Washington, DC California Canada 1150 18 th Street, NW, Suite 1000 712 5 th Street, Suite A 275 Slater Street, Suite 900 Washington, DC 20036 Davis, CA 95616 Ottawa, Ontario K1P 5H9 Tel: 202

- 223

- 4392 Tel: 530

- 757

- 1245 Tel: 613

- 247

- 6285 Technology Sciences Group Inc. 712 Fifth Street, Suite A Davis, CA 95616 Direct: 530

- 757

- 1298 Fax: 530

- 757

- 1299 E

- Mail: alawyer@TSGUSA.com Web: www.TSGUSA.com
Arthur L. Lawyer, Ph.D. President May 18 , 2012 DuPont Crop Protection: Petition to Delete Chlorsulfuron from TRI List

Mr. Arnold E. Layne Director Office of Information Analysis and Access (Mail Code 2841T) Office of Environmental Information Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460

Dear Mr. Layne , On behalf of DuPont Crop Protection (DuPont) , Technology Sciences Group Inc. (TSG) respectfully submits the following petition to delete chlorsulfuron from the Toxics Release Inventory (TRI) list of reportable toxic chemicals (40 CFR § 372.65). Petitioner (on behalf of DuPont Crop Protection) Arthur Lawyer, Ph.D., President Technology Sciences Group Inc. 712 Fifth Street, Suite A Davis, CA 95616 Phone: 530

- 757

- 1298 Email: alawyer@tsgusa.com
Action Requested Delete chlorsulfuron from the TRI list of reportable toxic chemicals
Chemical Identity Chemical Name: Chlorsulfuron [2

- chloro

- N

- [[5

- methoxy

- 6

- methyl

- 1,3,5

- triazin

- 2

- yl)amino]carbonyl]benzenesulfonamide] Chemical Abstracts Service Registry Number: 64902

- 72

- 3Mr. Arnold E. Layne Chlorsulfuron ( 64902

- 72

- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 2 of 12

Summary On November 30, 1994, the United States Envir onmental Protection Agency ( USEPA or Agency) published a final rule in the Federal Register to add 286 chemicals and chemical categories to the list of toxic chemicals subject to reporting under Section 313 of the Emergency Planning and Community Right

- to

- Know Act of 1986 (EPCRA) (USEPA, 1994b). Chlorsulfuron ( 2

- chloro

- N

- [[5

- methoxy

- 6

- methyl

- 1,3,5

- triazin

- 2

- yl)amino]carbonyl]benzenesulfonamide ; CASRN 64902

- 72

- 3 ) was included in the rule and was added to the TRI list effective January 1, 1995.

In the Janua ry 12, 1994 proposed rule, USEPA stated that “there is sufficient evidence for listing chlorsulfuron on EPCRA Section 313 pursuant to EPCRA Section 313(d)(2)(B) based on the available developmental and reproductive toxicity data for this chemical.” (USEPA , 1994a) EPA noted in the proposed rule that in a rabbit developmental study an increased incidence of fetal resorptions was observed at the lowest observed effect level (LOEL) of 75 mg/kg/day and that the no observed effect level (NOEL) was 25 mg/kg/da y. Also noted in the proposed rule was that in a 3

- generation rat reproduction study a decrease in the fertility index was observed at 125 mg/kg/day (LOEL) and that the NOEL was 25 mg/kg/day ( USEPA, 1994a ).
The toxicity data cited for the above effects i n the listing were: 1) a 1980 developmental toxicity study in rabbits (Hoberman et al., 1980) and 2) a 1981 3

- generation reproduction study in rats (Wood et al., 1981). These studies have been superseded by newer studies conducted according to USEPA

- Guide lines: a 1991 developmental toxicity st udy in rabbits (Alvarez, 1991) and a 2005 2

- generation reproductive toxicity study in rats (Mylchreest, 2005). In addition, a new developmental toxicity study was conducted in rats (Alvarez, 1991b). The adverse effects identified in the original 1980 and 1981 studies that led to the cl assification of chlorsulfuron under the TRI, did not occur (i.e., were not replicated) in the guideline studies.
In 2002, the Health Effects Division (HED) of the Office of Pesticide Programs (OPP) of the USEPA concluded ( USEPA, 2002a ) that: “The data p rovided no indication of increased susceptibility [qualitative and quantitative] following in utero exposure to chlorsulfuron in either the rat or rabbit developmental toxicity study,” regarding the data from the newer guideline studies ( Alvarez, 1991, and 1991b ). Furthermore, the evaluation of the guideline 2

- generation rat reproductive toxicity study on chlorsulfuron by the USEPA in 2007 concluded that there were no adverse effects on reproduction, including the fertility index ( Mylchreest, 2005 ; USEPA, 2007).
Therefore, the USEPA conclusions based on the current EPA

- Guideline studies, that there were no teratogenic effects or adverse effects on reproduction, support deletion of chlorsulfuron from the TRI list. In the sections below each specific TRI li sting criteria element is addressed and the data presented demonstrate that chlorsulfuron fails to meet each criterion.Mr. Arnold E. Layne Chlorsulfuron ( 64902

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- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 3 of 12

Specific Criteria Elements The information and data presented below support the conclusion that chlorsulfuron does not meet any of t he following health and environmental effects criteria, referenced in Section 313(d)(2) of EPCRA; consequently chlorsulfuron should be deleted from the TRI list:
(A) The chemical is known to cause or can reasonably be anticipated to cause significant adverse acute human health effects at concentration levels that are reasonably likely to exist beyond facility site boundaries as a result of continuous, or frequently occurring, releases. (B) The chemical is known to cause or can reasonably be anticipated to cause in humans: i. Cancer or teratogenic effects, or ii. Serious or irreversible: I. Reproductive dysfunction, II. Neurological disorders, III. Heritable genetic mutations, or IV. Other chronic health effects.
The data and rationale that support the assertion that chlorsulfuron does not meet these criteria is found below.

Rationale for Deletion of Chlorsulfuron

Criterion (A): The chemical is known to cause or can reasonably be anticipated to cause significant adverse acute human health effects at concentration levels that are reasonably likely to exist beyond facility site boundaries as a result of continuous, or frequen tly occurring, releases.
According to the USEPA’s July 17, 2002 Toxicity Chapter for Chlorsulfuron (USEPA, 2002a) on chlorsulfuron from the Health Effects Division (HED) of the Office of Pesticide Programs (OPP) of the USEPA, “the acute toxicity data indi cate that chlorsulfuron is not acutely toxic via the oral [Toxicity Category IV], dermal [Toxicity Category III], and inhalation [Toxicity Category IV] routes of exposure.” This conclusion is based on results from acute oral, dermal, and inhalation studie s on rats referenced in Table 2 of the Toxicity Chapter for Chlorsulfuron (USEPA, 2002a, page 7).
USEPA’s subsequent August 14, 2002 final rule establishing a pesticide tolerance for chlorsulfuron (USEPA, 2002c) also noted in the exposure assessment secti on that “no toxicological endpoint attributable to a single exposure was identified in the available toxicology studies.” Furthermore, it was found that “no appropriate studies available show any acute dietary effects of concern.” Lastly, in the final ru le USEPA concluded that “no acute risk is expected.” (USEPA, 2002c)Mr. Arnold E. Layne Chlorsulfuron ( 64902

- 72

- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 4 of 12

Finally, in OPP’s May 20, 2005 Reregistration Eligibility Decision for Chlorsulfuron ( USEPA, 2005 ), the Agency concluded that the “human health risk assessment for chlorsulfuron indicates minimal risks.” Additionally, USEPA determined that “dietary exposure from ground water or surface water sources of drinking water are also low and not of concern.” Likewise, the Agency noted that “there are no concerns about the risk to homeowners or o ccupational workers who handle chlorsulfuron or are exposed to residues after chlorsulfuron is applied.”
Therefore, based on the above

- referenced USEPA conclusions, chlorsulfuron is not known to cause and cannot reasonably be anticipated to cause significant adverse acute human health effects at concentration levels that are reasonably likely to exist beyond facility site boundaries as a result of continuous, or frequently occurring, releases. As a result, chlorsulfuron does not meet criterion (A)

. Criterion (B)(i): The chemical is known to cause or can reasonably be anticipated to cause cancer or teratogenic effects in humans
Carcinogenicity According to the USEPA’s July 17, 2002 Toxicity Chapter for Chlorsulfuron ( USEPA, 2002a ) on chlorsulfuron, the Agency concluded that “there is no evidence of carcinogenicity in rats or mice following oral exposure to chlorsulfuron at dose levels considered adequate for the assessment of carcinogenic potential.” Likewise, upon development of a pe sticide tolerance in 2002, USEPA classified chlorsulfuron as having “no evidence of carcinogenicity.” (USEPA, 2002c)
Teratogenicity As previously discussed, chlorsulfuron was added to the TRI list of reportable toxic chemicals with an effective date of January 1, 1995. This classification and listing was the result of two studies, a 1980 teratology study in rabbits (Hoberman et al., 1980) and a 1981 3

- generation reproductive toxicity study in rats (Wood et al., 1981). These studies have been superseded by USEPA

- Guideline studies; a 1991 teratology studies in rabbits (Alvarez, 1991) and a 2005 2

- generation reproductive toxicity study in rats (Mylchreest, 2005). The adverse effects identified in the original 1980 and 1981 studies that led to the classif ication of chlorsulfuron under the TRI, were not replicated in the two replacement studies. The teratology studies are discussed in this section below, while the reproductive studies are discussed under the next criterion.
In 2002, USEPA concluded ( USEPA , 2002a ) that “there were no teratogenic effects” based on a 1991 teratology study in rats ( Alvarez, 1991b ) and no adverse effects were observed on the offspring at doses that were toxic to the maternal animal, therefore indicating a lack of teratogenic ef fects, from the 1991 teratology study in rabbits (Alvarez, 1991)

.Mr. Arnold E. Layne Chlorsulfuron ( 64902

- 72

- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 5 of 12 Rationale for Replacing 19 80 Teratology Study in Rabbits with 1991 Teratology Study in Rabbits USEPA ’s November 13, 1981 evaluation of the original 1980 teratology study in rabbits stat ed that “A NOEL of 25 mg/kg body weight was established for fetotoxicity based on an increased incidence of resorptions and lower fetal viability at 75 mg/kg body weight.” (USEPA, 1981) This conclusion was repeated in the 1983 chlorsulfuron summary for th e US EPA’s TRI program (a summary that led to classification of chlorsulfuron under TRI). A new, FIFRA

- Guideline developmental toxicity study in rabbits was conducted by DuPont and submitted in 1991 (Alvarez, 1991 ). The USEPA evaluation of this study, on May 2, 2002, reported that there were no effects of chlorsulfuron on resorptions. The original, 1980 rabbit teratology study (Hoberman et al., 1980) was not further assessed by the US EPA , including during the Agency’s development of the ir 2005 R eregistration Eligibility Decision ( RED ) document on chlorsulfuron ( USEPA, 2005 )

. Last year, as part of ongoing efforts to delist chlorsulfuron from California Proposition 65, DuPont submitted a Supplement to the original 1980 terato logy study in rabbits to California’s Office of Environmental Health Hazard Assessment ( OEHHA ) ( Hoberman et al., 1980, Supplement 1, Revision 1, 2011 ). In the Supplement to the 1980 rabbit study, the data for fetal resorptions from the original study were reviewed, and a clar ified interpretation of these data is provided in the supplemental report. The fact that in the 1991 guideline developmental toxicity study in rabbits ( Alvarez, 1991 ) the resorption incidence in treated rabbits was similar to background levels, lacked dos e dependency, and did not reproduc e the results from the earlier study even at doses of up to 1000 mg/kg/day (a dose more than 10

- fold higher than the highest dose in the original 1980 rabbit study) warrants reconsideration of the findings from the 1980 s tudy in which there was no other evidence of developmental toxicity reported.
In summary, the data discussed above and the associated USEPA conclusions support the determination that chlorsulfuron is not known to cause and cannot reasonably be anticipated to cause cancer or teratogenic effects in humans. As a result, chlorsulfuron does not meet criterion (B)(i).
Criterion (B)(ii)(I): The chemical is known to cause or can reasonably be anticipated to cause serious or irreversibl e reproductive dysfunction in humans
As previously mentioned, chlorsulfuron was added to the TRI list of reportable toxic chemicals based on the results of two studies, a 1980 teratology study in rabbits (Hoberman et al., 1980) and a 1981 3

- generation r eproductive toxicity study in rats (Wood et al., 1981). Again, both of these studies have been superseded by newer USEPA

- Guideline studies; a 1991 teratology study in rabbits (Alvarez, 1991) and a 2005 2

- generation reproductive toxicity study in rats (My lchreest, 2005). The adverse effects identified in the original 1980 and 1981 studies, that led to the classification of chlorsulfuron under the TRI were not replicated in the two replacement studies.Mr. Arnold E. Layne Chlorsulfuron ( 64902

- 72

- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 6 of 12 Rationale for Replacing the 1981 3

- Generation Repro ductive Toxicity Study with the 2005 2

- Generation Reproductive Toxicity Study The US EPA’s November 10, 1982 evaluation ( USEPA, 1982 ) of the original 1981 3

- generation reproductive toxicity study ( Wood et al., 1981 ) reported “A NOEL of 500 ppm based on decreased fertility indices ...” in the third generation , a conclusion based on the statements of the study author at that time . This conclusion was repeated in 1983 in the summar y of chlorsulfuron toxicity for the US EPA’s TRI p rogram. Subsequently, a new, FIFRA

- Guideline 2

- generation reproductive toxicity study was conducted in 2005 by DuPont ( Mylchreest, 2005 ). The evaluation of the study by the USEPA in 2007 concluded that there were no adverse effects on reproduction, inclu ding the fertility index (USEPA, 2007).
Earlier this year, DuPont , as part of their ongoing efforts to delist chlorsulfuron from California Proposition 65, submitt ed a Supplement to the original 1981 reproductive toxicity study ( Wood et al., 1981, Supplem ent 3, Revision 2, 2012 ) to California’s OEHHA . The Supplement illustrates that the original conclusion of the study author regarding the fertility index was made in the absence of a statistical analysis and was in error. The Supplemental evaluation supp orts the conclusion that the NOEL for fertility effects from dietary exposure to chlorsulfuron should be the highest dose tested, 2500 ppm, and not the 500 ppm exposure originally identified by the study author. The evaluations in the current supplement i nclude :

1) Comparison to fertility index data from the subsequent 2005 multi

generation reproductive toxicity study.
2) Comparison to historical control fertility data from the laboratory, including context to the rat strain variability information from the vendor around that time.
3) Statistical analyses of the fertility index data according to U S EPA procedures and current standard practice.
4) Presentation of the male fertil ity data not shown previously.
The fertility indices of all the control and treatment g roups on study ranged from 79 to 100%, all well within the historical control range of 60 to 100%. No effects on fertility were evident in the subsequent 2005 multi

- generation reproductive toxicity study which tested dietary concentrations of up to 7500 p pm, a dose that is three times higher than the highest dose of the 1981 study. Finally, statistical analyses of the Generation 3A and 3B litter data show that there is no significant treatment

- related effect in any dose group in that generation. In this regard, both the Cochran

- Armitage test and a chi

- square analysis showed that there were no significant decreases in mating success in any treatment group, both by trend and pair

- wise assessments ( Wood et al., 1981, Supplement 3, Revision 2, 2012 )

.Mr. Arnold E. Layne Chlorsulfuron ( 64902

- 72

- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 7 of 12
The ori ginal 1981 study ( Wood et al., 1981 ) followed an old and rarely used combined chronic toxicity study protocol that incorporated a 3

- generation reproductive toxicity study. The original study director, without the benefit or use of statistical methods, cam e to the conclusion that the re was decreased fertility in the third generation of the test animal group treated with the highest doses of chlorsulfuron. It was this conclusion by the original study director that ultimately led to the statement in the USEP A’s “OneLiner” database (a paraphrase of the Study Director’s statement) that resulted in the 1994 TRI listing. T he USEPA’s Toxicity Chapter for Chlorsulfuron (USEPA, 2002a, page 14) concluded that the original reproductive toxicity study was an “unaccept able/non

- guideline” study, and was considered a “data gap” by the Agency. The Toxicity Chapter detailed several reasons for their conclusion and required that a new reproductive toxicity study be generated (USEPA, 2002a, page 6). A NOAEL of 100 ppm was established for the old study by the USEPA based on decreased female fertility (USEPA, 2002a, page 14 ) , al though this was an inadvertent error on USEPA’s part

– the NOAEL for this study had been established in the original USEPA DER as 500 ppm.

Furthermo re, a three

- generation reproduction study protocol is not recommended as a routine testing method by the U SEPA , the U.S. Food and Drug Administration (FDA) , or by European countries. Three

- generation reproduction studies have also not been recommended as a part of harmonized guidelines developed by either the Organization for Economic Cooperation and Development or the International Conference on Harmonisation. In fact , starting in the early 1980s, the USEPA concluded that the addition of a 3 rd generation added no significant understanding to the potential effects of compounds on reproduction or fertility. This has been the position of the Agency since that time

. The current USEPA Guidelines for Reproductive Toxicity Risk Assessment were published in 19 96 (USEPA, 1996). The 1996 Guidelines describe the 1987 workshop that consider ed the relative merits of different protocols for reproductive toxicity studies. These current Guidelines do not suggest that a study of 3

- generations is either necessary or ap propriate for evaluations of the potential reproductive toxicity of a compound.
As such, t he 1981 study has been replaced by a state

- of

- the

- art 2005 2

- generation rat reproduction study ( Mylchreest, 2005 ), as required by th e USEPA. We expect that EPA OPP will no longer use the data generated from the 1981 “unacceptable/non

- Guideline” 3

- gen e ration reproduction toxicity study (Wood, et al., 1981) in their assessments of chlorsulfuron now that the state of the art reproductive toxicity study ( Mylchreest, 2005 ) has been completed and found to be acceptable by the USEPA.
Therefore, for the reasons stated above, it is apparent that the 1981 study ( Wood et al., 1981 ) in fact indicated that there were no adverse effects on fertility by chlorsulfuron in any generation, consistent with the results of the 2005 multi

- generation reproductive toxicity study ( Mylchreest, 2005 ).
In summary, the data discussed above and the associated USEPA conclusions support the determination that chlorsulfuron is not known to c ause and cannot reasonably be anticipatedMr. Arnold E. Layne Chlorsulfuron ( 64902

- 72

- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 8 of 12 to cause serious or irreversible reproductive dysfunction in humans. As a result, chlorsulfuron does not meet criterion (B)(ii)(I).
Criterion (B)(ii)(II): The chemical is known to cause or can reasonably be anti cipated to cause serious or irreversible neurological disorders in humans
According to the USEPA’s July 17, 2002 Toxicity Chapter for Chlorsulfuron ( USEPA, 2002a ), the Agency concluded that “there is no evidence of neurotoxicity in any study on chlorsul furon.” The USEPA Hazard Identification Assessment Review Committee (HIARC ) reviewed chlorsulfuron toxicity and determined that no additional testing for neurotoxicity was necessary to support chlorsulfuron registration and use ( USEPA, 2002a ).
Therefore, these USEPA conclusions support the determination that chlorsulfuron is not known to cause and cannot reasonably be anticipated to cause serious or irreversible neurological disorders in humans. As a result, chlorsulfuron does not meet criterio n (B)(ii)(II).
Criterion (B)(ii)(III): The chemical is known to cause or can reasonably be anticipated to cause serious or irreversible heritable genetic mutations in humans
According to the USEPA’s July 17, 2002 Toxicity Chapter for Chlorsulfuron ( US EPA, 2002a ) on chlorsulfuron, the Agency concluded that “there is no concern for mutagenicity.” This conclusion is based on the fact that chlorsulfuron was negative for mutagenicity in a bacterial gene mutation (Ames) assay, negative in the mammalian cell (HGPRT) gene mutation assay, negative in the CHO chromosomal aberrations assay, negative in the dominant lethal assay, and negative in the unscheduled DNA synthesis (UDS) assay in rat hepatocytes ( USEPA, 2002 a).
In summary, these USEPA conclusions suppor t the determination that chlorsulfuron is not known to cause and cannot reasonably be anticipated to cause serious or irreversible heritable genetic mutations in humans. As a result, chlorsulfuron does not meet criterion (B)(ii)(III).
Criteria (B)(ii)(IV ): The chemical is known to cause or can reasonably be anticipated to cause other serious or irreversible chronic health effects in humans
Effects of chronic exposure to chlorsulfuron were generally non

- specific effects. USEPA reported that n o target organ was identified following chronic exposure in either the rat or the mouse study ( USEPA, 2002a ). Decreased body weight and or body weight gains were the primary effects in the rat, mouse and dog studies. There is no indication that chronic exposure would cause serious or irreversible chronic health effects in humans.
Therefore, these USEPA conclusions support the determination that chlorsulfuron is not known to cause and cannot reasonably be anticipated to cause other serious or irreversible chronic health effects in humans. As a result, chlorsulfuron does not meet criterion (B)(ii)(IV).Mr. Arnold E. Layne Chlorsulfuron ( 64902

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- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 9 of 12
Conclusion
Based on the clear USEPA OPP findings presented above resulting from numerous accepted toxicity studies on chlorsulfuron, the conclusion that none of the listing criteria are met warrants the deletion of chlorsulfuron from the TRI list of reportable toxic chemicals.
We truly appreciate your consideration of this petition to delete chlorsulfuron from the TRI list of reportable toxic chemicals. DuPont looks forward to your response and would welcome the opportunity to meet with you to discuss the information contained in this petition. Please contact Richard J. Ambrose, DuPont Crop Protection US Registration Manager at 302

- 366

- 5185 , or by e

- mail at richard.j.ambrose@usa.dupont.com if you have any questions, would like to set up a meeting, or need further information.
Sincerely,

Enclosures
CC: Daniel R. Bushman, Ph.D. TRI Petitions Coordinator Office of I nformation Analysis and Access ( Mail Code 2842T ) Office of Environmental Information United States Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 J. Vulkich, DuPont M. Battalora, DuPont R. Ambrose, DuPont A. C. Rodriguez, DuPontMr. Arnold E. Layne Chlorsulfuron ( 64902

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- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 10 of 12
References Alvarez L, 1991. Teratogenicity study of DPX

- W4189

- 165 (Chlorsulfuron) in Rabbits. DuPont Haskell Laboratory for Toxicology and Industrial Medicine. Study ID No. HLR 306

- 90. August 12, 1991. MRID 41983101. Alvarez L, 1991. Supplement 2, 2008. Teratogenicity study of DPX

- W4189

- 165 (Chlorsulfuron) in Rabbits. Supplement 2. DuPont Ha skell Laboratory for Toxicology and Industrial Medicine. Study ID No. : HLR 306

- 90. Supplement 2 author: Joseph M. Lewis. Completion Date: August 23 , 2008. Alvarez L, 1991. Supplement 3, 2012. Teratogenicity study of DPX

- W4189

- 165 (Chlorsulfuron) in R abbits. Supplement 3. DuPont Haskell Laboratory for Toxicology and Industrial Medicine. Study ID No. : HLR 306

- 90. Supplement 3 Author: S. M. Munley. Completion Date : February 1, 2012

. Alvarez L, 1991 b . Teratogenicity study of DPX

- W4189

- 165 (Chlorsu lfuron) in Rats. DuPont Haskell Laboratory for Toxicology and Industrial Medicine. Study ID No. HLR 734

- 90. MRID 41976406. Hoberman AM, Wolfe GW, Durloo RS, 1980. Chlorsulfuron (DPX

- W4189) Technical: Teratology Study in Rabbits. Laboratory ID HLO

- 534

- 80. Original Date July 17, 1980.
Hoberman AM, Wolfe GW, Durloo RS, 1980, Supplement 1, 2010. Chlorsulfuron (DPX

- W4189) Technical: Teratology Study in Rabbits. Laboratory ID HLO

- 534

- 80. Original Study Date: July 17, 1980. Supplement 1 Date : June 16, 2010.
Hoberman AM, Wolfe GW, Durloo RS, 1980, Supplement 1, Revision 1, 2011. Chlorsulfuron (DPX

- W4189) Technical: Teratology Study in Rabbits. Laboratory ID HLO

- 534

- 80. Original Study Date: July 17, 1980. Supplement 1, Revision 1 author: S. M. Munley. Supplement 1, Revision 1 date: October 27, 2011.
Mylchreest E , 2005. Chlorsulfuron (DPX

- W4189) Technical: Multigeneration Reproduction Study in Rats. DuPont Haskell Laboratory for Health and Environmental Sciences. Project No. DUPONT 13495, 14601, 904. USEPA, 1981. Data Evaluation Record. Teratology Study in Rabbits. Haskell #12,700. Revised Final Report. July 17, 1980. Evaluation Date: November 13, 1981. USEPA, 1982. Data Evaluation Record. Long

- Term Feeding Study with 2

- Chlo ro
- N

- [{4

- Methoxy

6

- Methyl

- 1,3,5

- Triazin

- 2

- yl)Aminocarbonyl]Benezenesulfonamide (INW

- 4189) in Rats. Haskell Lab. Report No. 557

- 81. Evaluation Date: October 13, 1982.
USEPA , 1984. Pesticide Assessment Guidelines. Subdivision F. Hazard Evaluation

– Hu man & Domestic Animals. Revised Edition. November 1984. PB86

- 108958. EPA No. 540/09

- 84

- 014.Mr. Arnold E. Layne Chlorsulfuron ( 64902

- 72

- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 11 of 12 USEPA, 1993. Standard Evaluation Procedure, Reproductive Toxicity Studies. Health Effects Division, Office of Pesticide Programs. (Draft 1993). USEPA, 1994a

. Addition of Certain Chemicals; Toxic Chemical Release Reporting; Community Right

- to

- Know; Proposed Rule

. Federal Register, January 12, 1994; 59(8):Pages Unknown. USEPA, 1994b

. Addition of Certain Chemicals; Toxic Chemical Release Reporting; Community Rig ht

- to

- Know; Final Rule

. Federal Register, November 30, 1994; 59(229):Pages Unknown. USEPA, 1996. Guidelines for Reproductive Toxicity Risk Assessment. Federal Register, October 31, 1996: 61(212):56274

- 56322. USEPA, 2002a. Toxicology Chapter for Chlors ulfuron. Memorandum from Linda L. Taylor to Felicia Fort. Date: July 17, 2002. TXR#: 0050894. PC Code 118601 USEPA, 2002b. Data Evaluation Record. Prenatal Developmental Toxicity Study

– Rabbits. Citation: Alvarez, L. (1991). Teratogenicity study o f DPX

- W4189

- 165 (Chlorsulfuron) in Rabbits. Haskell Laboratory for Toxicology and Industrial Medicine. No. HLR 306

- 90. August 12, 1991. Evaluation Date: May 2, 2002. Reviewer: Linda Taylor. TXR#: 0050460. P.C. Code: 118601. USEPA, 2002c

. Chlorsu lfuron; Pesticide Tolerance Final Rule

. Federal Register, August 14, 2002; 67(157):52866

- 52873.
USEPA , 2005. Reregistration Eligibility Decision for Chlorsulfuron. May 20, 2005. USEPA Case No. 0631.

USEPA , 2007. Data Evaluation Record. Reproduction and Fertility Effects Study

– Rat. Citation: Mylchreest, E. 2005. Chlorsulfuron (DPX

- W4189) Technical: Multigeneration Reproduction Study in Rats. DuPont Haskell Laboratory for Health and Environmental Sciences. Project No. DUPONT 13495, 14601, 904. Reviewer: Linda L. Taylor. Evaluation Date: June 14, 2007. MRID 46493201.
USEPA, 2010

. “Re: Fw: Proposed meeting to discuss chlorsulfuron developmental and reproductive toxicity.” Electronic mail message from Eric Miederhoff, USEPA OPP, to Richard Ambrose, DuPont Crop Science. Date: May 19, 2010. Wine RN, et al., 1997. Reproductive toxicity of di

- n
- butylphthalate in a continuous breeding protocol in Sprague

- Dawley rats. Environmental Health Perspectives

. 105 (1) : 102

– 107

. Wood CW, Wollenberg EJ, Turner DT, 1981. Long

- Term Feeding Study with 2

- Chloro

- N

- [(4

- methoxy

- 6

- methyl

- 1,3,5

- triazin

- 2

- yl)aminocarbonyl]benzenesulfonamide (IN

- W4189) in Rats. Laboratory ID: HLR

- 557

- 81. Original Study Date: October 8, 1981. Wood CW, Wollenberg EJ, Turner DT, 198 1, Supplement 3, Revision 1, 2011. Long

- Term Feeding Study with 2

- Chloro

- N

- [(4

- methoxy

- 6

- methyl

- 1,3,5

- triazin

- 2

- yl)aminocarbonyl]benzenesulfonamide (IN

- W4189) in Rats. Laboratory ID: HLR

- 557

- 81.Mr. Arnold E. Layne Chlorsulfuron ( 64902

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- 3) : Petition to Delete from TRI List May 1 8 , 2012 Page 12 of 12 Original Study Date: October 8, 1981. Supplement 3, Revis ion 1 author: SM Munley. Supplement 3, Revision 1 date: January 14, 2011. Wood CW, Wollenberg EJ, Turner DT, 1981, Supplement 3, Revision 2, 2012. Long

- Term Feeding Study with 2

- Chloro

- N

- [(4

- methoxy

- 6

- methyl

- 1,3,5

- triazin

- 2

- yl)aminocarbonyl]benzenesulfonamide (IN

- W4189) in Rats. Laboratory ID: HLR

- 557

- 81. Original Study Date: October 8, 1981. Supplement 3, Revision 2 author: SM Munley. Supplement 3, Revision 2 date : Febru ary 1 , 2012

.