructions for washables exist, use detergent and hot water. Keep and wash PPE
separately from other laundry."
Precautionary
Statements: Hazards
to Humans and
Domestic Animals
immediately following
the PPE
requirements
Engineering Controls for
aerial applications
Enclosed Cockpits

"Engineering Controls:

Pilots must use an enclosed cockpit that meets the requirements listed in the WPS for
agricultural pesticides [40 CFR 170.240(d)(6)]."
Precautionary
Statements: Hazards
to Humans and
Domestic Animals
immediately following
PPE and User Safety
Requirements.
85
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User Safety
Recommendations
"User Safety Recommendations

Users should wash hands before eating, drinking, chewing gum, using tobacco, or using
the toilet.

Users should remove clothing/PPE immediately if pesticide gets inside. Then wash
thoroughly and put on clean clothing.

Users should remove PPE immediately after handling this product. Wash the outside
of gloves before removing. As soon as possible, wash thoroughly and change into
clean clothing."
Precautionary
Statements under:
Hazards to Humans
and Domestic
Animals immediately
following Engineering
Controls or if no
Engineering Controls
statements,
immediately following
User Safety
Requirements

(Must be placed in a
box.)
Environmental Hazards
"This pesticide may be toxic to fish, aquatic invertebrates and aquatic plants. Do not
apply directly to water, to areas where surface water is present, or to intertidal areas
below the mean high water mark. Do not contaminate water when disposing of
equipment washwater or rinsate. Drift and runoff may be hazardous to aquatic
organisms in water adjacent to treated areas. Runoff of this product will be reduced
by avoiding applications when rainfall is forecasted to occur within 48 hours."

"This chemical has properties and characteristics associated with chemicals detected
in groundwater. The use of this chemical in areas where soils are permeable,
particularly where the water table is shallow, may result in groundwater
contamination."
Precautionary
Statements
immediately following
the User Safety
Recommendations
Restricted-Entry Interval for
MCPA products that contain
acid, amine, or sodium salt
forms and have directions for
use within the scope of the
WPS
"Do not enter or allow worker entry into treated areas during the restricted entry
interval (REI) of 48 hours."
Directions for Use,
Under Agricultural
Use Requirements
Box
86
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Restricted-Entry Interval for
MCPA products that contain
only ester forms and have
directions for use within the
scope of the WPS
"Do not enter or allow worker entry into treated areas during the restricted entry
interval (REI) of 12 hours."
Directions for Use,
Under Agricultural
Use Requirements
Box
Early Entry Personal
Protective Equipment for
MCPA products that contain
acid, amine, or sodium salt
forms and have directions for
use within the scope of the
WPS
"PPE required for early entry to treated areas that is permitted under the Worker
Protection Standard and that involves contact with anything that has been treated, such
as plants, soil, or water, is:
* coveralls,
* shoes plus socks,
* chemical-resistant gloves made of any waterproof material, and
* protective eyewear."
Direction for Use
Agricultural Use
Requirements box
immediately following
the REI statement
Early Entry Personal
Protective Equipment for
MCPA products that contain
only ester forms and have
directions for use within the
scope of the WPS
"PPE required for early entry to treated areas that is permitted under the Worker
Protection Standard and that involves contact with anything that has been treated, such
as plants, soil, or water is:
* coveralls,
* shoes plus socks, and
* chemical-resistant gloves made of any waterproof material."
Direction for Use
Agricultural Use
Requirements box
immediately following
the REI statement
General Application
Restrictions for products
primarily intended for
occupational (professional)
use
"Do not apply this product in a way that will contact workers or other persons, either
directly or through drift. Only protected handlers may be in the area during
application."
Place in the
Directions for Use
directly above the
Agricultural Use Box
if there is one,
otherwise place in
Directions for Use
under General
Precautions and
Restrictions
87
-------
Use-Specific Application
Restrictions

(Note: The maximum
allowable application rate
must be listed as pounds or
gallons of formulated product
per acre not just as pounds
active equivalent per acre.)
Wheat
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 0.75 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year)."

Barley
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 0.75 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year)."

Oats
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 0.75 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year)."

Rye
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 0.75 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year)."

Flax
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 0.25 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year)."
Directions for Use
Associated with the
Specific Use Pattern
-------
Other Application
Restrictions

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds active equivalent per
acre.)
Sod farms
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 1.5 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year).
Do not apply more than 2 applications per year with a minimum retreatment interval of
21 days."

Golf Courses
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 1.5 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year). Do not apply more than 2 applications per year with a
minimum retreatment interval of 21 days."

Grass Grown for Seed
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 1.5 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year). Do not apply more than 2 applications per year with a
minimum retreatment interval of 21 days."
Directions for Use
Associated with the
Specific Use Pattern
89
-------
Other Application
Restrictions

(Note: The maximum
allowable application rate and
maximum allowable rate per
year must be listed as pounds
or gallons of formulated
product per acre, not just as
pounds active equivalent per
acre.)
Pasture/ Rangeland
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 1.5 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year).
Do not apply more than 2 applications per year with a minimum retreatment interval of
21 days."

Noncropland Rights-of-Way (Broadcast Treatment)
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 1.5 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year).
Do not apply more than 2 applications per year with a minimum retreatment interval of
21 days."

Noncropland Rights-of-Way (Spot Treatment)
Permitted forms of MCPA include acid, salts, amines, and esters
"Do not apply more than 3.0 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year).
Directions for Use
Associated with the
Specific Use Pattern
Use Deletions
-Rice
Delete all references to applications to rice from all MCPA end-use labels.
- Grain sorghum
Delete all references to applications to grain sorghum from all MCPA end-use labels.
90
-------
Spray Drift
"SPRAY DRIFT MANAGEMENT"
"Avoiding spray drift at the application site is the responsibility of the applicator. The
interaction of many equipment-and-weather-related factors determine the potential for
spray drift. The applicator and the grower are responsible for considering all these
factors when making decisions."

"Apply only as a medium or coarser spray (ASAE standard 572) or a volume mean
diameter of 300 microns or greater for spinning atomizer nozzles."

"Apply only when the wind speed is 2-10 mph at the application site."

Additional requirements for aerial applications:
"The boom length must not exceed 75% of the wingspan or 90% or the rotor blade
diameter."
"Release spray at the lowest height consistent with efficacy and flight safety. Do not
release spray at a height greater than 10 feet above the crop canopy."

"When applications are made with a crosswind, the swath will be displaced downwind.
The applicator must compensate for this displacement at the downwind edge of the
application area by adjusting the path of the aircraft upwind."

"Do not make applications into temperature inversions."

Additional requirements for ground boom application:
"Do not apply with a nozzle height greater than 4 feet above the crop canopy."
Directions for Use
91
-------
End U
Application Restrictions
"Do not apply this product in a way that will contact any person, or pet, either directly
or through drift. Keep people and pets out of the area during application."
Directions for Use
under General
Precautions and
Restrictions
Other Application
Restrictions

(Note: The maximum
allowable application rate
must be listed as pounds or
gallons of formulated product
per acre not just as pounds
active ingredient per acre.)
Residential Turf

"Do not apply more than 1.5 Ib ae / acre per year (registrant state this in amount of
formulation per acre per year).
Do not apply more than 2 applications per year with a minimum retreatment interval of
21 days."
Entry Restrictions Liquid
Concentrate, Wettable
Powder, and Water
Dispersible Granule (Dry
Flowable) formulations
"Do not allow people or pets to enter the treated area until sprays have dried."
Directions for use
under General
Precautions and
Restrictions
Entry Restrictions for
Granular Formulations
"Do not allow people or pets to enter the treated area until dusts have settled."
[If watering in is required after the application, "do not enter or allow others to enter
the treated areas (except those involved in the watering) until the watering-in is
complete and the surface is dry."]
Directions for use
under General
Precautions and
Restrictions
92
-------
Environmental Hazard
Statement
"This pesticide may be toxic to fish, aquatic invertebrates, and aquatic plants. Do not
apply directly to water. Drift and runoff may be hazardous to aquatic organisms in
water adjacent to treated areas. Runoff of this product will be reduced by avoiding
applications when rainfall is forecasted to occur within 48 hours. Do not contaminate
water when disposing of equipment washwaters or rinsate."
Directions for Use
Associated with the
Specific Use Pattern
1 PPE that is established on the basis of Acute Toxicity of the end-use product must be compared to the active ingredient PPE in this document.
The more protective PPE must be placed in the product labeling. For guidance on which PPE is considered more protective, see PR Notice 93-7.
2 If the product contains oil or bears instructions that will allow application with an oil-containing material, the "N" designation must be dropped.
93
-------
Appendix A. Use Patterns Subject to Reregistration For MCPA (Case 0017)
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Food/ Feed Uses
Maximum # Applications per
Year
Maximum Yearly Rate
Use Directions and Limitations
ALFALFA
Sodium Salt
Spray
Aircraft/ Ground
Dormant
0.5 Ib
Dimethylamine Salt
Spray
Aircraft/Ground/Sprayer
Spray
Aircraft/Ground
Spray
Aircraft/Ground/Sprayer
Spray
Aircraft/Ground
Spray
Ground
Dormant
Foliar
Late fall
Late Tillering
Tillering
0.5 Ib
0.23125 Ib
0.5 Ib
0.25 Ib
0.23125 Ib
None
2
1.0 Ib
7 day(s) preforage interval (animals being finished for slaughter^
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (animals being finished for slaughtei
2
2
1
2
2
1.0 Ib
.4625 Ib
0.5 Ib
0.5 Ib
.4625 Ib
94
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Maximum it Applications per
Year
Maximum Yearly Rate
BARLEY
Sodium Salt
Broadcast
Aircraft/Low pressure ground sprayer
Broadcast
Aircraft/Ground/Low pressure ground sprayer
Spray
Aircraft/Ground
Spot Treatment/Spray
Aircraft/Low pressure ground sprayer
Early boot
Early Jointing
Postemergence
Tillering
0.75 Ib
0.75 Ib
0.75 Ib
0.75 Ib
7 days(s) preforage interval (animals being finished for slaughte:
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
14 days(s) preforage interval (animals being finished for slaught
14 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
2
l.Slb
l.Slb
l.Slb
l.Slb
).
*)•
95
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Dimethylamine salt
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Low pressure ground sprayer
Spray
Aircraft/Ground
Low volume spray (concentrate)
Aircraft/Low volume ground sprayer
Spray
Aircraft/Ground
Early boot
Foliar
Internode elongation
Postemergence
Spring
Tiller through boot
0.75 Ib
0.75 Ib
0.75 Ib
0.75 Ib
0.25 Ib
0.75 Ib
Maximum it Applications per
Year
Maximum Yearly Rate
14 days(s) preforage interval (animals being finished for slaught
14 days(s) pregrazing interval (meat animals being finished for
slaughter).
7 day(s) prefeeding interval.
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
2
1
2
l.Slb
l.Slb
l.Slb
l.Slb
0.25 Ib
3.0 Ib
96
-------
Site
Application Type
Application Equipment
Low volume spray (concentrate)/Spray
Aircraft/Ground/Low pressure ground sprayer
ApplicationTiming
Tillering
Max. Single Application
Rate
(AE)A
0.75 Ib
tsooctyl ester
Chemigation/Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer/Sprinkler irrigation
Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer
Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer
Internode elongation
Postharvest
Tillering
0.5 Ib
0.5 Ib
0.5 Ib
Maximum it Applications per
Year
2
Maximum Yearly Rate
3.0 Ib
45 day(s) pregrazing interval.
Buffer zone restriction.
2
2
2
1.0 Ib
1.0 Ib
1.0 Ib
97
-------
Site
Application Type

Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Maximum it Applications per
Year
Maximum Yearly Rate
2-Ethylhexyl ester
7 day(s) preforage interval (animals being finished for slaughter"
14 day(s) preforage interval ( animals being finished for slaughte r).
14 day(s) preforage interval (dairy animals).
14 day(s) pregrazing interval ( dairy animals).
14 day(s) preharvest interval (dry hay).
40 day(s) preharvest interval (grain).
45 day(s) pregrazing interval.
57 day(s) preharvest interval.
7 day(s) prefeeding interval.
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals)
7 day(s) pregrazing interval (dairy animals)
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
7 day(s) preharvest interval (forage).
Low volume spray (concentrate)/Spray
Aircraft/Ground
Early spring
0.75 Ib
1
1.38751b
Low volume spray (concentrate)/Spray
Aircraft/Ground
Fall
0.4625 Ib
0.4625 Ib
Broadcast/Chemigation/Low volume spray (concentrate)/Spo1
treatment/Spray

Aircraft/Backpack sprayer/Boom sprayer/Ground/Hand held
prayer/Low pressure ground sprayer/Low volume ground
sprayer/Sprinkler irrigation
Postemersence
0.75 Ib
3.0 Ib
98
-------
Site
Application Type
Application Equipment
Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer/Low volume ground sprayer
Geographic allowable: MN MT ND SD
Low volume spray (concentrate)/Spot treatment
Aircraft/Hand held sprayer/Low volume ground sprayer
Low volume spray (concentrate)/Spray
Aircraft/Ground Low volume ground sprayer
ApplicationTiming
Postharvest
Spring
Tillering
Max. Single Application
Rate
(AE)A
0.5 Ib
0.6844 Ib
0.4875 Ib
Maximum it Applications per
Year
2
1
2
Maximum Yearly Rate
1.0 Ib
0.6844 Ib
0.975 Ib
BARLEY-LEGUME MIXTURE
Sodium Salt
Broadcast/Low volume spray (concentrate)
Aircraft/Low pressure ground sprayer
Spray
Aircraft
Early jointing
Tillering
0.5 Ib
0.25 Ib
7 days(s) preforage interval (animals being finished for slaughte
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
14 days(s) preforage interval (animals being finished for slaught
14 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
1.0 Ib
0.5 Ib
).
*)•
99
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Dimethylamine salt
Spray
Aircraft/Ground/Low pressure
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground/Low pressure ground sprayer/Sprayer
Internode elongation
Late tillering
Tillering
0.24585 Ib
0.25 Ib
0.75 Ib
Maximum it Applications per
Year
Maximum Yearly Rate
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
0.4917 Ib
0.5 Ib
l.Slb
CLOVER
Sodium Salt
Spray
Aircraft/Ground
Dormant
0.5 Ib
Dimethylamine salt
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
1.0 Ib

100
-------
Site
Application Type

Application Equipment
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Spray
Ground
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Spray
Ground
ApplicationTiming

Dormant

Fall

Foliar

Late fall

Late tillering

Postemergence

Spring

Tillering

Max. Single Application
Rate
(AE)A

0.5 Ib

0.4625 Ib

0.23125 Ib

0.4625 Ib

0.25 Ib

0.4625 Ib

0.23125 Ib

Maximum it Applications per
Year

Maximum Yearly Rate

1.0 Ib

0.4625 Ib

0.5 Ib

0.925 Ib

0.4625 Ib

FLAX
101
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Sodium Salt
Low volume spray (concentrate)/Spray
Aircraft/Ground/Low pressure ground sprayer
Spray
Aircraft/Ground
Before bud Break
Postemergence
0.25 Ib
0.25 Ib
Dimethylamine Salt
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Before bud break
Boot
Foliar
0.25 Ib
0.25 Ib
0.25 Ib
Maximum it Applications per
Year
Maximum Yearly Rate
7 day(s) preforage interval (animals being finished for slaughter
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
0.50 Ib
0.50 Ib
7 day(s) prefeeding interval on threshings or stubble to meat am
7 day(s) prefeeding interval.
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
0.50 Ib
0.50 Ib
0.50 Ib
nals
102
-------
Site
Application Type
Application Equipment
High volume spray (dilute )/Low volume spray (concentrate)/S
Aircraft/Ground
ApplicationTiming
)rayPostemergence
Max. Single Application
Rate
(AE)A
0.25 Ib
tsooctyl ester
Chemigation/Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer/Sprinkler irrigation
Foliar
0.225 Ib
2-Ethylhexyl ester
Low volume spray (concentrate)/Spray
Aircraft/Ground
Broadcast/Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer/Ground Low volume ground sprayer
Foliar
Postemergence
0.25 Ib
0.25 Ib
Maximum it Applications per
Year
2
Maximum Yearly Rate
0.50 Ib
Buffer zone restriction.
2
0.45 Ib
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals)
7 day(s) pregrazing interval (dairy animals)
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
7 day(s) pregrazing interval.
2
2
0.50 Ib
0.50 Ib
GRASS FORAGE/FODDER/HAY
Sodium Salt
Low volume spray (concentrate)/Spray
Aircraft/Low pressure ground sprayer
Early jointing
0.93 Ib
7 days(s) preforage interval (animals being finished for slaughte:
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
1.861b
103
-------
Site
Application Type
Application Equipment
Spray
Aircraft/Ground
ApplicationTiming
Postemergence
Max. Single Application
Rate
(AE)A
0.93 Ib
2-Ethylhexyl ester
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground
Established plantings
Fall
Spring
l.Slb
1.38751b
1.38751b
Maximum it Applications per
Year
2
Maximum Yearly Rate
1.861b
1 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals)
7 day(s) pregrazing interval (dairy animals)
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
1
1
1
3.0 Ib
1.38751b
1.38751b
GRASS GROWN FOR SEED
Sodium Salt
Broadcast
Aircraft/Low pressure ground sprayer
Spring
1.0 Ib
Dimethylamine Salt
7 days(s) preforage interval (animals being finished for slaughte:
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
1
7 day(s) preslaughter interval.
1.0 Ib

104
-------
Site
Application Type
Application Equipment
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Spray
Aircraft/Ground
ApplicationTiming
Established plantings
Spring
Tillering
Max. Single Application
Rate
(AE)A
2.0 Ib
0.8775 Ib
0.8775 Ib
2-Ethylhexyl ester
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground/Sprayer
Established plantings
Fall
Spring
0.925 Ib
0.925 Ib
0.925 Ib
Maximum it Applications per
Year
2
1
2
Maximum Yearly Rate
4.0 Ib
0.8775 Ib
1.7551b
7 day(s) prefeeding interval.
7 day(s) pregrazing interval.
2
1
1
1.851b
0.925 Ib
0.925 Ib
LESPEDEZA
Dimethylamine Salt
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
105
-------
Site
Application Type
Application Equipment
Spray
Ground
ApplicationTiming
Tillering
Max. Single Application
Rate
(AE)A
0.23125 Ib
Maximum it Applications per
Year
2
Maximum Yearly Rate
0.4625 Ib
OATS
Sodium Salt
Broadcast
Aircraft/Low pressure ground sprayer
Broadcast
Aircraft/Ground/Low pressure ground sprayer
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Low pressure ground sprayer
Early boot
Early jointing
Postemergence
Tiller through boot
0.75 Ib
0.75 Ib
0.75 Ib
0.6975 Ib
7 days(s) preforage interval (animals being finished for slaughte:
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
14 days(s) preforage interval (animals being finished for slaught
14 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
2
l.Slb
l.Slb
l.Slb
1.3951b
).
*)•
106
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Dimethylamine Salt
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Low pressure ground sprayer
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground/Low pressure ground sprayer
Early boot
Foliar
Internode elongation
Postemergence
Tiller through boot
Tillering
0.75 Ib
0.75 Ib
0.75 Ib
0.75 Ib
0.75 Ib
0.75 Ib
Maximum it Applications per
Year
Maximum Yearly Rate
14 day(s) preforage interval (animals being finished for slaughte:
14 day(s) pregrazing interval (meat animals being finished for
slaughter).
7 day(s) preforage interval (animals being finished for slaughter^
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
2
2
2
l.Slb
l.Slb
l.Slb
l.Slb
l.Slb
l.Slb
107
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Isooctyl ester
Chemigation/Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer/Sprinkler irrigation
Low volume spray (concentrate)/Spray
Aircraft/Boom Sprayer
Rotational/plant back crop restriction. Geographic allowable:
MT ND SD
Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer
Internode elongation
Postharvest
vTN
Tillering
0.5 Ib
0.5 Ib
0.5 Ib
Maximum # Applications per
Year
Maximum Yearly Rate
45 day(s) pregrazing interval.
Buffer zone restriction.
2
2
2
1.0 Ib
1.0 Ib
1.0 Ib
108
-------
Site
Application Type

Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Maximum it Applications per
Year
Maximum Yearly Rate
2-Ethylhexyl ester
7 day(s) preforage interval (animals being finished for slaughter"
14 day(s) preforage interval (animals being finished for slaughte:
14 day(s) preforage interval (dairy animals).
14 day(s) pregrazing interval (dairy animals).
14 day(s) preharvest interval (dry hay ).
40 day(s) preharvest interval (grain)l
45 day(s) pregrazing interval.
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals)
7 day(s) pregrazing interval (dairy animals)
7 day(s) pregrazing interval ( meat animals being finished for
slaughter).
7 day(s) pregrazing interval.
7 day(s) preharvest interval (forage).
Broadcast/Chemigation/Low volume spray (concentrate)/Spo1
treatment/Spray

Aircraft/Backpack sprayer/Boom sprayer/Ground/Hand held
prayer/Low pressure ground sprayer/ Low volume ground
sprayer/Sprinkler irrigation
Postemereence
0.75 Ib
l.Slb
Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer/Low volume ground sprayer
Geographic allowable: MN, MT, ND, SD
Postharvest
0.5 Ib
1.0 Ib
109
-------
Site
Application Type
Application Equipment
Low volume spray (concentrate )/Spray treatment
Aircraft/Hand held sprayer/Low volume ground sprayer
Low volume spray (concentrate )/Spray
Aircraft/Ground
ApplicationTiming
Spring
Tillering
Max. Single Application
Rate
(AE)A
0.6844 Ib
(L)
Maximum # Applications per
Year
1
2
Maximum Yearly Rate
0.6844 Ib

OATS-LEGUME MIXTURE
Sodium Salt
Broadcast/Low volume spray (concentrate)
Aircraft/Low pressure ground sprayer
Spray
Aircraft
Early jointing
Tillering
0.50 Ib
0.25 Ib
Dimethylamine salt
Spray
Low pressure
Internode elongation
0.24585 Ib
7 days(s) preforage interval (animals being finished for slaughte:
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
14 days(s) preforage interval (animals being finished for slaught
14 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
1.0 Ib
0.50 Ib
7 day(s) preforage interval (animals being finished for slaughter^
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
0.4917 Ib
).
*)•
110
-------
Site
Application Type
Application Equipment
Spray
Aircraft/Ground
Low volume spray (conentrate)/Spray
Aircraft/Ground/Low pressure/Low pressure ground
sprayer/Sprayer
ApplicationTiming
Late tillering
Tillering
Max. Single Application
Rate
(AE)A
0.25 Ib
0.5 Ib
Maximum it Applications per
Year
2
2
Maximum Yearly Rate
0.50 Ib
1.0 Ib
PASTURES
Sodium Salt
Low volume spray (concentrate)/Spray
Aircraft/Low pressure ground sprayer
Broadcast/Spray
Aircraft/Ground/Low pressure ground sprayer
Spray
Aircraft/Ground
Broadcast/Spray
Aircraft/Ground/Low pressure ground sprayer
Established plantings
Fall
Postemergence
Spring
1.3951b
l.Slb
1.3951b
l.Slb
7 days(s) preforage interval (animals being finished for slaughte
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
1
2
1
2.79 Ib
l.Slb
2.79 Ib
l.Slb
111
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Dimethylamine Salt
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Broadcast/Spot treatment/Spray
Aircraft/Ground
Spray
Aircraft/Ground
Delayed dormant
through bloom
Established plantings
Fall
Foliar
Postemergence
Spring
l.Slb
l.Slb
l.Slb
l.Slb
l.Slb
l.Slb
Maximum it Applications per
Year
Maximum Yearly Rate
21 day(s) preharvest interval (dry hay).
21 day(s) preharvest interval (forage).
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
1
2
2
1
3.0 Ib
3.0 Ib
l.Slb
3.0 Ib
3.0 Ib
l.Slb
112
-------
Site
Application Type
Application Equipment
Broadcast/Spot treatment/Spray
Aircraft/Ground/High volume ground sprayer/Sprayer
ApplicationTiming
When needed
Max. Single Application
Rate
(AE)A
l.Slb
2- Ethylhexyl ester
Spot treatment/Spray
Aircraft/Ground
Broadcast/Low volume spray (concentrate)/ Spray
Aircraft/Ground
Broadcast/Low volume spray (concentrate)/Spray
Aircraft/Ground
Low volume spray (concentrate)/ Spot Treatment
Aircraft/Hand held sprayer/Low volume ground sprayer
Established plantings
Fall
Spring
When needed
l.Slb
l.Slb
l.Slb
l.Slb
Maximum it Applications per
Year
2
Maximum Yearly Rate
3.0 Ib
1 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals)
7 day(s) pregrazing interval (dairy animals)
7 day(s) pregrazing interval ( meat animals being finished for
slaughter).
7 day(s) pregrazing interval.
7 day(s) prefeeding interval.
2
1
1
2
3.0 Ib
l.Slb
l.Slb
3.0 Ib
PEAS (UNSPECIFIED)
Sodium Salt
7 day(s) preforage interval (animals being finished for slaughter^
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
Geographic allowable: ID or Pacific NW States (Label verbatim)
113
-------
Site
Application Type
Application Equipment
Broadcast/Low volume spray (concentrate)/Spray
Aircraft/Ground/Low pressure ground sprayer
Spray
Aircraft/Ground
ApplicationTiming
Postemergence
Prebloom
Max. Single Application
Rate
(AE)A
0.375 Ib
0.375 Ib
Dimethylamine Salt
Spray
Aircraft/Ground
High volume spray (dilute )/Low volume spray (concentrate)/!
Aircraft/Ground
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Foliar
prafostemergence
Prebloom
Tillering
0.375 Ib
0.375 Ib
0.3469 Ib
0.25 Ib
2-Ethylhexyl ester
Maximum # Applications per
Year
2
2
Maximum Yearly Rate
0.75 Ib
0.75 Ib
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
2
0.75 Ib
0.75 Ib
0.6938 Ib
0.50 Ib
Do not allow the feeding or grazing of foliage by livestock.
Geographic allowable: Pacific NW States (Label verbatim).
114
-------
Site
Application Type

Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Maximum it Applications per
Year
Maximum Yearly Rate
Spray
Aircraft/Ground
Postemereence
0.375 Ib
0.75 Ib
RANGELAND
Sodium Salt
7 days(s) preforage interval (animals being finished for slaughte:
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
Low volume spray (concentrate)/Spray
Aircraft/Low pressure ground sprayer
Established plantings
1.3951b
2.79 Ib
Broadcast/Spray
Aircraft/Ground/Low pressure ground sprayer
Fall
l.Slb
l.Slb
Spray
Aircraft/Ground
Postemersence
1.3951b
2.79 Ib
Broadcast Spray
Aircraft/Ground/Low pressure ground sprayer
Spring
l.Slb
l.Slb
Dimethylamine Salt
21 day(s) preharvest interval (dry hay).
21 day(s) preharvest interval (forage).
7 day(s) preforage interval (animals being finished for slaughter
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
7 day(s) preslaughter interval.
115
-------
Site
Application Type
Application Equipment
Spray
Aircraft/Ground
Spray
Aircraft/Ground/Sprayer
Spray
Aircraft/Ground
Broadcast/Spot treatment/Spray
Aircraft/Ground
Spray
Aircraft/Ground/Sprayer
Broadcast/Spot treatment/Spray
Aircraft/Ground/High volume ground sprayer/Sprayer
ApplicationTiming
Delayed dormant
through bloom
Fall
Foliar
Postemergence
Spring
When needed
Max. Single Application
Rate
(AE)A
l.Slb
l.Slb
l.Slb
l.Slb
l.Slb
l.Slb
2-Ethylhexyl ester
Maximum it Applications per
Year
2
I
2
2
I
2
Maximum Yearly Rate
3.0 Ib
l.Slb
3.0 Ib
3.0 Ib
l.Slb
3.0 Ib
1 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals)
7 day(s) pregrazing interval (dairy animals)
7 day(s) pregrazing interval ( meat animals being finished for
slaughter).
7 day(s) pregrazing interval.
7 day(s) prefeeding interval..
116
-------
Site
Application Type
Application Equipment
Spot treatment/Spray
Aircraft/Ground
Broadcast/Low volume spray (concentrate)/Spray
Aircraft/Ground
Broadcast/Low volume spray (concentrate)/Spray
Aircraft/Ground
Low volume spray (concentrate)/ Spot treatment
Aircraft/Hand held sprayer/Low volume ground sprayer
ApplicationTiming
Established plantings
Fall
Spring
When Needed
Max. Single Application
Rate
(AE)A
l.Slb
l.Slb
l.Slb
l.Slb
Maximum it Applications per
Year
2
1
1
2
Maximum Yearly Rate
3.0 Ib
l.Slb
l.Slb
3.0 Ib
RYE
Sodium Salt
Broadcast
Aircraft/Low pressure ground sprayer
Broadcast
Aircraft/Ground/Low pressure ground sprayer
Early boot
Early jointing
0.75 Ib
0.75 Ib
7 days(s) preforage interval (animals being finished for slaughte
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
14 days(s) preforage interval (animals being finished for slaught
14 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
l.Slb
l.Slb
117
-------
Site
Application Type
Application Equipment
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Low pressure ground sprayer
ApplicationTiming
Postemergence
Tiller through boot
Max. Single Application
Rate
(AE)A
0.75 Ib
0.6975 Ib
Dimethylamine Salt
Spray
Aircraft/Ground
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Low pressure ground sprayer
Spray
Aircraft/Ground
Early boot
Foliar
Internode elongation
Postemergence
0.75 Ib
0.75 Ib
0.75 Ib
0.75 Ib
Maximum it Applications per
Year
2
2
Maximum Yearly Rate
l.Slb
1.3951b
14 day(s) preforage interval (animals being finished for slaughte:
14 day(s) pregrazing interval (dairy animals).
7 day(s) prefeeding interval.
7 day(s) preslaughter interval.
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
2
l.Slb
l.Slb
l.Slb
l.Slb
118
-------
Site
Application Type

Application Equipment
High volume spray (dilute )/Low volume spray (concentrate)
Aircraft/Ground/Low volume ground sprayer
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground/Low pressure ground sprayer
ApplicationTiming

Spring

Tiller through boot

Tillering

Max. Single Application
Rate
(AE)A

0.25 Ib

0.75 Ib

tsooctyl ester

Chemigation/Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer/Sprinkler irrigation
Low volume spray (concentrate )/Spray
Aircraft/Boom sprayer
Rotational/plant back crop restriction. Geographic allowable:
MT ND SD
Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer
Internode elongation

Postharvest

vTN

Tillering

0.5 Ib

Maximum # Applications per
Year

Maximum Yearly Rate

0.25 Ib

l.Slb

45 day(s) pregrazing interval.
Buffer zone restriction.
2

1.0 Ib

119
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
2-Ethylhexyl ester
Low volume spray (concentrate)/ Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground
Broadcast/Chemigationi/Low volume spray (concentrate )/Spr,
Aircraft/Boom sprayer/Ground/Low volume ground
sprayer/Sprinkler irrigation
Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer/Low volume ground sprayer
Low volume spray (concentrate)/Spray
Aircraft/Ground
Early spring
Fall
y Postemergence
Postharvest
Tillering
0.75 Ib
0.4625 Ib
0.75 Ib
0.5 Ib
0.4875 Ib
Maximum it Applications per
Year
Maximum Yearly Rate
14 day(s) preforage interval (animals being finished for slaughte:
14 day(s) preforage interval (dairy animals).
14 day(s) pregrazing interval (dairy animals).
45 day(s) pregrazing interval.
7 day(s) prefeeding interval.
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals)
7 day(s) pregrazing interval (dairy animals)
7 day(s) pregrazing interval ( meat animals being finished for
slaughter).
7 day(s) pregrazing interval.
1
1
2
2
2
0.75 Ib
0.4625 Ib
l.Slb
1.0 Ib
0.975 Ib
120
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Maximum it Applications per
Year
Maximum Yearly Rate
RYE-LEGUME MIXTURE
Sodium Salt
Broadcast/Low volume spray (concentrate)
Aircraft/Low pressure ground sprayer
Spray
Aircraft
Early jointing
Tillering
0.5 Ib
0.25 Ib
Dimethylamine Salt
Spray
Low pressure
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground/Low pressure ground sprayer/Sprayer
Internode elongation
Late tillering
Tillering
0.24585 Ib
0.25 Ib
0.5 Ib
7 days(s) preforage interval (animals being finished for slaughte:
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
14 days(s) preforage interval (animals being finished for slaught
14 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
1.0 Ib
0.50 Ib
7 day(s) preforage interval (animals being finished for slaughter^
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
0.4917 Ib
0.50 Ib
1.0 Ib
).
*)•
121
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Maximum it Applications per
Year
Maximum Yearly Rate
SMALL GRAM-LEGUME MIXTURE
Dimethylamine Salt
Spray
Low pressure ground sprayer
Tillering
0.23125 Ib
2-Ethylhexyl ester
Low volume spray (concentrate)
Aircraft/Low pressure ground sprayer
Foliar
0.24375 Ib
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
0.4625 Ib
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
0.4875 Ib
SMALL GRAINS
Dimethylamine Salt
Low volume Spray (concentrate)
Aircraft/Ground
Early spring
0.25 Ib

1
0.25 Ib
TREFOIL
Dimethylamine Salt
Spray
Aircraft/Ground
Late tillering
0.25 Ib

2
0.50 Ib
SORGHUM
122
-------
Site
Application Type
Application Equipment
ApplicationTiming
Max. Single Application
Rate
(AE)A
Sodium Salt
Broadcast
Aircraft/Low pressure ground sprayer
Spray
Aircraft/Ground
Early jointing
Postemergence
0.75 Ib
0.75 Ib
Maximum it Applications per
Year
Maximum Yearly Rate
7 days(s) preforage interval (animals being finished for slaughte:
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
l.Slb
l.Slb
TRITICALE
2-Ethylexyl ester
Chemigation/Spray
Aircraft/Ground/Sprinkler irrigation
Postemergence
0.24375 Ib
Geographic allowable: OR
2
0.46875
WHEAT
Sodium Salt
Broadcast
Aircraft/Low pressure ground sprayer
Early boot
0.75 Ib
7 days(s) preforage interval (animals being finished for slaughte
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
14 days(s) preforage interval (animals being finished for slaught
14 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
l.Slb
123
-------
Site
Application Type
Application Equipment
Broadcast
Aircraft/Ground/Low pressure ground sprayer
Spray
Aircraft/Ground
Spot treatment/Spray
Aircraft/Low pressure ground sprayer
ApplicationTiming
Early jointing
Postemergence
Tillering
Max. Single Application
Rate
(AE)A
0.75 Ib
0.75 Ib
0.75 Ib
Dimethylamine Salt
Spray
Aircraft/Ground
Low volume spray (concentrate )/Spray
Aircraft/Ground/Low pressure ground sprayer
Spray
Aircraft/Ground
Foliar
Internode elongation
Postemergence
0.75 Ib
0.75 Ib
0.75 Ib
Maximum it Applications per
Year
2
2
2
Maximum Yearly Rate
l.Slb
l.Slb
l.Slb
14 day(s) preforage interval (animals being finished for slaughte:
14 day(s) pregrazing interval (dairy animals).
7 day(s) prefeeding interval.
7 day(s) preslaughter interval.
7 day(s) preforage interval (animals being finished for slaughter^
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
l.Slb
l.Slb
l.Slb
124
-------
Site
Application Type
Application Equipment
High volume spray (dilute)/Low volume spray (concentrate )/S
treatment
Aircraft/Ground/Low volume ground sprayer
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground/Low pressure ground sprayer
Spray
Aircraft/Ground
ApplicationTiming
5ot Spring
Tiller through boot
Tillering
When needed
Max. Single Application
Rate
(AE)A
0.75 Ib
0.75 Ib
0.75 Ib
0.75 Ib
Isooctyl ester
Chemigation/Low volume spray (concentrate)/Spray
Aircraft/Boom sprayer/Sprinkler irrigation
Low volume spray (concentrate)/ Spray
Aircraft/Boom sprayer
Low volume spray (concentrate)/Spray
Tillering
Aircraft/Boom sprayer
Rotational/plant back crop restriction. Geographic allowable:
MT ND SD
Internode elongation
Postharvest
Postharvest
vTN
0.5 Ib
0.5 Ib
0.5 Ib
Maximum # Applications per
Year
1
2
2
2
45 day(s) pregrazing interval.
Buffer zone restriction.
2
2
2
Maximum Yearly Rate
0.75 Ib
l.Slb
l.Slb
l.Slb

1.0 Ib
1.0 Ib
1.0 Ib
125
-------
Site
Application Type

Application Equipment
ApplicationTiming

Max. Single Application
Rate
(AE)A

2-Ethylhexyl ester

Low volume spray (concentrate)/Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground
Broadcast/Low volume spray (concentrate)
Aircraft/Boom sprayer/Low volume ground sprayer
Early spring

Fall

Foliar

0.75 Ib

0.4625 Ib

0.39375 Ib

Maximum it Applications per
Year

Maximum Yearly Rate

7 day(s) preforage interval (animals being finished for slaughter"
14 day(s) preforage interval ( animals being finished for slaughte
14 day(s) preforage interval (dairy animals).
14 day(s) pregrazing interval ( dairy animals).
14 day(s) preharvest interval (dry hay).
40 day(s) preharvest interval (grain).
45 day(s) pregrazing interval.
60 day(s) preharvest interval.
7 day(s) prefeeding interval.
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals)
7 day(s) pregrazing interval (dairy animals)
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
7 day(s) pregrazing interval.
7 day(s) preharvest interval (forage).
1

0.75 Ib

0.4625 Ib

0.7875 Ib

126
-------
Site
Application Type
Application Equipment
Broadcast/Chemigation/Low volume spray (concentrate)/Spo1
treatment/Spray
Aircraft/Backpack sprayer/Boom sprayer/Ground/Hand held
sprayer/Low pressure ground sprayer/Low volume ground
sprayer/Sprinkler irrigation
Low volume spray (concentrate)/Spray
Aircraft/Hand held sprayer/Low volume ground sprayer
Geographic allowable: MN, MT, ND, SD
Low volume spray (concentrate)/ Spot treatment
Aircraft/Hand held sprayer/ Low volume ground sprayer
Low volume spray (concentrate)/Spray
Aircraft/Ground/Low volume ground sprayer
ApplicationTiming
Postemergence
Postharvest
Spring
Tillering
Max. Single Application
Rate
(AE)A
0.75 Ib
0.5 Ib
0.6844 Ib
0.4875 Ib
Maximum # Applications per
Year
2
2
1
2
Maximum Yearly Rate
l.Slb
1.0 Ib
0.6844 Ib
0.975 Ib
WHEAT-LEGUME MIXTURE
Sodium Salt
Broadcast/Low volume spray (concentrate)
Aircraft/Low pressure ground sprayer
Early jointing
0.5 Ib
7 days(s) preforage interval (animals being finished for slaughte:
7 days(s) pregrazing interval (meat animals being finished for
slaughter).
14 days(s) preforage interval (animals being finished for slaught
14 days(s) pregrazing interval (meat animals being finished for
slaughter).
2
1.0 Ib
127
-------
Site
Application Type
Application Equipment
Spray
Aircraft
ApplicationTiming
Tillering
Max. Single Application
Rate
(AE)A
0.25 Ib
Dimethylamine Salt
Spray
Low pressure
Spray
Aircraft/Ground
Low volume spray (concentrate)/Spray
Aircraft/Ground/Low pressure ground sprayer/Sprayer
Internode elongation
Late tillering
Tillering
0.24585 Ib
0.25 Ib
0.5 Ib
Maximum it Applications per
Year
2
Maximum Yearly Rate
1.0 Ib
7 day(s) preforage interval (animals being finished for slaughter"
7 day(s) preforage interval (dairy animals).
7 day(s) pregrazing interval (dairy animals).
7 day(s) pregrazing interval (meat animals being finished for
slaughter).
2
2
2
0.4917 Ib
0.50 Ib
1.0 Ib
128
-------
Use Site
Max. Rate
per App.
Max Rate
Unit/Area
*UG
Form
Max. #
Apps.
CC&yr
Max. App.
Rate/ CC &
yr
Min. App
Interval
(days)
Application Equipment
/Type
(Reg # Code)
MCPA Acid
Commercial/ Industrial lawns

Commercial/ Institutional/
Industrial Premises/
Equipment (outdoor)
Golf Course Turf

Household/ Domestic
Dwellings Outdoor Premises
Nonagricultural Uncultivatec
Areas/ Soils

Ornamental Lawns and Turf

1.33
.0020
1.2972
1.33
.0020
.0328
1.2972
1.33
.0020
.0328
1.33
.0020
.0343
IbA
gal IK sq.ft
*C1
IbA
IbA
gal IK sq.ft
*C1
Ib IK sq.ft
*C1
IbA
IbA
gal IK sq.ft
*C1
Ib IK sq.ft
*C1
IbA
gal IK sq.ft
*C2
Ib IK sq.ft
*C2
SC/S
SC/S
SC/S
SC/S
SC/S
G
SC/S
SC/S
SC/S
G
SC/S
SC/S
G
NS
NS
NS
2/1 yr
2/1 yr
2/1 yr
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
21
21
21
NS
NS
NS
NS
NS
NS
NS
Sprayer
//Spray (a)
Controlled droplet applicator
//Spray (b)
Sprayer
//Broadcast (a)
Sprayer
//Spray (a)
Controlled droplet applicator
//Spray (b)
Spreader
//Broadcast (c)
Sprayer
//Broadcast (a)
Sprayer
//Spray (a)
Controlled droplet applicator
//Spray (b)
Spreader
//Broadcast (c)
Sprayer
//Spray (a)
Controlled droplet applicator
//Spray (b)
Spreader
//Broadcast (c)
129
-------
Use Site

Recreation Area Lawns

Recreational Areas
Residential Lawns

Urban Areas

Max. Rate
per App.
1
1.33
.0020
.0328
.0262
1.2972
.0276
1
.0276
1
Max Rate
Unit/Area
*UG
-(L)
*C2
IbA
gal IK sq.ft
*C1
Ib IK sq.ft
*C1
Ib IK sq.ft
*C1
IbA
Ib IK sq.ft
*K1
-(L)
*K1
Ib IK sq.ft
*C2
-(L)
*C2
Form
G
sc/s
sc/s
G
G
SC/S
G
G
G
G
Max. #
Apps.
CC&yr
NS
NS
NS
NS
NS
2/1 yr
2/1 yr
2/1 yr
NS
NS
Max. App.
Rate/ CC &
yr
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Min. App
Interval
(days)
28
30
NS
NS
NS
NS
30
NS
21
21
21
30
30
Application Equipment
/Type
(Reg # Code)
Spreader
//Broadcast/ Spot treatment (d)
Sprayer
//Spray (a)
Controlled droplet applicator
//Spray (b)
Spreader
//Broadcast (c)
Spreader
//Broadcast (a)
Sprayer
//Broadcast (a)
Spreader
//Broadcast (b)
Spreader
//Spot treatment (c)
Spreader
//Broadcast (a)
Spreader
//Spot treatment (b)
Use Site/Registration Number(s) for Maximum Dosages with Reg # Codes
Commercial/ Industrial Lawns
Commercial/ Institutional/ Industrial Premises/ Equipment (Outdooi
Golf Course Turf
Household/ Domestic Dwellings Outdoor Premises
228-228(b), 228-285(a)
2217-784(a)
228-228(b), 228-285(a), 228-306(c)
2217-784(a)
130
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Use Site
Max. Rate
per App.
Max Rate
Unit/Area
*UG
Form
STonagricultural Uncultivated Areas/ Soils
Ornamental Lawns and Turf
Recreation Area Lawns
Recreational Areas
Residential Lawns
Urban Areas
Sodium Salt
Agricultural Rights-of-Way/
Fence Rows/ Hedgerows

Agricultural Uncultivated
Areas

Grasses Grown for Seed
Industrial Areas (Outdoor)

STonagricultural
Rights-of-Way/ Fence Rows
Hedgerows
3.2706
.1289
3.272
.1289
1.0902
3.094
.1289
3.094
Ib A
lb/3 gal
*C1
Ib A
lb/3 gal
*C1
Ib A
Ib A
lb/3 gal
*C1
IbA
SC/L
EC
EC
EC
SC/L
EC
EC
EC
Max. #
Apps.
CC&yr
Max. App.
Rate/ CC &
yr
Min. App
Interval
(days)
Application Equipment
/Type
(Reg # Code)
228-228(b), 228-285(a), 228-306(c)
228-228(b), 228-285(a), 538-160(d), 538-2 18(d), 538-222(d), 2217-798(d), 9198-198(c)
228-228(b), 228-285(a), 228-306(c)
228-300(a),2217-822(a)
2217-784(a), 2217-798(b,c)
2217-798(a,b)
NS
NS
NS
NS
2/1 yr
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
21
NS
NS
NS
Aircraft/ Ground
//Spray (a)
Low pressure ground sprayer
//Spot treatment (b)
Aircraft/ Low pressure ground
sprayer
//Broadcast/ Spot treatment (a)
Low pressure ground sprayer
//Spot treatment (b)
Aircraft/ Ground
//Broadcast (a)
Aircraft/ Low pressure ground
sprayer
//Low volume spray
(concentrate) (a)
Low pressure ground sprayer
//Spot treatment (b)
Aircraft/ Low pressure ground
sprayer
//Low volume spray
(concentrate) (a)
131
-------
Use Site

STonagricultural Uncultivatec
Areas/ Soils

Ornamental Lawns and Turf

Ornamental Sod Farm (Turf)

Max. Rate
per App.
.1289
3.272
.1289
1.636
.0341
1.5
.0341
Max Rate
Unit/Area
*UG
lb/3 gal
*C1
Ib A
lb/3 gal
*C1
Ib A
Ib IK sq.ft
*C2
IbA
Ib IK sq.ft
*C1
Form
EC
EC
EC
EC
SC/L
SC/L
SC/L
Max. #
Apps.
CC&yr
NS
NS
NS
NS
NS
2/1 yr
2/1 yr
Max. App.
Rate/ CC &
yr
NS
NS
NS
NS
NS
NS
NS
Min. App
Interval
(days)
NS
NS
NS
NS
NS
21
21
Application Equipment
/Type
(Reg # Code)
Low pressure ground sprayer
//Spot treatment (b)
Aircraft/ Low pressure ground
sprayer
//Broadcast/ Spot treatment (a)
Low pressure ground sprayer
//Spot treatment (b)
Aircraft/ Low pressure ground
sprayer
//Broadcast (a)
Ground
//Spot treatment (b)
Aircraft/ Ground
//Broadcast (a)
Ground
//Spot treatment (b)
Use Site/Registration Number(s) for Maximum Dosages with Reg # Codes
Agricultural Rights-of-Way/ Fence Rows/ Hedgerows
Agricultural Uncultivated Areas
Grasses Grown for Seed
Industrial Areas (Outdoor)
STonagricultural Rights-of-Way/ Fence Rows/ Hedgerows
STonagricultural Uncultivated Areas/ Soils
Ornamental Lawns and Turf
Ornamental Sod Farm (Turf)
42750-24(b), 62719-58(a)
5905-5 10(a),42750-24(b)
62719-58(a)
42750-24(a,b)
42750-24(a,b)
5905-5 10(a),42750-24(b)
5905-510(a), 62719-58(b)
62719-58(a,b)
Dimethylamine Salt
132
-------
Use Site

Agricultural Fallow/ Idleland

Agricultural Rights-of-Way/
Fence Rows/ Hedgerows

Agricultural Uncultivated
Areas

Airports/ Landing Fields

Commercial/ Industrial Lawn

Drainage Systems

Max. Rate
per App.
3.6801

2.441

.1533

3.673

.1530

3.673

.1530

3.406

.1419

11816

.0350

3.406

.0788

Max Rate
Unit/Area
*UG
Ib A

lb/.5 gal
*C1
lb/3 gal
*C1
Ib A

lb/3 gal
*C1
IbA

Ib IK sq.ft
*C1
IbA

Ib IK sq.ft
*F1
Form

SC/L

Max. #
Apps.
CC&yr
NS

Max. App.
Rate/ CC &
yr
NS

3 Ib (L)/cc

.3633 Ib/cc

Min. App
Interval
(days)
NS

Application Equipment
/Type
(Reg # Code)
Aircraft/ Ground
//Spray (a)
Ground
//Spot treatment (b)
Ground
//Spot treatment (c)
Ground
//Spray (a)
Ground
//Spot treatment (b)
Ground
//Spray (a)
Ground
//Spot treatment (b)
Aircraft/ Ground
//Spray (a)
Ground
//Spot treatment (b)
Hose-end sprayer/ Knapsack
sprayer/ Pump-up sprayer
//Spray (a)
Ground
//Spray (b)
Aircraft/ Ground
//Spray (a)
Sprayer
//Spray (b)
133
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Use Site

Forest Plantings
(Reforestation Programs)(Tr<;
Farms, Tree Plantations, etc.;
Forest Trees (All or
Unspecified)
Golf Course Turf

Grasses Grown for Seed
Household/ Domestic
Dwellings Outdoor Premises
Nonagricultural
Rights-of-Way/ Fence Rows
Max. Rate
per App.
.0034
.1419
4.913
1.426
.8764
.1816
1.5
.0400
.1538
1.5
.0088 Ib IK s
*K1
.1816
Max Rate
Unit/Area
*UG
M234375
gal
*F1
lb/3 gal
*F1
Ib A
IbA
Ib A
IbA
IbA
Ib IK sq.ft
*C1
lb/3 gal
*C1
IbA
PENS
IbA
Form
EC
SC/L
SC/L
SC/L
SC/L
SC/L
EC
SC/L
EC
SC/L
NS21
SC/L
Max. #
Apps.
CC&yr
2/1 yr
NS
NS
NS
2/1 yr
2/1 yr
2/1 yr
2/1 yr
2/1 yr
2/1 yr
Hose-end
sprayer/
Sprayer
//Broadcast
(a)
NS
Max. App.
Rate/ CC &
yr
NS
NS
4.913 Ib/cc
NS
NS
.3633 Ib/cc
NS
NS
NS
NS

.3633 Ib/cc
Min. App
Interval
(days)
21
NS
NS
NS
21
10
21
21
21
21

10
Application Equipment
/Type
(Reg # Code)
Trigger spray bottle
//Spot treatment (c)
Ground
//Spot treatment (d)
Aircraft/ Ground/ High volume
ground sprayer
//Broadcast/ Spot treatment (a)
Ground
//Spray (a)
Sprayer
//Spray (a)
Hose-end sprayer/ Knapsack
sprayer/ Pump-up sprayer
//Spray (b)
Ground
//Broadcast/ Spray (c)
Controlled droplet applicator
//Spray (d)
Ground
//Spot treatment (e)
Aircraft/ Ground
//Spray (a)

Hose-end sprayer/ Knapsack
sprayer/ Pump-up sprayer
134
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Use Site
Hedgerows

STonagricultural Uncultivatec
Areas/ Soils

Max. Rate
per App.

4.913
3.6801
.3194
.0485
2.441
.1816
4.913
3.6801
.3194
.0034
.0485
2.441
Max Rate
Unit/Area
*UG

IbA
IbA
Ib IK sq.ft
*C2
lb/1 gal
*C2
lb/3 gal
*C1
IbA
IbA
IbA
Ib IK sq.ft
*C1
M234375
gal
*C1
lb/1 gal
*C1
lb/3 gal
*C1
Form

SC/L
EC
SC/L
SC/L
SC/L
EC
SC/L
SC/L
EC
SC/L
EC
SC/L
EC
Max. #
Apps.
CC&yr

NS
NS
NS
NS
NS
NS
NS
NS
NS
2/1 yr
NS
NS
Max. App.
Rate/ CC &
yr

4.913 Ib/cc
NS
NS
NS
NS
.3633 Ib/cc
4.913 Ib/cc
NS
NS
NS
NS
3 Ib (L)/cc
Min. App
Interval
(days)

NS
NS
NS
NS
NS
10
NS
NS
NS
21
NS
NS
Application Equipment
/Type
(Reg # Code)
//Spray (a)
Aircraft/ Ground/ High volume
ground sprayer
//Broadcast/ Spot treatment (b)
Aircraft/ Ground/ Sprayer
//Spray (c)
Sprayer
//Spray (d)
Tank-type sprayer
//Spot treatment (e)
Ground
//Spot treatment (f)
Hose-end sprayer/ Knapsack
sprayer/ Pump-up sprayer
//Spray (a)
Aircraft/ Ground/ High volume
ground sprayer
//Broadcast/ Spot treatment (b)
Aircraft/ Ground
//Spray (c)
Sprayer
//Spray (d)
Trigger spray bottle
//Spot treatment (e)
Tank-type sprayer
//Spot treatment (f)
Ground
//Spot treatment (g)
135
-------
Use Site

Ornamental Lawns and Turf

Max. Rate
per App.
2.441
1.753
.1816
2.461
.0300
.6533
.0520
.0013
.0034
.0169
8.250E-04
.0126
Max Rate
Unit/Area
*UG
lb/3 gal
*C1
Ib A
IbA
Ib A
Ib IK sq.ft
*C2
Ib IK sq.ft
*C2
Ib IK sq.ft
*C2
M234375
gal
*C2
M234375
gal
*C2
Vol. 25 gal
*C2
Vol.25 gal
*C2
lb/.5 gal
Form
EC
SC/L
SC/L
EC
RTU
G
G
RTU
ECNS
EC
SC/L
SC/L
Max. #
Apps.
CC&yr
NS
2/1 yr
NS
NS
2/cc
2/1 yr
NS
2/cc
NS21
2/cc
NS
NS
Max. App.
Rate/ CC &
yr
NS
NS
.3633 Ib/cc
NS
NS
NS
NS
NS
Sprayer
//Spot
treatment
(h)
NS
NS
NS
Min. App
Interval
(days)
NS
NS
10
NS
30
30
30
21

28
NS
NS
Application Equipment
/Type
(Reg # Code)
Ground
//Spot treatment (h)
Atomizing type sprayer/
Spinning-disc sprayer/ Sprayer
//Low volume spray
(concentrate)/ Spray (a)
Hose-end sprayer/ Knapsack
sprayer/ Pump-up sprayer
//Spray (b)
Ground
//Broadcast/ Spray (c)
Hose-end sprayer
//Spray (d)
Spreader
//Broadcast (e)
Spreader
//Broadcast (f)
Trigger spray bottle
//Spot treatment (g)

Sprayer
//Spot treatment (i)
Ground
//Spot treatment (j)
Sprayer
136
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Use Site

Ornamental Sod Farm (Turf)

Max. Rate
per App.

.0274

.1538

3.2

1.5

.1816

1.5

.0398

.0383

Max Rate
Unit/Area
*UG
*C2
lb/1 gal
*C2
lb/3 gal
*C1
-(L)
*C2

-(L)
*C2

fl.oz IK sq.ft
(L)
*C2
IbA

IbA

Ib IK sq.ft
*C1
Ib IK sq.ft
*C1
Form

SC/L

PRL
RTU

RTU
SC/L

SC/L

Max. #
Apps.
CC&yr

2/1 yr

2/cc

2/1 yr

Max. App.
Rate/ CC &
yr

.3633 Ib/cc

Min. App
Interval
(days)

14
AN
NS
NS

Application Equipment
/Type
(Reg # Code)
//Spot treatment (k)
Sprayer
//Spot treatment (1)
Ground
//Spot treatment (m)
Aerosol can/ Trigger spray
bottle
//Spot treatment (n)
Product container/ Sprayer/
Trigger spray bottle
//Spot treatment/ Spray (o)
Hose-end sprayer
//Broadcast (p)

Atomizing type sprayer/
Spinning-disc sprayer/ Sprayer
//Low volume spray
(concentrate)/ Spray (a)
Hose-end sprayer/ Knapsack
sprayer/ Pump-up sprayer
//Spray (b)
Ground
//Spray (c)
Controlled droplet applicator
//Spray (d)
Sprayer
//Spot treatment (e)
137
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Use Site

Paved Areas (Private Roads/
Sidewalks)

Recreation Area Lawns

Recreational Areas

Residential Lawns
Max. Rate
per App.
.0274
3.406
.1419
.1816
1.72
.0391
.1816
1.76
.0400
.0126
.1816
Max Rate
Unit/Area
*UG
lb/1 gal
*C1
IbA
lb/3 gal
*C2
IbA
IbA
Ib IK sq.ft
*C1
IbA
IbA
Ib IK sq.ft
*C1
lb/.5 gal
*C1
IbA
Form
SC/L
SC/L
SC/L
SC/L
SC/L
SC/L
SC/L
SC/L
SC/L
SC/L
SC/L
Max. #
Apps.
CC&yr
2/1 yr
NS
NS
NS
NS
NS
NS
NS
NS
NS
2/1 yr
Max. App.
Rate/ CC &
yr
NS
NS
NS
.3633 Ib/cc
NS
NS
.3633 Ib/cc
NS
NS
NS
.3633 Ib/cc
Min. App
Interval
(days)
21
NS
NS
10
NS
NS
10
NS
NS
NS
10
Application Equipment
/Type
(Reg # Code)
Sprayer
//Spot treatment (f)
Aircraft/ Ground
//Spray (a)
Ground
//Spot treatment (b)
Hose-end sprayer/ Knapsack
sprayer/ Pump-up sprayer
//Spray (a)
Atomizing type sprayer/
Spinning-disc sprayer/ Sprayer
//Low volume spray
(concentrate)/ Spray (b)
Controlled droplet applicator
//Spray (c)
Hose-end sprayer/ Knapsack
sprayer/ Pump-up sprayer
//Spray (a)
Spinning-disc sprayer/ Spoon
//Spray (b)
Controlled droplet applicator
//Spray (c)
Sprayer
//Spot treatment (d)
Hose-end sprayer/ Knapsack
sprayer/ Pump-up sprayer
//Spray (a)
138
-------
Use Site

Shelterbelt Plantings

Urban Areas

Max. Rate
per App.
.0166
.0316
.0126
1
3.673
.1530
.0335
.0126
Max Rate
Unit/Area
*UG
Ib IK sq.ft
*K1
Ib IK sq.ft
*K1
lb/.5 gal
*K1
-(L)
*K1
IbA
lb/3 gal
*J1
Ib IK sq.ft
*C2
lb/.5 gal
*C1
Form
SC/L
SC/L
SC/L
RTU
SC/L
SC/L
SC/L
SC/L
Max. #
Apps.
CC&yr
2/cc
2/1 yr
2/1 yr
2/1 yr
NS
NS
NS
NS
Max. App.
Rate/ CC &
yr
NS
NS
NS
NS
NS
NS
NS
NS
Min. App
Interval
(days)
14
21
21
14
NS
NS
NS
NS
Application Equipment
/Type
(Reg # Code)
Backpack sprayer/ Knapsack
sprayer/ Pump-up sprayer
//Broadcast (b)
Pressure sprayer/ Tank-type
sprayer
//Spray (c)
Sprayer
//Spot treatment (d)
Trigger spray bottle
//Spot treatment (e)
Ground
//Spray (a)
Ground
//Spot treatment (b)
Hose-end sprayer
//Spray (a)
Sprayer
//Spot treatment (b)
139
-------
Use Site Max. Rate Max Rate Form
perApp. Unit/Area
*UG
Max. # Max. App. Min. App Application Equipment
Apps. Rate/CC& Interval /Type
CC&yr yr (days) (Reg # Code)
Use Site/Registration Number(s) for Maximum Dosages with Reg # Codes
Agricultural Fallow/ Idleland
Agricultural Rights-of-Way/ Fence Rows/ Hedgerows
Agricultural Uncultivated Areas
Airports/ Landing Fields
Commercial/ Industrial Lawns
Drainage Systems
Forest Plantings (Reforestation Programs)(Tree Farms, Tree Planta
etc.)
Forest Trees (All or Unspecified)
Golf Course Turf
Grasses Grown for Seed
Household/ Domestic Dwellings Outdoor Premises
STonagricultural Rights-of-Way/ Fence Rows/ Hedgerows
STonagricultural Uncultivated Areas/ Soils
Ornamental Lawns and Turf
Ornamental Sod Farm (Turf)
Paved Areas (Private Roads/ Sidewalks)
Recreation Area Lawns
Recreational Areas
Residential Lawns
Shelterbelt Plantings
Urban Areas
228-290(b), 1386-587(a,c)
62719-13(a,b)
6271 9-1 3(a,b)
1381-104(a,b)
2217-729(b), 7969-78(a)
228-271(b,c), 1381-104(a,d)
iaa§,-296(a)
228-143(a)
228-313(d), 228-371(a), 2217-362(c,e), 7969-78(b)
228-143(a)
2217-785(a)
228-206(d,e), 228-290(f), 228-296(b), 1386-587(c), 5905-502(c), 7969-78(a)
228-206(d,f), 228-271(e), 228-290(g,h), 228-296(b), 1386-587(c), 7969-78(a)
228-224(n), 228-272(g), 228-276(d), 228-284(n), 228-310(h,i), 228-324(f), 228-334(o), 228-336(o),
228-349(o,p), 228-351(0), 228-353(fj, 228-371(a,l), 239-2634(o), 2217-362(c,m), 2217-732G),
2217-734(k), 2217-744(e), 2217-792(o), 7969-78(b)
228-371(a,d,f), 7969-78(b), 62719-13(c,e)
1381-104(a,b)
228-372(b,c), 7969-78(a)
228-3 13(b,c), 2217-734(d), 7969-78(a)
2217-733(b), 2217-734(c,d), 2217-792(e), 7969-78(a)
6271 9-1 3(a,b)
2217-734(b),2217-735(a)
140
-------
Use Site
Max. Rate
per App.
Max Rate
Unit/Area
*UG
Form
Max. #
Apps.
CC&yr
Max. App.
Rate/ CC &
yr
Min. App
Interval
(days)
Application Equipment
/Type
(Reg # Code)
2, Ethylhexyl Ester
agricultural fallow/idleland

agricultural
rights-of-way/fencerows/hec
rows
agricultural uncultivated are;

1.537
4.345
3
.0349
.1250
4.313
ge
1.537
4.313
.0349
Ib A
IbA
IbA
Ib IK sq.ft
*C1
lb/3 gal
*C1
IbA
IbA
IbA
Ib IK sq.ft
*C1
EC
EC
EC
EC
EC
EC
EC
EC
EC
1/cc
1/cc
NS
1/cc
NS
NS
NS
NS
NS
1.5371b/cc
NS
NS
1.5371b/cc
NS
NS
1.5371b/cc
NS
1.5371b/cc
NS
NS
NS
NS
NS
NS
NS
NS
NS
Aircraft/ Ground/ Low pressure
ground sprayer
//Broadcast/ Low volume spray
(concentrate) (a)
Aircraft/ Hand held sprayer/
Low volume ground sprayer
//Low volume spray
(concentrate)/ Spot
treatment (b)
Aircraft/ Ground
//Spray (c)
Backpack sprayer/ Hand held
sprayer
//Spot treatment (d)
Ground
//Spot treatment (e)
Aircraft/ Ground
//Spray (a)
Low pressure ground sprayer
//Broadcast (a)
Aircraft/ Ground
//Spray (b)
Backpack sprayer/ Hand held
sprayer
141
-------
Use Site

airports/landing fields

commercial/industrial lawns

commercial/institutional/indi
rial premises/equipment
(outdoor)

forest trees (all or unspecifiei
golf course turf
Max. Rate
per App.

1.6575
.0380
1.6575
2.686
.0380
.0313
it6575
.0380
^.Olll
1.5
Max Rate
Unit/Area
*UG

Ib A
Ib IK sq.ft
*C1
IbA
Ib A
Ib IK sq.ft
*C1
Ib IK sq.ft
*C1
IbA
Ib IK sq.ft
*C1
IbA
IbA
Form

EC
EC
EC
EC
EC
EC
EC
EC
EC
EC
Max. #
Apps.
CC&yr

2/1 yr
2/1 yr
2/1 yr
NS
2/1 yr
NS
2/1 yr
2/1 yr
NS
2/1 yr
Max. App.
Rate/ CC &
yr

NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Min. App
Interval
(days)

14
14
14
NS
14
AN
14
14
NS
14
Application Equipment
/Type
(Reg # Code)
//Spot treatment (c)
Boom sprayer
//Broadcast (a)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Spot treatment (b)
Backpack sprayer
//Broadcast (a)
Sprayer
//Broadcast/ Spot treatment (b)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Spot treatment (c)
Hand held sprayer
//Spot treatment (d)
Boom sprayer
//Broadcast (a)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Spot treatment (b)
Aircraft/ Ground
//Low volume spray
(concentrate)/ Spray (a)
Backpack sprayer
142
-------
Use Site

grasses grown for seed

lousehold/domestic dwellirij
outdoor premises

Max. Rate
per App.

1.5
.0380
.0360
.7735
1.5
1.5
i.6575
.0380
Max Rate
Unit/Area
*UG

Ib A
Ib IK sq.ft
*C1
Ib IK sq.ft
*C1
Ib A
Ib A
Ib A
IbA
Ib IK sq.ft
*K1
Form

EC
EC
G
EC
EC
EC
EC
EC
Max. #
Apps.
CC&yr

NS
2/1 yr
NS
NS
NS
NS
2/1 yr
2/1 yr
Max. App.
Rate/ CC &
yr

NS
NS
NS
.7735 Ib/cc
1.601 Ib/cc
NS
NS
NS
Min. App
Interval
(days)

NS
14
30
NS
AN
NS
NS
14
Application Equipment
/Type
(Reg # Code)
//Broadcast (a)
Sprayer
//Broadcast/ Spot treatment (b)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Spot treatment (c)
Spreader
//Broadcast (d)
Aircraft/ Boom sprayer/ Low
volume ground sprayer/
Sprinkler irrigation
//Chemigation/ Low volume
spray (concentrate)/ Spray (a)
Aircraft/ Hand held sprayer/
Low volume ground sprayer
//Low volume spray
(concentrate)/ Spot
treatment (b)
Aircraft/ Ground
//Spray (c)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Broadcast (a)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Spot treatment (b)
143
-------
Use Site
nonagricultural
rights-of-way/fencerows/hec
rows

nonagricultural uncultivated
areas/soils

Max. Rate
per App.
4.359
ge
1.6575
4.388
.0380
.0823
.0256
.3584
.7500
3.659
4.313
Max Rate
Unit/Area
*UG
IbA
Ib A
IbA
Ib IK sq.ft
*C2
Ib IK sq.ft
*C1
lb/1 gal
*C1
lb/3 gal
*C1
gal(L)
*C1
IbA
IbA
Form
EC
EC
EC
EC
EC
EC
EC
EC
EC
EC
Max. #
Apps.
CC&yr
2/cc
2/1 yr
NS
2/1 yr
NS
NS
NS
NS
1/cc
2/cc
Max. App.
Rate/ CC &
yr
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Min. App
Interval
(days)
AN
14
AN
14
NS
NS
AN
NS
NS
AN
Application Equipment
/Type
(Reg # Code)
Aircraft/ Ground
//Spray (a)
Boom sprayer
//Broadcast (b)
Aircraft/ Ground
//Spray (c)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Spot treatment (d)
Sprayer
//Spray (e)
Tank-type sprayer
//Spot treatment (f)
Ground
//Spot treatment (g)
Ground
//Spot treatment/ Spray (h)
Aircraft/ Hand held sprayer/
Low volume ground sprayer
//Low volume spray
(concentrate)/ Spot
treatment (a)
Aircraft/ Ground
//Spray (b)
144
-------
Use Site

ornamental lawns and turf

ornamental sod farm (turf)

Max. Rate
per App.
4.388
.0823
.0256
4.332
.7500
1.6575
2.686
.0380
.0313
1.6575
.5000
Max Rate
Unit/Area
*UG
IbA
Ib IK sq.ft
*C1
lb/1 gal
*C1
lb/3 gal
*C1
gal(L)
*C1
IbA
IbA
Ib IK sq.ft
*C2
Ib IK sq.ft
*C1
IbA
IbA
Form
EC
EC
EC
EC
ECNS
EC
EC
EC
EC
EC
EC
Max. #
Apps.
CC&yr
NS
NS
NS
NS
NSNS
2/1 yr
NS
2/1 yr
NS
2/1 yr
NS
Max. App.
Rate/ CC &
yr
NS
NS
NS
NS
Ground
//Spot
treatment
(g)
NS
NS
NS
NS
NS
.5 Ib/cc
Min. App
Interval
(days)
AN
NS
NS
NS

14
NS
14
AN
14
NS
Application Equipment
/Type
(Reg # Code)
Aircraft/ Ground
//Spray (c)
Sprayer
//Spray (d)
Tank-type sprayer
//Spot treatment (e)
Ground
//Spot treatment (f)

Backpack sprayer
//Broadcast (a)
Sprayer
//Broadcast/ Spot treatment (b)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Spot treatment (c)
Hand held sprayer
//Spot treatment (d)
Backpack sprayer
//Broadcast (a)
Aircraft/ Ground/ Sprinkler
145
-------
Use Site

recreation area lawns

recreational areas

Max. Rate
per App.

1.5
.0380
.0313
2.686
.0360
1.6575
1.093
.0380
.0256
Max Rate
Unit/Area
*UG

IbA
Ib IK sq.ft
*C1
Ib IK sq.ft
*C1
IbA
Ib IK sq.ft
*C1
IbA
IbA
Ib IK sq.ft
*C1
Ib IK sq.ft
*C1
Form

EC
EC
EC
EC
GNS
EC
EC
EC
EC
Max. #
Apps.
CC&yr

NS
2/1 yr
NS
NS
NS30
2/1 yr
NS
2/1 yr
NS
Max. App.
Rate/ CC &
yr

NS
NS
NS
NS
Spreader
//Broadcast
(b)
NS
NS
NS
NS
Min. App
Interval
(days)

AN
14
AN
NS

14
NS
14
NS
Application Equipment
/Type
(Reg # Code)
irrigation
//Chemigation/ Spray (b)
Aircraft/ Ground
//Broadcast/ Spray (c)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Spot treatment (d)
Hand held sprayer
//Spot treatment (e)
Sprayer
//Broadcast/ Spot treatment (a)

Boom sprayer
//Broadcast (a)
Sprayer
//Spray (b)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Spot treatment (c)
Low volume sprayer
//Low volume spray
(concentrate) (d)
146
-------
Use Site
residential lawns

urban areas

Max. Rate
per App.
2.686
.0360
1.6575
.0380
Max Rate
Unit/Area
*UG
IbA
Ib IK sq.ft
*K1
IbA
Ib IK sq.ft
*C2
Form
EC
G
EC
EC
Max. #
Apps.
CC&yr
NS
NS
2/1 yr
2/1 yr
Max. App.
Rate/ CC &
yr
NS
NS
NS
NS
Min. App
Interval
(days)
NS
30
14
14
Application Equipment
/Type
(Reg # Code)
Sprayer
//Broadcast/ Spot treatment (a)
Spreader
//Broadcast (b)
Boom sprayer
//Broadcast (a)
Backpack sprayer/ Compression
sprayer/ Knapsack sprayer
//Spot treatment (b)
Use Site/Registration Number(s) for Maximum Dosages with Reg # Codes
agricultural fallow/idleland
agricultural rights-of-way/fencerows/hedgerows
agricultural uncultivated areas
airports/landing fields
commercial/industrial lawns
commercial/institutional/industrial premises/equipment (outdoor)
forest trees (all or unspecified)
golf course turf
grasses grown for seed
lousehold/domestic dwellings outdoor premises
nonagricultural rights -of-way/fencerows/hedgerows
5905-506(c,e), 62719-86(b), 62719-307(a,d)
11685-21(a)
11685-21(b), 62719-307(a,c)
2217-834(a,b)
2217-803(b), 2217-834(a,c), 62719-59(d)
2217-834(a,b)
228-267(a)
228-203(d), 2217-803(b), 2217-834(a,c)
228-267(c), 51036-254(a), 62719-86(b)
2217-834(a,b)
228-205(f), 228-317(e), 1381-98(g), 2217-834(b,d), 9779-265(h), 42750-23(h), 42750-25(h),
71368-16(a), 71368- 17(c)
147
-------
Use Site
Max. Rate
per App.
Max Rate
Unit/Area
*UG
Form
Max. #
Apps.
CC&yr
Max. App.
Rate/ CC &
yr
Min. App
Interval
(days)
Application Equipment
/Type
(Reg # Code)
nonagricultural uncultivated areas/soils
228-205(e), 228-317(d), 11685-21(b), 42750-23(f,g), 42750-25(g), 62719-86(a), 71368-17(c)
ornamental lawns and turf
2217-803(b), 2217-834(a,c), 62719-59(d)
ornamental sod farm (turf)
264-690(b), 2217-834(a,d), 62719-59(c,e)
recreation area lawns
228-203(b), 2217-803(a)
recreational areas
228-205(b,d), 2217-834(a,c)
residential lawns
228-203(b), 2217-803(a)
urban areas
2217-834(a,b)
HEADER ABBREVIATIONS
Use Site

Max.Rate per App
Max.Rate Unit/Area
*UG
Form
Max. # Apps cc & yr
Max. App Rate/cc & yr

Min. App Interval (days)
Application Equipment
Application Type
Current as of -
The use site refers to the entity (crop, building, surface or article) where a
pesticide is applied and/or which is being protected.
Maximum dose for a single application to a single site. System calculated.
Units and Area associated with the maximum dose.
Use Group codes.
The physical form of the end use product found in the container.
The maximum number of applications.
The maximum amount of pesticide product that can be applied to a site in one
growing season (/cc) or during the span of one year (/yr).
The minimum retreatment interval between applications in days (aggregated).
The equipment used to apply pesticide (aggregated).
The type of pesticide application (aggregated).
The label data for the listed products in this report is current as of this date
ABBREVI AT IONS
- The dosage information provided is from the label in terms of product (e.g., ounces, gallons, or
pounds of the product) because there was insufficient information (e.g., missing density, area, c
active ingredient percentages) to provide converted dosage information.
- The tilde in "Max. Rate per App" indicates a dosage that includes information from a SLN label.
148
-------
APPLICATION RATE
W
PPM calculated by weight
PPM calculated by volume
Unknown whether PPM is given by weight or by volume
Hundred Weight.
nn times (10 power -xx), for instance, "1.234E-4" is equivalent to ".0001234".
No description available in LUIS unit conversion vocabulary.
The dosage information includes a contribution from one or more (TQ, CL, BR, I)
active ingredients.
FORMULATION CODES
G : Granular
SC/S : Soluble Concentrate/solid

USE GROUP CODES
Cl : TERRESTRIAL NON-FOOD CROP
C2 : TERRESTRIAL NON-FOOD+OUTDOOR RESIDENTIAL
Kl : OUTDOOR RESIDENTIAL
149
-------
Appendix B
Data Supporting Guideline Requirements for the Reregistration of MCPA
REQUIREMENT
Use Patterns
CITATION(S)
PRODUCT CHEMISTRY
New Guideline
Number
830.1550
830.1600
830.1620

830.1700
830.1750
830.1800

Old
Guideline
Number
61-1
61-2A
61-2B
61-3
62-1
62-2
62-3
63-0

Product Identity and Composition
Description of materials used to
produce the product
Description of production process
Discussion of Formation of Impurities
Preliminary Analysis
Certification of limits
Analytical Method
Reports of Multiple Phys/Chem
Characteristics

A,B, C,K
A,B, C,K

A,B, C,K
A,B, C,K
A,B, C,K

44645801, 44914027, 43129310, 44484501, 4448502,
43227201, 4322702, 4322703, 4422706, 44401301, 44645801,
42377401, 42577601, 43986101, 44463901, 40470101,
41193401, 42079401, 44645801, 45084401, 44914027,
43129310
44639901, 44394401, 42386401, 42577601, 43986101,
158077, 42377401, 45804402, 4504403
42079401,42386401
45804404
44639901, 45804405, 45804406, 42386402, 42377410,
42450901, 42657101, 44394401, 42079402, 42577602,
43986102, 40470101, 44639901
44645802, 42377401, 42377402, 42377403, 43986102,
42377405, 42377409, 42450901, 42079403, 40470101,
44401301,42377410
43227203, 42377404, 42377406, 42377407, 42377408,
42577608, 43986102, 44259401, 40470101, 42079403,
42377405,44463901
44484504, 4484503, 4322702, 43227206, 53734
150
-------
Appendix B
Data Supporting Guideline Requirements for the Reregistration of MCPA
REQUIREMENT
830.6302
830.6303
830.6304
830.6313
830.700
830.6317
830.6320
830.7200
830.7300
830.7550
830.6314
830.7840
830.7950
63-2
63-3
63-4
63-13
63-12
63-17
63-20
63-5
63-7
63-11
63-14
63-8
63-9
Color
Physical State
Odor
Stability to normal and elevated
temperatures, metals, and metal ions
PH
Storage Stability
Corrosion Characteristics
Melting Point
Density
Partition coefficient, shake flask
method
Oxidation or reducing action
Solubility
Vapor Pressure
Use Patterns
A, B, C,K
A,B, C,K
A,B, C,K
A,B, C,K
A,B, C,K

A, B, C,K
A,B, C,K
A,B, C,K

A, B, C,K
A, B, C,K
CITATION(S)
42450903, 42450902, 44861801
42450904
42757301
42450907,42757301
42450907
42638601, 45173401, 44484505, 444806, 45480901
44861801, 44929001, 44535802
42450905
42450906
40470101,40471801
44535801
40471802
40471803
ECOLOGICAL EFFECTS
850.2100
850.2200
71-1A
71-2A
Avian Acute Oral Toxicity
Avian Dietary Toxicity - Quail
A,B, C,K
A,B, C,K
40019201
40555803,4055802,
Data Gap ( MCPA EHE)
151
-------
Appendix B
Data Supporting Guideline Requirements for the Reregistration of MCPA
REQUIREMENT
850.1075
850.1010
850.1075
850.1300
850.4225
850.4250
850.5400
850.4225
850.4400
850.3020
72-1A
72-2A
72-3A
72-4A
122-1A
122-1B
122-2
123-1A
123-2
141-1
Fish Toxicity Bluegill
Invertebrate Toxicity
Estuarine/Marine Toxicity - Fish
Fish Early Life Stage - Daphnid
Terrestrial Plant Toxicity, Seedling
Emergence (Tier 11)
Terrestrial Plant Toxicity, Vegetative
Vigor (Tier II)
Aquatic Plant Growth
Seedling Germination and Seedling
Emergence
Aquatic Plant Growth
Honey Bee Acute Contact
Use Patterns
A,B, C,K
A,B, C,K
A,B, C,K
A,B, C,K
A,B, C,K
A,B, C,K
A,B, C,K
A,B, C,K
A,B, C,K
A,B, C,K
CITATION(S)
40062004, 42624402, 41800904, 40062005, 41800901,
41800902, 41800905, 41800901, 41800902, 41800903
41800906,42412201
43083210, 40062006, 43086501
44407202,44407201
43083205, 46148, 43083205, Data Gap (MCPA Acid, DMAS,
EHE)
Data Gap (MCPA Acid, DMAS, EHE)
43126502, 42461301, 45554403, 43083207, 43083212,
43083213, 43083214, 43083206, 43083207, 43083208,
45503801,43083211
42698701, 42669304, 43788201, 43257901
44903501, 44903502, 44903504, 44903503, 45312207,
44903505 Data Gap (MCPA Acid, DMAS, EHE)
42197801, 42150301, 42197801
TOXICOLOGY
870.1100
870.1200
870.1300
870.2400
81-1
81-2
81-3
81-4
Acute Oral Toxicity-Rat
Acute Dermal Toxicity-Rabbit/Rat
Acute Inhalation Toxicity-Rat
Primary Eye Irritation-Rabbit
A,B, C,K
A, B, C,K
A,B, C,K
A, B, C,K
21972(250090), (248567), 1156458
156459
40053101,42113103,156460
156522
152
-------
Appendix B
Data Supporting Guideline Requirements for the Reregistration of MCPA
REQUIREMENT
870.2600
870.6200
870.6300
870.3100
870.3200
870.3465
870.6200
870.4100
870.3700
870.3700
870.3800
870.5100
870.5375
870.7485
870.7600
870.7200
81-6
81-8
83-6
82-1A
82-2
82-4
82-7
83-1B
83-3A
83-3B
83-4
84-2
84-2B
85-1
85-3
86-1
Dermal Sensitization
Acute Neurotoxicity Screen Study
Developmental Neurotoxicity Study
Subchronic Oral Toxicity: 90-Day
Study Rodent
21-Day Dermal - Rabbit/Rat
90-Day Inhalation-Rat (28-Day
abbreviated 90-day protocol)
Subchronic Neurotoxicity
Chronic Feeding Toxicity - Non-
Rodent
Developmental Toxicity - Rat
Developmental Toxicity - Rabbit
2-Generation Reproduction - Rat
Bacterial Reverse Gene Mutation
Cytogenetics
General Metabolism
Dermal Penetration and Absorption
Domestic Animal Safety
Use Patterns
A, B, C,K
A, B, C,K
A,B, C,K
A,B, C,K
A, B, C,K
A, B, C,K
A,B, C,K
A,B, C,K
A,B, C,K
A, B, C,K
A,B, C,K
A, B, C,K
A,B, C,K
A,B, C,K
A,B, C,K
A, B, C,K
CITATION(S)
43062806, 40352101, 41613003, 43556801
43562602, 43556702
Data Gap (MCPA EHE)
43562601, 165470, 165471,61368, 106595,43556802,
43556801, 43556701, 43556801
42715001
Data Gap (MCPA Acid)
45889301,43562601
40634101,40792301,164352
42723801, 42723802, 40041701, 44954102, 44954101
42723802
40041701
42840403, 42860103, 42853504, 40027501, 42860102, 148720,
42624401, 42860101, 148720, 4287001, 42853505, 42853502,
42624401, 42860101, 42853506
40027501
43755202, 45595301, 45595302
46327601,44192701
5003259
153
-------
Appendix B
Data Supporting Guideline Requirements for the Reregistration of MCPA
REQUIREMENT
Use Patterns
CITATION(S)
OCCUPATIONAL/RESIDENTIAL EXPOSURE
875.1100
231
Estimation of Dermal Exposure,
Outdoor Sites

Data Gap (MCPA Acid)
ENVIRONMENTAL FATE
835.2120
835.2240
835.2410
835.4100
835.4400
835.4300
835.1240
835.1410
835.6100
835.6200
860.1850
161-1
161-2
161-3
162-1
162-3
162-4
163-1
163-2
164-1
164-2
165-1
Hydrolysis
Photodegradation - Water
Photodegradation - Soil
Aerobic Soil Metabolism
Anaerobic Aquatic Metabolism
Aerobic Aquatic Metabolism
Leaching/Adsorption/Desorption
Laboratory Volatilization
Terrestrial Field Dissipation
Aquatic Sediment Field Dissipation
Study
Confined Rotational Crop
A,B, C,K
A,B,C,K
A, B, C,K
A,B,C,K
A,B, C,K
A,B, C,K
A,B, C,K
A, B, C,K
A,B,C,K
A,B, C,K
A, B, C,K
42665301
42928101
43225801
41586001, Data Gap (MCPA EHE)
40461901
4055801,4 4239601, 44732401
4259603, Data Gap (MCPA EHE)
Data Gap (MCPA Acid)
42134201, 43883001, 43697501, 44026801, 42133901
Data Gap (MCPA Acid)
40961301
RESIDUE CHEMISTRY
860.1300

171-4A
17WA2
17WA3
Nature of Residue - Plants

Nature of Livestock
A, B, C,K
A,B, C,K
A,B, C,K
43575501, 41633, 53734, 43580301
5004272,00041633,43580301
43575501, 43575901, 43915401
154
-------
Appendix B
Data Supporting Guideline Requirements for the Reregistration of MCPA
REQUIREMENT
860.1300

860.1340

860.1380
860.1500
860.1540
860.1850

171-4B

171-4C

171-4E
171-4K
171-5
165-1

Nature of Residue - Livestock

Residue Analytical Method - Plants

Storage Stability - Plants
Crop Field Trials (Peas)
Anticipated Residues
Confined Accumulation inl Rotational
Crops
Use Patterns
A B C K

A,B, C,K

A,B,C,K
A,B, C,K
A,B, C,K
A,B, C,K

CITATION(S)
45288701, 43575901, 43575501, 43915401, 5575, 4724,4787,
4822,4492, 4627, 4764, 4766, 45288701, 45288701, 4449, 4766
45288712, 45288707, 45288713, 45288712, 45763101,
45288701, 4624,4625, 4491,4993, 43793901, 45288703,
45288708, 4288709, 45288705, 43756401, 45288706, 1 10363,
5567, 43718401, 43724301, 43724401, 43804601, 45288708,
45763101, 45763102, 45288709, 45288711, 45288702,
45288703, 45288705, 45288708, 45288709, 45288704,
45288712, 45763101, 45763102, 45763103, 45763104,
45763105, 45763106, 45288706 Data Gap (MCPA Acid)
Ruminant Feed Study
45288710, 45288711, 102704,4491, 4651, 4491, 4443, 4453,
4473, 78931, 4993, 4655, 4659, 25394 ,45288702, 45288703,
45288705, 45288708, 45288709, 102704, 43724301, 43826402,
43724301, 43804601, 45288712, 43764101, 45763101,
45763102, 45763103, 45763104, 45763105, 43724401,
43782401, 43826401, 43826402, 45288710, 45288711,
45763101, 45763102, 45763103, 45763104, 4576105,
45288704, 45288706, 45288710, 4528871 1, 45288713 Data
Gap (need modified method)
Data Gap (MCPA Acid)
Data Gap (MCPA Acid)
4438
40961301

155
-------
P5
* "g
a g
L- O, 2£
5 s ft
3 t/3 ft g
M -g 1 O
S 5 S M
R "
g
860.1900 165-2
Field Accumulation in Rotational Crop
Study
P
A,B, C,K
H
H
Data
Gap (MCPA Acid)
OTHER
156
-------
Appendix C. Technical Support Documents

Additional documentation in support of this RED is maintained in the OPP docket, located in
Room 119, Crystal Mall #2, 1801 South Bell Street, Arlington, VA. It is open Monday through Friday,
excluding legal holidays, from 8:30 am to 4 pm.

The docket initially contained preliminary risk assessments and related documents as of August 10,
1998. Sixty days later the first public comment period closed. The EPA then considered comments,
revised the risk assessment, and added the formal "Response to Comments" document and the revised
risk assessment to the docket on June 16, 1999.

All documents, in hard copy form, may be viewed in the OPP docket room or downloaded or
viewed via the Internet at the following site: www.epa.gov/pesticides/reregistration

These documents include:

HED Documents:
1. MCPA: Availability of Risk Assessments. 23-June-2004.
2. MCPA: Summary. 18-June-2004.
3. MCPA: Overview of Risk Assessment. 18-June-2004.
4. MCPA: Revised Human Health Risk Assessment for the RED document. 04-Jun-2004.
5. MCPA: Revised Product and Residue Chemistry Chapter for the Reregistration Eligibility
Decision. 03-Jun-2004.
6. MCPA: HED Response to Comments Submitted During 30- Day Registrant Error
Correction period. 04-Jun-2004.
7. MCPA: Revised MCPA Acute and Chronic Dietary Exposure Assessments for the
Reregistration Eligibility Document. 02-Jun-2004.
8. MCPA: Revised Occupational & Residential Exposure Risk Assessment for the
Reregistration Eligibility Document. 1 l-Jun-2004.
9. MCPA: Appendix A Standard Formula Used for Calculating Occupational & Residential
Exposures to MCPA. 08-Jun-2004.
10. MCPA: Appendix B Occupational Handler Exposure Data and Risk Calculations for
MCPA. 08-Jun-2004.
11. MCPA: Appendix C Occupational Post Application Risks of MCPA Exposures.
08-Jun-2004.
12. MCPA: Appendix D Residential Handler Exposure Data and Risk Calculations for
MCPA. 08-Jun-2004.
13. MCPA: Appendix E MCPA Turf Transferable Residue Data. 08-Jun-2004.
14. MCPA: Appendix F Residential Turf Post Application Risk Assessment for MCPA.
08-Jun-2004.
157
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15. MCPA: Corrected First Report of the Hazard Identification Assessment Review
Committee. 29-Oct-2003.
16. MCPA: Toxicology Chapter for RED. Ol-Jul-2003.
17. MCPA: Meeting Summary, August 4, 2004. 04-Aug-2004.
18. MCPA: Availability of Reregistration Eligibility Decision Document for Comment.
24-Nov-2004.
19. MCPA: RED Fact Sheet. 29-Oct-2004.
20. MCPA: Reregistration Eligibility Decision for MCPA. 30-Sept-2004.
21. MCPA: Corrected Revised Human Health Risk Assessment for the Reregistration
Eligibility Decision Document (RED). 14-Sep-2004.
22. MCPA: Second Revised Occupational and Residential Exposure and Risk Assessment
for the Reregistration Eligibility Decision Document (RED). 07-Sep-2004.
23. MCPA: Appendix A. Standard Formulas Used for Calculating Occupational and
Residential Exposures to MCPA. 07-Sept-2004.
24. MCPA: Appendix B, Occupational Handler Exposure Data and Risk Calculations for
MCPA. 07-Sep-2004.
25. MCPA: Appendix B, MCPA Short term MOEs for Handlers. 07-Sep-2004.
26. MCPA: Appendix C, Occupational Post-Application Risks of MCPA Exposures.
07-Sep-2004.
27. MCPA: Appendix D, Residential Handler Exposure Data and Risk Calculations for
MCPA. 07-Sept-2004.
28. MCPA: Appendix E, MCPA Turf Transferable Residue (TTR) Data. 07-Sep-2004.
29. MCPA: Appendix F, Residential Turf Post Application Risk Assessment for MCPA.
07-Sep-2004.
30. MCPA: Revised MCPA Acute and Chronic Dietary Exposure Assessments for the
Reregistration Eligibility Decision. 15-Sep-2004.
31. MCPA: Revised Product and Residue Chemistry Chapters for the Reregistration Eligibility
Decision. 14-Sep-2004.
32. MCPA: Residues of Concern. 07-Oct-2004.
33. MCPA: 4-chloro-2-Methylphenoxy Acetic acid (MCPA). 06-Oct-2004.
34. MCPA: Evaluation of Revised Application Rates and Dietary Consumption for the
2-methyl-4chlorophenoxyacetic acid (MCPA) Reregistration Eligibility Decision
Document. 21-Sep-2004.

EFED Documents
1. MCPA: Response to comments made by MCPA Task Force Three on EFED'S RED
Chapter. 14-Apr-2004.
2. MCPA: Revised Environmental Fate and Effects Division Preliminary Risk Assessment
for the 2-methyl-4chlorophenoxyacetic acid (MCPA) Reregistration Eligibility Decision
Document. 14-Apr-2004.
158
-------
3. MCPA: Environmental Rate and Effects Division's Risk Assessment for the
Reregistration Eligibility Document for 2-methyl-4chlorophenoxyacetic acid (MCPA).
Ol-Jun-2004.
159
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APPENDIX D: BIBLIOGRAPHY

MCPA General References:

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Pesticide Data for Semi-Permanent Wetlands in the Aspen Parkland of Alberta. Alberta
Environment, Publication No. T/673.

Blomquist, J.D., 2003. Personal Communication.

Blomquist, J.D., Denis, J.M., Cowles, J.L., Hetrick, J.A., Jones, R.D., and Birchfield, N.B. 2001.
Pesticides in Selected Water-Supply Reservoirs and Finished Drinking Water 1999-2000:
Summary of Results from a Pilot Monitoring Program. USGS Open-File Report 01-456.
Baltimore, Maryland 2001.

Dubberly, Dale., Florida Department of Agriculture and Consumer Services (FDOACS), 2003.
Personal Communication.
ECOFRAM. 1999. ECOFRAM Terrestrial Draft Report. Ecological Committee on FIFRA Risk
Assessment Methods. USEPA, Washington, DC.

Fletcher, J.S., I.E. Nellsen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA food-
chain (Kenaga) nomogram, an instrument for estimating pesticide residues on plants. Env.
Toxicol. Chem. 13:1381-1391.
Feitshans, T.A., 1999. An Analysis of State Pesticide Drift Laws, San Joaquin Agric. L. Rev. 1, 37
(Spring 1999).

Furlong, E.T., Anderson, B.D., Werner, S.L., Soliven, P.P., Coffey, L.J., and Burkhardt, M.R., 2001.
Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory -
Determination of Pesticides in Water by Graphitized Carbon-Based Solid-Phase Extraction and
High-Performance Liquid Chromotography/Mass Spectormetry. USGS Water-Resources
Investigations Report 01-4134. Denver, Colorado, 2001.
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Gibson, L. R. and M. Liebman. 2002. Course Material for Principles of Weed Science, Agronomy 317,
Iowa State University. Website accessed 15 July 2003,
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Harrison, S.A., Watschke, T.L., Mumma, R.O., Jarrett, A.R., and Hamilton, G.W. Jr. 1993. Nutrient
and pesticide concentrations in water from chemically treated turfgrass. In K. Racke and A.
Leslie (editors), Pesticides in urban environments: Fate and significance. American Chemical
Society (ACS) Symposium Series 1993, #522, p. 191-207.

Hoerger, F. and E. E. Kenaga. 1972. Pesticide residues on plants: correlation of representative data as a
basis for estimation of their magnitude in the environment, in. F. Coulston and F. Corte (editors),
Environmental Quality and Safety: Chemistry, Toxicology, and Technology. Vol I. Georg Thieme
Publishers, Stuttgart, West Germany, pp. 9-28.
Jones, R. D., Breithaupt, J., Carleton, J., Libelo, L., Lin, J., Matzner. R., Parker, R., and Birchfield, N.
Guidance for Use of the Index Reservoir in Drinking Water Exposure Assessments,
November 16, 1999. United States Environmental Protection Agency (USEPA) Office of
Pesticide Programs (OPP).

Kellogg, R.L., Wallace, S., Alt, K., and Goss, D.W. 1998. Potential Priority Watersheds for Protection
of Water Quality from Nonpoint Sources Related to Agriculture. United States Department of
Agriculture, Natural Resources Conservation Service (NRCS).

Majewski, M.S. and Capel, P.D. 1995. Pesticides in the Atmosphere: Distribution, Trends, and
Governing Factors. USGS Series: Pesticides in the Hydrologic System, Volume One in the
Series. Ann Arbor, Michigan.

Mayer, F. L. and M.R. Ellersieck. 1986. Manual of acute toxicity: Interpretation and data base for 410
chemicals and 66 species of freshwater animals. United States Department of the Interior, U.S.
Fish and Wildlife Service, Resource Publication 160.

Mineau, P., B. T. Collins, and A. Baril. 1996. On the use of scaling factors to improve interspecies
extrapolation of acute toxicity in birds. Regulatory Toxicology and Pharmacology. 24:24-29.

Nagy, K. A. 1987. Field metabolic rate and food requirement scaling in mammals and birds. Ecological
Monographs 57:111-128.

Paris, D.F., Steen, W.C., Baughman, G.L., and Barrnett, J.T. Jr, 1981. Second-Order Model to Predict
Microbial Degradation of Organic Compounds in Natural Waters. Applied and Environmental
Microbiology, vol. 41, No. 3, p 603-609.

161
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Paris, D.F., Wolfe, N.L., and Steen, W.C., 1983. Microbial Transformations of Esters of Chlorinated
Carboxylic Acids. Applied and Environmental Microbiology, vol. 47, No. 1, p 7-11.

Rawn, D.F.K., Halldorson, T.H.J., Lawson, B.D., and Muir, C.G., 1999. A Multi-Year Study of Four
Herbicides in Air and Precipitation from a Small Prairie Watershed. J. Environ. Qual. 28:898-
906.

Smith, A.E. and Hayden B.J., 1980. Hydrolysis of MCPA Esters and the Persistence of MCPA in
Saskatchewan Soils. Bull. Environm. Contam. Toxicol., 25, 369-373.

Steen, W.C. 1991. Microbial Transformation Rate Constants of Structurally Diverse Man-made
Chemicals. U.S. Environmental Protection Agency, Athens GA. EPA/600/3-91/016.

Swarzenbach, R.P., Gschwend, P.M., and Imboden, D.M., 1993. Environmental Organic Chemistry.
John Wiley and Sons, Inc. New York.

Thelin, G.P. and Gianessi, L.P. 2000. Method for Estimating Pesticide Use for County Areas of the
Conterminous United States. USGS Open-File Report 00-250, Sacramento, California 2000.

USEPA, 2002. Guidance for Selecting Input Parameters in Modeling the Environmental Fate and
Transport of Pesticides Input Parameter Guidance. Version U February 28, 2002. U.S.
Environmental Protection Agency, Office of Pesticide Programs, Environmental Fate and Effects
Division.

USEPA. 1993. Wildlife Exposure Factors Handbook. Office of Research and Development,
Washington, D.C. EPA/600/R-93/187. December 1993.

USEPA, 1999. Applying a Percent Crop Area Adjustment to Tier 2 Surface Water Model Estimates for
Pesticide Drinking Water Exposure Assessments. U.S. Environmental Protection Agency, Office
of Pesticide Programs, Environmental Fate and Effects Division.

USEPA, 1992. Pesticides in Ground Water Database: A Compilation Of Monitoring Studies: 1971-
1991, National Summary. EPA 734-12-92-001. Washington, D.C. September 1992.

Wolfe, N.L. 1990. Abiotic Transformations of Toxic Organic Chemicals in the Liquid Phase and
Sediments. In: Toxic Organic Chemicals in Porous Media. Z. Gerstl, Y. Chen, U. Mingelgrin and
B. Yaron. (Eds.). Springer-Verlag, New York. p. 136-147.

Wolfe, N.L., M.E-S. Metwally and A.E. Moftah. 1989. Hydrolytic Transformations of Organic
Chemicals in the Environment. In: Reactions and Movement of Organic Chemicals in Soils. B.L.
162
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Sawhney and K. Brown, (Eds), Soil Science Society of America and American Society of
Agronomy, Madison, WI. p. 229-242.

PC Code 030501:
1 MRID Citation Reference
4438 Miller. P.W.: Jensen. D.J. (1973^ Study of Alkaline Hydrolysis for Determination of
Residues of MCPA and 2-Methvl-4-chlorophenol in Milk: Report No. GH-C 628.
Method dated Feb 13. 1973. (Unpublished study received on unknown date under
9F0761: submitted bv Dow Chemical U.S.A.. Midland. Mich.: CDL:092000-C)

4443 Thornburg. W. (1973^ MCPA Residues in Peas: A Summary of Residue Data.
(Unpublished study received on unknown date under 9F0761: prepared by Del
Monte Corp.. submitted bv Dow Chemical U.S.A.. Midland. Mich.: CDL:092000-
a
4453 Winterlin. M.: Radosivich. S.R. (1974) Report of Analysis: Environ- mental
Toxicology Report No. 3445. Includes undated method. (Unpublished study
received Feb 10. 1976 under 6E1746: prepared by Univ. of California—Davis.
Dept. of Environmental Toxicology, submitted by Interregional Research Project No.
4. New Brunswick. N.J.: CDL:095368-C)

4473 Frost K.R.. Jr. (1966} Weed Control Headlines 1965-1966. (Unpublished study
received Nov 6. 1967 under 464-398: prepared by South Dakota State Univ..
submitted bv Dow Chemical U.S.A.. Midland. Mich.: CDL:003622-R)

4491 Herman. J.L.: Bierke. E.L.: Getzendaner. M.E. (1970) Residue of 2-Methyl-4-
chlorophenoxyacetic acid and 2-Methyl-4-chlorophenol in Milk and Cream from
Cows Fed MCPA. (Unpublished study received Jan 11. 1971 under 9F0761:
prepared by Dow Chemical Co.. submitted by National Agricultural Chemicals
Association. Indus- try Task Force on Phenoxy Herbicide Tolerances. Washington.
D.C.:CDL:091313-r>

4492 Herman. J.L.: Bjerke. E.L. (1970) Determination of MCPA and 2-Methyl-4-
chlorophenol in Milk and Cream by Gas Chromatography. Method no. ACR 70.17
dated Dec 2. 1970. (Unpublished study received Jan 11. 1971 under 9F0761:
prepared by Dow Chemical Co.. submitted by National Agricultural Chemicals
Association. Industry Task Force on Phenoxy Herbicide Tolerances. Washington.
D.C.:CDL:091313-D

4493 Amchem Products. Incorporated (1968} Summary of Performance Data: Brominal
163
-------
Plus). Summary of studies 002199-B through 002199-P. (Unpublished study
received Oct 30. 1968 under 264-239: submitted by Union Carbide Agricultural
Products Co.. Ambler. Pa.: CDL:002199-A)

4624 Herman. J.L.: Bierke. E.L.: Getzendaner. M.E. (1971) Residues of 2-Methvl-4-
chlorophenoxyacetic acid and 2-Methyl-4-chlorophenol in Milk and Cream from
Cows Fed MCPA. (Unpublished study received Oct 11. 1971 under 9F0761:
prepared by Dow Chemical Co.. submitted by National Agricultural Chemicals
Association. Indus- try Task Force on Phenoxy Herbicide Tolerances. Washington.
D.C.:CDL:091311-E^

4625 Bjerke. E.L.: Herman. J.L. (1971) Residues of 2-Methyl-4-chloro- phenoxyacetic
acid and 2-Methyl-4-chlorophenol in Tissues of Beef Calves Fed MCPA.
(Unpublished study received Oct 11. 1971 under 9F0761: prepared by Dow
Chemical Co.. submitted by Nation- al Agricultural Chemicals Association. Industry
Task Force on Phenoxy Herbicide Tolerances. Washington. D.C.: CDL:091311-F)

4626 Bjerke. E.L.: Herman. J.L. (1971^ Residues of 2-Methyl-4-chloro- phenoxyacetic
acid and 2-Methyl-4-chlorophenol in Tissues of Sheep Fed MCPA. (Unpublished
study received Oct 11. 1971 under 9F0761: prepared by Dow Chemical Co..
submitted by National Agricultural Chemicals Association. Industry Task Force on
Phenoxv Herbicide Tolerances. Washington. D.C.: CDL:091311-G)

4651 Higham. J.W.: Feenv. R.W. (1974) AvengeA(IOI (CL 84.777^: Determination of
MCPA (2-Methyl-4-chlorophenoxyacetic acid) Residues in Wheat Grain and Straw
Following Ground. Postemergence Applica- tion in Combination with Avenge (1.2-
Dimethyl-3.5-diphenyl pyra- zolium methyl sulfate). (Oregon): Report No. C-576.
(Unpublished study received Nov 14. 1975 under 6F1703: prepared in cooperation
with State Univ. of New York—Oswego. Lake Ontario Environmental Laboratories.
submitted by American Cyanamid Co.. Princeton. N.J.: CDL:094738-Y^

4655 Elenewski. C.A.: Wang. T. (1975) AvengeAflOI (CL 84.777s): Determination of CL
84.777 (1.2-Dimethyl-3.5-diphenyl-lH-pyrazolium methyl sulfate). Bromoxynil (3.5-
Dibromo-4-hydroxylbenzonitrile^ and MCPA (2-Methyl-4-chlorophenoxyacetic
acid) Residues in Durum Wheat Grain and Straw Following Aerial Application of
Avenge Alone and in Combination with MCPA or Bromoxynil. (Minnesota): Report
No. C-823. (Unpublished study received Nov 14. 1975 un- der 6F1703: prepared
in cooperation with Biodynamics. Inc.. submitted by American Cyanamid Co..
Princeton. N.J.: CDL:094738-AID

4659 Elenewski. C.A.: Wang. T. (1975) AvengeA(R)I TCL 84.777): Determination of CL
84.777 (1.2-Dimethvl-3.5-diphenvl-lH-pyrazolium methyl sulfate). Bromoxvnil (3.5-
164
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Dibromo-4-hydroxylbenzonitrile) and MCPA (2-Methyl-4-chlorophenoxyacetic
acid^ Residues in Wheat Grain and Straw Following Ground Application of Avenge
Alone and in combination with MCPA or Bromoxynil. (Oregon): Report No. C-
820. (Unpublished study received Nov 14. 1975 under 6F1703: prepared in
cooperation with Biodynamics. Inc.. submitted by American Cyanamid Co..
Princeton. N.J.: CDL:094738-AH)

4724 St. John. L.E.. Jr. (1967} MCPA. Pages 445-454. In Analytical Methods for
Pesticides. Growth Regulators and Food Additives: Volume 5. Edited by G. Zweig.
New York: Academic Press. (Also in unpublished submission received Sep 12.
1968 under 8F0676: submitted bv Dow Chemical U.S.A.. Midland. Mich.:
CDL:092980-AP^

4787 Guardigli. A. (1974^ Rhodia Analytical Method No. 123. Includes two methods
dated March 1974. (Unpublished study received Jan 30. 1976 under 359-534:
prepared by Rhodia. Inc.. submitted by Rhone-Poulenc. Inc.. Monmouth Junction.
N.J.: CDL:222737-A^

4822 Guvton. C.L. (1977) Procedures for the Measurement of Asulam. MCPA.
Sulfanilamide and Acetylasulam in/on Flax: Forages. Straw. Seed and Mill-
Processed Flax Seed Fractions. Method no. 143 dated Jul 1977. (Unpublished
study received Apr 13. 1979 under 359- 662: prepared by Rhodia. Inc.. submitted
bv Rhone-Poulenc. Inc.. Monmouth Junction. N.J.: CDL:238025-BN)

4993 IR-4 Project at Rutgers, the State University (1974} MCPA-Sorghum Residue
Studies. (Unpublished study received Oct 3. 1975 under 6E1681: CDL:097351-AN)

5575 Montgomery. M.L. (1970} MCPA Residue in Wheat: Oregon State University
Report. Includes methods dated Jun 17. 1970 and Apr 1. 1970. (Unpublished study
including summary report and letters dated Apr 2. 1970 from M.L. Montgomery to
Don T. Lillie and J.A. Ignatoski. received Jan 22. 1971 under 9F0761: prepared by
Ore- gon State Univ.. Dept. of Agricultural Chemistry, submitted by National
Agricultural Chemicals Association. Industry Task Force on Phenoxy Herbicide
Tolerances. Washington. D.C.: CDL:091308-D

21972 Raltech Scientific Services. Incorporated (1979} Oral Defined LD50. (Unpublished
study received Jul 16. 1979 under 39335-1: submit- ted by Fallek-Lankro Corp..
Tuscaloosa. Ala.: CDL:238870-B^

25394 Rvdrich. P.: Wallace. K.: Beck. B.: et al. (1976^ Residue Results: Banvel plus
Bromoxynil plus MCPA Tank Mix: Summary. (Unpub- lished study received Feb
18. 1976 under 876-25: prepared in co- operation with Oregon State Univ..
submitted bv Velsicol Chemi- cal Corp.. Chicago, ni.: CDL:225197-Q
165
-------
41633
46148
53734
61368
78931
102704
106595
15682
Keller. W.: Otto. S. (1979) Investigations into the Metabolism of MCPA in Winter
Wheat: Report No. 161 la. (Unpublished study including submitter summary.
received Aug 28. 1980 under 2217'-EX- 2: prepared by BASF. AG. submitted by
FBI-Gordon Corp.. Kansas City. Kans.: CDL:243167-A)

Interregional Research Project Number 4 (1980^ Summary of Residue Data for
MCPA in or on Forage Legumes Seeded with Small Grains. Includes two undated
methods entitled: Analysis of 2-Methyl-4- chlorophenoxyacetic acid from oats and
alfalfa: 2-Methyl-4- chlorophenol on oats and alfalfa. (Unpublished study received
Nov 5. 1980 under 6E1856: CDL:099690-A^

Akzo Zout Chemie Nederland. B.V. (1975^ MCPA: Some Information on
Properties. Applications. Stability and Toxicity. Summary of studies 231352-B
through 231352-D. 231352-N. 231352-O. 231352-O through 231352-T.
231355-D. 231355-F through 231355-K. 231355-M through 231355-R. 231355-
U. 231355-Y and 231355-Z. (Unpublished study received Aug 15. 1977 under
38117-3: CDL:231355-A)

Reuzel. P.G.J.: van der Heijden. C.A.: van Oostrum. E.C.M. (1978^ Range-Finding
(4-Week) Toxicity Study with MCPA in Beagle Dogs: Report No. R 5369. Final
rept. (Unpublished study received Nov 3. 1980 under 2217-EX-2: prepared by
Centraal Instituut voor Voedingsonderzoek. TNO. submitted by FBI-Gordon Corp..
Kansas City. Kans.: CDL:243634-A. 243633}

Rohm & Haas Company (1978^ Treatment and MCPA Residue Summary for
Barlev & Oats. (Unpublished study received Jul 14. 1981 under 707-75:
CDL:070183-B^

National Agricultural Chemicals Assoc. (1973^ The Results of Tests on the Amount
of Residue Remaining. Including a Description of the Analytical Method Used: (2.4-
D). (Compilation: unpublished study received Sep 7. 1973 under 8F0670:
CDL:092143-AN)

Reuzel. P.: Hendriksen. C: Feron. V.: et al. (1980) Subchronic (13-week) Oral
Toxicity Study of MCPA in Beagle Dogs: Report No. R 6478. Final rept.
(Unpublished study received Jul 6. 1982 under unknown admin, no.: prepared by
Centraal Instituut Voor Voedingsonderzoek. TNO. Neth.. submitted by Diamond
Shamrock Agricultural Chemicals. Cleveland. OH: CDL:247854-A: 247855:
247856;)

Bach. K. (1974) Acute Oral Toxicity in Rats of Weedar MCPA Concentrate:
Contract No. 121-2320-54. Final rent. (Unpublished study received Oct 18. 1982
166
-------
under 264-47: prepared by Affiliated Medical Research. Inc.. submitted by Union
Carbide Agricultural Products Co.. Inc.. Research Triangle Park. NC:
CDL:248567-C)

148720 Engelhardt. G. (1985^ Cytogenetic Investigations in Chinese Hamsters after a Single
Oral Administration of MCPA: [(4-Chloro- 2-methylphenoxy Acetic Acid)]: Sister
Chromatid Exchange (SCEY Project No. 16M0046/8356: Supplementary Study.
Unpublished study prepared by BASF AG. 32 p.

155099 BASF Wyandotte Chemical Co. (1985) Product-specific Data Require- ments for
MCPA Manufacturing Use Products. Unpublished com- pilation. 33 p.

155743 Gilmore. Inc. (1985) [Product Chemistry Data for MCPA Technical Acid].
Unpublished study. 84 p.

158077 A. H. Marks & Co.. Ltd. (19??) Manufacturing Process for MCPA Technical Acid.
Unpublished compilation. 10 p.

158078 A. H. Marks & Co.. Ltd. (19??) Analysis and Certification of Product Ingredients
[of MCPA]. Unpublished study. 2 p.

159470 Rhone-Poulenc Inc. (1986) Product Chemistry Data Requirements under EPA
Pesticide Assessment Guidelines Dated Oct. 1982: 2(-4- Chloro-2-methylphenoxy)
Acetic Acid. MCPA Tech.: ECD/JBU/LMC/ 2108. Unpublished compilation. 136
164352 Hellwig (1986) Report on the Study of the Toxicitv of MCPA in Beagle Dogs after
12-month Administration in the Diet: Project No. 33D0046/8341. Unpublished study
prepared by BASF Institute. 691 p.

165470 Kirsch. P. (1985) Report on the Study of the Toxicitv of MCPA in Mice after 4-
weeks Administration in the Diet (Range-finding Study): [To Determine Dosage for a
78-week Oncogenicitv Study]: Project No. 50S0046/8342. Unpublished study
prepared by BASF Ag. 177 p.

165471 Kirsch. P. (1985) Report on the Study of the Toxiciry of MCPA in Rats after 3
Months Administration in the Diet: [Range-finding Study for 2-year Oncogenicitv
Study in Rats]: Project No. 31S0046/8302. Unpublished study prepared bv BASF
Ag. 381 p.
167
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250090 Wolfe, G.; Shults, S.; Killeen, J.; et al. (1982) Acute Dermal Toxicity Study in
(128268) Albino Rabbits with 2-Methyl-4-chlorophenoxyacetic Acid (MCPA): Report
Document No. 520-5TX-81-0158-002. Primary Dermal and Eye Irritation Study in
Albino Rabbits with 2-Methyl-4-chlorophenoxyacetic Acid (MCPA): Report
Document No. 520-5TX-81-0160-002. Primary Oral Toxicity (LD50) Study in Rats
with 2-Methyl-4-chlorophenoxyacetic Acid (MCPA): Report Document No. 520-
TX-81-0157-002. (Un- published study received May 2, 1983 under 39335-4;
prepared in cooperation with Hazleton Laboratories America, Inc., submitted by
Diamond Shamrock Agricultural Chemicals, Tuscaloosa, AL; CDL: 250090-A)
5003259 Bjerke, E.L.; Herman, J.L.; Miller, P.W.; Wetters, J.H. (1972) Residue study of
phenoxy herbicides in milk and cream. Journal of Agricultural and Food Chemistry
20(5):963-967.

40019201 Grimes, J. (1986) MCPA Acid: An Acute Oral Toxicity Study with the Bobwhite:
Final Report: Wildlife International Ltd. Project No. 222-101. Unpublished study
prepared by Wildlife International Ltd. 19 p.

40027501 Gelbke, H.; Engelhardt, G. (1986) Cytogenetic Investigations in Chinese Hamsters
after a Single Oral Administration of MCPA: Bone Marrow Chromosomes Analysis:
Project No. 10M0046/8367. Un- published study prepared by BASF
Aktiengesellschaft. 55 p.

40041701 MacKenzie, K. (1986) Two-Generation Reproduction Study with MCPA in Rats:
Final Report: Study No. 6148-100. Unpublished study pre- pared by Hazleton
Laboratories America, Inc. 1304 p.

40053101 Klimisch, H. (1986) Acute Inhalation Toxicity LC50 4 Hours (Rat) Dust Aerosol
Study of MCPA: Project No. 1310046/83. Unpublished study prepared by BASF
Aktiengesellschaft. 19 p.

40461901 Obrist, J. (1987) Anaerobic Aquatic Metabolism of MCPA: Laboratory Project ID:
HLA 6015-325. Unpublished study prepared by Hazle- ton Laboratories America,
Inc. 75 p.

40470101 May & Baker Ltd. (1987) Addendum to Product Chemistry Data Requirements
Under EPA Pesticide Assessment Guidelines ...: 2-(4-chlo- ro-2-
methylphenoxy)acetic Acid, MCPA Technical: Lab. Proj. ID ECD/JBU/LMC/2108.
Unpublished study. 32 p.

40471801 Bailey, R; Hopkins, D. (1987) 2-Methyl-4-chlorophenoxyacetic Acid:
Determination of Octanol/Water Partition Coefficient: Lab. Proj. ID ES-DR-0004-
9672-4. Unpublished study prepared by Dow Chemi- cal Co. 13 p.
168
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40471802 Hopkins, D. (1987) 2-Methyl-4-Chlorophenoxyacetic Acid: Determination of the
Water Solubility: Lab. Proj. ID ES-DR-0004-9672-3. Unpublished study prepared
by Dow Chemical Co. 14 p.

40471803 Chakrabarti, A.; LaBean, M. (1985) Vapor Pressure of MCPA and Two MCPA
Esters: Lab. Proj. ID ML-AL-85-40005. Unpublished study prepared by Dow
Chemical Co. 13 p.

40555801 Goodwin, P.; Laskowski, D. (1988) An Adsorption Study of MCPA: Project No.
GH-C 1995. Unpublished study prepared by Dow Chemical Co. U.S.A. 51 p.

40634101 Kirsch, P. (1986) Report: Study on the Chronic Toxicity and Oncogenic Potential of
MCPA in Rats: Final Report: Project No. 71S0046/8345. Unpublished study
prepared by BASF Ag. 2026 p.

40792301 Kuhborth, B. (1986) Report: Study on the Oncogenic Potential of MCPA in Mice:
Project No. 80S0046/8358. Unpublished study prepared by BASF AG. 1067 p.

40961301 Ewing, D. (1988) MCPA Confined Accumulation Study on Rotational Crops: Proj.
ID PAL-EF-86-31. Unpublished study prepared by Analytical Development Corp.
149 p.

41193401 Unsworth, J. (1985) Product Chemistry Data Requirements Under EPA Pesticide
Assessment Guidelines ... 2-(4-Chloro-2-methylphenoxy) Acetic Acid MCPA
Technical: Proj. ID ECD/KBU/LMC/2108. Unpublished compilation prepared by
Rhone-Poulenc Ltd. 75 p.

41586001 Matt, F. (1990) Aerobic and Aerobic/Anaerobic Soil Metabolism of 14 C|-MCPA:
Lab Project Number: HLA 6237-107. Unpublished study prepared by Hazleton
Labs America, Inc. 120 p.

41759403 Buddie, G (1990) 4-Chloro-2-Methylphenoxyacetic acid 2-Ethylhexyl Ester:
Product Identity and Composition: Lab Project Number: P- 90-275. Unpublished
study prepared by Rhone-Poulenc Agriculture Ltd. 29 p.

42079400 Akzo Salt and Basic Chemicals BV (1991) Submission of Data to Support the
Reregistration Standard for Phenoxy Herbicides (MCPA): Product Chemistry Data.
Transmittal of 4 Studies.

42079401 Rausch, L. (1991) Product Chemistry for MCPA. Unpublished study prepared by
Akzo Chemicals Inc. 72 p.

42079402 Bicking, M. (1991) Preliminary Analysis of MCPA Technical Acid: Lab.Project
Number: 61-91-ACC.15. Unpublished study prepared by Twin City Testing Corp.
169
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57 p.

42079403 Rausch, L. (1991) Product Chemistry for MCPA. Unpublished study prepared by
Akzo Chemicals Inc. 13 p.

42079404 Bicking, M. (1991) Determination of Seven Product Chemistry Parameters for
MCPA Technical Acid: Lab Project Number: 53-91-ACC.7. Unpublished study
prepared by Twin City Testing Corp. 49 p.

42134001 Silvoy, J. (1991) LX143-04 (MCP Ester): Field Dissipation-Terrestrial-on Small
Grains in California: Lab Project Number: 6237- 118C: 1641-88-43-04-06K-04.
Unpublished study prepared by Hazleton Labs America, Inc. in coop, with Research
for Hire. 358 p.

42134101 Silvoy, J. (1991) LX143-04 (MCP Ester) Field Dissipation-Terrestrial on Bare
Ground: Lab Project Number: 6237-118D: 1641-88-43-04- 21E-03. Unpublished
study prepared by Hazleton Labs America, Inc. in coop with Northwest Agricultural
Research, Inc. 369 p.

42197801 Hoxter, K.; Lynn, S. (1992) MCPA 2-EHE: An Acute Contact Toxicity Study with
the Honey Bee: Lab Project Number: 222-101. Unpublished study prepared by
Wildlife International Ltd. 30 p.

42377401 Pryce, A. (1992) MCPA Acid (TGAI)-Product Chemistry: Final Report: Lab
Project Number: AHM/EPA/92/AP/02. Unpublished study prepared by A. H.
Marks & Co. Ltd. 41 p.

42377402 Anon. (1992) Beginning Materials-Data Sheets from Suppliers: (MCPA Acid
(TGAI)-Product Chemistry). Unpublished study prepared by A.H. Marks & Co.
Ltd. 48 p.

42377403 A. H. Marks and Co., Ltd. (1992) Beginning Materials~A H Marks' Purchase
Specifications: (MCPA Acid (TGAI)-Product Chemistry). 12 p.

42377404 A H Marks and Co., Ltd. (1992) A H Marks' Standard Analytical Methods:
(MCPA Acid (TGAI)-Product Chemistry). Unpublished study. 28 p.

42377405 Pryce, A. (1992) Confirmation of Identity of Impurity Standards by GC/MS: Lab
Project Number: D92/2. Unpublished study prepared by A H Marks & Co. Ltd. 25
P-

42377406 Anon. (1992) Statistical Analysis of PCOC Quality Data (Histograms). Unpublished
study prepared by A H Marks & Co. Ltd. 15 p.
170
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42377407
42377408
42377409
42377410
42386400
42386401
42386402
42386403
42450901
42450902
42450903
42450904
Anon. (1992) MCPA Acid (TGAI) Product Specification. Unpublished study
prepared by A H Marks & Co. Ltd. 5 p.

Anon. (1992) MCPA Acid (TGAI) Statistical Analysis of QC Data (3 Months to
June 1992). Unpublished study prepared by A H Marks & Co. Ltd. 20 p.

Welch, J. (1992) MCPA Acid (TGAI) Determination of Ash, Sodium, Chloride and
Sulfate: Lab Project Number: BL4/0481. Unpublished study prepared by
Butterworth Labs, Ltd. 46 p.

Anon. (1992) Protocol: Sampling of MCPA: EPA 91/005. Unpublished study
prepared by A H Marks & Co. Ltd. 13 p.

Rhone-Poulenc Ag Comp. (1992) Submission of Product Chemistry Data in Support
of Reregistration for MCPA. Transmittal of 3 studies.

Snell, R. (1990) MCPA Technical: Supplemental Data for Product Chemistry Series
61: Lab Project Number: ACD/GCB/MS/8762. Unpublished study prepared by
Rhone-Poulenc Agriculture Ltd. 26 p.

Buddie, G; Patel, P. (1991) 4-chloro-2-methylphenoxyacetic acid (MCPA)
Analysis and Certification of Product Ingredients, Provision of Supplementary
Analytical Method Validation: Lab Project Number: P-91-055. Unpublished study
prepared by Rhone-Poulenc Agriculture Ltd. 14 p.

Buddie, G; Mills, E. (1990) MCPA Technical: Physical Properties: Product
Chemistry Series 63-2 to 63-7: Lab Project Number: D AG. 1542. Unpublished
study prepared by Rhone-Poulenc Agriculture Ltd. 9 p.

Alexander, B.; Dinwoodie, N; Maclean, K. (1992) Product Chemistry of MCPA-
Acid Analysis: Lab Project Number: 351616: 8655. Unpublished study prepared by
Inveresk Research Intl. 74 p.

Dinwoodie, N. ; Maclean, K. (1992) Product Chemistry of MCPA-Acid: Colour:
Lab Project Number: 351621: 8541. Unpublished study prepared by Inveresk
Research Intl. 15 p.

Dinwoodie, N.; Maclean, K. (1992) Product Chemistry of MCPA-Acid: Physical
State: Lab Project Number: 351637: 8551. Unpublished study prepared by Inveresk
Research Intl. 15 p.

Dinwoodie, N.; Maclean, K. (1992) Product Chemistry of MCPA-Acid: Odour:
Lab Project Number: 351642: 8552. Unpublished study prepared by Inveresk
Research Intl. 15 p.
171
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42450905 Dinwoodie, N.; Maclean, K. (1992) Product Chemistry of MCPA-Acid: Melting
Point: Lab Project Number: 351658: 8553. Unpublished study prepared.by Inveresk
Research Intl. 15 p.

42450906 Alexander, B.; Dinwoodie, N; Maclean, K. (1992) Product Chemistry of MCPA-
Acid: Density: Lab Project Number: 351663: 8642. Unpublished study prepared by
Inveresk Research Intl. 17 p.

42450907 Alexander, B.; Dinwoodie, N.; Maclean, K. (1992) Product Chemistry of MCPA-
Acid: pH: Lab Project Number: 351679: 8675. Unpublished study prepared by
Inveresk Research Intl. 17 p.

42577600 AKZO (1992) Submission of product chemistry data in support of the registration of
MCPA. Transmittal of 3 studies.

42577601 Rausch, L. (1992) Product Chemistry: MCPA. Unpublished study prepared by
Akzo Chemicals, Inc. 84 p.

42577602 Landvoigt, W. (1992) Product Chemistry Dioxin Analysis for MCPA. Unpublished
study prepared by Chemie Linz AG. 145 p.

42577603 Rausch, L. (1992) Product Chemistry: MCPA. Unpublished study prepared by
AKZO Chemicals, Inc. 173 p.

42624401 Jones, E.; Kitching, 1; Anderson, A.; et al. (1992) Ames Salmonella Typhimurium
Bacterial Reverse Mutation Assay on MCPA DMAS: Lab Project Number: JEL
24/921053. Unpublished study prepared by Huntingdon Research Centre Ltd. 44
P-
42657101 Varcoe, F. (1992) Analysis of Poly chlorinated Dibenzo-p-dioxins and and
Polychlorinated Dibenzofurans in (4-Chloro-2-methylphenoxy) acetic Acid: Lab
Project No. 21916. Unpublished study prepared by Triangle Labs, Inc. 1402 p.

42665301 Lai, I. (1993) Hydrolysis of (carbon 14)-MCPA Acid in Buffered Aqueous
Solutions: Final Report: Lab Project Number: SC910160. Unpublished study
prepared by Battelle Memorial Institute. 67 p.

42715001 Baldrick, P.; Crook, D.; Gibson, W.; et al. (1992) Twenty-one Day Dermal Toxicity
Study in the Rabbit with MCPA Acid: Lab Project Number: JEL 23/921253.
Unpublished study prepared by Huntingdon Research Centre Ltd. 117 p.

42723801 Hellwig, J.; Hildebrand, B. (1993) Study of the Prenatal Toxicity of MCPA-Acid in
Rats after Oral Administration (Gavage): Lab Project Number: 30R0374/91096.
Unpublished study prepared by BASF Aktiengesellshaft. 302 p.
172
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42723802 Hellwig, J.; Hildebrand, B. (1993) Study of the Prenatal Toxicity of MCPA-Acid in
Rabbits after Oral Administration (Gavage): Lab Project No. 40R0374/91095.
Unpublished study prepared by BASF Aktiengesellshaft. 230 p.

42757301 Campbell, C; Dinwoodie, N. (1993) Product Chemistry of MCPA-Acid: Stability:
Lab Project Number: 9076. Unpublished study prepared by Inveresk Research
International. 56 p.

42840403 Jones, E.; Kitching, 1; Anderson, A.; et al. (1993) Ames Salmonella Typhimurium
Bacterial Reverse Mutation Assay on MCPA Acid: Lab Project Number: JEL
26/920957. Unpublished study prepared by Huntingdon Research Centre Ltd. 44 p.

42853504 Akhurst, L.; King, 1; Anderson, A.; et al. (1993) MCPA Acid Metaphase
Chromosome Analysis of Human Lymphocytes Cultured in vitro: Lab Project
Number: JEL 32/921190. Unpublished study prepared by Huntingdon Research
Centre Ltd. 48 p.

42860101 Adams, K.; Ransome, S.; Anderson, A.; et al. (1993) Chinese Hamster
Ovary/HGPRT Locus Assay: MCPA DMAS: Final Report: Lab Project Number:
JEL 27/921113. Unpublished study prepared by Huntingdon Research Centre Ltd.
42 p.
42860103 Adams, K.; Kirkpatrick, D.; Godfrey, A.; et al. (1993) Chinese Hamster
Ovary/HGPRT Locus Assay: MCPA Acid: Final Report: Lab Project Number: JEL
29/921115. Unpublished study prepared by Huntingdon Research Centre Ltd. 42 p.

42895701 Roberts, N. (1993) Determination of Physico-Chemical Properties of MCPA
Technical Acid: Final Report: Lab Study Number 15. Unpublished study prepared
by Rhone-Poulenc Chemicals Ltd. 150 p.

42928101 Concha, M.; Shepler, K. (1993) Sunlight Photodegradation of (carbon 14)-MCPA
in a Buffered Aqueous Solution at pH 5 by Natural Sunlight: Lab Project Number:
410W-1: 410W. Unpublished study prepared by PTRL West, Inc. 88 p.

43062806 Douds, D. (1993) A Dermal Sensitization Study in Guinea Pigs with EH 1154 Weed
and Feed: A Modified Buehler Design~3 Patch Induction: Final Report: Lab Project
Number: 3229.54. Unpublished study prepared by Springborn Labs, Inc. 42 p.

43083205 Hoberg, J. (1993) MCPA Acid-Determination of Effects on Seed Germination,
Seedling Emergence and Vegetative Vigor of Ten Plant Species: Final Report:_Lab
Project Number: 10566.0493. 6280.610: 93-8-4888. Unpublished study prepared
by Springborn Laboratories, Inc. 246 p.
173
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43225801 Concha, M.; Shepler, K. (1994) Photodegradation of (carbon 14)MCPA in/on Soil
by Natural Sunlight: Lab Project Number: 436W-1: 436W. Unpublished study
prepared by PTRL West, Inc. 91 p.

43556801 Hellwig et. al. (1995) MCPA-2-EH-Ester - Subchronic oral toxicity study in beagle
dogs - Administration in Diet. Department of Toxicology, BASF,
Ludwigshafen/Rhine, FRG, Report No. 31D0385/91115, January 9, 1995. MRID
43556801. Unpublished.

43556802 Hellwig, 1; Bachmann, S.; Deckardt, K.; et al. (1995) MCPA-DMA
Salt-Subchronic Oral Toxicity Study in Beagle Dogs: Administration in the Diet: Lab
Project Number: 31D0385/91115. Unpublished study prepared by BASF
Aktiengesellschaft. 407 p.

43562601 Mellert, W.; Deckardt, K.; Kaufmann, W.; et al. (1994) MCPA-Acid-Subchronic
Oral Dietary Toxicity and Neurotoxicity Study in Wistar Rats: Lab Project Number:
50C0374/91133. Unpublished study prepared by BASF Aktiengesellschaft. 723 p.

43562602 Mellert, W.; Kaufmann, W.; Hildebrand, B. (1994) MCPA-Acid-Acute Oral
Neurotoxicity Study in Wistar Rats: Lab Project Number: 20C0374/91106.
Unpublished study prepared by BASF Aktiengesellschaft. 388 p.

43575501 Sabourin, P.; Koebel, D. (1995) Nature of the Residue Study of (carbon 14)-2-
Methyl-4-Chlorophenoxyacetic Acid ((carbon 14)-MCPA) using Lactating Goats:
Final Report: Lab Project Number: SC930051. Unpublished study prepared by
Battelle Columbus Operations. 232 p.

43575901 Sabourin, P.; Morgens, J.; Koebel, D. et al. (1995) Nature of the Residue Study of
(carbon 14)-2-Methyl-4-Chlorophenoxyacetic Acid ((carbon 14)-MCPA) using
Egg-Laying White Leghorn Hens: Final Report: Lab Project Number: SC920100.
Unpublished study prepared by Battelle Columbus Operations. 285 p.

43755201 MCPA Task Force Three (1995) Overview of Comparative Absorption,
Distribution, Metabolism, and Excretion (ADME) of MCPA Acid, DMAS and
2EHE in Rats. Unpublished study. 18 p.

43755202 Jahanshahi, M.; Stow, R. (1995) (Carbon 14)-MCPA: Absorption, Distribution,
Metabolism, and Excretion in the Rat: Final Report: Lab Project Number: 1149/5-
1011: 1149/5. Unpublished study prepared by Corning Hazleton (Europe). 519 p.

43915401 Lawrence, L. (1996) Nature of the Residue Study of (carbon 14)-2-Methyl-4-
chlorophenoxyacetic Acid (MCPA) Using Lactating Goats: Supplemental Report for
MRID #43575501: Lab Project Number: 908: 1827: SC930051. Unpublished
174
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study prepared by PTRL East, Inc. 37 p.

43986101 Lawson, P. (1996) Product Identity and Composition MCPA Technical.
Unpublished study prepared by Akzo Nobel Chemicals, Inc. 42 p.

43986102 Lawson, P. (1994) Product Identity and Composition: MCPA Technical: Lab
Project Number: 94L00693. Unpublished study prepared by BASF AG. 101 p.

44027301 King, D. (1996) Characterization of ((hydrogen-2)/(carbon-12)/(carbon-
14))MCPA: Lab Project Number: 937: 1868. Unpublished study prepared by PTRL
East, Inc. 25 p.

44192701 MacGregor, J.; Markley, B. (1996) External Validation of a Method for the
Determination of 4-Chloro-2-methylphenoxyacetic Acid Dimethylamine Salt (MCPA
DMAS) as its Acid Equivalent, 4-Chloro-2-methylphenoxyacetic Acid (MCPA),
and 4-Chloro-2-methylphenoxyacetic Acid 2-Ethylhexyl Ester (MCPA 2-EHE) in
Water Samples by Gas Chromatography with Mass Selective Detection: Lab Project
Number: 364C-102: QMAM94002. Unpublished study prepared by Wildlife
International Ltd. 64 p.

44239601 Bashir, M. (1997) The Adsorption and Desorption of MCPA, 4-CC and 4-MCA in
Soil and Sediment: Lab Project Number: CO VANCE 6698-102: CHW 6698-102.
Unpublished study prepared by Covance Laboratories Inc. 120 p.

44259400 Nufarm bv (1997) Submission of Product Chemistry Data in Support of the MCPA
Registration Standard. Transmittal of 1 Study.

44259401 Mahlburg, W. (1997) Analytical Methods to Verify Certified Limits for MCPA Acid:
Method Validation for the Active Ingredient: Lab Project Number: 97-1 A: 61/91-
ACC.15: 4416-0001.01. Unpublished study prepared by Twin Cities Testing Corp.
58 p.

44337201 King, D. (1997) Characterization of (carbon 14)MCPA, (carbon 14)MCPA 2-
EHE, and (carbon 14)MCPADMAS: (Final Report): Lab Project Number: 1031:
1944. Unpublished study prepared by PTRL East, Inc. 61 p.

44337202 King, D. (1997) Characterization of 4-Chloro-2- methylphenoxyacetic Acid
Ornithine Conjugate (MCPA-Orn): (Final Report): Lab Project Number: 1041:
1920. Unpublished study prepared by PTRL East, Inc. 29 p.

44337203 King, D. (1996) Characterization of MCPA Glycine Conjugate: (Final Report): Lab
Project Number: 1023: 1922. Unpublished study prepared by PTRL Eastjnc. 28 p.
175
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44337204 King, D. (1996) Characterization of (carbon 14)MCPA Metabolites: (Final Report):
Lab Project Number: 1032: 1917. Unpublished study prepared by PTRL East, Inc.
74 p.

44394401 Petersen-Thiery, M.; Ohnsorge, U.; Liesner, M. et al. (1996) Product Chemistry:
Analysis and Certification of Product Ingredients, and Validation of Analytical
Methods for MCPA TGAI: Lab Project Number: 96/10117: 94/11238: 95/10013.
Unpublished study prepared by BASF Corp. 159 p.

44401301 Ohnsorge, U. (1996) Product Identity and Composition, Beginning Materials and
Manufacturing Process, and Discussion of the Formation of Impurities of MCPA
TGAI: Lab Project Number: 96/10096: 96/10101. Unpublished study prepared by
BASF Aktiengesellschaft. 211 p.

44463901 Sanson, D. (1997) Physical and Chemical Properties of EH1356 Herbicide.
Unpublished study prepared by FBI/Gordon Corp. 15 p. (OPPTS 830.6303,
830.7300, 830.7000, 830.6314, 830.1550, 830.1600, 830.1620, 830.1650,
830.1670,830.1800}

44639901 Moszczynski, W. (1998) Supplement to Product Chemistry Report on MCPA
TGAI: Lab Project Number: IPO 98/DN: MCPAOSCT: C/BFR0154. Unpublished
study prepared by Institute of Industrial Organic Chemistry. 15 p. {OPPTS
830.1600, 830.1650, 830.1670}

44645801 Ohnsorge, U. (1998) Product Identity and Composition, Beginning Materials and
Manufacturing Process, and Discussion of the Formation of Impurities of MCPA
TGAI: Lab Project Number: 98/10431. Unpublished study prepared by BASF
Aktiengesellschaft. 162 p. {OPPTS 830.1550, 830.1600, 830.1650, 830.1670}

44645802 Turk, W. (1998) Product Chemistry Certified Limits for MCPA TGAI: Lab Project
Number: 98/10284: PCP04660: 98/10339. Unpublished study prepared by BASF
Aktiengesellschaft. 60 p. {OPPTS 830.1700}

44655702 Barney, W. (1998) Determinaton of Transferable Turf Residues on Turf Treated with
2,4-D, 2,4-DP, MCPA, MCPP-p and Dicamba: Lab Project Number: BTH TFR
TF 001: 98-313: 6926-103. Unpublished study prepared by Grayson Research,
LCC. and Covance Laboratories Inc. 521 p. {OPPTS 875.2100}

44861801 White, L. (1999) Corrosion Characteristics of EH-1356 Herbicide: Lab Project
Number: 99-011. Unpublished study prepared by FBI/Gordon Corporation. 19 p.
{OPPTS 830.6320}

45001901 King, D. (1999) Characterization of (carbon-14)MCPA: Lab Project Number:
176
-------
1308: 2071. Unpublished study prepared by MCPA Task Force Three. 31 p.

45001902 King, D. (1999) Certification of (carbon(6)-13 Ring)HMCPA MME for Use as an
Analytical Reference Substance: Lab Project Number: 1362: 2072. Unpublished
study prepared by MCPA Task Force Three. 30 p.

45001903 King, D. (1999) Certification of (carbon(6)-13 Ring)HMCPA for Use as an
Analytical Reference Substance: Lab Project Number: 1362: 2072. Unpublished
study prepared by MCPA Task Force Three. 30 p.

45001904 King, D. (1999) Characterization of (D)HMCPAMME: Lab Project Number:
1310: 2070. Unpublished study prepared by MCPA Task Force Three. 28 p.

45288701 Morrissey, M.; Eberhard, J. (2000) Independent Laboratory Validation of a Method
for the Determination of 4-Chloro-2-methylphenoxyacetic Acid 2-Ethylhexyl Ester
(MCPA 2-EHE) and 4-Chloro-2-methylphenoxyacetic Acid Dimethylamine Salt
(MCPA DMAS) as their 4-Chloro-2-methylphenoxyacetic Acid (MCPA)
Equivalent, MCPA, 4-Chloro-2-hydroxymethylphenoxyacetic Acid (FDVICPA), 4-
Chloro-2-hydroxymethylphenoxyacetic Acid Glucose Conjugate (HMCPA GLU) as
its FDVICPA Equivalent, and 4-Chloro-2-carboxyphenoxyacetic Acid (CCPA) in
Wheat Forage, Straw, and Grain: Final Report: Lab Project Number: 6698-108:
6698-107. Unpublished study prepared by Covance Laboratories Inc. 449 p.

45288702 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt to Winter Wheat: Lab Project Number: GR97-267:
6698-116: 6698-107. Unpublished study prepared by Grayson Research, LLC. 519
p. (OPPTS 860.1500}

45288704 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt to Pasture Grass: Lab Project Number: GR97-273:
6698-111: QMAM94002. Unpublished study prepared by Grayson Research,
LLC. 361 p. {OPPTS 860.1500}

45288705 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt to Wheat Underseeded with Alfalfa: Lab Project
Number: GR97-258: 97258-1: 97258-2. Unpublished study prepared by Grayson
Research, LLC. 392 p. {OPPPTS 860.1500}
177
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45288706 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt to Rangeland Grass: Lab Project Number: GR97-
275: 97275: 97275-1. Unpublished study prepared by Grayson Research, LLC.
317 p. (OPPTS 860.1500}

45288707 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues in Processed
Fractions of Winter Wheat Following Treatment with MCPA Dimethylamine Salt:
Lab Project Number: GR97-271: 97271: 6698-107. Unpublished study prepared
by Grayson Research, LLC. 485 p. {OPPTS 860.1520}

45288708 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Applications
of MCPA 2-Ethylhexyl Ester to Winter Wheat: Lab Project Number: GR97-268:
97268: 6698-117. Unpublished study prepared by Grayson Research, LLC. Slip.
{OPPTS 860.1500}

45288709 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA 2-Ethylhexyl Ester to Spring Wheat: Lab Project Number: GR97-270:
6698-119: 6698-107. Unpublished study prepared by Grayson Research, LLC. 464
p. {OPPTS 860.1500}

45288710 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA 2-Ethylhexyl Ester to Pasture Grass: Lab Project Number: GR97-274:
97274: 97274-1. Unpublished study prepared by Grayson Research, LLC. 368 p.
{OPPTS 860.1500}

45288711 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA 2-Ethylhexyl Ester to Rangeland Grass: Lab Project Number: GR97-276:
97276: 97276-1. Unpublished study prepared by Grayson Research, LLC. 334 p.
{OPPTS 860.1500}

45288712 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA 2-Ethylhexyl Ester to Wheat Underseeded with Alfalfa: Lab Project
Number: G97-266: 6698-110: 6698-107. Unpublished study prepared by Grayson
Research, LLC. 288 p. {OPPTS 860.1500}

45288713 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues in Processed
Fractions of Winter Wheat Following Treatment with MCPA 2-Ethylhexyl Ester:
Lab Project Number: GR97-272: 97272: 97272-1. Unpublished study prepared by
Grayson Research, LLC. 484 p. {OPPTS 860.1520}

45549601 Eberhard, J. (2001) Final Report: Freezer Storage Stability Study for MCPA
DMAS, 4-Chloro-2-hydroxymethylphenoxyacetic Acid (2-HMCPA) and 4-
Chloro-2-carboxyphenoxyacetic Acid (CCPA) and MCPA 2-EHE in Selected
178
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Plant Matrices: Lab Project Number: 6698-122. Unpublished study prepared by
Covance Laboratories Inc. 1353 p. (OPPTS 860.1380}

45595301 Hardwick, T. (1999) (Carbon-14)-MCPA: Absorption and Excretion in the Beagle
Dog: Final Report: Lab Project Number: 729/197: 729/197-D1141. Unpublished
study prepared by Covance Laboratories Ltd. 148 p. {OPPTS 870.7485}

45595302 Hardwick, T. (2000) (Carbon-14)-MCPA: Metabolite Profiles in the Beagle Dog:
Amended Final Report: Lab Project Number: 729/201: 729/201-D1141.
Unpublished study prepared by Covance Laboratories Ltd. 78 p.

45763101 Barney, W. (2002) Magnitude of MCPA and Metabolite Residues From Application
of MCPA Dimethylamine Salt, MCPA 2-Ethylhexyl Ester and MCPA Acid to
Spring Wheat in Haywood, Manitoba: Lab Project Number: GR01-394: 01-394.1:
01-394. Unpublished study prepared by Grayson Research, LLC., Enviro-Test
Laboratories, Inc. and ICMS, Inc. 520 p. {OPPTS 860.1500}

45763102 Barney, W. (2002) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt, MCPA 2-Ethylhexyl Ester and MCPA Acid to
Spring Wheat in Elm Creek, Manitoba: Lab Project Number: GR01-413: 01-413.1:
01-413. Unpublished study prepared by Grayson Research, LLC., Enviro-Test
Laboratories, Inc. and Ag-Quest, Inc. 515 p. {OPPTS 860.1500}

45763103 Barney, W. (2002) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt, MCPA 2-Ethylhexyl Ester and MCPA Acid to
Spring Wheat in Barnwell, Alberta: Lab Project Number: GR01-414: 01-414.1: 01-
414. Unpublished study prepared by Grayson Research, LLC., Enviro-Test
Laboratories, Inc. and Ag-Quest, Inc. 522 p. {OPPTS 860.1500}

45763104 Barney, W. (2002) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt, MCPA 2-Ethylhexyl Ester and MCPA Acid to
Spring Wheat in Fairview, Alberta: Lab Project Number: GR01-415: 01-415.1:
02GRY17.REP. Unpublished study prepared by Grayson Research, LLC., Enviro-
Test Laboratories, Inc. and Three Links Ag Research. 502 p. {OPPTS 860.1500}

45763106 MCPA Task Force Three (2002) Summary Comparison of 1998 and 2001
Magnitude of Residue Results. Unpublished study. 19 p. {OPPTS 860.1500}
179
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45889301 Pigott, G. (2003) MCPA and Testicular Toxicity. Unpublished study prepared by
MCPA Task Force Three. 7 p.

46276101 Mellert, W.; Deckardt, K.; Kuttler, K.; *et. al. (2004) MCPA and CCPA:
Repeated Dose Toxicity Study in Wistar Rats: Administration in the Diet Over 4
Weeks. Project Number: 30C0288/03019, 01Y0288/038009, PCP02751.
Unpublished study prepared by BASF Aktiengesellschaft and BASF Ag Research
Station (Basf Aktieng). 329 p.

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Higham, J.W.; Feeny, R.W.; Cheston, K.G.; Snyder, E.H.; Wingfield, C.B. (1975)
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40019202 Grimes, J. (1986) MCPA Dimethylamine Salt: An Acute Oral Toxicity Study with
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40062004 Ward, T. (1986) Static Acute Toxicity of Technical MCPA Dimethyl- amine Salt (2-
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40352101 Jeffrey, M. (1987) MCP Amine Herbicide: Dermal Sensitization Poten- tial in the
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40555803 Grimes, J.; Jaber, M. (1988) MCPA Dimethylamine Salt (2-Methyl-4-
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41800905 Bowman, J.; Gormley, M. (1990) Acute Flow-through Toxicity of Rhomene
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38528. Unpublished study prepared by Analytical Bio-Chemistry Laboratories, Inc.
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41800906 Burgess, D. (1990) Acute Flow-Through Toxicity of Rhomene (MCPA DMA) to
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42113103 Holbert, M. (1991) Acute Inhalation Toxicity Study in Rats: Clean Crop MCP
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42134201 Silvoy, J. (1991) MCPA-Dimethylamine Salt Field Dissipation Terrestrial Study on
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88-43-01-18D-01. Unpublished study prepared by Hazleton Labs America, Inc., in
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42150301 Hoxter, K.; Lynn, S. (1991) MCPA DMAS: An Acute Contact Toxicity Study with
the Honey Bee: Lab Project Number: 222-102. Unpublished study prepared by
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42412201 Putt, A. (1992) MCPA DMAS-Acute Toxicity to Daphnids (Daphnia magna)
under Flow-through Conditions: Final Report: Lab Project Number: 92-4-4235:
10566.0391.6196.115. Unpublished study prepared by Springborn Laboratories,
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42457101 Chang, J. (1992) Special Study: Dissociation of MCPA DMAS in Water: Final
Report: Lab Project Number: SC920051. Unpublished study prepared by Battelle.
40 p.

42461301 Hoberg, J. (1992) MCPA-DMAS-Toxicity to the Freshwater Green Alga,
Selenastrum capricornutum: Final Report: Lab Project Number: 92-6-4285:
10566.1191.6213.430. Unpublished study prepared by Springborn Labs, Inc. 68 p.

42596903 Fernando, T. (1992) Sorption/Desorption of (carbon 14)-MCPA Acid on Soils by
the Batch Equilibrium Method: Lab Project Number: SC910081. Unpublished study
prepared by Bettelle Memorial Institute. 78 p.

42624401 Jones, E.; Kitching, J.; Anderson, A.; et al. (1992) Ames Salmonella Typhimurium
Bacterial Reverse Mutation Assay on MCPA DMAS: Lab Project Number: JEL
24/921053. Unpublished study prepared by Huntingdon Research Centre Ltd. 44 p.

42624402 Munk, R; Kirsch, P. (1992) Acute Toxicity Study on the Bluegill (Lepomis
macrochirus RAF.) of MCPA DMAS in a Static System: Lab Project Number:
14F0189/915055. Unpublished study prepared by BASF Aktiengesellschaft. 38 p.

42669304 Maggi, V. (1993) Tier II: The Effects of MCPA DMAS on Nontarget Plants:
Vegetative Vigor: A Supplement: Lab Project Number: CAR 146-91C: 1147.
Unpublished study prepared by California Agricultural Research, Inc. 163 p.

42698701 Maggi, V. (1993) The Effects of MCPA DMAS on Nontarget Plants: Seed
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91F: 1145. Unpublished study prepared by California Agricultural Research, Inc.
299 p.

42853502 Proudlock, R.; Taylor, K.; Anderson, A.; et al. (1993) MCPA DMAS Mcronucleus
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183
-------
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42853505 Akhurst, L.; King, 1; Anderson, A.; et al. (1993) MCPA DMAS Metaphase
Chromosome Analysis of Human Lymphocytes Cultured in vitro: Lab Project
Number: JEL 30/921176. Unpublished study prepared by Huntingdon Research
Centre Ltd. 45 p.

43083206 Hoberg, J. (1993) MCPA-DMA Salt-Toxicity to the Marine Diatom, Skeletonema
costatum: Lab Project Nos. 10566.0493.6298.450; 93-11-5029. Unpublished
study prepared by Springborn Laboratories, Inc. 70 p.

43083207 Hoberg, J. (1993) MCPA-DMA Salt-Toxicity to the Freshwater Diatom, Navicula
pelliculosa: Final Report: Lab Project Number: 10566.0493.6291.440: 93-6-4835.
Unpublished study prepared by Springborn Laboratories, Inc. 68 p.

43083208 Hoberg, J. (1993) MCPA-DMA Salt-Toxicity to the Freshwater Blue-Green Alga,
Anabaena flos-aquae: Final Report: Lab Project Number: 10566.0493.6295.420:
93-6-4841. Unpublished study prepared by Springborn Laboratories, Inc. 66 p.

43083210 Bettencourt, M. (1993) MCPA-DMA Salt-Acute Toxicity to Sheepshead Minnow
(Cyrinodon variegatus) under Flow-through Conditions: Final Report: Lab Project
Number: 10566.0493.6276. 505: 93-7-4859. Unpublished study prepared by
Springborn Laboratories, Inc. 73 p.

43126502 Hoberg, J. (1994) MCPA-DMA Salt: Toxicity to Duckweed, Lemna gibba: Final
Report: Lab Project Number: 93/11/5046: 10566/0493/6289/410. Unpublished
study prepared by Springborn Lab., Inc. 72 p.

43227201 Dyer, I. (1994) MCPA DMA 750 g/I Al-Product Chemistry: Lab Project Number:
AHM/EPA/93/ID/05. Unpublished study prepared by A H Marks & Co., Ltd. 37 p.
43227202 A. H. Marks & Co., Ltd. (1994) MCPA DMA 750 g/I AI-Beginning Materials
Data Sheets and A H Marks' Purchase Specifications: Lab Project Number:
AHM/EPA/93/ID/05. Unpublished study. 26 p.

43227203 A. H. Marks & Co., Ltd. (1994) A H Marks' Standard Analytical Methods: MCPA
DMA 750: Lab Project Number: AHM/EPA/93/ID/05. Unpublished study. 32 p.
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43227206 Sydney, P. (1993) Formulation of MCPA Dimethylamine Salt Containing 750 g/1:
Determination of Physico-chemical Properties: Final Report: Lab Project Number:
93/0995: AMS/044: 93/AMS044/0995. Unpublished study prepared by Pharmaco-
LSRLtd. 68 p.

43257901 Maggi, V. (1994) Tier II: The Effects of MCPA DMAS on Nontarget Plants:
Seedling Emergence (MRID No. 426987-01): Supplemental Report to the Final
Report #CAR 146-91F: Lab Project Number: CAR 195-93. Unpublished study
prepared by California Agricultural Research, Inc. and EPL Bio-Analytical Services,
Inc. 96 p.

43556802 Hellwig, J.; Bachmann, S.; Deckardt, K.; et al. (1995) MCPA-DMA Salt-
Subchronic Oral Toxicity Study in Beagle Dogs: Administration in the Diet: Lab
Project Number: 31D0385/91115. Unpublished study prepared by BASF
Aktiengesellschaft. 407 p.

43556902 Kirsch, P.; Deckardt, K.; Gembardt, C.; et al. (1995) Study of the Dermal Toxicity
of MCPA-DMA Salt in Wistar Rats: Application to the Intact Skin (21 Application):
Lab Project Number: 37H0385/91147. Unpublished study prepared by BASF
Aktiengesellschaft. 165 p.

43562701 Mellert, W.; Deckardt, K.; Kaufmann, W.; et al. (1994) MCPA-DMA Salt-
Subchronic Oral Dietary Toxicity and Neurotoxicity Study in Wistar Rats: Lab
Project Number: 50C0189/91140. Unpublished study prepared by BASF
Aktiengesellschaft. 680 p.

43562702 Mellert, W.; Kaufmann, W.; Hildebrand, B. (1994) MCPA-DMA Salt-Acute Oral
Neurotoxicity Study in Wistar Rats: Lab Project Number: 20S0189/91112.
Unpublished study prepared by BASF Aktiengesellschaft. 405 p.

43580301 Sabourin, P. (1995) Nature of the Residue of (carbon 14)-2- Methyl-4-
chlorophenoxyacetic Acid ((carbon 14)-MCPA) as the Dimethylamine Salt ((carbon
14)-MCPA DMA) and the 2-Ethylhexyl Ester ((carbon 14)-MCPA 2-EHE) in
Wheat: Final Report: Lab Project Number: SC930053. Unpublished study prepared
byBattelle. 318 p.

43697501 Singer, G. (1995) Terrestrial Field Dissipation of MCPA Dimethylamine Salt
Following Ground Application to Wheat and Bareground: Lab Project Number:
185
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AA940507: 6576-100A: HWI 6576-100A. Unpublished study prepared by
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43718401 Honey curt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA Dimethylamine Salt to Winter Wheat: Final Version: Lab
Project Number: 93-211RA-1: 94019: 94018. Unpublished study prepared by
Hazard Evaluation & Regulatory Affairs Co., Inc. 502 p.

43756401 Honeycutt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA Dimethylamine Salt to Spring Wheat: Final Report: Lab
Project Number: 93-211RA-3: 95-503: 5-TW1. Unpublished study prepared by
Quality Management & Analytical Services, Inc. and Hazard Evaluation &
Regulatory Affairs Co., Inc. 403 p.

43788201 Hoberg, J. (1995) MCPA-DMA Salt-Determination of Effects on Vegetative Vigor
of Five Plant Species: Lab Project Number: 13539.1294.6101.610: 95-5-5878.
Unpublished study prepared by Springborn Labs, Inc. 142 p.

43791901 Honeycutt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA Dimethylamine Salt to Pasture Grass: Lab Project Number:
93-211RA-7: 95-507: 95025. Unpublished study prepared by Hazard Evaluation &
Regulatory Affairs Co., Inc. and Quality Management & Analytical Services, Inc.
736 p.

43793901 Honeycutt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA Dimethylamine Salt to Spring Wheat Underseeded with
Alfalfa: Lab Project Number: 95-509: 93-211RA-9: 94027. Unpublished study
prepared by Hazard Evaluation & Regulatory Affairs Co., Inc. and Quality
Management & Analytical Services, Inc. 814 p.

43801301 Honeycutt, R; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA Dimethylamine Salt to Rangeland Grass, Ground Application:
Lab Project Number: 95-511: 93-211RA-11: QMAS 94029. Unpublished study
prepared by Hazard Evaluation & Regulatory Affairs Co., Inc. and Quality
Management & Analytical Services, Inc. 689 p.

43841501 Honeycutt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues in Processed
Fractions of Winter Wheat Following Treatment with MCPA Dimethylamine Salt:
Lab Project Number: 93-211RA-5: 95-505: 94023. Unpublished study prepared by
Hazard Evaluation & Regulatory Affairs Co., Inc. and Texas A&M University. 779
P-

43883001 Hatfield, M. (1995) Terrestrial Field Dissipation of MCPA Dimethylamine Salt
186
-------
Following Ground Application to Turfgrass and Bareground: Lab Project Number:
AA940509: 12-9406: 6576-100D. Unpublished study prepared by American
Agricultural Services, Inc.; Minnesota Valley Testing Lab; and Corning Hazleton Inc.
2381 p.

44026801 Fleming, P. (1996) Freezer Storage Stability For MCPA 2-EHE, MCPA, and
Major Metabolites in Soil: Lab Project Number: 12-9410: RAM-10-047.
Unpublished study prepared by Minnesota Valley Testing Laboratories, Inc. 139 p.

44407201 Drottar, K.; Krueger, H. (1997) MCPA DMAS: A Flow-Through Life-Cycle
Toxicity Test with the Cladoceran (Daphnia magna): Lab Project Number: 364A-
101. Unpublished study prepared by Wildlife International Ltd. 92 p. (OPPTS
850.1300}

44407202 Drottar, K.; Krueger, H. (1997) MCPA DMAS: An Early Life-Stage Toxicity Test
with the Fathead Minnow (Pimephales promelas): Lab Project Number: 364A-102.
Unpublished study prepared by Wildlife International Ltd. 121 p. {OPPTS
850.1400}

44484501 Ohnsorge, U. (1997) Product Chemistry: Product Identity and Composition,
Beginning Materials and Manufacturing Process, and Discussion of the Formation of
Impurities of MCPA-DMA 750g/L MP: Lab Project Number: 97/11248.
Unpublished study prepared by BASF Aktiengesellschaft. 60 p. {OPPTS 830.1550,
830.1600, 830.1650, 830.1670}

44484502 Ohnsorge, U. (1997) Product Chemistry: Certified Limits and Analytical Method for
MCPA-DMA 750g/L MP: Lab Project Number: 97/11206: CF-A 491: 94/11730.
Unpublished study prepared by BASF Aktiengesellschaft. 53 p. {OPPTS
830.1750}

44484503 Kaestel, R. (1997) Product Chemistry: Color, Physical State, Odor, Boiling Point,
Density, pH, Flammability, Storage Stability, and Viscosity for MCPA-DMA
750g/L MP (BAS 141 24H): Lab Project Number: 97/11068: PCF 01842.
Unpublished study prepared by BASF Aktiengesellschaft. 20 p.
187
-------
44484504 Loeffler, U. (1997) Product Chemistry: Flammability for MCPA-DMA 750g/L MP
(BAS 141 24H): Lab Project Number: 97/11327: SIK-NR. 97/1859. Unpublished
study prepared by BASF Aktiengesellschaft. 8 p.

44484505 Kaestel, W. (1994) Product Chemistry: Shelf Life in Original Container (Storage
Stability) for MCPA-DMA 550g/L EP (BAS 010 01H): Lab Project Number:
97/10380: PCF01468: PCF 01468. Unpublished study prepared by BASF
Aktiengesellschaft. 31 p.

44484506 Koenig, W. (1994) Product Chemistry: Storage Stability for MCPA-DMA 550g/L
EP (BAS 010 01H): Lab Project Number: 97/10004: PCF 01467. Unpublished
study prepared by BASF Aktiengesellschaft. 12 p.

44535801 McKerlie, L. (1998) BAS 141 24H: Determination of Oxidizing or Reducing Action:
Lab Project Number: 97221: FR9759: 97/5431. Unpublished study prepared by
BASF Corp. 14 p. (OPPTS 830.6314}.

44535802 Cannan, T. (1998) BAS 141 24H: Determination of Corrosion Characteristics: Lab
Project Number: 97210: FR9805: 98/5016. Unpublished study prepared by BASF
Corp. 12 p. {OPPTS 830.6320}

44732401 Bashir, M. (1998) Aerobic Aquatic Metabolism of (carbon-14)-4-Chloro-2-
Methylphenoxyacetic Acid Dimethylamine Salt: Lab Project Number: 6698-106.
Unpublished study prepared by Covance Laboratories Inc. 134 p. {OPPTS
835.4300}

44903501 Drottar, K.; Krueger, H. (1999) MCPA DMAS: A 14-Day Toxicity Test With
Duckweed (Lemna gibba G3): Final Report: Lab Project Number: 364A-103:
364/040798/LEM14DR/SUB364. Unpublished study prepared by Wildlife
International Ltd. 72 p.

44903502 Palmer, S.; Kendall, T.; Kreuger, H. (1999) MCPA DMAS: A 5-Day Toxicity Test
With the Freshwater Alga (Selenastrum capricornutum): Lab Project Number:
364A-104: 364/102798/SEL5D2WC/SUB364. Unpublished study prepared by
Wildlife International Ltd. 80 p. {OPPTS 850.5400}

44903503 Palmer, S.; Kendall, T.; Kreuger, H. (1999) MCPA DMAS: A 5-Day Toxicity Test
With the Freshwater Alga (Anabaena flos-aquae): Final Report: Lab Project
Number: 364A-105B: 364/102798/ANA5D2WC/SUB364. Unpublished study
188
-------
prepared by Wildlife International Ltd. 81 p. (OPPTS 850.5400}

44903504 Palmer, S.; Kendall, T.; Kreuger, H. (1999) MCPA DMAS: A 5-Day Toxicity Test
With the Freshwater Diatom (Navicula pelliculosa): Final Report: Lab Project
Number: 364A-106A: 364/102798/NAV5D2WC/SUB364. Unpublished study
prepared by Wildlife International Ltd. 82 p.

44903505 Palmer, S.; Kendall, T.; Kreuger, H. (1999) MCPA DMAS: A 5-Day Toxicity Test
With the Marine Diatom (Skeletonema costatum): Final Report: Lab Project
Number: 364A-107: 364/102798/SKE5D2WC/SUB364. Unpublished study
prepared by Wildlife International Ltd. 82 p. {OPPTS 850.5400}

44954102 Cappon, G. (1999) A Prenatal Developmental Toxicity Study of MCPA-DMA in
Rats: Final Report: Lab Project Number: WIL-325003. Unpublished study prepared
by WIL Research Laboratories, Inc. 464 p. {OPPTS 870.3700} Relates to
L0000410.

45033101 Hughes, D.; Bomkamp, D. (2000) Determination of Transferable Turf Residues on
Turf Treated with 2,4-D, MCPA DMA, 2,4-D DMA + MCPP-p DMA + Dicamba
DMA and MCPA DMA + MCPP-p DMA + 2,4-DP-p DMA: Lab Project
Number: BTH TFR TF 003: 6926-105. Unpublished study prepared by Covance
Laboratories. 394 p. {OPPTS 875.2100}

45288701 Morrissey, M.; Eberhard, J. (2000) Independent Laboratory Validation of a Method
for the Determination of 4-Chloro-2-methylphenoxyacetic Acid 2-Ethylhexyl Ester
(MCPA 2-EHE) and 4-Chloro-2-methylphenoxyacetic Acid Dimethylamine Salt
(MCPA DMAS) as their 4-Chloro-2-methylphenoxyacetic Acid (MCPA)
Equivalent, MCPA, 4-Chloro-2-hydroxymethylphenoxyacetic Acid (HMCPA), 4-
Chloro-2-hydroxymethylphenoxyacetic Acid Glucose Conjugate (HMCPA GLU) as
its HMCPA Equivalent, and 4-Chloro-2-carboxyphenoxyacetic Acid (CCPA) in
Wheat Forage, Straw, and Grain: Final Report: Lab Project Number: 6698-108:
6698-107. Unpublished study prepared by Covance Laboratories Inc. 449 p.

45288703 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt to Spring Wheat: Lab Project Number: GR97-269:
6698-107: 6698-118. Unpublished study prepared by Grayson Research, LLC. 445
p. {OPPTS 860.1500}
189
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45288704 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt to Pasture Grass: Lab Project Number: GR97-273:
6698-111: QMAM94002. Unpublished study prepared by Grayson Research,
LLC. 361 p. (OPPTS 860.1500}

45288706 Kludas, R. (2000) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt to Rangeland Grass: Lab Project Number: GR97-
275: 97275: 97275-1. Unpublished study prepared by Grayson Research, LLC.
317 p. {OPPTS 860.1500}

45312201 Mayer, P.; Oldersma, H.; Hanstveit, A. (2000) Determination of the Effect of
MCPA DMAS on the Growth of the Fresh Water Green Alga Selenastrum
capricornutum: Lab Project Number: 00-2317/01: V2317/01. Unpublished study
prepared by TNO Nutrition and Food Research. 39 p. {OPPTS 850.5400}.

45480901 Brown, A. (2001) MCPA-DMA 750g/L: One Year Shelf-Life Storage Stability and
Corrosion Characteristics in Commercial Type Containers: Final Report: Lab Project
Number: MI-0011. Unpublished study prepared by Micro Flo Company. 8 p.
{OPPTS 830.6317 and 830.6320}

45503801 Mayer, P.; Oldersma, H.; Hanstveit, A. (2001) Determination of the Effect of
MCPA DMAS on the Growth of the Fresh Water Green Alga Selenastrum
capricornutum: Addendum: Lab Project Number: ALGENTOX/180400: 00-
2317/01: TNO RPT V2317/01. Unpublished study prepared by Nufarm (UK) Ltd.
43 p.

45549601 Eberhard, J. (2001) Final Report: Freezer Storage Stability Study for MCPA
DMAS, 4-Chloro-2-hydroxymethylphenoxyacetic Acid (2-HMCPA) and 4-
Chloro-2-carboxyphenoxyacetic Acid (CCPA) and MCPA 2-EHE in Selected
Plant Matrices: Lab Project Number: 6698-122. Unpublished study prepared by
Covance Laboratories Inc. 1353 p. {OPPTS 860.1380}

45554403 Kranzfelder, J. (2000) Toxicity of MCPA DMAS to the Unicellular Green Alga,
Selenastrum capricornutum, Determined Under Static Test Conditions: Lab Project
Number: 45963. Unpublished study prepared by ABC Laboratories, Inc. 61 p.

45763101 Barney, W. (2002) Magnitude of MCPA and Metabolite Residues From.Application
of MCPA Dimethylamine Salt, MCPA 2-Ethylhexyl Ester and MCPA Acid to
190
-------
Spring Wheat in Haywood, Manitoba: Lab Project Number: GR01-394: 01-394.1:
01-394. Unpublished study prepared by Grayson Research, LLC., Enviro-Test
Laboratories, Inc. and ICMS, Inc. 520 p. (OPPTS 860.1500}

45763105 Barney, W. (2002) Magnitude of MCPA and Metabolite Residues from Application
of MCPA Dimethylamine Salt, MCPA 2-Ethylhexyl Ester and MCPA Acid to
Spring Wheat in Rosthern, Saskatchewan: Lab Project Number: GR01-416: 01-
416.1: 02GRY18.REP. Unpublished study prepared by Grayson Research, LLC.,
Ag Quest, Inc. and Enviro-Test Laboratories, Inc. 583 p. {OPPTS 860.1500}
PC Code 030564
MRID
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AG. 42 p.

156459 Ullmann, L. (1985) Acute Dermal Toxicity (LD50) Study with CL 8808/7 CE in
Rats: Report: Project 042006. Unpublished study prepared by Research &
Consulting Co. AG. 23 p.

156460 Ullmann, L. (1985) 4-Hour Acute Aerosol Inhalation Toxicity (LC50) Study with
191
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CL 8808/7 CE in Rats: Report: Project 042017. Unpub- lished study prepared by
Research & Consulting Co. AG. 35 p.

156522 Ullmann, L. (1985) Primary Eye Irritation Study with CL 8808/7 CE i Rabbits:
Report: Project 053583. Unpublished study prepared by Research & Consulting Co.
AG. 30 p.

42853506 Akhurst, L.; King, J.; Anderson, A.; et al. (1993) MCPA 2-EHE Metaphase
Chromosome Analysis of Human Lymphocytes Cultured in vitro: Lab Project
Number: JEL 31/921188. Unpublished study prepared by Huntingdon Research
Centre Ltd. 45 p.

42860102 Adams, K.; Henly, S.; Anderson, A.; et al. (1993) Chinese Hamster Ovary/HGPRT
Locus Assay: MCPA 2-EHE: Final Report: Lab Project Number: JEL 28/921114.
Unpublished study prepared by Huntingdon Research Centre Ltd. 42 p.

42870001 Jones, E.; Kitching, J.; Anderson, A.; et al. (1993) Ames Salmonella typhimurium
Bacterial Reverse Mutation Assay on MCPA 2-EHE: Final Report: Lab Project
Number: JEL 25/921054. Unpublished study prepared by Huntingdon Research
Centre Ltd. 44 p.

43083211 Hoberg, J. (1993) MCPA-2EH Ester Technical-Toxicity to the Freshwater Diatom,
Navicula pelliculosa: Final Report: Lab Project Number: 10566.0493.6293.440: 93-
10-4993. Unpublished study prepared by Springborn Laboratories, Inc. 68 p.

43083212 Hoberg, J. (1993) MCPA-2EH Ester Technical-Toxicity to the Marine Diatom,
Skeletonema costatum: Final Report: Lab Project Number: 10566.0493.6299.450:
93-10-4982. Unpublished study prepared by Springborn Laboratories, Inc. 69 p.

43083213 Hoberg, J. (1993) MCPA-2EH Ester Technical-Toxicity to the Freshwater Blue-
Green Alga, Anabaena flos-aquae: Final Report: Lab Project Number:
10566.0493.6296.420: 93-9-4939. Unpublished study prepared by Springborn
Laboratories, Inc. 64 p.

43083214 Hoberg, J. (1993) MCPA-2EH Ester Technical-Toxicity to Duckweed, Lemna
gibba: Final Report: Lab Project Number: 10566.0493.6290. 410: 93-10-4976.
Unpublished study prepared by Springborn Laboratories, Inc. 70 p.

43086501 Bettencourt, M. (1993) MCPA-2EH Ester Technical-Acute Toxicity to Sheepshead
Minnow (Cyprinodon variegatus) under Flow-through Conditions: Final Report: Lab
Project Number: 93/9/4928. Unpublished study prepared by Springborn
Laboratories, Inc. 66 p.

43129310 Dinwoodie, N. (1993) MCPA 2EH Ester Determination of Physical Chemical
192
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Properties: Lab Project Number: IRI351815: 9618. Unpublished study prepared by
Inveresk Research Laboratories. 56 p.

43556701 Mellert, W.; Deckardt, K.; Kaufmann, W.; et al. (1994) MCPA-2-EH Ester-
Subchronic Oral Dietary Toxicity and Neurotoxicity Study in Wistar Rats: Lab
Project Number: 50C0385/91141. Unpublished study prepared by BASF
Aktiengesellschaft. 686 p.

43556702 Mellert, W.; Kaufmann, W.; Hildenbrand, B.; et al. (1994) MCPA-2-EH Ester-
Acute Oral Neurotoxicity Study in Wistar Rats: Lab Project Number:
20S0385/91113. Unpublished study prepared by BASF Aktiengesellschaft. 391 p.

43556801 Hellwig, J.; Bachmann, S.; Deckardt, K.; et al. (1995) MCPA-2-EH-Ester-
Subchronic Oral Toxicity Study in Beagle Dogs: Administration in the Diet: Lab
Project Number: 31D0385/91115. Unpublished study prepared by BASF
Aktiengesellschaft. 398 p.

43 7243 01 Honey curt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA 2-Ethylhexyl Ester to Winter Wheat: (Final Report): Lab
Project Number: 95-502: 93-211RA-2: QMAS 94020. Unpublished study
prepared by Hazard Evaluation & Regulatory Affairs Co., Inc. 507 p.

43 724401 Honey curt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA 2-Ethylhexyl Ester to Spring Wheat: Final Version: Lab
Project Number: 95-504: 93-211RA-4: QMAS 94022. Unpublished study
prepared by Hazard Evaluation & Regulatory Affairs Co., Inc. and Quality
Management & Analytical Services, Inc. 402 p.

43 764101 Honey curt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues in Processed
Fractions of Winter Wheat Following Treatment with MCPA 2-Ethylhexyl Ester:
Lab Project Number: 93-211RA-6: 95-506: 94024. Unpublished study prepared by
Hazard Evaluation & Regulatory Affairs Co., Inc.; Quality Management & Analytical
Services, Inc.; and Texas A&M Univ. 683 p.

43782401 Honeycutt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA 2-Ethylhexyl Ester to Pasture Grass: Lab Project Numbers:
95-508: 93-211RA-8: 94026. Unpublished study prepared by Hazard Evaluation &
193
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Regulatory Affairs Co., Inc. 722 p.

43804601 Honeycutt, R; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA 2-Ethylhexyl Ester to Spring Wheat Underseeded with Alfalfa:
Lab Project Number: 95-510: 93-211RA-10: 94028. Unpublished study prepared
by Hazard Evaluation & Regulatory Affairs Co., Inc. and Quality Management &
Analytical Services, Inc. 814 p.

43 826401 Honeycutt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA 2-Ethylhexyl Ester to Rangeland Grass, Ground Application:
Lab Project Number: 93-211RA-12: 95-512: QMAS 94030. Unpublished study
prepared by Hazard Evaluation & Regulatory Affairs Co., Inc. and Quality
Management & Analytical Services, Inc. 680 p.

43 826402 Honeycutt, R.; DeGeare, M. (1995) Magnitude of MCPA Residues from
Application of MCPA 2-Ethylhexyl Ester to Rangeland Grass, Aerial Application:
Lab Project Number: 93-211RA-13: 95-513: QMAS 94031. Unpublished study
prepared by Hazard Evaluation & Regulatory Affairs Co., Inc. and Quality
Management & Analytical Services, Inc. 413 p.

44914027 Cookinham, J. (1999) Bronate Herbicide Product Chemistry: Lab Project Number:
5605-F. Unpublished study prepared by Midwest Research Institute. 126 p.
{OPPTS 830.1550, 830.1620, 830.1670, 830.1750}

44929001 Sawyer, R. (1999) Product Chemistry: Riverdale MCPA Technical IOE: Lab
Project Number: IOE-MCPA TECHNICAL. Unpublished study prepared by
Riverdale Chemical Co. 4 p.

44954101 Cappon, G (1999) A Prenatal Developmental Toxicity Study of MCPA-2-EHE in
Rats: Final Report: Lab Project Number: WIL-325004. Unpublished study prepared
194
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by WIL Research Laboratories, Inc. 447 p. (OPPTS 870.3700} Relates to
L0000410.

45173401 Sawyer, R. (1999) Product Chemistry: Riverdale MCPA Technical IOE.
Unpublished study prepared by Riverdale Chemical Company. 8 p.

45288701 Morrissey, M.; Eberhard, J. (2000) Independent Laboratory Validation of a Method
for the Determination of 4-Chloro-2-methylphenoxyacetic Acid 2-Ethylhexyl Ester
(MCPA 2-EHE) and 4-Chloro-2-methylphenoxyacetic Acid Dimethylamine Salt
(MCPA DMAS) as their 4-Chloro-2-methylphenoxyacetic Acid (MCPA)
Equivalent, MCPA, 4-Chloro-2-hydroxymethylphenoxyacetic Acid (HMCPA), 4-
Chloro-2-hydroxymethylphenoxyacetic Acid Glucose Conjugate (HMCPA GLU) as
its HMCPA Equivalent, and 4-Chloro-2-carboxyphenoxyacetic Acid (CCPA) in
Wheat Forage, Straw, and Grain: Final Report: Lab Project Number: 6698-108:
6698-107. Unpublished study prepared by Covance Laboratories Inc. 449 p.

45763101 Barney, W. (2002) Magnitude of MCPA and Metabolite Residues From Application
of MCPA Dimethylamine Salt, MCPA 2-Ethylhexyl Ester and MCPA Acid to
195
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Spring Wheat in Haywood, Manitoba: Lab Project Number: GR01-394: 01-394.1:
01-394. Unpublished study prepared by Grayson Research, LLC., Enviro-Test
Laboratories, Inc. and ICMS, Inc. 520 p. (OPPTS 860.1500}

45804401 Hale, M. (2002) MCPA 2EH Technical: Product Chemistry: Product Identity and
Composition: Lab Project Number: USA/MCPA 2EH/MCPA 2EHVOL1.
Unpublished study prepared by A.H. Marks and Company Ltd. lip. {OPPTS
830.1550}

45804402 Hale, M. (2002) MCPA 2EH Technical: Product Chemistry: Description of
Materials Used to Produce the Product: Lab Project Number: USA/MCPA
2EH/MCPA 2EHVOL2. Unpublished study prepared by A.H. Marks and
Company Ltd. 58 p. {OPPTS 830.1600}

45804403 Hale, M. (2002) MCPA 2EH Technical: Product Chemistry: Description of
Production Process: Lab Project Number: USA/MCPA 2EH/MCPA 2EHVOL3:
553: 552. Unpublished study prepared by A.H. Marks and Company Ltd. 60 p.
{OPPTS 830.1620}
196
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45804404 Hale, M. (2002) MCPA 2EH Technical: Product Chemistry: Discussion of
Formation of Impurities: Lab Project Number: USA/MCPA 2EH/MCPA 2EH
VOL4. Unpublished study prepared by A.H. Marks and Company Ltd. 12 p.
(OPPTS 830.1670}

45804405 Hale, M. (2002) MCPA 2EH Technical: Product Chemistry: 5 Batch Analysis Study
Report: Lab Project Number: USA/MCPA 2EH/MCPA 2EH VOL5: 00/0124.
Unpublished study prepared by A.H. Marks and Company Ltd. 123 p.

45804406 Hale, M. (2002) MCPA 2EH Technical: Product Chemistry: Preliminary Analysis,
Certified Limits, Enforcement Analytical Method: Lab Project Number: USA/MCPA
2EH/MCPA 2EHVOL6: AHM 00/MCPA 2EH: 322. Unpublished study prepared
by AH. Marks and Company Ltd. 48 p. {OPPTS 830.1700, 830.1750,
830.1800}
197
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Appendix E. Generic Data Call-In

A Data Call-In (DCI), with all pertinent instructions, was sent to registrants in March 2006 under
separate cover.
198
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Appendix F. Product-Specific Data Call-In

A Data Call-In (DCI), with all pertinent instructions, was sent to registrants in March 2006 under
separate cover.
199
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Appendix G. EPA'S Batching of MCPA 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 station of products containing MCPA 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 lexicological 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 lexicological 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
200
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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 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.

One hundred seventy three products were found which contain MCPA as the active ingredient.
These products have been placed into 4 sections: MCPA Acids (PC Code 030501 - contains 34
products placed in 6 batches and a No Batch group); MCPA Sodium Salts (PC Code 030502 -
contains 5 products placed in 1 batch and a No Batch group); MCPA Amine Salts (PC Code 030516
- contains 90 products placed in 16 batches and a No Batch group); MCPA 2-ethylhexyl ester (PC
Code 030564 - contains 44 products placed in 5 batches and a No Batch group). All were placed in
these batches in accordance with the active and inert ingredients and type of formulation. Two esters
from acid and sodium salt groups (EPA Reg. Nos. 2217-873 & 62719-8) have been batched with other
esters. Furthermore, the following bridging strategies are deemed acceptable for this chemical:

MCPA Acids:
Batch 2 - EPA Reg. No. 2217-722 may not cite data from EPA Reg. No. 2217-821.
Batch 3 - EPA Reg. No. 2217-750 may not cite data from EPA Reg. No. 2217-784.
Batch 6 - EPA Reg. Nos. 228-300 & 2217-822 may not cite data from EPA Reg. Nos. 228-
301,2217-798, & 2217-799.

MCPA Amine Salts:
Batch 1 - EPA Reg. Nos. 11685-23 & 15440-27 may not cite data from EPA Reg. No. 228-
290.
Batch 8 - EPA Reg. No. 228-349 may not cite data from EPA Reg. No. 228-350.
Batch 9 - EPA Reg. No. 228-269 may not cite data from EPA Reg. Nos. 228-270 or 228-330.
Batch 10 - EPA Reg. No. 228-324 may not cite data from EPA Reg. No. 228-326.
Batch 12 - EPA Reg. Nos. 228-219 & 228-225 may not cite data from EPA Reg. No. 228-
226.
Batch 13 - EPA Reg. No. 228-229 may not cite data from EPA Reg. No. 228-224.
Batch 14 - EPA Reg. No. 228-272 may not cite data from 2217-792.
Batch 15 - EPA Reg. Nos. 228-286, 228-229, & 228-327 may not cite data from 228-304.
201
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All sections: No Batch: All products in each of the No Batch groups should generate their own data.
NOTE: The technical acute toxicity values included in this document are for informational purposes only.
The data supporting these values may or may not meet the current acceptance criteria.
MCPA ACIDS (PC Code 0305011
Batch 1

EPA Res. No.

11685-13

11685-14

11685-22

15440-7

15440-21

35935-8
35935-9

62719-60

67591-2

70596-1
% Active Ingredient

94.0

96.0

95.0

94.0

95.0
95.0

96.6

95.0

96.6
Batch 2
EPA Reg. No.
% Active Ingredient
2217-722
MCPA: 45.59
MCPP: 10.20
Dicamba: 4.30
202
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Batch 2

EPA Reg. No.
2217-821
% Active Ingredient
MCPA: 45.00
MCPP: 9.00
Dicamba: 4.50

Batch 3

EPA Reg. No.
2217-750
2217-784
% Active Ingredient
MCPA acid: 32.43
MCPP: 7.26
Dicamba: 3.06
MCPA acid: 32.43
MCPP: 6.48
Dicamba: 3.24
Batch 4

EPA Reg. No.
5905-510
11685-20
62719-58
% Active Ingredient
23.7
24.0
23.7
Batch 5

EPA Res. No.

538-160

538-218

% Active Ingredient

MCPA: 1.37
MCPP: 1.37
MCPA: 1.37
MCPP: 1.37
203
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Batch 5

EPA Reg. No.
538-222
9198-198
% Active Ingredient
MCPA: 1.37
MCPP: 1.37
MCPA: 1.37
MCPP: 1.37
Batch 6

EPA Reg. No.
228-300
228-301
2217-798
2217-799
2217-822
% Active Ingredient
MCPA: 0.820
MCPP: 0.1 65
Dicamba: 0.080
MCPA: 0.630
MCPP: 0.125
Dicamba: 0.060
MCPA: 0.690
MCPP: 0.1 50
Dicamba: 0.060
MCPA: 0.560
MCPP: 0.120
Dicamba: 0.050
MCPA: 0.820
MCPP: 0.330
Dicamba: 0.08
No Batch

EPA Reg. No.
228-199
% Active Ingredient
22.25
204
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No Batch

EPA Reg. No.
228-228
228-285
228-306
2217-873
10404-70
42750-24
62719-8
% Active Ingredient
MCPA: 17.0
MCPP: 8.5
Dichlorrjroo: 8.5
MCPA: 50.0
MCPP: 20.0
Dicamba: 5.0
MCPA: 0.82
MCPP: 0.33
Dicamba: 0.08
MCPA: 43.09
MCPP: 5.64
Carfentrazone-ethyl: 0.50
MCPA: 3 1.50
MCPP: 12.70
Dicamba: 3.30
22.25
23.70
MCPA SODIUM SALTS (PC Code 030502s)
Batch 1

EPA Reg. No.
228-199
5905-510
62719-58
% Active Ingredient
22.25
23.70
23.70
205
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No Batch

EPA Reg. No.
11685-20
42750-24
% Active Ingredient
24.00
22.25
MCPA AMINE SALTS (PC Code 030516s)
Batch 1

EPA Res. No.

228-290
11685-23

15440-27
% Active Ingredient

75.0
77.9

77.8
Batch 2

Batch 3

Batch 4

EPA Reg. No.
34704-130
67591-01

EPA Reg. No.

11685-19
71368-55

EPA Reg. No.
2217-362
% Active Ingredient
52.0
52.0

% Active Ingredient

52.1
52.1

% Active Ingredient
50.37
206
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Batch 4

EPA Reg. No.
5905-502
15440-37
62719-13
% Active Ingredient
52.2
52.1
52.1
Batch 5

EPA Reg. No.
228-143
1381-104
% Active Ingredient
48.58
48.72
Batch 6

EPA Reg. No.
228-271
228-310
% Active Ingredient
MCPA: 10.10
MCPP: 2.00
Dicamba: 0.99
MCPA: 10.10
MCPP: 2.00
Dicamba: 0.99
Batch 7
EPA Reg. No.
% Active Ingredient
228-334
MCPA: 13.72
Triclopyr:1.56
Dicamba: 1.35
207
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Batch 7

Batch 8

EPA Res. No.

228-424

EPA Reg. No.
228-349

228-350
% Active Insredient

MCPA: 13.72
Triclopyr:1.56
Dicamba: 1.35

% Active Ingredient
MCPA: 13.47
Clopvralid:1.45
Dicamba: 1.32
MCPA: 10.78
Clopvralid:1.16
Dicamba: 1.06
Batch 9

EPA Reg. No.
228-269
228-270
228-330
% Active Ingredient
MCPA: 1.01
MCPP: 0.40
Dicamba: 0.09
MCPA: 0.808
MCPP: 0.1 57
Dicamba: 0.079
MCPA: 0.808
MCPP: 0.1 57
Dicamba: 0.060
208
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Batch 10

EPA Reg. No.
228-324
228-325
228-326
% Active Ingredient
MCPA: 1.625
Triclopvr: 0.184
Dicamba: 0.159
MCPA: 1.100
Triclopvr: 0.120
Dicamba: 0.110
MCPA: 0.820
Triclopyr: 0.093
Dicamba: 0.080
Batch 1 1

EPA Reg. No.
2217-730
2217-737
% Active Ingredient
MCPA: 2.093
MCPP: 1.858
Dicamba: 0.412
MCPA: 2.818
MCPP:0.672
Dicamba: 0.313
Batch 12
EPA Reg. No.
% Active Ingredient
228-219
MCPA: 0.416
MCPP: 0.206
2.4-DP: 0.203
209
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Batch 12
EPA Res. No.
% Active Ingredient
228-225
228-226
MCPA:0.318
MCPP:0.314
2.4-DP:0.310
MCPA:0.159
MCPP:0.157
2.4-DP:0.155
Batch 13

EPA Reg. No.
228-224

228-229

% Active Ingredient
MCPA: 0.331
MCPP:0.163
2.4-DP: 0.161
MCPA: 0.416
MCPP:0.411
2.4-DP: 0.405
Batch 14
EPA Reg. No.
% Active Ingredient
228-272
2217-792
MCPA: 0.67
MCPP:0.13
Dicamba: 0.06
MCPA: 0.34
MCPP:0.31
Dicamba: 0.07
210
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Batch 15

EPA Reg. No.
228-286
228-299
228-304
228-327
% Active Ingredient
MCPA: 0.750
MCPP: 0.145
Dicamba: 0.072
MCPA: 0.646
MCPP: 0.255
Dicamba: 0.064
MCPA: 0.404
MCPP: 0.079
Dicamba: 0.036
MCPA: 0.701
MCPP: 0.080
Dicamba: 0.069
Batch 16

EPA Reg. No.
9779-262
42750-14
% Active Ingredient
48.89
48.89

No Batch

EPA Reg. No.
228-204
228-206
% Active Ingredient
MCPA: 3. 31
MCPP: 3.26
DichlororoD: 3.22
MCPA: 17.15
MCPP: 8.47
Dichlorprop: 8.34
211
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No Batch

EPA Reg. No.
228-215
228-217

228-218
228-262
228-266
228-276
228-277
228-279
228-284
228-296
% Active Ingredient
MCPA: 1.65
MCPP: 1.63
DichlororoD: 1.61
MCPA: 4.78
MCPP: 2.36
Dichlororoo: 2.33
MCPA: 1.41
MCPP: 1.39
DichlororoD: 1.37
MCPA: 40.42
MCPP: 7.99
Dicamba: 3.97
MCPA: 14.0
MCPP: 10.0
MCPA: 6.46
MCPP: 2.50
Dicamba: 0.63
MCPA: 3.23
MCPP: 1.28
Dicamba: 0.31
95.5
MCPA: 0.67
MCPP: 0.27
Dicamba: 0.06
MCPA: 32.6
Dicamba: 16.0
212
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No Batch

EPA Reg. No.
228-303
228-313
228-323
228-328
228-333
228-335
228-336
228-351

228-352
% Active Ingredient
MCPA: 1.01
MCPP: 0.40
Dicamba: 0.09
MCPA: 48.99
Triclopyr: 5.59
Dicamba: 4.82
MCPA: 48. 13
Clopyralid: 5.18
Dicamba: 4.73
MCPA: 1.10
Triclopvr: 0.12
Dicamba: 0.11
MCPA: 48. 13
Clopyralid: 2.58
Dicamba: 4.73
MCPA: 10.97
Triclopyr: 1.25
Dicamba: 1.08
MCPA: 0.740
Triclopyr: 0.084
Dicamba: 0.072
MCPA: 0.843
Clopvralid: 0.090
Dicamba: 0.082
MCPA: 0.707
Clopyralid: 0.076
Dicamba: 0.069
213
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No Batch

EPA Reg. No.
228-353
228-371

228-372
228-411

228-419
239-2621
239-2634
432-892
1386-587
% Active Ingredient
MCPA: 1.300
Clopvralid: 0.140
Dicamba: 0.128
MCPA: 37.9
Triclopyr: 3.8
CloDvralid: 1.3
MCPA: 47.77
Clopvralid: 2.53
DichlororoD: 9.54
MCPA: 46.87
Triclopvr: 10.68
Dichlororoo: 9.12
MCPA: 5 1.05
Fluroxypyr: 12.00
Dicamba: 4.17
MCPA: 7.36
MCPP: 13.41
Dicamba: 1.49
MCPA: 0.1 5
MCPP: 0.30
Dicamba: 0.03
MCPA: 34.47
MCPP: 16.35
Dicamba: 3.76
MCPA: 52.2
214
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No Batch

EPA Reg. No.
2217-720
2217-721

2217-729
2217-731

2217-732
2217-733
2217-734
2217-735
2217-736
2217-738
% Active Ingredient
MCPA: 19.07
MCPP: 17.37
Dicamba: 3.85
MCPA: 34.47
MCPP: 8.18
Dicamba: 3.76
MCPA: 38.28
MCPP: 12.60
MCPA: 5.608
MCPP: 1.335
Dicamba: 0.614
MCPA: 7.35
MCPP: 6.71
Dicamba: 1.47
MCPA: 3.77
MCPP: 3.43
Dicamba: 0.76
MCPA: 9.43
MCPP: 2.24
Dicamba: 1.03
MCPA: 6.98
MCPP: 2.30
MCPA: 1.029
MCPP: 0.932
Dicamba: 0.205
MCPA: 3.638
MCPP: 1.198
215
-------
No Batch

EPA Reg. No.
2217-743
2217-744
2217-745
2217-773
2217-785
2217-786
2217-797
7969-78
8660-227
% Active Ingredient
MCPA: 0.353
MCPP: 0.321
Dicamba: 0.071
MCPA: 0.98
MCPP: 0.23
Dicamba: 0.11
MCPA: 1.20
Mecooroo: 0.40
MCPA: 38.68
MCPP: 8.16
Dicamba: 3.81
MCPA: 2.05
MCPP: 1.86
Dicamba: 0.41
MCPA: 5.63
MCPP: 1.33
Dicamba: 0.61
MCPA: 6.21
Monosodium
methanearsonate: 18.70
MCPP: 3.09
Dicamba: 1.48
MCPA: 6.2
Sodium Bentazon: 37.0
MCPA: 0.3 18
MCPP: 0.3 14
2.4-DP:0.310
216
-------
No Batch

EPA Reg. No.
62719-62
% Active Ingredient
MCPA: 63.5
MCPA 2-ethvlhexvl ester (PC Code 030564}
Batch 1

EPA Reg. No.
228-267
228-289
11685-15

11685-24

15440-9

35935-10

62719-64

67591-3
% Active Ingredient
91.0
97.0
93.0

97.0

97.5

94.0

95.8

99.9
Batch 2

EPA Reg. No.
228-156
1381-98

9779-265

11685-21

42750-23

71368-56
% Active Ingredient
68.7
68.7

69.7

67.9

69.7

67.9
217
-------
Batch 3

EPA Reg. No.
35935-20
42750-25
71368-16
% Active Ingredient
66.50
66.51

65.30
Batch 4
EPA Res. No.
% Active Ingredient
228-317
228-395
MCPA:56.14
Triclopyr: 5.00
Dicamba: 3.60
MCPA:56.14
Triclopyr: 5.00
Dicamba: 3.60
Batch 5

EPA Reg. No.
264-438
5905-550
42750-52
51036-254
71368-28
% Active Ingredient
MCPA: 34.0
Bromoxvnil: 31.7
MCPA: 34.0
Bromoxynil: 31.7
MCPA: 34.0
Bromoxynil: 31.7
MCPA: 34.0
Bromoxynil: 31.7
MCPA: 34.0
Bromoxynil: 31.7
218
-------
No Batch

EPA Reg. No.
228-203
228-205
264-649
264-654
264-655
264-690
264-699
554-125

1381-175

2217-803
% Active Ingredient
MCPA: 1.0
Mecoprop: 0.6
MCPA: 25.6
Mecoprop: 25.0
2.4-DP: 24.2
MCPA: 32. 11
Fenoxaprop-p-ethyl: 4.41
2.4-D: 10.35
MCPA: 37.66
Fenoxaprop-p-ethyl: 5.29
MCPA: 49.43
Fenoxaprop-p-ethyl: 2.64
MCPA: 40.0
Bromoxynil octanoate: 18.7
Bromoxynil heptonoate: 18.1
MCPA: 30.7
Bromoxynil octanoate: 18.5
Bromoxynil heptonoate: 17.9
74.93
MCPA: 43.03
Carfentrazone-ethyl: 1.39
MCPA: 26.83
MCPP: 3.44
Dicamba: 1.72
219
-------
No Batch

EPA Reg. No.
2217-834
2217-863
2217-865
2217-873
5905-506
62719-59
62719-86
62719-307
62719-513
71368-17
% Active Ingredient
MCPA:41.98
MCPP: 5.39
Dicamba: 2.69
Carfentrazone-ethyl: 0.48
MCPA:31.55
MCPP: 6. 16
Dicamba: 1.65
Carfentrazone-ethyl: 0.22
MCPA: 0.337
MCPP: 0.066
Dicamba: 0.018
Carfentrazone-ethyl: 0.002
MCPA: 43.09
MCPP: 5.64
Carfentrazone-ethyl: 0.50
74.4

74.4

MCPA: 43.4
Clopvralid: 5.0
MCPA: 52.0
Fluroxypyr: 12.0
MCPA: 43.4
Clopvralid: 5.0
Fluroxypyr: 26.2
81.9
220
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221
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Appendix H. List of Registrants Sent This Data Call-In
222
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Appendix I. LIST OF AVAILABLE RELATED DOCUMENTS AND ELECTRONICALLY
AVAILABLE FORMS
Pesticide Registration Forms are available at the following EPA internet site:

http://www.epa.gov/opprd001/fortns/

Pesticide Registration Forms (These forms are in PDF format and require the Acrobat reader)

Instructions

L 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

iL 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 at williams.nicole@epa.gov.

The following Agency Pesticide Registration Forms are currently available via the internet:
at the following locations:
8570-1
8570-4
Application for Pesticide
Registration/Amendment
Confidential Statement of Formula
http://www.epa.gov/opprd001/forms/8570-l.pdf

http://www.epa.gov/opprd001/forms/8570-4.pdf
223
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8570-5
8570-17
8570-25
8570-27
8570-28
8570-30
8570-32
8570-34
8570-35
8570-36
8570-37
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
Certification of Attempt to Enter into an
Agreement with other Registrants for
Development of Data
Certification with Respect to Citations of
Data (PR Notice 98-5)
Data Matrix (PR Notice 98-5)
Summary of the Physical/Chemical
Properties (PR Notice 98-1)
Self-Certification Statement for the
Physical/Chemical Properties (PR
Notice 98-1)
http://www.epa.gov/opprd001/forms/8570-5.pdf

http://www.epa.gov/opprd001/forms/8570-17.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.sov/opprd001/forms/8570-30.pdf

http://www.epa.sov/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. sov/opppmsd I/PR Notices/pr98- 1
.pdf
http://www.epa.gov/opppmsdl/PR Notices/pr98-l
.pdf
Pesticide Registration Kit
www.epa.sov/pesticides/resistrationkit/
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):
224
-------
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
a. Biopesticides and Pollution Prevention Division (BPPD) Contacts
b. Antimicrobials Division Organizational Structure/Contact List
225
-------
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' website.

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) at the following address:

National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161

The telephone number for NTIS is (703) 605-6000.
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 website.

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 (800) 858-7378 or through their website: ace.orst.edu/info/nptn.

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
226
-------
petitioner encloses with his submission a stamped, self-addressed postcard. The
postcard must contain the following entries to be completed by OPP:

a. Date of receipt;
b. EPA identifying number; and
c. 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 chemical abstract system (CAS) number if one has
been assigned.
227
-------
Appendix I. List of Available Related Documents and Electronically Available Forms

Pesticide Registration Forms are available at the following EPA internet site:

http://www.epa.gov/opprd001/fortns/

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 at williams.nicole@epa.gov.

The following Agency Pesticide Registration Forms are currently available via the internet:
8570-1 Application for Pesticide http://www.epa.gov/opprd001/forms/8570-l.pdf
Registration/Amendment
8570-4 Confidential Statement of Formula http://www.epa.gov/opprd001/forms/8570-4.pdf
8570-5 Notice of Supplemental Registration of http://www.epa.gov/opprd001/forms/8570-5.pdf
Distribution of a Registered Pesticide
Product
8570-17 Application for an Experimental Use Permit http://www.epa.gov/opprd001/forms/8570-17.pdf
8570-25 Application for/Notification of State http://www.epa.gov/opprd001/forms/8570-25.pdf
Registration of a Pesticide To Meet a
Special Local Need
228
-------
8570-27 Formulator's Exemption Statement
8570-28 Certification of Compliance with Data Gap
Procedures
8570-30 Pesticide Registration Maintenance Fee
Filing.
8570-32 Certification of Attempt to Enter into an
Agreement with other Registrants for
Development of Data
8570-34 Certification with Respect to Citations of
Data (PR Notice 98-5)
8570-35 Data Matrix (PR Notice 98-5)

8570-36 Summary of the Physical/Chemical
Properties (PR Notice 98-1)
8570-37 Self-Certification Statement for the
Physical/Chemical Properties (PR Notice
98-1)
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

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. go v/opppmsdl/PR_Notices/pr9 8-
l.pdf
http://www.epa. go v/opppmsdl/PR_Notices/pr9 8-
l.pdf
Pesticide Registration Kit
www.epa.gov/pesticides/registrationkit/
Dear Registrant:

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
229
-------
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 Acrobat reader.)

Other PR Notices can be found at http://www.epa.gov/opppmsdl/PR_NoticesPesticide 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' website.
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)
at the following address:
National Technical Information Service (NTIS)
230
-------
5285 Port Royal Road
Springfield, VA 22161

The telephone number for NTIS is (703) 605-6000.

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 website.
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 (800) 858-7378 or through their website: ace.orst.edu/info/nptn.

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:

1. Date of receipt;
2. EPA identifying number; and
3. 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 chemical abstract system (CAS) number if one has been assigned.
231
-------
232
-------