UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

MEMORANDUM 

Date: February 4, 2014 

SUBJECT: MCPP (Mecoprop): Tier I Review of Human Incidents 

PC Code: 031501.031503,031519,031520,03 1563,031564, 

119046, 129046 

Decision No.: 485917 

Petition No.: NA 

Risk Assessment Type: NA 

TXRNo.:NA 

MRID No.: NA 

FROM: 

DP Barcode: 0417595 

Registration No.: NA 

Regulatory Action: NA 

Case No.: NA 

CAS No.: 7085-19-0, 93-65-2 

40CFR: NA 

Ver.Apr.08 

Shanna Recore, Industrial Hygienist 

Toxicology and Epidemiology Branch 

Health Effect Division (7509P) 

and 

Elizabeth Evans, Envirorupental Protection Specialist 

Toxicology and Epidemiology Branch 

C4_. ~r~A ~-;._~ c=~

Health Effects Division (7509P) /J,J ,.,//& 

THROUGH: David Miller, Acting Branch Chief a 

Toxicology and Epidemiology Branch 

Health Effects Division (7509P) 

TO: Seyed Tadayon, Risk Assessor 

Risk Assessment Branch V 

Health Effects Division (7509P) 

and 

Kaitlin Keller, Chemical Review Manager 

Risk Management & Implementation Branch 3 

Pesticide Re-evaluation Division (7508P) 

Summary and Conclusions 

oy-r;J,.t.J,·r 

There are no incidents reported for MCPP as a single chemical only, but there is a high absolute 

number of incidents reported involving MCPP with another active ingredient. Although the vast 

majority of these incidents were of low severity, some high severity outcomes are reported in the 

IDS database. It is important to note that since most of these reported incidents involve more 

Page 1 of9 
than one active ingredient (i.e. MCPP and another active ingredient), the incidents that were 

reported were not necessarily attributable to MCPP. Further, while incident infonnation can be 

an important source of feedback to the Agency, reports of adverse health effects allegedly due to 

a specific pesticide exposure (i.e., an "incident") are largely self-reported and therefore, 

generally speaking, neither exposure to a pesticide or reported symptom (or the connection 

between the two) is validated or otherwise confirmed. Typically, causation cannot be 

determined based on incident data. Nevertheless, based on the absolute number of incidents and 

the few high severity outcomes that are reported, these incident data may warrant further analysis 

in the preliminary risk assessment phase of Registration Review. Obtaining additional 

information on current usage data for MCPP would improve future assessments. 

Detailed Review 

I. ACTION REQUESTED 

This review is intended to fulfill our requirement to docket summaries of incident data that were 

reported to the Agency, as well as to ensure human incident data and the Agricultural Health 

Study (AHS) are part of the problem formulation phase of registration review. Reports of 

adverse health effects allegedly due to a specific pesticide exposure (i.e., an "incident") are 

largely self-reported and therefore, generally speaking, neither exposure to a pesticide or 

reported symptom (or the connection between the two) is validated or otherwise confirmed. 

Typically, causation cannot be determined based on incident data. However, incident 

information can be an important source of feedback to the Agency: incidents of severe outcome, 

or a suggested pattern or trend among less severe incidents, can signal the Agency to further 

investigate a particular chemical or product. Observational epidemiology studies relate the risk 

of disease, e.g., cancer, and exposure to an agent such as a pesticide product in the general 

population or specific sub-groups like pesticide applicators. 

II. BACKGROUND 

MCPP-p compounds are plant growth regulators that are part of the chlorophenoxys 

group of herbicides. MCPP-p is used in combination with other herbicides for postemergence 

broadleafweed and brush control. It is used primarily on turf (i.e. lawns and golf courses) and 

sod farms with smaller quantities used on non-turf areas such as rights-of way. 

For this evaluation, both the OPP Incident Data System (IDS) and the Centers. for Disease 

Control and Prevention/National Institute for Occupational Safety and Health (CDC/NIOSH) 

Sentinel Event Notification System for Occupational Risk-Pesticides (SENSOR) databases were 

consulted for pesticide incident data on the active ingredient MCPP (PC codes: 03150 l , 031503, 

031519, 031520, 031563, 031564, 119046, 129046). The purpose of the database search is to 

identify potential patterns in the frequency and severity of the health effects attributed to MCPP 

exposure. MCPP is not included in the AHS, and therefore this study does not provide 

information for this report. 

III. RESULTS/DISCUSSION 

Page 2 of9 
Page 3 of 9

a. IDS (Incident Data System)

OPP’s IDS includes reports of alleged human health incidents from various sources, including 

mandatory Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Section 6(a)(2) reports 

from registrants, other federal and state health and environmental agencies, and individual 

consumers. Since 1992, OPP has compiled these reports in IDS. IDS contains reports from 

across the U.S. and most incidents have all relevant product information recorded. Reports 

submitted to the IDS represent anecdotal reports or allegations only, unless otherwise stated in 

the report. It should be noted there were two incident reported as lawsuits to IDS that were not 

considered in this report. 

IDS records incidents in one of two modules: Main IDS and Aggregate IDS:

 

o Main IDS contains incidents resulting in higher severity outcomes and provides 

more detail with regard to case specifics. This system stores incident data for 

death, major and moderate incidents, and it includes information about the 

location, date and nature of the incident. Main IDS incidents involving only one 

active ingredient (as opposed to pesticide products with multiple active 

ingredients) are considered to provide more certain information about the 

potential effects of exposure from the pesticide. 

o Aggregate IDS contains incidents resulting in less severe human incidents (minor, 

unknown, or no effects outcomes). These are reported by registrants only as 

counts in what are aggregate summaries. 

For the Main IDS, from January 1, 2009 to January 15, 2014, there were 0 incidents reported for 

single chemical only in the database. There were 261 incident reported involving more than one 

chemical.1 Eleven incidents were classified as major severity, 245 incidents were classified as 

moderate severity and 1 incident was classified as having unknown or no effects. The incident 

narratives for incidents classified as major severity are included in Appendix 1.

In Aggregate IDS, from January 1, 2009 to January 15, 2014, there were 1215 reported incidents 

involving MCPP. Twenty eight incidents were classified as unknown or no effects and 1187 

incidents were classified as minor severity. 

b. SENSOR-Pesticides

The SENSOR-Pesticides database covers 11 states from 1998-2009, although reporting varies 

from state to state. Cases of pesticide-related illnesses are ascertained from a variety of sources, 

including: reports from local Poison Control Centers, state Department of Labor workers’ 

compensation claims when reported by physicians, reports from State Departments of 

 

1 There were 21 foreign incidents were not reviewed in detail because of the potential differences in the exposure 

patterns, use practices, and product formulation. These incidents occurred in Canada (13), Germany (5), Ireland (1), 

England (1) and China (1). 
Page 4 of 9

Agriculture, and physician reports to state Departments of Health. Although both occupational 

and non-occupational incidents are included in the database, SENSOR-Pesticides focuses on 

occupational pesticide incidents, and is of particular value in providing that information. The 

state coordinator at each of the 11 respective state Departments of Health conducts case followup activities such as obtaining medical records to verify symptoms and severity. Using 

standardized protocol and case definitions derived from poison center reporting, the state 

SENSOR-Pesticide coordinator enters the incident information into the state-based system which 

is sent to NIOSH annually to be aggregated. 

A query of SENSOR-Pesticides 1998-2010 identifies 210 cases, stemming from 160 events, 

involving MCPP (pc codes 031501, 031503, 031519, 031520, 031563, 031564, 119046, and 

129046). Eighty nine cases were work-related; 121 cases were not work-related or unknown. 

Three cases were high in severity (one high severity case was a suicide attempt and will be 

excluded), 36 were moderate in severity, and 171 were low in severity. Reported health effects 

are included in Table 1. High and moderate case descriptions are provided in Appendix 2 below.

Table 1. SENSOR-Pesticides 1998-2010: Reported 

Health Effects for MCPP Cases 

N=210

Health Effect # of Times Reported

Nervous System 110

Respiratory 99

Gastrointestinal 81

Dermal 77

Ocular 29

Cardiovascular 25

Renal 2

* Cases may report multiple health effects

c. Agricultural Health Study (AHS)

The AHS is a high quality, prospective epidemiology study evaluating the link between pesticide 

use and various health outcomes including cancer. The AHS includes private and commercial 

pesticide applicators and their spouses. If there are AHS findings relevant to a particular 

pesticide going through registration review, the Agency will ensure they are considered in the 

problem formulation/scoping phase of the process and, if appropriate, fully reviewed in the risk 

assessment phase of the process. The AHS includes information on use of 50 different pesticide 

active ingredients commonly used in agriculture. MCPP is not included in the AHS, and 

therefore this study does not provide information for this report.

IV. CONCLUSION
Page 5 of 9

There are no incidents reported for MCPP as a single chemical only, but there is a high absolute 

number of incidents reported involving MCPP with another active ingredient. Although vast 

majority of these incidents were of low severity, some high severity outcomes are reported in the 

IDS database. It is important to note that since most of these reported incidents involve more 

than one active ingredient (i.e. MCPP and another active ingredient), the incidents that were 

reported were not necessarily attributable to MCPP. Further, while incident information can be 

an important source of feedback to the Agency, reports of adverse health effects allegedly due to 

a specific pesticide exposure (i.e., an “incident”) are largely self-reported and therefore, 

generally speaking, neither exposure to a pesticide or reported symptom (or the connection 

between the two) is validated or otherwise confirmed. Typically, causation cannot be 

determined based on incident data. Nevertheless, based on the absolute number of incidents and 

the few high severity outcomes that are reported, these incident data may warrant further analysis 

in the preliminary risk assessment phase of Registration Review. Obtaining additional 

information on current usage data for MCPP would improve future assessments.
Page 6 of 9

Appendix 1. Main IDS Major Severity Incidents Descriptions for MCPP. 

Human Incident Chemical: MCPP PC Codes: 031501, 031503, 031519, 031520, 031563, 031564, 119046, 129046

Incident 

Package 

Report

Incident 

Date Location

Reg 

Number Product Name Incident Description

020578 -

00003 1/6/2009

MISHAWAKA, 

IN

000538-

00282

TURF BUILDER 

WITH PLUS 2 

WATER SMART

An adult female was exposed to product and seems to be sick since then. 

Apparently it was a year ago but details are fuzzy.

020813 -

00174 4/15/2009 MONETA, VA

000538-

00028

TURF BUILDER 

WITH PLUS 2 

WEED CONTROL

A 77 year old male applied the product to his lawn with his bare hands. 

He developed slurred speech. He went to ER and was diagnosed with a 

TIA (mini-stroke).

020813 -

00176 4/17/2009

KANSAS CITY, 

MO

000239-

02640-

000538

TURF BUILDER 

WITH PLUS 2 

WEED CONTROL

An adult male got the product on his hands while applying it. He 

experienced nausea and stomach cramping. He went to ER and was 

diagnosed with appendicitis.

022933 -

00004 8/4/2010 KY

WEED-B-GON 

(NON-SPECIFIC)

An adult female used this product 8 months prior and she got some of it 

on her skin. She didn't rinse it off right away because she didn't think it 

was a big deal. She did rinse it off later that day and then the next day she 

developed dermal irritation and blisters. She didn't go to the doctor or 

call us back then because she didn't think it was a big deal and doesn't 

have health benefits. She said the symptoms started to look better and 

then they look bad again. Her skin is hard and discolored now and she 

still has tiny blisters that itch. 

023011 -

00017 5/10/2011

JEFFERSON 

CITY, MO

WEED-B-GON 

(NON-SPECIFIC)

A 60 year old male used the product. Approximately 2 hours after using 

the product, he fainted, displayed slurred speech, complained of 

confusion, malaise and headache. He went the hospital via ambulance. 

023301 -

00017 6/4/2011 DE

WEED-B-GON 

(NON-SPECIFIC)

An adult male mixed/loaded and applied the product and got it on his 

legs. He did not wash it off for at least an hour. His blood work shows 

decreased kidney function. His doctor took him off of his arthritis 

medication that he had been on for 20 years.

023382 -

00153 9/26/2011 STREET, MD

000239-

02689

WEED B GON 

MAX PLUS 

CRABGRASS 

KILLER RTU 1.1 

GAL

An adult woman rode around with product in the car for over a month. 

When she reached in to get it, she found it had fallen over and about half 

had spilled out. She had on occasion smelled chemical and has been 

treated for severe headaches for over a month. 

025017 -

00014 2/1/2013

HARRISBURG, 

NC

UNKNOWN 

PRODUCT

A young female child had a seizure after a post application exposure to 

the product.

025238 - 4/25/2013 PA 002217- VIGORO ULTRA This product was placed in the grass and was not watered down as 
Page 7 of 9

Human Incident Chemical: MCPP PC Codes: 031501, 031503, 031519, 031520, 031563, 031564, 119046, 129046

00001 00884-

073327

TURF 

PHOSPHORUSFREE WEED & 

FEED

directed in the package. The next day as the homeowner began to water 

down the product into the ground; her 2 year old grandson came outside 

and ran across the grass with no shoes on. Two hours rater, her grandson 

was "chewing on a lotion container" when he dropped it and began to 

cry. They gave him the lotion container again and he again began to 

chew on it. Caller states that within one minute he became "lifeless" and 

"stiff'' and was not breathing. Caller states that that she checked him for 

airway obstructions and could not see anything, and started to slap him 

on the back and he came to, but was still dazed. They rushed him to the 

ER, where they will be doing a CT scan and keeping him for observation. 

025337 -

00013 5/1/2013 UT

000538-

00282

TURF BUILDER 

WITH PLUS 2 

WEED CONTROL

A 1 year old male got into the product. He walked into the garage, put his 

hands in it and threw it up in the air. His mother states she didn't find any 

in his mouth at the time. She called poison control, who told her to watch 

for skin irritation. By the next day his fingers started cracking and 

peeling. She saw a doctor 24 hours after the exposure. The doctor 

diagnosed the child with burns down his throat. That evening the child 

vomited. the next day, the child had seizures and went to the ER. The 

child has been seen by 3 different doctors since these symptoms started. 

The latest MD said what she thinks are seizures are rigors. One MD 

diagnosed him with pneumonia while the other 2 disagreed. Something is 

seen in lower lobe of one lung on x-ray. He has some blood in his urine 

but they don't feel it's a bladder infection. He's been running a high temp 

of 104 on and off. When asked, he would have had access to the product 

for less than 30 seconds. There was no evidence in or around his mouth 

of ingestion. He has been treated with an antibiotic but she's not seeing 

much improvement. He has not been admitted to the hospital for further 

evaluation

025337 -

00020 5/10/2013 MI

000239-

02682

WEED-B-GON 

RTU

An adult female used the product twice. She describes no specific 

exposure during use. The wind was blowing, but caller states she was 

covered up with long pants and long sleeves. Two days later, she woke 

up with symptoms of an itchy rash covering her entire body. She has 

been using oral Benadryl at the recommended dosage as well as 

hydrocortisone cream, but her symptoms persisted. On call back it was 

stated that she was admitted to the hospital yesterday and diagnosed with 

cancer. She does not feel that her symptoms had anything to do with 

product use or exposure.
Page 8 of 9

Appendix 2.

SENSOR-Pesticides 1998-2010

MCPP High/Moderate Case Descriptions

N=38

ID Year Severity Case Description

MI00530 2006 High Fertilizer had been stored outside over winter. Roof leak resulted in chemical rx, heat. She was discarding into compactor.

NY00561 2002 High Man drinking alcohol all day had a fight with wife and reportedly drank 10 oz of weedkiller.

NY01820 2008 Moderate Medical record indicates that he got some of the product on his hands while working (substance is a powder).

NY01276 2005 Moderate Applying herbicide and accidentally got product in his eye.

NY01201 2005 Moderate Applying weed control product in garden for about 3 hours.

NY00802 2004 Moderate This man did not follow label precautions when he used a handheld granular spreader to treat his lawn.

NY00390 2000 Moderate Man had been applying a granular insecticide and herbicide to a customer's lawn on a hot day.

NY00176 1999 Moderate Subject lives in basement apt and super sprays pesticides around exterior of his windows.

FL01181 2003 Moderate Not provided

MI01161 2007 Moderate Required to mix/load pesticides but not provided with PPE as required by label

TX03209 2000 Moderate Exposed at work, lawn treated previous day, fumes seeped in building via vent.

MI00930 2007 Moderate Trigger got stuck, loosened nozzle to unclog, spray shot out. Got herbicides & fertilizer in eyes, thinks he swallowed 1/4 c.

MI00586 2005 Moderate Pulling hose out of backyard, stood up too fast & fainted (hot day, no history of fainting). Lay on lawn wet with spray 15-20 min.

IA00248 2007 Moderate Not provided

FL03884 2010 Moderate Caller states that he was using speed zone herbicide from 0800-1600 with gloves but still was exposed.

FL02603 2008 Moderate Patient was found in yard spraying pesticide.

FL02120 2007 Moderate Child was found eating fertilizer the evening before. Was fine until the next day.

NC00485 2008 Moderate Not provided

TX03229 2000 Moderate Exposed at work, lawn treated previous day, fumes seeped into building via vent.

WA02504 2007 Moderate A 39 y/o female landscaper used a backpack sprayer to apply 2 herbicides to weeds in a lawn. She didn't wear a mask and inhaled

WA02169 2006 Moderate A 47 y/o female developed respiratory & systemic symptoms after clearing weeds from a lawn. She treated herself. She sought

WA01647 2004 Moderate A 26 y/o male unlicensed applicator applied around an apartment complex. He was not using goggles or a respirator.

WA01176 2003 Moderate She said spray hit side of her truck/smelled spray

WA00719 2001 Moderate 71 y/o male dropped a container of Ortho Weed B Gon he got at a garage sale. He got some on his hand and smelled the chemical

TX06265 2010 Moderate Case had a container of spectracide weed stop for lawns in a case along with more containers of same pesticide. Case asserts that 

container must have ruptured during transport because when he reached to pick it up, as he grabbed it, that pressure

TX03232 2000 Moderate Exposed at work, lawn treated previous day, fumes seeped into building via vent.
Page 9 of 9

SENSOR-Pesticides 1998-2010

MCPP High/Moderate Case Descriptions

N=38

ID Year Severity Case Description

OR01383 2006 Moderate Worker was exposed to drift momentarily and then to fumes for three and a half days while product was applied to university campus.

TX03230 2000 Moderate Exposed at work, lawn treated on the previous day, fumes seeped into building via vent.

TX03203 2000 Moderate

TX03228 2000 Moderate

TX03225 2000 Moderate

TX03223 2000 Moderate

TX03219 2000 Moderate

TX03218 2000 Moderate

TX03213 2000 Moderate

TX03210 2000 Moderate

TX03231 2000 Moderate

WA02516 2007 Moderate A 73 y/o male developed primarily respiratory symptoms with some ocular and neurological involvement after an exposure to an