United States       Prevention, Pesticides     EPA 712-C-95-011
          Environmental Protection    and Toxic Substances     August 1995
          Agency         (7101)
&EPA   Product Properties
          Test Guidelines
          OPPTS 830.1700
          Preliminary Analysis
                  'Public Draft"

-------
                           INTRODUCTION
     This guideline is one of a series of test guidelines that have been
developed by the Office of Prevention, Pesticides and Toxic Substances,
United States Environmental Protection Agency for use in the testing of
pesticides and toxic substances, and the development of test data that must
be submitted to the Agency for review under Federal regulations.

     The Office of Prevention,  Pesticides and Toxic Substances (OPPTS)
has  developed this guideline through a  process of  harmonization that
blended the testing  guidance and requirements that existed in the  Office
of Pollution Prevention and Toxics  (OPPT) and appeared in Title 40,
Chapter I,  Subchapter R of the Code of Federal Regulations  (CFR), the
Office of Pesticide Programs (OPP) which appeared in publications of the
National Technical  Information Service (NTIS) and the guidelines pub-
lished by the Organization for Economic Cooperation and Development
(OECD).

     The purpose of harmonizing these guidelines into a single  set of
OPPTS  guidelines is to minimize variations among the testing procedures
that must be performed to meet the data requirements of the U. S. Environ-
mental Protection Agency under the Toxic  Substances Control Act (15
U.S.C. 2601) and the Federal Insecticide,  Fungicide and Rodenticide Act
(7U.S.C. I36,etseq.).

     Public Draft Access Information: This draft guideline is part of a
series of related harmonized guidelines that  need to  be considered as a
unit. For copies: These guidelines are available electronically from the
EPA Public Access Gopher (gopher.epa.gov) under the heading "Environ-
mental Test Methods and Guidelines" or in paper by  contacting the OPP
Public    Docket    at    (703)    305-5805    or    by    e-mail:
guidelines@epamail.epa.gov.

     To Submit Comments: Interested persons are invited to submit com-
ments. By mail: Public Docket and Freedom of Information Section,  Office
of Pesticide Programs, Field Operations Division (7506C), Environmental
Protection Agency,  401  M  St.  SW.,  Washington, DC 20460. In person:
bring to: Rm. 1132, Crystal Mall #2, 1921 Jefferson Davis Highway, Ar-
lington, VA. Comments may also be submitted  electronically by sending
electronic mail (e-mail) to: guidelines@epamail.epa.gov.

     Final  Guideline Release:  This document is available from the U.S.
Government Printing Office, Washington, DC 20402 on The Federal Bul-
letin Board. By modem dial 202-512-1387, telnet:  federal.bbs.gpo.gov
3001, or call 202-512-1530 for disks or  paper  copies.  This guideline is
available in ASCII and PDF (portable document format).

-------
OPPTS 830.1700   Preliminary analysis.
     (a) Scopeó(1) Applicability. This guideline is intended to meet test-
ing  requirements   of both  the  Federal  Insecticide,  Fungicide,   and
Rodenticide Act (FIFRA) (7 U.S.C. 136, et seq.) and the Toxic Substances
Control Act (TSCA) (15 U.S.C. 2601).

     (2) Background. The source material  used in developing this har-
monized OPPTS test guideline is 40 CFR 158.170.

     (b) Information required. (1)  If the product consists solely of the
technical grade active ingredient (TGAI) or is produced by an integrated
system, the applicant must provide a preliminary analysis of each technical
grade of active ingredient contained in the product to identify all impurities
present at 0.1 percent or greater of the TGAI (the Agency recognizes that
this may not be appropriate for certain biologicial pesticides). The prelimi-
nary analysis should be conducted at the  point in the production process
after which no further chemical reactions designed to produce  or purify
the substance are intended.

     (2) Based on the preliminary analysis, a statement of the composition
of the technical grade of active ingredient must be provided. If the tech-
nical grade of active ingredient cannot be isolated, a statement of the com-
position of the practical equivalent of the technical grade of active ingredi-
ent must be submitted.

     (c) Data reporting format.  (1) The  manufacturer's/registrant's/peti-
tioner's reports should include all information necessary to provide com-
plete and accurate topical discussions of the pesticide product.

     (i) Title/cover page. Title page and additional documentation require-
ments  (i.e., requirements for data submission and  procedures for claims
of confidentiality of data) if relevant to the study  report should precede
the content of  the  study formatted below.  These currently proposed re-
quirements are described at 49 FR 37596, September 26,  1984.

     (ii) Table of contents.

     (A) Summary and introduction.

     (7) Scope  (suitable matrices) and source of method (e.g.,  "Manual
of the  Association of Official Analytical Chemists," or "EPA Manual of
Chemical  Methods and Devices" (see paragraphs (d)(l) and (d)(2) of this
guideline).

     (2) Principles of the analytical procedure (describe) including identi-
fication of the  chemical species  determined and the limits of detection
and sensitivity.

     (B) Materials and methods.

-------
     (1) Equipment (list and describe).
     (2) Reagents and standards (list and describe source and preparation).
         Analytical procedure (detail in a stepwise fashion,  with special
emphasis on reagents or procedural  steps requiring  special precautions to
avoid safety or health hazards):
     (/) Preparation of sample.
     (//) Extraction (demonstrate efficiency, if relevant).
     (///) Clean-up.
     (iv) Derivatization (if any).
     (4) Instrumentation (to include information on):
     (/) Description (e.g.,  make/model, type/specificity of detectors, col-
umns, (packing materials, size), carrier gases, etc.).
     (//) Operating conditions (e.g., flow rates, temperatures, voltage, etc.).
     (///) Calibration procedures.
     (5) Interferences (describe tests):
     (/) Sample matrices.
     (//) Other pesticides.
     (///) Solvents.
     (iv) Labware.
     (6) Confirmatory techniques (describe).
     (7) Time required for  analysis (to carry a  sample/set completely
through the analytical procedure, including the determinative step).
     (8) Modifications or potential problems, if any, in analytical methods
(detail circumstances and corrective action to be taken).
     (9) Methods of calculation (describe in a stepwise fashion):
     (/) Calibration factors.
     (//) Analyte in sample.
     (Iff) Other (any and all  relevant information the petitioner considers
appropriate and relevant to provide  a complete and thorough description
of residue analytical methodology and the means of calculating the residue
results).

-------
     (C) Results and discussion (describe expected performance of meth-
od).
     (7) Accuracy (expected mean and range of recoveries).
     (2) Precision.
     (3) Limits of detection and quantification (provide definition).
     (4) Ruggedness testing , if performed.
     (5) Limitations.
     (D) Conclusions.  Discuss  applicability  of analytical  procedure for
measuring  specific  test compounds in various test substrates, ready avail-
ability of equipment, interferences, etc.
     (E) Certification.  Certification of  authenticity by the  study director
(including  signature, typed name, title, affiliation, address, telephone num-
ber, date).
     (F) Tables and figures.
     (G) References.
     (H) Appendices.
     (7) Representative chromatograms, spectra, etc. (as applicable).
     (2) Other (any relevant material not fitting in any of the other sections
to this report).
     (2) [Reserved]
     (d) References. The following references should be consulted for ad-
ditional background material  on this test guideline.
     (1) Manual of the Association of Official Analytical Chemists,  Asso-
ciation of Offical Analytical  Chemists (AOAC), Arlington, VA, latest edi-
tion.
     (2) EPA Manual of Chemical Methods  and Devices, published by As-
sociation of Official Analytical Chemists (AOAC), Arlington, VA (1992).

-------