r/EPA
                     United States
                     Environmental Protection
                     Agency
           Pesticide
           Fact Sheet
                      Name of Chemical:
                      Reason for Issuance:
                      Date Issued:
                                           Office of Prevention, Pesticides
                                           and Toxic Substances
                                           (7501C)
                                           Nicarbazin
                                           Conditional Registration
                                           November 2005
   i.
DESCRIPTION OF CHEMICAL
         Chemical Name:


         Common Name:

         EPA PC Code:

         Chemical Abstracts
         Service (CAS)
         Number:

         Year of Initial
         Registration:

         Pesticide Type:

         U.S. Producer:

         Products:
         Mode of
         Action:
                  Nicarbazin (C19H18N6O6), a complex of two compounds, 4,4'-
                  dinitrocarbanilide (DNC) and 4,6-dimethyl-2-pyrimidinol (HDP)

                  Nicarbazin

                  085712
                  330-95-0


                  2005

                  Egg Hatch Reduction in Resident Canada Geese (Branta canadensis)

                  Innolytics, LLC.

                  OvoControl-G (EPA Reg. No. 80224-3; 0.25% bait)
                  Nicarbazin 30% Granulated premix (EPA Reg. No. 80224-2)
                  Nicarbazin interferes with the formation of the vitelline membrane,
                  separating the egg yolk and egg white. The exact mode of action is
                  unknown, although it is thought nicarbazin interferes with cholesterol
                  metabolism in the formation of the membrane. Eggs from treated
                  birds are described as mottled in appearance, reflecting a porous
                  vitelline membrane.  The effect on hatchability is a function of time
                  and dose and the effect is reversible.

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2.
USE PATTERNS AND FORMULATIONS
Application Sites:
Types and Methods
of Application:
Application Rate:
             The use of OvoControl G is limited to sites in urban areas such as office
             parks, recreational parks, golf courses, schools, hospitals, restaurants, and
             commercial and industrial sites.  Urban is defined as a municipality and its
             adjacent areas with a population of 50,000 or more. It may also be used at
             land airports holding FAA certifications under 14 Code of Federal
             Regulations 139.101 and having a wildlife hazard management plan under 14
             Code of Federal Regulations 139.337.
             Bait may be applied with bait pans, broadcast directly on the ground by hand
             or with mechanical feeders (up to a 20 ft radius).  Mechanical feeders must
             be attended and triggered by the applicator daily, with the exception that
             unattended mechanical feeders may be used at land airports which have FAA
             certification under 14 CFR 139.101 and a wildlife hazard management plan
             under 14 CFR 139.337.

             Application  rate is 50 grams per goose per day. Beginning three weeks prior
             to first anticipated egg-laying, a small amount of bait is offered (7 grams per
             goose), and the amount is increased each day, as geese become acclimated to
             the bait.  Baiting continues throughout the nesting period, which lasts 8 to 10
             weeks.
3.     SCIENCE FINDINGS

       Nicarbazin product chemistry,  toxicology, ecological effects and environmental fate data
       necessary to support the registration and use pattern are discussed below.

Product Chemistry:

       Nicarbazin (C19H18N6O6) is a complex of two compounds, 4,4'-dinitrocarbanilide (DNC,
       302.25 molecular weight) and 4,6-dimethyl-2-pyrimidinol (FtDP, 124.14 molecular weight).
       DNC is considered to be the active component, while HDP aids in  absorption (Table 1).

       Table 1: Nicarbazin - Product Chemistry Summary
Physical Properly
CAS Reg No.
Molecular weight
Color
Physical State
Melting point, °C
Nicarbazin Technical Grade
330-95-0
426.38
light yellow
fine powder
265-275 °C (with decomposition)
OvoControl-G
330-95-0
NA
yellowish-tan
solid, round to oblong, semi-soft
kibbles
NA

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Physical Property
Odor
Stability to normal and
elevated temperatures, metals
and metal ions
UV/VIS absorption max, nm
Aqueous solubility, ppm
pH
Vapor Pressure
Flammability/explodability
density
storage stability
corrosion characteristics
Nicarbazin Technical Grade
characteristic
nicarbazin is inherently stable
under extreme conditions
nicarbazin produces a band of
absorption in the range of 300-
360 mm
slightly soluble in
dimetylsulphoxide (DMSO) and
dimethylformamide (DMF);
insoluble in water and methanol,
however it decomposes slowly
when mixed with them
5-7 (1% suspension in water)
expected to be zero at ambient
temperatures (based on high
melting point)
NA
0.5 g/ml
NA
NA
OvoControl-G
None to slight grain odor
NA
NA
NA
NA
NA
neither flammable or explodable
based on formulation ingredients
25-33 Ibs/bushel
must be submitted upon
completion for both products
must be submitted upon
completion for both products
Toxicology:
       Based on acute toxicity data, OvoControl-G and Nicarbazin 30% Granulated Premix are
       Toxicity Category IV for oral, dermal,  inhalation and primary dermal sensitization and
       Toxicity category III for primary eye irritation.  See toxicity endpoints in Table 2 below.
       The following precautionary label language is required:

       CA UTION: Causes moderate eye irritation.  Remove and wash contaminated clothing before reuse. Avoid
       contact with eyes or clothing. Wear protective eyewear. Wash thoroughly with soap and water after handling
       and before eating, drinking, chewing gum, or using tobacco. Wear: Long-sleeved shirt and long pants, Socks,
       Shoes, and gloves.

       Nicarbazin has been a Food and Drug Administration (FDA) approved veterinary drug for
       use as an anticoccidial agent in broiler chickens since 1955. FDA has established a
       tolerance of 4 parts per million for nicarbazin residues in uncooked chicken muscle, skin,
       liver, and kidney (21 Code of Federal Regulations 556.445). FDA has established a feed

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additive tolerance of 125 ppm in chickens (21 Code of Federal Regulations 558.366) for use
of nicarbazin in feed to prevent outbreaks of faecal and intestinal coccidiosis.
To address toxicity data requirements, EPA relied on the Joint Food and Agriculture
Organization/World Health Organization (WHO) Expert Committee on Food Additives
1988 nicarbazin summary report. Based on the WHO data summary, additional
toxicological testing on this chemical for use to reduce egg hatchability in resident Canada
geese is not required. The toxicology information summarized in the report is listed in
Table 2.

Table 2: Nicarbazin Toxicity Profile
Study Type
Acute Inhalation Toxicity - rat
Acute Dermal Toxicity - rat
Primary Eye Irritation - rabbit
Primary Dermal Irritation - rabbit
Dermal Sensitization - guinea pig
Chronic Feeding, 2 year - dog
Chronic Feeding, 2 year - rat
Reproductive Toxicity - rat
Developmental Toxicity - rat
Mutagenicity
Carcinogenicity
Results
LC50>0.147mg/L
LD50 > 5,000 mg/kg
moderate irritant (category III)
not an irritant
not a contact sensitizer
NOEL 240 mg/kg/day based on slij
effect
NOEL 400 mg/kg/day based on no
highest dose tested
NOEL 400 mg/kg/day based on no
highest dose tested
NOEL 200 mg/kg/day for maternal
toxicity
*ht bile-duct
effects at
effects at
and fetal
Not mutagenic
Not carcinogenic
Metabolism studies were reviewed by the Joint Food and Agriculture Organization/World
Health Organization (WHO) Expert Committee on Food Additives.  Residue depletion
studies in chickens showed rapid elimination from the birds at five to seven days after
withdrawal.

The potential for human exposure and mammals (e.g. dogs) is anticipated to be low from the
use of nicarbazin fed to resident Canada geese. The WHO studies indicate that non-target
mammals (including humans) would have to consume prohibitively large amounts of the
product to produce any toxic effects. Based on the rat acute oral LD50 toxicology data, an
acute single ingestion for a child (15kg or 331bs) would have to exceed 60 kilograms (132
pounds) of bait and for a dog (10kg or 231b.) 40kg (881bs) of bait to cause lethal effects in
50% of the population.

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       On a chronic basis, using the results of a 2 year chronic study in rats (NOEL = 400 mg/kg
       bw/day, based on HDT no treatment related toxicity), the no-effect quantities of bait on a
       daily consumption basis are 2.4 kg (5.2 Ibs) and 1.6 kg (3.5 Ibs) for the rest of their lives.
       Again, the consumption of bait on a daily basis is not realistic and consumption values are
       not physically possible.

       Label restrictions markedly reduce inadvertent exposure to children and pets because
       uneaten bait is not expected and any leftover bait must be removed. Also, once geese are
       acclimated to the bait, consumption typically takes place quickly and completely. By the
       end of the initial 21 day period, the daily dose (based on flock size) must be entirely
       consumed within 2 hours of application or treatment must cease.

Ecological Effects:

Terrestrial Animal Routes of Exposure:

       Feeding on nicarbazin bait placed in terrestrial environments is expected to be a route of
       primary exposure to non-target species. Exposure via this route is expected to occur
       primarily to birds and mammals, although it is possible for other terrestrial animals such as
       reptiles and terrestrial amphibians to be exposed if they consume the bait. Terrestrial
       species may also ingest nicarbazin and DNC by drinking contaminated water (e.g.,
       rainwater in bait pans, puddled water on the ground, pond water). Bait deposited in water
       bodies may also be directly consumed by terrestrial species that feed in water (e.g., non-
       target waterfowl).

       Secondary exposure is also possible, but the extent to which this may occur is unknown.
       Since it is expected to remain in soil, nicarbazin and DNC released into the terrestrial
       environment from bait or feces will be available to soil macroinvertebrates for uptake or
       consumption. Terrestrial animals that feed on soil macoinvertebrates may receive exposure
       via this pathway. Secondary exposure may also occur to predators and scavengers
       consuming tissues and/or eggs of animals that have ingested bait. This exposure may raise
       the potential for risk to species that consume eggs of animals that have consumed the bait.

Terrestrial Animal Exposure Assumptions:

       For the screening level assessment, very conservative assumptions were made. It was
       assumed that 2500 ppm nicarbazin bait would be available for a nontarget animal to
       consume on a 24 hour basis, and up to 13 weeks as the sole food source.
Terrestrial Animal Toxicity and Risk:

       Nicarbazin is characterized as practically non-toxic to the Northern bobwhite and slightly

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       toxic to the mallard on an acute/sub acute basis (Table 3)
        Table 3. Nicarbazin Acute Avian Toxicity to Birds
Test species
Mallard
Northern bobwhite
Percent Nicarbazin
>99
(both moieties)
Toxicity value
LC50 = 3680 ppnf
LC50 >5720 ppmb
LD50 >2250 mg/kg bw
       a mortality was 80% at 5720 ppm ai, 10% at 1968 ppm nicarbazin, andO% at the control and <802 ppm aitest levels;
       treatment-related signs of toxicity were evident by day 2
       b single mortalities (10%) were observed at the 1968 and 5720 ppm nicarbazin levels and may have been caused by exposure;
       effects were first observed between Days 5 and 6 and included wing droop, ruffled appearance, and/or foot lesions
       (from picking)

       The acute risk quotient (RQ = 0.7) for acute effects to birds slightly exceeds the acute high
       risk level of concern (LOG = 0.5) based on the conservative, screening level risk
       assessment. The  risk estimate assumes exposure.

       The likelihood of this  exposure  occurring is minimized by label restrictions.  Several label
       restrictions are imposed which will ensure a markedly reduced exposure to non-target birds,
       reptiles and mammals.  (See Labeling Restrictions).

Terrestrial Animal Chronic  Toxicity and Risk:

       Although there are no guideline  reproduction studies available for nicarbazin, several
       laboratory and field studies have shown that this chemical causes reproductive effects in
       several bird species.  These data clearly demonstrate that low concentrations of nicarbazin
       fed in the diet will adversely impact avian reproduction (which is to be expected given its
       mode of action).  For example, significantly reduced egg production and hatchability of
       fertile eggs was reported at a dietary concentration of 25 ppm when fed to chickens for only
       four days, and eggshell pigmentation was reduced after only two days of feeding. These
       effects were even more pronounced at dietary concentrations of 50 and 100 ppm.  In several
       studies, negative  impacts on egg hatchability in chickens fed 20 ppm nicarbazin in the diet
       for only 9 to 10 days have been reported in several studies. In another study, mortality
       occurred in chickens fed 1600 and 2500 ppm nicarbazin in food ration, and depressed
       growth and reduced egg hatchability was seen at lower concentrations.

       Based on worst-case findings of the published literature studies, a no observable adverse
       effect concentration (NOAEC) of 10 ppm is presumed due to adverse affects on egg
       hatching at 20 ppm.

       Based on the reproductive NOAEC of 20 ppm, the avian chronic effects RQ is X250. The
       concentration of nicarbazin in the bait (2500 ppm) exceeds the level shown to cause adverse
       reproductive effects in chickens, quail, and mallards after exposures of a few days to two
       weeks in the laboratory.
       The chronic risk estimate is very conservative, as it assumes that the bait would be available
       for nontarget animals to consume on a 24 hour basis, up to 13 weeks as the sole food source.

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       The likelihood of this exposure is low, and is further minimized by label restrictions.
       Several label restrictions are imposed which will ensure a markedly reduced exposure to
       non-target birds, reptiles and mammals. (See Labeling Restrictions).

Aquatic Animal Routes of Exposure:

       Nicarbazin and DNC deposited on land may reach aquatic environments and standing water
       via runoff.  Unconsumed bait deposited on the ground or in water will likely undergo
       physical breakdown, releasing nicarbazin and/or DNC into the water column in both water
       bodies and standing water.  DNC will be deposited in the aquatic environment through
       defecation by treated Canada geese. In addition, aquatic species may ingest nicarbazin and
       DNC by drinking contaminated water, or may be exposed via uptake through
       gills/integument. Bait deposited in water bodies may also be directly consumed by aquatic
       species (fish, invertebrates, and aquatic phase amphibians).  Secondary exposure may occur
       to predators and scavengers consuming tissues and/or eggs of animals that have ingested
       bait.

Aquatic Animal Exposure Assumptions:

       Based on conservative aquatic modeling (Table 4), predictions are that DNC will
       accumulate over time in the pond. In the water column, yearly average DNC concentrations
       rise to between 2 and 4 ppb in a FL turf and PA turf scenario. Benthic pore water
       concentrations are similar.  Concentrations in benthic sediment show approximately the
       same pattern, rising to about 0.20 to 0.25 ppm. Concentrations from 70 daily applications
       (rather than 26, as modeled) can be expected to be proportionately (3 times) higher.

       Table 4: Input Parameters for Aquatic Exposure Modeling for Dinitrocarbanilide (DNC)
Input Parameter
Aqueous Solubility, ppb
Organic Carbon Partitioning
Coefficient, mL/g
Chemical Application
Method (CAM)
Incorporation Depth, cm
Application Rate, kg/ha
Application Efficiency, %
Value
520
1650
4
1
0.0248 kg/ha
(0.022 Ib/acre)
50
Reference
lOx value at pH7; to ensure that
PRZM-EXAMS runs correctly.
estimated by EPI Suite
reflects granular application
(soil applied, user-defined
incorporation depth, uniform
with depth)
assumed: must be > 0.0 for
CAM =4
Label: max. 200 ounces (12.5
Ib) product/acre/day, adjusted
for 0.25% nicarbazin content;
71% DNC content in nicarbazin
Assumes geese consume all bait
expressed, and 50% of applied
bait (DNC) is excreted in feces
onto ground, of that a small
percentage (approx. 5%) runs
off into water.

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Input Parameter
Number of Applications,
interval
Hydrolysis Half-life
Soil Half-life, days
Water Half-life, days
Value
26 at 1-day intervals; 70 implied by
daily feeding for 10 weeks
stable
301
602
Reference
26 is the maximum number
allowed by pe4v01 graphical
user interface for
PRZM/EXAMS
MRID 46445305
MRTD 464 16449
2x soil value as per Input
Parameter Guidance, if no data
available; benthic half-life
assumed to be the same
       The modeling above is based on results of an acceptable hydrolysis study of the separate
       components DNC and HDP, and two supplemental field dissipation studies. The DNC
       portion degrades slowly in soil with half-life of approximately one year, and does not
       volatilize or leach through the soil. It may run-off with storm water, probably sorbed to soil
       particles. Once the nicarbazin complex is separated, it is likely that DNC and HDP will
       have different fate profiles, as HDP is far more water-soluble than DNC. It is highly
       hydophilic  (logKow of-0.94).  HDP absorbs visible light, and so may be photodegraded.

Aquatic Animal Toxicity and Risk:

       Based on the results of these acute toxicity studies, nicarbazin is practically nontoxic to
       aquatic animals on an acute basis (Table 5).  The acute risk quotient is not exceeded. Acute
       effects in fish and invertebrates are not expected based on submitted data. The main
       potential risk to aquatic animals is likely to be to sediment-dwelling organisms and also
       chronic exposure of aquatic organisms. There are no data to assess those potential risks.
        Table 5:  Nicarbazin - Acute Aquatic Toxicity
Test
species
Rainbow
trout
Bluegill
Water flea
Percent Nicarbazin (moiety)
99.4 (HDP)
98.0 (DNC)
99.4 (HDP)
98.0 (DNC)
99.4 HDP
98.0 DNC
Toxicity
96-hLC50>110ppm
96-h LC50 >69 ppb
96-h LC50 >122 ppm
96-h LC50 >72 ppb
48-hEC50>107ppm
48-h EC50 >93 ppb
       There is uncertainty as to the potential exposure to aquatic ecosystems due to runoff of bait

                                             8

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       or fecal deposition.

       The significance of any such potential impacts needs to be considered in the context of the
       ecological value of urban water bodies that presumably are associated with populations of
       resident geese that exceed the urban ecosystem's carrying capacity. Aquatic loading from
       goose defecation (untreated) probably represents much more of an ecological risk than
       would nicarbazin entering the aquatic environment. The environmental exposure from the
       use of nicarbazin to reduce egg hatchability will be small when compared to the poultry use.
       A label restriction "Do not apply within 20 feet of any body of water, including lakes,
       ponds or rivers." is required for this product

Endangered Species Assessment

       The endangered species assessment is incomplete at this time. Given that the label
       instructions control to a great degree the availability of the product to nontarget species, the
       Agency believes risks to threatened and endangered (T&E) species are low.

       In order to avoid and minimize potential impacts to Threatened and Endangered (T&E)
       species, it is a requirement that the permit applicant must contact the local United States
       Fish and Wildlife Service (USFWS) Ecological Services Office for assistance in
       determining the likelihood of effects to T&E species.
       Landowners or wildlife management agencies must first contact the USFWS Migratory Bird
       Permit Office responsible for the region where the geese are located to ontain a federal
       permit before bait is dispensed. Information on any T&E species that occur in the area must
       be provided to the USFWS Migratory Bird Permit Office with the application. The permit
       applicant must also identify the Certified Applicator who will apply the bait.
Product Efficacy:

       OvoControl-G is intended for use in reducing egg-hatchability in resident Canada geese.
       The applicator initiates baiting a minimum of 21 days prior to first nesting, which is in mid-
       February to early March depending on locality. During initial baiting, as geese become
       accustomed to the bait and delivery system, a small amount of bait is administered per
       goose (about 7 grams). The amount is increased each day until the rate of 50 gram per
       goose is attained. The amount of bait administered per site is based on visual observation of
       flock size. If the geese cannot be acclimated to the bait site, use is to be discontinued.
       Applicators should feed geese at daybreak in close proximity to where they feed  Bait is
       administered throughout the entire nesting season, which lasts 8 to 10 weeks.

       The application rate is 50 grams (2 oz) per goose per day, and is supported by  numerous
       laboratory and small plot studies conducted by the National Wildlife Research Center
       (NWRC) of the Animal and Plant Health Inspection Service (APHIS). In order to be
       effective, female geese must feed on the bait consistently during the time the eggs are being
       formed. A 2004 field study conducted by the NWRC in the state of Oregon  showed an

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       overall reduction in resident Canada geese egg-hatch of approximately 36% - 50% when
       compared to controls.

       OvoControl-G is not intended to be used alone, but rather as part of an integrated pest
       management program for the control of resident Canada geese.

4.      SUMMARY OF REGULATORY POSITION AND RATIONALE

       In many urban and suburban areas and for reasons not fully understood, Canada geese
       populations have become resident - remaining year round. Geese have been classified a
       public health pest by EPA due to the potential spread of disease through feces, possible
       human injury from attacks, and threat to public safety from encounters with aircraft.  Geese
       can also cause large amounts of property damage.  Burgeoning populations of resident
       Canada geese have become a serious environmental and public health issue.

       Typically, conflicts with Canada geese have been resolved through trapping and relocation,
       egg addling, aversive conditioning strategies (e.g., dogs harassing birds), physical and
       natural barriers, and lethal controls. There is significant controversy on current Canada
       geese management, particularly the killing of adult and juvenile birds during molting.
       Animal welfare groups and often the public have questioned the rationale and justification
       for lethal controls. Other than several repellents/deterrents, EPA does not have any
       currently registered products for Canada geese control.

       Nicarbazin provides a new tool for pest control operators and wildlife management
       personnel.  It is not intended nor will it be effective as a sole means of controlling
       populations of resident Canada geese.  When used with other control methods, nicarbazin
       will aid in long-term population control.

       Nicarbazin has been approved for use in the poultry industry since  1955 and approximately
       10 million kilograms of the active ingredient has been fed to 80 billion broiler chickens in
       the U.S. During 2003, broiler chickens in the U.S. consumed approximately 250,000
       kilograms of nicarbazin. If 100,000 resident Canada geese are treated with 50g of 2500
       ppm nicarbazin bait/goose/day for 10 weeks, the total amount of nicarbazin would be 350
       kilograms annually.  The environmental exposure from the use of nicarbazin to reduce egg
       hatchability will be small when compared to the poultry use.

       The registration of nicarbazin has strong support from organizations such as the U.S.
       Department of Agriculture (APHIS/NWRC), the Birdstrike Committee (a volunteer
       organization directed by a steering committee consisting of 2-3 members from each of the
       Federal Aviation Administration, Department of Defense, USDA and aviation industry), and
       the Humane Society of the United States.

       Based on the limited use pattern/exposure scenario, the submitted data are deemed adequate
       to support nicarbazin registration.
                                            10

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Avoiding nontarget exposure is the primary concern with use of OvoControl-G.  Reduction
in egg hatchability is the primary concern if nontarget birds are exposed to nicarbazin.  On
the basis of label requirements,  it can be reasonably assumed that exposure and resultant
risk to non-target and endangered species would be low. Labeling requirements include:

     !      restricted-use classification;

     !      applicator must obtain a permit for use from the USFWS prior to use;

     !      applicator must monitor site and keep daily written records of nontargets
           observed feeding on the bait;

     !      use is restricted to urban areas and approved airports. Urban is defined as a
           municipality with a population of 50,000 or more and its adjacent areas.

     !      unattended mechanical feeders may only be used at approved airports, the
           applicator must be present to trigger feeder on a daily basis;

     !      several label directions and restrictions designed to minimize nontarget
           exposure (see Labeling Requirements)

     !      bait cannot be applied within 20 feet of any body of water, including lakes,
           ponds or rivers.

    Labeling Restrictions

    To mitigate risk to nontarget animals, the following label requirements have been
    imposed:

     !      Restricted-use classification of OvoControl-G due to potential risk to nontarget
           species. OvoControl-G label requirements are:

                Restricted Use Pesticide (Due to Potential Risk to Nontarget Wildlife Species)
           For retail sale to and use only by Certified Applicators or persons under their direct supervision
           and only for those uses covered by the Certified Applicator's certification.

     \      Requiring a Migratory Bird Treaty Act permit and consultation with wildlife
           officials to determine if listed species occur in a proposed use area.  Applicators
           must obtain a permit from the U.S. Fish and Wildlife Service prior to any
           applications.  USFWS will evaluate the potential adverse impacts on the
           constituent elements of critical habitats prior to issuing a permit. OvoControl-G
           label requirements are:

           Federal Permit Requirement and Threatened or Endangered Species Considerations
           In order to avoid and minimize potential impacts to Threatened and Endangered (T&E) species,
           the permit applicant must contact the local USFWS Ecological Services Office (contact

                                         11

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       information can be found at http://www.fws.gov/endangered) for assistance in determining the
       likelihood of effects to T&E species.

       The federal Migratory Bird Treaty Act protects Canada geese. Landowners or wildlife
       management agencies seeking to control resident Canada geese using OvoControl G must
       contact the U.S. Fish and Wildlife Service (USFWS) Migratory Bird Permit Office responsible
       for the region where the geese are located for a federal permit before bait is dispensed.  Permit
       application forms and contact information are available at http://www.fws.gov/forms/3-200-
       13.pdf. Information on any T&E species that occur in the area must be provided to the USFWS
       Migratory Bird Permit Office with the migratory bird application. Once it has been determined
       that no additional permits (e.g., for take of T&E species) will be required, allow 90 days for
       processing. The permit applicant must also identify the Certified Applicator who will apply the
       bait.
       Limiting application to urban areas only and certain land airports.  OvoControl-
       G label requirements are:
       The use of OvoControl G is limited to sites in urban areas such as office parks, recreational
       parks, golf courses, schools, hospitals, restaurants, and commercial and industrial sites.  Urban
       is defined as a municipality and its adjacent areas with a population of 50,000 or more.  May
       only be used at land airports holding FAA certifications under 14 Code of Federal Regulations
       139.101 and a wildlife hazard management plan under 14 Code of Federal Regulations
       139.337.
\       Limitations on use of unattended mechanical feeders.  Unattended mechanical
       feeders may only be used at airports (as described above).  For all other sites,
       mechanical feeders must be triggered by the applicator on a daily basis.
       OvoControl-G label requirements are:
       Mechanical feeders must be attended and triggered by the applicator daily.  Unattended
       mechanical feeders may be used at land airports which have FAA certification under 14 CFR
       139.101 and a wildlife hazard management plan under 14 CFR 139.337. "


 \      Limitations on geographical use.  OvoControl-G label requirements are:
       Not for use in Hawaii, Guam, American Samoa, Northern Mariana Islands, Puerto Rico and US
       Virgin Islands.

\       Precautions limiting aquatic exposure. OvoControl-G label requirements are:
       Do not apply within 20 feet of any body of water, including lakes, ponds or rivers.


 \      Non-target observations and written records.  OvoControl-G label requirements
       are:
       The applicator must maintain daily and weekly records on baiting and document the amount of
       bait applied and confirm that bait is consumed within 2 hours. Records must also document an
       estimate of the amount of bait remaining after two hours or the amount of a previous day's bait
       observed prior to baiting. The records must also document the method used to clean and
       remove uneaten bait.
       For the migratory bird permitting, written records must be kept regarding date, time, number
       and identification of non-target species feeding on the bait. These records must be provided to
       the landowner.

                                       12

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               Reducing the likelihood of nontarget exposure to uneaten bait. The applicator
               must follow label instructions to minimize the potential for nontarget wildlife to
               feed on the bait. OvoControl-G label requirements are:
               By the end of the initial 21 day period, the daily dose (based on flock size) must be entirely
               consumed within 2 hours of application.  If uneaten bait remains after 2 hours of application,
               cease treatment.
               If geese cannot be habituated to the feeding program (at least 1 ounce (25 grams) OvoControl
               G/goose/day) within 21 days, discontinue treatment at that particular site.
               Do not apply more OvoControl-G than the geese will eat in a single feeding, as this may result
               in non-target species exposure to left over bait.  Do not apply bait at sites where non-target
               wildlife are observed feeding on OvoControl-G during the first 21 days.
               If non-targets consistently feed on bait during treatment, delay baiting until local wildlife
               authorities can determine if unacceptable risks exist to non-target species. It may be a violation
               of state and federal law to feed treated bait to protected nontarget species.

               After the initial 21 days of baiting, observations must be made to ensure that the geese are
               continuing to consume the bait within 2 hours of application. After the initial 21 day
               acclimation period, target population estimates and 2 hour observations for nontarget species
               must be made weekly.  The amount of bait being applied must be increased or decreased
               according to the number of geese observed at the site during the target population estimate.
               During treatment (day 22+),  if the applicator finds uneaten bait left over at the site from the
               previous day's feeding, the applicator must remove it, a target population estimate must be
               performed, and the daily application rate must be adjusted accordingly. Additionally, the
               applicator must resume 2 hour observation for nontarget species, every two days, until the bait
               is again consumed within 2 hours of application. If uneaten bait is found at the site for five
               consecutive observations, cease treatment.

               This product will reduce hatchability and adversely affect other aspects of
               reproduction in all avian species.
        !      Use in grass that is typically mowed to increase bait consumption and allow observation of
               uneaten bait. OvoControl-G label requirements are:
               Application to grass must be made in grass that is typically mowed to increase access to bait.


5.      CONFIRMATORY DATA REQUIREMENTS
        There are no confirmatory data requested for nicarbazin based on the labeled uses.


6.      CONTACT PERSON AT EPA
        Joanne Edwards, Entomologist
        Insecticide-Rodenticide Branch
        Registration Division (7505C)
        Office of Pesticide Programs
        Environmental Protection Agency

                                               13

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       Ariel Rios Building
       1200 Pennsylvania Avenue, N.W.
       Washington, DC 20460

       Office Location and Telephone Number
       Room 211, Crystal Mall Building #2
       1921 Jefferson Davis Highway
       Arlington, VA 22202
       (703)305-6736
       E-mail: edwards.joanne@epa.gov

DISCLAIMER: The information presented in this Pesticide Fact Sheet is for informational
purposes only and may not be used to fulfill data requirements for pesticide registration and
reregi strati on.
                                         14

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Appendix I
GLOSSARY OF TERMS AND ABBREVIATIONS
CAS         Chemical Abstracts Service
DNC         4,4'-dinitrocarbanilide
EPA         U.S. Environmental Protection Agency
FAA         Federal Aviation Administration
g/ml         grams per milliliter
HDP         4,6-dimethyl-2-pyrimidinol
Kow          Octanol-Water Partition Coefficient
kg/ha        Kilogram Per Hectare
Ib/acre       Pound Per Acre
Ibs          Pounds
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
LOQ         Limit of quantitation
mg/kg       Milligram Per Kilogram
mg/kg/bw    Milligram Per Kilogram Per Bodyweight
mg/kg/day    Milligram Per Kilogram Per Day
mg/L         Milligrams Per Liter
ml           Milliliter
MOE        Margin of Exposure
MRID       Master Record Identification (number), EPA's system of recording and tracking
             studies submitted
NA          Not Applicable
NOEC       No Observable Effect Concentration
NOEL       No Ob served Effect Level
                                         15

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NOAEL     No Observed Adverse Effect Level
NOAEC     No Observed Adverse Effect Concentration

GLOSSARY OF TERMS AND ABBREVIATIONS (Continued)

ppb         Parts Per Billion
ppm        Parts Per Million
PRZM/EXAMS Tier II Surface Water Computer Model
RQ         Risk Quotient
jig          micrograms
Hg/L        Micrograms Per Liter
|iL/g        Microliter per gram
USDA      United States Department of Agriculture
                                       16

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             Appendix II
CITATIONS CONSIDERED TO BE PART OF THE DATA BASE SUPPORTING THE
REGISTRATION OF NICARBAZIN
 MRID
Citation
46416400    Innolytics, LLC (2004) Submission of Product Chemistry, Toxicity, Fate,
             Efficacy and Environmental Fate Data in Support of the Application for
             Registrations of OvoControl-P, Nicarbazin 30% Granulated Premix, and
             OvoControl-G. Transmittal of 43 Studies.
46416401    Wolf, E.; MacDonald, A. (2004) Product Identity and Composition,
             Certification of Ingredient Limits, and Discussion of Impurities of Nicarbazin
             and Nicarbazin 30% Granulated Premix. Project Number:
             NICARBAZIN/04/22. Unpublished study prepared by Exponent. 51 p.
46416402    Wolf, E.; MacDonald, A. (2004) Product Identity and Composition,
             Certification of Ingredient Limits, and Discussion of Impurities of OvoControl-
             G and OvoControl-P. Project Number: NICARBAZIN/04/34. Unpublished
             study prepared by Exponent. 16 p.
46416403    Wolf, E.; MacDonald, A. (2004) Description of Materials Used to Produce the
             Product, Description of Production Process, Description of Formulation
             Process, Prelimiary Analysis for Nicarbazin and the Manufacturing Use Product
             Nicarbazin 30% Granulated Premix. Project Number: NICARBAZIN/04/08/03.
             Unpublished study prepared by Exponent. 130 p.
46416404    Wolf, E.; MacDonald, A. (2004) Description of Materials Used to Produce the
             Product, Description of Production Process, Description of Formulation
             Process, and Prelimonary Analysis for OvoControl-G and OvoControl-P.
             Project Number: NICARBAZIN/04/37. Unpublished study prepared by
             Exponent. 77 p.
46416406    Wolf, E.; MacDonald, A. (2004) Description and Validation of Analytical
             Method for the Determination of Nicarbazin in Goose Baits by HPLC/UV.
             Project Number: NICARBAZIN/04/36, P0000814, P0000545. Unpublished
             study prepared by Exponent. 38 p.
46416407    Wolf, E.; MacDonald, A. (2004) Description of Color, Physical State, Odor,
             Melting Point,  Specific Gravity, Solubility, Vapor Pressure, Dissociation
             Constant, pH, Stability, and Particle Size for Nicarbazin. Project Number:
             NICARBAZIN/04/31. Unpublished study prepared by Exponent. 31 p.
46416408    Wolf, E.; MacDonald, A. (2004) Description of Color, Physical State, Odor,
             Bulk Density, pH, Flammability, Explodability, Particle Size and Shape,
             Storage Stability, and Corrosion Characteristics for Nicarbazin 30% Granulated
                                        17

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             Premix. Project Number: NICARBAZIN/04/32. Unpublished study prepared by
             Exponent. 8 p.
 46416409    Wolf, E.; MacDonald, A. (2004) Description of Color, Physical State, Odor,
             Bulk Density, pH, Flammability, Explodability, Particle Size and Shape,
             Storage Stability, and Corrosion Characteristics for OvoControl-G and
             OvoControl-P. Project Number: NICARBAZIN/04/33. Unpublished study
             prepared by Exponent. 6 p.
46416410     Wolf, E. (2004) The Determiation of the Distribution Coefficients of the
             Components of Nicarbazin Between 1-Octanol and Aqueous Buffers (ADM-
             56). Project Number: NICARBAZIN/04/08/05. Unpublished study prepared by
             Exponent. 17 p. 46416411 McCracken, B. (2004) Water Solubility of DNC and
             HDP. Project Number: P0000936. Unpublished study prepared by Exygen
             Research. 26 p.
46416412     Habig, C.; Messina, J.; Daniels, C. (2004) Nicarbazin Support Documentation.
             Project Number: NICARBAZIN/04/30. Unpublished study prepared by
             Exponent. 112 p.
46416413     Messina, J. (2004) Nicarbazin Acute Oral Toxicity LD50: (Rat). Project
             Number: NICARBAZIN/04/12. Unpublished study prepared by Exponent. 7  p.
46416414     Messina, J.; Daniels, C. (2004) Nicarbazin Waiver Request from Further
             Testing: Acute Dermal Toxicity LD50. Project Number: NICARBAZIN/04/29.
             Unpublished study prepared by Exponent. 8 p.
46416415     Brooker, A. (2001) Koffogran: Acute (Four-Hour) Inhalation Study in Rats.
             Project Number: CYT/044/014207, NICARBAZIN/04/02. Unpublished study
             prepared by Huntingdon Life Sciences, Ltd. 35 p.
46416416     Blanchard, E. (2001) Koffogran: Eye Irritation to the Rabbit. Project Number:
             NICARBAZIN/04/02, CYT/002/013543/SE. Unpublished study prepared by
             Huntingdon Life Sciences, Ltd. 16 p.
46416417     Blanchard, E. (2001) Koffogran: Skin Irritation to the Rabbit. Project Number:
             NICARBAZIN/04/03, CYT/001/013542/SE. Unpublished study prepared by
             Huntingdon Life Sciences, Ltd. 15 p.
46416418     Coleman, D. (2001) Koffogran: Skin Sensitization to the Guinea-Pig (Buehler
             Method - 9 Inductions). Project Number: NICARBAZIN/04/04,
             CYT/003/013699/SS. Unpublished study prepared by Huntingdon Life
             Sciences, Ltd. 28 p.
46416419     Messina, J. (2004) Nicarbazin Chronic Toxicity Rat. Project Number:
             NICARBAZIN/04/08. Unpublished study prepared by Exponent. 184 p.
46416420     Messina, J. (2004) Nicarbazin Chronic Toxicity Dog. Project Number:
             NICARBAZIN/04/07. Unpublished study prepared by Exponent. 184 p.
46416421     Messina, J. (2004) Nicarbazin Developmental Toxicity. Project Number:
             NICARBAZIN/04/10. Unpublished study prepared by Exponent. 50 p.
46416422     Messina, J. (2004) Nicarbazin Multigeneration Reproduction Toxicology.

                                        18

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             Project Number: NICARBAZIN/04/05. Unpublished study prepared by
             Exponent. 48 p.
46416423     Messina, J. (2004) Nicarbazin Genotoxicity. Project Number:
             NICARBAZIN/04/09. Unpublished study prepared by Exponent. 20 p.
46416424     Innes, D. (2001) Nicarbazin: Micronucleus Test in Bone Marrow of CD-I Mice
             0 h + 24 h Oral Dosing and 48 h Sampling. Project Number: 20677,
             NICARBAZIN/04/11, 767115. Unpublished study prepared by Inveresk
             Research International. 31 p.
46416425     Messina, J. (2004) Nicarbazin Metabolism. Project Number:
             NICARBAZIN/04/06. Unpublished study prepared by Exponent. 252 p.
46416426     Gallagher, S.; Beavers, J. (2004) Nicarbazin Technical: An Acute Oral Toxicity
             Study With the Northern Bobwhite. Project Number: 573/103. Unpublished
             study prepared by Wildlife International, Ltd. 30 p.
46416427     Gallagher, S.; Beavers, J. (2004) Nicarbazin Technical: A Dietary LC50 Study
             with the Northern Bobwhite. Project Number: 573/101, P0000736. Unpublished
             study prepared by Wildlife International, Ltd. 89 p.
46416429     Habig, C.; Messina, J.; Daniels, C. (2004) Nicarbazin Waiver Request From
             Further Testing: Wild Mammal Toxicity. Project Number:
             NICARBAZIN/04/28. Unpublished study prepared by Exponent. 8 p.
46416431     Palmer, S.; Krueger, H. (2004) 2-Hydroxy-4,6 Dimethypyrimidine (HDP): A
             96-Hour Static Acute Toxicity Test With The Rainbow Trout (Oncorhynchus
             mykiss): Final Report. Project Number: 573 A/109, P997, V0002054/3.
             Unpublished study prepared by Exponent. 90 p.
46416432     Palmer, S.; Krueger, H. (2004) 4,4'-Dinitrocarbanilide (DNC): A 96-Hour Static
             Acute Toxicity Test with the Rainbow Trout (Oncorhynchus mykiss): Final
             Report. Project Number: 573 A/106. Unpublished study prepared by Wildlife
             International, Ltd. 89 p.
46416433     Palmer, S.; Krueger, H. (2004) 2-Hydroxy-4,6 Dimethylpyrimidine (HDP): A
             96-Hour Static Acute Toxicity Test with the Bluegill (Lepomis macrochirus):
             Final Report. Project Number: 573 A/108. Unpublished study prepared by
             Wildlife International, Ltd. 89 p.
46416434     Palmer, S.; Krueger, H. (2004) 4,4'-DinitroCarbanilide (DNC): A 96-Hour
             Static Acute Toxicity Test with the Bluegill (Lepomis macrochirus): Final
             Report. Project Number: 573 A/105. Unpublished study prepared by Wildlife
             International, Ltd. 90 p.
46416435     Palmer, S.; Krueger, H. (2004) 2-Hydroxy-4,6 Dimethylpyrimidine (HDP): A
             48-Hour Static Acute Toxicity Test with the Cladoceran (Daphnia magna):
             Final Report. Project Number: 573A/107C. Unpublished study prepared by
             Wildlife International, Ltd. 90 p.
46416436     Palmer, S.; Krueger, H. (2004) 4,4'-Dinitrocarbanilide (DNC): A 48-Hour Static
             Acute Toxicity Test with the Cladoceran (Daphnia magna): Final Report.
                                        19

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             Project Number: 573A/104A. Unpublished study prepared by Wildlife
             International, Ltd. 91 p.
46416437    Wolf, E. (2004) Nicarbazin Acute Freshwater Fish, Aquatic Invertebrates, Alga
             Toxicity. Project Number: NICARBAZIN/04/19. Unpublished study prepared
             by Exponent. 16 p.
46416438    Habig, C.; Messina, J.; Daniels, C. (2004) Nicarbazin Waiver Request from
             Further Testing: Acute LC50 Estuarine and Marine Organisms, Fish Early Life
             Stage and Aquatic Invertebrate Life-Cycle, Fish Life-Cycle, Aquatic Organism
             Accumulation,  and Simulated or Actual Field Testing-Aquatic Organisms.
             Project Number: NICARBAZIN/04/21. Unpublished study prepared by
             Exponent.  9 p.
46416439    Habig, C.; Messina, J.; Daniels, C. (2004) Nicarbazin Waiver Request from
             Further Testing: Seedling Emergence, Vegetative Vigor and Aquatic Plant
             Growth. Project Number: NICARBAZIN/04/20. Unpublished study prepared by
             Exponent.  8 p.
46416440    Habig, C.; Messina, J.; Daniels, C. (2004) Nicarbazin Waiver Request from
             Further Testing: Honey Bee Acute Contact LD50, Honey Bee Toxicity of
             Residues on Foliage, and Field Testing for Pollinators. Project Number:
             NICARBAZIN/04/20. Unpublished study prepared by Exponent. 8 p.
46416441    Messina, J. (2004) Nicarbazin, HDP, and DNC Acute Earthworm Toxicity.
             Project Number: NICARBAZIN/04/16. Unpublished study prepared by
             Exponent.  58 p.
46416442    Messina, J. (2004) Nicarbazin Pigeon Efficacy Information. Project Number:
             NICARBAZIN/04/17. Unpublished study prepared by Exponent. 15 p.
46416445    Habig, C.; Messina, J.; Daniels, C. (2004) Nicarbazin Waiver Request from
             Further Testing: Aqueous Photolysis. Project Number: NICARBAZIN/04/25.
             Unpublished study prepared by Exponent. 10 p.
46416446    Wolf, E. (2004) A Study to Determine the Rate of Depletion of lonophore and
             14-C Nicarbazin in a Field Soil Plot. Project Number: NICARBAZIN/04/13.
             Unpublished study prepared by Exponent. 7 p.
46416447    Wolf, E. (2004) Mobility of 14-C DNC on Soil Thin-Layer Plates. Project
             Number: NICARBAZIN/04/15. Unpublished study prepared by Exponent.  8 p.
46416449    Manthey, J. (1985) A Study to Determine the Rate of Depletion of Narasin and
             14-C Nicarbazin in a Field Soil Plot. Project Number: ABC/0284. Unpublished
             study prepared  by Exponent. 55 p.
46445300    Innolytics, LLC (2005) Submission of Product Chemistry, Toxicity,
             Environmental  Fate Data in Support of the Application for Registrations of
             LLC/Nicarbazin 30% Granulated Premix, Ovocontrol P and Ovocontrol G.
             Transmittal of 6 Studies.
46445301    Wolf, E.; MacDonald, A. (2004) Description of Analytical Methods for
             Nicarbazin and the Manufacturing Use Product Nicarbazin 30% Granulated
                                        20

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             Premix, Impurities, and Quality Control Processes. Project Number:
             NICARBAZIN/04/24. Unpublished study prepared by Exponent. 82 p.
46445302    Gallagher, S.; Beavers, J. (2004) Nicarbazin Technical: A Dietary LC50 Study
             with the Mallard. Project Number: 573/102. Unpublished study prepared by
             Wildlife International, Ltd. 89 p.
46445303    Messina, J. (2004) Nicarbazin Avian Reproduction. Project Number:
             NICARBAZIN/04/18. Unpublished study prepared by Wildlife International,
             Ltd. 35 p.
46445304    Bynum, K.; Eisemann, J.; Miller, L.; et. al. (2004) Efficacy of 2500 ppm
             Nicarbazin for Reproductive Inhibition in Canada Geese. Unpublished study
             prepared by US Dept. of Agriculture, APHIS, WS. 37 p.
46445305    McCracken, B. (2004) Aqueous Hydrolysis of Nicarbazin Under Laboratory
             Conditions Amendment 1. Project Number: EXP/108/002, P0000693.
             Unpublished study prepared by Exygen Research. 55 p.
46445306    Manthey, J. (1984) A Greenhouse Study to Determine the Rate of Decline of
             Soil Incorporated Narasin and 14C Nicarbazin Singly and in Combination.
             Project Number: ABC/0209. Unpublished study prepared by Exponent. 58 p.
46459800    Innolytics, LLC (2005) Submission of Toxicity and Fate Data in Support of the
             Application for Registration of Nicarbazin. Transmittal of 2 Studies.
46459801    Habig, C.; Messina, J.; Daniels, C. (2005) Nicarbazin Waiver Request from
             Further Testing. Project Number: NICARBAZIN/04/40. Unpublished study
             prepared by Exponent. 10 p.
46459802    Habig, C.; Messina, J.; Daniels, C. (2005) Nicarbazin Waiver Request from
             Further Testing. Project Number: NICARBAZIN/04/39. Unpublished study
             prepared by Exponent, lip.
46471700    Innolytics, Inc. (2005) Submission of Environmental Fate Data in Support of
             the Application for Registration of Nicarbazin. Transmittal of 1 Study.
 46471701    Wolf, E. (2005) Determination of the Toxicity of Nicrazin (Nicarbazin) and
             Supacox (Pancoxin Plus) to Eight Higher-Plant Species by Soil Application.
             Project Number: NICARBAZIN/04/38, WD00775/000. Unpublished study
             prepared by Exponent. 47 p.
46497100    Innolytics. LLC. (2005) Submission of Toxicity and Efficacy Data in Support of
             the Application for Registration of Ovocontrol P. Transmittal of 3 Studies.
46497101    Wolf, E. (2005) Nicarbazin Avian Reproduction Support Documentation.
             Project Number: QA/737, QA/774, QA/850. Unpublished study prepared by US
             Dept.  of Agriculture, APHIS, WS, University of Georgia and Clemson
             University. 115 p.
46497102    Habig, C.; Messina, J.; Daniels, C. (2005) Nicarbazin Waiver Request from
             Further Testing: Fish Accumulation. Project Number: NICARBAZIN/03/15.
             Unpublished study prepared by Exponent. 9 p.
                                        21

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46497103     Bynum, K.; Eisemann, I; Weaver, G.; et. al.; (2005) QA-1102: Multi-center
             Field Study of Nicarbazin Bait for use in the Reduction in Hatching of Eggs
             Laid by Local Canada Goose (Branta canadensis) Flocks. Project Number:
             QA/1102. Unpublished study prepared by US Dept. of Agriculture, APHIS, WS
             and Innolytics, LLC. 130 p.
46645600     Innolytics, LLC (2005) Submission of Toxicity Data in Support of the
             Application for Registration of OvoControl G. Transmittal of 1 Study.
46645601     Messina, J.; Daniels, C. (2005) Nicarbazin Waiver Request from Further
             Testing: Acute Inhalation Toxicity LC50. Project Number:
             NICARBAZIN/05/01. Unpublished study prepared by Exponent. 8 p.
                                        22

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