Draft for Public Comment March 11, 2016

1

Retrospective Analysis & Guidance for Waiving Acute Dermal Toxicity Tests for 

Pesticide Formulations

1.0 Introduction

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) authorizes EPA to register pesticides and 

require supporting studies to meet statutory safety standards as stipulated under 40 Code of Federal 

Regulations (CFR) Part 158. There is flexibility, however, in implementing Part 158. Additional data can 

be required (§158.75), alternative approaches can be accepted, and studies can be waived (§158.45). 

The 2007 NAS report on Toxicity Testing in the 21st Century describes a new vision for toxicity testing. 

EPA’s Office of Pesticide Programs has developed a Strategic Direction for New Pesticide Testing and 

Assessment Approaches (http://www2.epa.gov/pesticide-science-and-assessing-pesticiderisks/strategic-vision-adopting-21st-century-science) which describes OPP’s approach to implementing 

the NAS vision. One component of OPP’s strategic vision describes the need for improved approaches 

to more traditional toxicity tests to minimize the number of animals used while expanding the amount 

of information obtained. OPP’s document on Guiding Principles for Data Requirements notes the 

importance of only requiring data that inform regulatory decision making and avoid unnecessary use of 

time and resources, data generation costs, and animal testing

(http://www2.epa.gov/sites/production/files/2015-04/documents/data-require-guide-principle.pdf). 

Waiving studies, when such data offer little or no additional scientific information or public health 

protection, is an important component of the guiding principles for data requirements. OPP staff can

focus on the information most relevant to a particular assessment and still ensure there is sufficient 

information for regulatory decisions that are protective of public health and the environment. 

In 2012, OPP published a “Guidance for Waiving or Bridging of Mammalian Acute Toxicity Tests for 

Pesticides and Pesticide Products (Acute Oral, Acute Dermal, Acute Inhalation, Primary Eye, Primary 

Dermal, and Dermal Sensitization)” which consolidated previously existing guidance on waivers for acute 

toxicity tests. That 2012 guidance document noted that generally, waivers are considered when data to 

support a particular endpoint are not relevant to the chemical. Specifically, data related to dermal acute 

toxicity for conventional, antimicrobial, and biochemical pesticides may be waived if any of the following 

criteria are met:

 The test material has been placed in Toxicity Category I for primary dermal irritation. Such 

products will be placed in dermal Toxicity Category I1on the basis of potential dermal effects.

 The test material is corrosive to skin, or has a pH less than 2 or greater than 11.5. (40 CFR 

158.500(e)(3); 40 CFR 158.2050(e)(2); 40 CFR 158. 2083(e)(2); 40 CFR 161.340(b)(2). Such 

products will be placed in dermal Toxicity Category I on the basis of potential dermal effects.

 The product design prevents dermal exposure. Products such as childproof insect baits and 

rodent bait boxes typically meet these criteria.

 

1

Acute toxicity categories are defined in Table 2. 
Draft for Public Comment March 11, 2016

2

The current document expands the potential for data waivers for acute dermal studies for formulated 

pesticide products. Several published studies (Creton et al, 2010; Seidle et al., 2011; Moore et al., 

2013)2have investigated comparability between oral and dermal acute hazard classifications to assess 

whether tests for both routes are needed. Together, these studies suggest that dermal and oral acute 

studies generally classify chemicals into similar categories, but none suit the needs of OPP since they did 

not evaluate the EPA OPP categorization scheme and primarily evaluated single agents. OPP and the 

National Toxicology Program (NTP) Interagency Center for the Evaluation of Alternative Toxicological 

Methods (NICEATM) have conducted a retrospective analysis of oral and dermal acute lethality studies 

that fit the regulatory context relevant for OPP. This analysis focuses on formulated pesticide products 

and considers the EPA pesticide categorization scheme which uses acute study results (see

40CFR156.212 and 40CFR156.62). The OPP/NICEATM analysis is designed to evaluate the relative 

consistency of the findings of oral and dermal studies (Section 2.0). The agency has used this analysis 

to support a draft policy statement in Section 4.0 to waive all acute lethality dermal studies for

formulated pesticide products. 

Ecological effects assessments often rely on acute studies for the technical active ingredient and are 

thus needed to ensure the safety to non-human mammals. As such, this document focuses only on

formulated pesticide product testing. However, many more acute toxicity studies are submitted to OPP 

annually for formulated pesticide products than are acute studies on active ingredients. Thus, the 

potential animal and resource savings from waivers is derived more from formulated pesticide products 

than single chemical acute toxicity studies. 

2.0 Retrospective Analysis

The retrospective analysis conducted by OPP/NICEATM is provided below. 

2.1 Dataset for Analysis

The agency developed a dataset of rat acute oral and acute dermal LD50 studies. The spreadsheet of 

data used in the analysis is provided in Dermal Data Spreadsheet for 593 Active Pesticide 

Ingredients.xlxs. Inclusion/exclusion criteria are described below.

2.1.1. Selection of Studies

Identification of Active Ingredients: The active ingredients include conventional pesticides, 

antimicrobials, and biopesticides are included across numerous chemical classes and across Toxicity 

Categories. Fumigants and rodenticides were excluded because of their physical forms and the types of 

 

2

Creton et al. 2010. Acute toxicity testing of chemicals-Opportunities to avoid redundant testing and use 

alternative approaches. Crit Rev Toxicol 40: 50-83. Seidle et al. 2011. Examining the regulatory value of multiroute mammalian acute systemic toxicity studies. ALTEX 28:95-102. Moore et al. 2013. Can acute dermal systemic 

toxicity tests be replaced with oral tests? Regul Toxicol Pharmacol 66:30-7.
Draft for Public Comment March 11, 2016

3

exposures that would be anticipated for them. There are 316 active ingredients3in the dataset used in 

the current analysis (Appendix 1). 

Identification of Acute Oral & Dermal Studies: Searches were conducted from the Office of Pesticide 

Programs Information Network (OPPIN) database in December 2013-January 2014 which included all 

available acute studies for formulated pesticide products available for the active ingredients listed in 

Appendix 1. Information collected from OPPIN included: Master Record Identification (MRID) number, 

product registration number, Pesticide Chemical (PC) code, CAS number, formulation name, formulation 

type, registration status, species (and sex), LD50 value, EPA toxicity category, test acceptability, and study 

type. This search yielded thousands of studies across different taxa and different routes/toxicities. 

From this initial search, acute oral and dermal studies were identified. To achieve a dataset that was 

broadly representative, but manageable in size, the following considerations were used: 

1. Only rat studies were selected. To reduce uncertainty associated with comparing 

results across species, non-rat species were eliminated. 

2. Focus on studies from last decade. With changes to approved inerts and revisions to 

the acute oral guideline, when data on multiple formulation types were available for a 

particular active ingredient, the study selection focused on newer studies. This was 

balanced with the need to have broad representation of formulation type and Toxicity

Category.

3. Because toxicity (particularly absorption) can be influenced by the nature of the 

exposure, multiple formulation types. For each active ingredient in the dataset, 

generally, one oral-dermal study pair was selected for each formulation type available 

for that active ingredient.

4. Impregnated materials & microencapsulated formulations were excluded. These types 

of products were excluded because they tend to have a unique composition which can 

impact the rate of release from the product. This uniqueness does not lend itself to an 

analysis intended for groups of products to be used in a generic approach. 

5. Formulation intermediates were excluded. Since there will be limited/no exposure to 

pesticide handlers & applicators to intermediates, these data are not relevant to the 

analysis.

From the identified oral & dermal studies, “paired” studies were selected. ‘Paired’ studies are those 

which were conducted on the same formulated pesticide product for oral and dermal lethality. This 

pairing was achieved by matching the registration number and formulated pesticide product name with 

consideration of PC code and CAS number. Data evaluation records (DERs) were collected for paired 

studies. From these DERs, the LD50 and Toxicity Category were entered into the spreadsheet.

 

3

Note: Some active ingredients come in multiple forms such as salts or acids; each form is counted as a separate 

active ingredient for this document. 
Draft for Public Comment March 11, 2016

4

2.1.2. Characterization of the Dataset

The dataset of rat acute oral and acute dermal LD50 studies includes 593 formulated pesticide products, 

representing 316 active ingredients; all four Toxicity Categories; and 13 different formulated pesticide 

product types (Table 1). Among the 593 formulations, 272 of these formulations have a single active 

ingredient, 185 have two, 78 have three, and 58 have four or more. 

Table 1. Formulated pesticide product types in the dataset

Formulation Type Number

Dust 16

Emulsifiable concentrate 143

Flowable concentrate 64

Granular 45

Pellet/tablet 7

Pressurized dust 1

Pressurized liquid 20

Ready to use solution 69

Soluble concentrate 125

Soluble concentrate/solid 8

Water dispersible granule 64

Water soluble package 14

Wettable powder 13

Not available (n/a) 4

2.2 Comparison of Toxicity Category between oral and dermal studies 

As shown in the blue boxes in Table 2 below, for 339 of the 593 formulations, the paired oral and dermal 

studies provide the same Toxicity Category (blue boxes). For 224 formulations, the oral study provides a 

lower (i.e., more potent) Category than the dermal study (light orange boxes). 

For 30 formulations, the dermal study provides a lower (i.e., more potent) Category than the oral study 

(tan and purple boxes). Two formulations (tan box) have a Toxicity Category II for dermal and Toxicity 

Category III for oral (i.e., a more potent Category for dermal compared to oral) and 28 formulations in 

the dataset have a Toxicity Category III for dermal and a Toxicity Category IV for oral (purple box). 

One of the most important uses of acute study data in the registration process for pesticides is in making 

personal protective equipment (PPE) decisions (such as a requirement to wear gloves when using the 

product). Therefore, for the 30 formulated pesticide products where the dermal study provides a lower 

Toxicity Category than the oral study, the agency further investigated additional information used for 

evaluating dermal worker PPE (see Section 2.3). The Toxicity Categories are also used for hazard 

labeling, first aid, and precautionary statements (http://www2.epa.gov/pesticide-registration/labelreview-manual).
Draft for Public Comment March 11, 2016

5

Table 2. Results of comparison analysis for oral & dermal formulation acute 

studies

Rat 

Dermal 

Hazard 

Category 

(mg/kg)

Rat Oral Hazard Category (mg/kg)

EPA I EPA II EPA III EPA IV

≤50 >50 – ≤500 >500 – ≤5000 >5000

EPA I

1 0 0 0

≤200

EPA II

>200 – 0 2 2 0

≤2000

EPA III

>2000 – 0 23 133 28

≤5000

EPA IV

0 28 173 203

>5000

Total 1 53 308 231

2.3 Detailed Evaluation of Studies with Lower Dermal Category Compared to Oral 

As noted above, for the 30 formulations (purple & tan boxes in Table 2) which showed a lower Toxicity 

Category from the dermal study compared to the oral, the agency further investigated what information 

was used for determining dermal PPE to determine if the dermal hazard study was critical to decisions 

on required protective equipment. 

EPA’s Label Review Manual4provides information on how acute toxicity information is used in pesticide

labeling; Table 3 was extracted from Chapter 10 (Worker Protection Labeling). 

 

4

http://www2.epa.gov/sites/production/files/documents/label-review-manual.pdf
Draft for Public Comment March 11, 2016

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Table 3. ToxicityCategoryby Routeof Exposureof End-UseProduct

Routeof Exposure

I

DANGER

II

WARNING

III

CAUTION

IV

CAUTION

Dermal Toxicity or Skin

Irritation Potential1

Coverallswornover

long-sleeved shirt and

longpants

Coverallswornover

short-sleevedshirt and

short pants

Long-sleevedshirt and

longpants

Long-sleevedshirt and

longpants

Socks Socks Socks Socks

Chemical-resistant

footwear

Chemical-resistant

footwear

Shoes Shoes

Chemical-resistant

Gloves2

Chemical-resistant

Gloves2

Chemical-resistant

Gloves2

Nominimum4

Inhalation

Toxicity

Respiratory

protectiondevice3

Respiratory

protectiondevice3

Nominimum4Nominimum4

Eye Irritation

Potential

Protectiveeyewear

5

Protectiveeyewear

5

Nominimum4Nominimum4

1

If dermaltoxicity and skinirritationtoxicity categories are different,PPE shallbe determinedby themore severetoxicitycategoryofthe

two. If dermaltoxicity orskin irritationis category I orII,referto Section 2 below to determine if additional PPE isrequired beyondthat

specifiedin Table1

2

Referto Section3, Table 3 todeterminethe specific typeof chemical-resistant glove.

3

Referto Section4 to determinethe specific typeofrespiratoryprotection.

4

AlthoughnominimumPPE isrequiredforthesetoxicity categoriesandroutesof exposure,the Agency may requirePPEona

product-specificbasis.

5

“Protective eyewear”isto be usedinsteadof “goggles”and/or “faceshield”and/or “shieldedsafety glasses”and similartermsto

describe eyeprotection, unlessthe assessmentrequiresa specific typeof eyewearfor adequate protection.

Two of the 30 formulations are consumer products for which EPA does not require gloves or any other 

form of protective clothing (e.g., use of a coverall). 

Three of the remaining 28 formulations (FINALE--glufosinate ammonium; SCALA--pyrimethanil; DREXEL 

SUFFA-8--sulfur) were tested at a limit dose of 4000 mg/kg in the dermal study with no mortalities. The 

limit dose to achieve Category IV is 5000 mg/kg. For these three formulations, the agency believes that 

a dermal dose of 4000 mg/kg is close in magnitude to 5000 mg/kg and believes the dermal Category III is 

an artifact of dose selection, not due to toxicity from dermal exposure below 5000 mg/kg. 

As noted in Table 3, the dermal irritation study is also used in pesticide labeling. Of the remaining 25

formulated pesticide products, five of the products have a dermal irritation study which provides a 

Toxicity Category equal to or lower than the dermal acute Toxicity Category. 

For the remaining 20 products, the agency considered the chemical-specific worker protection labeling 

requirements identified in regulatory assessment documents (Reregistration Eligibility Decision (RED), 

Registration Review Documents, etc.). In the pesticide labeling process, label reviews consider not only 

the product specific labeling defined in the acute toxicity review, but also the chemical-specific worker 

protection labeling defined by the RED/registration review document and the most current regulatory 

risk assessment document. As such, the acute toxicity review is not the only source of information for 

pesticide labeling. Table 3 provides the framework for defining personal protective equipment for acute 

dermal toxicity and dermal irritation studies; however, the framework in Table 3 is pre-empted when 
Draft for Public Comment March 11, 2016

7

the human health risk assessment identifies potential concern for worker risk that requires more PPE

than identified by the acute toxicity review. 

Information on how pesticide handler5exposure assessment is conducted to assess worker dermal risk 

can be found at: http://www2.epa.gov/pesticide-science-and-assessing-pesticide-risks/occupationalpesticide-handler-exposure-data. This exposure assessment approach specifically considers exposure 

scenarios for specific type(s) of application equipment, formulation type, job function, and level of PPE. 

Calculated exposure values are then compared to toxicology values (e.g., no-observed adverse effects 

levels, NOAELs) to assess potential worker risk. These toxicity values are derived from acute or repeat 

dosing studies in laboratory animals evaluating systemic toxicity, not lethality. Thus, these toxicity 

values are more robust and appropriate for assessing worker safety than are acute lethality studies. As 

such, the human health risk assessment provides the agency a means to specifically consider whether or 

not PPE are required to protect against human health effects. 

For the remaining 20 pesticide products identified with lower dermal toxicity categories than oral, 11 

had active ingredients for which the human health risk assessment indicated PPE was required based on

risk concerns. Risk assessments for the active ingredient in five formulations indicated no dermal risk at 

‘baseline’ (baseline scenario means that the analysis is conducted assuming long sleeved shirt, pants and 

socks and shoes (i.e., without a consideration for use of gloves)), and risk assessments for the active 

ingredient in four formulations indicated no dermal hazard based on subchronic dermal toxicity 

studies—together suggesting that the glove requirement associated with the Toxicity Category III from 

the acute lethality study over labeled the PPE for these nine. 

3.0 Discussion: Implications of Retrospective Analysis on Utility of Acute Dermal Formulated 

pesticide product Studies

The overall purpose of this analysis is to address the utility of the acute dermal toxicity study for 

formulations in pesticide labelling for end use products as described in 40CFR156.2126. To this end, this 

analysis includes a large number of formulations (593) and active ingredients (316) across numerous 

classes representing conventional pesticides, antimicrobials, and biopesticides. 

For 57% of the 593 formulations, oral and dermal studies provide the same Toxicity Category. For 38%, 

the oral study provides a lower (i.e., more conservative) Category. Thus, for 95% of the formulations in 

the analysis, the dermal toxicity study was similar or less sensitive than the oral study. In other words, 

for 95% of the studies, if the dermal study had not been available and labelling had occurred only from 

the Toxicity Category for the oral formulation study, the respective labelling would have been equally 

protective or more protective. For the remaining 5%, as noted above, the dermal acute toxicity category 

is not the only source of information for pesticide labelling. Dermal irritation studies are used in 

 

5

Individuals who are involved in, and potentially can experience exposure during, the pesticide application process 

in agricultural and non-agricultural settings.

6

The agency is aware that with respect to pesticide labelling of end use products based on Toxicity Categories, 

other aspects such as the signal word (40CFR156.64) and precautionary statements (40CFR156.70) may be affects.
Draft for Public Comment March 11, 2016

8

addition to chemical-specific worker protection labeling defined by the RED/registration review 

document and the most current regulatory risk assessment, where the risk assessments utilize more 

robust approaches to worker protection. When all these sources of information are considered 

together, the dermal acute toxicity study for formulations provides little to no added value in regulatory 

decision making. 

4.0 Waiver Guidance.

The agency believes this retrospective analysis fully supports a conclusion that waivers can be granted of 

acute dermal toxicity studies for formulations. The agency will be soliciting public comment on this draft 

policy. Registrants may begin submitting waiver requests through existing processes to respective OPP 

division. 
Draft for Public Comment March 11, 2016

9

Appendix 1. List of active ingredients in the retrospective analysis
Draft for Public Comment March 11, 2016

10

1-Decanaminium, N-decyl-N,Ndimethyl-, chloride

1-Methylheptyl ester

1,2 Benzisothiazolin

1,2-Benzisothiazolin-3-one

1H-Pyrrole-3-carbonitrile,4-bromo-2-

(4-chlorophenyl)-5-(trifluoromethyl)-

2-(Thiocyanomethylthio)benzothiazole

2-Bromo-2-nitro-1,3-propanediol

2-Bromo-2-nitropropane-1,3-diol

2-Methyl-3(2H)-isothiazolone

2-Methyl-4-chlorophenoxyaceticacid

2-Methyl-4-isothiazolin-3-one

2-N-Octyl-4-isothiazolin-3-one

2-Pyridinecarboxylicacid

2-Pyridinesulfonamide

2,4-D

2,4-D, dimethylamine salt

2,4-Dichlorophenoxy

3-Iodo-2-propynylButylCarbamate

3-Iodo-2-propynylester

4,5-Dichloro-2-n-octyl-3(2H)-

isothiazolone

5-Chloro-2-methyl-3(2H)-isothiazolone

5-Chloro-2-methyl-4-isothiazolin

5-Chloro-2-methyl-4-isothiazolin-3-

one

AA10717

Abamectin

Acephate

Acequinocyl

Acetamiprid

Acetochlor

Aldicarb

Alkyl dimethyl benzyl ammonium 

chloride

Alkyl* dimethyl benzyl ammonium 

chloride *(60%C14, 30%C16, 5%C18, 

5%C12)

Alkyl* dimethyl benzyl ammonium 

chloride *(67%C12, 25%C14, 7%C16, 

1%C18)

Ametoctradin

Amicarbazone

Aminochloropryridazinones

Aminocyclopyrachlor

Aminopyralid

Amitraz

Amitrole

Ammonium bromide

Ammonium soaps of fatty acids

Atrazine

Azoxystrobin

Benzeneacetate

Bifenazate

Bifenthrin

Bispyribac-sodium

Boscalid

Bromadiolone

Bromoxynil

Bronopol

Buprofezin

Butoxy polypropylene glycol

Captan

Carbamic acid

Carbamic acid, butylCarbendazim

Carboxin

Carfentrazone-ethyl

Carobxin

Chlorantraniliprole

Chlorfenapyr

Chlorimuron-ethyl

Chlorine dioxide

Chlorothalonil

Chloroxylenol

Chlorpropham

Chlorpyrifos

Chlorpyrifos-methyl

Chlorsulfuron

Cinnamaldehyde

cis-9-tricosene

Citric acid

Clopyralid

Clothianidin

Copper Carbonate

Copper Pyrithione

Cupric oxide

Cuprous oxide

Cyclanilide

Cyfluthrin

Cyhalofop-butyl

Cymoxanil

Cypermethrin

Cyproconazole

Cyprodinil

Cyromazine

DDVP

Deltamethrin

Desmedipham

Di-potassium phosphite

Dicamba

Dicamba, dimethylamine salt

Dicamba acid

Dichlorophenylpryridazinones

Didecyl dimethyl ammonium chloride

Difenconazole

Diflubenzuron

Dimethenamid

Dimethoate

Dimethomorph

Dimethylamine

Dinotefuran

Dioctyl dimethyl ammonium chloride

Diphacinone

Diquat bromide

Diquat Dibromide

Dithiopyr

Diuron

Econea

Emamectin benzoate

Esfenvalerate

Ethaneperoxoic acid

Ethanol

Ethephon

Ethofumesate

Ethyl alcohol

Ethylhexyl ester

ETOC

Etofenprox

Etoxazole

Famoxadone

Fenhexamid
Draft for Public Comment March 11, 2016

11

Fenpropathrin

Fenpropimorph

Fipronil

Flazasulfuron

Flonicamid

Florasulam

Fluazifop-p-butyl

Flubendiamide

Fludioxonil

Flufenacet

Flumetsulam

Flumioxazin

Fluopicolide

Fluopyram

Fluoxastrobin

Fluroxypyr

Fluroxypyr 1-methylheptyl ester

Fluroxypyr-meptyl acetic acid

Flurprimidol

Fluthiacet-methyl

Flutriafol

Fluxapyroxad

Folpet

Forchlorfenuron

Fosthiazate

Gamma-cyhalothrin

geraniol

Glufosinate

Glufosinate-ammonium

Glutaraldehyde

Glycolic acid

Glyphosate

Glyphosate IPA

Halosulfuron-methyl

Hydrogen peroxide

Hydroprene

Imazalil

Imazamox

Imazethapyr

Imazosulfuron

Imidacloprid

Imiprothrin

Indaziflam

Indoxacarb

Iodosulfuron-methyl-sodium

IPBC

Ipconazole

Iprodione

Isopropanol

Isoxaben

Isoxaflutole

Kresoxim-methyl

lambda-cyhalothrin

Malathion

Maleic hydrazide

Mancozeb

Mandipropamide

MCPA

MCPA (and salts and esters)

MCPPpacid

Mecoprop

Mecoprop-p

Mecoprop-p acid

Mefenoxam

Mepiquat chloride

Mesosulfuron-methyl

Mesotrione

Metaflumizone 

Metalaxyl

Metalaxyl-M

Metaldehyde

Metconazole

Methiocarb

Methomyl

Methoxyfenozide

Methylene bis(thiocyanate)

Methyleugenol

Metiram

METRAFENONE

Metribuzin

Metsulfuron

MGK264

Mono-potassium phosphite

Myclobutanil

N-[[(4,6-dimethoxy-2-

pyrimidinyl)amino]carbonyl]-3-(2,2,2-

trifluoroethoxy)-, monosodium salt, 

monohydrate

n-Alkyl dimethyl benzyl ammonium 

chloride

N-Alkyl dimethyl ethylbenzyl 

ammonium chlorides

N-Cyclopropyl-N-N’-(1,1-

dimethyethyl)-6-(methylthio)- 1,3,5-

triazine-2,4-diamine

N-Octyl bicycloheptene dicarboximide

Napropamide

Nicosulfuron

NOIT

Nonanoic acid

Noviflumuron

o-Phenylphenol

Octhilinone

Octyldecyldimethylammoniumchloride

ortho-benzyl-para-chlorophenol

Orthosulfamuron

Paclobutrazol

para-tertiary-amylphenol

PBO

Pelargonic acid

Pendimethalin

Penflufen

Penoxsulam

Pentachloronitrobenzene

Penthiopyrad

Permethrin

Phenmedipham

Phosmet

Picloram

Picoxystrobin

Pinoxaden

Piperonyl Butoxide

Potassium phosphate, monobasic

Potassium Salts of Fatty Acids

Potassium silicate

Prallethrin

Prohexadione calcium

Promethryn

Propiconazole

Propoxycarbazone-sodium 

Propyzamide

Prothioconazole
Draft for Public Comment March 11, 2016

12

Pyraclostrobin

Pyraflufen-ethyl

Pyrasulfotole Technical

Pyrazon

Pyrethrins

Pyridine

Pyrimethanil

Pyriproxyfen

Pyroxasulfone

Pyroxsulam

Quinclorac

Quinoxyfen

Rimsulfuron

S-bioallethrin

S-Methoprene

S-metochlor

Saflufenacil

Sedaxane

Silver

Silver nitrate

Simazine

Sodium bromide 

Sodium chlorite

Sodium dichloro-s-triazinetrione

Sodium percarbonate

Sodium salt of dicamba

Spinetoram

Spinosad

Spirodiclofen

Spirotetramat

Stabilene

sulfentrazone

Sulfosulfuron

Sulfur

Tau-fluvalinate

Tebuconazole

Tembotrione

Tepraloxydim

Terbuthylazine

Tetrachloroisophthalonitrile

Tetrachlorvinphos

Tetraconazole

Tetrahydro-3,5-dimethyl-1,3,5-

thiadiazine

Thiabendazole

Thiamethoxam

Thidiazuron

Thiencarbazone-methyl

Thifensulfuron

Thifensulfuron-methyl

Thiophanate-methyl

Thiram

Thymeoil

Tolfenpyrad

Topramezone

Tralopyril

Triasulfuron

Tribenuron Methyl

Trichlorfon

Triclopyr

Trifloxystrobin

Trifluralin

Trinexapac-ethyl

Triticonazole

Zeta-Cypermethrin

Zinc pyrithione

Zinc 2-pyridinethiol-1-oxide

Zoxamide
Draft for Public Comment March 11, 2016

13