Washington, DC California Canada

1150 18th Street, NW, Suite 1000 712 5th 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: 64902-72-3
Mr. Arnold E. Layne

Chlorsulfuron (64902-72-3): Petition to Delete from TRI List

May 18, 2012

Page 2 of 12

Summary

On November 30, 1994, the United States Environmental 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 January 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/day. 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 in 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-Guidelines: a 1991 developmental toxicity study 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 classification 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 provided 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 listing criteria element is addressed 

and the data presented demonstrate that chlorsulfuron fails to meet each criterion.
Mr. Arnold E. Layne

Chlorsulfuron (64902-72-3): Petition to Delete from TRI List

May 18, 2012

Page 3 of 12

Specific Criteria Elements

The information and data presented below support the conclusion that chlorsulfuron does not 

meet any of the 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 frequently 

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 indicate 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 

studies 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 section 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 rule 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 18, 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 occupational 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 pesticide 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 classification 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 effects, from the 1991 teratology study in rabbits (Alvarez, 1991). 
Mr. Arnold E. Layne

Chlorsulfuron (64902-72-3): Petition to Delete from TRI List

May 18, 2012

Page 5 of 12

Rationale for Replacing 1980 Teratology Study in Rabbits with 1991 Teratology Study in Rabbits

USEPA’s November 13, 1981 evaluation of the original 1980 teratology study in rabbits stated 

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 the USEPA’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 USEPA, including during the Agency’s 

development of their 2005 Reregistration 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 teratology 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 clarified 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 dose dependency, and did not reproduce 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 study 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 irreversible 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 reproductive 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 

(Mylchreest, 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 18, 2012

Page 6 of 12

Rationale for Replacing the 1981 3-Generation Reproductive Toxicity Study with the 2005 2-

Generation Reproductive Toxicity Study

The USEPA’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 summary of

chlorsulfuron toxicity for the USEPA’s TRI program. 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, including the fertility index (USEPA, 2007).

Earlier this year, DuPont, as part of their ongoing efforts to delist chlorsulfuron from California 

Proposition 65, submitted a Supplement to the original 1981 reproductive toxicity study (Wood 

et al., 1981, Supplement 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 supports 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 include: 

1) Comparison to fertility index data from the subsequent 2005 multigeneration 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 USEPA procedures 

and current standard practice.

4) Presentation of the male fertility data not shown previously.

The fertility indices of all the control and treatment groups 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 ppm, 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 18, 2012

Page 7 of 12

The original 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, came to the conclusion 

that there 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 USEPA’s “OneLiner” database (a paraphrase of the Study 

Director’s statement) that resulted in the 1994 TRI listing. The USEPA’s Toxicity Chapter for 

Chlorsulfuron (USEPA, 2002a, page 14) concluded that the original reproductive toxicity study 

was an “unacceptable/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), although 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.

Furthermore, a three-generation reproduction study protocol is not recommended as a routine 

testing method by the USEPA, 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 3rd 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 1996 (USEPA, 1996). The 1996 

Guidelines describe the 1987 workshop that considered 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 appropriate for evaluations of the potential 

reproductive toxicity of a compound.

As such, the 1981 study has been replaced by a state-of-the-art 2005 2-generation rat 

reproduction study (Mylchreest, 2005), as required by the USEPA. We expect that EPA OPP will 

no longer use the data generated from the 1981 “unacceptable/non-Guideline” 3-generation 

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 cause and cannot reasonably be anticipated 
Mr. Arnold E. Layne

Chlorsulfuron (64902-72-3): Petition to Delete from TRI List

May 18, 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 anticipated 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 chlorsulfuron.” 

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 criterion (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 (USEPA, 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, 2002a).

In summary, these USEPA conclusions support 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 no 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 (64902-72-3): Petition to Delete from TRI List

May 18, 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 Information 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, DuPont
Mr. Arnold E. Layne

Chlorsulfuron (64902-72-3): Petition to Delete from TRI List

May 18, 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 Haskell 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 Rabbits. 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, 1991b. Teratogenicity study of DPX-W4189-165 (Chlorsulfuron) 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-Chloro-N-[{4-Methoxy6-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 – Human & 

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 18, 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 

Right-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 Chlorsulfuron. 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 of 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. Chlorsulfuron; 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, 1981, 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 (64902-72-3): Petition to Delete from TRI List

May 18, 2012

Page 12 of 12

Original Study Date: October 8, 1981. Supplement 3, Revision 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: February 1, 2012.