United States Prevention , Pesticides EPA 738-R-05-002
Environmental Protection an d Toxic Substances June 2005 Agency (7508C) 

# Reregistration Eligibility Decision for 2,4-D

### Reregistration Eligibility Decision

for

2,4-D

List A

Case 0073

Approved By:



### ______________________ Debra Edwards, Ph.D. Director, Special Review and Reregistration Division

______________________ Dateiii Table of Contents

Glossary of Terms and Abbreviations

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii

2,4-D Reregistration Eligibility Decision Team ....................................... x

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi

I. Introduction .................................................................1

II. Chemical Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 A. Regulatory History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

B. Chemical Identification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

C. Use Profile . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 D. Estimated Usage of Pesticide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

III. Summary of 2,4-D Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
A. Human Health Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 1. Toxicity of 2,4-D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 a. Toxicity Profile . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 b. Safety and Database Uncertainty Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 c. Carcinogenicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
d. Cumulative Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

e. Endocrine Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 2. Dietary Exposure and Risk from Food . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 a. Exposure Assumptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 b. Population Adjusted Dose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
c. Food Risk Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 3. Dietary Exposure and Risk from Drinking Water . . . . . . . . . . . . . . . . . . . . . . . . . 24
a. Surface Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
b. Ground Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
c. EDWCs Selected for Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 4. Residential and Other Non-occupational Exposure . . . . . . . . . . . . . . . . . . . . . . . . 27 a. Toxicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

b. Residential Handler . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

1) Exposure Scenarios, Data, and Assumptions . . . . . . . . . . . . . . . . . . . . . . . . 29 2) Residential Handler Risk Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 c. Residential Postapplication Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

1) Exposure Scenarios, Data, and Assumptions . . . . . . . . . . . . . . . . . . . . . . . . 32 2) Postapplication Risk Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

d. Recreational Swimmer Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34iv 1) Exposure Scenarios, Data, and Assumptions . . . . . . . . . . . . . . . . . . . . . . . . . 35 2) Recreational Swimmer Risk Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 5. Aggregate Exposure and Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 a. Acute Aggregate Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 b. Chronic Aggregate Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 c. Short-term Aggregate Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 d. Cancer Aggregate Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 e. Aggregate Risk Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 6. Occupational Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 a. Occupational Toxicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 b. Occupational Handler Exposure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 c. Occupational Handler Risk Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 d. Occupational Postapplication Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

1) Exposure Scenarios, Data, and Assumptions . . . . . . . . . . . . . . . . . . . . . . . . . 50 2) Occupational Postapplication Risk Estimates . . . . . . . . . . . . . . . . . . . . . . . . . 51

7. Human Incident Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 8. Cancer Epidemiology Studies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52
B. Environmental Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 1. Environmental Exposure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 a. Environmental Fate and Transport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 b. Aquatic Organism Exposure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

1) Exposure to 2,4-D Acid in Surface Water . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 2) Surface Water Modeling of 2,4-D Esters . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 3) Modeling of Direct Application of 2,4-D for Control of Aquatic Weeds . . . . 56 4) Modeling of 2,4-D Use on Rice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57 c. Terrestrial Organism Exposure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

1) Birds and Mammals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 a) Exposure to Nongranular (Liquid) Formulations . . . . . . . . . . . . . . . . . . . . . . 58 b) Exposure to Granular Formulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 2) Non-target Terrestrial Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 2. Environmental Effects (Toxicity) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 a. Toxicity to Aquatic Organisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 b. Toxicity to Terrestrial Organisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 3. Ecological Risk Estimation (RQs) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 a. Risk to Aquatic Organisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

1) Fish and Aquatic Invertebrates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63 2) Aquatic Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64 b. Risk to Non-target Terrestrial Organisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

1) Birds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 2) Mammals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67 3) Non-Target Insects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 4) Non-target Terrestrial Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 4. Ecological Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 5. Endangered Species Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72v 6. Risk Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74 a. Characterization of risk to aquatic organisms from direct aquatic application . . 74

b. Characterization of risk to mammals from terrestrial use . . . . . . . . . . . . . . . . . 75

c. Characterization of risk to birds from terrestrial use . . . . . . . . . . . . . . . . . . . . . 76 d. Characterization of risk to non-target plants from terrestrial use . . . . . . . . . . . . 77

IV. Risk Management, Reregistration, and Tolerance Reassessment Decision . . . . . . . . . . . . . . . 79 A. Determination of Reregistration Eligibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 B. Public Comments and Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 C. Regulatory Position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 1. Food Quality Protection Act Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 a. “Risk Cup” Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 b. Determination of Safety to U.S. Population . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 2. Endocrine Disruptor Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81
3. Cumulative Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81 4. Special Review Disposition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82
5. Dioxin Contaminants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 D. Tolerance Reassessment Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84 1. Tolerances Currently Listed Under 40 CFR §180.142 . . . . . . . . . . . . . . . . . . . . . . 84 2. Tolerances to Be Proposed Under 40 CFR §180.142 . . . . . . . . . . . . . . . . . . . . . . . 89
3. Codex Harmonization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97 4. Residue Analytical Methods - Plants and Livestock (GLN 860.1340) . . . . . . . . . . . 97 E. Regulatory Rationale . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98 1. Human Health Risk Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

a. Residential Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

1) Residential risk summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98 2) Residential Post-application Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 3) Residential Swimmer Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 b. Aggregate Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100

1) Aggregate Risk Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100 2) Acute Aggregate Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100 3) Short-term Aggregate Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101 4) Chronic (Non-Cancer) Aggregate Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101 5) Aggregate Risk Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102 c. Occupational Risk Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102

1) Handler Risk Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102 2) Post-application Risk Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102 2. Environmental Risk Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103
a. Birds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103

b. Mammals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104 c. Aquatic Organisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105 d. Non-target Insects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 e. Non-target Terrestrial Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 f. Summary of Environmental Risk Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . 106vi F. Other Labeling Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 1. Endangered Species Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 2. Spray Drift Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107 3. Consumer Labeling Initiative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107

V. What Registrants Need To Do . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108 A. Manufacturing Use Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 1. Additional Generic Data Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109

B. End-Use Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111 1. Additional Product-Specific Data Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . 111 2. Labeling for End-Use Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111 C. Existing Stocks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111 D. Required Labeling Changes Summary Table . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 113

VI. Appendicies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 153 Appendix A. Table of 2,4-D Use Patterns Eligible for Reregistration (Case 0073) . . . . . . . 154 Appendix B. Data Supporting Guideline Requi rements for the Reregistration of 2,4-D . . . 169 Appendix C. Technical Support Documents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 184 Appendix D. Citations Considered to be Part of the Data Base Supporting the Reregistration Eligibility Decision (Bibliography) for 2,4-D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 187 Appendix E. Generic Data Call-In . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 292 Appendix F. Product Specific Data Call-In . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 294 Appendix G. EPA’s Batching of 2,4-D Pr oducts for Meeting Acute Toxicity Data Requirements for Reregistration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 296 Appendix H. List of Registrants Sent This Data Call-In . . . . . . . . . . . . . . . . . . . . . . . . . . . 298vii 

### Glossary of Terms and Abbreviations

A Acre AGDCI Agricultural Data Call-In ae Acid Equivalent ai Active Ingredient aPAD Acute Population Adjusted Dose AR Anticipated Residue

BCF Bioconcentration Factor CFR Code of Federal Regulations cPAD Chronic Population Adjusted Dose

CSF Confidential Statement of Formula CSFII USDA Continuing Surveys for Food Intake by Individuals

DCI Data Call-In DEEM Dietary Exposure Evaluation Model DFR Dislodgeable Foliar Residue DWLOC Drinking Water Level of Comparison.

EC Emulsifiable Concentrate Formulation EDSP Endocrine Disruption Screening Program EDWC Estimated Drinking Water Concentration

EEC Estimated Environmental Concentration EPA Environmental Protection Agency

EUP End-Use Product FDA Food and Drug Administration FIFRA Federal Insecticide, Fungicide, and Rodenticide Act FFDCA Federal Food, Drug, and Cosmetic Act FQPA Food Quality Protection Act FOB Functional Observation Battery

G Granular Formulation GENEEC Tier I Surface Water Computer Model

GLN Guideline Number HAFT Highest Average Field Trial

HAT Hour After Treatment

IR Index Reservoir LC50 Median Lethal Concentration. A statistically derived concentration of a substance that can be expected to cause death in 50% of te st animals. It is usually expressed as the weight of substance per weight or volume of water, air or feed, e.g., mg/l, mg/kg or

ppm. LD50 Median Lethal Dose. A statistically derived single dose that can be expected to cause death in 50% of the test animals when administered by the route indicated (oral, dermal, inhalation). It is expressed as a weight of substance per unit weight of animal, e.g., mg/kg.

LOC Level of Concern

LOD Limit of Detection

LOAEL Lowest Observed Adverse Effect Levelviii MATC Maximum Acceptable Toxicant Concentration

: g/g Micrograms Per Gram

: g/L Micrograms Per Liter mg/kg/day Milligram Per Kilogram Per Day mg/L Milligrams Per Liter MOE Margin of Exposure MRID Master Record Identification (number). EPA's system of recording and tracking

studies submitted MSWC Maximum Swimming Water Concentration MUP Manufacturing-Use Product NA Not Applicable NAWQA USGS National Water Quality Assessment NCOD National Drinking Water Contaminant Occurrence Database NPDES National Pollutant Discharge Elimination System NR Not Required

NOAEL No Observed Adverse Effect Level OP Organophosphate OPP EPA Office of Pesticide Programs OPPTS EPA Office of Prevention, Pesticides and Toxic Substances ORETF Outdoor Residential Exposure Task Force PAD Population Adjusted Dose PCA Percent Crop Area PDIC Product-Specific Data Call-In PDP USDA Pesticide Data Program PHED Pesticide Handler's Exposure Data

PHI Preharvest Interval ppb Parts Per Billion PPE Personal Protective Equipment ppm Parts Per Million

PRZM/ EXAMS Tier II Surface Water Computer Model Q1* The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer Risk

Model RAC Raw Agriculture Commodity RED Reregistration Eligibility Decision REI Restricted Entry Interval

RfD Reference Dose RQ Risk Quotient SCI-GROW Tier I Ground Water Computer Model SAP Science Advisory Panel SF Safety Factor SLC Single Layer Clothing SLN Special Local Need (Registrations Under Section 24(c)) of FIFRA) STORET Storage and Retrieval Environmental Data Systemix TGAI Technical Grade Active Ingredient

TRR Total Radioactive Residue TWAM Time Weighted Annual Mean USDA United States Department of Agriculture USGS United States Geological Survey UF Uncertainty Factor

UV Ultraviolet

WPS Worker Protection Standardx 

### 2,4-D Reregistration Eligibility Decision Team

Office of Pesticide Programs:

Biological and Economic Analysis Assessment

Elisa Rim

Rafael Prieto

Steve Jarboe Tim Kiely

Environmental Fate and Effects Risk Assessment

Mark Corbin

Bill Evans

James Hetrick

Sid Abel

Health Effects Risk Assessment

Bill Hazel Timothy Dole Linda Taylor

Felecia Fort Toiya Jimerson Michael Metzger Whang Phang

Risk Management

Katie Hall

Mark Seaton Moana Appleyard Tom Myers Margaret Ricexi Executive Summary

EPA has completed its review of public comments on the preliminary risk assessments and is issuing its risk management decision for 2,4-D. The revised risk assessments are based on review of the required target data base supporting the use patterns of the currently registered products and additional information received from the 2,4-D Task Force II. After considering the risks identified in the revised risk assessment and comments and mitigation suggestions from interested parties, EPA developed its risk management decision for uses of 2,4-D that pose risks of concern. The decision is discussed fully in this document.

2,4-D is an herbicide in the phenoxy or phenoxyacetic acid family that is used post-emergence for selective control of broadleaf weeds. 2,4-D is registered for use on a variety of food/feed sites including field, fruit, and vegetable crops. 2,4-D is al so registered for use on turf, lawns, rights-ofway, aquatic and forestry applications. Residential homeowners may use 2,4-D on lawns.

Based primarily on pesticide usage information from 1992 through 2000 for agriculture and 1993 through 1999 for non-agriculture, total annual domestic usage of 2,4-D is approximately 46 million pounds, with 30 million pounds (66%) used for agriculture and 16 million pounds (34%) used for non-agriculture. In terms of pounds, total 2,4-D usage is allocated mainly to pasture/rangeland (24%), lawn by homeowners with fertilizer ( 12%), spring wheat (8%), winter wheat (7%), lawn/garden by lawn care operators/landscape maintenance contractors (7%), lawn by homeowners alone (without fertilizer) (6%), field corn (6%), soybeans (4%), summer fallow (3%), hay other than alfalfa (3%) and roadways (3%). Agricultural sites with at least 10% of U.S. acreage treated include spring wheat (51%), filberts (49%), sugarcane (36%), barley (36%), seed crops (29%), apples (20%), rye (16%), winter wheat (15%), cherries (15%), oats (15%), millet (15%), rice (13%), soybeans (12%), and pears (10%). For 2,4-D, rates per application and rates per year are generally less than 1.50 pounds acid equivalent (a.e.) per acre and 2.00 pounds a.e. per acre (lbs ae/A), respectively. 2,4- D is used predominantly in the Midwest, Great Plains, and Northwestern United States.

The Food Quality Protection Act (FQPA) requires that, when considering whether to establish, modify, or revoke a tolerance, the Agency consider “available information” concerning the cumulative effects of a particular pesticide’s residues and “other substances that have a common mechanism of toxicity.” Unlike other pesticides for which EPA has followed a cumulative risk approach based on a common mechanism of toxicity, EPA has not made a common mechanism of toxicity finding as to 2,4-D and any other substances. For the purposes of this tolerance action, therefore, EPA has not assumed that 2,4-D has a common mechanism of toxicity with other substances. For information regarding EPA’s efforts to determine which chemicals have a common mechanism of toxicity and to evaluate the cumu lative effects of such chemicals, see the policy statements released by EPA’s Office of Pesticide Programs (OPP) concerning common mechanism determinations and procedures for cumulating effects from substances found to have a common

mechanism on EPA’s website at http://www.epa.gov/pesticides/cumulative/.

Dietary Riskxii Acute and chronic dietary exposures for food and drinking water do not exceed the Agency’s level of concern; therefore, no mitigation is warranted at this time for any dietary exposure to 2,4-D.

The maximum contaminant level (MCL) established by EPA’s Office of Water (OW) for 2,4-D is 70 micrograms/liter (ug/l; ppb). Further, it is important to note that an MCL is an enforceable limit under the Safe Drinking Water Act (SDWA). To minimize the possibility that aquatic applications will result in drinking water concentrations in excess of the MCL, registrants and the Agency have developed label language for the direct aquatic use of 2,4-D to control aquatic weeds.

Residential Risk

Potential exposures are anticipated as a result of homeowner and commercial applications in residential areas. Applications can be made to lawns. In addition to residential areas, there are also potential postapplication exposure scenarios that may o ccur in public areas such as parks, recreational areas, and golf courses. The Agency evaluated 2,4-D exposures to residential handlers during mixing, loading and application to turf/ornamentals and 2,4-D postapplication exposure to residues by

adults and children on treated turf.

In preliminary versions of the risk assessment, when considered alone, acute and short-term residential risks posed by the use of 2,4-D were not of concern to the Agency; however, when considered as part of an aggregate exposure with food and drinking water, exposures did exceed the Agency’s level of concern. As a result, 2,4-D registrants agreed to reduce the maximum application rate to turf and residential lawns from 2.0 lbs ae/A to 1.5 lbs ae/A. Chronic residential exposures to 2,4-D are not expected due to its use pattern.

Aggregate Risk

An aggregate risk assessment looks at the combined risk from dietary exposure (food and drinking water pathways), as well as exposures from non-occupational sources (e.g., residential uses). In the preliminary and revised risk assessments, the estimated acute and short-term exposures exceeded the Agency’s level of concern. As a resu lt, 2,4-D registrants agreed to reduce the maximum application rate to turf and residential lawns from 2.0 pounds acid equivalent per acre (lbs ae/A) to 1.5 lbs ae/A. The current risk assessment considers exposures from the reduced application rate for

residential turf.

Two methods of aggregate risk calculations were employed in assessing the aggregate risk of 2,4-D. The first method is the drinking water level of concern (DWLOC) method. OPP (Office of Pesticide Programs) has traditionally compared estimates of concentrations of a pesticide in drinking water to DWLOCs. A DWLOC is the portion of the acute population adjusted dose (aPAD) or chronic population adjusted dose (cPAD) remaining after estimated dietary (food only) exposures have been subtracted and the remaining exposure has been converted to a concentration (ug/liter or ppb). This concentration value (DWLOC) represents the available or allowable exposure through drinking water. The second method is the forward calculation method. In this approach, food, drinking water, and residential exposures are aggregated and compared to an appropriate endpoint. Axiii population adjusted dose, or PAD, is the reference dose (RfD) adjusted for the FQPA safety factor. A risk estimate that is less than 100% of the acute PAD (aPAD), the dose at which an individual could be exposed over the course of a single day and no adverse health effects would be expected, does not exceed EPA’s level of concern. Likewise, risk estimate that is less than 100% of the chronic PAD (cPAD), the dose at which an individual could be exposed over the course of a lifetime and no adverse health effects would be expected, does not exceed EPA’s level of concern.

In the case of 2,4-D, the DWLOCs were calculated for comparison to the MCL established by the EPA Office of Water and aggregate risks were calculated using the forward calculation approach for comparison to the appropriate endpoint. The respective DWLOCs and aggregate risks are shown for acute, chronic and short term exposures in the following sections.

Acute aggregate risk. The acute aggregate risk assessments address exposure to 2,4-D residues in food and water using both the DWLO C and forward calculation approach. Acute residential exposures from swimming in treated water bodies or playing on treated turf were not included because exposures are unlikely to co-occur with acute dietary exposures. The acute DWLOCs are 432 ppb or greater with the most sensitive population being females 13-49 years old. The estimated drinking water concentrations (EDWCs) of 118 ug/liter for surface water and 15 ug/liter for groundwater are substantially less than th e DWLOCs which means that the risks are not of

concern.

Acute aggregate risks were also assessed by aggregating acute food exposures and acute water exposures using Lifeline. The acute aggregate risk s are not of concern because they are less than 100 percent of the aPAD. The highest risks (58 per cent of the aPAD) are for females 13-49 years old because these risks are based upon the lower no-observed adverse effect level (NOAEL) of 25 mg/kg/day from a developmental study in rats.

Short-term aggregate risk. Short term aggregate risk assessments were conducted by calculating DWLOCs based upon short term turf exposures, chronic food exposures and short term endpoints. Short term exposures from swimming in treated water bodies were not included because these exposures represent high-end unlikely scenarios. The short term DWLOCs were calculated only for females 13-49 and children 1-6 because these population subgroups have the highest exposure and are protective of the other subgroups. The DWLOCS range from 24 to 54 ug/liter. These DWLOCs are all greater than the EDWCs, which range from 15 to 23 ug/liter, and indicate that

short term risks are not of concern.

Short term aggregate risks were also assessed by aggregating short term turf exposures, chronic food exposures and chronic water exposures using the forward calculation approach. Short term aggregate risks were calculated only for females 13-49 and children 1-6 because these population subgroups have the highest exposure and are protective of the other subgroups. The short term aggregate margins of exposure (MOEs) indicate that the short term risks are not of concern because the MOEs equal or exceed the target MOE of 1000.xiv Chronic (non-cancer) aggregate risk. Chronic DWLOCs were calculated based upon chronic dietary exposures. As there are no chronic residential exposures, residential exposures were not included in the chronic DWLOC calculations. The chronic DWLOCs are 47 ug/liter or greater with the most sensitive populations being infants and children. The EDWCs, which range from 1.5 to 23 ug/liter, are less than the DWLOCs which means that the risks are not of concern. It should be noted that the master label indicates that potable water consumption from a treated water body cannot begin until the 2,4-D concentration is 70 ug/liter or below, therefore an annual average exposure at the MCL of 70 ug/liter would not occur because dissipa tion would reduce the initial concentration of 70 ug/liter to an annual average concentration of 11 ug/liter.

Chronic aggregate risks were also assessed by aggregating chronic food exposures and chronic water exposures using the forward calculation approach. The chronic aggregate risks are presented as percent cPAD are not of concern because they ar e less than 100 percent of the cPAD. The highest risks (38 percent of the cPAD) are for children 1-2 years old.

Occupational Risk

Based on current use patterns, occupational handlers (mixers, loaders, and applicators) may be exposed to 2,4-D during and after normal use. The Agency identified 18 handler scenarios resulting from mixing/loading and applying 2,4-D for crop and non-crop uses. For the occupational use of 2,4- D, EPA is concerned about any Margin of Exposure (MOE) less than 100, which incorporates uncertainty factors of 10x for interspecies variation and 10x for intraspecies variation.

With the exception of mixing/loading wettable powder, all of the short-term and intermediateterm MOEs exceed the target of 100 with baselin e personal protective equipment (PPE) (i.e., longsleeved shirt, long pants, shoes plus socks, no respirator) or single layer PPE (i.e., long-sleeved shirt, long pants, shoes plus socks, gloves, no respirator) and are not of concern. The MOEs for handling wettable powder are above 100 with engineering controls (i.e., water soluble bags).

Ecological Risk

Fish and Aquatic Invertebrates : Estimated risk quotients (RQs) from use of 2,4-D acid and amine salts in aquatic weed control through direct subsurface application to water bodies exceed the

restricted use LOCs for freshwater invertebrates. There are no chronic LOC exceedances for this use. Estimated RQs from use of 2,4-D BEE in weed cont rol through direct subsurface application to water bodies exceed the acute risk level of concern (LOC) for freshwater fish and invertebrates and chronic risk LOC for freshwater and estuarine fish and freshwater invertebrates when compared on an acid equivalent basis. Estimated RQs from use of 2,4-D acid and amine salts in rice paddies exceed the acute endangered species LOCs for freshwater invertebrates.

Non-Target Aquatic Plants: For non-target aquatic plants, estimated RQs from the runoff/drift of 2,4-D acid and amine salts from use on terrestrial crops exceed the aquatic vascular plant endangered species LOCs for use of 2,4-D acid and amine salts on pasture and apples. Consideration of average application rates and assuming a proportional reduction in EECs results in RQs below thexv endangered species LOC. Likewise, there are no LOC exceedances from the drift of the ester forms to aquatic water bodies or from the runoff of the ester forms to water bodies from use on terrestrial

sites. Estimated RQs for the scenario of direct application to water for aquatic weed control for 2,4-D acid and amine salts exceed the acute and endangered species LOCs for aquatic vascular and acute the LOC for non-vascular plants, while estimated RQs from use of 2,4-D BEE (the only ester registered for aquatic weed control) for direct application to water for weed control exceed all LOCs for vascular and the acute LOC for non-vascular plants. Estimated RQs for use of 2,4-D acid and amine salts in rice paddies exceed the acute and endangered species LOCs for aquatic vascular plants. Consideration of average application rates results in RQs below the endangered species LOCs.

Birds: For non-granular spray applications of 2,4-D acid, amine salts, and esters, estimated RQs exceed acute LOCs for most crop scenarios for short grass, tall grass, and broadleaf forage exposures. For birds that eat fruit and large insects, acute endangered LOCs are exceeded for non-cropland, forest, and cranberry scenarios. Chronic LOCs are exceeded for birds that forage on short grass when the application rate of 2,4-D ranges from 2.0 to 4.0 lbs ae/A such as with non-cropland areas, cranberries, or asparagus. For granular broadcast applications, acute LOCs are exceeded for several different crop scenarios and bird weights. The ch ronic LOC is not exceeded for granular broadcast applications.

Mammals: For non-granular formulations of 2,4-D, estimated RQs exceed acute LOCs for mammals feeding on plants and insects for all uses assessed for small and medium size mammals, except potatoes and citrus. There were no exceedances for granivores exposed to non-granular formulations of 2,4-D. LOCs for acute exposure to granular 2,4-D products are exceeded for all sites with the following exceptions: 1000 g mammals in turf, aquatic areas, and cranberries. Mammalian chronic RQs range from 0.05 to 200 and chronic LOCs were exceeded in all cases with the exception of potatoes and citrus (large insects, seeds). Consideration of average application rates results in acute RQs below the LOCs for non-granular and gra nular applications. However, consideration of average application rates for non-granular and granul ar applications did not result in RQs below the

chronic LOC.

Insects: Since study results show that 2,4-D DMAS and 2,4-D EHE are practically non-toxic to honey bees, the potential for 2,4-D and its salts and esters is predicted to pose minimal risk to pollinators and other beneficial insects.

Non-Target Terrestrial Plants: Estimated RQs exceed acute LOCs for both non-endangered and endangered plants for non-granular and granular us es at many use sites. Consideration of average application rates did not result in RQs below LOCs.

In summary, some ecological risks are of concern on some sites for some species. The Agency’s characterization of its assessment of ecol ogical risk is provided in section III.B.3 of this document. The mitigation measures of (1) reducing maximum application rates, and (2) specifying axvi required spray droplet size of “Medium to Coarse” or coarser (i.e., prohibiting “fine” sprays) are expected to lessen, but not eliminate, the risk of 2,4-D to wildlife and plants.

Summary of Mitigation Measures

EPA has determined that 2,4-D is eligible for reregistration provided the mitigation outlined in this document is implemented.

Dietary Risk

• Acute and chronic dietary exposures for food and drinking water do not exceed the Agency’s level of concern; therefore, no mitigation is warranted at this time for any dietary exposure to 2,4-D.

Residential Risk

C Maximum turf rate is reduced from 2.0 lbs ae/A to 1.5 lbs ae/A.

C At the agreed-upon maximum application rate of 1.5 lbs ae/A for residential turf, acute and short-term residential risks posed by the use of 2,4-D are not of concern to the Agency. Due to its use pattern, chronic residential exposures to 2,4-D are not expected.

Occupational Risk

• Risks from handling wettable-powder products will be mitigated by requiring wettable powder products to be packaged in water-soluble packaging. • Personal protective equipment (PPE) prescribed in the exposure reduction plan set forth in 1992 will be replaced with the PPE require ments outlined in this document.

Ecological Risk

• The measures to control spray drift are expected to reduce the risk of 2,4-D to non-target plants.

• Maximum turf rate is reduced from 2.0 lbs ae/A to 1.5 lbs ae/A. • Implementation of the application rates set forth in the Master Label will reduce rates (as compared to current rates on existing labels) for field corn, popcorn, sweet corn, small grains, fallowland/stubble, non-cropland, turf, aquatic applications (surface), pasture, and soybean.Page 1 of 304 I. Introduction

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended in 1988 to accelerate the reregistration of products with active ingredients registered prior to November 1, 1984. The amended Act calls for the development and submission of data to support the reregistration of an active ingredient, as well as a review of all submitted data by the U.S. Environmental Protection Agency (referred to as EPA or "the Agency"). Reregistration involves a thorough review of the scientific database underlying a pesticide's regist ration. The purpose of the Agency's review is to reassess the potential hazards arising from the currently registered uses of the pesticide; to determine the need for additional data on health and environmental effects; and to determine whether or not the pesticide meets the "no unreasonable adverse effects" criteria of FIFRA.

On August 3, 1996, the Food Quality Protection Act of 1996 (FQPA) was signed into law. This Act amends FIFRA and the Federal Food Drug and Cosmetic Act (FFDCA) to require reassessment of all existing tolerances for pesticides in food. FQPA also requires EPA to review all tolerances in effect on August 3, 1996 by August 3, 2006. In reassessing these tolerances, the Agency must consider, among other things, aggregate risks from non-occupational sources of pesticide exposure, whether there is increased susceptibility to infants and children, and the cumulative effects of pesticides with a common mechanism of toxicity. When a safety finding has been made that aggregate risks are not of concern and the Agency concludes that there is a reasonable certainty of no harm from aggregate exposure, the tolerances are considered reassessed. EPA decided that, for those chemicals that have tolerances and are undergoing reregistration, tolerance reassessment will be accomplished through the reregistration process.

As mentioned above, FQPA requires EPA to consider "available information" concerning the cumulative effects of a particular pesticide's residues and "other substances that have a common mechanism of toxicity" when considering whethe r to establish, modify, or revoke a tolerance.

Potential cumulative effects of chemicals with a common mechanism of toxicity are considered because low-level exposures to multiple chemicals causing a common toxic effect by a common

mechanism could lead to the same adverse health effect as would a higher level of exposure to any one of these individual chemicals. For information regarding EPA’s efforts to determine which chemicals have a common mechanism of toxicity and to evaluate the cumulative effects of such chemicals, see the policy statements released by the EPA’s Office of Pesticide Programs concerning common mechanism determinations and procedures for cumulating effects from substances found to have a common mechanism on EPA’s website at http://www.epa.gov/pesticides/cumulative/.

Unlike other pesticides for which EPA has considered cumulative risk based on a common mechanism of toxicity, EPA has not made a common mechanism of toxicity finding for 2,4- dichlorophenoxyacetic acid (2,4-D). Therefore, for the purposes of tolerance reassessment and a decision on reregistration eligibility, EPA is assuming that 2,4-D does not share a common mechanism of toxicity with other compounds. In the future, if information suggests 2,4-D shares a common mechanism of toxicity with other compounds, additional testing may be required and a cumulative assessment may be necessary.Page 2 of 304 This document presents summaries of EPA’s revised human health and ecological risk assessments, tolerance reregistration decision, and the reregistration eligibility decision for 2,4-D. The document consists of six sections. Section I contains the regulatory framework for reregistration/tolerance reassessment. Section II provides a profile of the use and usage of the chemical. Section III gives an overview of the revised human health and environmental effects risk assessments based on data, public comments, and other information received in response to the preliminary risk assessments. Section IV presents the Agency’s reregistration eligibility and risk management decisions. Section V summarizes label changes necessary to implement the risk mitigation measures outlined in Section IV. Finally, the Appendices list related information, supporting documents. The preliminary and revised risk assessments for 2,4-D are available in the Public Docket, under docket number OPP- 2004-0167 and on the Agency’s web page, http://www.epa.gov/edockets.Page 3 of 304 II. Chemical Overview

A. Regulatory History

2,4-D has been used as an herbicide since the mid-1940s. Currently over 600 end-use products are registered for use on over 300 distinct agricultural and residential sites, and there are over 100 tolerances for 2,4-D listed in the Code of Federal Regulations. 2,4-D was the subject of a Registration Standard and a Registration Standard Guidance Document dated February 16, 1988 and September 9, 1988, respectively. These documents summarized the regulatory conclusions based on available data, and specified the additional data required for reregistration purposes. Numerous data submissions have been received and evaluated since the Registration Standard Guidance Document was published.

Special Review

2,4-D has been in pre-Special Review status since September 22, 1986, because of carcinogenicity concerns. More specifically, there were concerns for epidemiological links of 2,4-D to non-Hodgkin’s lymphoma from both occupational and residential exposure. A proposed decision not to initiate Special Review was published (53 FR 9590) on March 23, 1988 based on findings that such a link could not be established. The final decision was deferred until reregistration. In part to address these concerns, the 2,4-D Task Force agreed to risk reduction measures in September 1992 that included an exposure reduction plan effected through modifications of technical and manufacturing-use product labels and implementation of a user education program.

A Science Advisory Board/Scientific Advi sory Panel Special Joint Committee reviewed available epidemiological and other data on 2,4-D in 1992 and concluded that “the data are notsufficient to conclude that there is a cause and effect relationship between exposure to 2,4-D and nonHodgkin’s lymphoma.” 2,4-D was classified as a Group D, not classifiable as to human carcinogenicity. The Agency requested further histopathological examinations of rat brain tissues and mouse spleen tissues in question. These exams were submitted and reviewed, and on March 16, 1999, the Agency notified the 2,4-D Task Force that the Agency would continue to classify 2,4-D as a Group D carcinogen.

The Agency has twice recently reviewed epidem iological studies linking cancer to 2,4-D. In the first review, completed January 14, 2004, EPA concluded there is no additional evidence that would implicate 2,4-D as a cause of cancer (E PA, 2004). The second review of available epidemiological studies occurred in response to comments received during the Phase 3 Public Comment Period for the 2,4-D RED. EPA’s report, dated December 8, 2004 and authored by EPA Scientist Jerry Blondell, Ph.D., found that none of the more recent epidemiological studies definitively linked human cancer cases to 2,4-D.

Final notice of the Agency’s decision not to in itiate Special Review will be issued at the completion of the reregistration process.Page 4 of 304 Residue Tolerances

Tolerances for residues of 2,4-D in/on plant and processed food/feed commodities, fish, and potable water are expressed in terms of 2,4-D per se [40 CFR §180.142(a)(1-6 and 9-12) and (b)]. There are currently approximately 110 tolerances for 2,4-D.

The Industry Task Force II on 2,4-D Research Data (Task Force II) is supporting the reregistration of 2,4-D. The members of the Task Force currently include Agro-Gor Corp (jointly owned by Atanor, S.A. and PBI-Gordon Corp.), Dow AgroSciences, and Nufarm USA. In addition, USDA’s Interregional Project No. 4 (IR-4) is supporti ng the reregistration of a number of minor crop uses for 2,4-D, and the California Citrus Quality Council (CCQC) is supporting selected uses of 2,4- D isopropyl ester (IPE) on citrus fruits.

B. Chemical Identification

2,4-D [2,4-dichlorophenoxyacetic acid] is a List A pesticide active ingredient classified as an herbicide, a plant growth regulator, and a fungicide . It is, however, mainly used as a selective postemergence herbicide for the control of broadleaf weed species in a vari ety of food/feed sites including field, fruit, and vegetable crops. In addition to the acid form, there are numerous salts and esters of 2,4-D in Reregistration Case 0073, each with an assigned PC Code number, that are presently registered as active ingredients in end-use products (EPs). Nine forms of 2,4-D are currently supported; these forms are listed in Table 1 below. With regards to analytical methodology, the quantitative recovery of residues of concern are enhanced by the formation of the more polar acid form of 2,4-D. Given that results of 2,4-D analyses are typically expressed in terms of the quantified levels of the acid form, 2,4-D concentrations in product formulations are typically referred to in terms of acid equivalents (ae).

Chemical structures and information are presented in Tables 1 and 2 for 2,4-D acid and those salts and esters with registered manufacturing-use and/or end-use products (MPs/EPs) being supported by 2,4-D Task Force II and its member companies.

Table 1. Chemical Structures for Supported Forms of 2,4-D Acid, Amine Salts, and Esters

2,4-D active ingredients with registered MPs/EPs

2,4-D acid Empirical Formula: C 8 H 6 Cl 2 O 3 Molecular Weight: 221.0 CAS Registry No.: 94-75-7

PC Code: 030001 2,4-D sodium salt (Na) Empirical Formula: C 8 H 5 Cl 2 NaO 3 Molecular Weight: 243.03 CAS Registry No.: 2702-72-9

PC Code: 0300042,4-D active ingredients with registered MPs/EPs

Page 5 of 304 O Cl

O Cl

O [NH 2 (CH 3 ) 2 ] +

O Cl Cl

O

O NH + (CH 2 CHOHCH 3 ) 3 O Cl Cl

OH

O O Cl Cl

O

O Na +

O Cl Cl

O O - [NH 2 (CH 2 CH 2 OH) 2 ] +

Cl Cl

O O

O - [NH 3 CH(CH 3 ) 2 ] + 2,4-D diethanolamine salt (DEA) Empirical Formula: C 12 H 17 Cl 2 NO 5 Molecular Weight: 326.18 CAS Registry No.: 5742-19-8

PC Code: 030016 2,4-D dimethylamine salt (DMA) Empirical Formula: C 10 H 13 Cl 2 NO 3 Molecular Weight: 266.13 CAS Registry No.: 2008-39-1

PC Code: 030019

2,4-D isopropylamine salt (IPA) Empirical Formula: C 11 H 15 Cl 2 NO 3 Molecular Weight: 280.04 CAS Registry No.: 5742-17-6

PC Code: 030025 2,4-D triisopropanolamine salt (TIPA) Empirical Formula: C 17 H 27 Cl 2 NO 6 Molecular Weight: 412.31 CAS Registry No.: 32341-80-3

PC Code: 030035

2,4-D 2-butoxyethyl ester (BEE) Empirical Formula: C 14 H 18 Cl 2 O 4 Molecular Weight: 321.20 CAS Registry No.: 1929-73-3

PC Code: 030053 2,4-D 2-ethylhexyl ester (2-EHE) 1 Empirical Formula: C 16 H 22 Cl 2 O 3 Molecular Weight: 333.27 CAS Registry No.: 1928-43-4

PC Code: 0300632,4-D active ingredients with registered MPs/EPs

Page 6 of 304 O Cl Cl

O O CH 3

CH 3 O Cl Cl

O

O O CH 3

Cl Cl

O O CH 3

O CH 3 2,4-D isopropyl ester (IPE) Empirical Formula: C 11 H 12 Cl 2 O 3 Molecular Weight: 263.12 CAS Registry No.: 94-11-1

PC Code: 030066

1 Formerly identified as the isooctyl ester.

Available data concerning identification of the active ingredients are summarized in Table 2 for 2,4-D acid, salts, and esters with registered MPs/EPs.Page 7 of 304Table 2. Available Data Concerning Identification of the Active Ingredient1Active ingredient(PC Code) Color Physical StateMelting Point/Boiling PointDensity/SpecificGravityOctanol/WaterPartition Coeff. Vapor Pressure Solubility2,4-D acid(030001)whitecrystallinesolidm.p. 138-141 Cs.g.=1.416at 25 CLog KO/W0.001 M sol’npH 5 2.14pH 7 0.177pH 9 0.1021.4 x 10-7mm Hgat 25 Cwater = 569 mg/L at 20 C2,4-D Na salt(030004)white powder m.p. 200 Cbulk = 42.2 lb/ft3at 25 CN/A2; salt dissociates to acid in waterwater = 4.5 g/100 mL at 25C2,4-D DEA salt(030016)cream powder m.p. 83 Cbulk = 0.762g/cm3at 25 C2.24 x 10-2at 25 C<1.33 x 10-5Pa at25 Cmg/g at 25 Cwater = 8062,4-D DMA salt(030019)amberaqueousliquidm.p. 118-120 C(PAI)s.g. = 1.23at 20 CN/A; saltdissociates to acidin water<1 x 10-7mm Hgat 26 Cg/100 mL at 20 Cwater = 72.9 (pH 7)2,4-D IPA salt(030025)amberaqueousliquidm.p. 121 C(PAI)s.g. = 1.15at 20 CN/A; salt dissociates to acid in waterg/100 mL at 20 Cwater = 17.4 (pH 5.3)2,4-D TIPA salt(030035)amber aqueous liquidm.p. 87-110 C(PAI)s.g. = 1.21at 20 CN/A; salt dissociates to acid in waterg/100 mL at 20 Cwater = 46.1 (pH 7)2,4-D BEE(030053)darkamberliquid b.p. 89 Cs.g. = 1.225at 20 Clog = 4.13-4.17at 25 C2.4 x 10-6mm Hgat 25 Cg/100 mL at 20 Cwater = insoluble2,4-D 2-EHE(030063)darkamberliquid b.p. 300 Cs.g. = 1.152at 20 Clog = 5.78(temp N/A)3.6 x 10-6mm Hg(temp N/A)water = 86.7 ppb2,4-D IPE(030066)paleamberliquid b.p. 240 Cs.g. = 1.252at 25 C253.8 ± 44.4(temp N/A)5.3 x 10-6mbar water = 0.023 g/100 mL1Data assembled from Agency memoranda and comprehensive review documents, including the 2,4-D Reregistration Standard.2N/A = Not available.Page 8 of 304 C. Use Profile

2,4-D comes in multiple chemical forms and is found in numerous end-use products intended for use in a wide range of use patterns. 2,4-D is an ingredient in approximately 660 agricultural and home use products, as a sole active ingredient and in conjunction with other active ingredients. 2,4-D is formulated primarily as an amine salt in an a queous solution or as an ester in an emulsifiable concentrate. Chemical forms covered by this risk assessment are as 2,4-D acid, 2,4-D DMAS, 2,4-D IPA, 2,4-D TIPA, 2,4-D EHE, 2,4-D BEE, 2,4-D DEA, 2,4-D IPE, and 2,4-D sodium salt. Copies of all labels may be found at http://www.cdpr.ca.gov/docs/epa/m2.htm. The following is information on the currently registered uses including an overview of use sites and application methods. A detailed table of the uses of 2,4-D eligible for reregistration is contained in Appendix A.

Type of Pesticide : Herbicide

Target organism(s) : A wide variety of broadleaf weeds and aquatic weeds

Mode of action : 2,4-D is thought to increase cell-wall plasticity, biosynthesis of proteins and the production of ethylene. The abnormal increase in these processes is thought to result in uncontrolled cell division and growth which damages vascular tissue.

Use Sites : Table 3 presents a summary of the registered 2,4-D uses.

Use Classification: General use

Formulation Types: Formulation types registered include emulsifiable concentrate, granular, soluble concentrate/solid, water dispersible granules, and wettable powder.

Application Methods: 2,4-D may be applied with a wide range of application equipment includingfixed-wing aircraft, backpack sprayer, band sprayer, boom sprayer, granule applicator, grounddirected sprayers, hand held sprayer, helicopter, injection equipment, tractor-mounted granule applicator, and tractor-mounted sprayers.

Application Rates: For 2,4-D, rates per application and rates per year are generally less than 1.5 pounds acid equivalent (ae) per acre per year and 2.0 pounds a.e. per acre per year (lbs ae/A), respectively. Maximum rates are 4.0 lbs ae/A per year for asparagus, forestry uses, and non-cropland uses, among others. The maximum rate for aquatic uses is 10.8 lbs ae/acre foot for submerged aquatic plants.

Application Timing: Timing of 2,4-D application can include at emergence, before bud break, during dormancy, to established plantings, foliar, post-emergence, pre-emergence, pre-harvest, and pre-plant.Page 9 of 304 Table 3. Registered 2,4-D Uses

Crop Grouping Representative Crops

Terrestrial food crop Pear, Pistachio, Stone fruits

Terrestrial food and feed

crop Agricultural fallow/idleland; Agricultural rights-of-way/fencerows/hedgerows; Agricultural uncultivated areas; Apple; Barley; Citrus fruits; Corn (unspecified);Corn, field; Corn, pop; Corn, sweet; Fruits (unspeci fied), Grapefruit, Lemon, Oats, Orange, Pome fruits, Rice, Rye, Small fruits, Soil, preplant/outdoor, Sorghum, Sorghum (unspecified), Soybeans (unspecified), Sugar cane, Tangelo, Tree nuts, Wheat

Terrestrial feed crop Grass forage/fodde r/hay, Pastures, Rangeland, Rye, Sorghum

Terrestrial non-food crop Agricultural fallow/idleland, Agricultural rights-of-way/fencerows/hedgerows, Agricultural uncultivated areas, Airports/la nding fields, Christmas tree plantations, Commercial/industrial lawns, Commercial/ins titutional/industrial, premises/equipment (outdoor), Forest nursery plantings (for transp lant purposes), Golf course turf, Grasses grown for seed, Industrial areas (outdoor), Nonagricultural outdoor buildings/structures, Nonagricultural rights-of-way/fencerows/hedgerows, Nonagricultural uncultivated areas/soils, Ornamental and/or shade trees, Ornamental lawns and turf, Ornamental sod farm (turf), Ornamental woody shrubs and vine s, Paved areas (private roads/sidewalks), Potting soil/topsoil, Recreation area lawns, Recreational areas, Soil, preplant/outdoor,

Urban areas

Terrestrial non-food and

outdoor residential Fencerows/hedgerows, Nonagricultural right s-of-way/fencerows/hedgerows, Ornamental and/or shade trees, Ornamental lawns and turf, Ornamental woody shrubs and vines, Paths/patios, Paved areas (private roads/sidewalks), Urban areas

Aquatic food crop Agricultural drainage systems, Aquatic ar eas/water, Commercial fishery water systems, Irrigation systems, Lakes/ponds/reservoirs (with human or wildlife use), Rice, Streams/rivers/channeled water, Swam ps/marshes/wetlands/stagnant water

Aquatic non-food

outdoor Aquatic areas/water, Streams/rivers/channeled water, Swamps/marshes/wetlands/stagnant water

Aquatic non-food

industrial Drainage systems, Industrial waste dispos al systems, Lakes/ponds/reservoirs (without human or wildlife use)

Forestry Conifer release, Forest pl antings (reforestation programs)(tree farms, tree plantations, etc.), Forest tree management/forest pest ma nagement, Forest trees (all or unspecified), Forest trees (hardwoods, broadleaf tr ees), Pine (forest/shelterbelt)

Outdoor residential Residential lawns

Indoor non-food Commercial transportation facilities-nonfeed/nonfood

D. Estimated Usage of Pesticide

Based primarily on pesticide usage information from 1992 through 2000 for agriculture and 1993 through 1999 for non-agriculture, total annual domestic usage of 2,4-D is approximately 46 million pounds, with 30 million pounds (66%) used by agriculture and 16 million pounds (34%) used by non-agriculture (see the OPP Biological and Economic Assessment Division [BEAD] quantitative use analysis [QUA] which is available on EPA’s Pesticide Docket OPP-2004-0167 located at:Page 10 of 304 http://www.epa.gov/edockets). In terms of pounds, total 2,4-D usage is allocated mainly to pasture/rangeland (24%), lawn by homeowners with fertilizer (12%), spring wheat (8%), winter wheat (7%), lawn/garden by lawn care operators/landscape maintenance contractors (7%), lawn by homeowners alone (without fertilizer) (6%), field corn (6%), soybeans (4%), summer fallow (3%), hay other than alfalfa (3%), and roadways (3%).

Agricultural sites with at least 10% of U.S. acr eage treated include spring wheat (51%), filberts (49%), sugarcane (36%), barley (36%), seed crops (29%), apples (20%), rye (16%), winter wheat (15%), cherries (15%), oats (15%), millet (15%), rice (13%), soybeans (12%) and pears (10%). For 2,4-D, rates per application and rates per year are generally less than 1.5 lbs ae/A per year and 2.0 lbs ae/A per year, respectively. 2,4-D is used predominantly in the Midwest, Great Plains, and Northwestern United States (Figure 1).Figure 1. Estimated 2,4-D usage (lbs ae/square mile).The estimates are based on pesticide use rates compiledby the National Center for Food and Agricultural Policy(NCFAP) and modified by Thelin, G.P. and Gianessi,L.P., 2000 (USGS Open-File Report 00-250)Page 12 of 304 Application Rates, Timing and Frequency of Applications

The 2,4-D master label (available in EPA docket #OPP-2004-0167) has been developed by the2,4-D Task Force and represents the maximum supported application rates for agricultural and nonagricultural uses. All end-use product manufacturers obtain 2,4-D starting material from companies represented by the 2,4-D Task Force. EPA used the master label rates in the 2,4-D human health and ecological risk assessments. Some master label rates are lower than the rates present on existing labels. The Agency and the task force have agreed that all of the 2,4-D labels will be updated with the new master label rates as part of the registration process. All of the registrants, including those that are not in the 2,4-D task force, will have to conform to the master label rates. The master label agreement is discussed in an internal Agency memo (EPA, March 18, 2003), which is available on EPA’s Pesticide Docket OPP-2004-0167 located at: http://www.epa.gov/edockets.

Typically, one to three applications are made per growing season. Applications are made to the target weeds prior to crop emergence, after crop emergence, prior to harvest, and in the dormant season, depending upon the crop. The label required spray volumes for ground applications range from 0.0375 lbs ae/A for applications to low bush blue berries to 4.0 lbs ae/A for brush control. 2,4-D can be applied over the top to tolerant crops such as small grains and rice, but must be directed or shielded for the more sensitive crops such as fruits and berries.

The application rates on the master label are included in Table 4 for non-crop areas and Table 5 for agricultural crops. The average application rates from the 2,4-D QUA report (EPA BEAD 2001) are shown for comparison. With the exception of filberts, the QUA data indicate that only one application is made to most crops. The National Agricultural Pesticide Impact Assessment Program (NAPIAP) report on Phenoxy Herbicides indicates that on average one 2,4-D application is made annually to turfgrass.

Table 4. 2,4-D Application Rates for Non-Crop Areas

Aquatic Areas, Forestry, Non-Crop Areas and

Turf Acid Equivalent lbs (ae) Application Rates Per Application/Per crop or Year

Master Label Amount Used per QUA Report

Aquatic Areas - Floating Weeds 2.0/4.0 per acre 512,000 lbs A

Aquatic Areas - Submerge d Weeds 10.8 per acre foot

Tree and Brush Control - Tree Injection 1 to 2 ml per inch of trunk diameter 136,000 lbs

Forestry - Weed and Brush Control 4.0/4.0 per acre

Forestry - Conifer Release 4.0/4.0 per acre

Irrigation Ditch Banks 2.0/4.0 per acre

Rights of Way Areas 2.0/4.0 per acre 2.1 million lbs

Rangeland, Pastures 2.0/4.0 per acre

Turf - Grass Grown for Seed or Sod 2.0/4.0 per acre 351,000 lbsAquatic Areas, Forestry, Non-Crop Areas and

Turf Acid Equivalent lbs (ae) Application Rates Per Application/Per crop or Year

Master Label Amount Used per QUA Report

Page 13 of 304 Turf - Ornamental 2.0/4.0 per acre B 11.6 million lbs

A. According to the NAPIAP report about 98,000 acres were treat ed for floating weeds and about 5,000 acres were treated for submerged weeds by state agencies in 1993. B. The registrants have agreed to reduce the ornamental turf ra te from 2.0 to 1.5 lbs ae per acre. The new maximum yearly rat e will be 3.0 lbs ae per acre.

Table 5. 2,4-D Application Rates for Agricultural Crops

Agricultural Crops Acid Equivalent lbs (ae) Application Rates per Acre Per Application/Per crop or Year

Master Label Average Rate per QUA Report

Asparagus 2.0/4.0 1.1/1.3

Blueberries - Low Bush Wi per Bar 0.0375 lb/GA 0.46/0.51

Blueberries - High Bush 1.4/2.8

Citrus (Growth Regulator) 0.1 No Data

Conifer Plantations 4.0/4.0 No Data

Corn (sweet) Corn (field and pop) 0.5 to 1.0/1.5

0.5 to 1.5/3.0 0.48/0.51

0.44/0.46

Cranberries - granular applications Cranberries - liquid applications 4.0/4.0 dormant season application 1.2/2.4 growing season application 1.8/2.0

Fallowland and Crop Stubble 2.0/4.0 0.69/0.89

Filberts 1.0 lb per 100 Ga/4 Apps per year 0.64/1.7

Grain Sorgum 0.5 to 1.0/1.0 0.46/0.50

Grapes 1.36/1.36 0.73/0.87

Orchard Floors (Pome and Stone Fruits, Tree Nuts) 2.0/4.0 Apples = 1.2/1.4

Pears = 1.1/1.5

Potatoes 0.07/0.14 0.10/0.17

Rice 1.0 or 1.5/1.5 0.92/0.94

Soybeans (Preplant burndown) 0.5 or 1.0/1.0 0.46/0.47

Strawberries (Except CA or FL) 1.5/1.5 1.2/1.3

Sugarcane 2.0/4.0 0.75/0.99

Cereal Grains (Wheat, Barley, Millet, Oats and Rye) 0.5 or 1.25/1.75 Wheat= 0.44/0.48 Barley =0.46/0.47

Oats = 0.46/0.46 Rye = 0.50/0.50

Millet= 0.44/0.44Agricultural Crops Acid Equivalent lbs (ae) Application Rates per Acre Per Application/Per crop or Year

Master Label Average Rate per QUA Report

Page 14 of 304 Wild Rice (MN only) 0.25/0.25 0.20/0.20Page 15 of 304 III. Summary of 2,4-D Risk Assessment

The following is a summary of EPA’s human health and ecological risk findings and conclusions for 2,4-D, as presented fully in the documents “2,4-D. HED’s Revised Human Health Risk Assessment for the Reregistration Eligib ility Decision (RED) Revised to Reflect Public Comments” dated May 12, 2005, and the “Environmental Fate and Effects Division’s Risk Assessment for the Reregistration Eligibility Decision for 2,4-D,” dated October 28, 2004.

The purpose of this section is to summarize the ke y features and findings of the risk assessment in order to help the reader better understand the risk management decisions reached by the Agency. While the risk assessments and related addenda are not included in this document, they are available in the public docket OPP-2004-0167, and on the Agency's website at http://www.epa.gov/pesticides/reregistration/status.htm

A. Human Health Risk Assessment

EPA released its preliminary risk assessments for 2,4-D for public comment on June 23, 2004, thereby starting Phase 3 of a six phase public participation process. In response to comments received during Phase 3, the human health risk assessment was updated. EPA issued the revised risk assessments for 2,4-D for a second public comment period on January 12, 2005 (Phase 5 of the public participation process). The risk assessments were revised again in response to Phase 5 public comments, and are available for review.

The 2,4-D degradates detected in the various laboratory environmental fate studies were 1,2,4- benzenetriol, 2,4-dichlorophenol (2,4-DCP), 2,4- dichloroanisole (2,4-DCA), 4-chlorophenol, chlorohydroquinone (CHQ), volatile organics, bound residues, and carbon dioxide. The OPP Metabolism Assessment Review Committee (MARC) determined that all residues other than 2,4-D are not of risk concern due to low occurrence under environmental conditions, comparatively low toxicity, or a combination thereof. Therefore, the Agency assessed risks from 2,4-D per se

.

1. Toxicity of 2,4-D

With very few exceptions, the effects and relative toxicities of the salt and ester forms of 2,4-D are quite similar to those of the acid form. Thus, the acid form was selected as being representative of all members of the 2,4-D reregistration case (Case No. 0073). The member chemicals in the 2,4-D case exhibit low to slight acute toxicity with the exception of the acid and salt forms being severe eye irritants. The Agency has reviewed all toxicity studies submitted for 2,4-D and has determined that the toxicological database is sufficient for reregistration. Further details on the toxicity of 2,4-D can

be found in the technical support documents cited in Appendix C.

a. Toxicity Profile

Major features of the toxicology profile are presented below. In acute studies, 2,4-D generally has low acute toxicity (Toxicity Category III or IV) via the oral, dermal and inhalation routes ofPage 16 of 304 exposure. 2,4-D is not a skin irritant (Toxicity Category III or IV), nor a skin sensitizer. Although the 2,4-D ester forms are not eye irritants (Toxicity Category III or IV), the acid and salt forms are considered to be severe eye irritants (Toxicity Category I). The acute toxicity of all 2,4-D forms is

listed in Table 6.

Table 6. Acute Toxicity Data for 2,4-D ac id, 2,4-D ester forms, and 2,4-D amine salts 1

.

Guideline

No. Study Type MRID Numbers Results Toxicity Category

870.1100 Acute Oral 2,4-D acid

DEA salt

DMA salt

IPA salt

IPE ester
TIPA salt

BEE ester

EHE ester 00101605

41920901

00157512

00252291

41709901

41413501

40629801

41209001 rat LD 50 = 639 mg/kg

rat LD 50 = 735 mg/kg

rat LD 50 = 949 mg/kg

rat LD 50 = 1646 mg/kg

rat LD 50 = 1250 mg/kg

rat LD 50 = 1074 mg/kg

rat LD 50 = 866 mg/kg

rat LD 50 = 896 mg/kg III

III

III

III

III

III

III

III

870.1200 Acute Dermal 2,4-D acid

DEA salt

DMA salt

IPA salt

IPE ester
TIPA salt

BEE ester

EHE ester 00101596

41920911

00157513

00252291

41709902

41413502

40629802

41209002 rabbits LD 50 >2000 mg/kg

rabbits LD 50 >2000 mg/kg

rabbit LD 50 1829 mg/kg

rabbits LD 50 >2000 mg/kg

rabbits LD 50 >2000 mg/kg

rabbits LD 50 >2000 mg/kg

rabbits LD 50 >2000 mg/kg

rabbits LD 50 >2000 mg/kg III

III

III

III

III

III

III

III

870.1300 Acute Inhalation 2,4-D acid

DEA salt

DMA salt

IPA salt

IPE ester
TIPA salt

BEE ester

EHE ester 00161660

41986601

00157514

40085501

40352701

41957601

40629803

42605202 rat LC 50 >1.79 mg/L

rat LC 50 >3.5 mg/L

rat LC 50 >3.5 mg/L

rat LC 50 =3.1 mg/L

rat LC 50 >4.97 mg/L

rat LC 50 =0.78 mg/L

rat LC 50 =4.6 mg/L

rat LC 50 >5.4 mg/L III

IV

IV

IV

IV

III

IV

IV

870.2400 Primary Eye Irritation 2,4-D acid

DEA salt

DMA salt

IPA salt

IP ester
TIPA salt

BEE ester

EHE ester 41125302

41920902

00157515

00252291

40352702

41413504

40629804

44725303 severe eye irritant severe eye irritant severe eye irritant severe eye irritant not an eye irritant severe eye irritant not an eye irritant not an eye irritant I

I

I

I

IV

I

III

III

870.2500 Primary Skin Irritation 2,4-D acid

DEA salt

DMA salt

IPA salt

IPE ester
TIPA salt

BEE ester

EHE ester 42232701

41920903

00157516

00252291

40352703

41413505

40629805

41413505 unacceptable slight skin irritant slight skin irritant slight skin irritant slight skin irritant slight skin irritant very mild irritant

not a skin irritant N/A

III

IV

IV

IV

IV

IV

IVGuideline

No. Study Type MRID Numbers Results Toxicity Category

Page 17 of 304 870.2600 Dermal Sensitization 2,4-D acid

DEA salt

DMA salt

IPA salt

IPE ester
TIPA salt

BEE ester

EHE ester 00161659

41920904

41642805

41233701

40352704

41413506

40629806

41209006 not a dermal sensitizer

not a dermal sensitizer unacceptable unacceptable

not a dermal sensitizer

not a dermal sensitizer

not a dermal sensitizer unacceptable N/A

1. The technical acute toxicity values included in this docum ent are for informational purposes only. The data supporting the se values will be evaluated during reregistration and may or may not meet the current Agency acceptance criteria.

The mechanisms responsible for renal clearance of 2,4-D have been investigated in several species. 2,4-D is actively secreted by the proximal tubules. This mechanism of renal clearance is consistent with results seen with other phenoxy ac ids. It has been suggested that observed dosedependent, non-linear, pharmacokinetics of 2,4-D are primarily due to the saturation of this renal secretory transport system. Due to a limited capacity to excrete organic acids, the dog is more sensitive to the effects of 2,4-D than the rat with respect to repeated dosing.

In laboratory animals, following subchronic, oral exposure at dose levels of 2,4-D above the threshold of saturation for renal clearance, the primary target organs are the eye, thyroid, kidney, adrenals, and ovaries/testes. Changes in these organs are also observed following exposure to the amine salts and esters of 2,4-D. Systemic toxicity was not observed following repeated dermal exposure to 2,4-D, EHE, and TIPA at or above the limit dose or following repeated dermal exposure to BEE and IPA at the highest dose tested. Liver toxicity was observed following repeated high-dose dermal exposure to DEA, and one death occurred following repeated high-dose dermal exposure to

DMA.

There are no repeat-dose inhalation exposure data available on 2,4-D. The most reliable way to characterize inhalation toxicity and to quantify inhalation risk is through the use of inhalation toxicity studies. In general, chemicals tend to be more toxic by the inhalation route than by the oral route due to rapid absorption and distribution, bypassing of the liver’s metabolic protection (portal circulation), and potentially serious portal-of-entry effects, su ch as irritation, edema, cellular transformation, degeneration, and necrosis. An inhalation risk assessment that is based on oral data generally underestimates the inhalation risk because it cannot account for these factors. However, in the case of 2,4-D, based on the limited metabolism of 2,4-D via the oral route, the moiety to which the body would be exposed would be the same for both rout es of exposure. With regard to portal-of-entry effects, these can only be assessed in an inhalation study. Therefore, a subchronic (28-day) inhalation study is required for 2,4-D.

Developmental toxicity, characterized mainly as an increased incidence of skeletal abnormalities in the rat, was observed following exposure to 2,4-D and its amine salts and esters at

dose levels that were at or above the threshol d of saturation of renal clearance. Similarly, developmental toxicity was observed in the rabbit only following exposure to 2,4-D (abortions) and DEA (increased number of litters with fetuses having 7th cervical ribs) at or above the threshold ofPage 18 of 304 renal clearance.

Reproductive toxicity, characterized as an incr ease in gestation length, was observed following exposure to 2,4-D at a dose level above the threshold of saturation of renal clearance. A repeat 2- generation reproduction study (using the revised EPA pr otocol) is required to address concerns for endocrine disruption.

Neurotoxicity was demonstrated following expos ure to 2,4-D at relatively high dose levels. Clinical signs of neurotoxicity (ataxia, decreased motor activity, myotonia, prostration, lateral recumbency, impaired/loss of the righting reflex, and skin cold to the touch) were observed in pregnant rabbits following exposure to 2,4-D and its amine salts and esters. Neuropathology (retinal degeneration) was observed following 2,4-D exposure in several studies in female rats. Incoordination and slight gait abnormalities (forepaw flexing or knuckling) were observed following acute dosing and increased forelimb grip strength was observed following chronic exposure to 2,4-D at dose levels that exceeded the threshold of saturation of renal clearance. A developmental neurotoxicity study in the rat is required for 2,4-D.

2,4-D is classified as a Group D chemical (not cl assifiable as to human carcinogenicity). Based on the overall pattern of responses observed in both in vitro and in vivo genotoxicity tests, 2,4-D was not mutagenic, although some cytogenic effects were observed. 2,4-D acid is currently considered to be representative of all nine member chemicals of the 2,4-D case.

The toxicological endpoints that were used to complete the risk assessments are summarized in Table 7. These endpoints were selected by the Agency from animal studies. With respect to dermal exposures, the Agency previously selected a dermal absorption factor of 5.8 percent based on the average absorbed dose value from a human dermal absorption study. That factor (5.8 percent) was used in previous versions of the human health risk assessment. Based on comments received during the Phase 5 comment period, the dermal absorption study and resulting absorption factor were reconsidered. In order to account for the variability observed in the dermal absorption study, the dermal absorption factor was changed from 5.8 percent to 10 percent. In their “Re-evaluation of the Lawn and Turf Uses of 2,4-D,” which was made available to the public for review, Health Canada also selected a factor of 10 percent based upon the weight of evidence from several published studies, taking into account the variability in the data and the limitations of the various studies. These studies include the Feldman and Maibach study discussed above and studies from Harris and Solomon 1992, Moody et. al. 1990, Wester et. al. 1996, and Pelletier et al. 1988.

b. Safety and Database Uncertainty Factors

The Food Quality Protection Act (FQPA) directs th e Agency to use an additional tenfold (10X) safety factor to protect for special sensitivity of infants and children to specific pesticide residues in food, drinking water, or residential exposures, or to compensate for an incomplete database. FQPA authorizes the Agency to modify the tenfold safe ty factor only if reliable data demonstrate that another factor would be appropriate.

FQPA Special Safety Factor. After evaluating hazard and exposure data for 2,4-D, EPAPage 19 of 304 removed the default 10X FQPA special safety fa ctor. The toxicity database for 2,4-D includes acceptable developmental and reproductive toxicity studies. Developmental toxicity studies were conducted in both rats and rabbits for most 2,4-D forms. There is qualitative evidence of susceptibility in the rat developmental toxicity study with 2,4-D acid and DEA salt where fetal effects (skeletal abnormalities) were observed at a dose level that produced less severe maternal toxicity (decreased body-weight gain and food consumption). There is no evidence of increased (quantitative or qualitative) susceptibility in the prenatal developmental toxicity study in rabbits or in the 2- generation reproduction study in rats on 2,4-D. Regarding the 2,4-D amine salt and ester forms, no evidence of increased susceptibility (quantitative or qualitative) was observed in the prenatal developmental toxicity study in rats and rabbits (except for 2,4-D DEA) dosed with any of the amine salts or esters of 2,4-D. There is evidence of increased susceptibility (qualitative) in the prenatal developmental study in rabbits for 2,4-D DEA salt.

After establishing developmental toxicity endpoints to be used in the risk assessment with traditional uncertainty factors (10x for interspecies variability and 10x for intraspecies variability), the Agency has no residual concerns for the effects seen in the developmental toxicity studies. Therefore, the 10X FQPA special safety factor was reduced to 1X.

Database Uncertainty Factor. On April 8, 2003, based on the weight of evidence presented, the Agency reaffirmed the previous conclusion that a developmental neurotoxicity (DNT) study in rats is required for 2,4-D because there is a concern for developmental neurotoxicity resulting from exposure to 2,4-D. There is evidence of neurotoxicity, including clinical signs such as ataxia and decreased motor activity in pregnant rabbits following dosing during gestation days 6-15 in studies on 2,4-D itself and 2,4-D amine salts and esters, and tremors in dogs that died on test following repeat exposure to 2,4-D. Incoordination and slight gait abnormalities (forepaw flexing or knuckling) were also observed following dosing in the acute neurotoxicity study with 2,4-D. There is also evidence of developmental toxicity, as discussed above in the FQPA Special Safety Factor section. In addition, the Agency determined that a repeat 2-generation reproduction study using the new protocol is required to address specific concerns for e ndocrine disruption (thyroid and immunotoxicity measures). Therefore, the Agency determined that a 10X database uncertainty factor (UF DB ) is

needed to account for the lack of these studies.

c. Carcinogenicity

A Science Advisory Board/Scientific Advi sory Panel Special Joint Committee reviewed available epidemiological and other data on 2,4-D in 1992 and concluded that “the data are notsufficient to conclude that there is a cause and effect relationship between exposure to 2,4-D and nonHodgkin’s lymphoma.” 2,4-D has been classified as a Category D chemical (i.e., not classifiable as to human carcinogenicity), by the EPA/OPP Cancer Peer Review Committee in 1996. The Agency requested further histopathological examinations of rat brain tissues and mouse spleen tissues in question. These exams were submitted and reviewed and on March 16, 1999, the Agency notified the 2,4-D Task Force that the Agency would continue to classify 2,4-D as a Group D carcinogen.

The Agency has twice recently reviewed epidem iological studies linking cancer to 2,4-D. In the first review, completed January 14, 2004, EPA concluded there is no additional evidence thatPage 20 of 304 would implicate 2,4-D as a cause of cancer (EPA, 2004). The second review of available epidemiological studies occurred in response to comments received during the Phase 3 Public Comment Period for the 2,4-D RED. This report, dated December 8, 2004 and authored by EPA Scientist Jerry Blondell, Ph.D., found that none of the more recent epidemiological studies definitively linked human cancer cases to 2,4-D.

2,4-D Diethanolamine (DEA). The Agency recently reviewed the available toxicology data on diethanolamine (DEA) and related compounds. The Agency concluded that it was not likely that exposure to the DEA salt of 2,4-D resulting from occupational use would pose a carcinogenic risk to humans. While liver tumors were observed in mice following dermal exposure to DEA, there was no evidence of carcinogenicity in rats following dermal exposure, and there was no evidence of a genotoxic or mutagenic concern. Although no formal assessment has been performed on the proposed mode of action (choline deficiency), this mode of action was considered plausible for the mouse hepatocellular tumors observed following dermal exposure to DEA, as were other confounding factors, including the use of ethanol as a vehicle for dose administration and the fact that humans are generally refractive to choline deficiency. Additionally, the low use pattern for 2,4-D DEA indicates that there is no potential long-term dermal exposure to the diethanolamine salt of 2,4-D in agricultural uses. The Agency also determined that, at this time, no carcinogenicity studies are required for the DEA salt of 2,4-D.

d. Cumulative Assessment

FQPA requires EPA to consider "available inform ation" concerning the cumulative effects of a particular pesticide's residues and "other substances that have a common mechanism of toxicity" when considering whether to establish, modify, or revoke a tolerance. Potential cumulative effects of chemicals with a common mechanism of toxicity are considered because low-level exposures to multiple chemicals causing a common toxic effect by a common mechanism could lead to the same adverse health effect as would a higher level of exposure to any one of these individual chemicals. 2,4-D is a member of the alkylphenoxy herbicide class of pesticides. A cumulative risk assessment has not been performed as part of this human hea lth risk assessment because the Agency has not yet made a determination whether or not phenoxy herbicides have a common mechanism of toxicity. For information regarding EPA’s efforts to determine which chemicals have a common mechanism of toxicity and to evaluate the cumulative effects of such chemicals, see the policy statements released by the EPA’s Office of Pesticide Programs concerning common mechanism determinations and procedures for cumulating effects from substances found to have a common mechanism on EPA’s

website at http://www.epa.gov/pesticides/cumulative/

e. Endocrine Effects

EPA is required under the Federal Food, Drug, and Cosmetic Act (FDCA), as amended by the Food Quality Protection Act (FQPA), to develop a screening program to determine whether certain substances (including all pesticide active and other ingredients) "may have an effect in humans that is similar to an effect produced by a naturally occurri ng estrogen, or other such endocrine effects as the Administrator may designate."Page 21 of 304 When the appropriate screening and/or testing protocols being considered under the Agency’s Endocrine Disruption Screening Program (EDSP) have been developed, 2,4-D may be subject to additional screening and/or testing to better characterize effects related to endocrine disruption.

Based on currently available toxicity data, which demonstrate effects on the thyroid and gonads following exposure to 2,4-D, there is concern regarding its endocrine disruption potential. There have been no studies on 2,4-D that specifically assess its endocrine disruption potential. The Agency has determined that a repeat 2-generation reproduction study using the most recent protocol is required to address both the concern for thyroid effects (comparative assessment between the young and adult animals) and immunotoxicity, as well as a more thorough assessment of the gonads and reproductive/developmental endpoints

.

f. Toxicological Endpoints for Risk Assessment

The toxicological endpoints used in the human health risk assessment for 2,4-D are listed in Table 7. The safety factors used to account for interspecies extrapolation, intraspecies variability, special susceptibility of infants and children, and database uncertainties are also described in Table 7 below. This table also describes any absorption factors used to extrapolate from one route of exposure to another (e.g., oral to dermal).

Table 7. Toxicity Endpoints for Human Health Risk Assessment for 2,4-D

Exposure
Scenario Dose Used in Risk Assessment, UF Special FQPA SF and Level of

Concern for Risk Assessment Study and Toxicological Effects

Dietary Exposures

Acute Dietary (Females 13-49 years of age) MRID 00130407,

00130408 NOAEL = 25 mg/kg/day

UF = 1000

Acute RfD = 0.025 mg/kg/day FQPA SF = 1X

aPAD = acute RfD(0.025) FQPA SF (1)

= 0.025 mg/kg/day Rat Developmental Toxicity Study, LOAEL = 75 mg/kg/day based on skeletal

abnormalities

Acute Dietary (General population including infants and children)

MRID 43115201 NOAEL = 67 mg/kg/day

UF = 1000

Acute RfD = 0.067 mg/kg/day FQPA SF = 1X

aPAD = acute RfD (0.067) FQPA SF (1)

= 0.067mg/kg/day Acute Neurotoxicity Study in Rats LOAEL = 227 mg/kg/day based on gait

abnormalities

Chronic Dietary (All populations)

MRID 43612001 NOAEL= 5 mg/kg/day

UF = 1000

Chronic RfD = 0.005 mg/kg/day FQPA SF = 1X

cPAD = chronic RfD (0.005) FQPA SF (1)

= 0.005 mg/kg/day Rat Chronic Toxicity Study LOAEL = 75 mg/kg/day based on decreased body-weight gain (females) and food consumption (females), alterations in hematology , and clinical chemistry parameters, decreased T4 (both sexes), glucose (females), cholesterol (both sexes), and triglycerides (females).

Occupational and Resident ial Non-Dietary ExposuresExposure
Scenario Dose Used in Risk Assessment, UF Special FQPA SF and Level of

Concern for Risk Assessment Study and Toxicological Effects

Page 22 of 304 Short-Term Incidental Oral (1- 30 days) MRID 00130407,

00130408 NOAEL= 25 mg/kg/day Residential LOC for MOE

=1000

Occupational = NA Rat developmental toxicity study LOAEL = 75 mg/kg/day based on decreased maternal body-weight gain

IntermediateTerm Incidental Oral (1- 6 months)

MRID 41991501 NOAEL = 15 mg/kg/day Residential LOC for MOE =

1000

Occupational = NA Rat Subchronic Oral Toxicity LOAEL = 100 mg/kg/day based on decreased body weight/body-weight gain, alterations in some hematology, and clinical chemistry parameters, and cataract

formation.

Short-Term

Dermal*

MRID 00130407,

00130408 Oral study NOAEL= 25 mg/kg/day Residential LOC for MOE

= 1000

Occupational LOC for MOE =

100 Rat Developmental Toxicity Study LOAEL = 75 mg/kg/day based on decreased maternal body-weight gain and

skeletal abnormalities

IntermediateTerm
Dermal* MRID 00130407,

00130408 Oral study NOAEL = 15 mg/kg/day Rat Subchronic Oral Toxicity (same as for intermediate-term incidental oral)

Long-Term
Dermal*

MRID 43612001 Oral study NOAEL= 5 mg/kg/day Rat Chronic Toxicity Study (same as for chronic dietary)

Short-Term

Inhalation*

MRID 00130407,

00130408 Oral study NOAEL= 25 mg/kg/day Rat Developmental Toxicity Study (same as for short-term dermal)

IntermediateTerm Inhalation* MRID 00130407,

00130408 Oral study NOAEL = 15 mg/kg/day Rat Subchronic Oral Toxicity (same as intermediate-term incidental oral)

Long-Term
Inhalation*

MRID 43612001 Oral study NOAEL= 5 mg/kg/day Rat Chronic Toxicity Study (same as for chronic dietary)

Cancer Classification : Group D [not classifiable as to human carcinogenicity]

The dermal absorption factor is 10 percent and the inhalation absorption factor is 100 percent.

UF = uncertainty factor, FQPA SF = Special FQPA safety f actor, NOAEL = no observed adverse effect level, LOAEL = lowest observed adverse effect level, PAD = popula tion adjusted dose (a = acute, c = chronic) , RfD = reference dose, MOE = margin of exposure, LOC = level of concern, NA = Not Applicable

Dermal Absorption . A dermal absorption study utilizing human volunteers is available. Excretion following dermal application was 5.8 ± 2.4 percent (mean ± S.D.) of the administered dose and after intravenous administration was 100 ± 2.5 percent. The Agency previously selected a dermalPage 23 of 304 absorption factor of 5.8 percent based on the human dermal absorption study. This factor was used in previous versions of this risk assessment. Based on comments received during the Phase 5 comment period, this dermal absorption study and factor were reconsidered. In order to account for the variability observed in the dermal absorption study, the dermal absorption factor was changed from 5.8 percent to 10 percent. In their “Re-evaluation of the Lawn and Turf Uses of 2,4-D,” which was made available to the public, Health Canada also selected a factor of 10 percent based upon the weight of evidence from several published studies, taking into account the variability in the data and the limitations of the various studies. These studies include the Feldman and Maibach study

discussed above and studies from Harris and Solomon 1992, Moody et. al. 1990, Wester et. al. 1996,

and Pelletier et al. 1988.

2. Dietary Exposure and Risk from Food

a. Exposure Assumptions

Acute and chronic dietary exposure and risk analyses for 2,4-D were conducted using the Lifeline TM Model Version 2.0 and Dietary Exposure Evaluation Model software with the Food Commodity Intake Database (DEEM-FCIDTM, Version 1.33). DEEM incorporates consumption data from USDA’s Continuing Surveys of Food Intakes by Individuals (CSFII), 1994-1996 and 1998. Lifeline TM uses food consumption data from the United States Department of Agriculture’s (USDA’s) Continuing Surveys of Food Intakes by Individuals (CSFII) from 1994-1996 and 1998. LifelineTM uses recipe files contained within th e program to relate raw agricultural commodities (RACs) to foods “as-eaten.” LifelineTM conve rts the RAC residues into food residues by randomly selecting a RAC residue value from the “user defined” residue distribution (created from the residue, percent crop treated, and processing factors data), and calculating a net residue for that food based on the ingredients’ mass contribution to that food item.

LifelineTM models the individual’s dietary exposures over a season by selecting a new CSFII diary each day from a set of similar individuals based on age and season attributes. LifelineTM groups CSFII diaries based on the respondent’s age and the season during which the food diary was recorded. Based on analysis of the 1994-96, and 1998 CSFII consumption data, which took into account dietary patterns and survey respondents, the Agency concluded that it is most appropriate to report risk for the following population subgroups: the general U.S. population, all infants (<1 year old), children 1-2, children 3-5, children 6-12, youths 13-19, adults 20-49, females 13-49, and adults 50+ years old. The most highly exposed population subgroup for 2,4-D using both DEEM and Lifeline was children 1-2 years of age.

The acute dietary assessment was only slightly refined as the following assumptions were made: tolerance-level exposure values for most commodities, the highest field trial residue value for citrus commodities, and 100% crop treated (%CT). Note that half of the average level of detection (LOD) from the United States Department of Ag riculture (USDA) Pesticide Data Program (PDP) monitoring data was used as the milk residue value because no milk sample contained detectable 2,4- D residues over several years of PDP sampling.Page 24 of 304 The chronic dietary assessment was moderately refined, making use of the following assumptions: tolerance-level exposure values for most commodities; averages of field trial data and processing study factors for small grains, citrus, and sugarcane sugar and molasses; %CT information for all commodities; and the MCL (70 ppb) as well as the highest observed groundwater monitoring concentration (15 ppb) for drinking water in a forward calculation. As in the case of the acute assessment, half of the average LOD from PDP monitoring data was used for milk.

b. Population Adjusted Dose

A population adjusted dose, or PAD, is the refe rence dose (RfD) adjusted for the FQPA safety
factor. A risk estimate that is less than 100% of the acute PAD (aPAD), the dose at which an individual could be exposed over the course of a single day and no adverse health effects would be expected, does not exceed EPA’s level of concern. Likewise, a risk estimate that is less than 100% of the chronic PAD (cPAD), the dose at which an individual could be exposed over the course of a

lifetime and no adverse health effects would be expected, does not exceed EPA’s level of concern.

In the case of 2,4-D , the FQPA SF has been remove d (equivalent to a factor of 1x), so the acute or chronic RfD is identical to the respective aPAD or cPAD. In addition, an uncertainty factor is determined for each chemical. In the acute and chronic dietary risk assessments for 2,4-D, the total uncertainty factor (UF) is 1000x; 10x for interspeci es variability, 10x for intraspecies variability, and 10x for database uncertainty.

c. Food Risk Estimates

Acute: Risk to the general U.S. population was 18% and 17% of the aPAD using both DEEM and Lifeline, respectively. The most highly exposed population subgroup using both DEEM and Lifeline was children 1-2 years of age; risks were 33% and 32% of the aPAD, respectively. Risk to females 13-49 years of age was 31% of the aPAD using DEEM and 42% of the aPAD using Lifeline; these higher calculated risks for women of child-bearing age are due to the 2.7x lower toxicological point of departure for developmental effects applic able to Females 13-49 years of age. These acute dietary (food) risks are all less than the Agen cy’s level of concern (100% of the aPAD).

Chronic: Risk to the general U.S. population was 4.1% and 3.8% of the cPAD, using DEEM and Lifeline, respectively. Risk to children 1-2 years of age, the most highly exposed population subgroup, was 8.5% of the cPAD using DEEM and Lifeline.

3. Dietary Exposure and Risk from Drinking Water

Drinking water exposure to pesticides can occur through surface and ground water contamination. EPA considers acute (one day) and chronic (lifetime) drinking water risks and uses either modeling or monitoring data, if available and of sufficient quality, to estimate those exposures. In assessing drinking water risks, EPA compares model results to concentrations that would be acceptable in drinking water from a human health perspective (e.g., DWLOCs). If the estimated drinking water concentrations (EDWCs) in water are less than the DWLOCs, EPA does not havePage 25 of 304 concern from consuming drinking water. If the EDWCs are greater than DWLOCs, EPA will conduct further analysis to characterize the potentia l dietary risk from drinking water. Risks from exposure to 2,4-D in drinking water are further discussed in the section III.A.5.

2,4-D is an herbicide used in a wide variety of environments. As the major route of degradation is aerobic microbial metabolism, 2,4-D is non-persistent (t 1/2 =6.2 days) in terrestrial (aerobic) environments, moderately persistent (t 1/2 =45 days) in aerobic aquatic environments, and highly persistent (t 1/2 = 231 days) in anaerobic terrestrial and aquatic environments. Because 2,4-D will be anionic (X-COO

- H + ) under most environmental conditions, it is expected to be mobile (K

oc =61.7) in soil and aquatic environments.

The 2,4-D degradates detected in the various laboratory environmental fate studies were 1,2,4- benzenetriol, 2,4-dichlorophenol (2,4-DCP), 2,4- dichloroanisole (2,4-DCA), 4-chlorophenol, chlorohydroquinone (CHQ), volatile organics, bound residues, and carbon dioxide. The Agency has determined that residues other than 2,4-D are not of risk concern due to low occurrence under environmental conditions, comparatively low toxicity, or a combination thereof.

Estimated Environmental Concentrations (EEC) were derived through an evaluation of monitoring data and modeling. A number of different scenarios were assessed and EECs provided for each. Scenarios evaluated included the direct application of 2,4-D to water bodies for aquatic weed control, a rice use scenario, and terrestrial uses including food and nonfood uses.

a. Surface Water

Modeling: The Tier II screening models, Pesticide Root Zone Model and Exposure AnalysisModeling System (PRZM-EXAMS),with the Index Reservoir and Percent Crop Area adjustment (IRPCA PRZM/EXAMS) were used to estimate 2,4-D residues in surface water used for drinking water.

The Index Reservoir represents a watershed that is more vulnerable than most watersheds used as drinking water sources. It was developed from a watershed in western Illinois that has been used for drinking water purposes. The Index Reservoir is used as a standard watershed that, in combination with local soils types, weather conditions, and cropping practices, represents a vulnerable watershed that could support a drinking water supply.

For terrestrial uses of 2,4-D, EECs were calculated from aquatic exposure modeling using PRZM/EXAMS with the Index Reservoir and a percen t crop area treated (PCA) adjustment (Tier II). Fifteen scenarios were chosen for aquatic exposure modeling, including sugarcane in Florida; turf in Florida and Pennsylvania; spring wheat in North Dakota; winter wheat in Oregon; corn in Illinois and California; sorghum in Kansas and Texas; soybean in Mississippi; pasture in North Carolina; apples in North Carolina, Oregon, and Pennsylvania; and filberts in Oregon. Although this only represents a portion of the crops for which 2,4-D has a labeled use, it does represent crops with higher application rates and crops which have a large percentage of their total acreage treated with 2,4-D.

Surface water concentrations were modeled using PRZM version 3.12 and EXAMS versionPage 26 of 304 2.98.04. Ground water concentrations were modeled using SCIGROW version 2.2. The 15 crop scenarios listed above were modeled using PRZM/EXAMS. Based on the maximum modeledvalues, (more specifically, the North Carolina apple model scenario), the model-estimated, surfacewater-derived drinking water concentrations for the use of 2,4-D are:

118 ug/L for the 1 in 10 year annual peak concentration (acute) 64 ug/L for the 1 in 10 year 90-day average 23 ug/L for the 1 in 10 year annual mean concentration (chronic)

Monitoring : Monitoring data considered in the assessment were the United States Geological Survey’s (USGS) National Water Quality Asse ssment Program (NAWQA) groundwater and surface water database, USGS/EPA reservoir monitoring database, National Drinking Water Contaminant Occurrence Database (NCOD), and US EPA’s Storage and Retrieval environmental data system (STORET). Review of these databases was conducte d to provide peak and median concentrations. Additionally, the quality of data was evaluated for targeting pesticide use areas, detection limits, and analytical recoveries. The monitoring data indicate that 2,4-D is detected in groundwater and surface water. Also, 2,4-D is detected in finished drinking water. Maximum concentrations of 2,4-D in surface source water and ambient groundwater are 58 ug/L and 14.8 ug/L, respectively. The highest median 2,4-D concentration of 1.18 ug/L was derived from finished water samples in the NCOD database. The highest time weighted annual mean (TWAM) concentration was 1.45 ug/L from the NAWQA database containing nontargeted data reflecting pesticide concentrations in flowing water as opposed to more stationary bodies of water such as ponds, lakes, and reservoirs.

The PRZM/EXAMS surface water-derived drinking water model estimate that would be appropriate for acute exposure (118 ug/L) is approximately two times the peak concentration of 58 ug/L detected in the surface water monitoring data ev aluated as part of this assessment. However, since 70 ug/l is the current maximum contaminant level (MCL) established under the Safe Drinking Water Act, and is the label-prescribed 2,4-D concentration in treated water to be used for drinking water, this MCL limit is a reasonable and practical value to be used for the surface water concentration of 2,4-D for acute risk assessment purposes.

Note that the peak surface water concentration of 58 ug/L is consistent with the 70-ppb label instruction (also the MCL). Although the surface wa ter monitoring was not specifically targeted to known 2,4-D- treated sites or even areas of high 2,4-D usage, this agreement suggests that, from a practical standpoint, the MCL is a reasonable regulatory limit.

Although of high quality, the available monitoring data is not targeted to 2,4-D use. However, the data provide context to model results and indicat e that there is little evidence that concentrations are likely to be found exceeding these levels.

b. Ground Water

Monitoring : The maximum 2,4-D concentration detected in ground water is 14.89 ug/L based on the USGS NAWQA program and 8 ug/L based on the NCOD monitoring data. The next highestPage 27 of 304 concentration detected in the NAWQA groundwater data is 4.54 ug/L which is consistent with the NCOD-reported concentration. Therefore, the Agency is using 15 ug/L based on monitoring for the groundwater EDWC.

c. EDWCs Selected for Risk Assessment

The EDWCs for 2,4-D in surface and ground water are listed in Table 8 below. The EDWCs were selected from both modeling calculations and monitoring data.

Table 8. Surface and Ground Water Estimated Drinking Water Concentrations (EDWCs)

Drinking Water Source Duration EDWC (ppb) (ppb = ug/liter) Data Source

Surface Water Acute (Peak) 70 ug/liter (aquatic applications) Maximum Contaminant Level (MCL)

118 ug/liter (terrestrial applications) Modeling - PRZMEXAMS (NC apple scenario)

Short and Intermediate 70 ug/liter (aquatic applications) Maximum Contaminant Level (MCL)

64 ug/liter (terrestrial applications) Modeling - PRZMEXAMS (NC apple 1 in 10 year annual average)

Chronic 11 ug/liter (aquatic application) Modeling - Dissipation modeling of aquatic application

23 ug/liter (terrestrial application) Modeling - PRZMEXAMS worst case terrestrial use (NC apple scenario)

1.5 ug/liter (terrestrial application) Monitoring - Maximum time weighted annual mean from NAWQA

database

Ground Water All Duration 15 ug/liter Monitoring - Highest

monitored value from

NAWQA database

4. Residential and Other Non-occupational Exposure

Residential exposure assessment considers all potential pesticide exposure, other than exposure due to residues in foods or in drinking water. Exposure may occur during and after application on lawns and turf, golf courses, parks, cemeteries, and other grass areas. Exposure may also occur to recreational swimmers while swimming in waters tr eated with 2,4-D for aquatic weeds. Each routePage 28 of 304 of exposure (oral, dermal, inhalation) is assessed, where appropriate, and risk is expressed as a Margin of Exposure (MOE), which is the ratio of estimated exposure to an appropriate NOAEL. 2,4- D products are marketed for homeowner use on residential lawns and turf. 2,4-D containing products are also marketed for use by professional applicat ors on residential turf, golf courses, and on other turf such as recreational or commercial areas. Based on these uses, 2,4-D has been assessed for the residential mixing/loading/applicator (or “handler”) exposure for applications by homeowners to home lawns. For post-application exposure, 2,4-D has been assessed for toddlers playing on treated turf, adults performing yardwork on treated turf, a dults playing golf on treated turf, and children and adults swimming in bodies of water treated with 2,4-D for aquatic weed control.

a. Toxicity

The toxicological endpoints, and associated uncertainty factors used for assessing the nondietary risks for 2,4-D are listed in Table 9.

In a dermal absorption study utilizing human volunteers, excretion following dermal application was 5.8 ± 2.4% and after i.v. administration was 100 ± 2.5%. In previous risk assessments, the Agency selected a dermal absorption factor of 5.8 percent based on the human dermal absorption study. Based on comments received during the Phase 5 comment period, this dermal absorption study and factor were reconsidered. In order to account for the variability observed in the dermal absorption study, the dermal absorption factor was changed from 5.8 percent to 10 percent. In their “Re-evaluation of the Lawn and Turf Uses of 2,4- D,” which was made available to the public, Health Canada also selected a factor of 10 percent base d upon the weight of evidence from several published studies, taking into account the variability in the data and the limitations of the various studies. These studies include the Feldman and Maibach study discussed above and studies from Harris and Solomon 1992, Moody et. al. 1990, Wester et. al. 1996, and Pelletier et al. 1988.

Chronic endpoints were not used in the residential assessment because chronic occupational and residential exposures to 2,4-D are not expected to occur. Per the 2,4-D Master Label, the maximum label frequency for application of 2,4-D to turf is two times per year. 2,4-D also rapidly dissipates from foliage and is readily excreted from the human body.

A MOE greater than or equal to 1000 is considered adequately protective for the residential exposure assessment. The MOE of 1000 includes 10x for interspecies extrapolation, 10x for intraspecies variation, and 10x for a database uncertainty factor. Table 9 lists the toxicity endpoints selected for assessing residential risk for 2,4-D.

Table 9. Toxicity Endpoints Selected for Assessing Residential Risk for 2,4-D

Exposure

Scenario Dose Used in Risk Assessment, UF Level of Concern for

Risk Assessment Study and Toxicological Effects

Occupational and Resident ial Non-Dietary ExposuresExposure

Scenario Dose Used in Risk Assessment, UF Level of Concern for

Risk Assessment Study and Toxicological Effects

Page 29 of 304 Short-Term Incidental Oral (1-30 days) MRID 00130407,

00130408 NOAEL= 25 mg/kg/day

UF DB = 10 Residential LOC for

MOE =1000

Occupational = NA rat developmental toxicity study LOAEL = 75 mg/kg/day based on decreased maternal body-weight gain

Intermediate-Term Incidental Oral (1- 6 months)

MRID 41991501 NOAEL = 15 mg/kg/day Residential LOC for

MOE = 1000

Occupational = NA subchronic oral toxicity - rat LOAEL = 100 mg/kg/day based on decreased body weight/body-weight gain, alterations in some hematology, and clinical chemistry parameters, and

cataract formation.

Short-Term Dermal* MRID 00130407,

00130408 Oral study NOAEL= 25 mg/kg/day Residential LOC for

MOE

= 1000

Occupational LOC for

MOE = 100 rat developmental toxicity study LOAEL = 75 mg/kg/day based on decreased maternal body-weight gain and

skeletal abnormalities

Intermediate-Term

Dermal* MRID 00130407,

00130408 Oral study NOAEL = 15 mg/kg/day subchronic oral toxicity - rat (same as for incidental oral)

Long-Term Dermal*

MRID 43612001 Oral study NOAEL= 5 mg/kg/day rat chronic toxicity study (same as for chronic dietary)

Short-Term Inhalation* MRID 00130407,

00130408 Oral study NOAEL= 25 mg/kg/day rat developmental toxicity study (same as for short-term dermal)

Intermediate-Term

Inhalation* MRID 00130407,

00130408 Oral study NOAEL = 15 mg/kg/day subchronic oral toxicity - rat (same as incidental oral)

Long-Term Inhalation*

MRID 43612001 Oral study NOAEL= 5 mg/kg/day rat chronic toxicity study (same as for chronic dietary)

Cancer Classification : Group D [not classifiable as to human carcinogenicity]

*The dermal absorption factor is 10 percent and the inhalation absorption factor is 100 percent.

UF = uncertainty factor, FQPA SF = Special FQPA safety f actor, NOAEL = no observed adverse effect level, LOAEL = lowest observed adverse effect level, PAD = popula tion adjusted dose (a = acute, c = chronic) , RfD = reference dose, MOE = margin of exposure, LOC = level of concern, NA = Not Applicable

b. Residential Handler

1) Exposure Scenarios, Data, and Assumptions

Homeowners (or others) may be exposed to 2,4-D while treating their lawns. All homeowneruse products are available in liquid or granular form. 2,4-D is applied using hose-end sprayers, pump sprayers, ready-to-use sprayers, broadcast spreaders, bellygrinders, and hand application, either

before or after seasonal weed emergence, at a rate up to 1.5 lbs ae/A. A number of assumptions, orPage 30 of 304 estimates, such as adult body weight and area treated per application, are made by the Agency for residential risk assessment. Also, note that residential handlers are addressed somewhat differently than occupational handlers in that homeowners are assumed to complete all elements of an application (mix/load/apply) without use of personal protective equipment (assessments are based on an assumption that individuals will be wearing short pants and short-sleeved shirts).

The quantitative exposure/risk assessment developed for residential handlers is based on these

scenarios: 1) Hand application of granules 2) Belly grinder application 3) Load/apply granules with a broadcast spreader 4) Mix/load/apply with a hose-end sprayer (mix your own) 5) Mix/load/apply with a hose-end sprayer (ready-to-use) 6) Mix/load/apply with hand held pump sprayer 7) Mix/load/apply with ready-to-use sprayer

Exposure estimates for these scenarios are taken from the Pesticide Handlers Exposure Database (PHED, Version 1.1 August 1998) which is used to assess handler exposures when chemical-specific monitoring data are not available. In addition to PHED data, the residential risk assessment relies on data from the Outdoor Residential Exposure Task Force (ORETF) and proprietary studies. Three turf transferable residue studies submitted by the Broadleaf Turf Herbicide Turf Transferable Residue (TTR) Task Force. These studies measured the dissipation of several phenoxy herbicides, including 2,4-D, using the ORETF roller technique. Scenarios #1 through #5 use ORETF or PHED data; scenarios #6 and #7 use exposure data from the Carbaryl Mixer/Loader/Applicator Exposure Study (EPA MRID 444598-01).

The results of a biomonitoring study (Harris and Solomon 1992) were also used to calculate dermal MOEs for post application exposure on turf. The study was conducted with adult volunteers who were exposed to 2,4-D while performing controlled activities for one hour on turf treated with 2,4-D. The controlled activities were conducted at 1 hour after treatment (HAT) and at 24 HAT. Ten volunteers participated in the study. Five volunteers wore long pants, a tee shirt, socks and closed

footwear. The other five wore shorts and a tee sh irt and were barefoot. The volunteers walked on the turf for a period of 5 minutes and then sat or lay on the area for 5 minutes and then continued in this

fashion for 50 more minutes. Each volunteer coll ected all urine for the next 96 hours immediately following the exposure. The MOEs for the DAT 1 volunteers who wore shorts and no shoes ranged from 1000 to 26000 with the lowest MOE corresponding to a volunteer who removed his shirt during the exposure period. The MOEs for the remaining volunteers ranged from 17000 to 27000.

For more information, see “2,4-D. HED’s Revised Human Health Risk Assessment for the Reregistration Eligibility Decision (RED) Revised to Reflect Public Comments. PC Code 030001; DP Barcode D316597" dated May 12, 2005, and the “2,4-D: 3 rd Revised Occupational and Residential Exposure and Risk Assessment and Response to Public Comments for the Registration Eligibility Decision (RED) Document” dated May 4, 2005.Page 31 of 304 Assumptions Regarding Residential Handlers

• Clothing would consist of a short-sleeved shirt, short pants and no gloves. • Broadcast spreaders and hose end sprayers would be used for broadcast treatments and the other application methods would be used for spot treatments only.

C An area of 0.023 acre (1000 square feet) would be treated per application during spot treatments and an area of 0.5 acre would be treated during broadcast applications.

C The application rate is 1.5 lb ae/acre representing the most recent revision to the master label.

C Average body weight of an adult handler is 70 kg.

C The duration of exposure is expected to be short-term (1-30 days) for residential handlers of 2,4-D. Intermediate- and long-term exposures of residential applicators are not anticipated based on 2,4-D’s residential use pattern.

2) Residential Handler Risk Estimates

Based on toxicological criteria and potential for exposure, the Agency has conducted both a dermal and an inhalation exposure assessment. Risk assessment for short-term inhalation exposure is based on a rat developmental study. An assumption is made that 100% of the estimated inhalation dose will be absorbed. A dermal absorption factor of 10 percent was selected for converting dermal exposures to oral equivalent doses. An MOE greater than or equal to 1000 (10x for interspecies extrapolation, 10x for intraspecies variation, and 10x for database uncertainty) is considered adequately protective for this assessment. Since all residential handler MOEs are greater than 1000, risk to residential handlers is not of concern. The 2,4-D risk estimates are presented in Table 10

below.

In preliminary versions of the risk assessment, when considered alone, acute and short-term residential risks posed by the use of 2,4-D were not of concern to the Agency; however, when considered as part of an aggregate exposure with food and drinking water, exposures did exceed the Agency’s level of concern. As a result, 2,4-D registrants agreed to reduce the maximum application rate to turf and residential lawns from 2.0 lbs ae/A to 1.5 lbs ae/A. The revised application rate (1.5 lbs ae/A) was used in the current risk assessment.

Table 10. 2,4-D Short Term Risk Estimates for Residential Handlers

Scenario Application Rate (lbs ae/acre) Treated Area (acres/day) MOE

1. Hand Application of Granules 1.5 0.023 3,700

2. Belly Grinder Application 1.5 0.023 3,900

3. Load/Apply Granules with a Broadcast Spreader 1.5 0.5 29,000

4. Mix/Load/Apply with a Hose-end Sprayer (Mix your own) 1.5 0.5 1,800

5. Mix/Load/Apply with a Hose-end Sprayer (Ready to Use) 1.5 0.5 7,400

6. Mix/Load/Apply with Hand Held Pump Sprayer 1.5 0.023 11,000Scenario Application Rate (lbs ae/acre) Treated Area (acres/day) MOE

Page 32 of 304 7. Mix/Load/Apply with Ready to Use Sprayer 1.5 0.023 7,900

Note: 1000 square feet equals 0.023 acres

For more information, see Appendix F of “2,4-D: 3 rd Revised Occupational and Residential Exposure and Risk Assessment and Response to Public Comments for the Reregistration Eligibility Decision (RED) Document (PC Code 030001, DP Barcode D316596)” dated May 4, 2005.

c. Residential Postapplication Risk

1) Exposure Scenarios, Data, and Assumptions

2,4-D uses in the residential setting include applications to home lawns. The following scenarios were assessed for residential post application risks:

1) Toddlers playing on treated turf 2) Adults performing yardwork on treated turf 3) Adults playing golf on treated turf

These scenarios chosen for risk assessment represent what the Agency considers the likely upper-end estimates of possible exposure. An MOE of 1000 (or more) is considered protective for

this assessment.

Assumptions Regarding Residential Postapplication Risk

• An assumed initial turf transferable residue (TTR ) value of 5.0% of the application rate is used for assessing hand to mouth exposures. • An assumed initial TTR value of 20% of the application is used for assessing object to mouth

exposures. • Soil residues are contained in the top centimeter and soil density (i.e., the ratio of the mass of dry solids to the bulk volume of the soil occupied by those dry solids) is 0.67 gram/mL. • Three year old toddlers are expected to weigh 15 kg. • Hand-to-mouth exposures are based on a frequency of 20 events/hour and a surface area per

event of 20 cm 2 representing the palmar surfaces of three fingers. • Saliva extraction efficiency is 50 percent. Every time the hand goes in the mouth approximately half of the residues on the hand are removed. • Adults are assessed using a transfer coefficient of 14,500 cm 2 /hour. • Toddlers are assessed using a transfer coefficient of 5,200 cm 2 /hour. • Golfers are assessed using a transfer coefficient of 500 cm 2 /hour. • An exposure duration of 2 hours per day is assumed for toddlers playing on turf or adults performing heavy yardwork.Page 33 of 304 The following assumptions that are specific to 2,4-D are used for assessing residential post application exposures.

C The master label application rate of 1.5 lbs ae/acre was used.

C The exposure following the application of granular formulations was not assessed because there were no TTR data submitted for granular formulations. It was assumed this exposure would be less than or equal to the exposure from liquid formulations.

Other residential exposure standard operating procedures (SOPs) may be viewed at the following website: http://www.epa.gov/oscpmont/sap/1997/september/sopindex.htm

.

Calculation Method for Postapplication Exposure for Toddlers on Treated Turf

MOEs were calculated for acute toddler exposures using the maximum TTR value along with the acute dietary NOAEL of 67 mg/kg/day. This NOAEL was adapted to acute dermal exposures by using the dermal absorption factor of 10 percent to account for route to route extrapolation. The MOEs for toddler short term exposures were calculated using the seven day average TTR value because the short term NOAEL was based upon decreased body weight gain which occurred after several days of exposure. MOEs for acute and adult short term exposures were calculated using the maximum TTR value because the acute and short term NOAELs are the same and are based upon the developmental effects which could have occurred following one day of exposure.

The quantitative exposure/risk assessment for postapplication risk to children is based on these

scenarios:

1) Dermal activity from treated turf: Postapplication exposure to children from the dermal exposure of pesticide residues from activity on treated turf. 2) Hand-to-mouth activity from treated turf: Postapplication exposure to children from the “incidental” ingestion of pesticide residues on treated turf from hand-to-mouth transfer (i.e., those residues that end up in the mouth from children touching turf and then putting their hands in their mouths). 3) Object-to-mouth activity from treated turf: Postapplication exposure to children from incidental ingestion of pesticide residues on treated turf from object-to-mouth transfer (i.e., those residues that end up in the mouth from a child mouthing a handful of treated turf). 4) Soil ingestion activity: Postapplication exposure to children from incidental ingestion of

soil in a treated area.

For more information on formulas used for calculating occupational and residential exposures to 2,4-D, see Appendix A of “2,4-D: 3 rd Revised Occupational and Residential Exposure and Risk Assessment and Response to Public Comments fo r the Reregistration Eligibility Decision (RED) Document” dated May 4, 2005.

2) Postapplication Risk EstimatesPage 34 of 304 Risk assessment for children’s postapplication exposure is based on a NOAEL of 67 mg/kg/day from an oral study of acute neurotoxicity study in rats. A Margin of Exposure (MOE) of 1000 (10x for interspecies extrapolation, 10x for intraspecies variation, and 10x for database uncertainty) isconsidered adequately protective for this assessment. Table 11 below presents the MOEs for PostApplication Exposure in Children. Since all MOEs meet or exceed 1000, postapplication exposure to

children is not of concern.

Table 11. Children Post-Application Exposure to Turf Treated with 2,4-D

Application Rate (lbs ae/acre) Dermal

MOE Hand-to Mouth

MOE Object to

Mouth MOE Soil Ingestion

MOE Total

MOE

Acute Toddler Risks Using the Maximum TTR (North Carolina Trial 1 using 2,4-D DMA)

DAT 0 1.5 1,900 3000 12,000 >100,000 1,100

Short Term Toddlers Risks Using California TTR Data (DMA Mix, No Rain)

DAT 0 to

DAT 6 1.5 3,900 2,100 8,500 >100,000 1,200

Short Term Toddler Risks Using North Carolina TTR Data from Trial 1 (DMA and DMA Mix, No Rain)

DAT 0 to

DAT 6 1.5 5,100 4,400 18,000 >100000 2,100

Short Term Toddler Risks Using North Carolina TTR Data from Trial 2 (DMA Mix, Some Rain)

DAT 0 to

DAT 6 1.5 12,000 7,000 28,000 >100000 3,900

The acute NOAEL is 67 mg/kg/day for neurotoxic effects observed in the acute neurotoxicity study. The short term NOAEL is 25 mg/kg/day for matern al effects observed in the developmental study.

Table 12 below lists the adult acute/short term MO Es for exposure to turf treated with 2,4-D. The acute/short term NOAEL is 25 mg/kg/day from the rat developmental toxicity study. The LOAEL was 75 mg/kg/day based on skeletal abnormalities from a developmental toxicity study in rats. All MOEs meet or exceed 1000, so postappli cation exposure to adults is not of concern.

Table 12. Adult Acute/Short Term MOEs for Exposure to Turf Treated with 2,4-D

Exposure Scenario Application Rate (lbs ae/acre) TTR (ug/cm 2 ) Acute/Short Term Dermal MOE 1 on Day 0

Heavy Yardwork

Playing Golf 1.5 0.50 1000

15000

1. The acute/short term NOAEL is 25 mg/kg/day for deve lopmental effects observed in the developmental study.

d. Recreational Swimmer RiskPage 35 of 304 1) Exposure Scenarios, Data, and Assumptions

The master label indicates that 2,4-D can be us ed for aquatic weed c ontrol of surface weeds such as water hyacinth and submersed weeds such as Eurasian milfoil. Su rface weeds are controlled by foliar applications at a maximum rate of 4.0 lb ae/acre. Submersed weeds are controlled by subsurface injection of liquids to achieve a target concentration of 2 to 4 ppm in the water column surrounding the weeds. This requires 5.4 to 10.8 lb ae per acre foot of water depth (e.g., 5.4 lbs ae would be required to achieve 2 ppm in a one acre pond that has an average depth of 1 foot). Granular formulations of BEE (Aquakleen and Navigate) are also used to control submersed weeds. The granular formulations resist rapid decomposition in water and release the herbicide into the root zone.

Although many herbicide treatments are applied to aquatic areas where recreational swimming is not likely to occur, some of the subsurface tr eatments are made at recreational lakes. These

treatments are made because the Eurasian milfoil in terferes with recreation and other activities. This problem is particularly prevalent in the northern states such as Minnesota and Washington and in the New England region.

The following exposure scenarios are assessed for recreational swimmers:

1) Adult Recreational Swimmer 2) Child Recreational Swimmer

Assumptions Regarding Recreational Swimmer Risk

The following assumptions were used for the a ssessment of swimmer risks. Many of these assumptions were taken from the Residential SOPs and are also used in the SWIMODEL.

C The skin surface area of adults is assumed to be 21,000 cm 2 (Residential SOPs). This is

the 95 th percentile value for females (EPA Exposure Factors Handbook, 1997).

C The body weight for children is assumed to be 22 kg as cited in the Residential SOPs. This is a mean value for 6 year old children.

C The skin surface area for children is assumed to be 9,000 cm 2 as cited in the Residential

SOPs. This is the 90 th percentile value for male and female children.

C The assumed mean ingestion rate is 0.05 liters per hour for both adults and children as cited in the Residential SOP. This value may be greater for young children playing in water and accidentally ingesting a remarkable quantity of water (U.S. EPA SAP, 1999).

C The exposure time is assumed to be 3 hours per day. This is the 90 th

percentile value for time spent swimming in a freshwater pool (EPA Child Specific Exposure Factors Handbook, 2002).

C The body weight for female adult acute exposures is assumed to be 60 kg.

C The body weight for male adult acute exposures is assumed to be 70 kg.

C The body weight for adult short term exposure is assumed to be 60 kg because the endpoint is gender specific.

C Risks were not calculated for foliar treatments because the application rate of 2.0 lb ae/acre would result in water concentration of only 0.25 ppm in a three foot water columnPage 36 of 304 even if all of the spray were to run off the leaves into the water.

Calculation Method for Recreational Swimmer Exposure

The Agency used the Swimmer Exposure Assessment Model (SWIMODEL) to calculate exposures to swimmers in water treated with 2,4-D for aquatic weed control. The SWIMODEL estimates exposure for up to six exposure routes (i .e., oral ingestion, dermal absorption, inhalation, buccal/sublingual, nasal/orbital, and aural routes), or calculates exposure as a function of any one of the three major exposure routes (i.e., oral ingesti on, dermal absorption, or inhalation). Other factors used in the SWIMODEL formulae for dermal and ingestion exposure which are described in Appendix A of “2,4-D: 3 rd Revised Occupational and Residential Exposure and Risk Assessment and Response to Public Comments for the Reregistra tion Eligibility Decision (RED) Document” dated May 4, 2005.

The SWIMODEL formulas for the other dermal pathways (aural, buccal/sublingual and orbital/nasal) were not used in the 2,4-D human h ealth risk assessment because these formulas are based upon recreational swimmers in swimming pools w ho swim with their heads partially immersed. It is anticipated that recreational swimmers in w eed infested areas would be less likely to swim with

their heads immersed than recreational swimmers in weed- free swimming pools. In addition, the formulas for the buccal/sublingual and orbital/nasal pathways contain a default absorption factor of 0.01 which is based upon the absorption of nitroglycerin. This factor would greatly overestimate the risk of 2,4-D exposure because 2,4-D is absorbed at a much lower rate.

Because the 2,4-D water concentrations can vary depending upon the application rate and site conditions the Maximum Swimming Water Concentration (MSWC) was calculated. The MSWC is the water concentration at which the combined dermal and ingestion MOE meets or exceeds the target MOE of 1000. The MSWCs were calculated for children’s acute exposures using the acute NOAEL of 67 mg/kg/day and the MSWCs for children’s short term exposures were calculated using the short term NOAEL of 25 mg/kg/day for maternal effects. The MSWCs for adult acute/short term exposures were calculated using a NOAEL of 25 mg/ kg/day that is based upon developmental effects which could have occurred following one day of exposure.

2) Recreational Swimmer Risk Estimates

The MSWCs are summarized in Table 13 and the detailed calculations are included in Appendix H of the 3 rd Revised Occupational and Residential Exposure Assessment for 2,4-D. The acute MSWCs range from 1.2 ppm for 2,4-D BEE to 9.8 ppm for 2,4-D acid while the short term MSWCs range from 0.9 ppm for 2,4-D BEE to 3.6 ppm for 2,4-D acid or amine. The MSWCs for 2,4-D BEE are lower because based on its chemical properties, 2,4-D BEE is expected to have a much higher dermal absorption value.Page 37 of 304 Table 13. Maximum Swimming Water Concentrations for 2,4-D Aquatic Applications

Exposure Duration NOAEL (mg/kg/day) 2,4-D Form 2,4-D MSWC* (ppm) Dermal

MOE Ingestion

MOE Combined

MOE

Adults

Acute/Short Term 25 Acid or Amine 9.8 97000 1000 1000

25 BEE 1.2 1200 8300 1000

Children

Acute 67 Acid or Amine 9.8 425000 1000 1000

Acute 67 BEE 2.4 1300 4100 1000

Short Term 25 Acid or Amine 3.6 230000 1000 1000

Short Term 25 BEE 0.90 1300 4100 1000

* The MSWC is the concentration below which the combined MOE would be above 1000 and the risks would not be of

concern.

The Acute MSWC of 9.8 ppm for exposures to 2,4-D acid or amine is greater than the master label application rate of 4.0 ppm, therefore, acute exposures to 2,4-D acid or amine are not of concern. The MSWC of 3.6 ppm for short-term exposures to 2,4-D acid or amine is also not of concern because some dissipation or dispersion is likely to occur which would cause the 7-day average of 2,4-D concentrations to be less than 3.6 ppm. Dissipation studies submitted to EFED indicated that the half lives following pond and lake liquid treatments ranged from 3.2 days to 27.8 days which yield 7 day average concentrations of 1.9 ppm when the half life equals 3.2 days to 3.6 ppm when the half life equals 27.8 days.

The MSWCs for 2,4-D BEE are less than the master label application rate of 4 ppm, but they are unlikely to be of concern for the following reasons:

C 2,4-D BEE degrades rapidly by abiotic hydrolysis in sterile water to form 2,4-D acid particularly when the pH is 7.5 or above.

C 2,4-D BEE degrades to 2,4-D acid by microbial hydrol ysis with an averag e half life of 2.6 +

1.8 hours at a bacterial concentration of 5 x 10 -8 organisms per liter. Therefore, degradation of 2,4-D BEE to 2,4-D under typical environmental conditions will be rapid leading to significantly lower risk estimates because the 2,4-D acid has a lower rate of dermal absorption.

C Modeling predicts direct water application of 2,4-D BEE will yield surface water concentrations of 2,4-D BEE concentrations in the Agency standard pond of 624 ug/L for peak (24 hour average), 30 ug/L for the 21-day average, and 10 ug/L for the 60-day average.

C The existing label rates for 2,4-D BEE products are also lower than the master label rate.Page 38 of 304 5. Aggregate Exposure and Risk

OPP has traditionally compared estimates of concentrations of a pesticide in drinking water to DWLOCs. A DWLOC is the portion of the acute PAD or chronic PAD remaining after estimated dietary (food only) exposures have been subtracted and the remaining exposure has been converted to a concentration (ug/L or ppb). This concentration value (DWLOC) represents the available or allowable exposure through drinking water. In an acute risk assessment, the remaining portion of the aPAD is based on dietary exposures at the percentile of exposure appropriate for a given risk assessment and depends on each relevant population subgroup considered. Estimated Drinking Water Concentrations (EDWCs) of 2,4-D in ground a nd surface water that are less than the DWLOCs do not exceed the Agency’s level of concern. DWLOC values vary for population subgroups depending on dietary exposure through foods for each subgroup, assumptions made about the volume of drinking water consumed, and default body weights for each subgroup.

More recently, OPP has adopted the forward calculation approach for the assessment of aggregate risks. In this approach, food, drinking water and residential exposures are aggregated and compared to an appropriate endpoint.

In the case of 2,4-D, the DWLOCs were calculated for comparison to the MCL established by the EPA Office of Water and aggregate risks were calculated using the forward calculation approach for comparison to the appropriate endpoint. The respective DWLOCs and aggregate risks are shown for acute, chronic and short term exposures in the following sections.

a. Acute Aggregate Risk Assessment

DWLOC Approach

Acute DWLOCs were calculated based upon acute dietary exposures. Acute residential exposures from swimming in treated water bodies or playing on treated turf were not included because exposures are unlikely to co-occur with acute dietary exposures. The acute DWLOCs are summarized in Table 14 and are 432 ppb or greater with the most sensitive population being females 13-49 years old. The EDWCs of 118 ug/liter for surface water and 15 ug/liter for groundwater are substantially less than the DWLOCs which means that the risks are not of concern.Page 39 of 304 Table 14. Acute DWLOC Calculations

Population Subgroup Body Weight (kg) Water Consumption

(liters/day) aPAD (mg/kg/day) Food Exp 1
(mg/kg/day) Max Water Exposure (mg/kg/day 2 ) DWLOC (μg/L) 3

General U.S. Population 70 2.0

0.067 0.0118 0.0552 1932

All Infants (< 1 year old) 10 1.0 0.0132 0.0538 538

Children 1-2 years old 10 1.0 0.0221 0.0449 449

Children 3-5 years

old 10 1.0 0.0206 0.0464 464

Children 6-12 years old 10 1.0 0.0147 0.0523 523

Females 13-49 years old 60 2.0 0.025 0.0106 0.0144 432

1. Food exposure values are the maximum of the acute DEEM or Lifeline values.

2 . Maximum water exposure (mg/kg/day) = [(acute PAD - food exposure)] 3. DWLOC (μg/L) = [maximum water exposur e x body weight] ÷ [water consumption x 10 -3 mg/μg].

Surface Water EDWC = 70 ug/liter (aquatic applica tions) or 118 ug/liter (terrestrial applications) Ground Water EDWC = 15 ug/liter

Forward Calculation Approach

Acute aggregate risks were assessed by aggregating acute food exposures and acute water exposures. The acute aggregate risks are presented in Table 15 and are not of concern because they are less than 100 percent of the aPAD. The highest risks (58 percent of the aPAD) are for females 13- 49 years old because these risks are based upon the lower NOAEL of 25 mg/kg/day.

Table 15. 2,4-D Aggregate Acute MOEs

Population Subgroup Body Weight

(kg) Water Consumption

(liters/day) Food Exposure 1
(mg/kg/day) Drinking

Water Exposure 2
(mg/kg/day) Aggregate Exposure 3
(mg/kg/day ) aPAD 4
(mg/kg/day ) Percent

aPAD 5

General U.S. Population 70 2.0 0.0118 0.00337 0.0152 0.067 23

Females 13-49 yrs old 60 2.0 0.0106 0.0039 0.015 0.025 58

Notes for Table X 1. Food exposure values are the maximum of the DEEM or Lifeline acute values. 2. Drinking Water Exposure = (E DWC * daily water consumption) / (1000 ug/mg * Body Weight ); where the EDWC = 118 ug/liter 3. Aggregate Exposure = Food Exposure + Drinking Water Exposure 4. aPAD = NOAEL/1000; where the NOAEL is 25 mg/kg/day for fe males 13-49 and 67 mg/kg/day fo r all other population subgroups 5. Percent aPAD = (Aggregate Exposure/aPAD) * 100Page 40 of 304 b. Chronic Aggregate Risk Assessment

DWLOC Approach

Chronic DWLOCs were calculated based upon chronic dietary exposures. As there are no chronic residential exposures, residential exposures were not included in the chronic DWLOC calculations. The chronic DWLOCs are summarized in Table 16 and are 46 ug/liter or greater with the most sensitive population being children. The EDWCs, which range from 1.5 to 23 ug/liter, are

less than the DWLOCs which means that the risks ar e not of concern. It should be noted that the master label indicates that potable water consumption from a treated water body cannot begin until the 2,4-D concentration is 70 ug/liter or below, therefore an annual average exposure at the MCL of 70 ug/liter would not occur because dissipation woul d reduce the initial concentration of 70 ug/liter to an annual average concentration of 11 ug/liter.

Table 16. Chronic DWLOC Calculations

Population Subgroup Body Weight

(kg) Water Consumption

(liters/day) cPAD (mg/kg/day) Food Exp 1
(mg/kg/day) Max Water Exposure (mg/kg/day) 2 DWLOC (μg/L) 3

General U.S. Population 70 2.0

0.005 0.00020 0.0048 168

All Infants (< 1 year old) 10 1.0 0.00016 0.00484 48

Children 1-2 years old 10 1.0 0.00042 0.00458 46

Children 3-5 years old 10 1.0 0.00037 0.00463 46

Children 6-12 years old 10 1.0 0.00026 0.00474 47

Youth 13-19 years old 60 2.0 0.00019 0.00481 144

Adults 20-49 years old 70 2.0 0.00019 0.00481 168

Adults 50+ years old 70 2.0 0.00018 0.00482 169

Females 13-49 years old 60 2.0 0.00020 0.0048 144

1. Food exposure values are the maximum of the DEEM or Lifeline chronic dietary values.

2. Maximum water exposure (mg/kg/day) = [(chronic PAD - food exposure)] 3. DWLOC (μg/liter) = [maximum water exposur e x body weight] ÷ [water consumption x 10 -3 mg/μg].

Surface Water EDWC (maximum time weighted annua l mean from the NAWQA database) = 1.5 ug/liter Surface Water EDWC (dissipation modeling of aquatic a pplication when 70 ppb occurs at time zero) = 11 ug/liter Surface Water EDWC (worst case terrestrial use PRZM-EXAMs run) = 23 ug/liter Ground Water EDWC (the highest monitored va lue from the NAWQA database) = 15 ug/liter

Forward Calculation Approach

Chronic aggregate risks were also assessed by aggregating chronic food exposures and chronic water exposures in a forward calculation approach. The chronic aggregate risks are presented as percent cPAD in Table 17 and are not of concern b ecause they are less than 100 percent of the cPAD. The highest risks (38 percent of the cPAD) are for children 1-2 years old.

Table 17. 2,4-D Aggregate Chronic RisksPage 41 of 304 Population Subgroup Body Weight

(kg) Water Consumption

(liters/day) Food Exposure 1
(mg/kg/day) Drinking

Water Exposure 2
(mg/kg/day) Aggregate Exposure 3
(mg/kg/day ) cPAD 4
(mg/kg/day ) Percent

cPAD 5

General U.S. Population 70 2.0 0.00020 0.00043 0.0006 0.005 13

Children 1-2 yrs old 10 1.0 0.00042 0.0015 0.002 0.005 38

1. Food exposure values are from Table X and are the maxi mum of the DEEM or Lifeline chronic dietary values. 2. Drinking Water Exposure = (EDW C * daily water consumption) / (1000 ug/mg * Body Weight ); where the EDWC = 15 ug/liter 3. Aggregate Exposure = Food Exposure + Drinking Water Exposure 4. cPAD = NOAEL of 5 mg/kg/day / 1000 5. Percent cPAD = (Aggregate Exposure/aPAD) * 100

c. Short-term Aggregate Risk Assessments

DWLOC Approach

Short-term aggregate risks assessments were conducted by calculating DWLOCs based upon short term turf exposures, chronic food exposures and short term endpoints. Short-term exposures from swimming in treated water bodies were not included because these exposures represent episodic scenarios that are unlikely to occur the same day as an acute dietary exposure. The short-term DWLOCs were calculated only for females 13-49 and children 1-6 because these population subgroups have the highest exposure and are protective of the other subgroups. The DWLOCS are listed in Table 18 and range from 24 to 54 ug/liter. These DWLOCs are all greater than the EDWCs, which range from 15 to 23 ug/liter, and indicate that short term risks are not of concern.

Table 18. Short-Term DWLOC Calculations for 2,4-D

Pop. Subgroup Body Weight

(kg) Water Consumption

(liters/day) NOAEL/UF (mg/kg/day) Turf Exposure (mg/kg/day) Food Exp 1
(mg/kg/day) Max Water Exposure (mg/kg/day) 2 DWLOC (μg/L) 3

Children 1-6 15 1.0 0.025 0.021 0.00042 0.00358 54

Females 13-

49 60 2.0 0.025 0.024 0.00020 0.00080 24

1. Food exposure values are the maximum of the DEEM or Lifeline chronic dietary values.

2 Maximum water exposure (mg/kg/day) = [(NOA EL/UF) - (Turf exposure + food exposure)] 3. DWLOC (μg/liter) = [maximum water exposur e x body weight] ÷ [water consumption x 10 -3 mg/μg].

Surface Water EDWC (worst case terrestrial use PRZM-EXAMs run) = 23 ug/liter Ground Water EDWC (based upon the highe st monitored value) = 15 ug/liter

Forward Calculation Approach

Short-term aggregate risks were also assessed by directly aggregating short-term turf exposures, chronic food exposures and chronic water exposures. Short-term aggregate risks were calculated only for females 13-49 and children 1-6 because these population subgroups have the highest exposure and are protective of the other subgroups. The short term aggregate MOEs are presented in Table 19 and

indicate that the short term risks are not of c oncern because the MOEs equal or exceed the target

MOE of 1000.Page 42 of 304 Table 19. 2,4-D Aggregate Short-Term MOEs Including Turf Exposures

Population Subgroup 1 Turf Application

Rate (lbs ae/acre) Chronic

Food Exposure 2
(mg/kg/day) Short-Term

Turf Exposure 3
(mg/kg/day) Chronic

EDWC 4
(ug/liter) Drinking

Water Exposure 5
(mg/kg/day) Aggregate Exposure 6
(mg/kg/day) Aggregate

MOE 7

Females 13 - 49 1.5 0.000195 0.024 15 0.00050 0.0247 1000

Children 1 - 6 1.5 0.000424 0.021 15 0.0010 0.0224 1100

Females 13 - 49 1.5 0.000195 0.024 23 0.00077 0.0250 1000

Children 1 - 6 1.5 0.000424 0.021 23 0.0015 0.0230 1100

1. Body weights are 60 kg (females) and 15 kg (children). Water consumption values are 2 liter/day (females) and 1.0 liter/da y (children). 2. The food exposure for females is from Lifeline. The food e xposure for children is from DEEM and is for 1-2 year old child ren 3. Female’s turf exposures are from the dermal route only. Ch ildren’s turf exposures are from the dermal and incidental oral routes. 4. EDWC is 15 ug/liter for ground wa ter and 23 ug/liter for surface water. 5. Drinking Water Exposure = (EDWC * daily wa ter consumption) / (1000 ug/mg * Body Weight ) 6. Aggregate Exposure = Turf Exposure + Food Exposure + Drinking Water Exposure 7. Aggregate MOE = NOAEL/Aggregate E xposure where the NOAEL is 25 mg/kg/day.

d. Cancer Aggregate Risk

2,4-D was classified as a Category D chemical, i.e., not classifiable as to human carcinogenicity, by the EPA/OPP Cancer Peer Review Committee in 1996. Thus, no aggregate

cancer assessment is warranted.

e. Aggregate Risk Characterization

The highest aggregate risks are the short term ri sks that include the turf exposure scenarios. For the most sensitive subpopulation (females 13-49), these risks just meet the target MOE of 1000 and the turf exposure is the risk driver as it contribut es 96 percent of the risk. It is important to note, however, that the turf exposure estimate is based upon modeling and is greater than exposure measurements obtained from biomonitoring. The results of a biomonitoring study (Harris and Solomon 1992) were also used to calculate dermal MOEs for post application exposure on turf. The study was conducted with adult volunteers who were exposed to 2,4-D while performing controlled activities for one hour on turf treated with 2,4-D. The controlled activities were conducted at 1 hour after treatment (HAT) and at 24 HAT. Ten volunteers participated in the study. Five volunteers wore long pants, a tee shirt, socks and closed footwear. The other five wore shorts and a tee shirt and were barefoot. The volunteers walked on the turf for a period of 5 minutes and then sat or lay on the area

for 5 minutes and then continued in this fashion for 50 more minutes. Each volunteer collected all urine for the next 96 hours immediately following the exposure. The MOEs for the DAT 1 volunteers who wore shorts and no shoes ranged from 1000 to 26000 with the lowest MOE corresponding to a volunteer who removed his shirt during the exposure period. The MOEs for the remaining volunteers ranged from 17000 to 27000. If the calculated MOE of 1000 is considered in conjunction with the biomonitoring results, it is clear that the short term risks are upper bound estimates and not likely to be of concern.Page 43 of 304 6. Occupational Risk

Workers can be exposed to a pesticide through mixing, loading, and/or applying a pesticide, or re-entering treated sites. Occupational handlers of 2,4-D include workers in agricultural areas, workers in forest areas, workers in rights-of-way and non-cropland areas, workers in lawn and turf areas (including turf grown for seed or sod), and workers applying 2,4-D for aquatic weed control. Occupational risk for all of these potentially e xposed populations is measured by an MOE which determines how close the occupational exposure comes to a NOAEL. In the case of 2,4-D, MOEs greater than 100 do not exceed the Agency’s level of concern. For workers entering a treated site, MOEs are calculated for each day after application to determine the minimum length of time required before workers can safely reenter.

Occupational risk estimates are expressed as MOEs, which are the ratio of estimated exposure to an established dose level (NOAEL). 2,4-D MO Es are determined by a comparison of specific exposure scenario estimates to the NOAELs for short-term assessment and intermediate-term assessment, respectively. The NOAEL for short-term dermal and inhalation exposure is 25 mg/kg/day from a rat developmental toxicity study, and the NOAEL for intermediate-term dermal and inhalation exposure is 15 mg/kg/day from a rat subchronic oral toxicity study. The dermal absorption factor is 10 percent and the inhalati on absorption factor is 100 percent. For 2,4-D users an MOE of 100 has been determined to be adequately protective (for both short- and intermediate-term exposure) based on the standard uncertainty factors of 10x for interspecies extrapolation and 10x for intraspecies variability. Long-term worker exposure is not expected for 2,4-D.

Occupational risk is assessed for exposure at the time of application (termed “handler” exposure) and assessed for exposure following application, or postapplication exposure. Application parameters are generally defined by the physical nature of the formulation (e.g., formula and packaging), by the equipment required to deliver the chemical to the use site, and by the application rate required to achieve an efficacious dose. Post-application risk is assessed for activities such as scouting, irrigating, pruning, and harvesting and is based primarily on dermal exposure estimates.

Occupational risk estimates are calculated based on assumptions concerning acres treated per day and the seasonal duration of exposure. For more information on the assumptions and calculations of potential risk of 2,4-D to workers, see th e Occupational Exposure Assessment (Section 7.0) in “2,4-D: 3 rd Revised Occupational and Residential Exposure and Risk Assessment and Response to Public Comments for the Reregistration Eligibility Decision (RED) Document,” dated May 4, 2005.

a. Occupational Toxicity

Table 20 provides a listing of the toxicological endpoints used in the 2,4-D occupational risk

assessment.Page 44 of 304 Table 20. Toxicological Endpoints for the Occupational Risk Assessment

Exposure

Scenario Dose Used in Risk Assessment, UF Level of Concern

for Risk

Assessment Study and Toxicological Effects

Short-Term Dermal* Oral study NOAEL=

25 mg/kg/day Occupational
LOC for MOE =

100 Rat developmental toxicity study LOAEL = 75 mg/kg/day based on decreased maternal body-weight gain and skeletal abnormalities

Intermediate-Term

Dermal* Oral study NOAEL = 15 mg/kg/day Subchronic oral toxicity - rat LOAEL = 100 mg/kg/day based on decreased body weight/body-weight gain, alterations in some hematology, and clinical chemistry parameters, and

cataract formation.

Long-Term
Dermal* Oral study NOAEL=

5 mg/kg/day Rat Chronic Toxicity StudyLOAEL = 75 mg/kg/day based on decreased bodyweight gain (females) and food consumption (females), alterations in hematology , and clinical chemistry parameters, decreased T4 (both sexes), glucose (females), cholesterol (both sexes), and triglycerides (females)].

Short-Term

Inhalation* Oral study NOAEL= 25 mg/kg/day Rat developmental toxicity study (same as for dermal)

Intermediate-Term

Inhalation* Oral study NOAEL = 15 mg/kg/day Subchronic oral toxicity - ra t (same as incidental oral)

Long-Term
Inhalation* Oral study NOAEL= 5 mg/kg/day Rat chronic toxicity study (same as for chronic dietary)

Cancer Classification : Group D [not classifiable as to human carcinogenicity]

*The dermal absorption factor is 10 percent and the inhalation absorption factor is 100 percent.

UF = uncertainty factor, FQPA SF = Special FQPA safety factor , NOAEL = no observed adverse effect level, LOAEL = lowest observe d adverse effect level, PAD = population adjusted dose (a = acute, c = chr onic), RfD = reference dose, MOE = margin of exposure, LOC = le vel of concern, NA = Not Applicable

For more occupational toxicity information, see “2,4-D: HED’s Revised Human Health Risk Assessment for the Reregistration Eligibility Decisi on (RED) Revised to Reflect Public Comments,” dated January 4, 2005.

b. Occupational Handler Exposure

Occupational handler risk estimates have been assessed for both short- and intermediate-term exposure durations. Because 2,4-D is typically applied only a few times per season and because the agricultural scenarios occur for only a few months per year, it is anticipated that 2,4-D exposures would primarily be short-term. Intermediate-term risk estimates are provided as an upper-bound

assessment.

Occupational handler assessments are conducted using increasing levels of protection. ThePage 45 of 304 Agency typically evaluates all exposures with minimal protection and then considers additional protective measures using a tiered approach (going from minimal to maximum levels of protection). The lowest tier is represented by the baseline clothing scenario (i.e., single layer clothing, socks, and shoes), followed by, if MOEs are of concern, increasing levels of risk mitigation such as personal protective equipment (PPE) and engineering controls (EC). With the exception of mixing and loading wettable powders, MOEs for most occupational exposure scenarios are above 100 at baseline PPE (long-sleeved shirt, long pants, socks, and s hoes) or single layer PPE (long-sleeved shirt, long pants, socks, shoes, and gloves). The MOEs for handling wettable powder are acceptable with engineering controls (i.e. water soluble bags). While the generic assessment for 2,4-D as an active ingredient does not indicate a need for additiona l PPE, evaluation of end-use product toxicity data may. End-use product PPE will be assessed on a product-by-product basis.

c. Occupational Handler Risk Summary

The Agency has determined that there are potential exposures to individuals who mix, load, apply, and otherwise handle 2,4-D during the usual use patterns associated with the pesticide’s use. Based on the use patterns, 18 major occupational handler exposure scenarios were identified as

follows:

Mixer/Loader (1a) Mix/Load Wettable Powder for Aerial Application (1b) Mix/Load Wettable Powder for Groundboom Application (1c) Mix/Load Wettable Powder fo r Aquatic Subsurface Application (1e) Mix/Load Wettable Powder for 10 Man Crew Backpack Application (1f) Mix/Load Wettable Powder for Row Sprayer (1g) Mix/Load Wettable Powder for Aquatic Foliar Application (1h) Mix/Load Wettable Powder for Turfgun Application (2a) Mix/Load Liquids for Aerial Application (2b) Mix/Load Liquids for Groundboom (2c) Mix/Load Liquids for Aquatic Subsurface Application (2d) Mix/Load Liquids for Airblast Application (2e) Mix/Load Liquids for 10 Man Crew Backpack Application (2f) Mix/Load Liquids for Row Sprayer (2g) Mix/Load Liquids for Aquatic Foliar Application (2h) Mix/Load Liquids for Turfgun Application (3) Load Granules for Broadcast Spreader

Applicator (4) Aerial Application (5) Groundboom Application (6) Subsurface Application of Liqui ds to Submersed Aquatic Weeds (7) Airblast Application (8) Backpack Application (9) Rights of Way (ROW) ApplicationPage 46 of 304 (10) Foliar Application of Liquids to Floating Aquatic Weeds (11) Turfgun Application (12) Broadcast Spreader Application

Mixer/Loader/Applicator (13) Mix/Load/Apply Wettable Powder with a Turfgun (14) Mix/Load/Apply Liquids with a Turfgun (15) Mix/Load/Apply Water Dispersable Granules with a Turfgun (16) Mix/Load/Apply Liquids with a Backpack Sprayer (17) Load/Apply Granules with a Push Spreader

Flagger (18) Flag Aerial Application

Occupational Handler Exposure Assumptions

When possible, the assumptions for daily areas treated are taken from the Health Effects Division Science Advisory Committee on Exposure Policy 9: Standard Values for Daily Acres Treated in Agriculture (July 5, 2000). In other instances, the daily areas treated were defined for each handler scenario by best scientific judgement, or th e best information available, as footnoted below in

Table 21.

Analyses were completed using acceptable surrogate exposure data for the scenario assessed. Several handler assessments were completed using data from the Pesticide Handler Exposure Database (PHED) (version 1.1). PHED data were used primarily for the large scale agricultural and forestry scenarios. Some handler assessments (i.e., handheld handgun equipment, push-type spreader, and other lawn care scenarios) were completed using data from the Outdoor Residential Exposure Task Force (ORETF). California Department of Pe sticide Regulation (CA DPR) data were used for the backpack applicator forestry scenario where multiple applicators are supplied by a nurse tank.

The following assumptions and factors were used in order to complete the exposure and risk assessments for occupational handlers and applicators:

C The average work day was 8 hours.

C A listing of application methods and amounts of acreage treated per 8 hour day is

included in Table 22 and Table 23.

C The application rate for submerged aquatic weeds is based upon the master label rate of 10.8 lbs a.e. per acre foot times an average lake depth of 5 feet.

C Maximum application rates and daily acreage were used to evaluate short term exposures.

C Average application rates were used to evaluate intermediate term exposures.

C A body weight of 60 kg was assumed for short-term exposures because the short-term endpoint relates to females 13-50 years of age.

C A body weight of 70 kg was assumed for intermediate-term exposures because thePage 47 of 304 intermediate-term endpoint is not gender-specific.

C The dermal absorption rate is 10%.

C The inhalation absorption rate is 100%.

C Baseline PPE includes long sleeve shirts, long pants and no gloves or respirator.

C Single Layer PPE includes baseline PPE with gloves.

C Double Layer PPE includes coveralls over single layer PPE.

C Double Layer PPE PF5 includes above with a PF5 respirator (i.e. a dustmask).

C Double Layer PPE PF10 includes above with a PF10 cartridge respirator.

C Only closed cockpit airplanes are used for aerial application.

C There are very little exposure data to evaluate the exposure in helicopters; therefore, the exposure data for fixed-wing aircraft are used as a surrogate.

C Airplane and helicopter pilots do not wear chemical resistant gloves.

Table 21. 2,4-D Application Methods and Assumptions

Application Method Typical Crops Treated Treated Area 1

Aerial Small Grain, Field Corn

, Sugarcane Citrus Growth Regulation 1200

350

Groundboom Small Grains, Field Corn, Sugarcane Orchard/Vineyard Floors

Strawberries 200

80

80

Subsurface Application of Liquids Submersed Aquatic Weeds 30 2

Airblast Citrus Growth Regulation 40

Backpack Sprayer - Mix/Load/Apply Christmas Tree Plantations 2 3

Backpack Sprayer - Apply Only Conifer Release 4 4

Right of Way (ROW) Sprayer Weed Control - 20 gallons per acre Brush Control - 400 gallons per acre 50 5

2.5 5

Foliar Application of Liquids Floating Aquatic Weeds 10 6

Broadcast Spreader - Tractor Drawn or Boat

Mounted Turf Submersed Aquatic Weeds 40

50 7

Turfgun Turf 5

Broadcast Spreader - Push Type Turf 5
1. Except as noted, the acres treated per day values ar e from ExpoSAC Policy #9 “Standard Values for Daily Acres Treated in Agriculture”, Revised 7/5/2000. 2. The area treated for aquatic application of liquids to submersed aquatic weeds is based on information provided in an email of 12/11/03 from Dr. Kurt Getsinger of the US Army Corp s of Engineers to Timothy C. Dole of the US EPA Office of Pesticide Programs. 3. The area treated for Backpack Sprayer (Mix/Load/Apply) is 40 gallons per day from ExpoSAC Policy #9 divided by the label recommended spray volume of 20 gallons per acre. 4. The area treated for Backpack Sprayer (Apply Only) is 4 acres per day based upon the acreage treated in CA DPR HS1769 normalized to an 8 hour day. 5. The area treated for ROW sprayers was determined by the dividing the daily spray volume handled (1000 gallons perPage 48 of 304 day) from ExpoSAC Policy #9 by the label recommended spra y volume of 20 gallons per acre for weed control and 400 gallons per acre for woody brush control. 6. The area treated for foliar application of liquids to floa ting aquatic weeds is based upon use information reported in the HED Memorandum “Occupational and Residential Exposur e Characterization/Risk Assessment for Triclopyr Triethylamine for Aquatic Weed Control, DP Barcode D269448 of 7/22/2002. 7. The area treated for application of granules to submerse d aquatic weeds is based upon information provided in an email of 11/22/2000 from Jim Kannenburg of Marine Biochemists/A pplied Biochemists to Troy Swackhammer of the US EPA Office of Pesticide Programs.

Summary of Risk Concerns and Data Gaps for Handlers

The MOEs for handlers are summarized in Tables 22 and 23 below. With the exception of mixing/loading wettable powder, all of the short-te rm and intermediate-term MOEs exceed the target of 100 with baseline PPE (i.e., long-sleeved shirt, long pants, shoes plus socks, no respirator) or single layer PPE (i.e., long-sleeved shirt, long pants, shoe s plus socks, gloves, no respirator) and are not of concern. The MOEs for handling wettable powder are adequate with engineering controls (i.e. water soluble bags).

Table 22. MOEs for Short-Term Risk to Occupational Handlers

Exposure Scenario Crop Type Application

Rate (lb ae/acre) Acres/ Day Base-line Single Layer Eng.

Control

Mixer/Loader (M/L)

M/L WP All Crops 0.25 to 4 5 to 1200 > 1 > 5 > 260

M/L Liquids All Crops 0.25 to 4 5 to 1200 > 1 > 89 > 330

M/L Liquids Submersed Weeds 54 30 3.2 260 980

Load Granulars for Broadcast Spreader Golf Courses and Aquatic Areas 2 to 54 40 or 50 > 220 > 230 >1000

Applicator (APP)

Aerial Application All Crops 1.25 to 4.0 1200 ND ND >550

Groundboom Application All Crops 1.25 to 4 40 to 200 >1000 >1000 >1000

Subsurface Aquatic Application of Liquids Submersed Weeds 54 30 430 430 >1000

Airblast Application Citrus 0.1 40 >1000 >1000 >1000

Backpack Application Conifer Release 4 4 ND 140 ND

ROW Application Weed Control 2 50 110 350 ND

Foliar Aquatic Application of Liquids Floating Weeds 2 10 280 870 ND

Turfgun Application turf 1.5 5 ND >1000 >1000

Broadcast Spreader App lication Golf Courses and Aquatic Areas 1.5 or 54 40 or 50 >250 >290 >1000

Mixer/Loader/Applicator (M/L/A)Exposure Scenario Crop Type Application

Rate (lb ae/acre) Acres/ Day Base-line Single Layer Eng.

Control

Page 49 of 304 M/L/A Liquids with Backpack Sprayer Christmas Trees 4 2 ND 730 ND

M/L/A WD Granules with a Turfgun turf 1.5 5 ND >1000 ND

M/L/A Wettable Powder with a Turf

Gun turf 1.5 5 ND >1000 >1000

M/L/A Liquid Flowables with a Turfgun turf 1.5 5 ND >1000 ND

Load/Apply Granules with a Push Spreader turf 1.5 5 ND 710 ND

Flagger

Flag Aerial Liquid Application All Crops 1.25 to 4.0 1200 > 210 > 200 > 1000

MOEs in bold font do not exceed th e target MOE of 100 and are of concern

ND not determined

Table 23. MOEs for Intermediate-Term Risk to Occupational Handlers

Exposure Scenario Crop Type Application

Rate (lb ae/acre) Acres/ Day Base-line Single Layer Eng.

Control

Mixer/Loader (M/L)

M/L WP All Crops 0.25 to 4 5 to 1200 > 1.1 > 7.3 > 360

M/L Liquids All Crops 0.25 to 4 5 to 1200 > 1.5 > 130 > 460

M/L Liquids Submersed Weeds 54 30 2.2 190 690

Load Granulars for Broadcast Spreader Golf Courses or Aquatic

Areas 1.5 or 54 40 or 50 > 150 > 160 >1000

Applicator (APP)

Aerial Application All Crops 0.5 to 2.0 1200 ND ND >770

Groundboom Application All Crops 0.5 to 4 40 to 200 >1000 >1000 >1000

Subsurface Aquatic Applicatio n Submersed Weeds 54 30 300 300 >1000

Airblast Application Citrus 0.1 40 >1000 >1000 >1000

Backpack Application Conifer Release 2 4 ND 200 ND

ROW Application Weed Control 2 50 78 240 ND

Foliar Aquatic Application of Liquids Floating Weeds and Wild

Rice 4 or 0.25 10 > 200 > 610 ND

Turfgun Application turf 1.5 5 ND >1000 ND

Broadcast Spreader App lication Golf Courses and Aquatic Areas 1.5 or 54 40 or 50 > 180 > 200 ND

Mixer/Loader/Applicator (M/L/A)Exposure Scenario Crop Type Application

Rate (lb ae/acre) Acres/ Day Base-line Single Layer Eng.

Control

Page 50 of 304 M/L/A Liquids with Backpack Sprayer Conifer Plantations 4 2 ND 510 ND

M/L/A WD Granules with a Turfgun turf 1.5 5 ND >1000 ND

M/L/A Wettable Powder with a

Turf Gun turf 1.5 5 ND >1000 >1000

M/L/A Liquid Flowables with a Turfgun turf 1.5 5 ND >1000 ND

Load/Apply Granules with a Push Spreader turf 1.5 5 ND 500 ND

Flagger

Flag Aerial Liquid Application All Crops 0.50 to 2.0 1200 > 660 > 610 > 1000

MOEs in bold font do not exceed th e target MOE of 100 and are of concern

d. Occupational Postapplication Risk

Post application 2,4-D exposures can occur in the agricultural environment when workers enter fields recently treated with 2,4-D to conduct tasks such as scouting and irrigation. In the Worker Protection Standard (WPS), a restricted entry interval (REI) is defined as the duration of time which must elapse before residues decline to a level so entry into a previously treated area and engaging in a specific task or activity would not result in exposur es that are of concern. The WPS REI for 2,4-D is

12 hours for the ester and sodium salt forms and is 48 hours for the acid and amine salt forms.

1) Exposure Scenarios, Data, and Assumptions

Postapplication dislodgeable foliar residue (DFR) data were submittted for 2,4-D as well as turf transferable residue (TTR) data from treated turf. Three turf transferable residue (TTR) studies were submitted by the Broadleaf Turf Herbicide TTR Task Force. These studies are described in “2,4-D:

3 rd Revised Occupational and Residential Exposure (ORE) and Risk Assessment and Response to Public Comments for the Reregistration Eligibility Decision (RED) Document”dated May 4, 2005, and in Appendix F of that document. These data were used in the human health risk assessment along with standard transfer coefficients based on EPA Science Advisory Council guidance to assess potential exposures to workers reentering treated sites.

For all other postapplication activities, EPA used the EPA Science Advisory Council for Exposure (Exposure SAC) policy on agricultural transfer coefficients.

The following assumptions were made regarding postapplication occupational exposure:

• Short term risks were assessed using master label rates. • Intermediate term risks were assessed using average application rates when available.Page 51 of 304 C The transfer coefficients are from an interi m transfer coefficient policy developed by HED’s Science Advisory Council for Exposure using proprietary data from the Agricultural Re-entry Task Force (ARTF) database (US EPA, August 7, 2001). This policy will be periodically updated to incorporate additional information about agricultural practices in crops and new data

on transfer coefficients. Much of this inform ation will originate from exposure studies currently being conducted by the ARTF, from further analysis of studies already submitted to the Agency, and from studies in the published scientific literature.

C The transfer coefficients for turf harvesting and maintenance are based upon recently conducted ARTF studies that are being reviewed by EPA.

C In cases where applications would be made in such a way as to minimize contact with crop foliage postapplication exposures are expected to be negligible and are not assessed. These cases are included in “2,4-D: 3 rd Revised Occupational and Residential Exposure and Risk Assessment and Response to Public Comments for the Reregistration Eligibility Decision (RED) Document (PC Code 030001, DP Barcode D316596)”, dated May 4, 2005. • The initial percent of application rate as Di slodgeable Foliar Residue (DFR) was assumed to be 20% for all crops except turf. This is the standard value used in the absence of chemical specific

data.

2) Occupational Postapplication Risk Estimates

All short- and intermediate-term MOEs are above 100 on day zero. All occupational postapplication risk scenarios are not of concern. S hort-term and intermediate-term risk estimates are

shown in Tables 24 and 25 below.

Table 24. 2,4-D Postapplication Short-Term Worker Risks

Crop Group ShortTerm MOE on Day 0

Application Rate

(lb a.e./acre) Low Exposure

Scenarios Medium Exposure

Scenarios High Exposure

Scenarios

Field/row crop, low/med (cereal grains) 1.25 6,700 450 NA

Field/row crop, low/med (rice) 1.5 5,600 370 NA

Field/row crop, tall (corn)

Pre-harvest rate for field corn Post-emergence rate for sweet corn 1.5

0.5 5,600 17,000 1,400 4,200 560

NA

Field/row crop, tall (sorghum) 1.0 8,400 2,100 NA

Sugarcane 2.0 NA 420 210

Turf - California

Turf - North Carolina 2.0

2.0 1,900

860 NA

NA 950

430Page 52 of 304 Table 25. 2,4-D Postapplication Intermediate Term Worker Risks

Crop Group Intermediate Term MOE on Day 0

Application Rate+ (lb a.e./acre) Low Exposure

Scenarios Medium Exposure

Scenarios High Exposure

Scenarios

Field/row crop, low/med (cereal grains) 0.5 12,000 780 NA

Field/row crop, low/med (rice) 0.92 6,400 420 NA

Field/row crop, tall (field corn) 0.44 13,000 3,300 1,300

Field/row crop, tall (sweet corn) 0.48 13,000 3,100 NA

Field/row crop, tall (sorghum) 0.46 13,000 3,100 NA

Sugarcane 0.75 NA 780 390

Turf - California

Turf - North Carolina 2.0

2.0 1,600

610 NA

NA 810

300

+ Average application rates as reported in the QUA report or NASS report were used when available.

7. Human Incident Data

In evaluating incidents to humans, the Agency reviewed reports from the National Poison Control Centers, the EPA OPP’s Incident Data System (IDS), the California Pesticide Illness Surveillance Program, and the National Pesticide Telecommunications Network (NPTN).

The Agency reviewed 2,4-D incident reports in January 2004. A total of 45 incidents were reported in the OPP Incident Data System and many of these incidents involved irritant effects to the eyes, skin and occasionally respiratory passages. Poison Control Center Incident Data (1993 to1998) indicated that 2,4-D is generally less likely than ot her pesticides to cause minor, moderate or life threatening symptoms. The most common symptoms were dermal irritation and ocular problems. Incident data from the California Pesticide Illness Surveillance Program indicated that the number of cases generally ranges from 0 to 3 per year and most of these cases were due to eye or skin effects. Incident data from the National Pesticide Information Center for the years 1996 to 2002 indicated that an average of 3 cases definitely or probably related to 2,4-D exposure were reported per year.

8. Cancer Epidemiology Studies

A Science Advisory Board/Scientific Advi sory Panel Special Joint Committee reviewed available epidemiological and other data on 2,4-D in 1992 and concluded that “the data are notsufficient to conclude that there is a cause and effect relationship between exposure to 2,4-D and nonHodgkin’s lymphoma” and 2,4-D was classified as a Group D, not classifiable as to human carcinogenicity. The Agency has twice recently re viewed epidemiological studies linking cancer to 2,4-D. In the first review, completed January 14, 2004, EPA concluded there is no additional evidence that would implicate 2,4-D as a cause of cancer (EPA, 2004). The second recent review of available epidemiological studies occurred in response to comments received during the Phase 3 Public Comment Period during the reregistration process for 2,4-D. EPA’s report, dated December 8,Page 53 of 304 2004 and authored by Jerry Blondell, Ph.D., found that none of the more recent epidemiological studies definitively linked human cancer cases to 2,4-D.

B. Environmental Risk Assessment

A summary of the Agency’s environmental risk assessment for 2,4-D is presented below. The Agency has conducted an assessment of potential risks to aquatic and terrestrial organisms resulting from the use of 2,4-D and its associated chemical forms including 2,4-D dimethylamine salt (2,4-D DMAS), 2,4-D isopropylamine salt (2,4-D IPA), 2,4- D triisopropanolamine salt (2,4-D TIPA), 2,4-D ethylhexyl ester (2,4-D EHE), 2,4-D butoxyethyl es ter (2,4-D BEE), 2,4-D-diethanolamine salt (2,4- D DEA), 2,4-D isopropyl ester (2,4-D IPE) and 2,4-D sodium salt. In this document, the term “chemical form” is used to refer to the supported technical formulations listed above, while the term “formulation” refers to the physical nature (e.g. gra nular or emulsifiable concentrate) of the applied product, and the term “end use product” is used to refer to any formulated product including mixtures of pesticide sold in the United States.

2,4-D has the following registered uses, which result in environmental exposures: pasture/rangeland, turf, wheat, corn, soybeans, fallowland, hay other than alfalfa, noncropland (roadways, rights-of-way, ditches, industrial sites, etc.), forestry, rice, sugarcane, pome fruits, stone fruits, nut orchards, filberts, grass grown for seed and sod, aquatic weed control, potatoes, asparagus, strawberries, blueberries, grapes, cranberries, and citrus.

This summary will present exposure estimates and hazard determinations associated with 2,4-D and its various chemical forms. In addition, risk s of concern, as determined in the environmental assessment, will be identified and characterized. More detailed information associated with the potential environmental risk from the use of 2,4-D can be found in the Environmental Fate and Effects Division’s Risk Assessment for the Reregistration Eligibility Document for 2,4- Dichlorphenoxyacetic Acid, (2,4-D), dated October 28, 2004. The complete environmental risk assessment is not included in this RED, but may be accessed in the OPP Public Docket (OPP-2004- 0167) and on the Agency’s website at http://www.epa.gov/pesticides/reregistration/status.htm.

1. Environmental Exposure

a. Environmental Fate and Transport

The environmental fate database is sufficient to characterize the environmental exposure associated with 2,4-D use. However, there are some studies that will be required as a result of the reregistration process. An aerobic aquatic metabolism study for 2,4-D BEE in acidic aquatic environments is required, along with several other dissipation studies. See section V.A.1 of this reregistration eligibility decision (RED) document for a complete list of all required studies. EPA intends to issue a DCI as part of this RED to requi re submission of additional data to address areas of uncertainty. These data are expected to conf irm the conclusions of this environmental risk

assessment.Page 54 of 304 Database A complete database has been assembled for 2,4-D acid. The dissipation of 2,4-D appears to be dependent on oxidative microbial-mediated mineralization, photodegradation in water, and leaching. 2,4-D is stable to abiotic hydrolysis. Phot odegradation of 2,4-D was observed [half life (t 1/2 ) =12.9 calendar days or 7.57 days of constant light] in pH 5 buffer solution. However, the 2,4-D photodegradation half-life on soil was 68 days.

Degradation Summary The degradation of 2,4-D was rapid (t 1/2 = 6.2 days ) in aerobic mineral soils. The half-life of 2,4-D in aerobic aquatic environments was 15 days. 2,4-D was moderately persistent to persistent (t 1/2 = 41 to 333 days) in anaerobic aquatic laboratory studies.

Several degradates were detected in the laboratory fate studies reviewed. The degradates detected were 1,2,4-benzenetriol, 2,4-DCP, 2,4- DCA, chlorohydroquinone (CHQ), 4-chlorophenol, volatile organics, bound residues, and carbon dioxide. For a complete listing of 2,4-D degradates for each route of degradation, please see the environmental risk assessment. No degradates were considered for further analysis in water or the terrestrial ecological assessment.

Mobility 2,4-D has a low binding affinity (K ad

< 3 and K de < 1) in mineral soils and sediment. The mobility of 2,4-D in supplemental soil thin layer chromatography (TLC) studies was classified as intermediately mobile (R f =0.41) to very mobile (R f =1.00) in "sieved" mineral soils. Aged radiolabeled residues of 2,4-D appeared to be i mmobile in supplemental soil column studies. 2,4-D was studied in sandy loam, sand, silty clay loam and loam soil. Freundlich K ads values were 0.17 for the sandy loam soil, 0.36 for the sand soil, 0.52 for the silty clay loam soil, and 0.28 for the loam soil. Corresponding K

oc values were 70, 76, 59 and 117 mL/g.

Bridging Strategy The 1988 2,4-D Registration Standard proposed an environmental fate strategy for bridging the degradation of 2,4-D esters and 2,4-D amine salts to 2,4-D acid. The bridging provides information on the dissociation of 2,4-D amine salts and hydrolysis of 2,4-D esters is included in the ecological risk assessment. The bridging data indicate esters of 2,4-D are rapidly hydrolyzed in alkaline aquatic environments, soil/water slurries, and moist soils. The 2,4-D amine salts have been shown to dissociate rapidly in water. However, 2,4-D esters may persist under sterile acidic aquatic conditions and on dry soil. These bridging data indicate under most environmental conditions 2,4-D esters and 2,4-D amines will degrade rapidly to form 2,4-D acid.

2,4-D Amine Salts Additional data submitted subsequent to establishment of the environmental fate bridging strategy generally support the strategy for the amine salts. Direct evidence of the stability of 2,4-D amine salts in soil and aquatic environments is diffi cult due to the lack of analytical methods. Based on maximum application rates for 2,4-D amine salts (at 4 lbs ae/A), 2,4-D amine salts are expected to fully dissociate in soil environments because their theoretical concentrations in soil solution does not exceed water solubilities. Additionally, dissociation studies indicate the time for completePage 55 of 304 dissociation is rapid (less than 3 minutes). Alt hough the analytical methods in the field studies for 2,4-D DMAS were not capable of separating a nd identifying 2,4-D DMAS from 2,4-D acid, the most conservative half-lives of 2,4-D DMAS would be e quivalent to the 2,4-D acid half-lives in field

studies. Half-lives of 2,4-D in 2,4-DMAS field studies ranged from 1.1 days to 30.5 days with a

median half-life of 5.6 days.

2,4-D Esters The conversion of 2,4-D esters to the acid and an associated alcohol moiety is more difficult to generalize. Unlike the physical dissociation mechanism of 2,4-D amine salts, the de-esterification of 2,4-D esters is dependent on abiotic and microbial-mediated processes. Any environmental variable influencing microbial populations or microbial activity could theoretically influence the persistence of the 2,4-D ester. Soil properties including clay mineralogy, organic carbon content, temperature, and moisture content are known to influence hydrolysis rates (Wolfe, et al, 1989 and Wolfe, 1990).

Registrant-sponsored research indicates the 2,4-D esters (ethylhexyl, isopropyl, butoxyethyl) degrade rapidly (half life less than 24 hours) in soil slurries, aerobic aquatic environments, and anaerobic, acidic aquatic environments. In terrestrial field dissipation studies for 2,4-D EHE, the half-lives for 2,4-D EHE ranged from 1 to 14 days with median half-life of 2.9 days. 2,4-D BEE, applied as a granule formulation, degraded rapidly in the water column in aquatic field dissipation studies under alkaline conditions. However, the 2,4-D BEE residues were detected in sediment samples from Day 0 (immediately posttreatment) to 186 days posttreatment. It is unclear whether 2,4-D BEE persistence in sediment is due to the slow release of the granule formulation or to slow deesterification of sediment bound 2,4-D BEE. Available open-literature and registrant sponsored laboratory data would suggest slow granule dissolution prolonged the persistence of 2,4-D BEE. In forest dissipation studies, the 2,4-D EHE ester degraded slowly on foliage and in leaf litter.

Persistance of 2,4-D Amine Salts and 2,4-D Esters The weight of evidence from open-literature and registrant sponsored data indicates that 2,4-D amine salts and 2,4-D esters are not persistent under most environmental conditions including those associated with most sustainable agricultural cond itions. 2,4-D amine salt dissociation is expected to be instantaneous (< 3 minutes) under most environmental conditions. Although the available data on de-esterification of 2,4-D ester may not support instantaneous conversion from the 2,4-D ester to 2,4- D acid under all conditions, it does show 2,4-D esters in normal agriculture soil and natural water conditions are short lived compounds (< 2.9 days). Under these conditions, the environmental exposure from 2,4-D esters and 2,4-D amines is expected to be minimal in both terrestrial and aquatic

environments.

b. Aquatic Organism Exposure

For exposure to aquatic fish and invertebrates, EPA considers surface water exposure only, since most aquatic organisms are not found in ground water. Surface water models are used to estimate exposure to freshwater aquatic animals. Unlike the drinking water assessment described in the human health risk assessment section of this document, the ecological water resource assessment does not include the Index Reservoir (IR) and Percent-Crop Area (PCA) factor refinements. The IRPage 56 of 304 and PCA factors represent a drinking water reservoir, not the variety of aquatic habitats, such as ponds adjacent to treated fields, relevant to a risk assessment for aquatic animals. Therefore, the EEC values used to assess exposure to aquatic animals are not the same as the values used to assess human dietary exposure from drinking water sources.

1) Exposure to 2,4-D Acid in Surface Water

The aquatic exposure assessment for 2,4-D has relied on a combination of monitoring data and modeling. Both Tier I (SCIGROW and screening level models for aquatic uses) and Tier II (PRZM/EXAMS) models have been used to estimate exposure to 2,4-D and its various chemical forms in a variety of exposure scenarios. Concentrations used for ecological assessment are 62.8 ug ae/L for peak, 55.1 ug ae/L for the 21-day average concentration, and 45.4 ug ae/L for the 60-day average. The predicted 2,4-D concentrations in surface water are slightly higher than reported monitoring data. The modeling predictions are expected to indicate upper bound concentration ranges for 2,4-D. Model input and output files for the ecological assessment may be found in the ecological risk assessment for 2,4-D.

2) Surface Water Modeling of 2,4-D Esters

The Agency’s strategy for bridging the fate data requirements for the ester and amine salt forms of 2,4-D to the acid form was supported by laboratory data which indicated rapid conversion of the amine and ester forms of 2,4-D to the acid form. However, 2,4-D esters may persist under acidic aquatic conditions. In order to account for the potential impact of the spray application of 2,4-D esters to aquatic environments, and to account for runoff during the time in which 2,4-D EHE may remain in the field, the Agency conducted additional modeling with PRZM/EXAMS to assess the potential for aquatic organisms to be exposed to 2,4-D EHE through spray drift or runoff. The peak (acute) estimated environmental concentrations (EECs) for the 2,4-D esters were estimated for each scenario and range from 0.6 ug ae/L (CA citrus) to 7.4 ug ae/L (NC pasture). A chronic EEC was not provided in this scenario because the hydrolysis soil slurry data indicate that dissipation in a nonsterile water body will occur at all pHs and therefore long-term exposures are unlikely.

3) Modeling of Direct Application of 2,4-D for Control of Aquatic Weeds

Because there are no aquatic herbicide model scenarios, a first approximation of an aquatic ecological EEC was predicted assuming direct application to the standard pond. For this assessment, the Agency developed a simple spreadsheet model that incorporates degradation based on an acceptable aerobic aquatic metabolism study for the EFED standard pond with no flow. In this model, the 21-day average and 60-day average concentrations were calculated assuming first-order dissipation from aerobic aquatic degradation, but does not assume dissipation.

The interpretation of the label for aquatic weed control is that the target rate for 2,4-D amine (2,4-D DMAS) and ester (2,4-D BEE) use is based on concentration and not application rate. In order to account for this scenario it was assumed that 2,4-D would be applied at a rate to meet the target concentration of 4000 ug/l. This assumption would be applicable across all water bodies sincePage 57 of 304 the target rate is based on a rate per acre foot of water (10.8 lbs ae/acre-foot) and would be independent of water body geometry/volume. This scenario included the assumption of uniform application across the entire water body; however, this application scenario will over-predict actual concentrations because 2,4-D is not applied to more than 50% of a water body in a single treatment. Treating more than 50% of a water body will result in oxygen depletion due to decaying plant material. Typically, 2,4-D is applied to control aquatic weeds in littoral zones that make up less than 50% of the water body. Modeling the 2,4-D concentration that results when 100% of the water body is treated predicts direct water application of 2,4-D will yield surface water concentrations of 2,4-D concentrations in the EFED standard pond of 4000 ug ae/L for peak, 3417 ug ae/L for the 21-day average, and 2610 ug ae/L for the 60-day average. Actual concentrations are expected to be less given the conservative treatment area assumption as described above, and the likely effects of dispersion on 2,4-D concentrations.

EFED evaluated the potential for exposure to 2,4-D BEE using a similar approach. Modeling predicts direct water application of 2,4-D BEE w ill yield surface water concentrations of 2,4-D BEE concentrations in the EFED standard pond of 624 ug/L for peak (24 hour average), 30 ug/L for the 21-day average, and 10 ug/L for the 60-day average.

4) Modeling of 2,4-D Use on Rice

Finally, the use of 2,4-D on rice was evaluated using a screening level model. 2,4-D is registered for use in rice paddies for the acid and amine salt forms of 2,4-D (esters are not registered for rice use) with a maximum seasonal application rate of 1.5 pounds ae per acre. Modeling of this use rate results in an estimated acute 2,4-D con centration in the rice paddy of 1431 ug ae/L. This value is expected to represent upper percentile concentrations for edge of paddy concentrations because of the lack of consideration for degr adation, dilution and dispersion. EFED conducted a preliminary evaluation of the effect of degrada tion and holding times on EECs for the use of 2,4-D on rice. As with the previous rice model, this refined model provides a single EEC which represents both an acute and chronic exposure and is an approxi mation of the EEC at the point of release into a receiving water body. Modeling with all three scenarios predict initial concentrations in the paddy water between 678 ug ae/L (California) and 762 ug ae/L (Louisiana) and decreasing concentrations with holding times based on degradation due to aerobic aquatic metabolism.

c. Terrestrial Organism Exposure

The Agency assessed exposure to terrestrial organisms by first predicting the amount of 2,4-D residues found on animal food items and then by determining the amount of pesticide consumed by using information on typical food consumption by various species of birds and mammals. The amount of residues on animal feed items are based on the Fletcher nomogram (a model developed by Fletcher, Hoerger, Kenaga, et al.) 1 and the current maximum application rate as stated in the Master Label for 2,4-D. For terrestrial uses of 2,4-D, the Master Label allows a maximum single application of 4 lbs ae/A and up to two 2 lbs ae/A applications per season for a total seasonal maximum rate of 4Page 58 of 304 lbs ae/A. Therefore, for terrestrial uses, EPA modeled the maximum and mean residues of 2,4-D in various food items immediately after the 4 lb lbs ae/A application. The Agency assumed no dilution due to the growth of the plants or degradation of 2,4-D. EPA’s estimates of 2,4-D residues on various

wild animal food items are summarized in Table 26. EPA used these EECs and standard food consumption values to estimate dietary exposure levels for 2,4-D to birds and mammals.

Table 26. Estimated Environmental Concentrations on Avian and Mammalian Food Items (ppm) Following a Single Application at 1 lb ae/A

Food Items EEC (ppm)

Predicted Maximum Residue 1 EEC (ppm)

Predicted Mean Residue 1

Short grass 240 85

Tall grass 110 36

Broadleaf/forage plants and small

insects 135 45

Fruits, pods, seeds, and large insects 15 7

1 Predicted maximum and mean residues are fo r a 1 lb ae/a application rate and are base d on Hoerger and Kenaga (1972) as modifie d by Fletcher et al. (1994).

1) Birds and Mammals

The Agency expects exposure to birds and mammals from residues of 2,4-D on food items. Exposure is probable because 2,4-D is applied in many different environments that provide habitats rich in food sources attractive to various avian and mammalian species.

a) Exposure to Nongranular (Liquid) Formulations

Toxicant concentrations on food items following multiple applications are predicted based on a first-order residue decline using the Agency's FATE5 model. The FATE5 model allows determination of residue dissipation over time by incorporating degradation half-life. Predicted maximum and mean EECs resulting from multiple applications are calculated by taking into account the maximum or mean initial EEC from the first application, the total number of applications, the time interval between applications, and a first-order foliar degradation rate of 8.8 days.

b) Exposure to Granular Formulations

Birds and small mammals may be exposed to granular formulations through ingestion of granules. The number of lethal doses (LD 50 ) that are available within one square foot immediately after application (LD 50 /ft 2 ) is used as the risk quotient (RQ) for granular products. RQs are calculated for three separate weight classes of birds (1000 g, 180 g, and 20 g) and mammals (15 g, 35 g, and 1000 g, 35 g, and 15 g).

2) Non-target Terrestrial PlantsPage 59 of 304 Due to the differences in the solubilities of the acid and amine salts when compared to the solubilities of the esters, risks for these two groups were calculated separately for the non-target terrestrial plant risk assessment. The terrestrial plant toxicity data for the 2,4-D acid and amine salts were bridged as one group, while that of the esters were bridged as another group.

Terrestrial plants inhabiting dry and semi-aquatic areas may be exposed to pesticides from runoff, spray drift or volatilization. EPA’s runoff e xposure estimate assumes a 1-in-10 year rain event and is based on a pesticide's water solubility and the amount of pesticide present on the soil surface and its top one inch, characterized as "sheet runoff" (one treated acre to an adjacent acre) for dryareas, characterized as "channelized runoff" (10 treated acres to a distant low-lying acre) for semiaquatic areas, and is based on percent runoff values of 0.01, 0.02, and 0.05 for water solubility of <10ppm, 10-100 ppm, and >100 ppm, respectively. The modeled runoff exposure estimates likely overestimate actual exposures from runoff, given the conservative 1-in-10 year rain event assumption, and also given that farming practices, intended to minimize soil loss from runoff, are not taken into

account.

Spray drift exposure from ground and overhead chemigation applications is assumed to be 1% of the application rate. Spray drift from aerial, ai rblast, and forced-air applications is assumed to be 5% of the application rate with an application efficiency (i.e., the amount that lands on the target area) of 60%. The effects of multiple applications are addressed by summing the application rates from individual applications.

Applications of granular formulations may pose risks to terrestrial plants inhabiting dry and semi-aquatic areas. Exposure is assumed to be from runoff only, and drift is assumed not to occur with granular applications of pesticides. Therefor e, the Agency's runoff scenario is essentially the same as that used in the non-granular scenario described above, with the exception that the drift component is removed.

The EECs for the acid and amine salts as well as the esters to dry and semi-aquatic areas are tabulated in Appendix F of the 2,4-D ecological risk assessment for single applications to the targeted use sites. The percent runoff value based on water solubility is assumed to be 5% for the acid and
amines and 1% for the esters.

2. Environmental Effects (Toxicity)

a. Toxicity to Aquatic Organisms

Freshwater and Estuarine/Marine Fish

The available acute toxicity data on 2,4-D indicate that the acid and amine salts are practically non-toxic to freshwater or marine fish. The esters are highly to slightly toxic to marine or freshwater fish. Toxicities for the acid and amine salts range from a LC 50 of >80.24 to 2244 milligrams acid equivalent per liter (mg ae/L). The ester toxicities range from a LC 50 of >0.1564 to 14.5 mg ae/L.Page 60 of 304 Chronic toxicity, based on length and larval su rvival from the early life stage studies, range from a NOEC of 14.2 to 63.4 mg ae/L for 2,4-D acid, 2,4-D DEA and 2,4-D DMAS. The NOEC based on larval fish survival for the fish full life cycle studies ranged from 0.0555 to 0.0792 mg ae/L for 2,4-D BEE and 2,4-D EHE.

Amphibians

Although not currently required by the Agency, freshwater amphibian studies were conducted on frog tadpoles (Rana pipiens). Tests were conducted using the ASTM (American Society for Testing and Materials) Standard E729-88a. Te sts indicate that 2,4-D acid, 2,4-D DMA, and 2,4-D EHE are practically non-toxic to tadpoles.

Freshwater and Estuarine/Marine Invertebrates

Acute toxicity of 2,4-D acid and amine salts to freshwater aquatic invertebrates ranges from a

LC 50 of 25 to 642.8 mg ae/L (slightly toxic to practica lly non-toxic). The freshwater toxicities of the esters range from 2.2 mg ae/L for the 2,4-D IPE to 11.88 mg ae/L for the 2,4-D EHE (moderately toxic to slightly toxic). Acute toxicity of 2,4-D acid and amine salts to marine invertebrates range

from an LC 50 of 49.6 for 2,4-D IPA to 830 mg ae/L for 2,4-D DMA (slightly toxic to practically nontoxic). The marine invertebrate LC 50 s range from >0.092 to >66 mg ae/L for the 2,4-D esters (highly toxic to practically non-toxic). These toxicities indicate that the esters are more toxic than the acid and amine salts. Although acute data are missing for so me of the amine salts, these studies will not be required because none of the RQs exceed the aquatic levels of concern for the acid amine salts.

Chronic toxicity tests for freshwater and estuarine/marine invertebrates were performed on 2,4- D acid, 2,4-D DEA, 2,4-D DMAS, and 2,4-D BEE. The toxicity ranged from a NOEC of 16.05 mg ae/l for 2,4-D DEA (survival and reproduction) a nd 79 mg ae/L for the 2,4-D acid (number of young). The chronic freshwater NOEC is 0.20 mg ae/L for the 2,4-D BEE (survival and reproduction). There are no freshwater or marine chronic toxicity data for any of the other 2,4-D esters.

Although an estuarine/marine invertebrate life-cycl e toxicity test using the TGAI is required to establish the toxicity of products containing the 2,4-D acid, salts, and amines, a chronic study will not be required. The data from the freshwater inverteb rate studies will be bridged to the estuarine/marine invertebrates for the 2,4-D acid and amine salts. The RQs for the freshwater chronic studies were well below the levels of concern, and the chronic risk for estuarine/marine invertebrates would be expected to be low. However, there is a risk c oncern for for estuarine/marine invertebrates for the 2,4-D esters. A chronic study will be required for 2,4-D BEE to reduce the uncertainty to

estuarine/marine invertebrates.

Aquatic Plants

The vascular plant EC 50 toxicity data for the acid and amine salts range from 0.29 mg ae/L for 2,4-D DEA to 1.28 mg ae/L for 2,4-D TIPA. The EC 50 toxicity data for the more toxic esters range from 0.33 mg ae/L for 2,4-D EHE to 0.3974 mg ae/L for 2,4-D BEE. The same trend is shown for thePage 61 of 304 non-vascular plant EC 50 . The nonvascular plant EC

50 toxicity data range for the acid and amine salts is 3.88 to 156.5 mg ae/L for 2,4-D DMA. The range for the esters is 0.066 mg ae/L for 2,4-D EHE to 19.8 mg ae/L for 2,4-D EHE. In addition, based on the data available, it appears that the vascular plants are more than two orders of magnitude more sensitive than the non-vascular plants.

b. Toxicity to Terrestrial Organisms

The bird and mammal toxicity values of the 2,4-D acid, salts, amine salts, and esters were pooled because the toxicity values were within one to two orders of magnitude for all the chemical

forms.

Birds

Toxicity ranges for birds do not show distinct differences between the acid, salts, amine salts, and esters, as indicated for aquatic animals. All studies have been conducted with the active ingredient, and have been converted to the acid equivalent since use rates on the master label are given in pounds acid equivalent per acre.

2,4-D is classified as moderately toxic to practically non-toxic to birds on an acute oral basis,

since the oral LD 50 ranges from 500 mg ai/kg (415 mg ae/kg) for 2,4-D DMAS to >1000 mg ae/kg for the 2,4-D acid.

The chronic NOEC of 962 ppm is based on the endpoints of eggs cracked and a decreased number of eggs laid for the 2,4-D acid. There is no comparable study for the mallard duck and no other avian chronic study was performed on any of the other active ingredients.

Mammals

The Agency expects exposure to mammals from residues of 2,4-D on food items, since 2,4-D is used in many different mammalian habitats, including pasture and rangeland, and turf lawns. Toxicity ranges for mammals do not show distinct differences between the acid, salts, amine salts, and esters as indicated for aquatic animals. All studies have been conducted with the active ingredient, and have been converted to the acid equivalent since all use rates on the master label are given in pounds acid equivalent per acre. The rat LD 50 ranged from 579 to 1300 mg ae/kg.

Mammalian chronic toxicity values are from rat and rabbit developmental toxicity studies for the 2,4-D acid and all amine salts, and esters. In addition, the 2-generation rat study is also available for the 2,4-D acid. The NOAEL in the rat chronic toxicity study was 5 mg/kg/day, with a LOAEL of 75 mg/kg/day based on decreased body-weight gain and alterations in hematology. The NOAEL in the rabbit developmental toxicity study was 30 mg/kg/day, and the LOAEL was 90 mg/kg/day based on clinical signs, loss of righting reflex, and abortions.Page 62 of 304 Non-Target Insects

Available data from a honey bee acute toxicity study indicated that technical 2,4-D is practically non-toxic to the honey bee. The LD 50 in the honey bee acute toxicity study is greater than 10 micrograms per bee; see MRID 445173-04 for 2,4-D DMA and MRID 445173-01 for 2,4-D EHE. Minimal risk is expected to non-target insects from 2,4-D use.

Terrestrial Plants

The terrestrial plant runoff exposure scenario is based on the solubility of the 2,4-D compound. The water solubilities differ greatly between 2,4-D esters and 2,4-D acid and amine salts. The terrestrial plant toxicity values for 2,4-D acid and amine salts is summarized in Table 27, and have been listed as the acid equivalent. The sensitivity ranges for the monocot and dicot species are listed for the seedling emergence and vegetative vigor studies.

Table 27. Terrestrial Plant Toxicity Summary for 2,4-D Acid and amine salts

Study Type Most sensitive Crop / Active Ingredient EC25 / NOEC (lb ae/A)

Seedling Emergence Monocot Sorghum / 2,4-D DMAS 0.026 / 0.015

Dicot Mustard /2,4-D DEA 0.045 / <0.045

Vegetative Vigor Monocot Onion / 2,4-D Acid <0.0075 / <0.0075

Dicot Tomato / 2,4-D DEA 0.003 / 0.002

The terrestrial plant toxicity for the 2,4-D esters is summarized in Table 28. The sensitivity ranges for the monocot and dicot species are listed for the seedling emergence and vegetative vigor

studies.

Table 28. Terrestrial Plant Toxicity Summary for 2,4-D Esters

Study Type Most sensitive Crop / Active Ingredient EC25 / NOEC (lb ae/A)

Seedling Emergence Monocot Onion / 2,4-D IPE 0.01 / 0.005628

Dicot Lettuce / 2,4-D IPE 0.00081 / 0.00047

Vegetative Vigor Monocot Corn /2,4-D IPE 0.2016 / 0.0252

Dicot Lettuce / 2,4-D IPE 0.00126 / 0.006132

3. Ecological Risk Estimation (RQs)

The Agency’s ecological risk assessment compares toxicity endpoints from ecological toxicity studies to estimated environmental concentrations (EECs) based on environmental fate characteristics and pesticide use data. To evaluate the potential risk to non-target organisms from the use of 2,4-DPage 63 of 304 products, the Agency calculates a Risk Quotient (R Q), which is the ratio of the EEC to the most sensitive toxicity endpoint values. These RQ values are then compared to the Agency’s levels of concern (LOCs), given in Table 29, which indicate wh ether a pesticide, when used as directed, has the potential to cause adverse effects on non-target organisms. When the RQ exceeds the LOC for a particular category (e.g., endangered species), the Agency presumes a risk of concern to that category. These risks of concern may be addressed by further refinements of the risk assessment or by mitigation. Use, toxicity, fate, exposure, and incidents are considered when characterizing the risk, as well as the levels of uncertainty in the assessment.

Table 29. EPA’s Levels of Concern and Associated Risk Presumptions.

Risk Presumption LOC

terrestrial

animals LOC aquatic

animals LOC Plants

Acute Risk - there is potential for acute risk; regulatory action may be

warranted in addition to restricted use classification. 0.5 0.5 1

Acute Restricted Use - there is potential for acute risk, but may be mitigated through restricted use classification. 0.2 0.1 N/A

Acute Endangered Species - endangered species may be adversely affected; regulatory action may be warranted. 0.1 0.05 1

Chronic Risk - there is potential for chronic risk; regulatory action may be warranted. 1 1 N/A

For a more detailed explanation of the ecological risks posed by the use of 2,4-D, refer to Environmental Fate and Effects Division’s Risk Assessment for the Reregistration Eligibility Document for 2,4- Dichlorophenoxyacetic Acid (2,4-D), dated October 28, 2004.

a. Risk to Aquatic Organisms

The RQs for aquatic organisms are presented in detail in Appendix F of the ecological risk assessment for 2,4-D.

1) Fish and Aquatic Invertebrates

There were no acute or chronic Level of Concern (LOC) exceedances for aquatic organisms through use of 2,4-D acid and amine salts due to runoff/drift from use on terrestrial sites, no acute LOC exceedances for aquatic organisms due to drift-only of 2,4-D esters to water bodies from use on terrestrial sites, and, there were no acute LOC exceedances for aquatic organisms due to the runoff/drift of 2,4-D esters to water bodies from use on terrestrial sites. Chronic concerns were not evaluated for terrestrial uses of 2,4-D esters.

Estimated risk quotients (RQs) from use of 2,4-D acid and amine salts in aquatic weed control through direct subsurface application to water bodies exceed the restricted use LOCs for freshwaterPage 64 of 304 invertebrates. There are no chronic LOC exceedances for this use. Estimated RQs for use of 2,4-D BEE in weed control through direct subsurface app lication to water bodies exceed the acute risk LOC

for freshwater fish and invertebrates and chronic risk LOC for freshwater and estuarine fish and freshwater invertebrates when compared on an acid equivalent basis.

Additional characterization of the potential risk a ssociated with the direct application of 2,4-D for aquatic weed control was completed by back-calculating the target concentration needed to reduce EECs below LOCs. This type of consideration pr ovides context to the characterization of potential risk and indicates that for all 2,4-D chemical forms target concentration reduction of up to 10-fold still exceeds all LOCs for aquatic organisms.

While noting the potential risks identified above, it is important to note the benefits gained through the direct application of 2,4-D to aquatic bodies, for the control of invasive species. The U.S Army Corps of Engineers (USACE), among others, has identified 2,4-D as an important tool for protecting the nation's waters from the invasion and establishment of some of the world's worst species of exotic nuisance vegetation. 2,4-D has a reputation as a selective and economical means to remove invasive plants, enhance the growth and recovery of desirable native vegetation, restore water quality, reduce sedimentation rates in reservoirs, and improve fish and wildlife habitat. 2,4-D products are used to control invasive w eeds, such as Eurasian watermilfoil ( Myriophyllum spicatum ) in the northern tier states and water hyacinth ( Eichhornia crassipes ) in the Gulf Coast states. Effective control of these plants can benefit public health with respect to reducing levels of mosquito habitat. In addition, according to USACE, no other product (or alternative technique) can control these plants in a more cost-effective manner (K. Getsinger, USACE, Public Comment; Docket ID# OPP-2004-0167- 0053).

Estimated RQs for use of 2,4-D acid and amine salts in rice paddies exceed the acute endangered species LOCs for freshwater invertebrate s. The rice model used to predict these EECs is a screening level model which predicts concentration in tailwater at the point of release from the paddy. It is anticipated that once released, the concentration will be reduced and subsequently is expected to decrease away from the point of re lease. Additional characterization was conducted by considering average application rates (average rates are presented in the quantitative usage analysis dated August 9, 2001 prepared by the Biological and Economic Affairs Division of EPA/OPP) versus maximum label rates and assuming a proportional reduction in EECs. Consideration of average application rates results in EECs below the endangered species LOC.

2) Aquatic Plants

For non-target, aquatic plants, estimated RQs resulting from the runoff/drift of 2,4-D acid and amine salts from use on terrestrial crops exceed the aquatic vascular plant endangered species LOCs for use of 2,4-D acid and amine salts on pasture and apples. Consideration of average application rates and assuming a proportional reduction in EECs results in RQs below the endangered species LOC. Likewise, there are no LOC exceedances from the drift of the ester forms to aquatic water

bodies or from the runoff of the ester forms to water bodies from use on terrestrial sites.Page 65 of 304 Estimated RQs for the scenario of direct application to water for aquatic weed control for 2,4-D acid and amine salts indicate acute and endangered species LOC exceedances for aquatic vascular plants and acute LOC exceedances for non-vascular plants, while estimated RQs for the use of 2,4-D BEE for direct application to water to control aquatic weeds exceed all LOCs for vascular and one acute LOC exceedance for non-vascular plants. Risk to endangered non-vascular plants is not evaluated because at this time there are no listed endangered nonvascular plant species. Additional characterization of potential risk for the direct application of 2,4-D for aquatic weed control was completed by back-calculating the target concentration needed to reduce the RQs below LOCs. This type of consideration provides context to the character ization of potential risk and indicates that for all 2,4-D chemical forms target concentration reduction of up to 100-fold still exceeds all LOCs for aquatic plants.

While noting the potential risks identified above, it is important to note the benefits gained through the direct application of 2,4-D to aquatic bodi es, for the control of invasive species. The U.S Army Corps of Engineers (USACE), among others, has identified 2,4-D as an important tool for protecting the nation's waters from the invasion and establishment of some of the world's worst species of exotic nuisance vegetation. 2,4-D has a reputation as a selective and economical means to remove invasive plants, enhance the growth and r ecovery of desirable native vegetation, restore water quality, reduce sedimentation rates in reservoirs, and improve fish and wildlife habitat. 2,4-D products are used to control invasive weeds, such as Eurasian watermilfoil ( Myriophyllum spicatum ) in the northern tier states and water hyacinth ( Eichhornia crassipes ) in the Gulf Coast states. Effective control of these plants can benefit public health with respect to reducing levels of mosquito habitat. In addition, according to USACE, no other product (or alternative technique) can control these plants in a more cost-effective manner (K. Getsinger, USACE, Public Comment; Docket ID# OPP-2004-0167- 0053).

Estimated RQs for use of 2,4-D acid and amine salts in rice paddies exceed the acute and endangered species LOCs for aquatic vascular plants. Consideration of average application rates results in RQs below the endangered species LOCs.

b. Risk to Non-target Terrestrial Organisms

1) Birds

The RQs for birds are presented in detail in A ppendix F of the ecological risk assessment for 2,4-D. Potential risks were evaluated for non-granular and granular formulations applied both as banded and broadcast applications.

EPA has relied on risk estimates from oral gavage studies on birds (LD 50 of 415 mg ae/kg-bw ) to assess risk because no definitive endpoint was determined from dietary studies. Therefore, it is likely that the risk estimates associated with th e gavage studies overestimate the actual exposure of birds in the field. For predicted maximum exposures when compared with oral gavage data there are exceedances of acute LOCs for all use sites except potatoes and citrus for most small birds and some

medium birds. There are also exceedances of acute restricted use and endangered species LOCs for medium and large birds feeding on short grass, tall grass, and broadleaf forage/small insects at all use sites except potatoes and citrus. However, comparison with the lowest dietary LC 50 of >5620 mgPage 66 of 304 ae/kg-diet would result in no acute LOC exceedances . As noted previously, no definitive endpoint was available from the avian acute dietary studies and, hence, risk was not evaluated using this endpoint.

The RQs are presented below in Table 30 for the avian risk due to 2,4-D residues on various

food items.

Table 30. Avian Risk Quotient Summaries for Non-granular Spray Applications of 2,4-D acid,

amine salts and esters

Use Site (Acute & Chronic Risk) Scenario

Short Grass Tall Grass Broadleaf, forage,

small insects Fruit, large insects,

Fallow areas and Crop Stubble; Turf (Golf courses, Reside ntial Lawns, Grasses Grown for Seed, and Sod); Pastures, Rangeland, Perennial Grassland; Sugarcane (2 lb s ae/A/app, 2 app., ground/aerial, 30 day interval)

Acute RQ Exceedance 0.1* - 1.91*** 0.04 - 0.88*** 0.04 - 0.78*** -

Non-Cropland (Fencerows, Hedgerows, Roadsides, Ditches, Rights-of-Way, Utility Power Lines, Railroads, Airports, Industrial Sites, etc.); Forest Uses, Cranberry (4.0 lbs ae/A /app, 1 app., ground/aerial,)

Acute RQ Exceedance 0.18* - 3.5*** 0. 07 - 1.6*** 0.07 - 1.43*** 0.01 - 0.15*

Fruit, Small Grains (Except Corn), Asparagus (1.4 to 2.0 lbs ae/A/app)

Acute RQ Exceedance 0.09 - 1.75*** 0.04 - 0.81*** 0.03 - 0.72*** -

Corn (1.5 lbs ae/A/app, 2 app., 7 day interval, ground or aerial)

Acute RQ Exceedance 0.1* - 2.07*** 0.04 - 0.81*** 0.03 - 0.72*** -

* indicates an exceedance of Endangered Species Level of Concern (LOC).

** indicates an exceedance of Acute Restricted Use LOC.

*** indicates an exceedance of Acute Risk LOC.

Chronic risk calculations resulted in RQ’s of 1.0 to 1.1 on birds which forage on short grass when the application rate of 2,4-D ranges from 2.0 to 4.0 lb ae/A such as seen with rights-of-way, cranberries or asparagus. The chronic risk LOC is 1.0.

Non-granular Banded Applications - According to the Master Label for 2,4-D, products that allow for banded applications of sprays to row crops require all formulators to adjust the application rates according to a formula provided. Many current labels do not advise applicators to adjust the application rates, and the resulting treatment can be interpreted to concentrate the per acre application rate into a narrow band. Birds, at least in theory, could be exposed to the higher concentration of toxicant by foraging or wandering into the treated band. EPA/OPP evaluated the banded risk by comparing the RQs from unadjusted band rates to those using the adjusted band rates to illustrate the increased risk. OPP assumed a 6 inch band and 30 inch row space as a typical banded application. The RQs indicate that levels of concern are not exceeded for 1000 g birds for rates adjusted due to band widths. LOCs are also not exceeded for these adjusted rates for potatoes for all weight classes of birds. The unadjusted band width rate, however, exceeds LOCs for all weight classes of birds for all uses with the exception of potatoes.

Granular Broadcast Applications - Acute RQs for granular products are calculated for three separatePage 67 of 304 weight classes of birds using the LD 50 /ft 2 : 1000 g (e.g., waterfowl), 180 g (e.g., upland gamebird), and 20 g (e.g., songbird). The acute RQs for broadcast applications of granular products are tabulated below for the use sites from the 2,4-D Master Label which support granular formulations.

Table 31: Avian Acute Risk Quotient Calcul ations for Granular Broadcast Applications

Bird Body Weight (g) Acute RQ (LD 50 per ft 2 ) a

Non-Cropland (4.0 lbs ae/A/app, 1 app., ground/aerial,) Aquatic areas (4.0 lb ae/A/app. 3 wks between apps) Cranberry (4.0 lbs ae/A/app, 1 app., ground) 20 5.02***

180 0.55***

1000 0.1*

Turf (2.0 lbs ae/A/app, 2 app., ground/aerial, 30 day interval) Aquatic areas - Ditchbank applications (2.0 lb ae/A/app., 2 app., ground) 20 2.5***

180 0.3**

1000 0.05

Aquatic areas - Surface application or subsurface injection (10.8 lb ae/acre-foot to an average pond depth of 5 feet) 20 13.55***

180 1.5***

1000 0.27**

a RQ = App. Rate (lbs ae) x 453,590 mg x Acre x 1 x 1000 g x Kg Acre Lb 43,560 ft 2 Animal weight (g) 1 kg LD50 mg * indicates an exceedance of Endangered Species Level of Concern (LOC).

** indicates an exceedance of Acute Restricted Use LOC.

*** indicates an exceedance of Acute Risk LOC.

Granular Banded Applications - In addition to broadcast applications of granular formulations, a number of labels instruct the applicators to apply unincorporated banded treatments of granular products to crops. As explained for banded spray treatments above, many labels adjust application rates according to band width and row spaces, but many others do not. If banded granular applications were used at the same sites as banded spray applications, the risk would be similar.

2) Mammals

Acute LOCs for mammals feeding on plants and insects were exceeded when considering nongranular formulations, for all uses assessed for small and medium size mammals, except potatoes and citrus. There were no exceedances for granivores. Banded applications result in exceedances of

acute LOCs at all use sites.

Mammalian chronic RQs range from 0.05 to 200 and chronic LOCs were exceeded in all cases with the exception of potatoes and citrus (large ins ects, seeds). Consideration of average application rates results in EECs below the LOCs for non-granular, granular, or banded applications. However, consideration of average application rates for non- granular, granular and banded applications did not result in exposure below the chronic LOC.Page 68 of 304 Acute Exposure from Nongranular 2,4-D Products The acute RQs for broadcast applications of nongranular products are tabulated for herbivores/insectivores and granivores in Appendix F of the ecological risk assessment for 2,4-D. When the LD 50 of 1072 mg ai/kg (579 mg ae/kg) is used for in herbivore/insectivore RQ calculations, endangered species LOCs are exceeded at many sites for mammals foraging on short and tall grass, broadleaf plants, and small insects. The RQs range from 1.72 for asparagus to < 0.01 for potatoes. There are no LOC exceedances for granivorous mammals.

As described above for avian risk, in addition to broadcast spray, a number of labels instruct the applicators to apply unincorporated banded treatments of sprays to row crops. Using the same assumptions as described above for birds, the RQs for mammals are presented in Table 32. Again, for purposes of comparison, the unadjusted rates that appear on many of the current labels have been included. Using the mammalian LD50 of 579 mg ae/kg, acute levels of concern are exceeded at all use sites and for 15, 35, and 1000 g mammals when banded rates are not adjusted. When the banded rates are adjusted, LOCs are not exceeded for 1000 g mammals. The results of these calculations are tabulated in Appendix F of the ecological risk assessment for 2,4-D.

Acute Exposure to Granular 2,4-D Products - Mammalian species also may be exposed to granular pesticides by ingesting granules. The number of lethal doses (LD 50 ) that are available within one square foot immediately after application can be used as a RQ (LD 50 /ft 2) for the various types of exposure to pesticides. RQs are calculated for three separate weight classes of mammals: 15 g, 35 g, and 1000 g. The LOCs are exceeded for all sites with the following exceptions: no LOCs are exceeded for 1000 g mammals in turf, aquatic ar eas (ditchbanks and surface applications), or

cranberries.

The acute RQs for broadcast applications of granular products are tabulated below for the use sites from the master label which support granular formulations.

Table 32: Mammalian Acute Risk Quotient Calcul ations for Granular Broadcast Applications

Animal Body Weight (g) Acute RQ (LD 50 per ft 2 ) 1

Non-Cropland (4.0 lbs ae/A/app, 1 app., ground/aerial,) Aquatic areas (4.0 lb ae/acre/app. 3 weeks between applications) Cranberry (4.0 lbs ae/A/app, 1 app., ground) 15 4.8 ***

35 2.1 ***

1000 0.1 *

Turf (2.0 lbs ae/A/app, 2 app., ground/aerial, 30 day interval) Aquatic areas - Ditchbank applications (2.0 lb ae/acre/app., 2 app., ground 15 2.4 ***

35 1.0 ***

1000 ??

Aquatic areas - Surface application or subsurface injection (10.8 lb ae/acre foot to an average pond depth of 5 feet) 15 12.9 ***

35 5.5 ***

1000 0.2 **

1 RQ = App. Rate (lbs ae) x 453,590 mg x Acre x 1 x 1000 g x Kg Acre Lb 43,560 ft 2 Animal weight (g) 1 kg LD50 mg

* indicates an exceedence of Endangered Species Level of Concern (LOC).

** indicates an exceedence of Acute Restricted Use LOC.

*** indicates an exceedence of Acute Risk LOC.Page 69 of 304 Chronic Exposure to Mammals - The chronic RQs for broadcast applications of nongranular products are tabulated in Appendix F of the 2,4-D ecological risk assessment for all classes of

mammals. The parental toxicity NOAELs ranged from 5 mg/kg/day based on female body weight gain and male renal tubule alteration for the 2,4-D acid. The FATE program was used to determine the maximum and 56-day average residues that occur in a one year time period. The application rate, minimum number of applications, and the interval between applications were determined from the 2,4-D Master Label and represent the highest single application rates. Levels of concern were exceeded in all cases with the exception of potatoes and citrus (large insects, seeds) and RQs ranged

from 0.1 to 200.

3) Non-Target Insects

The Agency currently does not quantify risks to te rrestrial non-target insects. RQs are therefore not calculated for these organisms. Since the test results from one of the salts (2,4-D DMAS) and 2,4-D EHE was practically non-toxic to honey bees (LD 50 of >100 μg/bee), the potential for 2,4-D and its salts and esters is predicted to pose minimal risk to pollinators and other beneficial insects.

4) Non-target Terrestrial Plants

Acute LOCs for both non-endangered and endangered terrestrial plants were exceeded for nongranular and granular uses at many use sites. Consideration of average application rates did not result in exposure below LOCs.

RQs for terrestrial plants in dry and semi-aquatic areas are calculated for multiple and single spray applications for endangered and non-endangered species. As mentioned above in the exposure section, the runoff scenarios are based on solubility, and as a consequence, the environmental concentrations must be calculated separately for the esters and the acid and amine salts. The environmental concentrations for the esters were calculated separately at a percent runoff value of 0.01, while that of the acid and amine salts were calculated at a value of 0.05. A 60% efficiencyfactor is also included for aerial applications. In addition, banded applications granular and nongranular formulations are also calculated. The detailed calculations for terrestrial plants are tabulated in Appendix F of the ecological risk assessment.

Risk Quotient (RQ) Calculations - To calculate the RQs for non-endangered plants the EC 25 value of the most sensitive species in the seedling emergence study is compared to runoff and drift exposure to determine the RQ (EEC/toxicity value). The EC 25 value of the most sensitive species in the vegetative vigor study is compared to the drift exposure to determine the acute RQ. RQs are calculated for the most sensitive monocot and dicot species.

RQs for Endangered Plants - To calculate the RQs for endangered plants the NOEC or EC 05 value of the most sensitive species in the seedling emergence study is compared to runoff and drift exposure (EEC/toxicity value). The NOEC or EC 05 value of the most sensitive species in the vegetative vigor study is compared to the drift exposure to determ ine the acute RQ. RQs are calculated for the most sensitive monocot and dicot species. The RQ ranges for single and multiple applications are summarized below for non-endangered and endangered plants for the acid and amine salts, andPage 70 of 304 separately for the esters.

• Single Spray Applications - Most use sites on the 2,4-D Master Label allow multiple applications. However, the following use sites are labeled for maximum application rate for a single application.

Table 33. 2,4-D Use Sites With Maximum Labeling for a Single Application

Use Site Application Rate/Method

Non-crop 1 , Forest Uses, Cranberry Ground & Aerial Applications (4.0 lbs ae/A/app.,)

Strawberry, Rice Ground & Aerial Applications (1.5 lbs ae/ac/app.)

Grapes Ground Applications (1.36 lbs ae/A/app.)

Sorghum, Soybean Ground and Aerial Applications (1.0 lbs ae/A/app.)

Soybean Ground & Aerial Applications (1.0 lbs ae/A/app.)

Citrus Ground or Aerial Applications (0.1 lbs ae/A/app.)

1 Woody plants in rights-of-way. Other non-crop sites may have up to 2 applications of 2 lbs each.

The detailed RQ calculations for single applications are tabulated in detail in Appendix F of the ecological assessment for 2,4-D, and a summary is presented below.

Table 34. Terrestrial Plant Risk Quotients for Single Applications

Chemical Group (acid / ester) Plant Group (non-endangered / endangered) Risk Quotient Range

2,4-D Acid and Amine Salt non-endangered 0.18 - 67

endangered 0.13 - 136

2,4-D Ester non-endangered <0.01 - 543.21

endangered 0.04 - 936.17

Multiple spray applications - Most of the 2,4-D products on the 2,4-D Master Label allow second applications at prescribed intervals ranging from 7 to 30 days with the exception of pome fruit which allows a 75 day interval. The RQs for multiple applications follow a linear pattern for changes in application rates, and since a maximum of two applications is allowed, the RQ doubles for these applications. The detailed calculations are tabulated in detail in Appendix F of the 2,4-D ecological risk assessment, and a summary is presented below.

Table 35. Terrestrial Plant Risk Quotients for Multiple Applications

Chemical Group (acid / ester) Plant Group (non-endangered / endangered) Risk Quotient Range

2,4-D Acid and Amine Salt non-endangered 0.19 - 157

endangered 0.19 - 272Chemical Group (acid / ester) Plant Group (non-endangered / endangered) Risk Quotient Range

Page 71 of 304 2,4-D Ester non-endangered 0.01 - 12

endangered 0.01 - 33

Banded Spray Applications - Banded spray applications are allowed on a number of labels and instruct the applicators to apply unincorporated banded treatments of sprays to row crops. Many labels adjust application rates according to band width and row spaces, but others do not. For the labels which do not adjust the application rates, th e treatments could be more concentrated in the bands. Since non-target plants do not migrate from treated to untreated bands as is the case with birds and mammals, exposure to plants is characterized as "sheet runoff" (one treated acre to an adjacentacre) for dry areas and "channelized runoff" (10 treated acres to a distant low-lying acre) for semiaquatic areas. Therefore, the higher per acre rates in the concentrated bands do not affect the exposure to non-target plants when label rates are not adjusted.

The 2,4-D Task Force proposal to require all formulators to adjust the application rates for banded applications will reduce the exposure to non-targ et plants. If we assume use of the same 6 inch band and 30 inch row space that we used for the analysis of birds and mammals, the per acre banded application rate would be reduced by 1/5 of the broadcast application rate. The RQs are detailed in Appendix F of the ecological risk assessment for 2,4-D, and summarized for multiple and single applications in the following table.

Table 36. Non-target Plant Risk Quotient Summa ry of Adjusted Band Applications to Selected Row Crops.

Chemical Group (acid / ester) Plant Group (nonendangered / endangered) Risk Quotient Range (Single Applications) Risk Quotient Range (Multiple Applications)

2,4-D Acid and Amine Salt non- endangered 0.02 - 60 0.04 - 120

endangered 0.02 - 439 0.04 - 878

2,4-D Ester non-endangered <0.01 - 27 <0.01 - 54

endangered <0.01 - 47 <0.01 - 94

Granular Applications - The only currently approved granular applications which are currently allowed on the master label are on grass grown for seed or sod, turf, cranberries, non-crop land, and aquatic weed control sites. The non-target terrestri al plant RQ summaries for the acid and amine salts for the esters are presented below. Detailed RQs are presented in Appendix F of the ecological risk assessment for 2,4-D.Page 72 of 304 Table 37. Non-target Plant Risk Quotient Summary of Granular Applications to Selected Uses.

Chemical Group (acid / ester) Plant Group (non-endangered / endangered) Risk Quotient Range (Single Applications) Risk Quotient Range (Multiple

Applications) 1

2,4-D Acid and Amine Salt non-endangered 2.2 - 77 4.4 - 154

endangered 2.2 - 133 4.4 - 266

2,4-D Ester non-endangered 2.0- 494 4.0 - 987.62

endangered 3.57 - 851 7.14 - 1702.12

1 Turf is only site for multiple applications of granular products

.

4. Ecological Incidents

Aquatic Incidents The EFED Ecological Incident Information System (EIIS) database reports pesticide incidents that have been voluntarily submitted to EPA by state agencies. The report assigns a certainty index of 0 (unrelated), 1 (unlikely), 2 (possible) 3 (probable) or 4 (highly probable) to each incident. In addition, a judgement of registered use, accidental misuse, intentional misuse, or undetermined is assigned. There were 227 incidents reported for 2,4-D, and 24 of these incidents were reported as aquatic incidents under the 2,4-D acid only. The two “highly probable” registered use incidents occurred when 2,4-D was applied to corn and a railroad right-of-way. The corn application resulted in bluegill and largemouth bass mortalities in Missouri, while the right-of-way application resulted in a kill of 23,000 (presumably) fish. The corn incident affected bluegill, catfish, crappie, fox squirrel, greengill, largemouth bass, silver minnow, smallmouth bass, sunfish and watersnake. This incident was determined to be “highly probable” and was not listed as a misuse, however, no residue analysis was obtained. Another incident was recorded as “possible” and the use was “undetermined.” The species affected included bass, catfish, crappie, grass carp, and perch. Results from these incidents should be regarded with caution since it is not clear exactly which products or tank mixes might be involved. In addition, residue analysis was not available in almost

all instances.

Terrestrial Incidents There were 227 terrestrial incidents reported for 2,4-D, and 155 of these incidents were reported as plant incidents under the acid form only. Two incidents were reported as both terrestrial and aquatic. Eighty-four incidents to plants were listed as registered uses and most were considered“probable.” Crop damage was reported to have occurred on numerous crops, but most common nontarget plant damages occurred on grass and corn. However, most of these incidents resulted from applications to lawns/turf and corn, respectively. Results from the incident reports should be regarded with caution since it is not clear exactly which products or tank mixes might be involved. In addition, residue analysis was not available in

almost all instances.

5. Endangered Species ConcernsPage 73 of 304 The Agency has developed the Endangered Species Protection Program to identify pesticides whose use may cause adverse impacts on endangered and threatened species, and to implement mitigation measures that address these impacts. The Endangered Species Act requires federal agencies to ensure that their actions are not likely to jeopardize listed species or adversely modify designated critical habitat. To analyze the potential of registered pesticide uses to affect any particular species, EPA puts basic toxicity and e xposure data developed for REDs into context for individual listed species and their locations by evaluating important ecological parameters, pesticide use information, the geographic relationship between specific pesticide uses and species locations, and biological requirements and behavioral aspects of the particular species. This analysis will take into consideration any regulatory changes recommended in the RED that are being implemented at this time. A determination that there is a likelihood of potential impact to a listed species may result in limitations on use of the pesticide, other measures to mitigate any potential impact, or consultations with the Fish and Wildlife Service and/or the National Marine Fisheries Service as necessary.

The Endangered Species Protection Program as de scribed in a Federal Register notice (54 FR 27984-28008, July 3, 1989) is currently being implemented on an interim basis. As part of the interim program, the Agency has developed County Specific Pamphlets that articulate many of the specific measures outlined in the Biological Opinions issued to date. The Pamphlets are available for voluntary use by pesticide applicators on EPA’s website at www.epa.gov/espp

.

The preliminary risk assessment for endangered species indicates that 2,4-D exceeds the endangered species LOCs for the following combinations of analyzed uses and species:

• Estimated risk quotients (RQs) from use of 2,4-D DMAS in weed control through direct subsurface application to water bodies exceed the endangered species LOC for freshwater and estuarine fish, and estuarine invertebrates. However, there are currently no endangered

estuarine/marine invertebrates. • Estimated RQs from use of 2,4-D BEE in weed control through direct subsurface application to water bodies exceed the endangered species LOC for freshwater fish and invertebrates and

estuarine fish. • Estimated RQs from use of 2,4-D acid and amine salts in rice paddies exceed endangered species LOCs for freshwater invertebrates. The rice model used to predict these EECs is a screening level model which predicts concentration in tailwater at the point of release from the paddy. It is anticipated that once released, the concentration will be reduced and subsequently, RQs will decrease. • The scenario of the direct application to water for weed control for the acid and amine salts indicates a endangered species concern for aquatic vascular plants. Estimated RQs from use of 2,4-D BEE for direct application to water for weed control exceed all LOCs for both vascular and non-vascular plants. Potential risk to endangered non-vascular plants is not evaluated because at this time there are no listed endangered non-vascular plant species. • Target acute RQs for birds and mammals were exceeded for endangered species risks for multiple crops and multiple animal weights. Banded and granular applications result in higher RQs at more use sites.• Target acute LOCs for both non-endangered and endangered plants were exceeded for nongranular and granular for multiple uses, based on predicted EECs.Page 74 of 304 In December 2004, EPA completed a refined assessment for 2,4-D's potential effects to 26 environmentally significant units (ESUs) of Pacific Salmonids (salmon and steelhead). That refined assessment concluded that 2,4-D has "no effect" on these species when used according to label directions on terrestrial sites. Further, that a ssessment concluded that use of 2,4-D on rice "may affect but is not likely to adversely affect" 4 ESU's and will have "no effect" on 22 ESU's. That same analysis concluded that use of 2,4-D "may affect" each of the 26 ESU's when used for aquatic weed control purposes. As a result of that assessment, EPA is currently engaged in consultation with the National Marine Fisheries Service regarding those scenarios that resulted in a determination that 2,4- D "may affect but is not likely to adversely affect" the species, or "may affect" the species.

The Agency’s level of concern for endangered and threatened freshwater fish and invertebrates, estuarine invertebrates, birds, mammals, aquatic vascular plants, and terrestrial non-target plants is exceeded for the use of 2,4-D. The Agency recognizes that there are no Federally listed estuarine/marine invertebrates. The registrant must provide information on the proximity of Federally listed freshwater vascular plants, birds, mammals, and non-target terrestrial plants (there are no listed estuarine/marine invertebrates) to the 2,4-D use sites. This requirement may be satisfied in one of three ways: 1) having membership in the FIFRA Endangered Species Task Force (Pesticide Registration [PR] Notice 2000-2); 2) citing FIFR A Endangered Species Task Force data; or 3) independently producing these data, provided the information is of sufficient quality to meet FIFRA requirements. The information will be used by the OPP Endangered Species Protection Program to develop recommendations to avoid adverse effects to listed species.

6. Risk Characterization

The Agency has considered available information on 2,4-D’s toxicity, use areas, usage, fate properties, and application methods and formulations in characterizing ecological risks related to normal use. Upon review and synthesis of this information, the Agency concludes use of 2,4-D for aquatic weed control presents risk to aquatic organisms, while 2,4-D use on terrestrial sites presents the greatest potential risks to small mammals, birds, and non-target terrestrial plants.

a. Characterization of risk to aquatic organisms from direct aquatic application

Whereas the maximum labeled target concentration for control of aquatic weeds is 4 ppm, the typical target concentration is 2 ppm. Moreover, the risks to aquatic organisms were estimated based on a 2,4-D application that resulted in a whole-reservoir concentration of 4 ppm. Treating 100% of the water body would result in a large amount of decaying plant life, thereby creating an oxygendepleted environment that would most likely result in fish kills. To avoid that scenario, the 2,4-D label advises the applicator to avoid treating more than 50% of a water body in a single application. In actual practice, aquatic weeds that 2,4-D contro ls tend to grow in littoral zones. As a result, generally a maximum of 20-30% of a water body is treated in a single application. Applying the typical rate of 2 ppm, and taking into account a typical maximum treated area of 30% would decrease calculated RQs by approximately 6-fold. While noting the potential risks to aquatic organisms from the direct application of 2,4-D for the control of aquatic weeds identified above, it is impor tant to note the benefits gained through the direct application of 2,4-D to aquatic bodies, for the control of invasive species. The U.S Army Corps ofPage 75 of 304 Engineers (USACE), among others, has identified 2,4-D as an important tool for protecting the nation's waters from the invasion and establishment of some of the world's worst species of exotic nuisance vegetation. 2,4-D has a reputation as a selective and economical means to remove invasive plants, enhance the growth and recovery of desirable native vegetation, restore water quality, reduce sedimentation rates in reservoirs, and improve fish and wildlife habitat. 2,4-D products are used to control invasive weeds, such as Eurasian watermilfoil ( Myriophyllum spicatum ) in the northern tier states and water hyacinth ( Eichhornia crassipes ) in the Gulf Coast states. Effective control of these plants can benefit public health with respect to reducing levels of mosquito habitat. In addition, according to USACE, no other product (or alternative technique) can control these plants in a more cost-effective manner (K. Getsinger, USACE, Public Comment; Docket ID# OPP-2004-0167-0053).

b. Characterization of risk to mammals from terrestrial use

All of the calculated RQs for mammalian acute risk for the non-granular use of 2,4-D were based on maximum labeled application rates. The QUA from BEAD (Quantitative Usage Analysis for 2,4-D, Case Number: 0073, Date: 8-9-01, A. Halvorson) suggests that the average applicationrates for many crops are considerably less than the modeled maximum application rates. For nongranular spray application mammalian acute concerns, the highest RQ was 1.72 for use on asparagus for small mammals feeding on short grass based on a maximum application rate of 4 lbs ae/acre; however, the average application rate was only 1.10 lbs ae/acre (BEAD QUA). If the modeled application rate was reduced to the reported average application rate of 1.10 lbs ae/acre for asparagus, the RQ would be 1.08 which is still above the acute LOC of 0.5. However, asparagus is representative of a minor 2,4-D use, and risk to mammals from use of 2,4-D on asparagus would be minimal, given that fact. To add context to the acute mammalian assessment, the effect of assuming an average application rate was determined. Major 2,4-D crops include pasture/rangeland, turf, wheat, corn, and soybeans. For pasture/rangeland, the highest acute RQ was 0.86 for small mammals feeding on short grass based on a maximum application rate of 4 lbs ae/acre. However, the average application rate was only 0.62 lbs ae/acre (BEAD QUA). If the modeled application rate was reduced to 0.62 lbs ae/acre for pasture/rangeland, the resulting RQ is 0.31 which is below the acute LOC, but above the restricted use LOC of 0.2. Similar trends are noted for other major use sites. Calculated chronic risks to mammals were greatest for small herbivores/insectivores. For 15 g mammalian herbivores/insectivores, chronic RQs based on maximum residues and mean residues ranged from <1 to 200 and <1 to 70, respectively. For major use sites, including rangeland/pasture, RQs were approximately 100. These chronic risk estimates are likely conservative as described

below.

Exposure The chronic RQs calculated for mammalian herbivores/insectivores are based on conservative estimates of exposure that are not likely to occur in nature. In the example of pasture/rangeland, the chronic RQ of approximately 100 for maximum residues (35 for mean residues) was calculated based on an application rate of 4 lbs ae/A. This maximum application rate was determined based on the knowledge that the maximum rate of 2 lbs ae/A may be applied twice per year, at a 30 day interval. However, the Biological and Economic Analysis Division within OPP has determined that the average application rate on pasture/rangeland is only 0.62 lbs ae/acre (BEAD QUA). Moreover, information from several state contacts indicate that a once per year application of less than 1 lb ae/APage 76 of 304 is typical (personal communications). As the typical rate is approximately 25% of the assessed rate, use of the typical rate would be expected to decrease the RQ for the pasture/rangeland scenario to approximately 25 for maximum residues and 9 for mean residues.

A second example of the conservative assumptions included in the assessment of exposure to mammalian herbivores/insectivores is the assumption that 100% of the long term diet is limited to single food types foraged only from treated fields . The assumption of 100% diet from a single food type may be realistic for acute exposures, but diets are likely to be more variable over longer periods of time. Moreover, currently Agency models do not account for the uptake of 2,4-D by plants and therefore assume that all non-dissipated pesticide applied to the field is present for exposure to organisms. In fact, many pesticides, including 2,4-D, are systemic and are absorbed by plants in the field so that the current approach may overestimate the amount of 2,4-D available for exposure in terrestrial systems. Therefore, the percent of diet assumption is likely to be conservative and will tend to overestimate potential risks for chronic exposure, especially for larger organisms that have larger home ranges.

Hazard The mammalian chronic risk assessment utilized a toxicity endpoint from a rat two-generation reproduction test. This endpoint was the NOAEL of 5 mg/kg-bw/day for growth rate reductions in F1b offspring. The agency considers that reduced growth (reductions in pup body weight gains relative to controls) in offspring as a potentially important effect with implications for the survivability of offspring and therefore a potential impact on fecundity. Because the endpoint is the no effect level for this measured parameter, evaluations of the significance of any exposures above this endpoint were conducted. From the same two-generation rat reproduction study, the LOAEL associated with F1b pup growth rate reducti on was 20 mg/kg-bw/day. This LOAEL corresponds with body-weight gain reductions of 15 to 17 % (males and females) relative to controls. The 20 mg/kg-bw/day dose level also represents a NOAEL for increased gestational length and incidents of skeletal anomalies and reduced ossification in F1b pups. The LOAEL for these gestational and skeletal effects is 80 mg/kg-bw/day.

In addition to the available rat two generation reproduction study, a number of developmental toxicity studies are available in rats and rabbits for the acid, amine salts and esters. These data are from studies involving short-term exposures during critical periods of fetal development and are useful to determine if long-term or short-term e xposure events are necessary for the types of effects observed in the two-generation reproduction study. MRID 41747601, developmental toxicity in rabbits with the acid, shows a NOAEL of 30 mg/kg-bw/d ay for increased rate of fetal abortions, with a LOAEL 90 mg/kg-day. Similar NOAEL and LOAEL thresholds were observed in studies in rabbits with the amine salts and esters of 2,4- D. MRID 000251031, developmental toxicity in rats with the acid, showed a NOAEL of 25 mg/kg-bw /day and a LOAEL of 75 mg/kg-bw/day for

increased incidence of skeletal malformations. Sim ilar results are reported in other studies with rats involving the amine salt and esters of 2,4-D.

c. Characterization of risk to birds from terrestrial use

The assessment of risk to birds from exposure to 2,4-D is likely conservative as follows. Currently, Agency models do not account for the uptake of 2,4-D by plants and therefore assume thatPage 77 of 304 all non-dissipated pesticide applied to the field is present for exposure to organisms. In fact, many pesticides, including 2,4-D, are systemic and are absorbed by plants in the field and therefore, the current approach may overestimate the amount of 2,4-D available for exposure in terrestrial and aquatic systems. For non-granular spray application, the highest acute avian RQ (3.50) was from the cranberry scenario, for birds feeding on short grass. That assessment was based on a maximum application rate of 4 lbs ae/acre; however, the average application rate is 1.83 lbs ae/acre (see the BEAD QUA). If the modeled application rate was reduced to 1.83 lbs ae/acre for cranberries, and an assumption made that the resulting EEC will be reduced linearly, the RQ would be 1.60. To determine the hazard associated with acute exposures to birds, the assessment has considered two types of data, a suite of dietary studi es and a suite of gavage studies. For avian acute exposures, the dietary studies result in non-definitive endpoints which are not appropriate for estimating risk. Therefore, the assessment has relied on the gavage studies to estimate avian acute risks. The Agency recognizes that this approach may overestimate risk to birds due to the fact that birds would not typically be expected to consume 2,4-D in this manner. Given the conservative assumptions in both exposure scenarios and hazard determinations, the Agency finds that the acute risk to birds from 2,4-D exposure does not exceed the Agency’s level of

concern. Potential chronic risks to birds is limited to a few use sites. These include non-cropland, forest, asparagus, and cranberry. The RQs for these sites range from 1 -1.09. Further characterization of these use sites by evaluating average application rates versus maximum application rates lower these RQs to below the LOCs.

d. Characterization of risk to non-target plants from terrestrial use

Acute LOCs for both non-endangered and endangered terrestrial plants were exceeded for nongranular and granular uses at many use sites. Consideration of average application rates did not result in exposure below LOCs. However, the exposure estimates used to develop the RQs were likely conservative, as follows. In the exposure calculation for non-target plants, the major contributor is run-off from the application site. The runoff and leaching vulnerability schemes used in this assessment were adapted from a vulnerability scheme developed by the USDA (Kellogg et al, 1998), and incorporate several conservative assumptions. For example, a 1-in-10 year rain event is modeled, resulting in 3 cm of runoff water. USDA identified several caveats to be considered when using this vulnerability scheme which could contribute to the uncertainty associat ed with this assessment. Among these are that estimates of runoff and leaching vulnerability are estimated through the use of algorithms (i.e. they represent estimates of vulnerability and not actual field measurements), fate and transport processes (i.e. dilution and recharge) are not included, farm management practices are not considered, and some watershed estimates are based on major crops only. The effect of these factors on the vulnerability assessment is unknown, however, there is a low proba bility that a 1-in-10 year rain event will coincide with the first few days following a 2,4-D application at the maximum application rate. Also, it is likely that farm management practices would be in place to limit run-off, as run-off events are detrimental to the farm as a whole for reasons other than pesticide damage. Currently Agency models do not account for the uptake of 2,4-D by plants and therefore assume that all non-dissipated pesticide applied to the field is present for exposure to organisms. In fact, many pesticides, including 2,4-D, are systemic and are absorbed by plants in the field andPage 78 of 304 therefore, the current approach may overestimate the amount of 2,4-D available for exposure in terrestrial and aquatic systems.Page 79 of 304 IV. Risk Management, Reregistration, and Tolerance Reassessment Decision

A. Determination of Reregistration Eligibility

Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission of relevant data concerning an active ingredient, whether or not products containing the active ingredient are eligible for reregistration. The Agency has previ ously identified and required the submission of the generic (i.e., active ingredient-specific) data to support reregistration of products containing 2,4-D as an active ingredient. The Agency has completed its review of these generic data, and has determined that the data are sufficient to support reregistration of all products containing 2,4-D .

The Agency has completed its assessment of the dietary, occupational, residential, and ecological risk associated with the use of pestic ide products containing the active ingredient 2,4-D . Based on a review of these data and on public comments on the Agency’s assessments for the active ingredient 2,4-D , the Agency has sufficient information on the human health and ecological effects of 2,4-D to make decisions as part of the tolerance reassessment process under FFDCA and reregistration process under FIFRA, as amended by FQPA. The Agency has determined that 2,4-D containing products are eligible for reregistration provided that: (i) current data gaps and confirmatory data needs are addressed; (ii) the risk mitigation measures outlined in this document are adopted; and (iii) label amendments are made to implement these measures. Label changes are described in Section V. Appendix A summarizes the uses of 2,4-D that are eligible for reregistration. Appendix B identifies the generic data requirements that the Ag ency reviewed as part of its determination of reregistration eligibility of 2,4-D, and lists the s ubmitted studies that the Agency found acceptable. Data gaps are identified as generic data requireme nts that have not been satisfied with acceptable

data.

Based on its evaluation of 2,4-D, the Agency has determined that 2,4-D products, unless labeled and used as specified in this document, would pres ent risks inconsistent with FIFRA. Accordingly, should a registrant fail to implement any of the ri sk mitigation measures identified in this document, the Agency may take regulatory action to address the risk concerns from the use of 2,4-D . If all changes outlined in this document are incorporated into the product labels, then all current risks for 2,4-D will be adequately mitigated for the purposes of this determination.

B. Public Comments and Responses

Through the Agency’s public participation process, EPA worked extensively with stakeholders and the public to reach the regulatory decisions for 2,4-D . During the public comment period on the revised risk assessments, which closed on March 14, 2005, the Agency received comments from numerous parties. These comments in their entirety are available in the public docket (OPP-2004- 0167) at http://www.epa.gov/edockets. Individual responses to these comments are also available in the public docket (OPP-2004-0167).

The RED and technical supporting documents for 2,4-D are available to the public through EPA’s electronic public docket and comment system, EPA Dockets, under docket identification number OPP-2004-0167. The public may access EPA Dockets at http://www.epa.gov/edockets. InPage 80 of 304 addition, the 2,4-D RED may be downloaded or viewed through the Agency’s website at http://www.epa.gov/pesticides/reregistration/status.htm.

C. Regulatory Position

1. Food Quality Protection Act Findings

a. “Risk Cup” Determination

As part of the FQPA tolerance reassessment pr ocess, EPA assessed the risks associated with this pesticide. EPA has determined that risk from dietary (food sources only) exposure to 2,4-D is within its own “risk cup.” An aggregate assessment was conducted for exposures through food, drinking water, and residential uses. The Agency has determined that the aggregate human health risks from these combined exposures are within the risk cup. In other words, EPA has concluded that the tolerances for 2,4-D meet FQPA safety standards. In reaching this determination, EPA has considered the available information on the special sensitivity of infants and children, as well as aggregate exposure from food, water, and residential uses.

b. Determination of Safety to U.S. Population

The Agency has determined that the established tolerances for 2,4-D , with amendments and changes as specified in this document, meet th e safety standards under the FQPA amendments to section 408(b)(2)(D) of the FFDCA, and that there is a reasonable certainty no harm will result to the general population or any subgroup from the use of 2,4-D. In reaching this conclusion, the Agency has considered all available information on the toxicity, use practices and exposure scenarios, and the environmental behavior of 2,4-D . Both the acute dietary (food alone) and chronic dietary risk from 2,4-D are not of concern.

Acute and chronic risks from drinking water exposures are not of concern. Models have been

used to estimate surface water concentrations. The surface water EECs are below the DWLOCs for all population subgroups. Drinking water monitoring data from the USGS NAWQA Program confirm that concentrations of 2,4-D are less th an modeled estimates for surface water. The maximum concentration detected in ground water monitoring (from USGS NAWQA) has been used as the ground water EEC. The ground water EEC is below the DWLOCs for all populations subgroups.

EPA has determined that the established tolerances for 2,4-D, with amendments and changes as specified in this document, meet the safety standards under the FQPA amendments to section 408(b)(2)(C) of the FFDCA, that there is a reasonabl e certainty of no harm for infants and children. The safety determination for infants and children considers the factors noted above for the general population, but also takes into account the possibility of increased dietary exposure due to the specific consumption patterns of infants and children, as well as the possibility of increased susceptibility to the toxic effects of 2,4-D residues in this popul ation subgroup. FQPA directs EPA, in setting pesticide tolerances, to use an additional tenfold margin of safety to protect infants and children, taking into account the potential for pre- and postnatal toxicity and the completeness of the toxicology and exposure databases. The statute authorizes EPA to replace this tenfold FQPA safety factor with aPage 81 of 304 different FQPA factor only if reliable data demons trate that the resulting level of exposure would be

safe for infants and children.

FQPA Special Safety Factor

EPA concludes that the toxicology database for 2,4-D is substantially complete since all required studies have been submitted. After evaluating hazard and exposure data for 2,4-D, EPA removed the default 10X FQPA special safety factor. The toxicity database for 2,4-D includes acceptable developmental and reproductive toxicity studies. Developmental toxicity studies were conducted in both rats and rabbits for most 2,4-D forms. There is qualitative evidence of susceptibility in the rat developmental toxicity st udy with 2,4-D acid and DEA salt where fetal effects (skeletal abnormalities) were observed at a dose level that produced less severe maternal toxicity (decreased body-weight gain and food consumption). There is no evidence of increased (quantitative or qualitative) susceptibility in the prenatal devel opmental toxicity study in rabbits or in the 2- generation reproduction study in rats on 2,4-D. Regarding the 2,4-D amine salt and ester forms, no evidence of increased susceptibility (quantitativ e or qualitative) was observed in the prenatal developmental toxicity study in rat and rabbits (e xcept for 2,4-D DEA) dosed with any of the amine salts or esters of 2,4-D. There is evidence of increased susceptibility (qualitative) in the prenatal developmental study in rabbits for 2,4-D DEA salt. After establishing developmental toxicity endpoints to be used in the risk assessment with traditional uncertainty factors (10x for interspecies variability and 10x for intraspecies variability), the Agency has no residual concerns for the effects seen in the developmental toxicity studies. Therefore, the 10X FQPA special safety factor was reduced to 1X.

Database Uncertainty Factor

The EPA has concluded that there is a concern for developmental neurotoxicity resulting from exposure to 2,4-D, and that a developmental neurotoxicity (DNT) study in rats is required for 2,4-D. The Agency has also concluded that a 2-generation reproduction study is required to address both the concern for thyroid effects and immunotoxicity, as well as a more thorough assessment of the gonads and reproductive/developmental endpoints. EPA has determined that a 10X database uncertainty factor (UF DB ) is needed to account for the lack of these studies. This Uncertainty Factor is applied only to exposure scenarios that are expected for children or pregnant women, and thus is not applied to occupational exposure scenarios.

2. Endocrine Disruptor Effects

EPA is required under the FFDCA, as amended by FQPA, to develop a screening program to determine whether certain substances (including all pesticide active and other ingredients) “may have

an effect in humans that is similar to an eff ect produced by a naturally occurring estrogen, or other endocrine effects as the Administrator may designate.” When the appropriate screening and/or testing protocols being considered under the EDSP have been developed, 2,4-D may be subject to additional screening and/or testing to better characterize effects related to endocrine disruption.

3. Cumulative RisksPage 82 of 304 The Food Quality Protection Act (FQPA) requires EPA to consider "available information" concerning the cumulative effects of a particular pes ticide's residues and "other substances that have a common mechanism of toxicity" when considering whether to establish, modify, or revoke a

tolerance. Potential cumulative effects of chem icals with a common mechanism of toxicity are considered because low-level exposures to multiple chemicals causing a common toxic effect by a common mechanism could lead to the same adverse health effect as would a higher level of exposure to any one of these individual chemicals. 2,4-D is a member of the alkylphenoxy herbicide class of pesticides. A cumulative risk assessment has not b een performed as part of this human health risk assessment because the Agency has not yet made a determination of whether 2,4-D and other alkylphenoxy compounds have a common mechanism of toxicity. For information regarding EPA’s efforts to determine which chemicals have a common mechanism of toxicity and to evaluate the cumulative effects of such chemicals, see the po licy statements by the EPA’s Office of Pesticide Programs concerning common mechanism determinations and procedures for cumulating effects

from substances found to have a common mechanism on EPA’s website at http://epa.gov/pesticides/cumulative/ .]

4. Special Review Disposition

2,4-D has been in pre-Special Review status since September 22, 1986, because of carcinogenicity concerns. In 1994 a Science Adviso ry Panel/Scientific Advisory Board classified 2,4-D as a Group D carcinogen (not classifiable to human carcinogenicity). The Agency requested further histopathological examinations of rat brain tissues and mouse spleen tissues in question. These exams were submitted and reviewed, and on March 16, 1999, The Agency notified the 2,4-D Task Force that the Agency would continue to classify 2,4-D as a Group D carcinogen. Also, in a 1994 review of all relevant epidemiological st udies, EPA found that none of the more recent epidemiological studies definitively linked human cancer cases to 2,4-D. A final notice of the Agency’s intent not to initiate Special Review w ill be published in concert with the release of this

RED document.

5. Dioxin Contaminants

Exposure In 1987, a DCI titled “Data Call-In Notice for Product Chemistry Relating to Potential Formation of Halogenated Dibenzo-p-dioxin or Dibenzofuran Contaminants in Certain Active Ingredients,” was issued to identify pesticides that may contain halogenated dibenzo-p-dioxin and dibenzofuran contaminants. A second DCI in 1987, “Data Call-In for Analytical Chemistry Data on Polyhalogenated Dibenzo-p-Dioxins/Dibenzofura ns (HDDs and HDFs),” was issued, under which registrants whose products did not qualify for an exemption or waiver were required to generate and submit analytical methods and certification limits of dioxins and furans. The specific results of analysis of multiple 2,4-D technical products, submitted to EPA in response to both DCIs, are considered confidential business information (CBI) and cannot be released by EPA to the public. In summary, two of eight technical products had concentrations of 2,3,7,8- tetrachlorodibenzo-p-dioxin (TCDD; dioxin) greater than the limit of quantitation (LOQ; LOQ = 0.1 ppb) and three of eight had concentrations of 1,2,3,7,8-pentachlorodibenzo-p-dioxin (PCDD) greater than the LOQ (LOQ = 0.5 ppb). In 1991, the EPA’s Office of Research and De velopment (EPA/ORD) began an assessment ofPage 83 of 304 the health risks of exposure to dioxins. The most recent revision of that assessment has recently been submitted to the National Academies of Science (NAS) for review. In that document and elsewhere, a source inventory of dioxin was published. As a result of the 1987 DCI data, and the amount of 2,4- D applied to agricultural and residential settings (approximately 50 million pounds per year), the current draft dioxin source inventory (see The Inve ntory of Sources and Environmental Releases of Dioxin-Like Compounds in the United States: The Year 2000 Update , EPA/600/P-03/002A, External Review Draft, March 2005) identifies 2,4-D as a source of dioxin emissions (28.9 g TEQDFWHO98; TEQ = Toxic EQuivalent amount, or an am ount of total dioxin equivalent to 28.9 g of the most toxic dioxin congener, 2,3,7,8-TCDD). It should be noted that this estimate of dioxin release assumes all products are contaminated and does not take into account manufacturing changes since the DCI. Moreover, that estimate is specific for the year 1995, and therefore should not be considered

the current estimate of dioxin release. The 1995 estimate for dioxin emissions from 2,4-D, taken together with NAS estimates for

2002/2004 releases from other sources of dioxin in th e U.S., suggest that 2,4-D applications to land ranks seventh (2.6% of all dioxin sources) behind backyard burning (57%), sewage sludge application (6.9%), residential wood burning (5.7%), coal-fir ed utilities (5.4%), diesel trucks (3.2%), and secondary aluminum smelting (2.6%) in terms of dioxin emissions (see The Inventory of Sources and Environmental Releases of Dioxin-Like Compounds in the United States: The Year 2000 Update

, EPA/600/P-03/002A, External Review Draft, March 2005) . According to 2,4-D registrants, since the 1990’s, the manufacturing processes for 2,4-D and its chemical intermediate, dichlorophenol, have been modified, and those modifications decrease the chance that TCDD and PCDD are formed during the manufacturing process. The following descri ption of the current 2,4-D manufacturing process summarizes information submitted by the 2,4-D Task Force II. A key chemical intermediate in the manufactur e of 2,4-D is 2,4-dichlorophenol (2,4-DCP) and the purity of this intermediate has a strong correlation to the purity of 2,4-D acid produced from it. In the manufacture of 2,4-DCP, multiple positions around the phenyl ring structure may be chlorinated. The desired positions for chlorination are carbons two and four of the phenyl ring, but the reaction may yield small quantities of compounds chlorinated at different positions. Certain combinations of these chlorinated structures may form precursors to the dioxin 2,3,7,8-TCDD. Manufacture of the 2,4-DCP intermediate has been optimized by controlling processing conditions necessary to drive the chlorination reaction to the preferred two and four carbon positions, thereby limiting the formation of impurities that can lead to dioxin formation. Controlled temperature and residence time during the chlorination reaction, programmed addition of the chlorinating agent, and efficient agitation in the reaction vessel are pro cessing factors that contribute to the purity of 2,4- DCP. Additionally, distillation of 2,4-DCP is a t echnique that may be employed post-chlorination to increase purity. Moreover, quality control sampling and analytical procedures are also utilized to verify product quality at various steps of the 2,4-DCP process. According to Results of testing of 2,4-DCP, performed in response to the Toxic Substances Control Act (TSCA) Dioxin/Furan Test Rule, showed no detectable concentrations of 2,3,7,8-substituted tetra- through hepta-CDD/CDFs. In the manufacture of 2,4-D acid per se , there are additional process conditions and procedures that must be controlled to maximize yield and purity. Details regarding these measures are dependent on specific manufacturing methodologies and, as such, are protected under FIFRA Section 10 as

Confidential Business Information.

Anticipated ResiduesPage 84 of 304 The Agency’s most recent evaluations of anticipated dioxin and furan residues resulting from 2,4-D applications are based on the concentrations of dioxins and furans present in technical grade 2,4-D as determined by review of analytical data submitted in response to the 1987 DCI. In those evaluations, completed in the early 1990's, the ratios of individual chlorodibenzo-p-dioxin (CDD; dioxin) or chlorodibenzo-p-furan (CDF; fura n) contaminant concentrations to 2,4-D acid concentrations were calculated, and those ratios were used with 2,4-D tolerance expressions to calculate an anticipated residue in eggs, fruits, grains, kidney (hogs), meat (hogs), milk, nuts, poultry, and sugarcane, for each detected dioxin or furan. For each technical 2,4-D formulation for which the Agency received data, calculation of an anticipated dietary exposure was based on a worst-case scenario in which the highest anticipated residue was used, and an assumption was made that 100% of the diet consisted of the food item with the highest anticipated residue.

Toxicological Significance Based on the calculation of dietary exposures, using the worst-case scenario described above, both the cancer and non-cancer risks from dietary expos ure to dioxins and furans as contaminants of 2,4-D acid were considered to be of no toxicological concern at the time of the assessment.

Risk Management Members of the 2,4-D Task Force II have submitted information about the current manufacturing process for the 2,4-D intermediate, 2,4-DCP, as well as for 2,4-D acid itself, and have included in their submissions explanatory text on how current manufacturing processes minimize the chance of dioxin and furan formation. To confirm that the changes to the manufacturing processes since the time of the 1987 DCI have resulted in lower concentrations of dioxin congeners in technical 2,4-D products, the Agency is requiring that five recent batches of all technical products be analyzed for 2,3,7,8-TCDD, 2,3,7,8-TCDF and their respective higher substituted chlorinated congeners using validated analytical methods. The Agency is specifying that the manufacturers use the most current state-of-the art laboratory methods for measuri ng 2,3,7,8-TCDD and TCDF at levels less than 1 part per trillion (EPA Method 1613, Tetra- through Octa -Chlorinated Dioxins and Furans by Isotope Dilution HRGC/HRMS). Because 1,2,3,7,8-PeCDD is equi-potent to 2,3,7,8-TCDD in the TEF scheme, the Agency is adding this compound to our testing requirements. The pentachloro-congener was reported as present in 2,4-D in the 1987 Data Call-in. Registrants are encouraged to submit their analytical methods and sampling plans to the Agency for review prior to commencing these studies.

D. Tolerance Reassessment Summary

1. Tolerances Currently Listed Under 40 CFR §180.142

Tolerances for residues of 2,4-D in/on plant RACs and processed commodities, fish, and potable water are currently expressed in terms of 2,4-D per se [40 CFR §180.142(a)(1-6 and 9-12) and (b)]. Tolerances for residues in livestock co mmodities are currently expressed in terms of 2,4-D and/or its metabolite 2,4-dichlorophenol (2,4-DCP) [40 CFR §180.142(a)(8)]. EPA has concluded that 2,4-D is the residue of concern and that tolerances listed in 40 CFR §180.142 are to be defined as residues of 2,4-D, both free and conjugated, determined as the acid.

The listing for 2,4-D tolerances in 40 CFR §180.142 should be recodified into parts (a), (b), (c), and (d). Part (a) should be reserved for commoditie s with permanent tolerances reflecting at least aPage 85 of 304 preharvest (field) or postharvest use, part (b) for Section 18 emergency exemptions, part (c) for tolerances with regional use registrations, and part (d) for commodities bearing 2,4-D residues solely inadvertently, including irrigated crops. A summary of 2,4-D tolerance reassessments and recommended recodifications is presented in Table 37 along with any recommended changes in commodity definitions.

Note that some commodities currently are the subject of two or more separate tolerances depending on the use pattern, the 2,4-D form applied, timing of treatment (preharvest or postharvest), or degree of intent to deposit residues (direct treat ment or inadvertent). Direct treatment involves intentional field treatment of crop sites or postharvest treatment of harvested commodities on registered labels. Inadvertent deposition involves the incidental exposure of crops when water passing through 2,4-D-treated irrigation ditchbanks or diverted from 2,4-D-treated bodies of water is used to irrigate crops. EPA is proposing to remove most such use-pattern or FIFRA-related language at 180.142. Due to the complicated nature of the routes of residue deposition, we are proposing to subsume the lower tolerances in the highest existing or reassessed tolerance established in the same commodity - even if that results in 180.142(a) containing some tolerances that reflect 2,4-D residues that could potentially result from two or more exposure routes. An example is citrus which has tolerances for 2,4-D in the RAC resulting from preharvest use + postharvest use, irrigation ditchbank treatment (inadvertent), and direct water body treatment (also inadvertent). If there are no registered uses on a given commodity and residues are likely to occur on that commodity solely inadvertently, i.e., via irrigation, then the tolerance in that commodity will be located under 180.142(d). In most cases, residues, and hence the tolerance, resulting from a direct, registered use are higher than the residues (and the tolerance) resulting inadvertently. EPA proposes these revisions because we know that an enforcement agency, having detected 2,4-D residues in a commodity, would: (i) not be able to distinguish which form of 2,4-D had been applied; (ii) rarely be able to determine who applied the pesticide, when, or for what purpose; and (iii) not know whether a sample is violative if the 2,4-D

concentration falls between two tolerance levels.

Tolerances Listed Under 40 CFR §180.142(a)(1) : Adequate data are available to reassess the established tolerances for the following commodities: apple, apricot, citrus fruit, pear, potato and quince. The available apple and pear residue data will support a crop group tolerance at 0.05 ppm for pome fruits under the redesignated section 180.142(a). The separate tolerances on apple, pear, and quince should be revoked concomitant with establishing a new pome fruit crop group tolerance. The 5 ppm tolerance on citrus fruits should be reassessed to 3.0 ppm to reflect any combination of the preharvest use on citrus, the postharvest use of 2,4-D on lemons in the U.S., a similar postharvest use on oranges imported into the U.S., and any inadvertent (irrigation) residues that may be incurred as a result of 2,4-D use in aquatic sites. The tolerances in citrus fruit of 0.1 ppm at 180.142(a)(3) and 1.0 ppm at 180.142(a)(6), both reflecting inadvertent residues, should be revoked as they will be subsumed by the reassessed tolerance of 3.0 ppm at 180.142(a). The tolerance for residues in/on apricots should be revoked as residues in/on apricots will be covered by the tolerance in stone fruits.

Tolerances Listed Under 40 CFR §180.142(a)(2) :Page 86 of 304 Adequate data are available to reassess all the tolerances listed under 180.142(a)(2). All reassessed tolerances should be recodified under the revised section 180.142(a). Based on the available residue data, the current tolerances on grass hay and tree nuts are adequate. However, tolerances can be lowered on the following commodities: blueberry, sweet corn (kernel plus cob with husks removed), corn forage and grain, cranberry, stone fruits, grape, grass forage, pistachio, rice straw, sorghum forage, grain and stover, and sugarcane. Tolerances should be increased on the following commodities: corn stover, rice grain, and wheat grain and forage.

The available residue data for wheat commodities will be used to reassess tolerances on similar commodities from barley, millet, oats, and rye. Tolerances should be increased accordingly on: barley grain; millet grain, forage and straw; oat forage and grain; and rye forage and grain. The tolerance for residues in sugarcane forage should be revoked because it is no longer considered a significant livestock feed item (OPPTS GLN 860.1000).

Tolerances Listed Under 40 CFR §180.142(a)(3) : Tolerances listed in 40 CFR §180.142(a)(3) are established for negligible residues of 2,4-D in irrigated crops from application of its dimethylamine salt to irrigation ditch banks in the Western United States in programs of the Bureau of Recl amation, U.S. Department of Interior; cooperating water user organizations; the Bureau of Sport Fish eries, U.S. Department of Interior; Agricultural Research Service, U.S. Department of Agriculture ; and the Corps of Engineers, U.S. Department of Defense. Where tolerances are established at higher levels resulting from other uses of 2,4-D, the higher tolerance applies also to residues in crops from the irrigation ditch bank use cited in this paragraph. The tolerances in crops or crop groups listed under 40 CFR §180.142(a)(3) that do not have a direct treatment tolerance under 180.142(a) should be recodified as 180.142(d), i.e., inadvertent

residue tolerances. The available irrigated crop data support tolerances for inadvertent residues at 0.2 ppm in foliage of legume vegetables (group 7) and non-grass animal feed (group 18) and at 0.05 ppm in/on the following crops groups: bulb vegetables (group 3), legume vegetables (group 6), cucurbit vegetables (group 9), and fruiting vegetables (group 8). In addition, tolerances resulting from the primary use of 2,4-D on grasses, citrus fruits, and tree nuts are high enough to cover any inadvertent residues in these crops that may result from the use of 2,4-D treated irrigation water. Therefore, separate tolerances for inadvertent residues in/on these crops are not required. Separate tolerances for inadvertent residues are unnecessary in pome fruits, stone fruits, pistachios, grapes, blueberry, and strawberry as these crops all have tolerances resulting from the direct use of 2,4-D. However, the tolerances in all of these commodities have been reassessed at 0.05 ppm, the limit of quantitation of the enforcement method, to reflect only direct treatment at this time. It is reasonably possible that inadvertent residues resulting from irrigation with treated water could contribute concentrations of 2,4-D in the commodities necessitating tolerances higher than 0.05 ppm. Therefore, confirmatory irrigated crop residue data are required for a representative perennial crop (strawberry). Also, additional residue data on sugar beets and tops irrigated with water containing 2,4-D at 0.1 ppm are required to permit reassessment of the tolerances in the Root and Tuber Vegetables Group and the Leaves of Root and Tuber Vegetables Group resulting inadvertently due toPage 87 of 304 irrigation with 2,4-D-treated water. These data may also be used to reassess inadvertent tolerances established at 180.142(d) as a result of the 2,4-D RED.

Tolerance Listed Under 40 CFR §180.142(a)(4) : The established tolerance for residues in/on asparagus is reassessed at the current level under the revised tolerance expression and is to be recodified as 40 CFR §180.142(a).

Tolerance Listed Under 40 CFR §180.142(a)(5) The established tolerance for residues in/on strawberry is reassessed at the current level under the revised tolerance expression and is to be recodified as 40 CFR §180.142(a).

Tolerances Listed Under 40 CFR §180.142(a)(6) : Tolerances listed in 40 CFR §180.142(a)(6) are established for residues of 2,4-D from application of its dimethylamine salt for water hyacinth control in ponds, lakes, reservoirs, marshes, bayous, drainage ditches, canals, rivers, and streams that are quiescent or slow moving in programs conducted by the Army Corps of Engineers or other Federal, State, or local public agencies. Where tolerances are established at higher levels from other uses of the dimethylamine salt of 2,4-D on crops included within these commodity groups, the higher tolerances also apply to residues from the aquatic uses cited in this paragraph. Based on the available residue data, the current tolerance in shellfish is adequate and the tolerance in fish can be reduced to 0.1 ppm. Both tolerances should be recodified under the revised section 180.142(a). Tolerances for residues in/on the irrigated crops and crop groups at the current §180.142(a)(6) are set at 1.0 ppm whereas the tolerances in/on the identical crops/crop groups at §180.142(a)(3) are at 0.1 ppm for the irrigation ditchbank use. The recommended/reassessed tolerances from §180.142(a)(3) to be recodified under sections §180.142(a) or §180.142(d) concomitantly address the reassessments/recodifications recommended for tolerances at §180.142(a)(6), depending on whether residues are incurred directly and/or inadvertently, as explained above.

Tolerances Listed Under 40 CFR §180.142(a)(8) : Tolerances listed in 40 CFR §180.142(a)(8) are established for residues of 2,4-D and/or its metabolite 2,4-DCP in livestock commodities. As indicated by the Agency, the regulated residue in animal commodities is 2,4-D (free and conjugated). As a result of this residue definition change, all reassessed livestock tolerances should be recodified to §180.142(a). Based upon the available livestock feeding study, the 0.1 ppm tolerance in milk is reassessed at 0.05 ppm and the tolerances in cattle, goat, horse, and sheep commodities are reassessed at: 0.3 ppm in fat, meat, and meat byproducts except kidney and 4.0 ppm in kidney. The established tolerances for 2,4-D residues in hog commodities may be revoked. Based on the MTDB for swine (1.6 ppm) and the results of the ruminant feeding study, there is no reasonable expectation of finite 2,4-D residues occurring in hog commodities [Category 3 of 40 CFR §180.6(a)(3)]. In addition, the established tolerances for 2,4-D residues in eggs and poultry tissues may be revoked. Based on the results of the 2,4-D poultry metabolism study, there is no reasonable expectation of finite residues in poultry tissu es and eggs [Category 3 of 40 CFR §180.6(a)(3)].Page 88 of 304 Tolerance Listed Under 40 CFR §180.142(a)(9) : Tolerances listed in 40 CFR §180.142(a)(9) are established for residues of 2,4-D from applications of its dimethylamine salt or its butoxyethanol ester for Eurasian water milfoil control in programs conducted by the Tennessee Valley Authority in dams and reservoirs of the TVA system. The tolerance for 2,4-D residues in fish at 40 CFR §180.142(a)(9) should be revoked and this section deleted. There is no need for two 2,4-D tolerances in fish. It has already been recommended that the 1.0 ppm tolerance in fish currently at §180.142(a)(6) be reassessed at 0.1 ppm and that this reassessed tolerance be recodified at the new 40 CFR §180.142(a).

Tolerance Listed Under 40 CFR §180.142(a)(10) : The tolerance listed in 40 CFR §180.142(a)(10) is a regional registration as defined in Sec. 180.1(n) and is established for the residues of 2,4-D in raspberries. The tolerance includes residues from the application of 2,4-D and its N-oleyl-1,3-propylenediamine salt. As the members of Task Force II are not supporting 2,4-D use on this commodity, the tolerance for residues in/on raspberries should be revoked unless another party wishes to support a use on this crop. 40 CFR §180.142(a)(10) should be deleted and any tolerances with regional use registration should be established under the revised section 40 CFR §180.142(c).

Tolerance Listed Under 40 CFR §180.142(a)(11) : A time-limited tolerance of 0.02 ppm has been established for residues of 2,4-D resulting from the preplant use of 2,4-D ester or amine in/on soybean seed [40 CFR §180.142(a)(11)], expired on December 31, 2004. Adequate residue data are available to support permanent tolerances on soybean commodities. Section 180.142(a)(11) should be deleted, and permanent tolerances for 2,4-D residues in/on soybean seed, forage, and hay are recommended to be established under the revised section 180.142(a).

Tolerances Listed Under 40 CFR §180.142(a)(12) : Tolerances listed at 40 CFR §180.142(a)(12) are established for residues of 2,4-D in processed feeds. Such residues may be present therein only as a result of application to the growing crop of the herbicides identified in this section. Tolerances formerly listed at 40 CFR §180.1450 were moved to 40 CFR §180.142(a)(12) (63 FR 34829, 6/26/98). The tolerance for residues in sugarcane bagasse should be revoked because it is no longer considered a significant livestock feed item and has been deleted from Table 1 (OPPTS GLN 860.1000). 40 CFR §180.142(a)(12) should be deleted. The tolerance for 2,4-D residues in milled fractions derived from barley, oats, rye, and wheat should be revoked as the commodity definition will change and the tolerances will be increased and recodified at the revised 40 CFR §180.142(a) for residues in barley bran, rye bran, and wheat bran. No tolerances in other processed products of small grains are necessary because concentration of residues does not occur in them.

Tolerances Listed Under 40 CFR §180.142(a)(13) : Tolerances listed at CFR §180.142(a)(13) are established for residues of 2,4-D in processed foods and potable water.Page 89 of 304 40 CFR §180.142(a)(13) should be deleted. The tolerances for 2,4-D residues in sugarcane molasses and in milled fractions derived from barley, oats, rye, and wheat should be revoked as tolerances will be recodified under the revised 40 CFR §180.142(a) for residues in sugarcane molasses, barley bran, rye bran, and wheat bran. The established tolerance for residues of 2,4-D in potable water should be revoked as EPA/OPPTS/OPP no longer establishes pesticide tolerances in potable water. Instead, the EPA Office of Water establishes Maximum Contaminant Levels (MCLs). An MCL of 0.07 ppm has been established for 2,4-D in drinking water.

Tolerances Listed Under 40 CFR §180.142(b) : The tolerance listed in 40 CFR §180.142(b) is a time-limited tolerance established for 2,4-D in/on wild rice in connection with use of 2,4-D in MN under a Section 18 emergency exemption granted by EPA. The tolerance is set to expire on December 31, 2005. As adequate residue data are available on wild rice grown in MN, a permanent tolerance for rice, wild, grain should be established at 0.05 ppm under 40 CFR §180.142(c).

2. Tolerances to Be Proposed Under 40 CFR §180.142

Tolerances Needed Under 40 CFR §180.142(a) : The revised section will include all permanent tolerances for residues of 2,4-D, defined as residues of 2,4-D, both free and conjugated, determined as the acid. The section will include all plant commodities (excluding crop commodities exposed solely inadvertently), livestock commodities, fish, and shellfish at reassessed levels. In addition, the available residue data indicate that new tolerances should be established for 2,4- D residues in/on the following commodities: almond hulls; aspirated grain fractions; barley bran and straw; oat straw; rice hulls; rye bran and straw; soybean forage, hay, and seeds; and wheat bran and

straw. Once adequate residue data become available, new tolerances should also be established for wheat hay. Wheat hay data will be translated to barley hay, millet hay, and oat hay.

Tolerances Needed Under 40 CFR §180.142(c) : Based on the available residue data, tolerances with regional use registrations should be established for wild rice grain at 0.05 ppm, reflec ting the use of 2,4-D on wild rice grown in MN.

Tolerances Needed Under 40 CFR §180.142(d) : Tolerances for inadvertent 2,4-D residues in irrigated crops that have no registered, direct uses will be moved from paragraph §180.142(a)(3) to paragraph §180.142(d) and the commodity and crop group listings will be revised to the current EPA definitions.

Table 38. Tolerance Reassessment Summary for 2,4-D.

Commodity Tolerance Listed

Under 40 CFR §180.142 (ppm) Reassessed Tolerance (ppm) Comment [Corrected Commodity Definition]

Tolerances Listed Under 40 CFR §180.142 (a) (1) 2Commodity Tolerance Listed

Under 40 CFR §180.142 (ppm) Reassessed Tolerance (ppm) Comment [Corrected Commodity Definition]

Page 90 of 304 Apple 5 Revoke A single tolerance should be established at 0.05 ppm under 180.142(a) for direct and inadvertent

residues in/on the Fruit, pome, group 11

. Apricot 5 Revoke Residues in/on apricots will be covered by the

tolerance for direct and inadvertent residues in stone fruits at 180.142(a).

Fruit, citrus 5

3.0 A tolerance should be established in Fruit, citrus, group 10, recodified as 180.142(a), that will cover the preharvest use on citrus, the postharvest use on lemons in the U.S., the postharvest use on citrus imported into the U.S., and the inadvertent residues due to irrigation with treated water.

Pear 5 Revoke A single tolerance should be established at 0.05 ppm under 180.142(a) for direct and inadvertent

residues in/on the Fruit, pome, group 11

. Potato 0.2 0.40 Includes direct and inadvertent (irrigation) residues. Recodify as 180.142(a).

Quince 5 Revoke Residues in/on quince will be included under the 0.05 ppm tolerance at 180.142(a) for direct and

inadvertent residues in/on the Fruit, pome, group

11

. Tolerances Listed Under 40 CFR §180.142 (a) (2) 2

Barley, grain 0.5 2.0 The submitted data for wheat grain may be translated to barley grain. Recodify as 180.142(a).

Blueberry 0.1 Revoke To be included under the 0.2 ppm Berries group 13 tolerance to be recodified as 180.142(a).

Corn, fodder 20 50.0 Residue data from the 7-day PHI. Recodify as 180.142(a). Corn, stover

Corn, forage 20 6.0 Residue data from the 7-day PHI. Recodify as 180.142(a).

Corn, fresh, sweet, kernel plus cob with

husks removed 0.5 0.05 Recodify as 180.142(a).

Corn, grain 0.5 0.05 Residue data from 7-day PHI. Recodify as 180.142(a).

Cranberry 0.5 Revoke To be included under the 0.2 ppm Berries group 13 tolerance to be recodified as 180.142(a).

Fruit, stone 0.2 0.05 Recodify as 180.142(a). This tolerance will now

cover both direct and inadvertent residues. Fruit, stone, group 12

Grape 0.5 0.05 Residue data on grape are available for the entire U.S. Recodify as 180.142(a).

Grass, hay 300 300 Residue data from the 7-day posttreatment interval (PTI) for Grass, hay. Recodify as 180.142(a).Commodity Tolerance Listed

Under 40 CFR §180.142 (ppm) Reassessed Tolerance (ppm) Comment [Corrected Commodity Definition]

Page 91 of 304 Grass, pasture 1,000 360 Recodify as 180.142(a). Residue data from the 0- day PTI. This new tolerance will now cover both

direct and inadvertent residues. Grass, forage Grass, rangeland 1,000

Millet, forage 20 25 The data for wheat forage, grain, and straw may be translated to millet forage, grain, and straw. The required wheat hay data will be translated to millet hay. Recodify as 180.142(a). This new tolerance

will now cover both direct and inadvertent residues. Millet, grain 0.5 2.0

Millet, straw 20 50

Nut 0.2 0.2 Recodify as 180.142(a). This new tolerance will

now cover both direct and inadvertent residues. Nut, tree, group 14

Oat, forage 20 25 The data for wheat forage may be translated to oat forage. Recodify as 180.142(a). This new tolerance

will now cover both direct and inadvertent residues.

Oat, grain 0.5 2.0 The data for wheat grain may be translated to oat grain. Recodify as 180.142(a). This new tolerance

will now cover both direct and inadvertent residues.

Pistachio 0.2 0.05 Recodify as 180.142(a). This new tolerance will

now cover both direct and inadvertent residues.

Rice 0.1 0.5 Recodify as 180.142(a). This new tolerance will

now cover both direct and inadvertent residues. Rice, grain

Rice, straw 20 10 Recodify as 180.142(a). This new tolerance will

now cover both direct and inadvertent residues.

Rye, forage 20 25 Recodify as 180.142(a). This new tolerance will

now cover both direct and inadvertent residues. The data for wheat forage may be translated to rye forage.

Rye, grain 0.5 2.0 Recodify as 180.142(a). This new tolerance will

now cover both direct and inadvertent residues. The data for wheat grain may be translated to rye grain.

Sorghum, fodder 20 0.2 Recodify as 180.142(a). This new tolerance will

now cover both direct and inadvertent residues. Sorghum, stover

Sorghum, forage 20 0.2 Recodify as 180.142(a). This new tolerance will

now cover both direct and inadvertent residues.

Sorghum, grain 0.5 0.2 Recodify as 180.142(a). This new tolerance will

now cover both direct and inadvertent residues.

Sugarcane 2 0.05 Recodify as 180.142(a). Sugarcane, cane

Sugarcane, forage 20 Revoke Sugarcane forage is no longer considered a significant livestock feed item.Commodity Tolerance Listed

Under 40 CFR §180.142 (ppm) Reassessed Tolerance (ppm) Comment [Corrected Commodity Definition]

Page 92 of 304 Wheat, forage 20 25 Recodify as 180.142(a). This new tolerance will

now cover both direct and inadvertent residues. The 14-day PHI residue data on wheat forage and grain will be used to support tolerances for residues in/on similar commodities of barley, millet, oats, and rye. Wheat, grain 0.5 2.0

Tolerance Listed Under 40 CFR §180.142 (a)(3) 4

Avocado 0.1(N) 0.05 Recodify as 180.142(d).

Cottonseed 0.1(N) 0.05 Recodify as 180.142(d). Cotton, undelinted seed

Cucurbits 0.1(N) 0.05 Recodify as 180.142(d). Vegetable, cucurbit, group

9

Fruit, citrus 0.1(N) Revoke Inadvertent residues will be covered by the crop group tolerance on citrus fruit at 180.142(a).

Fruit, pome 0.1(N) Revoke Inadvertent residues will be covered by the crop group tolerance on pome fruit at 180.142(a).

Fruit, stone 0.1(N) Revoke Revocation of one strone fruit tolerance is necessary to avoid duplication. Inadvertent residues will be covered by the stone fruit group tolerance at 180.142(a)(2) to be recodified as 180.142(a).

Grain, crop 0.1(N) Revoke Separate tolera nces in RACs of each grain will be individually established and recodified as 180.142(a) in/on grain, forage, fodder, stover, or hay, as applicable, to cover both direct and inadvertent residues. Upon formal Agency approval, a small grains subgroup tolerance may be

established.

Grass, forage 0.1(N) Revoke Inadvertent residues will be covered by the grass forage tolerance for direct residues to be recodified as 180.142(a).

Hop 0.1(N) 0.2 Inadvertent residues will be covered by the hop tolerance for direct residues upon establishment at 180.142(a) in response to PP#2E6352.

Leafy vegetables 0.1(N) 0.4 Establish se parate tolerances for inadvertent

residues in the Vegetable, leafy, except brassica, group 4 and Vegetable, brassica, leafy, group 5 at 0.4 ppm under the revised 180.142(d)

Legume, forage 0.1(N) Group 7 - 0.2 Group 18 - 0.2 Establish separate tolerances for the Vegetable, foliage of legume, group 7 and Animal feed, nongrass, group 18 for inadvertent residues under 180.142(d).

Nut 0.1(N) Revoke Inadvertent residues will be covered by the tolerance in the tree nuts crop group at 180.142(a)Commodity Tolerance Listed

Under 40 CFR §180.142 (ppm) Reassessed Tolerance (ppm) Comment [Corrected Commodity Definition]

Page 93 of 304 Root crop vegetables 0.1(N) Group 1 - TBD Group 2 - TBD Group 3 - 0.05 Additional data are required to determine inadvertent residues in sugar beet roots and tops to represent root and tuber vegetables. Establish separate tolerances in the Vegetable, bulb, group 3. When sugar beet data are received, establish separate tolerances in the Vegetable, root and tuber, group 1 and Vegetable, leaves of root and tuber, group 2 . Recodify as 180.142(a).

Seed and pod vegetables 0.1(N) 0.05 Establish tolerance for inadvertent residues at 180.142(d) in the Vegetable, legume, group 6

. Small fruit 0.1(N) 0.2 The 0.2 ppm tolerance in the Berries group 13 , to be recodified at §180.142(a), will also cover

inadvertent residues. Inadvertent residues in/on blueberry and cranberry will also be covered by this group tolerance. Inadvertent residues in/on grape and strawberry will be covered by separate tolerances for direct uses on these crops §180.142(a).

Vegetable, fruiting 0.1(N) 0.05 Establish tole rance for inadvertent residues at 0.05 ppm in the Vegetable, fruiting, group 8 recodified under §180.142(d).

Tolerance Listed Under 40 CFR §180.142 (a)(4) 2

Asparagus 5 5.0 Recodify as §180.142(a).

Tolerance Listed Under 40 CFR §180.142 (a)(5) 2

Strawberry 0.05 0.05 Recodify as §180. 142(a). This tolerance will cover

direct and inadvertent residues.

Tolerance Listed Under 40 CFR §180.142 (a)(6) 2

Crops in paragraph (c) of this section 1.0 Revoke The tolerances to be established under paragraphs §180.142(a) and §180.142(d) will be sufficient to cover inadvertent residues in irrigated crops under the recodified §180.142(a)(6).

Crop groupings in paragraph (c) of this

section 1.0 Revoke The tolerances to be established under paragraphs §180.142(a) and §180.142(d) will be sufficient to cover inadvertent residues in irrigated crops under the recodified §180.142(a)(6).

Fish 1.0 0.10 Residue data for fish and shellfish are from recent tests where fish and shellfish were exposed to 2,4-D under static conditions at 6.0 ppm (1.5x). Recodify to §180.142(a). Shellfish 1.0 1.0

Tolerance Listed Under 40 CFR §180.142 (a)(8) 2

Cattle, fat 0.2 0.3 Recodify as §180.142(a).

Cattle, kidney 2 4.0 Recodify as §180.142(a).

Cattle, meat 0.2 0.3 Recodify as §180.142(a).Commodity Tolerance Listed

Under 40 CFR §180.142 (ppm) Reassessed Tolerance (ppm) Comment [Corrected Commodity Definition]

Page 94 of 304 Cattle, meat byproducts, except kidney 0.2 0.3 Recodify as §180.142(a).

Egg 0.05 Revoke Category 3 of 40 CFR §180.6(a)(3) applies.

Goat, fat 0.2 0.3 Recodify as §180.142(a).

Goat, kidney 2 4.0 Recodify as §180.142(a).

Goat, meat 0.2 0.3 Recodify as §180.142(a).

Goat, meat byproducts, except kidney 0.2 0.3 Recodify as §180.142(a).

Hog, fat 0.2 Revoke Category 3 of 40 CFR §180.6(a)(3) applies.

Hog, kidney 2

Hog, meat 0.2

Hog, meat byproducts, except kidney 0.2

Horse, fat 0.2 0.3 Recodify as §180.142(a).

Horse, kidney 2 4.0 Recodify as §180.142(a).

Horse, meat 0.2 0.3 Recodify as §180.142(a).

Horse, meat byproducts, except kidney 0.2 0.3 Recodify as §180.142(a).

Milk 0.1 0.05 Residues in milk increased linearly with dose; therefore, the 0.05 ppm tolerance will be adequate for the 1x dose level. Recodify as §180.142(a).

Poultry 0.05 Revoke Category 3 of 40 CFR §180.6(a)(3) applies.

Sheep, fat 0.2 0.2 Recodify as §180.142(a).

Sheep, kidney 2 2.0 Recodify as §180.142(a).

Sheep, meat 0.2 0.2 Recodify as §180.142(a).

Sheep, meat byproducts, except kidney 0.2 0.2 Recodify as §180.142(a).

Tolerance Listed Under 40 CFR §180.142 (a)(9) 2

Fish 1.0 Revoke The reassessed tolerance of 0.1 ppm at §180.142(a)(6) will be recodified as §180.142(a). There is no need for duplication of tolerances.

Tolerance Listed Under 40 CFR §180.142 (a)(10) 2

Raspberry 1.0 Revoke Although there is no indication that IR-4 or the Task Force II is supporting a use on raspberries, it would be covered by the 0.2 ppm tolerance in the Berries group 13 at §180.142(a).Commodity Tolerance Listed

Under 40 CFR §180.142 (ppm) Reassessed Tolerance (ppm) Comment [Corrected Commodity Definition]

Page 95 of 304 Tolerance Listed Under 40 CFR §180.142 (a)(11) 3

Soybean, seed 0.02 0.02 Tolerance expired on 12/31/04. Residue data support a permanent tolerance. If established, recodify as §180.142(a).

Tolerance Listed Under 40 CFR §180.142 (a)(12) 2

Sugarcane bagasse 5 Revoke Sugarcane bagasse is no longer considered a significant livestock feed item.

Sugarcane molasses 5 0.20 Maximum residue value is based on HAFT residues of 0.015 ppm in/on sugarcane and a 7x concentration factor for molasses. Recodify as §180.142(a). Sugarcane, molasses

Milled fractions derived from barley, oats, rye, and wheat to be ingested as

animal feed or

converted into animal

feed 2 Revoke Tolerances for direct and inadvertent residues of 2,4-D in barley, bran; rye, bran; and wheat, bran are to be established under revised 40 CFR 180.142(a). Tolerances in other small grain processed products are not necessary as residues do not concentrate upon processing.

Tolerance Listed Under 40 CFR §180.142 (a)(13) 2

Sugarcane molasses 5 Revoke The sugarcane molasses reassessed tolerance at §180.142(a)(12) will be recodifed as §180.142(a). Duplication of tolerances is not necessary.

Milled fractions derived from barley, oats, rye, and wheat to be ingested as

animal feed or

converted into animal

feed 2 Revoke Tolerances for direct and inadvertent residues of 2,4-D in barley, bran; rye, bran; and wheat, bran are to be established under revised 40 CFR 180.142(a). Tolerances in other small grain processed products are not necessary as residues do not concentrate upon processing.

Potable water 0.1 (N) Revoke OPP no longer establishes tolerances in drinking

water. EPA’s Office of Water has established an MCL for 2,4-D at 0.07 ppm.

Tolerances Needed Under 40 CFR §180.142 (a); this list does not include recodifications, etc. from above

Almond hulls None 0.10 Almond, hulls

Aspirated grain

fractions None 40 Based on HAFT residues of 0.038 ppm for corn grain and a 39x concentration factor, maximum expected residues would be 1.48 ppm in aspirated grain fractions (AGF) derived from corn grain. Based on HAFT residues of 3.24 ppm for wheat grain and a 11.2x concentration factor, maximum expected residues would be 36.3 ppm in AGF derived from wheat grain. As sorghum and soybeans uses are early-season uses, residue data on AGF were not generated for these crops. Establish tolerance in AGF at 40 ppm.Commodity Tolerance Listed

Under 40 CFR §180.142 (ppm) Reassessed Tolerance (ppm) Comment [Corrected Commodity Definition]

Page 96 of 304 Barley, hay None TBD Data for wheat straw were translated to barley straw. Required wheat wheat hay data will be translated to barley hay. Barley, straw None 50

Barley, bran None 4.0 Data for wheat bran were translated to barley bran.

Millet, hay None TBD Required wheat wheat hay data will be translated to millet hay.

Oat, hay None TBD Data for wheat straw were translated to oat straw. Required wheat wheat hay data will be translated to oat hay. Oat, straw -- 50

Rice, hulls None 2.0 Maximum residue value is based on HAFT residues of 0.425 ppm in/on rice grain and a 3.3x

concentration factor for hulls.

Rye, straw None 50 Data for wheat straw were translated to rye straw.

Rye, bran None 4.0 Data for wheat bran were translated to rye bran.

Soybean, forage None 0.02 Adequate residue data are available to support permanent tolerances on soybean commodities. Soybean, hay None 2.0

Soybean, seed None 0.02

Wheat, hay None TBD Data are required on wheat hay

Wheat, straw None 50

Wheat, bran None 4.0 Maximum residue value is based on HAFT residues of 1.08 ppm in/on wheat grain (14-day PHI) and a

3.6x concentration factor for bran.

Tolerance Listed Under 40 CFR §180.142 (b) 5

Wild rice 0.1 0.05 Tolerance expires 12/31/05. Adequate data are available to establish a permanent tolerance with a regional registration to be recodified as §180.142(c)

for Rice, wild, grain at 0.05 ppm.

Tolerance Needed Under 40 CFR §180.142 (c) 6

Rice, wild, grain None 0.05 regional tolerance with use restricted to MN

Tolerances Needed Under 40 CFR §180.142 (d) 7

Commodities and crop groups currently listed under paragraph (a)(3) 0.1 (N) NA See comments listed under §180.142(a)(3)

1 Maximum residue of treated RAC sample(s) following appli cation of 2,4-D formulations according to use patterns the Task Force II registrants intend to support for reregistration.

2 This subparagraph will be dele ted and tolerances recodified under revised paragraph (a).

3 TBD = To be determined. Reassessment of tolerances(s) cannot be made at this time because additional data are required.

4 Tolerances listed under §180.142 (a)(3) fo r inadvertent residues will be recodified as either §180.142(a) or §180.142(d).

5 This paragraph will be reserved for future time-lim ited tolerances under Section 18 Emergency Exemptions.

6 Tolerances with regional use registration.Page 97 of 304 7 Paragraph (d) will contain tolerances fo r inadvertent residues (e.g., residues in irrigated crops) only, i.e., there is no registration for direct use in the U.S. If residues may re sult inadvertently as well as intentionally (direct, labeled treatment), the tolerance is codified at §180.142(a)

3. Codex Harmonization

The Codex Alimentarius Commission has established several maximum residue limits (MRLs) for residues of 2,4-D in/on various plant and animal commodities. The Codex MRLs are expressed in terms of 2,4-D per se . The expression of residues for Codex MRLs and U.S. tolerances is harmonized. A numerical comparison of the Codex MRLs and the corresponding reassessed U.S. tolerances is presented in Table 39.

Table 39. Codex MRLs and applicable U.S. tolerances for 2,4-D. Recommendations for compatibility are based on conclusions following reassessment of U.S. tolerances

Codex Reassessed U.S. Tolerance,

ppm Recommendation And Comments Commodity, As Defined MRL (mg/kg)

Barley 0.5 2.0

Blackberries 0.1 0.20 U.S. tolerance for Berries group 13

Citrus fruits 2.0 3.0

Eggs 0.05 (*) Revoked

Maize 0.05 (*) 0.05

Meat (from mammals other than marine mammals) 0.05 (*) 0.30 Meat, fat, and mbyp except kidney

4.0 Kidney

Milk products 0.05 (*) 0.05

Milks 0.05 (*) 0.05

Oats 0.5 2.0

Potato 0.2 0.40

Raspberries, Red, Black 0.1 0.20 U.S. tolerance for Berries group 13

Rice 0.05 (*) 0.50

Rye 0.5 2.0

Sorghum 0.05 (*) 0.20 Forage, grain, and stover=0.2

Vaccinium berries, including Bearberry 0.1 0.20 U.S. tolerance for Berries group 13

Wheat 0.5 2.0

(*) = At or about the limit of detection.

4. Residue Analytical Methods - Plants and Livestock (GLN 860.1340)

For the purpose of reregistration, adequate methods are available for data collection and the enforcement of plant commodity tolerances. Th e Pesticide Analytical Manual (PAM) Vol. II lists three GC methods (designated as Methods A, B, and C) with microcoulometric detection and one GCPage 98 of 304 method (designated as Method D) with electron capture detection (ECD). In a letter dated September 3, 1993 (CBRS No. 12270, DP Barcode D193335, 9/3/93, W. Smith), Task Force II indicated that the enforcement methods currently listed in PAM Vol. II are unsuitable for determining residues of 2,4-D in wheat and poultry commodities.

Plant Commodities : Task Force II submitted an adequate proposed GC/ECD enforcement method for plants (designated as EN-CAS Method No. ENC- 2/93) which has been independently validated. Adequate radiovalidation data have been submitted and evaluated for the proposed enforcement method using samples from the wheat metabolism study. The proposed enforcement method or modifications of the enforcement method were used for data collection purposes.

Livestock Commodities : Task Force II submitted two separate (but essentially comparable) proposed enforcement methods (GC/ECD) for determination of 2,4-D in livestock commodities. Adequate radiovalidation data have been submitted for the method using samples of fat, kidney, and milk from the goat metabolism study and samples of eggs from the poultry metabolism study. The Agency concluded that the methods are adequate provided the registrants satisfy the following requests: (i) submit a revised method which combines the two methods into a single method; (ii) delete from the method all references to the use of diazomethane as a derivatizing agent; and (iii) provide complete raw data and sample calculations (including chromatograms showing peak areas, external standard linearity curves and associated data, standard calculations, etc.). Once an adequate revised method is submitted, the Agency will evaluate the tolerance method validation. Recently, it has been determined that the technology to generate diazomethane has advanced such that it is no longer considered to be a dangerous procedure; as a result, the use of diazomethane as a derivatizing agent is now considered acceptable.

E. Regulatory Rationale

The following is a summary of the rationale for managing risks associated with the use of 2,4- D. Where labeling revisions are warranted, specific language is set forth in the summary tables of

Section V of this document.

1. Human Health Risk Management

a. Residential Risk

1) Residential risk summary

A Margin of Exposure (MOE) of 1000 (10x for interspecies extrapolation, 10x for intraspecies variation, and 10x database uncertainty factor) is considered adequately protective for this assessment

of residential risks. Residential handler risks ar e not of concern. All MOEs for post-application, oral exposure to children from playing on treated lawns meet or exceed 1000; therefore, post-application exposure to children is not of concern. Likewise, all adult acute/short term MOEs meet or exceed 1000, so post-application exposure is not of concern for adults.Page 99 of 304 As discussed below, potential risks were identified to individuals who swim in water treated with 2,4-D. Although the risk assessment is likely to be conservative, mitigation measures will be required.

2) Residential Post-application Mitigation

For residential, post-application exposures, when the calculated MOE of 1000 based onmodeling is considered in conjunction with biomonitoring results, it is clear that the modeled shortterm risks from post-application exposure are upper bound estimates. At one day post-treatment, the MOEs for the volunteers who wore shorts and no shoes ranged from 1400 to 35000 with the lowest MOE corresponding to the volunteer who removed his shirt during the exposure period. The MOEs for the remaining volunteers ranged from 24000 to 37000. The Agency has concluded that no further mitigation is needed for residential post-application exposures.

3) Residential Swimmer Mitigation

The acute MSWC of 9.8 ppm for exposures to 2,4-D acid or amine is greater than the proposed maximum application rate of 4.0 ppm, therefore, acute exposures to acid or amine are not of concern. The MSWC of 3.6 ppm for short-term exposures to acid or amine is also not of concern because some dissipation or dispersion is likely to occur which would cause the 7-day average of 2,4-D concentrations to be less than 3.6 ppm. Dissipation studies submitted to the Agency indicated that the half lives following pond and lake liquid treatments ranged from 3.2 days to 27.8 days which yield 7 day average concentrations of 1.9 ppm when the half life equals 3.2 days, to 3.6 ppm when the half life equals 27.8 days.

The MSWCs for 2,4-D BEE are less than the master label application rate of 4 ppm, but they are unlikely to be of concern for the following reasons:

C 2,4-D BEE degrades rapidly by abiotic hydrolysis in sterile water to form 2,4-D acid particularly when the pH is 7.5 or above.

C 2,4-D BEE degrades to 2,4-D acid by microbial hydrol ysis with an averag e half life of 2.6 +

1.8 hours at a bacterial concentration of 5 x 10 -8 organisms per liter. Therefore, degradation of 2,4-D BEE to 2,4-D under typical environmental conditions will be rapid leading to significantly lower risk estimates because the 2,4-D acid has a lower rate of dermal absorption.

C Modeling predicts direct water application of 2,4-D BEE will yield surface water concentrations of 2,4-D BEE concentrations in the Agency standard pond of 624 ug/L for peak (24 hour average), 30 ug/L for the 21-day average, and 10 ug/L for the 60-day average.

C The existing label rates for 2,4-D BEE products are also lower than the master label rate.Page 100 of 304 Although the risk characterization above suggests that the risk estimates are conservative, a 24 hour post-application restriction on swimming is necessary to ensure the safety of children swimming in water treated with 2,4-D BEE.

b. Aggregate Risk

The Food Quality Protection Act amendments to the Federal Food, Drug, and Cosmetic Act (FFDCA, Section 408(b)(2)(A)(ii)) require “that ther e is a reasonable certainty that no harm will result from aggregate exposure to pesticide chemical residue, including all anticipated dietary exposures and other exposures for which there is reliable information.” Aggregate exposure willtypically include exposures from food, drinking water, residential uses of a pesticide, and other nonoccupational sources of exposure.

1) Aggregate Risk Summary

For 2,4-D, EPA conducted acute, short-term, and chronic aggregate risk assessments using the reduced maximum application rate for residential turf (1.5 lbs ae/A). The aggregate risk assessment compares the Drinking Water Level of Comparison (DWLOC) for each scenario with the appropriate Estimated Drinking Water Concentration (EDWC) for the pesticide. The DWLOC is the maximum concentration in drinking water which, when consid ered together with food, and, if appropriate, residential exposure, does not exceed EPA’s level of concern. Generally, EDWCs that are less than the corresponding DWLOC are not of concern to the Agency. It is important to note that the MCL for 2,4-D, established by EPA’s Office of Water under the Safe Drinking Water Act (SDWA), is 70 ug/L. To minimize the possibility that direct aquatic applications will result in drinking water concentr ations in excess of the MCL, the Agency has worked with the 2,4-D Task Force and water quality specialists to develop appropriate label requirements for 2,4-D products registered for use to control aquatic weeds.

2) Acute Aggregate Risk

DWLOC Approach Acute DWLOCs were calculated based upon acute dietary exposures. Acute residential exposures from swimming in treated water bodies or playing on treated turf were not included because exposures are unlikely to co-occur with acute dietary exposures. The acute DWLOCs are range from 432 to 1932 with the most sensitive population being females 13 to 49 years old. The EDWCs of 118 ug/liter for surface water and 15 ug/lite r for groundwater are substantially less than

the DWLOCs which means that the risks are not of concern.

Forward Calculation Approach Acute aggregate risks were assessed by directly combining acute food exposures and estimates of acute water exposures. The acute aggregate risk s and are not of concern because they are less than 100 percent of the aPAD. The highest risks (58 pe rcent of the aPAD) are for females 13-49 years old because these risks are based upon the lower NOAEL of 25 mg/kg/day from a developmental study inPage 101 of 304 rats. Whereas, estimates of other population gr oups are based on a NOAEL of 67 mg/kg/day from an acute neurotoxicity study in rats.

3) Short-term Aggregate Risk

DWLOC Approach Short-term aggregate risks assessments were conducted by calculating DWLOCs based upon short-term turf exposures, chronic food exposures and short-term endpoints. Short-term exposures from swimming in treated water bodies were not included because these exposures represent high-end unlikely scenarios. The short-term DWLOCs were calculated only for females 13-49 and children 1- 6 because these population subgroups have the highest exposure and estimates calculated for these groups are protective of the other subgroups. The DWLOCs range from 24 to 36 ug/liter. The EDWCs range from 15 to 23 ug/liter. Since the DWLO Cs are all greater than the EDWCs, the short

term risks are not of concern.

Forward Calculation Approach Short-term aggregate risks were assessed by aggregating short-term turf exposures, chronic food exposures and chronic water exposures. Short-term aggregate risk were calculated only for females 13-49 and children 1-6 because these population subgroups have the highest exposure and estimates calculated for these groups are protective of the other subgroups. The short-term aggregate

MOEs indicate that the short term risks are not of concern because the MOEs equal or exceed the target MOE of 1000.

4) Chronic (Non-Cancer) Aggregate Risk

DWLOC Approach Chronic DWLOCs were calculated based upon chronic dietary exposures. As there are no chronic residential exposures, residential exposures were not included in the chronic DWLOC calculations. The chronic DWLOCs are 46 ug/L or greater with the most sensitive populations being infants and children. The EDWCs, which range from 1.5 to 23 ug/L, are less than the DWLOCs

which means that the risks are not of concern. It should be noted that the master label indicates that potable water consumption from a treated water body cannot begin until the 2,4-D concentration is 70 ug/L or below, therefore an annual average expos ure at the MCL of 70 ug/L would not occur because dissipation would reduce the initial concentration of 70 ug/L to an annual average concentration of 11 ug/L.

Forward Calculation Approach Chronic aggregate risks were assessed by aggregating chronic food exposures and chronic water exposures. The chronic aggregate risks are not of concern because they are less than 100 percent of the cPAD. The highest risks (38 per cent of the cPAD) are for children 1-2 years old.Page 102 of 304 5) Aggregate Risk Mitigation

Given the reduced maximum application rate to residential lawns (1.5 lbs ae/A), the highest aggregate risks are the risks from short-term exposures, which include the turf exposure scenarios. For the most sensitive subpopulation (females 13-49) these risks meet the target MOE of 1000 and the turf exposure is the risk driver as it contributes 96 percent of the risk. Whereas calculated risks just meet the Agency’s ta rget MOE, it is important to note that the turf exposure estimate is based upon modeling and is greater than exposure measurements obtained from biomonitoring. As described in the human health assessment, the results of a biomonitoring study were used to calculated MOEs by assuming that all of the urinary 2,4-D measured in the 96 hours after the exposure period was the result of the turf exposure. This assumption is protective because 2,4-D exposures due to inhalation and due to food and water ingestion would be counted as dermal exposure. The biomonitoring results were adjust ed by a factor of two to account for the SOP assumption of two hours of daily exposure vs one hour of exposure during the study, and a factor of 1.7 to account for an application rate of 1.5 lbs ae/acre vs 0.88 lb ae/acre applied during the study. At one day post-treatment, the MOEs for the volunteers who wore shorts and no shoes ranged from 1400 to 35000 with the lowest MOE corresponding to the volunteer who removed his shirt during the exposure period. The MOEs for the remaining volunteers ranged from 24000 to 37000. If the calculated MOE of 1000 based on modeling is considered in conjunction with the MOE calculated based on biomonitoring results, it is clear that the modeled short-term risks are upper bound estimates. The Agency has concluded that aggregate risks from acute, short-term and chronic exposures are not of concern. No further mitigation beyond reducing the maximum application rate from 2.0 to 1.5 lbs/ae per acre is needed.

c. Occupational Risk Mitigation

1) Handler Risk Mitigation

With the exception of mixing/loading wettable powder, the short-term and intermediate-term Margin of Exposure estimates (MOEs) exceed 100 w ith baseline attire (i.e., long-sleeved shirt, long pants, shoes plus socks) or single layer attire (i.e., long-sleeved shirt, long pants, shoes plus socks, gloves) and are not of concern. The MOEs for handling wettable powder are acceptable with engineering controls (i.e. water soluble bags). Water soluble bags will be required for wettable powder formulations.

2) Post-application Risk Mitigation

All short- and intermediate-term MOEs are above 100 on day zero. All occupational postapplication risk scenarios are below EPA’s level of concern. Products containing 2,4-D salt and ester forms as active ingredient with Worker Prot ection Standard (WPS) uses will require a re-entry interval (REI) of 12 hours. Becau se of acute eye irritation concerns, products containing 2,4-D acid and amine forms with WPS uses will require a REI of 48 hours and protective eyewear. The requirements for individual products will be finalized based on product-specific chemistry and acutePage 103 of 304 toxicity review. The exposure reduction program implemented in 1992 will be replaced with the personal protective equipment described in section V.D. of this document.

2. Environmental Risk Mitigation

The Agency has considered available information on 2,4-D’s toxicity, use areas, usage, fate properties, application methods, and formulations in calculating ecological risks. The resulting assessment suggests that the use of 2,4-D for aquatic weed control presents risk to aquatic organisms,while 2,4-D use on terrestrial sites presents greater potential risks to small mammals, birds, and nontarget terrestrial plants, than to other plants and animals.

a. Birds

Acute Risk Whereas the assessment of risk to birds from the terrestrial use of 2,4-D suggests risks of concern, the assessed exposures to 2,4-D are likely conservative in the following ways. Currently,Agency models do not account for the uptake of 2,4-D by plants and therefore assume that all nondissipated pesticide applied to the field is present for exposure to organisms. In fact, many pesticides, including 2,4-D, are systemic and are absorbed by plants in the field and therefore, the current approach may overestimate the amount of 2,4-D available for exposure in terrestrial and aquatic
systems. For non-granular spray application, the highest acute avian RQ (3.5) was from the cranberry use-site scenario, for birds feeding on short grass. That assessment was based on a maximum application rate of 4 lbs ae/acre; however, the average application rate is 1.83 lbs ae/acre (see the Agency’s quantitative use assessment). If the modeled application rate was reduced to 1.83 lbs ae/acre for cranberries, and an assumption made that the resulting EEC will be reduced linearly, the RQ would be 1.6. To determine the hazard associated with acute exposures to birds, the assessment has relied on two types of data, a suite of dietary studies and a suite of gavage studies. For avian acute exposures, the dietary studies result in non-definitive endpoints which are not appropriate for estimating risk. Therefore, the assessment has relied on the gavage st udies to estimate avian acute risks. The Agency recognizes that this approach may overestimate risk to birds due to the fact that birds would not typically be expected to consume 2,4-D in this manner.

Chronic Risk Potential chronic risks to birds is limited to the following use sites: non-cropland, forest, asparagus, and cranberry. The RQs for these sites range from one to slightly above one. Further characterization of these use sites by evaluating average application rates versus maximum application rates lower these RQs to below the LOCs. Given the conservative assumptions in both exposure scenarios and hazard determinations, the Agency finds that the acute and chronic risks to birds from 2,4-D exposure are not of concern.Page 104 of 304 b. Mammals
Acute risk All of the calculated RQs for mammalian acute risk for the non-granular use of 2,4-D were based on maximum labeled application rates. The EPA’s quantitative use assessment (EPA QUA) suggests that the average application rates for many crops are considerably less than the modeled maximum application rates. For non-granular spray application mammalian acute concerns, the highest RQ was 1.72 for use on asparagus for small mammals feeding on short grass based on a maximum application rate of 2 lbs ae/A applied two times a year; however, the average application rate was only 1.10 lbs ae/A (EPA QUA). If the modeled application rate was reduced to the reported average application rate of 1.10 lbs ae/A for asparagus, the RQ would be 1.08 which is still above the acute LOC of 0.5. However, asparagus is represen tative of a minor 2,4-D use, and risk to mammals from use of 2,4-D on asparagus would be minimal, given that fact. To add context to the acute mammalian assessment, the effect of assuming an average application rate was determined. Major 2,4-D crops include pasture/rangeland, turf, wheat, corn, and soybeans. For pasture/rangeland, the highest acute RQ was 0.86 for small mammals feeding on short grass based on a maximum application rate of 4 lbs ae/A. However, the average application rate was only 0.62 lbs ae/A (BEAD QUA). If the modeled application rate was reduced to 0.62 lbs ae/A for pasture/rangeland, the resulting RQ is 0.31 which is below the acute LOC, but above the restricted use LOC of 0.2. Similar trends are noted for other major use sites. Although the calculated RQ values still exceed th e Agency’s level of concern when average applications rates are considered, the Agency has concluded that the benefits from 2,4-D use (including control of invasive and noxious weed speci es), taken together with the low toxicity of 2,4- D to humans, outweigh the concerns of toxicity to small mammals. No additional mitigation steps

will be taken.

Chronic risk Calculated chronic risks to mammals were greatest for small herbivores/insectivores. For 15 g mammalian herbivores/insectivores, chronic RQs based on maximum residues and mean residues ranged from <1 to 200 and <1 to 70, respectively. For major use sites, including rangeland/pasture, RQs were approximately 100. These chronic risk estimates are likely conservative as described

below. The chronic RQs calculated for mammalian herbivores/insectivores are based on conservative estimates of exposure that are not likely to occur in nature. In the example of pasture/rangeland, the chronic RQ of approximately 100 for maximum residues (35 for mean residues) was calculated based on an application rate of 2 lbs ae/A applied twice per year, at a 30 day interval. However, the EPA has determined that the average application rate on pasture/rangeland is only 0.62 lbs ae/A (EPA QUA). Moreover, information from several of the Agency’s state contacts indicate that a once per year application of less than 1 lb ae/A is typical (personal communications). As the typical rate is approximately 25% of the assessed rate, use of the typical rate would be expected to decrease the RQ for the pasture/rangeland scenario approximately four-fold, to approximately 25 for maximum

residues and 9 for mean residues. A second example of the conservative assumptions included in the assessment of exposure to mammalian herbivores/insectivores is the assumption that 100% of the long term diet is relegated toPage 105 of 304 single food types foraged only from treated fields . The assumption of 100% diet from a single food type may be realistic for acute exposures, but diets are likely to be more variable over longer periods
of time. The risk assessment assumed that 100% of the small mammals’ diet consists of short grasses. Several published reports suggest that actual diets of small mammals are more varied, and would likely include invertebrates, worms, fungi, and seeds, in addition to plant matter. Given the conservative assumptions in the exposure scenarios, the Agency finds that the risks identified in the risk assessment are likely to overestimate actual risks to mammals from 2,4-D applications. Based on information about average application rates and dietary patterns as described above, the Agency has concluded that actual 2,4-D exposures to mammals are likely to be significantly lower than those assessed but may still be above the chronic LOC for this screening level assessment. However, the Agency has concluded that the benefits from 2,4-D use (including control of invasive and noxious weed species), ta ken together with the low toxicity of 2,4-D to humans, outweigh the concerns of toxicity to small mammals. No additional mitigation is being required at this time.

c. Aquatic Organisms

Whereas the assessment of risk to aquatic organisms suggests risks of concern, the assessed exposures to 2,4-D are likely conservative as follows. Whereas the maximum labeled target concentration for control of aquatic weeds is 4 ppm, the typical target concentration is 2 ppm. A rate of 4 ppm is reserved for spot-treating new aquatic weed stands and hybrid weed species that tend to be less susceptible to 2,4-D. Per the product label, re-application of 2,4-D can occur after 21 days. In the current assessment, the risks to aquatic organisms were estimated based on a 2,4-D application that resulted in a whole-reservoir concentration of 4 ppm. Treating 100% of the water body would likely result in a large amount of decaying plant life, thereby creating an oxygen-depleted environment that would most likely result in fish kills. To avoid that scenario, the current 2,4-D label advises that the applicator avoid treating more than 50% of a water body in a 21-day period. In actual practice, aquatic weeds that 2,4-D controls tend to grow near the shore of lakes, ponds, and reservoirs. As a result, generally a maximum of 20-30% of a water body is treated in a single application. Applying the typical rate of 2 ppm, and taking into account a typical maximum treated area of 30%, would decrease calculated RQs by approximately 6-fold. While noting the potential risks to aquatic organisms from the direct application of 2,4-D for the control of aquatic weeds identified above, it is impor tant to note the benefits gained through the direct application of 2,4-D to aquatic bodies, for the control of invasive species. The U.S Army Corps of Engineers (USACE) and state agencies have identifie d 2,4-D as an important tool for protecting water bodies from the invasion and establishment of some species of exotic nuisance vegetation. 2,4-D has a reputation as a selective and economical means to remove invasive plants, enhance the growth and recovery of desirable native vegetation, restore water quality, reduce sedimentation rates in reservoirs, and improve fish and wildlife habitat. 2,4-D products are used to control invasive weeds, such as Eurasian water milfoil ( Myriophyllum spicatum ) in the northern tier states and water hyacinth ( Eichhornia crassipes ) in the Gulf Coast states. Effective control of these plants can benefit public health with respect to reducing levels of mosquito habitat. In addition, according to USACE, no other product (or alternative technique) can control thes e plants in a more cost-effective manner (K. Getsinger, USACE, Public Comment; Docket ID# OPP-2004-0167-0053).Page 106 of 304 Given the typical application rates and treatment areas, and considering the beneficial aspects of using 2,4-D to control invasive plant species, the Agency concludes that the benefits from direct aquatic use of 2,4-D outweigh the risk concerns for aquatic organisms. No additional mitigation measures will be required at this time to address risk to aquatic organisms.

d. Non-target Insects

Risk to non-target insects do not exceed the Agency’s level of concern. Available data from a honey bee acute toxicity study indicated that technical 2,4-D is practically non-toxic to the honey bee. The potential for 2,4-D and its salts and esters to pose risk to pollinators and other beneficial insects is expected to be minimal.

e. Non-target Terrestrial Plants

Estimated RQs exceeded acute LOCs for both non-endangered and endangered terrestrial plants for non-granular and granular uses at many use sites. Consideration of average application rates did not result in exposure below LOCs. However, the exposure estimates used to develop the RQs were likely conservative, as follows. In the exposure calculation for non-target aquatic plants and terrestrial plants in intermittently flooded areas, the major contributor is run-off from the application site. The run-off and leaching vulnerability schemes used in this assessment incorporate several conservative assumptions which are fully discussed in the ecological risk assessment. Also, it is likely that farm management practices would be in place to limit run-off, as run-off events are detrimental to the farm as a whole for reasons other than pesticide damage. Whereas the risk assessments are likely conservative as described above, the Agency is concerned about the risk to non-target terrestrial plants from drift of 2,4-D during application. To address that concern, the Agency is implementing sp ray drift controls that will decrease the risk that 2,4-D will drift onto non-target plants.

f. Summary of Environmental Risk Mitigation

Characterization of the risks identified in the Ag ency’s screening level risk assessment suggests that risks from drift onto non-target plants exceed s the Agency’s level of concern. The Agency is implementing spray drift controls that will decr ease the risk that 2,4-D will drift onto non-target plants.

F. Other Labeling Requirements

In order to be eligible for reregistration, various use and safety information will be included in the labeling of all end-use products containing 2,4-D. For the specific labeling statements and a list of outstanding data, refer to Section V of this RED document.

1. Endangered Species ConsiderationsPage 107 of 304 The Agency has developed the Endangered Species Protection Program to identify pesticides whose use may cause adverse impacts on endangered and threatened species, and to implement mitigation measures that address these impacts. The Endangered Species Act requires federal agencies to ensure that their actions are not likely to jeopardize listed species or adversely modify designated critical habitat. To analyze the potential of registered pesticide uses that may affect any particular species, EPA uses basic toxicity and exposure data and considers ecological parameters, pesticide use information, geographic relationship between specific pesticide uses and species locations, and biological requirements and behavioral aspects of the particular species. Based on EPA’s screening level assessment for 2,4-D, RQs exceed levels of concern for mammals, birds, aquatic plants, and terrestrial plants. However, these findings are based solely on EPA’s screening level assessment and do not constitute “may affect” findings under the ESA. The Agency is requiring additional data to further characterize and refine its ecological and endangered species risk assessments. The 2,4-D Task Force has submitted a limited endangered species assessment on several crops for the Agency’s consideration. This assessment was generated using the FIFRA Endangered Species Task Force (FESTF) integrated management system (IMS).

2. Spray Drift Management

The Agency has been working closely with stakeholders to develop improved approaches for mitigating risks to human health and the environment from pesticide spray and dust drift. As part of the reregistration process, we will continue to work with all interested parties on this important issue. From its assessment of 2,4-D, as summarized in this document, the Agency concludes that certain drift mitigation measures are needed to addre ss the risks from off-target drift for 2,4-D. Label statements implementing these measures are listed in the "spray drift management" section of the Labeling Changes Summary Table in section V.D. of this RED document. In the future, 2,4-D product labels may need to be revised to include additional or different drift label statements.

3. Consumer Labeling Initiative

The Consumer Labeling Initiative (CLI) is an effort among federal, state, and local government agencies, industry, environmental groups, and other interested parties working to improve product labels on residential pesticides in order to improve consumer understanding and compliance of consumer labels. The CLI Work Group of the Pesticide Program Dialogue Committee (PPDC) is working to revise consumer labels. In addition to the labeling changes presented in this RED, the Agency will leave open the possibility that changes to residential product labeling may occur as the

result of the PPDC CLI.Page 108 of 304 V. What Registrants Need To Do

For 2,4-D technical grade active ingredient products, registrants need to submit the following items.

Within 90 days from receipt of the generic data call-in (DCI):

(1) completed response forms to the generic DCI (i.e., DCI response form and requirements status and registrant’s response form); and

(2) submit any time extension and/or waiver requests with a full written justification.

Within the time limit specified in the generic DCI:

(1) cite any existing generic data which address data requirements or submit new generic data responding to the DCI.

Please contact Katie Hall at (703) 308-0166 with questions regarding generic reregistration and/or the DCI. All materials submitted in response to the generic DCI should be addressed:

By US mail: By express or courier service: Document Processing Desk (DCI/SRRD) Document Processing Desk (DCI/SRRD)

Katie Hall Katie Hall US EPA (7508C) Office of Pesticide Programs (7508C) 1200 Pennsylvania Ave., NW Room 604, Crystal Mall 2 Washington, DC 20460 1801 S. Bell Street Arlington, VA 22202
- 4501

For products containing the active ingredient 2,4-D registrants need to submit the following items for each product.

Within 90 days from the receipt of the product-specific data call-in (PDCI):

(1) completed response forms to the PDCI (i.e., PDCI response form and requirements status and registrant’s response form); and

(2) submit any time extension or waiver requests with a full written justification.

Within eight months from the receipt of the PDCI:

(1) two copies of the confidential st atement of formula (EPA Form 8570-4);Page 109 of 304 (2) a completed original application for reregistration (EPA Form 8570-1). Indicate on the form that it is an “application for reregistration”;

(3) five copies of the draft label incorporating all label amendments outlined in Table 40 of this document;

(4) a completed form certifying compliance with data compensation requirements (EPA Form 8570-34);

(5) if applicable, a completed form certifying compliance with cost share offer requirements (EPA Form 8570-32); and

(6) the product-specific data responding to the PDCI.

Please contact Moana Appleyard at (703) 308-8175 with questions regarding product reregistration and/or the PDCI. All materials submitted in response to the PDCI should be addressed:

By US mail: By express or courier service only: Document Processing Desk (PDCI/PRB) Document Processing Desk (PDCI/PRB) Moana Appleyard Moana Appleyard US EPA (7508C) Office of Pesticide Programs (7508C) 1200 Pennsylvania Ave., NW Room 266A, Crystal Mall 2 Washington, DC 20460 1801 Bell Street Arlington, VA 22202

A. Manufacturing Use Products

1. Additional Generic Data Requirements

The generic data base supporting the reregistration of 2,4-D for eligible uses has been reviewed and determined to be substantially complete. However the following data requirements are necessary to confirm the reregistration eligibility decision documented in this RED.

Table 40. Data Requirements for the Rereg istration Eligibility Decision for 2,4-D

Guideline Study Name New OPPTS

Guideline No. Old

Guideline

No.

Environmental Fate and Effects Data Requirements

Aquatic field dissipation studies (Behavior of 2,4-D BEE under acidic to neutral aquatic conditions in a water/sediment system) 835.6200 164-2

Laboratory volatility study (2,4-D IPE) 835.1410 163-2

Terrestrial field dissipation studies (2,4 -D IPA, 2,4-D TIPA, 2,4-D DEA, 2,4-D BEE) 835.6100 164-1Guideline Study Name New OPPTS

Guideline No. Old

Guideline

No.

Page 110 of 304 Aquatic field dissipation studies in a rice use scenario (2,4-D IPA, 2,4-D TIPA, 2- 4-D DEA) 835.6200 164-2

Aquatic field dissipation studies in an aquatic weed control scenario (2,4-D IPA, 2,4-D TIPA, 2-4-D DEA) 835.6200 164-2

Forest field dissipation studies (2,4-D IPA, 2,4-D TIPA, 2,4-D BEE, and 2,4-D DEA) 835.6300 164-3

Fish acute toxicity test, freshwater and marine with typical end-use product (TEP) (2,4-D BEE) 850.1075 72-1

Oyster acute toxicity test with TEP (2,4-D BEE) 850.1025 72-3

Mysid acute toxicity test with TEP (2,4-D BEE) 850.1035 72-3

Penaid acute toxicity test with TEP (2,4-D BEE) 850.1045 72-3

Sediment and soil adsorption/desorption (2,4-D BEE granular formulation) 835.1230 163-1

Seedling Germination/Seedling Emergence Vegetative Vigor

Non-target terrestrial plants - TEP repr esentative testing from the acid and amine salts group, and representative testing from the ester group. The test products should include the most common and most active surfactants and adjuvants which affect the toxicity of the product. The registrants should consult with the Agency before finalizing which products to test. 850.4225

850.4250 123-1(a) 123-1(b)

The registrant must provide information on the proximity of Federally listed freshwater vascular plants, birds, mammals , and non-target terrestrial plants (there

are no listed estuarine/marine inverteb rates) to the 2,4-D use sites. This requirement may be satisfied in one of three ways: 1) having membership in the FIFRA Endangered Species Task Force (Pesticide Registration [PR] Notice 2000- 2); 2) citing FIFRA Endangered Species Task Force data; or 3) independently producing these data, provided the information is of sufficient quality to meet FIFRA requirements. Registrants should consult with the Agency prior to fulfilling this data requirement. - -

Human Health Effects Data Requirements

Developmental neurotoxicity study 870.6300 83-6

Subchronic inhalation toxicity study (28-day) 870.3465 82-4

Repeat two-generation reproduction study (using the most recent Agency protocol) addressing concerns for endocrine disruption (thyroid and immunotoxicity measures) 870.3800 83-4

Product and Residue Chemistry Data Requirements

Crop field trials - wheat hay 860.1500 171-4kGuideline Study Name New OPPTS

Guideline No. Old

Guideline

No.

Page 111 of 304 Water, fish, and irrigated crops - irrigate d crop studies in strawberries and sugar beet roots and tops 860.1400 171-4f

Residue analytical method - revised enforcement method for determination of 2,4-

D in livestock commodities 860.1340 171-4c

Directions for Use 860.1200 171-3

Other Data Requirements

UV/Visible Absorption 830.7050 None

Droplet Size Spectrum 840.1100 201-1

Drift Field Evaluation 840.1200 202-1

The Agency is requiring that five recent batches of all technical products be analyzed for 2,3,7,8-TCDD, 2,3,7,8-TCDF and their respective higher substituted chlorinated congeners using validated analytical methods. The Agency specifies

that the manufacturers use the most current state-of-the art laboratory methods for measuring 2,3,7,8-TCDD and TCDF at le vels less than 1 part per trillion (EPA Method 1613, Tetra- through Octa-Chlorin ated Dioxins and Furans by Isotope Dilution HRGC/HRMS). Because 1,2,3,7, 8-PeCDD is equi-potent to 2,3,7,8- TCDD in the TEF scheme, the Agency is adding this compound to our testing requirements. - -

B. End-Use Products

1. Additional Product-Specific Data Requirements

Section 4(g)(2)(B) of FIFRA calls for the Agen cy to obtain any needed product-specific data regarding the pesticide after a determination of eligibility has been made. Registrants must review previous data submissions to ensure that they m eet current EPA acceptance criteria and if not, commit to conduct new studies. If a registrant believes that previously submitted data meet current testing standards, then the study MRID numbers should be cited according to the instructions in the Requirement Status and Registrants Response Form provided for each product.

2. Labeling for End-Use Products

Labeling changes are necessary to implement the mitigation measures outlined in Section IV above. Specific language to incorporate these changes is specified in Table 40.

C. Existing Stocks

Registrants may generally distribute and sell products bearing old labels/labeling for 12

months from the date of the issuance of this Reregistration Eligibility Decision document. PersonsPage 112 of 304 other than the registrant may generally distribute or sell such products for 24 months from the date of the issuance of this RED. However, existing stocks time frames will be established case-by-case, depending on the number of products involved, the number of label changes, and other factors. Refer to “Existing Stocks of Pesticide Products; Statement of Policy”; Federal Register , Volume 56, No. 123, June 26, 1991.Page 113 of 304D. Required Labeling Changes Summary TableIn order to be eligible for reregistration, all product labels must be amended to incorporate the risk mitigation measures outlined in SectionIV. The following table describes how language on the labels should be amended.Table 41: Summary of Labeling Changes for 2,4-DDescription Amended Labeling Language Placement on LabelFor all Manufacturing UseProducts“Only for formulation into anherbicide or plant growth regulatorfor the following use(s)[fill blank only with those uses that are being supported by MP registrant].”“Wettable powder formulations must bepackaged in water-soluble packages.”Directions for UseOne of these statements maybe added to a label to allowreformulation of the productfor a specific use or alladditional uses supported by aformulator or user group“This product may be used to formulate products for specific use(s) not listed on the MPlabel if the formulator, user group, or grower has complied with U.S. EPA submissionrequirements regarding support of such use(s).”“This product may be used to formulate productsfor any additional use(s) not listed on theMP label if the formulator, user group, orgrower has complied with U.S. EPA submissionrequirements regarding support of such use(s).”Directions for UseEnvironmental HazardsStatements Required by theRED and Agency LabelPolicies"This chemical is toxic to fish and aquaticinvertebrates. Donot discharge effluentcontaining this product into lakes, streams, ponds, estuaries, oceans, or other waters unlessin accordance with the requirements of a National Pollution Discharge Elimination System(NPDES) permit and the permitting authority has been notified in writing prior todischarge. Do not discharge effluent containing this product to sewer systems withoutpreviously notifying the local sewage treatmentplant authority. For guidance contact yourState Water Board or Regional Office of the EPA."PrecautionaryStatementsEnd Use Products Intended for Occupational UsePage 114 of 304PPE RequirementsEstablished by the RED1for liquids, wettable powdersformulated in water-solublepackages, and waterdispersible granules“Personal Protective Equipment (PPE)“Some materials that are chemical-resistant to this product are” (registrant inserts correctchemical-resistant material). “If you want more options, follow the instructions forcategory”[registrant inserts A,B,C,D,E,F,G,or H] “on an EPA chemical-resistancecategory selection chart."“All mixers, loaders, applicators, flaggers, and other handlersmust wear:- long-sleeved shirt and long pants,- shoes and socks, plus- chemical resistant gloves, when applying postharvest dips or spraysto citrus, applyingwith any handheld nozzle or equipment,mixing or loading, cleaning up spills orequipment, or otherwise exposed to the concentrate.- chemical resistant apron when applying postharvest dips or spraysto citrus, mixing orloading, cleaning up spills or equipment,or otherwise exposed to the concentrate.See engineering controls for additional requirements.”Immediatelyfollowing/belowPrecautionaryStatements: Hazardsto Humans andDomestic AnimalsPPE RequirementsEstablished by the RED1for granularformulations“Personal Protective Equipment (PPE)All loaders, applicators, and other handlersmust wear:- long-sleeved shirt and long pants,- shoes plus socks.”Immediatelyfollowing/belowPrecautionaryStatements: Hazardsto Humans andDomestic AnimalsUser Safety Requirements “Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructionsfor washables exist, use detergent and hot water. Keep and wash PPEseparately from otherlaundry.”PrecautionaryStatements: Hazardsto Humans andDomestic Animalsimmediatelyfollowing the PPErequirementsPage 115 of 304Engineering Controlsfor aerial applicationsEnclosed Cockpits“Engineering Controls:Pilots must use an enclosed cockpit thatmeets the requirements listed in the WPS foragricultural pesticides [40 CFR 170.240(d)(6)]”PrecautionaryStatements: Hazardsto Humans andDomestic Animals(Immediatelyfollowing PPE andUser SafetyRequirements.)Engineering Controlsfor wettable powderformulations packaged inwater-soluble packages“Engineering Controls”“Water-soluble packets when used correctlyqualify as a closed loading system under theWPS. Mixers and loaders using water-soluble packets (1) must wear the PPE specifiedabove for mixers and loaders and (2) must beprovided, have immediately available for usein an emergency, such as a broken package, spill, or equipment breakdown a NIOSHapproved dust mist filtering respirator with MSHA/NIOSH approval number prefix TC21Cora NIOSH-approved respirator with any N2, R, P, or HE filter.”PrecautionaryStatements: Hazardsto Humans andDomestic Animals(Immediatelyfollowing PPE andUser SafetyRequirements.)User SafetyRecommendations“User Safety RecommendationsUsers should wash hands before eating, drinking, chewing gum, using tobacco, or using thetoilet.Users should remove clothing/PPE immediately if pesticide gets inside. Then washthoroughly and put on clean clothing. If pesticide gets on skin, wash immediately withsoap and water.Users should remove PPE immediately after handling this product. Wash the outside ofgloves before removing. Assoon as possible, wash thoroughly and change into cleanclothing.”PrecautionaryStatements under:Hazards to Humansand DomesticAnimals immediatelyfollowingEngineering Controls(Must be placed in abox.)Page 116 of 304Environmental HazardStatement for Terrestrial Uses“This pesticide may be toxic to fish and aquatic invertebrates. Do not apply directly towater, to areas where surface water is present,or to intertidal areas below the mean highwater mark except as noted on appropriate labels. Drift and runoff may be hazardous toaquatic organisms in water adjacent to treated areas. Do not contaminate water whendisposing of equipment wash waters or rinsate.This chemical has properties and characteristics associated with chemicals detected ingroundwater. The use of this chemical in areas where soils are permeable, particularlywhere the water table is shallow, may resultin groundwater contamination. Applicationaround a cistern or well may result in contamination of drinking water or groundwater.”PrecautionaryStatementsimmediatelyfollowing the UserSafetyRecommendationsEnvironmental HazardStatement for products usedfor aquatic weed control“Fish breathe dissolved oxygen in the water and decaying weeds also use oxygen. Whentreating continuous, dense weed masses, it maybe appropriate to treat only part of theinfestation at a time. For example, apply the product in lanes separated by untreated stripsthat can be treated after vegetation in treatedlanes has disintegrated. During the growingseason, weeds decompose in a 2 to 3 week period following treatment. Begin treatmentalong the shore and proceed outwards in bands toallow fish to move into untreated areas.Waters having limited and less dense weed infestations may not require partial treatments.”PrecautionaryStatementsimmediatelyfollowing the UserSafetyRecommendationsRestricted-Entry Interval forproducts containing withdirections for use within thescope of the WPS andcontaining 2,4-D acid or amineforms“Do not enter or allow worker entry into treated areas during the restricted entry interval(REI) of 48 hours.”Directions for Use,Under AgriculturalUse RequirementsBoxRestricted-Entry Interval forproducts containing withdirections for use within thescope of the WPS andcontaining 2,4-D salt or esterforms“Do not enter or allow worker entry into treated areas during the restricted entry interval(REI) of 12 hours.”Directions for Use,Under AgriculturalUse RequirementsBoxPage 117 of 304Early Entry PersonalProtective Equipmentestablished by the RED forproducts containing 2,4-D acidor amine forms and with WPSuses“PPE required for early entry to treated areasthat is permitted under the Worker ProtectionStandard and that involves contact with anything that has been treated, such as plants, soil,or water is:- coveralls,- chemical-resistant gloves made of any water-proof material,- shoes plus socks,- protective eyewear.”Directions for Use,Agricultural UseRequirements BoxEarly Entry PersonalProtective Equipmentestablished by the RED forproducts containing 2,4-D saltor ester forms and with WPSuses“PPE required for early entry to treated areasthat is permitted under the Worker ProtectionStandard and that involves contact with anything that has been treated, such as plants, soil,or water is:- coveralls,- chemical-resistant gloves made of any water-proof material,- shoes plus socks.”Directions for Use,Agricultural UseRequirements BoxEntry Restrictions for GranularFormulations with directionsfor use outside the scope of theWPS“Do not enter or allow people (or pets) to enter the treated area until dusts have settled.” If no WPS uses on theproduct, place theappropriate statementin the Directions forUse Under GeneralPrecautions andRestrictions. If theproduct also containsWPS uses, then createa NonAgricultural UseRequirements box asdirected in PR Notice93-7 and place theappropriate statementinside that box.Page 118 of 304Entry Restrictions for liquids,water-dispersible granules, andwettable powders formulatedin water-soluble packages withdirections for use outside thescope of the WPS“Do not enter or allow people (or pets) to enter the treated area until sprays have dried.” If no WPS uses on theproduct, place theappropriate statementin the Directions forUse Under GeneralPrecautions andRestrictions. If theproduct also containsWPS uses, then createa NonAgricultural UseRequirements box asdirected in PR Notice93-7 and place theappropriate statementinside that box.General ApplicationRestrictions for productsprimarily intended foroccupational (professional) use“Do not apply this product in a way that will contact workers or other persons, eitherdirectly or through drift. Only protected handlers may be in the area during application.”Directions for Useunder GeneralPrecautions andRestrictionsPage 119 of 304Use-Specific ApplicationRestrictions(Note: The maximumallowable application rate mustbe listed as pounds or gallonsof formulated product persurface acre, not just as poundsacid equivalent per surfaceacre.)“Aquatic weed control”For all acids, salts, amines, and butoxyethanolester forms used for aquatic weed control,the following statements must appear on the product label:> “Ditchbank applicationPostemergence:Limited to 2 applications per season.Maximum of 2.0 lbs ae/acre per application.Minimum of 30 days between applications.Spot treatment permitted.Do not use on small canals with a flow rate less than 10 cubic feet per second (CFS) wherewater will be used for drinking purposes. CFS may be estimated by using the formulabelow. The approximate velocity neededfor the calculation can be determined byobserving the length of time that it takes a floating object to travel a defined distance.Divide the distance (ft.) by the time (sec.) toestimate velocity (ft. per sec.). Repeat 3 timesand use the average to calculate CFS.Average Width (ft.) x Average Depth (ft.) x Average Velocity (ft. per sec.) = CFSFor ditchbank weeds:Do not allow boom spray to be directed onto water surface.Do not spray across stream to opposite bank.Directions for UseAssociated with theSpecific Use PatternPage 120 of 304Use-Specific ApplicationRestrictions(Note: The maximumallowable application rate mustbe listed as pounds or gallonsof formulated product persurface acre, not just as poundsacid equivalent per surfaceacre.)For shoreline weeds:Allow no more than 2 foot overspray onto water.”> “Floating and Emergent WeedsMaximum of 4.0 lbs ae/surface acre per application.Limited to 2 applications per season.Minimum of 21 days between applications.Spot treatments are permitted.Apply to emergent aquatic weeds in ponds, lakes, reservoirs, marshes, bayous, drainageditches, non-irrigation canals, rivers, and streams that are quiescent or slow moving.Coordination and approval of local and state authorities may be required, either by letter ofagreement or issuance of special permits for aquatic applications.Water Use1. Water for irrigation or sprays:A.If treated water is intended to be used onlyfor crops or non-crop areas that are labled fordirect treatment with 2,4-D such as pastures, turf, or cereal grains, the treated water may beused to irrigate and/or mix sprays for these sites at anytime after the 2,4-D aquaticapplication.Directions for UseAssociated with theSpecific Use PatternPage 121 of 304Use-Specific ApplicationRestrictionsB.Due to potential phytotoxicity considerations, the following restrictions are applicable:If treated water is intended to be used to irrigate or mix sprays for plants grown incommercial nurseries and greenhouses; and other plants or crops that are not labeled fordirect treatment with 2,4-D, the water must not be used unless one of the followingrestrictions has been observed:i.A setback distance from functional water intake(s) of greater than or equal to 600 ft. wasused for the application, or,ii.A waiting period of 7 days from the time of application has elapsed, or,iii.An approved assay indicates that the 2,4-D concentration is 100 ppb (0.1 ppm) or less atthe water intake. Wait at least 3 days afterapplication before initial sampling at waterintake.2. Drinking water (potable water):A.Consult with appropriate stateor local water authorities beforeapplying this productto public waters. State or local agenciesmay require permits. The potable water userestrictions on this label are to ensure thatconsumption of water bythe public is allowedonly when the concentration of 2,4-D inthe water is less than the MCL (MaximumContaminant Level) of 70 ppb. Applicators should consider the unique characteristics of thetreated waters to assure that 2,4-D concentrations in potable water do not exceed 70 ppb atthe time of consumption.Directions for UseAssociated with theSpecific Use PatternPage 122 of 304Use-Specific ApplicationRestrictionsB.For floating and emergent weed applications, the drinking water setbackdistance from functioning potablewater intakes is greaterthan or equal to 600 ft.C.If no setback distance of greater than orequal to 600 ft. is used for application,applicators or the authorizing organization must provide a drinking water notification priorto a 2,4-D application to the party responsible for public water supply or to individualprivate water uses. Notification to the party responsible for a public water supply or toindividual private water users must be done ina manner to assure that the party is aware ofthe water use restrictions when thisproduct is appliedto potable water.The following is an example of a notificationvia posting, but other methods of notificationwhich convey the above restrictions may be used and may berequired in some cases understate or local law or as a condition of a permit.Example:Posting notification should be located every 250feet including the shoreline of the treatedarea and up to 250 feet of shoreline past theapplication site to include immediate publicaccess points. Posting must include the day and time of application. Posting may beremoved if analysis of a sample collected atthe intake 3 or more days following applicationshows that the concentration in the water is less than 70 ppb (100 ppb for irrigation orsprays), or after 7 days following application, whichever occurs first.Directions for UseAssociated with theSpecific Use PatternPage 123 of 304Use-Specific ApplicationRestrictionsText of notification:Wait 7 days before diverting functioning surface water intakesfrom the treated aquatic site to use as drinking water, irrigation, or sprays, unless water atfunctioning drinking water intakes is tested at least 3 days after application and isdemonstrated by assay to contain not more than70 ppb 2,4-D (100 ppb for irrigation orsprays).Application Date:_____ Time:______D.Following each application of this product, treated water must not be used fordrinking water unless one of the following restrictions has been observed:i.A setback distance from functional water intake(s) of greater than or equal to 600 ft. wasused for the application, or,ii.A waiting period of at least 7 days fromthe time of application has elapsed, or,iii.An approved assay indicates that the 2,4-D concentration is 70 ppb (0.07 ppm) or less atthe water intake. Sampling for drinking wateranalysis should occur no sooner than 3 daysafter 2,4-D application. Analysis of samples must be completed by a laboratory that iscertified under the Safe Drinking Water Act toperform drinking water analysis using acurrently approved version of analytical Method Number 515, 555, other methods for 2,4-D as may be listed in Title 40 CFR, Part 141.24, or Method Number 4015 (immunoassayof 2,4-D) from U.S. EPA Test Methods for Evaluating Solid Waste SW-846.E.Note: Existing potable water intakes that are nolonger in use, such as those replacedby a connection to a municipal water system ora potable water well, are notconsidered to be functioning potable water intakes.Directions for UseAssociated with theSpecific Use PatternPage 124 of 304Use-Specific ApplicationRestrictionsF.Drinking water setback distances do not apply to terrestrial applications of 2,4-Dadjacent to water bodies with potable water intakes.3. Swimming (2,4-D butoxyethanol ester only):A.Do not swim in treated water fora minimum of 24 hours after application.B.Users must provide notification priorto performing a 2,4-D BEE application.Notification to the party responsible for thepublic swimming area or to individual privateusers must be done in a manner to assure thatthe party is aware of the water use swimmingrestrictions when this product is applied to water. The following is an example of anotification via posting, but other methodsof notification which convey the aboverestrictions may be used and may be required in some cases under state or local law or as acondition of a permit.Example:Posting notification should be located every250 feet including the shoreline of the treatedarea and up to 250 feet of shoreline past theapplication site to include immediate publicaccess points.Text of Notification:Do not swim in treated water for a minimum of 24 hours afterapplication. Application Date: ______ Time: _____ .4.Except as stated above, there are no restrictions on using water from treated areas forswimming, fishing, watering livestock or domestic purposes.”Directions for UseAssociated with theSpecific Use PatternPage 125 of 304Use-Specific ApplicationRestrictions(Note: The maximumallowable application rate mustbe listed as pounds or gallonsof formulated product per acrefoot, not just as pounds acidequivalent per acre-foot.)> “Submersed WeedsMaximum of 10.8 lbs ae/per acre-foot per application.Limited to 2 applications per season.Apply to aquatic weeds in ponds, lakes, reservoirs, marshes, bayous,drainage ditches, nonirrigation canals, rivers, and streams that are quiescent or slow moving.Do not apply within 21 days of previous application.When treating moving bodies of water, applications must be made while travelingupstream to prevent concentration of 2,4-D downstream from the application.Coordination and approval of local and state authorities may be required, either by letter ofagreement or issuance of special permits for such use.Directions for UseAssociated with theSpecific Use PatternTable 1. Amount of 2,4-D to Apply for a Target Subsurface ConcentrationSurface Area Average Depth For typicalconditions - 2 ppm2,4-D ae/acre-footFor difficultconditions* - 4ppm 2,4-D ae/acrefoot1 acre1 ft. 5.4 lbs 10.8 lbs2 ft. 10.8 lbs 21.6 lbs3 ft. 16.2 lbs 32.4 lbs4 ft. 21.6 lbs 43.2 lbs5 ft. 27.0 lbs 54.0 lbs* Examples include spot treatment of pioneer colonies of Eurasian Water Milfoil andcertain difficult to control aquatic species.Page 126 of 304Use-Specific ApplicationRestrictionsWater Use:1.Water for irrigation or sprays:A.If treated water is intended to be used only for crops or non-crop areas that are labeledfor direct treatment with 2,4-D such as pastures, turf, or cereal grains, the treated water maybe used to irrigate and/or mix sprays forthese sites at anytime after the 2,4-D aquaticapplication.B.Due to potential phytotoxicity and/or residue considerations, the following restrictionsare applicable:If treated water is intended to be used to irrigate or mix sprays for unlabeled crops, noncrop areas or other plants not labeled for direct treatment with 2,4-D, the water must not beused unless one of the following restrictions has been observed:i.A setback distance described in the Drinking Water Setback Table was used for theapplication, or,ii.A waiting period of 21 days from the time of application has elapsed, or,iii.An approved assay indicates that the 2,4-D concentration is 100 ppb (0.1 ppm) or less atthe water intake. See Table 3 for the waiting period after application but before taking theinitial sampling at water intake.2. Drinking water (potable water):A.Consult with appropriate state or local water authorities before applying this product topublic waters. State or local agencies may require permits.Directions for UseAssociated with theSpecific Use PatternPage 127 of 304Use-Specific ApplicationRestrictionsThe potable water use restrictions on this label are to ensure that consumption of water bythe public is allowed only when the concentration of 2,4-D in the water is less than theMCL (Maximum Contaminant Level) of 70ppb. Applicators should consider the uniquecharacteristics of the treated waters to assurethat 2,4-D concentrations in potable water donot exceed 70 ppb at the time of consumption.B.For submersed weed applications, the drinking water setback distances fromfunctioning potable water intakes are provided in Table 2. Drinking Water SetbackDistance (below).C.If no setback distance from the Drinking Water Setback Table (Table 2) is to be used forthe application, applicators or the authorizing organization must provide a drinking waternotification and an advisory to shut offall potable water intakes prior to a 2,4-Dapplication. Notification to the party responsible for a public water supply or to individualprivate water users must be done in a manner toassure that the party is aware of the wateruse restrictions when this product is applied to potable water. The following is an exampleof a notification via posting, but other methods of notificationwhich convey the aboverestrictions may be used and may be required in some cases under state or local law or as acondition of a permit.Directions for UseAssociated with theSpecific Use PatternPage 128 of 304Use-Specific ApplicationRestrictionsExample:Posting notification should be located every 250 feet including the shoreline of the treatedarea and up to 250 feet of shoreline past theapplication site to include immediate publicaccess points. Posting should include the dayand time of application. Posting may beremoved if analysis of a sample collected atthe intake no sooner than stated in Table 3(below) shows that the concentration in thewater is less than 70 ppb (100 ppb for irrigationor sprays), or after 21 days followingapplication, whichever occurs first.Text of notification:Wait 21 days before diverting functioning surface water intakes fromthe treated aquatic site to use as drinkingwater, irrigation, or sprays, unless water atfunctioning drinking water intakesis tested no sooner than (insert days from Table 3) and isdemonstrated by assay to contain not more than 70 ppb 2,4-D (100 ppb for irrigation orsprays).Application Date: ______ Time: _____ .D.Following each application of this product, treated water must not be used for drinkingwater unless one of the followingrestrictions has been observed:i.A setback distance described in the Drinking Water Setback Distance Table was used forthe application, or,ii.A waiting period of at least 21 days fromthe time of application has elapsed, or,Directions for UseAssociated with theSpecific Use PatternPage 129 of 304Use-Specific ApplicationRestrictionsiii.An approved assay indicates that the 2,4-D concentration is 70 ppb (0.07 ppm) or less atthe water intake. Sampling for drinking water analysis should occur no sooner than statedin Table 3. Analysis of samples must be completed by a laboratory that is certified underthe Safe Drinking Water Act to perform drinking water analysis using a currently approvedversion of analytical Method Number 515, 555,other methods for 2,4-D as may be listed inTitle 40 CFR, Part 141.24, or Method Number 4015 (immunoassay of 2,4-D) from U.S.EPA Test Methods for Evaluating Solid Waste SW-846.E.Note: Existing potable water intakes that are no longer in use, such as those replaced bya connection to a municipal water system or apotable water well, are not considered to befunctioning potable water intakes.F.Drinking water setback distances do not apply to terrestrial applications of 2,4-Dadjacent to water bodies with potable water intakes.Directions for UseAssociated with theSpecific Use PatternPage 130 of 304Use-Specific ApplicationRestrictions3. Swimming (2,4-D butoxyethanol ester only):A.Do not swim in treated water for a minimum of 24 hours after application.B.Users must provide the following notification prior to performing a 2,4-D BEEapplication. Notification to the party responsible for the public swimming area or toindividual private users must be done in a manner to assure that the party is aware of thewater use swimming restrictions when this product is applied to water. The following is anexample of a notification via posting, but other methods of notification which convey theabove restrictions may be used and may be required in some cases under state or local lawor as a condition of a permit.Example:Posting notification should be located every 250 feet including the shoreline of the treatedarea and up to 250 feet of shoreline past theapplication site to include immediate publicaccess points.Text of Notification:Do not swim in treated water for a minimum of 24 hours afterapplication. Application Date: ______ Time: _____ .4.Except as stated above, there are no restrictions on using water from treated areas forswimming, fishing, watering livestock or domestic purposes.”Directions for UseAssociated with theSpecific Use PatternUse-Specific ApplicationRestrictionsTable 2. Drinking Water Setback Distancefor Submersed Weed ApplicationsDirections for UseAssociated with theSpecific Use PatternApplication Rate and Minimum Setback Distance (feet) From Functioning Potable WaterIntakePage 131 of 3041 ppm* 2 ppm* 3 ppm* 4 ppm*600 1200 1800 2400* ppm acid equivalent target water concentrationTable 3. Sampling for Drinking Water Analysis After 2,4-D Application forSubmersed Weed ApplicationsMinimum Days After Application BeforeInitial Water Sampling at the FunctioningPotable Water Intake1 ppm* 2 ppm* 3 ppm* 4 ppm*5 10 10 14* ppm acid equivalent target water concentration”Page 132 of 304Use-Specific ApplicationRestrictions(Note: The maximumallowable application rate mustbe listed as pounds or gallonsof formulated product per acre,not just as pounds acidequivalent per acre.“Asparagus”Permitted forms of 2,4-D include acid, salts, and amines.“The preharvest interval (PHI) is 3 days.Limited to 2 applications per crop cycle.Maximum of 2.0 lb ae/acre per applicationMinimum of 30 days between applications.”“Blueberry, low bush”Permitted forms of 2,4-D include acid, salts, and amines.“Postemergence:Limited to one postemergence application per year.Maximum of 0.0375 lbs ae/gallons ofspray solution per application.Postharvest:Limited to one postharvest application per year.Maximum of 1.0 lbs ae/gallon spray solution per application.For spot or directed wipe treatment only.Apply only in non-bearing years.”Directions for UseAssociated with theSpecific Use PatternPage 133 of 304Use-Specific ApplicationRestrictions(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Blueberry, high bush”Permitted forms of 2,4-D include acid, salts, and amines.“The preharvest interval (PHI) is 30 days.Postemergence and postharvest:Limited to 2 applications per year.Maximum of 1.4 lbs ae/acre per application.”“Cereal Grains (wheat, barley, millet, oats, and rye)”Permitted forms of 2,4-D include acid, salts, amines, and esters.“The preharvest interval (PHI) is 14 days.Postemergence:Limited to one postemergence application per crop cycle.Maximum of 1.25 lbs ae/acre per application.Preharvest:Limited to one preharvest application per crop cycle.Maximum of 0.5 lbs ae/acre per application.Limited to 1.75 lbs ae/acre per crop cycle.”Directions for UseAssociated with theSpecific Use PatternPage 134 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Citrus (growing fruit)Permitted form of 2,4-D is isopropyl ester.“The preharvest interval (PHI) is 7 days.-To increase fruit size on growing Navel oranges, Valencia oranges, and grapefruit:Limited to one application per crop cycle.Maximum of 45 grams ae per acre (0.1 lbs ae/acre).-To reduce pre-harvest fruit drop on growingNavel oranges, Valencia oranges, andgrapefruit:Limited to one application per crop cycle.Maximum rate of 200 ppm per application.-To prevent pre-harvest drop of mature fruit and leaves on lemons, Navel oranges, Valenciaoranges, and Tangelos:Limited to one application per crop cycle.Maximum rate of 24 ppm per application.”Directions for UseAssociated with theSpecific Use PatternPage 135 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)Postharvest Citrus TreatmentPermitted form of 2,4-D is isopropyl ester.“Permitted application methods include dip or spray.Postharvest packing house application to lemons:Limited to one application per crop.Maximum rate of 500 ppm per application.”Directions for UseAssociated with theSpecific Use PatternPage 136 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Corn, field and pop”Permitted forms of 2,4-D include acid, salts, amines, and esters.“Do not use treated crop as fodder for 7 days following application.The preharvest interval (PHI) is 7 days.Maximum of 3 lbs ae/acre per crop cycle.Preplant or preemergence:Limited to one preplant or preemergence application per crop cycle.Maximum of 1.0 lb ae/acre per application.Postemergence:Limited to one postemergence application per crop cycle.Maximum of 0.5 lb ae/acre per application.Preharvest:Limited to one preharvest application per crop cycle.Maximum of 1.5 lbs ae/acre per application.”Directions for UseAssociated with theSpecific Use PatternPage 137 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Corn, sweet”Permitted forms of 2,4-D include acid, salts, amines, and esters.“Do not use treated crop as fodder for 7 days following application.The preharvest interval (PHI) is 45 days.Minimum of 21 days between applications.Maximum of 1.5 lbs ae/acre per crop cycle.Preplant or preemergence:Limited to one preplant or preemergence application per crop cycle.Maximim of 1.0 lb ae/acre per application.Postemergence:Limited to one postemergence application per crop cycle.Maximum of to 0.5 lb ae/acre per application.”Directions for UseAssociated with theSpecific Use PatternPage 138 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Cranberries”Permitted forms of 2,4-D include acid, salts, amines, and esters.“The preharvest interval (PHI) is 30 days.Dormant Season:Limited to one application per crop cycle.Maximum of 4.0 lbs ae/acre per dormant seasonPostemergence:Limited to 2 applications per crop cycle.Maximum of 1.2 lbs ae/acre per postemergence application.”“Filberts”Permitted forms of 2,4-D include acid, salts, and amines.“The preharvest interval (PHI) is 45 days.Minimum of 30 days between applications.Limited to 4 applications per year.Maximum of 1.0 lbs ae per 100 gallonsof spray solution per application.“Fallowland (crop stubble on idle land, orpostharvest to crops, or between crops)”Permitted forms of 2,4-D include acid, salts, amines, and esters.“Plant only labeled crops within29 days following application.Limited to 2 applications per year.Maximum of 2.0 lbs ae/acre per application.Minimum of 30 days between applications.”Directions for UseAssociated with theSpecific Use PatternPage 139 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Forestry (forest site preparation, forest roadsides, brush control, established coniferrelease, Chrismas trees, reforestation areas)”Permitted forms of 2,4-D include acid, salts, amines, and esters.Broadcast application:Limited to 1 broadcast application per year.Maximum of 4.0 lbs ae/acre per broadcast application.Basal spray, Cut Surface - Stumps, and Frill:Limit of one basal spray or cut surface application per year.Maximum of 8.0 lbs ae per 100 gallons of spray solution.Injection:Limit to one injection application per year.Maximum of 2 ml of 4.0 lbs ae formulation per injection site.”“Grapes”Permitted forms of 2,4-D include acid, salts, and amines.“For use only in California.The preharvest interval (PHI) is 100 days.Limited to 1 application per crop cycle.Maximum of 1.36 lbs ae/acre per application.”Directions for UseAssociated with theSpecific Use PatternPage 140 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Grasses (pastures and rangelandnot in agricultural production)”Permitted forms of 2.4-D include acid, salts, amines, and esters.“The preharvest interval (PHI) is 7 days (cut forage for hay).Postemergence:Limited to 2 applications per year.Maximum of 2.0 lbs ae/acre per application.Minimum of 30 days between applications.If grass is to be cut for hay, Agricultural Use Requirements for the Worker ProtectionStandard are applicable.For program lands, such as ConservationReserve Program, consult program rules todetermine whether grass or hay may be used.The more restrictive requirements of theprogram rules or this label must be followed.”“Hops”Permitted forms of 2,4-D include acid and amines.“The preharvest interval (PHI) is 28 days.Postemergence:Limited to 3 applications per crop cycle.Maximum of 0.5 lb ae/acre per application.Maximum of 1.5 lbs ae/acre per crop cycle.Minimum of 30 days between applications.”Directions for UseAssociated with theSpecific Use PatternPage 141 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Non-Cropland (fencerows, hedgerows, roadsides, ditches, rights-of-way, utilitypower lines, railroads, airports, and industrial sites)”Permitted forms of 2,4-D include acid, salts, amines, and esters.“Postemergence (annual and perennial weeds):Limited to 2 applications per year.Maximum of 2.0 lbs ae/acre per application.Minimum of 30 days between applications.Postemergence (woody plants):Limited to 1 application per year.Maximum of 4.0 lbs ae/acre per year.Applications to non-cropland areas are not applicable to treatment of commercial timber orother plants being grown for sale or other commercial use, or for commercial seedproduction, or for research purposes.”Directions for UseAssociated with theSpecific Use PatternPage 142 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Pasture and Rangeland (established grass pastures, rangeland, and perennialgrasslands not in agricultural production)”Permitted forms of 2,4-D include acid, salt, amines, and esters.“Do not cut forage for hay within 7 days of application.Postemergence:For susceptible annual and biennial broadleafweeds: Use 1.0 lbs ae/acre per application.For moderately susceptible biennial and perennial broadleaf weeds: Use 1.0 to 2.0 lbsae/acre per application.For difficult to control weeds and woody plants: Use 2.0 lbs ae/acre per application.Spot treatment: Use 2.0 lbs ae/acre.Maximum of two applications per year.Maximum of 4.0 lbs ae/acre per year.Minimum of 30 days between applications.If grass is to be cut for hay, Agricultural Use Requirements for the Worker ProtectionStandard are applicable.”“Pistachios”Permitted forms of 2,4-D include acid, salts, and amines.“Do not cut orchard floor forage forhay within 7 days of application.The preharvest interval (PHI) is 60 days.Postemergence:Limited to 2 applications per year.Maximum of 2.0 lbs ae/acre per application.Minimum of 30 days between applications.”Directions for UseAssociated with theSpecific Use PatternPage 143 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Pome Fruits”Permitted forms of 2,4-D include acid, salts, and amines.“The preharvest interval (PHI) is 14 days.Do not cut orchard floor forage forhay within 7 days of application.Postemergence:Limited to 2 applications per crop cycle.Maximum of 2.0 lbs ae/acre per application.Minimum of 75 days between applications.”“Potatoes”Permitted forms of 2,4-D include acid, salts, amines, and esters.“Only for use on potatoes intended for fresh market.The preharvest interval (PHI) is 45 days.Postemergence:Limited to 2 applications per crop cycle.Maximum of 0.07 lb ae/acre per application.Minimum of 10 days between applications.”Directions for UseAssociated with theSpecific Use PatternPage 144 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Rice”Permitted forms of 2,4-D include acid, salts, and amines.“The preharvest interval (PHI) is 60 days.Maximum of 1.5 lbs ae/acre per crop cycle.”Preplant:Limited to one preplant application per crop cycle.Maximum of 1.0 lbs ae/acre per preplant application..Postemergence:Limited to one postemergence application per crop cycle.Maximum of 1.5 lbs ae/acre per postemergence application.“Rice, wild”Permitted forms of 2,4-D include acid, salts, and amines.“For use in Minnesota only.The preharvest interval (PHI) is 60 days.Postemergence:Limited to 1 application per crop cycle .Maximum of 0.25 lb ae/acre per application.”Directions for UseAssociated with theSpecific Use PatternPage 145 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Sorghum”Permitted forms of 2,4-D include acid, salts, amines, and esters.“The preharvest interval (PHI) is 30 days.Do not permit meat or dairy animals to consume treated crop as fodder or forage for 30days following application.Postemergence (acid, salts, and amines):Limited to 1 application per crop cycle.Maximum of 1.0 lb ae/acre per application.Postemergence (esters):Limited to 1 application per crop cycle.Maximum of 0.5 lb ae/acre per application.”Directions for UseAssociated with theSpecific Use PatternPage 146 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Soybeans”Permitted forms of 2,4-D include acid, salts, amines, and esters.“The maximum rate per crop cycle is 1.0 lb ae/acre.Preplant:Limited to 2 preplant applications per crop cycle.Maximum of 0.5 lb ae/acre per preplant application.> Esters: Apply not less than 7 days prior to planting soybeans.>Amines, acid, salts: Apply not less than 15 days prior to planting soybeans.”or“Preplant:Limited to 1 application per crop cycle.Maximum of 1.0 ae/acre per preplant application.>Esters: Apply not less than 15 days prior to planting soybeans.>Amines, acid, salts: Apply not less than 30 days prior to planting soybeans.”“Stone Fruits”Permitted forms of 2,4-D include acid, salts, and amines.“The preharvest interval (PHI) is 40 days.Do not cut orchard floor forage forhay within 7 days of application.Postemergence:Limited to 2 applications per crop cycle.Maximum of 2.0 lb ae/acre per application.Minimum of 75 days between applications.”Directions for UseAssociated with theSpecific Use PatternPage 147 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Strawberry”Permitted forms of 2,4-D include acid, salts, and amines.“Do not apply in California or Florida.Dormant or after last picking:Limited to 1 application per crop cycle.Maximum of 1.5 lbs ae/acre per application.”“Sugarcane”Permitted forms of 2,4-D include acid, salts, and amines.“Do not harvest cane prior to crop maturity.Do not apply more than 4 lbs ae/acre per crop cycle.Preemergence:Limited to one application per crop cycle.Maximum of 2.0 lbs ae/acre per application.Postemergence:Limited to one application per crop cycle.Maximum of 2.0 lbs ae/acre per application..”Directions for UseAssociated with theSpecific Use PatternPage 148 of 304Other Application Restrictions(Risk Mitigation)(Note: The maximumallowable application rate andmaximum allowable rate peryear must be listed as poundsor gallons of formulatedproduct per acre, not just aspounds acid equivalent peracre.)“Tree Nuts”Permitted forms of 2,4-D include acid, salts, and amines.“The preharvest interval (PHI) is 60 days.Do not cut orchard floor forage for harvest within 7 days of application.Postemergence:Limited to 2 applications per crop cycleMaximum of 2.0 lbs ae/acre per application.Minimum of 30 days between applications.”“Turf, ornamental (golf courses, cemetaries,parks, sports fields, turfgrass, lawns andother grass areas)”Permitted forms of 2,4-D include acid, salts, amines, and esters.“Postemergence:Limited to 2 applications per year.Maximum of 1.5 lbs ae/acre per application.The maximum seasonal rate is 3.0 lbs ae/acre, excluding spot treatments.”“Turf, grown for seed or sod”Permitted forms of 2,4-d include acid, salts, amines, and esters.“Limited to 2 applications per year.Maximum of 2.0 lbs ae/acre per application.Minimum of 21 days between applications.”Directions for UseAssociated with theSpecific Use PatternPage 149 of 304Spray Drift “SPRAY DRIFT MANAGEMENT”“A variety of factors including weather conditions (e.g., wind direction, wind speed,temperature, relative humidity) and method ofapplication (e.g., ground, aerial, airblast,chemigation) can influence pesticide drift.The applicator must evaluate all factors andmake appropriate adjustments when applying this product.”Droplet Size“When applying sprays that contain 2,4-D asthe sole active ingredient, or when applyingsprays that contain 2,4-D mixed with active ingredients that require a Coarse or coarserspray, apply only as a Coarse or coarser spray (ASAE standard 572) or a volume meandiameter of 385 microns or greater for spinning atomizer nozzles.”“When applying sprays that contain 2,4-D mixed with other active ingredients that requirea Medium or more fine spray, apply only asa Medium or coarser spray (ASAE standard572) or a volume mean diameter of 300 microns or greater for spinning atomizer nozzles.”Wind Speed“Do not apply at wind speeds greater than 15 mph. Only apply this product if the winddirection favors on-target deposition and there are not sensitive areas (including, but notlimited to, residential areas, bodies of water,known habitat for nontarget species, nontargetcrops) within 250 feet downwind. If applyinga Medium spray, leave one swath unsprayedat the downwind edge of the treated field.”Directions for UsePage 150 of 304Temperature Inversions“If applying at wind speeds less than 3 mph, the applicator must determine if: a)conditions of temperature inversion exist, orb) stable atmospheric conditions exist at orbelow nozzle height. Do not make applications into areas of temperature inversions orstable atmospheric conditions.”Susceptible Plants“Do not apply under circumstances where spray drift may occur to food, forage, or otherplantings that might be damaged or crops thereof rendered unfit for sale, use orconsumption. Susceptible crops include, butare not limited to, cotton, okra, flowers,grapes (in growing stage), fruit trees (foliage), soybeans (vegetative stage), ornamentals,sunflowers, tomatoes, beans, and other vegetables, or tobacco. Small amounts of spraydrift that might not be visible may injure susceptible broadleaf plants.”Other State and Local Requirements“Applicators must follow all state and local pesticide drift requirements regardingapplication of 2,4-D herbicides. Where stateshave more stringent regulations, they must beobserved.”Equipment“All aerial and ground application equipmentmust be properly maintained and calibratedusing appropriate carriers or surrogates.”Additional requirements for aerial applications:“The boom length must not exceed 75% ofthe wingspan or 90% of the rotor bladediameter.”Page 151 of 304“Release spray at the lowest height consistent with efficacy and flight safety. Do notrelease spray at a height greater than 10 feet above the crop canopy unless a greater heightis required for aircraft safety. This requirement does not apply to forestry or rights-of-wayapplications.”“When applications are made with a crosswind, the swath will be displaced downwind.The applicator must compensate for this byadjusting the path of the aircraft upwind.”Additional requirements for ground boom application:“Do not apply with a nozzle height greater than 4 feet above the crop canopy.”Additional requirements for liquid productsapplied as a spray and containing an esterform of 2,4-D (e.g. 2,4-D butoxyethyl ester,2,4-D ethylhexyl ester, 2,4-D isopropyl ester):“2,4-D esters may volatilize during conditions of low humidity and high temperatures.Do not apply during conditions oflow humidity and high temperatures.”End Use Products Intended for Residential UseApplication Restrictions “Do not apply this product in a way that will contact any person or pet, either directly orthrough drift. Keep people and petsout of the area during application.”Directions for Useunder GeneralPrecautions andRestrictionsEntry Restrictions forliquids,water-dispersible granules, andwettable powders formulatedin water-soluble packages“Do not allow people or pets to enter the treatedarea until sprays have dried.” Directions for useunder GeneralPrecautions andRestrictionsPage 152 of 304Entry Restrictions for granularformulations“Do not allow people or pets to enter the treatedarea until dusts have settled.” Directions for useunder GeneralPrecautions andRestrictionsEnvironmental HazardStatement for Residential Uselabels“This pesticide is toxic to fish and aquatic invertebrates. Do not apply directly to water, toareas where surface water is present, or to intertidal areas below the mean high water markexcept as noted on appropriate labels. Drift and runoff may be hazardous to aquaticorganisms in water adjacent to treated areas.Do not contaminate water when disposing ofequipment wash waters or rinsate.2This chemical has properties and characteristics associated with chemicals detected ingroundwater. The use of this chemical inareas where soils are permeable, particularlywhere the water table is shallow, may resultin groundwater contamination. Applicationaround a cistern or well may result in contamination of drinking water or groundwater.”PrecautionaryStatementsimmediatelyfollowing the UserSafetyRecommendations1PPE that is established on the basis of Acute Toxicity of the end-use product must becompared to the active ingredient PPE inthis document. The moreprotective PPE must be placed in the product labeling. For guidance on which PPE is considered more protective, see PR Notice93-7.2May be deleted forready-to-use products.Page 153 of 304 VI. AppendiciesPage 154 of 304 Appendix A. Table of 2,4-D Use Patterns Eligible for Reregistration (Case 0073)Page 155 of 304Appendix A. Use Patterns Subject to Reregistration for 2,4-D (Case 0073)Use Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsAquaticweed control- DitchbankapplicationWettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid,Solubleconcentrate -solid,Granular2.0 Lbs ae/acre 2 per season 4.0 lbsae/acre30 NA NA See Label Changes Summary Tablein 2,4-D RED.Aquaticweed control- floatingandemergentweedsWettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid,Solubleconcentrate -solid,Granular4.0 Lbsae/surfaceacre2 per season 8.0 lbsae/surfaceacre21 NA NA Apply to aquatic weeds in ponds,lakes, reservoirs,marshes, bayous,drainage ditches, non-irrigationcanals, rivers, and streams that arequiescent or slow moving.Coordination and approval of localand state authorities may be required,either by letter of agreement orissuance of special permits for suchuse.See Label Changes Summary Tablein 2,4-D RED.Use Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 156 of 304Aquaticweed control- submersedweedsWettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid,Solubleconcentrate -solid,Granular10.8 Lbs ae peracre-foot2 per season 21.6 lbs aeper acre-footper season21 24 hourswimmingrestriction for2,4-D BEE formNA Apply to aquatic weeds in ponds,lakes, reservoirs,marshes, bayous,drainage ditches, non-irrigationcanals, rivers, and streams that arequiescent or slow moving.When treating moving bodies ofwater, applications must be madewhile traveling upstream to preventconcentration of 2,4-D downstreamof the application.Coordination and approval of localand state authorities may be required,either by letter of agreement orissuance of special permits for suchuse.See Label Changes Summary Tablein 2,4-D RED.Asparagus Wettable powder,Emulsifiableconcentrate,solubleconcentrate -liquid, solubleconcentrate - solid2.0 Lbs ae/acre 2 per cropcycle4.0 lbsae/acre30 2,4-D acid andamines -48hours;2,4-D salt andesters - 12 hoursNA See Label Changes Summary Tablein 2,4-D RED.Use Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 157 of 304Blueberry,low bushWettable powder,Emulsifiableconcentrate,solubleconcentrate -liquid, solubleconcentrate - solidPostemergence:0.0375Postharvest:1.0lbs ae pergallon spraysolution perapplicationPostemergence: 1Postharvest:10.0375 lbs aeper gallonspraysolutionNA 2,4-D acid andamines -48hours;2,4-D salt andesters - 12 hoursNA Postharvest: For spot or directed wipetreatment only.Apply only in non-bearing years.See Label Changes Summary Tablein 2,4-D RED.Blueberry,high bushWettable powder,Emulsifiableconcentrate,solubleconcentrate -liquid, solubleconcentrate - solid1.4 Lbs ae/acre 2 per year 2.8 lbsae/acreNS 2,4-D acid andamines -48hours;2,4-D salt andesters - 12 hoursPHI - 30 days See Label Changes Summary Tablein 2,4-D REDUse Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 158 of 304Citrus,growing fruitEmulsifiableconcentrateToincreasefruit sizeongrowingNaveloranges,Valenciaoranges,andgrapefruit:0.1To reducepreharvestfruit dropongrowingNaveloranges,Valenciaoranges,andgrapefruit:200To increasefruit size ongrowingNaveloranges,Valenciaoranges, andgrapefruit:lbs ae/acreTo reducepre-harvestfruit drop ongrowingNaveloranges,Valenciaoranges, andgrapefruit:ppm1 per cropcyclesame asmax. singleapp. rateNA 12 hours PHI - 7 days See Label Changes Summary Tablein 2,4-D REDUse Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 159 of 304Topreventpreharvestdrop ofmaturefruit andleaves onlemons,Naveloranges,Valenciaoranges,andTangelos:24To preventpre-harvestdrop ofmature fruitand leaveson lemons,Naveloranges,Valenciaoranges, andTangelos:ppm1 same asmax. singleapp. rateCitrus,postharvesttreatementEmulsifiableconcentrate500 ppm 1 500 ppm NA NA NA Application methods include dip orspraySee Label Changes Summary Tablein 2,4-D REDCorn, fieldand popWettable powder,Emulsifiableconcentrate,Granular, Solubleconcentrate -liquid, Solubleconcentrate - solidPreplantorpreemergence: 1.0Postemergence: 0.5Preharvest: 1.5Lbs ae/acre Preplant orpreemergence: 1Postemergence: 1Preharvest: 13.0 lbsae/acreNA 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursPHI - 7 daysPGI - 7 daysSee Label Changes Summary Tablein 2,4-D REDUse Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 160 of 304Corn, sweet Wettable powder,Emulsifiableconcentrate,Granular, Solubleconcentrate -liquid, Solubleconcentrate - solidPreplantorpreemergence: 1.0Postemergence: 0.5Lbs ae/acre Preplant orpreemergence: 1Postemergence: 11.5 lbsae/acre percrop cycle21 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursPHI - 45 daysPGI - 7 daysSee Label Changes Summary Tablein 2,4-D REDCranberries Wettable powder,Emulsifiableconcentrate,Granular, Solubleconcentrate -liquid, Solubleconcentrate - solidDormantseason:4.0Postemergence: 1.2Dormantseason: lbsae/acre perdormantseasonPostemergence: lbsae/acre perpostemergenceapplicationDormantseason: 1Postemergence: 2Dormantseason: 4 lbsae/acre perdormantseasonPostemergence: 2.4 lbsae/acre perpostemergenceapplicationNS 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursPHI - 30 days See Label Changes Summary Tablein 2,4-D REDFilberts Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid1.0 lbs ae per100 gallonsof spraysolution4 4.0 lbs ae per100 gallonsof spraysolution peryear30 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursPHI - 45 days See Label Changes Summary Tablein 2,4-D REDUse Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 161 of 304Fallowland(crop stubbleon idle land,orpostharvestto crops, orbetweencrops)Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid2.0 Lbs ae/acre 2 per year 4.0 lbsae/acre peryear30 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursNS Plant only label crops within 29 daysfollowing application.See Label Changes Summary Tablein 2,4-D REDForestry(forest sitepreparation,forestroadsides,brushcontrol,establishedconiferrelease,Christmastrees,reforestationareas)Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solidBroadcast:4.0Basalspray, cutsurface -stumps,frill: 8.0Injection:2Broadcast:lbs ae/acreBasal spray,cut surface -stumps, frill:lbs ae per100 gallonsof spraysolutionInjection: mlof 4.0 lbs aeformulationper injectionsite1 per year Broadcast:4.0 lbsae/acre peryearBasal spray,cut surface -stumps, frill:lbs ae per100 gallonsof spraysolutionInjection: mlof 4.0 lbs aeformulationper injectionsiteNA 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursNA See Label Changes Summary Tablein 2,4-D REDGrapes Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid1.36 lbs ae/acre 1 per cropcycle1.36 lbsae/acre peryearNA 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursPHI - 100 days For use in California only.Do not apply to grape foliage, shoots,or stems.See Label Changes Summary Tablein 2,4-D REDUse Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 162 of 304Grasses(pastures andrangelandnot inagriculturalproduction)Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid2.0 Lbs ae/acre 2 per year 4.0 lbsae/acre peryear30 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursPHI - 7 days Do not cut forage for hay within 7days of application.If grass is to be cut for hay,Agricultural Use Requirements forthe Worker Protection Standard areapplicable.For program lands, such asConservation Reserve Program,consult program rules to determinewhether grass or hay may be used.The more restrictive requirements ofthe program rules or this label mustbe followed.See Label Changes Summary Tablein 2,4-D REDHops Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid0.5 Lbs ae/acre 3 per cropcycle1.5 lbsae/acre percrop cycleNS 2,4-D acid andamines - 48hoursPHI - 28 days See Label Changes Summary Tablein 2,4-D REDUse Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 163 of 304NonCropland(fenecrows,hedgerows,roadsides,ditches,rights-ofway, utilitypower lines,railroads,airports, andindustrialsites)Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate -solid, GranularPostemergence(annualandperennialplants): 2Postemergence(woodyplants): 4lbs ae/acre Postemergence (annualandperennialplants): 2Postemergence (woodyplants): 14.0 lbsae/acrePostemergence(annualandperennialplants): 30daysPostemergence(woodyplants):NA2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursNA Applications to non-cropland areasare not applicable to treatment ofcommercial timber or other plantsbeing grown for sale or othercommercial use, or for commercialseed production, or for researchpurposes.See Label Changes Summary Tablein 2,4-D RED.NutOrchardsWettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid2.0 Lbs ae/acre 2 per year 4.0 lbsae/acre peryear30 2,4-D acid andamines - 48hours;2,4-D salt - 12hoursNS Do not cut forage for hay within 7days of application.See Label Changes Summary Tablein 2,4-D RED.Use Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 164 of 304Pasture andRangeland(establishedgrasspastures,rangeland,andperennialgrasslandsnot inagriculturalproduction)Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solidSusceptible annualandbiennialbroadleafweeds: 1.0Moderatelysusceptible biennialandperennialbroadleafweeds: 1.0to 2.0Difficultto controlweeds andwoodyplants: 2.0Spottreatment:2.0Lbs ae/acre 2 per year 4.0 lbsae/acre30 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursDo not forage for hay within 7 daysof application.For program lands, such asConservation Reserve Program,consult program rules to determinewhether grass or hay may be used.The more restrictive requirements ofthe program rules or this label mustbe followed.If grass is to be cut for hay,Agricultural Use Requirements forthe Worker Protection Standard areapplicable.See Label Changes Summary Tablein 2,4-D RED.Pome fruits Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid2.0 Lbs ae/acre 2 per cropcycle4.0 lbsae/acre75 2,4-D acid andamines - 48hours;2,4-D salt - 12hoursPHI - 14 days Do not cut orchard floor forage forhay within 7 days of application.See Label Changes Summary Tablein 2,4-D RED.Use Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 165 of 304Potatoes Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid0.07 Lbs ae/acre 2 per cropcycle0.14 per cropcycle10 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursPHI - 45 days Only for use on potatoes intended forfresh market.See Label Changes Summary Tablein 2,4-D RED.Rice Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solidPreplant:1.0Postemergence:1.5Lbs ae/acre Preplant: 1per cropcyclePostemergence: 1 percrop cycle1.5 lbsae/acre percrop cycleNA 2,4-D acid andamines - 48hours;2,4-D salt - 12hoursPHI - 60 days See Label Changes Summary Tablein 2,4-D RED.Rice, wild Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid0.25 Lbs ae/acre 1 per cropcycle0.25 lbsae/acre percrop cycleNA 2,4-D acid andamines - 48hours;2,4-D salt - 12hoursPHI - 60 days For use in Minnesota only.See Label Changes Summary Tablein 2,4-D RED.Use Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 166 of 304Sorghum Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solidPostemergence(acid,salts, andamines):1.0Postemergence(esters):0.5Lbs ae/acre 1 per cropcyclePostemergence (acid,salts, andamines): 1.0lbs ae/acreper cropcyclePostemergence (esters):0.5 lbsae/acre percrop cycleNA 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hoursPHI - 30 days Do not permit meat or dairy animalsto consume treated crop as fodder orforage for 30 days followingapplication.See Label Changes Summary Tablein 2,4-D RED.Soybean Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid1.0 Lbs ae/acre 1 app. of 1.0lbs ae/acreper cropcycleOR2 apps. Of0.5 lbsae/acre percrop cycle1.0 lbsae/acre percrop cycleNS 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hours- 0.5 lbs ae/acre rate:>Esters: Apply not less than 7 daysprior to planting soybeans.>Amines, acid, salts: Apply not lessthan 15 days prior to plantingsoybeans.1.0 lb ae/acre rate:>Esters: Apply not less than 15 daysprior to planting soybeans.>Amines, acid, salts: Apply not lessthan 30 days prior to plantingsoybeans.See Label Changes Summary Tablein 2,4-D RED.Use Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 167 of 304Stone fruits Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid2.0 Lbs ae/acre 2 4.0 lbsae/acre percrop cycle75 2,4-D acid andamines - 48hours;2,4-D salt - 12hoursPHI - 40 days Do not cut orchard floor forage forhay within 7 days of application.See Label Changes Summary Tablein 2,4-D RED.Strawberry Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solid1.5 Lbs ae/acre 1 1.5 lbsae/acre percop cycleNA 2,4-D acid andamines - 48hours;2,4-D salt - 12hours- Do not apply in California or Florida.Apply in dormant stage or after lastpicking.See Label Changes Summary Tablein 2,4-D RED.Sugarcane Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate - solidPreemergence: 2.0Postemergence: 2.0Lbs ae/acre Preemergence: 1Postemergence: 14 lbs ae/acreper cropcycleNS 2,4-D acid andamines - 48hours;2,4-D salt - 12hours- Do not harvest cane prior to cropmaturity.See Label Changes Summary Tablein 2,4-D RED.Use Site Formulation Max.SingleApp.RateUnit Max. #App. PerCropCycle/YearMax. App.Rate PerCropCycle/YearMin.RetreatmentInterval(days)ReentryInterval (REI)PreharvestInterval (PHI)PregrazingInterval (PGI)PreslaughteringInterval (PSI)Restrictions/CommentsPage 168 of 304Turf,ornamental(golfcourses,cemetaries,parks, sportsfields,turfgrass,lawns, andother grassareas)Wettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate -solid, Granular1.5 Lbs ae/acre 2 3.0 lbsae/acre peryear,excludingspottreatmentsNS NS - See Label Changes Summary Tablein 2,4-D RED.Turf, grownfor seed orsodWettable powder,Emulsifiableconcentrate,Solubleconcentrate -liquid, Solubleconcentrate -solid, Granular2.0 Lbs ae/acre 2 4.0 lbsae/acre percrop cycle21 2,4-D acid andamines - 48hours;2,4-D salt andesters - 12 hours- See Label Changes Summary Tablein 2,4-D RED.Page 169 of 304 Appendix B. Data Supporting Guideline Requirements for the Reregistration of 2,4-DPage 170 of 304Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)PRODUCT CHEMISTRYNewGuidelineNumberOldGuidelineNumber830.1550 61-1 Product Identity and CompositionAll41219701, 41223801, 41926201, 43516401, 43516402,43981801, 40808301, 41219601, 41055804, 41055805,41220101, 41973501, 41055801, 41055802, 41220101,41973501, 41067001, 41203301, 41123601, 41055809,41055810, 41964401, 41055815, 41055816, 41978001,44807001, 41055818, 41055819, 41055812, 41055813,41961301, 41055806, 41055807, 41968301, 41015001,42188601, 42786501, 40443301, 41224201830.1600 61-2ADescription of materials used toproduce the productAll41223801, 41637501, 41790601, 44149301, 44547901,43516401, 40808301, 41246701, 41681901, 41796201,41055804, 41496701, 41055801, 41496701, 41973501,41067001, 41599401, 42537501, 44184201, 41055809,41055815, 41055818, 41055812, 44584501, 44963803,41055806, 44982101, 41015001, 42188601, 41376701,40443301, 41224201830.1620 61-2B Description of production process41223801, 41790601, 44149301, 44547901, 43516401,40808301, 41246701, 41796201, 41496701, 41055801,41973501, 41067001, 41599401, 41789901, 42537501,44184201, 41055809, 41055815, 44727101, 44807001,41055818, 44228301, 41055812, 44584501, 44963803,41055806, 44982101, 41015001, 42188601, 41376701,40443301, 41224201Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 171 of 304830.1670 61-2B Formation of ImpuritiesAll41223801, 41790601, 44149301, 44547901, 43516401,40808301, 41246701, 41496701, 41055801, 41973501,41067001, 41599401, 41789901, 41789902, 41123601,42537501, 44184201, 41055809, 41964401, 42798101,41055815, 41978001, 42798301, 44727101, 44807001,41055818, 42798201, 44228301, 41055812, 41961301,44584501, 44963803, 41055806, 41968301, 44982101,41015001, 42188601, 42786501, 40443301830.1700 62-1 Preliminary AnalysisAll41219701, 41926201, 41790602, 44149302, 44543502,44543503, 44932701, 43516401, 43516402, 43981801,40808301, 41724201, 41724202, 41349001, 41796201,41796202, 41219601, 41796202, 41055805, 41220101,41496701, 41973501, 43777501, 44287101, 41055802,41220101, 41496701, 41973501, 43777502, 44228601,41067001, 41203301, 41735701, 41123601, 41055810,41964401, 43314701, 41055816, 41055819, 44620501,41055813, 44963801, 41349002, 41724201, 41724203,41055807, 45014801, 41015002, 42188601, 40443301,41206901830.1750 62-2 Certification of limitsAll41219701, 41223801, 41926201, 43516401, 43516402,43981801, 40808301, 41219601, 41055804, 41055805,41220101, 41496701, 41973501, 41055801, 41055802,41220101, 41496701, 41973501, 41067001, 41203301,41599401, 41123601, 41055809, 41055810, 41964401,41055815, 41055816, 41978001, 44807001, 41055818,41055819, 41055812, 41055813, 41961301, 44963804,41055806, 41055807, 41968301, 41015001, 42188601,40443301, 41206901Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 172 of 304830.1800 62-3 Analytical MethodAll41219701, 41223801, 41637501, 41926201, 44543502,44543503, 43516401, 43516402, 43981801, 40808301,41219601, 41796202, 41055802, 41220101, 41496701,41055802, 41220101, 41496701, 41067001, 41203301,41599401, 41789902, 41123601, 41055810, 41055816,41055819, 41055813, 449638034, 44963804, 41055807,44982102, 41015002, 42188601, 42786501, 40443301,41206901830.6302 63-2 ColorAll41223801, 44543504, 43516403, 43516404, 40808301,41055803, 41067001, 41123601, 42857203, 41055811,41055817, 41055820, 41055814, 44963802, 41055808,41015003, 40443301, 41224201830.6303 63-3 Physical StateAll41223801, 44543504, 43516403, 43516404, 40808301,41055803, 41067001, 41123601, 42857203, 41055811,41055817, 41055820, 41055814, 44963802, 41055808,41015003, 40443301, 41224201830.6304 63-4 OdorAll41223801, 44543504, 43516403, 43516404, 40808301,41055803, 41067001, 41123601, 42857203, 41055811,41055817, 41055820, 41055814, 44963802, 41055808,41015003, 40443301, 41224201830.6313 63-13Stability to normal and elevatedtemperatures, metals, and metal ionsAll41223801, 41745301, 42023601, 44543504, 41055803,41855701, 42023601, 42795401, 43516403, 43516404,40808301, 41055803, 41855701, 42023601, 42795401,41055803, 42795401, 41973502, 41067001, 41855701,42857209, 41978002, 42487901, 41968303, 44963802,41015003, 42116702, 42786501, 40443301, 41224201830.6314Oxidation/Reduction: ChemicalIncompatibilityAll42023601, 43516403, 43516404, 40808301, 41973501,41067001, 41055811, 41055817, 41055820, 41055814,41968303, 44963802, 41055808, 40443301, 41224201Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 173 of 304830.6315 FlammabilityAll41055811, 41055817, 41055820, 41055814, 41055808,41015003, 40443301, 41224201830.6316 ExplodabilityAll41745302, 43516403, 43516404, 40808301, 41973501,41067001, 42537501, 41055811, 41055817, 41055820,41055814, 41055808, 41015003, 40443301, 41224201830.6317 Storage stabilityAll41745301, 41926203, 43516403, 43516404, 40808301,43260501, 41067001, 41123601, 42227501, 41055811,45642701, 41055817, 43874601, 41055820, 41055814,41055808, 41015003, 42786501, 40443301, 41224201830.6319 MiscibilityAll 40443301, 41224201830.6320 Corrosion characteristics42023601, 43516403, 43516404, 40808301, 43260501,41973501, 41067001, 41123601, 42227501, 41055811,45642701, 41055817, 41055820, 41055814, 41055808,41015003, 40443301, 41224201830.7000 63-12 pHAll41926202, 44543504, 43516403, 43516404, 40808301,41123601, 42857208, 41055811, 41055817, 41055820,41015003, 40443301, 41224201830.7050 None UV/Visable AbsorptionAll 44543504,Datagap830.7100 ViscosityAll41055811, 41055817, 41055820, 41055814, 41055808,41015003, 40443301, 41224201830.7200 63-5 Melting PointAll41223801, 44543504, 41055803, 41067001, 41223801,43516403, 43516404, 40808301, 41055803, 41067001,42537501, 42857209, 42829901, 42831001, 43325003,830.7220 63-6 Boiling PointAll43325001, 42830901, 43325001, 44963802, 43325002,44963802, 42831101, 41015003, 40443301, 41224201Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 174 of 304830.7300 63-7 DensityAll41223801, 44543504, 43516403, 43516404, 40808301,41055803, 41973501, 41067001, 41855701, 41123601,42857204, 41055811, 41055817, 41055820, 41055814,44963802, 41055808, 41015003, 40443301, 41224201830.7370 63-10 Dissociation constants in waterAll41223801, 41308901, 44543504, 41055803, 41067001,41972501, 44543504, 43516403, 43516404, 40808301,41055803, 41067001, 41332009, 41015003, 41224201830.7550 63-11Partition coefficient, shake flaskmethodAll41332004, 44543504, 41332004, 43516403, 43516404,40808301, 41055803, 41067001, 42537501, 42857207,41647001, 44963802, 41055808, 44963802, 41055808,41015003, 42116702, 40443301, 41224201830.7840 63-8 SolubilityAll41223801, 42023601, 41332002, 44543504, 45692501,41055803, 45692501, 43516403, 43516404, 40808301,45692501, 41055803, 41067001, 41332002, 41880601,42537501, 42857205, 43358801, 41055811, 42021002,41978001, 43358802, 41669501, 42830901, 42831101,44963802, 41055808, 41968302, 41015003, 421167023,42786501, 43302001, 40443301, 41224201830.7950 63-9 Vapor PressureAll41223801, 44543504, 41055803, 41067001, 44543504,43516403, 43516404, 40808301, 41055803, 41067001,42537501, 42857206, 42021001, 41431101, 41431301,44963802, 41055808, 44963802, 41055808, 41015003,40443301, 41224201ECOLOGICAL FATE AND EFFECTS835.2120 161-1 HydrolysisA, B410073-01,413537-01, 414831-01, 413496-01, 434412-01,427354-01, 427705-02, 427705-01835.2240 161-2 Photodegradation in WaterA, B411253-06,414831-02,427497-02835.2410 161-3 Photodegradation on SoilA, B 411253-05, 427497-02Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 175 of 304835.2370 161-4 Photodegradation in AirA, B414831-03835.4100 162-1 Aerobic Soil MetabolismA, B431675-01,437991-01,431496-01,434159-01,436859-01,437991-02,438215-01835.4200 162-2 Anaerobic Soil MetabolismA, B 433560-01, 434159-01,835.4400 162-3 Anaerobic Aquatic MetabolismA, B415579-01, 433560-01,425747-01, 437991-03, 436063-01,438829-01,439083-01,437991-05,437991-04835.4300 162-4 Aerobic Aquatic MetabolismA, B420453-01, 429792-01, 441886-01, 437991-06, 431496-01,436910-01, 436859-02, 444394-01, 437796-01, 437991-08,437991-07835.1230 163-1 Leaching-Adsorption/DesorptionA, B 420253-02, 441179-01, 441585-01, 441052-01,Datgap835.1410 163-2 Laboratory VolatilityA, B 417180-01, 420596-01,Datagap835.8100 163-3 Field VolatilityA, B835.6100 164-1 Terrestrial Field DissipationA, B435146-01, 435334-01, 435428-01, 436406-01, 437052-02,437624-04, 437624-03, 437624-01, 438317-02, 438317-01,438491-02, 438640-01, 439147-01, 438727-03, 437634-02446031-01, 434704-01, 436697-02, 435003-01, 436697-01,435928-02, 436121-01, 436768-03, 437052-01, 437979-02,438107-01, 438317-03, 438343-01, 438491-01, 438640-02,438727-02, 438727-01, 438724-01, 446031-02,Datagap835.6200 164-2 Aquatic Field DissipationA, B445250-01,439083-02, 439547-01, 434916-01,458971-01,439083-02, 439547-01,Datagap835.6300 164-3 Forestry DissipationA, B439083-03, 439271-01,439547-02,Datagap840.1100 201-1 Droplet Size SpectrumA, BDatagap840.1200 202-1 Drift Field EvaluationA, BDatagap850.2100 71-1A Avian Acute Oral ToxicityA, B415462-02, 419751-01, 415462-01, 233351, 00138871, 416444-01,414541-01, 411583-03, 72472, 226397, 439350-01Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 176 of 304850.220071-2A71-2BAvian Dietary ToxicityA, B415861-01, 415462-02, 419751-02, 419751-03, 417495-01,233351, 417495-02, 00138870, 00138872, 416444-02, 416444-03,414484-01, 414290-07, 411583-05, 45070, 411583-04, 226397,439349-01, 439352-01850.230071-4A71-4BAvian ReproductionA, B453364-01850.1075 72-1 Fish Toxicity BluegillA, B411583-01, 53986, 419751-05, 419751-04, 0073-091-01, 233350,411583-11, 419751-04, 234027, 419751-04, 01338869, 413538-03,413538-04, 413538-01, 00050674, 00053988, 417373-03, 45068,45069, 439331-01, 439332-01, 439307-01439103-01,Datagap850.1010 72-2A Invertebrate ToxicityA, B411583-01, 419751-06, 232630, 413538-03, 413538-01, 67328850.1075 72-3A Estuarine/Marine Toxicity - FishA, B429797-01, 417373-06, 420183-02, 419751-07, 411583-10,419734-01, 411583-11, 418252-08, 232630, 414290-03, 414290-02,414290-06, 411583-10, 418352-04, 418352-01, 411583-11,418352-06, 418352-03850.1025 72-3B Estuarine/Marine Toxicity - MolluskA, B429797-01, 420183-02, 411583-11, 419734-01, 414290-03,414290-06, 411583-10, 418352-04, 418352-01,Datagap850.1035 72-3C Estuarine/Marine Toxicity - ShrimpA, B417373-06, 419751-07, 411583-11, 419252-08, 232630, 414290-02,414290-05, 418352-06, 418352-03,Datagap850.1045 72-3 Estuarine/Marine Toxicity - PenaidA, BDatagap850.1300 72-4A Fish Early Life Stage - DaphnidA, B417373-04, 420183-04, 417677-01850.1350 72-4BEstuarine/Marine Invertebrate LifeCycleA, B418352-11, 420183-03, 418352-10, 413583-02850.1400 72-4C Freshwater Fish- Acute ToxicityA, B850.1500 72-5 Life Cycle FishA, B413457-01, 417373–05850.4100 122-1ATerrestrial Plant Toxicity, SeedlingEmergenceA, BAppendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 177 of 304850.5400 122-2 Aquatic Plant GrowthA, B850.4225 123-1ASeedling Germination and SeedlingEmergenceA, B424168-02, 426091-1, 442756-01, 430167-02, 423895-01, 431970-03, 431970-02, 431970-01, 424492-01, 439821-01,Datagap850.4250 123-1B Vegetative VigorA, B424168-01, 426091-02, 423439-02, 437882-01, 426693-04,439821-01,Datagap850.4400 123-2 Aquatic Plant GrowthA, B442951-01, 427122-04, 427122-05, 427122-01, 427122-02,427122-03, 415059-04, 414200-02, 415059-01, 415059-03,415059-02, 417321-02, 434886-02, 417321-01, 434886-03,434886-04, 434886-01, 420684-04, 417321-02, 420684-04,420684-03, 417352-03, 417352-06, 417352-04, 417352-05,417352-02850.3020 141-1 Honey Bee Acute ContactA, B445173-04, 445173-01TOXICOLOGY870.1100 81-1 Acute Oral Toxicity-RatA, B00101605, 41920901, 00157512, 00252291, 41709901, 41413501,40629801, 41209001870.1200 81-2 Acute Dermal Toxicity-Rabbit/RatA, B00101596, 41920911, 00157513, 00252291, 41709902, 41413502,40629802, 41209002870.1300 81-3 Acute Inhalation Toxicity-RatA, B00161660, 41986601, 00157514, 40085501, 40352701, 41957601,40629803, 42605202870.2400 81-4 Primary Eye Irritation-RabbitA, B41125302, 41920902, 00157515, 00252291, 40352702, 41413504,40629804, 44725303870.2500 81-5 Primary Skin IrritationA, B42232701, 41920903, 00157516, 00252291, 40352703, 41413505,40629805, 41413505870.2600 81-6 Dermal SensitizationA, B00161659, 41920904, 41642805, 41233701, 40352704, 41413506,40629806, 41209006870.3100 82-1ASubchronic Oral Toxicity: 90-DayStudy RodentA, B41991501,41928101,41994001,41896701,41896702,42021401,43515901,42021402Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 178 of 304870.3150 82-1BSubchronic Oral Toxicity: 90-DayStudy Non-rodentA, B41737301,42780001,42780003,43515501,42780002870.3200 82-2 21-Day Dermal - Rabbit/RatA, B41735304,41735301,41407901,41920905,41735303, 41735306,41735302, 41735305,41407903,41407902870.3465 82-4 90-Day Inhalation-RatA, BDatagap870.4100 83-1B Chronic Feeding ToxicityA, B43612001,430490001870.3700 83-3A Developmental Toxicity - RatA, B00130407, 00130408,41527101, 41527104, 41920906, 41986602,41735201, 42304601, 42304602, 43523101, 43523001, 41527103;41527106, 41527102; 41527105870.3700 83-3B Developmental Toxicity - RabbitA, B41747601,42158703, 42158706, 42055501, 42013501, 42224001,42304603, 42304604, 42158702; 42158704, 42158701, 42158705870.3800 83-4 2-Generation Reproduction - RatA, B00150557, 00163996,Repeat Study Required870.4300 83-5Combined Chronic Toxicity/Carcinogenicity: RatsA, B43879801, 43597201870.4200 83-2B Carcinogenicity MiceA, B43612001870.5265 84-2Gene MutationA, B41409801, 41388204, 41797903, 41409802, 41409803,41388203, 41797902, 42015701, 43935101, 41388202,41797901870.5300 84-2In vitroMammalian Cell GeneMutation TestA, B 43394201, 43327304, 43327302870.5375 84-2In vitroChromosome AberrationA, B 43327305, 43327303, 43327301870.5385 84-2BIn vivochromosome aberrationA, BMustonen,et al., 41478301, 42015704, 42015701, 42015707,41409805, 41870102, 41409806, 41870103, 41478303,42015701, 42015703, 42015706, 43930801, 41478302,42015701, 42015702, 42015705870.5395 84-2 Micronucleus AssayA, B 41409804, 41870101Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 179 of 304870.5450 84-2 Rodent Dominant Lethal AssayA, B41409807, 41498101, 41409808, 41409809, 41498103,43930501, 41498102870.620081-8, 82-7,83-1Neurotoxicity Screening BatteryA, B43115201,43293901870.6300 83-6 Developmental NeurotoxicityA, BDatagap870.7485 85-1 General MetabolismA, B41737302870.7600 85-3 Dermal Penetration and AbsorptionA, BFeldman. R. J. And Maibach, H. I. (1974)OCCUPATIONAL/RESIDENTIAL EXPOSURE875.1100 231Estimation of Dermal Exposure atOutdoor SitesA, B 449722-01, 444598-01875.1300 232Estimation of Inhalation Exposure atOutdoor SitesA, B 449722-01, 444598-01875.2200 132-1b Soil Residue DissipationA, B 446557-01, 446557-04, 446557-03, 450331-01RESIDUE CHEMISTRY860.1200 Directions for UseA, BDatagap860.1300 171-4A Plant MetabolismA, B00004666, 00004667, 00004669, 00004675, 00004676,00004677, 00004680, 00004681, 00004682, 00004683,00004689, 00004693, 00004698, 00004699, 00004715,00004723, 00004960, 00004996, 00074214, 00074215,00074216, 00074217, 00102675, 00102676, 0010267900102717, 00123973, Blacktop and Linscott. (1968),Feung, et al. (1972), 41991503, 42423101, 4243970142615601, 43290501, 43496101860.1300 171-4BLivestock MetabolismA, B 00004705, 00068891, 42605201, 42749701, 43160201Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 180 of 304860.1340 171-4CResidue Analytical Method - PlantcommoditiesA, B00004720, 00033119, 00036171, 00037169, 00042288,00045364, 00045365, 00046125, 00059025, 00059026,00059027, 00059033, 00060113, 00060120, 00060870,00060872, 00060880, 00061012, 00061014, 00061016,00061017, 00061018, 00061645, 00074219, 00075198,00075715, 00075716, 00075719, 00088176, 00102605,00102710, 00102717, 00102719, 00102737, 00102815,00102862, 00102865, 00109535, 00115499, 00115509,00120057, 00121733, 00123269, 00126684, 00127273,00133938, 00136845, 00138635, 00139511, 00139951,00140092, 00156264, PP#6E2606 (1979), Aly and Faust(1964), Bontoyan (1985), Freed (1948), 43289301,43691101, 43893701860.1340 171-4CResidue Analytical Method - LivestockcommoditiesA, B00004701, 00004707, 00004719, 00037169, 00043759,00055485, 00066156, 00068011, 00068892, 00068893,00071787, 00078237, 00102713, 00102714, 00102760,00102816, 00102821, 00115509, 00115515, 00120057Otto et al(1982), 44016501, 44016502,Datagap860.1340 171-4C Residue Analytical Method - WaterA, B00035913, 00115509, 00121711, 00136848, 00140032, Ottoet al(1982)860.1380 171-4E Storage Stability - Plant commoditiesA, B00136845, 00140092, 00145248, 43809901, 43870301,43879901, 43879902, 43879903, 43879904, 43879905,43886401, 43886402, 43886403, 43886404, 43886405,43886406, 43943101, 43963801, 43963802, 44211901,45245601860.1380 171-4EStorage Stability - LivestockcommoditiesA, B 44024801, 44967401860.1380 171-4E Storage Stability - WaterA, B 00035913, 00139511860.1400 171-4FWater, Fish, and Irrigated Crops -Irrigated CropsA, B 00052597, 00139511,DatagapAppendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 181 of 304860.1400 171-4FWater, Fish, and Irrigated Crops -Fish and ShellfishA, B00028443, 00035913, 00043759, 00052597, 00102760,00115741, 43378801, 44135201, 44577801860.1400 171-4FWater, Fish, and Irrigated Crops -WaterA, B00035913, 00038429, 00052597, 00102788, 00115741,00118549, 42968501, 42968502860.1480 171-4JMeat, Milk, Poultry, Eggs - Milk andthe Fat, Meat, and Meat Byproducts ofCattle, Goats, Hogs, Horses, and SheepA, B00004701, 00004707, 00004719, 00059034, 00068892,00068893, 00102714, 44024801860.1480 171-4JMeat, Milk, Poultry, Eggs - Eggs andthe Fat, Meat, and Meat Byproducts ofPoultryA, B 00102719860.1500 171-4KCrop Field Trials (Root and TuberVegetables Group - Potatoes)A, B 00060876, 00102814, 00102862, 00136845, 43886401860.1500 171-4KCrop Field Trials (Legume Vegetables(Succulent or Dried) Group - Soybeanseed)A, B 43356301, 43356302, 43356303, 43669801860.1500 171-4KCrop Field Trials (Foliage of LegumeVegetables Group - Soybean forageand hay)A, B 43356301, 43356302, 43356303, 43669801860.1500 171-4KCrop Field Trials (Citrus -Grapefruits, Lemons, Oranges)A, B00102605, 43870303, 00102879, 00115509, 43870303,45462201, 00042526, 00102605, 00102737, 00139059,00163903, 43870303, 45462201, 45672201860.1500 171-4KCrop Field Trials (Pome Fruits Group- Apples, Pears, Quinces)A, B 00102824, 43943101, 00102824, 43886405860.1500 171-4KCrop Field Trials (Stone Fruits Group- Cherry, Peach, Plum/Fresh Prune)A, B 00088176, 43879902, 43879901, 43879903860.1500 171-4KCrop Field Trials (Berries Group -Blueberries, Raspberries)A, B 00061010, 00061012, 43886403, 44268501, 40881401Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 182 of 304860.1500 171-4KCrop Field Trials (Tree Nut Group -Almond, Filbert, Pecan, Walnut)A, B 00088176, 44211901, 43963801, 43963802, 00115509860.1500 171-4KCrop Field Trials (Cereal GrainsGroup - Barley, grain; Corn, field,grain; Corn, sweet (K+CWHR);Millet, grain; Oats, grain; Rice, grain;Rice, wild, grain; Rye, grain;Sorghum, grain; Wheat, grain)A, B00004610, 00036168, 00036169, 00036171, 00036169,00059025, 00059027, 00059029, 00060117, 00061010,00021755, 00022329, 00025383, 00028385, 00030697,43676801, 43686001, 43693702, 00102865, 43886406,00025330, 00161187, 00036169, 00059028, 00102816,00004594, 00120057, 43747901, 43785901, 43853601,00102719, 00102889, 00120057, 43697801, 43718001,43718002, 00022622, 00036168, 00036170, 00036171,00045369, 00046127, 00059029, 00060111, 00061010,00078482, 00090361, 00127226, 00128778, 43665201,43665202, 43676802, 43797901, 43797903, 44190301,44190302,Datagap860.1500 171-4KCrop Field Trials (Forage, Fodder, andStraw of Cereal Grains Group -Barley, haw and straw; Corn, field,forage, and stover; Corn, sweet, forageand stover; Millet, forage, hay, andstraw; Oat, forage, hay, and straw;Rice, straw; Rye, forage and straw;Sorghum, forage and stover; Wheat,forage, hay, and straw)A, B00036168, 00036171, 00059025, 00059027, 00021755,00022622, 00025383, 00028385, 00030697, 00073273,00075715, 00075724, 00102865, 00127273, 00139511,43676801, 43686001, 43693702, 00059028, 00120057,43747901, 43785901, 00102719, 00102889, 00120057,43697801, 43718001, 43718002, 00004485, 00028173,00028200, 00042288, 00061010, 00063507, 00090360,00102712, 00120057, 00138635, 00144791, 00147047,43665201, 43665202, 43676802, 43797901, 43797903,44190301, 44190302,Datagap860.1500 171-4KCrop Field Trials (Grass Forage,Fodder, and Hay Group - Grass(pastures and rangeland) forage andhay)A, B00004485, 00028173, 00028200, 00042288, 00061010,00063507, 00090360, 00102712, 00120057, 00138635,00144791, 00147047, 43592101, 43610801, 43610802,43665203, 43665204, 43665205, 43779501, 43779502,43779503, 43779504Appendix BData Supporting Guideline Requirementsfor the Reregistration of 2,4-DREQUIREMENTUse PatternsCITATION(S)Page 183 of 304860.1500 171-4KCrop Field Trials (MiscellaneousCommodities - Asparagus; AspiratedGrain Fractions; Cranberries; Grapes;Hops; Pistachios; Strawberries;Sugarcane)A, B00025338, 00060870, 43879905, 43693701, 43709701,00061010, 00061012, 43886402, 00061012, 00102833,43947901, 45245601, 45647101, 45665801, 45512701,43879904, 00102717, 00102812, 43886404, 00030701,00079738, 00102640, 00102794, 00115793, 00127823,43736101, 43736102860.1520 171-4LProcessed Food/Feed (Apples; Barley;Citrus; Corn, field; Grape; Oats;Potato; Prunes; Rice; Rye; Sorghum;Soybean; Sugarcane; Wheat)A, B43943101, 43870302, 43709701, 45245601, 45647101,43879903, 43755402, 43709702, 00030701, 00068889,43755401, 43693701860.1850 165-1 Confined Rotational CropsA, B 43356002OTHER840.1100 201-1 Droplet Size SpectrumA, B Reserved840.1200 202-1 Drift Field Deposition EvaluationA, B ReservedPage 184 of 304 Appendix C. Technical Support DocumentsPage 185 of 304 Appendix C. TECHNICAL SUPPORT DOCUMENTS

Additional documentation in support of this RED is maintained in the OPP docket, located in Room 119, Crystal Mall #2, 1801 South Bell Str eet, Arlington, VA. It is open Monday through Friday, excluding legal holidays, from 8:30 am to 4 pm.

The docket initially contained preliminary risk assessments and related documents as of June 23, 2004. Sixty days later the first public comment period closed. The EPA then considered comments, revised the risk assessment, and added the response to comments documents, preliminary mitigation strategies, and the revised risk assessments to the docket on January 12, 2005. The second sixty day public comment period closed on March 14, 2005. The 2,4-D Reregistration Eligibility Decision (RED), revised risk assessments, and response to comments

documents were made available in the summer of 2005.

All documents, in hard copy form, may be viewed in the OPP docket room or downloaded or viewed via the Internet at the following site:

www.epa.gov/pesticides/reregistration

These documents include:

HED Documents:

1. 2,4-D. HED’s Revised Human Health Risk Assessment for the Reregistration Eligibility Decision (RED) Revised to Reflect Public Comments. PC Code 030001; DP Barcode D316597. May 12, 2005.

2. 2,4-D. Revised Acute and Chronic Dietary Exposure Assessments Including Proposed New Uses Hops and Potatoes for the Reregistration Eligibility Decision. April 18, 2005.

3. 2,4-D: 3 rd Revised Occupational and Residential Exposure and Risk Assessment and Response to Public Comments for the Registrati on Eligibility Decision (RED) Document (PC Code 030001, DP Barcode D316596). May 4, 2005.

4. 2,4-D: Response to Phase 5 Public Comments (PC Code 030001, DP Barcode D315562). June 7, 2005.

5. 2,4-D. Revised Acute and Chronic Dietary Exposure Assessments for the Reregisration Eligibility Decision. October 13, 2004.

6. 2,4-D: Health Effects Division (HED ) Metabolism Assessment Review Committee (MARC) Decision Document-Revised. DP Barcodes D309452 Chemical I.D. No. 030001. Case No. 0073. Meeting date 9/3/03. October 13. 2004.

7. 2,4-D. Revisions to the Product and Residue Chemistry Chatpers of the Reregistration Eligibility Decision; Reregistration Case no. 0073. Chemical I. D. No. 030001; DP Barcode No. D309450 and D309451. October 12, 2004.

8. 2,4-D PC Code 030001, Case No. 0073 DP Barcode D309450 Reregistration Eligibility Decision Revised Chemistry Considerations. October 12, 2004.Page 186 of 304 9. 2,4-D Case 0073 Reregistration Eligibility Decision: Revised Product Chemistry Considerations (DP Barcode D309451). October 12, 2004.

10. 2,4-D - Phase 3 Toxicology Chapter Revision. December 9, 2004.

11. 2,4-D: Response to Public Comments [PC Code 030001, DP Barcode D307717]. December 16, 2004.

EFED Documents:

1. Revised Environmental Fate and Effects Division Revised Preliminary Risk Assessment for the 2,4-Dichlorophenoxyacetic acid (2,4-D) Reregistration Eligibility Decision Document. October 28, 2004.

2. Revised EFED Revised Preliminary Risk Assesssment for the 2,4-D Reregistration Eligibility Document. October 28, 2004.

3. 2,4-D - Response to Public Comments on the Revised EFED Science Chapter for the Reregistration Eligibility Decision Document. October 28, 2004.

4. 2,4-D - Response to Public Comments from the San Francisco Department of the Environment on the EFED Science Chapter for the Reregistration Eligibility Decision Document. November 1, 2004.Page 187 of 304 Appendix D. Citations Considered to be Part of the Data Base Supporting the Reregistration Eligibility Decision (Bibliography) for 2,4-D

### 2,4-D Bibliography

Page 188 of 304 Toxicology References

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. Garry, V. F.; Tarone, R. E.; Kirsch, I. R.; et al. (2001). Biomarker Correlations of Urinary 2,4-D Levels in Foresters: Genomic Instability and Endocrine Disruption. Environmental Health Perspectives (2001). 109 (5): 495-500.

Griffin, R. J. ; Godfrey, V. B.; Kim, Y-C ; et al. (1997). Sex-Dependent Differences in the Disposition of 2,4-Dichlorophenoxyacetic Acid in Sprague-Dawley Rats, B6C3F1 Mice, and Syrian Hamsters. Drug Metabolism and Disposition. The American Society for Pharmacology and Experimental Therapeutics, Vol. 25, No. 9.

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Page 189 of 304 Amer, SM and Aly, FAE (2001). Genotoxic e ffect of 2,4-dichlorophenoxyacetic acid and its metabolite 2,4-dichlorophenol in mouse. Mutat Res 494:1-12.

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Food and Chem Toxicol 39:941-946.

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Occupational and Residential References

2,4-D Smart Meeting , March 6, 2001, Industry Task Force II on 2,4-D Research Data and the USDA Office of Pest Management Policy.

2,4-D Master Label, September 24, 2004, Industry Task Force II on 2,4-D Research Data and the USDA Office of Pest Management Policy.

Abbott, et. al., 1987 “Worker Exposure to a Herbic ide Applied with Ground Sprayers in the United Kingdom”, AIHA Journal 48 (2): 167-175

Bothwell, Max L. and Daley, Ralph J. “Selected Observations on the Persistence and Transport of Residues from Aqua-Kleen 20 (2,4-D) Treatments in Wood and Kalamalka Lakes, B.C.” The National Water Research Institute, Inland Waters Directorate, Pacific and Yukon Region, West Vancouver, B.C. August, 1981.

Burnside, Oliver C. et al, Biologic and Econom ic Assessment of Benefits from Use of Phenoxy

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Page 190 of 304 Crowell, Wendy J., November 1999, “Minnesota DNR Tests the Use of 2,4-D in Managing Eurasian Watermilfoil.” Aquatic Nuisance Species Digest ,, Volume 3, No. 4, pp 42-43.

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Harris and Solomon, 1992, “Human Exposure to 2,4-D Following Controlled Activities on Recently Sprayed Turf,” Journal of Environmental Science and Health, B27 (1), 9-22 (1992).

Industry Task Force II on 2,4-D Research Data, “EPA/SRRD and 2,4-D Task Force Lawn and Turf Application Rate”, May 2, 2005.

Maroni et al./Chapter 6 -Phenoxyacetate Herbicides , Toxicology 143 (2000), 77-83.

Paris et. al. “Second Order Model to Predict Microbial Degradation of Organic Compounds in Natural Waters”, Applied and Environmental Microbiology, Vol. 41, No. 3, March 1981, p. 603-609

USFS, September 20, 1998, 2,4-Dichlorophenoxyacetic acid Formulation - Human Health and Ecological Risk Assessment Final Report , Prepared for the USFS by Syracuse Environmental Research Associates, Inc.

U.S. EPA, August, 1997 Exposure Factors Handbook Volume I - General Factors . U.S. Environmental Protection Agency, Office of Research and Development, EPA/600/P-95/002Fa.

U.S. EPA, February 10, 1998 Draft Standard Op erating Procedures for Residential Exposure

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U.S. EPA, 1998. PHED Surrogate Exposure Guide, V1.1. U.S. Environmental Protection Agency, Office of Pesticide Programs, August 1998.

U.S. EPA SAP, “Exposure Data Requirement fo r Assessing Risks from Pesticide Exposure of Children”, SAP Meeting of March 8, 1999, page 60.

U.S. EPA, 1999, “Use of Values from the PHED Surrogate Table and Chemical-Specific Data.” Science Advisory Council for Exposure, Policy.007, U.S. Environmental Protection Agency, Office of Pesticide Programs.

U.S. EPA, August 7, 2000, "Agricultural Default Transfer Coefficients" Science Advisory Council for Exposure, SOP 003.1, .U.S. Environmental Prot ection Agency, Office of Pesticide Programs.

U.S. EPA, July 5, 2000, “Standard Values for Daily Acres Treated in Agriculture” HED Science Advisory Council for Exposure, Policy.009, U.S. Environmental Protection Agency, Office of Pesticide Programs.

U.S. EPA, 8/9/2001, Quantitative Usage Analysis for 2,4-D.

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U.S. EPA, January 14, 2004, Review of 2,4-D Incident Reports ; Authors: Jerome Blondell, Ph.D. and Monica Hawkins, M.P.H., DP Barcode D297233.

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00025330 Suzuki, H.K.; Fenster, C.R. (1976) Dicamba: Residue Tolerance Peti- tion-- Proso Millet. (Unpublished study received Jan 24, 1979 under 9E2166; prepared in cooperation with Univ. of Nebraska, submitted by Velsicol Chemical Corp., Chicago, Ill.; CDL: 097773-A)

00025338 Klausen-Rogers, G.; Renfrow, J.; Slater, L.; et al. (1970) Residue Results: ?Dicamba|. (Unpublished study received Jun 15, 1973 under 1F1131; prepared in cooperation with Del Monte Corp. and others, submitted by Velsicol Chemical Corp., Chicago, Ill.; CDL:090907-F)

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00036171 Bjerke, E.L.; Dietrich, I.; Baker, L.O.; et al. (1975) A Residue Study of Picloram and 2,4-D in Wheat and Barley following Post- emergence Application of Tordon 22K Weed Killer plus Formula 40 Herbicide: GH-C 821. (Unpublished study received Jul 3, 1975 under 6F1653; prepared in cooperation with Univ. of Montana and Montana State Univ., submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:094498-F)

00037169 Marquardt, R.P.; Luce, E.N. (1961) A new basic procedure for determining phenoxy acid herbicides in agricultural products. Journal of Agricultural and Food Chemistry 9(4):266-270. (Also In unpublished submission received Dec 6, 1972 under 3G1339; submitted by Interregional Research Project No. 4, New Brunswick, N.J.; CDL:093578-A)

00038429 Smith, G.E.; Isom, B.G. (1967) Investigation of effects of large- scale applications of 2,4-D on aquatic fauna and water quality. Pesticides Monitoring Journal 1(3):16-21. (Also in unpublished submission received Jul 11, 1971 under 1E1046; submitted by U.S. Dept. of the Army, Washington, D.C.; CDL:093359-Y)

00042288 Grigsby, B.H.; Farwell, E.D. (1950) Some Effects of Herbicides on Pasture and on Grazing Livestock. Michigan Agricultural Experiment Station Quarterly Bulletin 32(3): 378-385. (Submitter ACD file no. HF-19; also in unpublished submission received Oct 3, 1966 under unknown admin. no.; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:106349-A)

00042526 Meagher, W.G.; Phillips, R.L. (1966) Physiological Effects and Chemical Residues Resulting from 2,4-TP and 2,4,5-TP Sprays used for Control of Preharvest Fruit Drop in Pineappl e Oranges. Progress rept., Jun 30, 1966. (Unpublished study received Mar 4, 1974 under 4E1476; prepared by Univ. of Florida, Citrus Experiment Station, submitted by Interregional Research Project No. 4, New Brunswick, N.J.; CDL:093925-D)

00043280 Whitney, E.W.; Montgomery, A.B.; Martin, E.C.; et al. (1968) The effects of a 2,4-D application on the biota and water quality in Currituck Sound, North Carolina. Without title| ? (? ):13- 17. (Also in unpublished submission received Aug 4, 1976 under 876-222; submitted by Velsicol Chemical Corp., Chicago, Ill.; CDL:242936-D)

00043759 Sikka, H.C. (1976) Fate of 2,4-D in Fi sh and Blue Crabs: Contract No. DACW39-74-C-0068. (Syracuse Research Corp. for U.S. Army, Office of the Chief of Engineers, Environmental Characterization Branch, MESL, Waterways Experiment Station, unpublished study; CDL:099544-D)

### 2,4-D Bibliography

Page 203 of 304 00045364 Swann, R.L.; Pettyjohn, M.A.; Bjerke, E.L. (1972) Determination of Residues of 2,4-D in Wheat, Barley and Oat Green Forage, Grain and Straw by Gas Chromatography. Method ACR 72.8 dated May 12, 1972. (Unpublished study received Jul 3, 1975 under 6F1653; prepared in cooperation with International Research and Development Corp., submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:094500-B)

00045365 Bjerke, E.L. (1973) A Study of Extracti on of Picloram and 2,4-D from Small Cereal Grains: GH-C 680. (Unpublished study received Jul 3, 1975 under 6F1653; submitted by Dow Chemical U.S.A., Mid- land, Mich.; CDL:094500- C)

00045369 Bjerke, E.L.; Ervick, D.K. (1975) A Residue Study of Picloram and 2,4-D in Milled Wheat Fractions: GH-C 798. (Unpublished study received Jul 3, 1975 under 6F1653; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:094501-B)

00046125 Yip, G. (1964) Herbicides and plant growth regulators: Determina- tion of herbicides in oils. Journal of the Association of Official Analytical Chemists 47(6):1116-1119. (Also in unpublished submission received on unknown date under 6F0459; submitted by U.S. Dept. of Agriculture, Agricultural Research Service, unknown location; CDL:098165-I)

00046127 Phillips, W.M.; Yip, G.; Finney, K.F.; et al. (1964) The Effects and Residue Status of Applications of Amine and Es ter; Applica- tions of 2,4-D at Three Preharvest Growth Stages on Hard Red Winter Wheat. (Unpublished study received on unknown date under 6F0459; prepared in cooperation with Kansas State Univ., Agricultural Experiment Station, Dept. of Flour and Feed Milling Industries and others, submitted by U.S. Dept. of Agriculture, Agricultural Research Service, unknown location; CDL:098165-L)

00052597 Frank, P.A. (1969) Residues of 2,4-D in Irrigation Water and Ir- rigated Crops. (U.S. Dept. of Agriculture, Crops Protection Branch, unpublished study; CDL:091863-D)

00055485 Khajeh-Noori, K. (19??) Method for Anal ysis of Residues of N,N- Dimethyl2,4-dichlorophenoxyacetamide on Whole Fish. Undated method. (Unpublished study received Nov 22, 1971 under 16133-1; prepared by Thornton Laboratories, Inc., submitted by Clearwater Chemical Corp., Ft. Myers, Fla.; CDL:015056-K)

00055755 Whitney, E.W.; Montgomery, A.B.; Martin, E.C.; et al. (19??) The effects of a 2,4-D application on the biota and water quality in Currituck Sound, North Carolina. ?Without Title| ? (? ):13-17. (Also in unpublished submission received May 19, 1975 under 2E1221; submitted by U.S. Dept. of the Army, Washington, D.C.; CDL:094080-J)

### 2,4-D Bibliography

Page 204 of 304 00059025 Glas, R.D. (1975) Residues of Dowco 290 and 2,4-D in Wheat and Barley following Postemergence Application of Lontrel 205 Herbicide: GH-C 836. (Unpublished study received Nov 12, 1980 under 464-563; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:099735-D)

00059026 Gardner, R.C.; Bjerke, E.L. (1975) Residues of Dowco 290, 2,4-D and MCPA in Green Forage, Straw and Grain of Wheat and Barley after Postemergence Treatment with Lontrel Herbicides: GH-C 850. (Unpublished study received Nov 12, 1980 under 464-563; submit- ted by Dow Chemical U.S.A., Midland, Mich.; CDL:099735-E)

00059027 Kutschinski, A.H. (1979) Residues of Dowco 290 and 2,4-D in Barley and Wheat following Postemergence Application of Lontrel 205 Herbicide by Ground vs Aerial Sprayer: GH-C 1208. (Unpublished study received Nov 12, 1980 under 464-563; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:099735-F)

00059028 Kutschinski, A.H. (1979) Residues of Dowco 290 and 2,4-D in Oats following Postemergence Application of Lontrel 205 Herbicide: GH-C 1217. (Unpublished study received Nov 12, 1980 under 464- 563; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL: 099735-G)

00059029 Glas, R.D. (1978) Residues of 3,6-Dichloropicolinic acid and 2,4-D in Milling and Malting Fractions following Postemergence Application of Lontrel 205 Herbicide to Wheat and Barley: GH-C 977. (Unpublished study received Nov 12, 1980 under 464-563; sub- mitted by Dow Chemical U.S.A., Midland, Mich.; CDL:099735-H)

00059033 Kutschinski, A.H. (1979) Determination of Residues of 3,6-Dichloro- picolinic acid and 2,4-D in Barley and Wheat by Gas Chromatography. Method ACR 79.5 dated Apr 18, 1979. (Unpublished study received Nov 12, 1980 under 464- 563; submitted by Dow Chemical U.S. A., Midland, Mich.; CDL:099735-L)

00059034 Miller, P.W. (1975) Residues of 2,4-D and 2,4-Dichlorophenol in Milk from Cows Fed 2,4-D in Conjunction with Dowco 290: GH-C 804. (Unpublished study received Nov 12, 1980 under 464-563; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:099736-A)

00060111 American Cyanamid Company (1977) General Summary: Avenge in Wheat Grain and Straw|. (Compilation; unpublished study received Apr 26, 1977 under 241-250; CDL:229617-A)

00060113 Peterson, R.P. (1976) CL 84,777 Combination: Gas Chromatographic Procedure for the Determination of 2,4-D Residues in Wheat. Method M-733 dated Oct 8, 1976. (Unpublished study received Apr 26, 1977 under 241-250; submitted by American Cyanamid Co., Princeton, N.J.; CDL:229617-D)

00060117 American Cyanamid Company (1975) General Summary: ?Studies to Determine Avenge and 2,4-D Residues in Ba rley Grain and Straw|. (Compilation; unpublished study received Apr 26, 1977 under 241- 250; CDL:229616-A)

### 2,4-D Bibliography

Page 205 of 304 00060120 Peterson, R.P. (1976) CL 84,777 Combination: Gas Chromatographic Procedure for the Determination of 2,4-D Residues in Barley. Method M-738 dated Oct 8, 1976. (Unpublished study received Apr 26, 1977 under 241-250; submitted by American Cyanamid Co., Princeton, N.J.; CDL:229616-D)

00060870 Dow Chemical U.S.A. (1956) Residue Study on Samples from Washington and California Trials: 2,4-D for Weed Control in Asparagus Cul- ture. (Unpublished study received Jan 2, 1958 under PP0162; CDL:090188-K)

00060872 Dow Chemical U.S.A. (1955?) Method of Analysis for 2,4-D on Treated Asparagus. (Unpublished study received Jan 2, 1958 under PP0162; CDL:092439-C)

00060876 Florida Fruit & Vegetable Association (1960) The Results of Tests on the Amount of Residue Remaining, Including a Description of the Analytical Method Used: (2,4-D). (Unpublished study received Oct 12, 1963 under PP0272; CDL:090295-B)

00060880 University of California--Davis (19??) Analysis for Combined 2,4-D esters in Potatoes. Undated method. (Unpublished study received Oct 12, 1963 under PP0272; prepared by Agricultural Extension Service, Dept. of Agronomy, submitted by Florida Fruit & Vegetable Association, Orlando, Fla.; CDL:090295-G)

00061010 National Agricultural Chemical Association (1965?) The Results of Tests on the Amount of Residue Remaining, Including a Description of the Analytical Method Used: (2,4-Dichlorophenoxyacetic acid). (Compilation; unpublished study received May 15, 1967 under 8F0670; CDL:091172-AL)

00061012 National Agricultural Chemical Association (1967) Summary of Residues. (Compilation; unpublished study received May 15, 1967 un- der 8F0670; CDL:091172-AN)

00061014 Dow Chemical Company (1959) Analyti cal Method: Determination of Trace Amounts of 2,4-Dichlorophenoxyacetic acid in Sugar Cane Juice. Method no. MLE.59.4 dated Apr 23, 1959. (Unpublished study received May 15, 1967 under 8F0670; submitted by National Agricultual Chemical Association, unknown location; CDL: 091172-AR)

00061016 Dow Chemical Company (1964) Determination of 2,4-Dichlorophenoxya- cetic acid in Peanut Hay and Immature Peanut Vines. Method no. MLE.64.16 dated Aug 20, 1964. (Unpublished study received May 15, 1967 under 8F0670; submitted by National Agricultural Chemical Association, unknown location; CDL:091172-AT)

00061017 Dow Chemical Company (1964) Analytical Method: Determination of 2,4- Dichlorophenoxyacetic acid in Peanuts. Method no. MLE.64.21 dated Apr 17, 1964. (Unpublished study received May 15, 1967 under 8F0670; submitted by National Agricultural Chemical Association, unknown location; CDL:091172- AU)

### 2,4-D Bibliography

Page 206 of 304 00061018 Marquardt, R.P.; Luce, E.N. (1955) Determination of 2,4-Dichlorophenoxyacetic acid (2,4-D) in grain and seed. Agricultural and Food Chemistry 3(1):51-53. (Also In unpublished submission received May 15, 1967 under 8F0670; submitted by National Agricultural Chemical Association, unknown location; CDL:091172-AV)

00061645 Munro, H.E. (1972) Determination of 2,4-Dichlorophenoxyacetic acid and 2,4,5-Trichlorophenoxyacetic acid in tomato plants and other commercial crops by microcoulometric gas chromatography. Pesti- cide Science 3(4):371-377; taken from Weed Abstracts, 1973 22(2):38. (Abstract no. 376). (Also~In~unpublished submission received Dec 9, 1974 under 33652-1; submitted by Chemie Linz AG, Chemie, Austria; CDL:230516-U)

00063507 Colorado. Department of Agriculture (1979) Residue Test No. 1734: Range Grass from York, Nebraska. (Unpublished study; CDL: 244533-J)

00066156 Duffy, J.R.; Shelfoon, P. (1967) Determination of 2,4-D and its butoxyethanol ester in oysters by gas chromatography. Journal of the Association of Official Analytical Chemists 50(5):1098- 1102. (Also~In~unpublished submission received Aug 4, 1976 under 876-222; submitted by Velsicol Chemical Corp., Chicago, Ill.; CDL:229171-E)

00068011 Diamond Shamrock Agricultural Chemicals (1975) Residue Studies in Grass and Hay. (Compilation; unpublished study, including published data, received Nov 19, 1980 under unknown admin. no.; CDL:244821-A)

00068889 Kutschinski, A.H.; Bates, T.W.; Swann, R.L. (1971) Residues of 2,4-D in Sugarcane and Its Factory Products Resulting from Applications of Amine or Ester Formulations of the Herbicides. Final rept. (Unpublished study received Oct 9, 1971 under 8F0670; prepared by Dow Chemical Co. in cooperation with International Research and Development Corp., submitted by National Agricultural Chemicals Association, Industry Task Force on Phenoxy Herbicide Tolerances, Washington, D.C.; CDL:091173-D)

00068891 Miller, P.W.; Jensen, D.J. (1971) Identification of 2,4,6-Tri- chlorophenol and 2,6-Dichlorophenol Residues in Milk from Cows Fed 2,4- Dichlorophenoxyacetic acid. (Unpublished study re- ceived Oct 9, 1971 under 8F0670; prepared by Dow Chemical Co., submitted by National Agricultural Chemicals Association, Industry Task Force on Phenoxy Herbicide Tolerances, Washington, D.C.; CDL:091173-G)

00068892 Miller, P.W.; Jensen, D.J.; Gentry, W.M. (1971) Residues of 2,4- Dichlorophenoxyacetic acid and 2,4-Dichlorophenol in Tissues of Beef Calves Fed 2,4-D. Final rept. (Unpublished study received Oct 9, 1971 under 8F0670; prepared by Dow Chemical Co., submitted by National Agricultural Chemicals Association, Industry Task Force on Phenoxy Herbicide Tolerances, Washington, D.C.; CDL:091173-H)

### 2,4-D Bibliography

Page 207 of 304 00068893 Jensen, D.J.; Miller, P.W.; Palmer, J.S. (1971) Residues of 2,4- Dichlorophenoxyacetic acid and 2,4-Dichlorophenol in Tissues of Sheep Fed 2,4-D. (Unpublished study received Oct 9, 1971 under 8F0670; prepared by Dow Chemical Co. in cooperation with U.S. Agricultural Research Service, Animal Disease and Parasite Research Div., submitted by National AgriculturalChemicals Association, Industry Task Force on Phenoxy Herbicide Tolerances, Washington, D.C.; CDL:091173-I)

00071787 Toetz, D. (1976) Residues of 2,4-D in Fl esh of Selected Fish Species in Lake Fort Cobb as a Result of Herbicide Use on Eurasian Watermilfoil~Myriophyllum spicatum. (Oklahoma State Univ., School of Biological Sciences, Research Foundation for U.S. Dept. of the Interior, Bureau of Reclamation; unpublished study; CDL:099179-D)

00073273 Anon. (1979) A Comparison of Dicamba Dimethylamine Salt Emulsifiable Concentrate with Dicamba Acid Granules in Terms of Stand Reduction and Residues. (Reports by various sources; unpublished study received Nov 3, 1980 under OK 80/13; submitted by Oklahoma, Dept. of Agriculture, Oklahoma City, Okla.; CDL: 243740-A)

00074214 Feung, C.; Hamilton, R.H.; Mumma, R.O. (1975) Metabolism of 2,4- dichlorophenoxyacetic acid. VII. Comparison of metabolites from five species of plant callus tissue cultures. Journal of Agri- cultural and Food Chemistry 23(3):373-376. (Also in unpublished submission received Apr 14, 1981 under 0F2404; submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:070006-D)

00074215 Feung, C.; Hamilton, R.H.; Mumma, R.O. (1973) Metabolism of 2,4-dichlorophenoxyacetic acid. V. Identification of metabolites in soybean callus tissue cultures. Journal of Agricultural and Food Chemistry 21(4):637-640. (Also in unpublished submission received Apr 14, 1981 under 0F2404; submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:070006-E)

00074216 Feung, C.; Hamilton, R.H.; Witham, F.H. (1971) Metabolism of 2,4- dichlorophenoxyacetic acid by soybean cotyledon callus tissue cultures. Journal of Agricultural and Food Chemistry 19(3):475, 479. (Also in unpublished submission received Apr 14, 1981 under 0F2404; submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:070006-F)

00074217 Hamilton, R.H.; Hurter, J.; Hall, J.K.; et al. (1971) Metabolism of 2,4- dichlorophenoxyacetic acid and 2,4,5-trichlorophenoxyacetic acid by bean plants. Journal of Agricultural and Food Chemistry 19(3):480-483. (Also~In~unpublished submission received Apr 14, 1981 under 0F2404; submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:070006-G)

00074219 Lokke, H. (1975) Analysis of free and bound chlorophenoxy acids in cereals. Bulletin of Environmental Contamination & Toxicology 13(6):730-736. (Also~In~unpublished submission received Apr 14, 1981 under 0F2404; submitted by Dow Chemical Co., Indianapolis, Ind.; CDL:070006-J)

### 2,4-D Bibliography

Page 208 of 304 00075198 Carlile, B.L. (1968) Degradation and Depletion of Herbicides in Drainage Waters and Accumulation of Residues in Crops Irrigated with Treated Water: Annual Report--2,4-D and Silvex. (Battelle Memorial Institute for U.S. Dept. of Agriculture; unpublished study; CDL:090913-D)

00075715 Velsicol Chemical Corporation (1981) ?Residues in Corn|. Includes undated method AM-0691. (Compilation, unpublished study received Jun 12, 1981 under 876-25; CDL:245471-B)

00075716 Velsicol Chemical Corporation (1981) ?Residues in Wheat|. In- cludes undated method AM-0691. (Compilation; unpublished study received Jun 12, 1981 under 876-25; CDL:245471-C)

00075719 Velsicol Chemical Corporation (1981) ?Determination of Banvel and Dicamba in Sorghum|. (Compilation; unpublished study received Jun 12, 1981 under 876- 25; CDL:245471-F)

00075724 Velsicol (1981) (Determination of Banvel and Dicamba in Various Crops). Includes method AM-0691 dated Jul 25, 1979. (Compila- tion; unpublished study received Jun 22, 1981 under CO 81/11; CDL:245581-A)

00078237 Bjerke, E.L.; Herman, J.L.; Miller, P.W.; et al. (1971) A Residue Study of Phenoxy Herbicides in Milk and Cream. (Unpublished study received on unknown date under 1E1123; prepared by Dow Chemical U.S.A., submitted by Interregional Research Project No. 4, New Brunswick, N.J.; CDL:098798-A)

00078482 Montana, Department of Agriculture (1974) ?Residue Tests for Picloram in Grains|. (Compilation; unpublished study received on unknown date under 4E1489; CDL:093948-F)

00079738 Velsicol Chemical Corporation (1981) Sugarcane Residue Studies. (Compilation; unpublished study received Sep 11, 1981 under 876- 25; CDL:070319-D)

00088176 Interregional Research Project Number 4 (1978) ?Residues Study of Envy 2,4-D on Stone Fruit|. (Compilation; unpublished study re- ceived Nov 18, 1981 under 2E2606; CDL:070506-A)

00090360 Klingman, D.L.; Gordon, C.H.; Yip, G.; et al. (1966) Residues in the forage and in milk from cows grazing forage treated with esters of 2,4-D. Weeds 14(2):164- 167. (Also~In~unpublished submission received May 31, 1966 under 6F0459;submitted by U.S. Dept. of Agriculture, Agricultural Research Service, unknown address; CDL:090505-A)

00090361 Hilton, J.L.; Phillips, W.M.; Shaw, W.C. (1960) A Summary of the Effects of Amine and Ester Formulations of 2,4-Dichlorophenoxy- acetic Acid ?2,4-D| on Small Grains, Including the Status of Residues When 2,4-D is Applied to the Crop at Various Stage of Growth: Line Project No. CR FL-16. (U.S. Agricultural Research Service, Crops Research Div.; unpublished study; CDL:090505-C)

### 2,4-D Bibliography

Page 209 of 304 00102605 Phillips, R. (1970) 2,4-D--Oranges and Grapefruit--CES (Lake Alfred) 1969. (Unpublished study received Sep 28, 1970 under 359-177; prepared by Univ. of Florida, Dept. of Food Science, Pesticide Research Laboratory, submitted by Rhone-Poulenc, Inc., Monmouth Junction, NJ; CDL:026724-A)

00102640 National Agricultural Chemicals Assoc. (1970) (2,4-D: Residues in Sugarcane). (Compilation; unpublished study received Jan 18, 1971 under 8F0670; CDL:091176-A)

00102675 Canny, M.; Markus, K. (1960) The breakdown of 2,4-dichlorophenoxy- acetic acid in shoots and roots. Australian J. Biol. Sci. 13 (4):486-502. (Also In unpublished submission received Sep 12, 1968 under 8F0670; submitted by National Agricultural Chemicals Assoc., Industry Task Force on Phenoxy Herbicide Tolerances, Washington, DC; CDL:092089-L)

00102676 National Agricultural Chemicals Assoc. (1968) (Phenoxy Herbicides: Residues in Various Crops). (Compilation; unpublished study received Sep 12, 1968 under 8F0670; CDL:092089-O)

00102679 Luckwill, L.; Lloyd-Jones, C. (1960) Metabolism of plant growth regulators I. 2,4-dichlorophenoxyacetic acid in leaves of red and of black currant. II. Decarboxylation of 2,4-dichlorophen- oxyacetic acid in leaves of apple and strawberry. Ann. Appl. Biol. 48(3): 613-636. (Also In unpublished submission received Sep 12, 1968 under 8F0670; submitted by National Agricultural Chemicals Assoc., Industry Task Force on Phenoxy Herbicide Tol- erances, Washington, DC; CDL:092089-AC)

00102710 Florida Fruit & Vegetable Assoc. (1960) (Analyses for 2,4-D Residue in Potatoes). (Compilation; unpublished study received Sep 26, 1960 under PP0272; CDL:092551-D)

00102712 Gentry, W. (1971) Residues of 2,4-Dichlorophenoxyacetic Acid, 2,4,5- Trichlorophenoxyacetic Acid, and 2-( 2,4,5-Trichloro- phenoxy)propionic Acid in Grass Treated with Phenoxy Herbicides. (Unpublished study received Sep 7, 1973 under 8F0670; prepared by Dow Chemical Co., submitted by National Agricultural Chemicals Assoc., Industry Task Force on Phenoxy Herbicide Tolerances, Washington, DC; CDL:092965-C)

00102713 National Agricultural Chemicals Assoc. (1973) Discussion of Anal- yses for Residues of 2,4-D and 2,4-Dichlorophenol in Animal Tissues, July 1973. Summary of study 092142-AD. (Compilation; unpublished study received Sep 7, 1973 under 8F0670; CDL: 092965-D)

00102714 National Agricultural Chemicals Assoc. (1973) Discussion of Anal- yses for Residues of 2,4-D and 2,4-Dichlorophenol in Milk, July 1973. (Compilation; unpublished study received Sep 7, 1973 under 8F0670; CDL:092965-F)

### 2,4-D Bibliography

Page 210 of 304 00102717 Crabtree, G.; Sheets, W.; Montgomery, M.; et al. (1974) Residue Study: 2,4-D for Control of Broadleaf Weeds in Strawberries. (Unpublished study received on unknown date under 5E1544; pre- pared by Oregon State Univ., submitted by Interregional Research Project N o. 4, New Brunswick, NJ; CDL:094206-A)

00102719 National Agricultural Chemicals Assoc. (1975) Summary of Additional Residue Data for 2,4-D in Sorghum, Poultry and Eggs, and Discussion on Residues in/on Forage Grasses. (Compilation; unpublished study received Jul 16, 1975 under 8F0670; CDL: 094530-A)

00102737 Honse, C.; Yoh, J.; Moye, H.; et al. (1973) (Alkanolamine Salt of 2,4-D: Residues in Organs). (Unpublished study received Sep 25, 1975 under 6E1678; prepared by Univ. of Florida, Pesticide Research Laboratory, submitted by Interregional Research Project N o. 4, New Brunswick, NJ; CDL:097352-B)

00102760 Rawls, C. (1968) The Accumulation and Loss of Field-applied Butoxy- ethanol Ester of 2,4-dichlorophenoxyacetic Acid in Eastern Oysters, ... and Soft-shelled Clams, Mya arenaria. (Unpublished study received Jan 5, 1972 under 2E1221; prepared by Univ. of Maryland, Natural Resources Institute, Chesapeake Biological Laboratory, submitted by U.S. Dept. of the Army, Washington, DC; CDL:097882-Z)

00102788 Bartley, T.; Gangstad, E. (1975) Dissipa tion of Residues of 2,4-D in Irrigation Canals. (U.S. Dept. of the Interior, Bure au of Reclamation, Office of the Chief Engineer, Division of Research and U.S. Dept. of the Army, Office of the Chief of Engineers, Directorate of Civ il Works, Planning Div.; unpublished study; CDL:097921-A)

00102794 Kutschinski, A. (1972) Residues of 2,4-D in Louisiana Sugarcane Resulting from Multiple Applications of Amine Formulations In- cluding a Late Summer Treatment: GH-C 512. (Unpublished study received Dec 6, 1973 under 464-1; submitted by Dow Chemical U.S.A., Midland, MI; CDL:101303-A)

00102812 Reasor Hill Corp. (1960) ?Residues of 2,4-D in Strawberries and Cranberries|. (Compilation; unpublished study received Feb 27, 1961 under 347-136; CDL:120079-A)

00102814 Zweig, G. (1962) Letter sent to J. McLean dated Nov 27, 1962 ?Re- port of analysis for 2,4-D in potatoes|. (Unpublished study received Dec 17, 1962 under unknown admin. no.; prepared by Univ. of California--Davis, Presticide Residue Research, sub- mitted by Chemical Machines, Winnipeg, Canada; CDL:120204- A)

00102815 Brannock, D.; Freed, V. (1965) Analysis of Pears and Apples for Residues of 2,4-D from Dacamine-D. (Unpublished study received May 18, 1965 under 677-200; prepared by Oregon State Univ., Dept. of Agricultural Chemistry, submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, OH; CDL:120205-A)

### 2,4-D Bibliography

Page 211 of 304 00102816 Dow Chemical Co. (1955?) Studies on Raw Agricultural Commodities for Residues of 2,4-Dichlorophenoxyacetic Acid (2,4-D). (Un- published study received on unknown date under unknown admin. no.; CDL:120208-A)

00102821 Boyce Thompson Institute for Plant Research, Inc. (1962) Residues of 2,4-D in Milk from Cows Grazing on Sprague Pastures. (Un- published study received Mar 22, 1962 under unknown admin. no.; submitted by Rhone-Poulenc, Inc., Monmouth Junction, NJ; CDL: 122170-A)

00102824 Legault, R.; Benson, N.; Reynolds, D.; et al. (1963) Pesticide Res- idue Analysis. (Unpublished study received 1964 under 264-37; prepared by Washington State Univ., Dept. of Agricultural Chem- istry, submitted by Union Carbide Agricultural Products Co., Inc., Research Triangle Park, NC; CDL:122187-A)

00102833 Rhone-Poulenc, Inc. (1964) Use of Weedez Bar (2,4-D) in Grape Vineyards-- Application to USDA for Registration on no Residue Basis. (Unpublished study received Mar 23, 1964 under 359- EX-42; CDL:125194-B)

00102862 Chemical Machines (1964) ?2,4-D: Residues in Potatoes|. (Compi- lation; unpublished study received Mar 24, 1964 under 3462-8; CDL:221908-B)

00102865 Leng, M.; Jensen, D.; Miller, P. (1973) Residues of 2,4-D in Field Corn and Sweet Corn from Preemergence or Postemergence Treatments with the Herbicide. (Unpublished study received Mar 4, 1976 under 464-201; submitted by Dow Chemical U.S.A., Midland, MI; CDL:223616-A)

00102879 Bice, J. (1961) Physiological Effect of 2,4-D on Lemons. (Unpub- lished study received Jun 15, 1967 under 5202-18; submitted by Brogdex Co., Pomona, CA; CDL:230582-A)

00102889 Wisconsin Alumni Research Foundation (1969) Assay Report: W.A.R.F. No. 8110601-630. (Unpublished study received Oct 5, 1976 under 11275-2; submitted by Guth Corp., Naperville, IL; CDL:235811-A)

00109535 Velsicol Chemical Corp. (1982) ?Dicamba: Residues in Cows & Other Subjects|. (Compilation; unpublished study received Aug 6, 1982 under 876- 168; CDL:248024-A)

00115499 Dow Chemical Co. (1972) Amendment to PP 1F1102 Requesting Toler- ances for Residues of ... (2,4,5-T). (Compilation; unpublished study received Jul 21, 1972 under 1F1102; CDL:090864-A)

00115509 National Agricultural Chemicals Assoc. (1967) (Study: 2,4-D Resi- due in Crops, Animal Tissue of Animal Products). (Compilation; unpublished study received Sep 16, 1968 under 8F0669; CDL: 092964-Q)

### 2,4-D Bibliography

Page 212 of 304 00115515 Dow Chemical Co. (1971) Study: 2,4,5-T Residues in Animals and Se- lected Crops|. (Compilation; unpublished study received Sep 29, 1971 under 1F1102; CDL:093415-A)

00115741 Otto, N. (1982) Letter sent to Chief, Applied Sciences Branch dated Sep 8, 1982: Herbicidal residues and environmental effects re- sulting from the experimental application of two 2,4-D formula- tions to control eurasian watermilfoil. (U.S. Bureau of Recla- mation, Engineering and Research Center; unpublished study; CDL: 248613-B)

00115793 Ciba-Geigy Corp. (1977) Residues of Ametryn and 2,4-D Amine in or on Sugarcane from Single and Multiple Applications--Louisiana. (Compilation; unpublished study received Jan 16, 1978 under 100- 473; CDL:232676-A)

00118549 Amchem Products, Inc. (1971) Fenac Residue Data--Total Water Treat- ment. (Compilation; unpublished study received Jul 7, 1972 under 2F1213; CDL:091039-T)

00120057 National Agricultural Chemicals Assoc. (1970) The Results of Tests on the Amount of Residue Remaining, Including a Description of the Analytical Method Used: (2,4-Dichlorophenoxyacetic Acid). (Compilation; unpublished study received Jan 18, 1971 under 8F0670; CDL:091174-A)

00121711 Washington, Dept. of Game (1967) ?DDT : Residues in Seafood|. (Compilation; unpublished study received 1967 under 4F0419; CDL:092706-A)

00121733 Thompson Chemicals Corp. (19??) Method: ?Residues of Phenoxyacids and Their Amine Salts in Apples and Other Crops|. (Unpublished study received Apr 3, 1967 under 7F0589; CDL:092877-A)

00123269 Interregional Research Project No. 4 (1973) ?2,4-D Residues in Asparagus and Other Subjects|. (Compilation; unpublished study received Mar 1, 1974 under 4E1475; CDL:093923-A)

00123973 U.S. Fish and Wildlife Service (1972) Metabolism of Pesticides: ?2,4-D|. (Unpublished study received 1972 under 4G1487; CDL: 093950-A)

00126684 PBI-Gordon Corp. (1982) ?Ultra-Sulv (2,4-D) Residues in Wheat and Corn and Rate of Decline in Soil|. (Compilation; unpublished study received Apr 1, 1983 under 2217-703; CDL:249863-G)

00127226 U.A. Agricultural Research Service (1961) ?Residues: 2,4-D|. (Compilation; unpublished study received Mar 16, 1964 under 6F0459; CDL:092748-A)

00127273 PBI-Gordon Corp. (1982) Residues: (MCPP--Soil and Other Subjects). (Compilation; unpublished study received Apr 1, 1983 under 2271-EX-3; CDL:071501-Z)

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Page 213 of 304 00127823 Velsicol Chemical Co. (1981) Hawaiian Sugarcane Residue Data: ?Banvel|. (Compilation; unpublished study received Apr 15, 1983 under 876-25; CDL:249983-A)

00128778 Uniroyal Chemical (1981) Residue: ?2,4-D Amine|. (Compilation; unpublished study received Jun 27, 1983 under 400-390; CDL: 250616-A)

00133938 Stauffer Chemical Co. (1976) Residue Chemistry Data: ?Eradicane 6.7-E and Other Chemicals in Corn|. (Compilation; unpublished study received Apr 20, 1976 under 476-2157; CDL:224095-A)

00136845 Interregional Research Project No. 4 (1974) ?Residue Levels of 2,4- Dichlorophenoxyacetic Acid and 2,4-Dichlorophenol in Red Potato Tubers|. (Compilation; unpublished study received 1974 under 1E1122; CDL:093432-A)

00136848 U.S. Dept. of the Interior (1962?) Re sidues: Method of Analysis of 2,4-D in Water and Crop Plants. (Compilation; unpublished study received Jan 22, 1971 under 1E1136; CDL:093444-A)

00138635 Velsicol Chemical Corp. (1983) The Re sults of Tests on the Amount of Residue Remaining, Including a Description of the Analytical Method Used: ?Dicamba and 5-Hydroxy Dicamba Residue in Vege- tables, Forage Crops, Legumes, Cottonseed and Cottonseed Frac- tions and Grains|. (Compilation; unpublished study received Feb 2, 1984 under 876-449; CDL:072332-A)

00139059 California. (1975) ?Residue of 2,4-Dichlorophenoxyacetic Acid Iso- propyl Ester in Oranges|. (Compilation; unpublished study re- ceived Feb 29, 1984 under CA 83/69; CDL:252533-A)

00139511 U.S. Dept. of the Interior (1973) ?Residue Studies: 2,4-D: Crops|. (Compilation; unpublished study received Apr 21, 1983 under 3E2876; CDL:071564-F)

00139951 International Research and Development Corporation (19??) Determi- nation of Residues of 2,4 Dichlorophenoxyacetic Acid (2,4-D) in Asparagus-gas Chromatography. Undated method IRDC 6. (Un- published study received Jan 11, 1971 under 1F1131; submitted by Velsicol Chemical Corp., Chicago, Ill.; CDL:091953-P)

00140032 Union Carbide Agricultural Products Company, Incorporated (1965?)Analytical Methods. (Unpublished study received Apr 19, 1968 under 264-EX30G; CDL:123220-E)

00140092 National Agricultural Chemicals Assoc. (1970) Residue Studies on Sugarcane. (Compilation; unpublished study received Jul 19, 1973 under 8F0670; CDL:092966-A)

00144791 Uniroyal Chemical (1985) DED-WEED SU LV Residues in Pasture Grass and Wheat Forage. Unpublished study. 14 p.

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00147047 PBI Gordon Corp. (1984) Residue Analysis. Unpublished study. 25 p.

00156264 Interregional Research Project No. 4 (1985) The Results of Tests on the Amount of 2,4-D Residues Remaining in or on Soybeans Includ- ing a Description of the Analytical Method Used. Unpublished compilation. 62 p.

00161187 Interregional Research Project No. 4 (1977) The Results of Tests on the Amount of Residues 2,4-D and its Metabolite Remaining in or on Millet Including a Description of the Analytical Method Used. Unpublished compilation. 10 p.

00163903 FMC Corp. (1986) Freshgard 26 Product Data: Residue Chemistry Data. Unpublished compilation. 17 p.

40881401 Baron, J. (1988) 2,4-D--Magnitude of Residue on Rasberry: Laborato- ry Project ID IR-4 PR 2844/3718. Unpublished study prepared by North Dakota State University. 34 p.

41991503 Smith, G. (1991) Metabolism of 14 Carbon-(2,4-Dichlorophenoxy) Acetic Acid, Dimethylamine Salt in Apples: Lab Project Number: 38072. Unpublished study prepared by ABC Laboratories, Inc. 37 p.

42423101 Puglis, J.; Smith, G. (1992) Metabolism of Uniformly Ring Labeled ?carbon 14| 2,4-Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester in Potatoes: Lab Project Number: 38075. Unpublished study prepared by ABC Labs, Inc. 49 p.

42439701 Puvanesarajah, V. (1992) Metabolism of Uniformly ?carbon 14|-Ring Labeled 2,4-Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester in Wheat: Lab Project Number: 38076. Unpublished study prepared by ABC Laboratories, Inc. 121 p.

42605201 Puvanesarajah, V.; Bliss, M. (1992) Metabolism of Uniformly Ring Labeled (carbon 14)2,4-Dichlorophenoxyacetic Acid in Poultry: Lab Project Number: 38077. Unpublished study prepared by ABC Labs Inc. 91 p.

42615601 Puvanesarajah, V.; Ilkka, D. (1992) Metabolism of Uniformly (carbon 14)-Ring Labeled 2,4-Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester in Wheat: A Supplement: Lab Project Number: 38076-01. Unpublished study prepared by ABC Labs, Inc. 57 p.

42749701 Guo, M.; Stewart, S. (1993) Metabolism of Uniformly (carbon 14)-Ring Labeled 2,4-Dichlorophenoxyacetic Acid in Lactating Goats: Lab Project Number: 40630. Unpublished study prepared by ABC Labs, Inc. 110 p.

42968501 U.S. Army Corps of Engineers (1993) 2,4-D Residue Data Provided by the U.S. Army Corps of Engineers. Unpublished study prepared by Rhone-Poulenc Ag Co. 297 p.

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Page 215 of 304 42968502 Rhone-Poulenc Ag Co. (1993) Miscellaneous Data on Residues and Persistenceof 2,4-D in Aquatic Environments. Unpublished study prepared by RhonePoulenc Ag Co. 160 p.

43160201 Guo, M.; Stewart, S. (1994) Supplemental Data for the Study, Metab- olism of Uniformly (Carbon 14)-Ring Labeled 2, 4-Dichlorophen- oxyacetic Acid in Lactating Goats: Final Report: Lab Project Nos. 40630-01; 40630. Unpublished study prepared by ABC Labs, Inc. 26 p.

43289301 James, J. (1994) Radiovalidation of EN-CAS Method ENC-2/93 for the Determination of 2,4-Dichlorophenoxyacetic Acid (2,4-D) in/on Wheat Forage, Straw, and Grain Treated with (P henyl (U)(carbon 14))-2,4-Dichlorophenoxy Acetic Acid: Final Report: Lab Project Number: 93-0018: ENC-2/93. Unpublished study prepared by EN-CAS Analytical Labs. 211 p.

43290501 Wu, D. (1994) Metabolism of (carbon 14)-2,4-D IPE in Stored Lemons-Nature of the Residue in Plants: Lab Project Number: XBL 93012: RPT00166. Unpublished study prepared by XenoBiotic Labs, Inc. 246 p.

43356002 Burnett, T.; Ling, K. (1994) Confined Rotational Crop Study on Uniformly (carbon 14)-Ring-Labeled 2,4-Dichlorophe noxyacetic Acid (2,4-D): Lab Project Number: 92155. Unpublished study prepared by Pan-Agricultural Labs, Inc. 184

p.

43356301 Carringer, R. (1994) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Soybeans Following Ground Application with 2,4-D Acid: Lab Project Number: 93-0022-0227: AA930227. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Labs. 368 p.

43356302 Carringer, R. (1994) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Soybeans Following Ground Application with 2,4-D 2-Ethylhexyl Ester: Lab Project Number: 93-0022-0226: AA930226.Unpublished study prepared by American Agricultural Services, Inc. and ENCAS Analytical Labs. 450 p.

43356303 Carringer, R. (1994) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Soybeans Following Ground Application with 2,4-D Dimethylamine Salt: Lab Project Number: 93-0022-0225: AA930225.Unpublished study prepared by American Agricultural Services, Inc. and ENCAS Analytical Labs. 370 p.

43378801 Premkumar, N.; Stewart, S. (1994) Uniformly (carbon 14)-Ring Labeled 2,4- Dichlorophenoxyacetic Acid: A Metabolism Study in Bluegill Sunfish: Final Report: Lab Project Number: 41116. Unpublished study prepared by ABC Laboratories, Inc. 128 p.

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Page 216 of 304 43496101 Premkumar, N.; Vengurlekar, S. (1994) Uniformly (carbon 14)- Ring Labeled 2,4-Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester: Nature of the Residue in Potato: Final Report: Lab Project Number: 41256: M-9149. Unpublished study prepared by ABC Labs, Inc. 203 p.

43592101 Rosemond, J. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Rangelands Following Ground Applications with 2,4-D 2-Ethylhexyl Ester: (Final Report): Lab Project Number: AA930220: 93-0025-0220. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical labs. 409 p.

43610801 Rosemond, J. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxyacetic Acid) in Rangelands Following Ground Applications with 2,4-D Dimethylamine Salt: Lab Project Number: 93-0025-0219: AA930219. Unpublished study prepared by American Agricultural Services and EN-CAS Analytical Laboratories. 417 p.

43610802 Rosemond, J. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxyacetic Acid) in Grass Pastures Following Ground Applications with 2,4-D 2-Ethylhexyl Ester: La b Project Number: AA930217: 93-0026-0217. Unpublished study prepared by American Agricultural Services and EN-CAS Analytical Labs. 484 p.

43665201 Carringer, S. (1995) Magnitude of th e Residue of 2,4-D (2,4-Dichlorophenoxy Acetic Acid) in/on Wheat (Winter and Spring) Following Ground Applications with 2,4-D 2-Ethylhexyl Ester: La b Project Number: AA930204: 93-0019-1054: 47509. Unpublished study prepared by American Agricultural Services, Inc. and En-Cas Analytical Labs. 705 p.

43665202 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in/on Wheat (Winter and Spring) Following Ground Applications with 2,4-D Acid: Lab Project Number: AA930205: 93- 0019-0205: ENC-2/93. Unpublished study prepared by American Agricultural Services, Inc. and En-Cas Analytical Labs. 403 p.

43665203 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Grass Pastures Following Ground Applications with 2,4-D Dimethylamine Salt: Lab Project Number: AA930216: 93-0026-0216: ENC-2/93. Unpublished study prepared by American Agricultural Services, Inc. and En-Cas Analytical Labs. 488 p.

43665204 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Grass Pastures Following Ground Applications with 2,4-D Acid: Lab Project Number: AA930218: 93-0026-0218: ENC-2/93. Unpublished study prepared by American Agricultural Services, Inc. and En-Cas Analytical Labs. 352 p.

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Page 217 of 304 43665205 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Rangelands Following Ground Applications with 2,4-D Acid: Lab Project Number: AA930221: 93-0025-0221: ENC-2/93.Unpublished study prepared by American Agricultural Services, Inc. and EnCas Analytical Labs. 368 p.

43669801 Carringer, R. (1994) Magnitude of th e Residue of 2,4-D (2,4-Dichlorophenoxy Acetic Acid) in Soybeans Following Ground Applications with 2,4-D Ethylhexyl Ester: Amendment to Final Report: Lab Project Number: AA930226: 60635: 60636. Unpublished study prepared by American Agricultural Services, Inc. 55 p.

43676801 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Field Corn Following Ground Applications with 2,4-D-Ethlhexyl Ester: Lab Pr oject Number: AA930209: ENC-2/93: 93- 0020-0209. Unpublished study prepared by American Agricultural Services and EN-CAS Analytical Labs. 708 p.

43676802 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Wheat (Winter and Spring) Following Ground Applications with 2,4-D Dimethylamine Salt: Lab Project Number: AA930207: 93-0019-0207: ENC-2/93. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Labs. 569 p.

43686001 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Field Corn Following Ground Applications with 2,4-D Dimethylamine Salt: Lab Project Number: AA930208: 93-0020- 0208. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Labs. 709 p.

43691101 Zheng, S. (1995) Independent Laborator y Validation of EN-CAS Method No. ENC-2/93, the Determination of 2,4-Dichlorophenoxy Acetic Acid (2,4-D) in/on Various Raw Agricultural Commodities and Their Processed Fractions: Lab Project Number: 011-03: 94P-011-03. Unpublished study prepared by Centre Analytical Labs, Inc. 95 p.

43693701 Carringer, S. (1995) Magnitude of th e Residue of 2,4-D Acid, 2-Ethylhexyl Ester in Processed Wheat (Winter and Spring) Fractions (Bran, Flour, Middlings, and Shorts) Following Ground Applications with 2,4-D 2-Ethylhexyl Ester: Lab Project Number: AA930206: 93-0019-0206. Unpublished studyprepared by American Agricultural Services, Inc.; Texas A&M Univ.; and ENCAS Analytical Labs. 700 p.

43693702 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Field Corn Following Applications with 2,4-D Acid: Lab Project Number: AA930210: 93-0020-0210. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Labs. 584 p.

### 2,4-D Bibliography

Page 218 of 304 43697801 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Grain Sorghum Following Ground Applications with 2,4-D 2-Ethylhexyl Ester: Lab Project Number: AA930214: 93-0021-0214: F93196531. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Labs. 554 p.

43709701 Carringer, S. (1995) Magnitude of the Residue of 2,4-D 2-Ethylhexyl Ester, 2,4- D Acid in Processed Field Corn Fractions Following Ground Applications with 2,4-D 2-Ethylhexyl Ester: Lab Project Number: AA930211: 93-0020-0211: ENC-2/93. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Labs. 658 p.

43709702 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Processed Grain Sorghum Fractions (Starch and Flour) Following Ground Applications with 2,4-D Dimethylamine Salt: Lab Project Number: AA930213: 93-0021-0213: ENC-2/93. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Labs. 539 p.

43718001 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Grain Sorghum Following Ground Applications with 2,4-D Dimethylamine Salt: Lab Project Number: AA930212: 93-0021-0212. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Labs. 567 p.

43718002 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Grain Sorghum Following Ground Applications with 2,4-D Acid: Lab Project Number: AA930215: 93-0021-0215.Unpublished study prepared by American Agricultural Services, Inc. and ENCAS Analytical Labs. 518 p.

43736101 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Sugarcane Following Ground Application with 2,4-D Dimethylamine Salt: (Final Report): Lab Project Number: 93-0023- 0201: AA930201. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Lab. 760 p.

43736102 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Sugarcane Following Ground Application with 2,4-D Acid: (Final Report): Lab Project Number: 93-0023-0202: AA930202. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Lab. 642 p.

43747901 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Rice Following Ground Applications with 2,4-D Acid: (Final Report): Lab Project Number: AA930224: 93-0024-0224: ENC-2/93. Unpublished study prepared by American Agricultural Services, Inc. 495 p.

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Page 219 of 304 43755401 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Processed Fractions of Sugarcane Following Ground Application with 2,4-D Dimethylamine Salt: Lab Project Number: AA930203: 93-0023-0203: 5450. Unpublished study prepared by American Agricultural Services, Inc. and Hawaiian Sugar Planters Association. 575 p.

43755402 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Processed Rice Fractions (Hulls, Bran, and White Milled Rice) Following Ground Application with 2,4-D Dimethylamine Salt: Lab Project Number: AA930223: 93-0024-0223: ENC-2/93. Unpublished study prepared by American Agricultural Services, Inc. and South Texas Ag Research. 548 p.

43779501 Carringer, S. (1995) Magnitude of the Re sidue of 2,4-D Acid in Grass Pastures Following Ground Applications with 2,4-D 2-Ethylhexyl Ester: (Final Report): Lab Project Numbers: AA940503: 6397-154. Unpublished study prepared by American Agricultural Services, Inc. and Hazleton Wisconsin, Inc. 383 p.

43779502 Carringer, S. (1995) Magnitude of the Re sidue of 2,4-D Acid in Grass Pastures Following Ground Applications with 2,4-D Dimethylamine Salt: (Final Report): Lab Project Numbers: AA940504: 6397-155. Unpublished study prepared by American Agricultural Services, Inc. and Hazleton Wisconsin, Inc. 383 p.

43779503 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid in Rangelands Following Ground Applications with 2,4-D 2-Ethylhexyl Ester: (Final Report): Lab Project Numbers: AA940505: 6397-156. Unpublished study prepared by American Agricultural Services, Inc. and Hazleton Wisconsin, Inc. 360 p.

43779504 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid in Rangelands Following Ground Applications with 2,4-D Dimethylamine Salt: (Final Report): Lab Project Number: AA940506: 6397-157: HWI 6397-157. Unpublished study prepared by American Agricultural Services, Inc. and Hazleton Wisconsin, Inc. 360 p.

43785901 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid (2,4- Dichlorophenoxy Acetic Acid) in Rice Following Ground Application with 2,4- D Dimethylamine Salt: Lab ProjectNumber: AA930222: 93-0024-0222: ENC2/93. Unpublished study prepared by American Agricultural Services, Inc. and EN-CAS Analytical Labs. 582 p.

43797901 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid in Wheat (Winter and Spring) Following Ground Applicati ons with 2,4-D 2-Ethylhexyl Ester: (Final Report): Lab Project Number: AA940501: HWI 6397-151. Unpublished study prepared by American Agricultural Services, Inc. and Hazleton Wisconsin, Inc. 630 p.

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Page 220 of 304 43797903 Carringer, S. (1995) Magnitude of the Residue of 2,4-D Acid in Wheat (Winter and Spring) Following Ground Applications with 2,4-D Dimethylamine Salt: (Final Report): Lab Project Number: AA940502: HWI 6397-152. Unpublished study prepared by American Agricultural Services, Inc. and Hazleton Wisconsin, Inc. 607 p.

43809901 Barker, W. (1995) Determination of Frozen Storage Stability for 2,4- Dichlorophenoxy Acetic Acid (2,4-D) in/on Crops: Final Report: Lab Project Number: 93-0044: ENC-2/93: 93-0044 ITFII. Unpublished study prepared by EN-CAS Analytical Labs. 793 p.

43853601 Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Wild Rice (Zizania palustris L.): Lab Project Number: 1015.92-MN01: 1015.92-NDR09: PR 1015. Unpublished study prepared by IR-4. 246 p.

43870301 Johnson, G.; Strickland, M. (1995) Storage Stability of (2,4- Dichlorophenoxy)Acetic Acid Residues in/on Raw Orange, Grapefruit, Lemon Fruit and Processed Lemon Products: Final Report: Lab Project Number: 101- 006: R289408: CCQC 94-03. Unpublished study prepared by Western EcoSystems Technology; Research for Hire; and Corning Hazleton. 205 p.

43870302 Johnson, G.; Strickland, M. (1995) Magnitude of Residues in/on Products Processed from Lemons Treated with (2,4-Dichlorophenoxy)Acetic Acid Isopropyl Ester: Final Report: Lab Project Number: 101-005: R289407: R289409. Unpublished study prepared by Western EcoSystems Technology; Research for Hire; and Corning Hazleton. 267 p.

43870303 Johnson, G.; Strickland, M. (1995) Magnitude of Residues in/on California Citrus Fruit after Growth Regulator Treatments with (2,4- Dichlorophenoxy)Acetic Acid Isopropyl Ester: Final Report: Lab Project Number: 101-004: R289401: R289402. Unpublished study prepared by Western EcoSystems Technology; Research for Hire; and Corning Hazleton. 337 p.

43879901 Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Peach: Lab Project Number: 4255.93-CAR05: 4255.93-GA08: 4255.93-NJ01. Unpublished study prepared by Environmental Technologies Institute, Inc. and Interregional Research Project No. 4. 282 p.

43879902 Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Cherry: Lab Project Number: 4254.92-NDR03: 4254.94-CA49: 4254.92-MI10. Unpublished study prepared by Environmental Technologies Institute, Inc. and Interregional Research Project No. 4. 264 p.

43879903 Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Plum: Lab Project Number: 4257.93-CAR06: 4257.93-WA01: 4257.93-MI04. Unpublished study prepared by Environmental Technologies Institute, Inc. and Interregional Research Project No. 4. 348 p.

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Page 221 of 304 43879904 Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Pistachios: Lab Project Number: 4301.94-CAR10: 4301.94-CA99: 4301.94-CA08. Unpublished study prepared by Environmental Technologies Institute, Inc. and Interregional Research Project No. 4. 215 p.

43879905 Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Asparagus: Lab Project Number: 04090.94-YAR14: 04090.92-YAR01: 4090.92-WA12. Unpublished study prepared by Interregional Research Project No. 4. 348 p.

43886401 Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of the Residue on Potato (Reregistration): Lab Project Number: 04302: .92-ND04: .92-CA24. Unpublished study prepared by University of Idaho; University of Maine; and University of Wisconsin. 783 p.

43886402 Barney, W.; Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Cranberry (Reregistration): Lab Project Number: 4297.92-NDR08: 4297.92-MA01: 4297.92-WI07. Unpublished study prepared by University of Massachusetts and University of Wisconsin. 303 p.

43886403 Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Blueberry (Lowbush): Lab Project Number: 4295.94-CAR26: 94-CAR96: R&R 520.XLS. Unpublished study prepared by University of California and University of Maine. 166 p.

43886404 Kunkel, D. (1995) 2,4-D: Magnitude of Re sidue on Strawberry (Reregistration): Lab Project Number: 04179.95-CAR03: 4179.95-WA13: 4179.95-WA14. Unpublished study prepared by Washington State University and University of Wisconsin. 422 p.

43886405 Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Pear (Reregistration): Lab Project Number: 04256.92-WA16: 4256.92-NY18: 4256.92-CA94. Unpublished study prepared by Cornell University; Collins Ag Consultant, Inc.; and University of California. 515 p.

43886406 Kunkel, D. (1995) 2,4-D: Magnitude of Residue on Corn (Sweet): Lab Project Number: 4183.95-WA29: 4183.95-SC11: 4183.95-WI07. Unpublished study prepared by University of Wisconsin; University of Florida; and Oregon State University. 628 p.

43893701 Siirila, A. (1995) Method Validation for the Determination of (2,4- Dichlorophenoxy)Acetic Acid in/on California Citrus Fruit and Lemon Processed Products: Revised Final Report: Lab Project Number: HWI 6578- 101A: MP-CCO1-MA: HWI 6179-100A. Unpublished study prepared by Hazleton Wisconsin, Inc. 149 p.

43943101 Barney, W.; Kunkel, D. (1995) 2,4-D: Ma gnitude of the Residue on Apple: Lab Project Number: PR 4182: 4182.94-CAR25: 4182.92-NYP06. Unpublished study prepared by Environmental Technologies Institute, Inc. 347 p.

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44016501 Howard, J. (1996) Development, Validation and Radiovalidation of Analytical Methodology for the Quantitation of Residues of 2,4-Dichlorophenoxyacetic Acid (2,4-D) in Poultry Muscle, Liver, Fat and Eggs: Lab Project Number: 949: 1874. Unpublished study prepared by PTRL East, Inc. 80 p.

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44024801 Krautter, G.; Downs, J. (1996) 2,4-D: Magnitude of Residues in Meat and Milk of Lactating Dairy Cows: Lab Project Number: 886: 1889: 912. Unpublished study prepared by PTRL East, Inc. 608 p.

44135201 Biever, R. (1996) A Freshwater Fish a nd Shellfish Magnitude of Residues Study in a Static Aquatic System: Amine 400 2,4-D Weed Killer: Lab Project Number: 3140.0796.6106.395: 96-9-6660: 1064. Unpublished study prepared by Springborn Labs, Inc. and PTRL East, Inc. 167 p.

44190301 Carringer, S. (1996) Magnitude of the Residue of 2,4-D Acid in Wheat (Winter and Spring) Following Ground Applicati ons with 2,4-D 2-Ethylhexyl Ester: (Final Report): Lab Project Number: AA960501: CHW 6397-164: 6397-164. Unpublished study prepared by American Agricultural Services, Inc. and Corning Hazleton, Inc. 498 p.

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44967401 Howard, J. (1999) Determination of the Stability of 2,4-Dichlorophenoxyacetic Acid (2,4-D) in Frozen Clam Tissue: Lab Project Number: 1135: 2062. Unpublished study prepared by PTRL East, Inc. 44 p.

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45462201 Johnson, G.; Stickland, M. (2001) Magnitude of Residues in/on Citrus Fruit After Post Harvest Treatments with (2,4-Dichlorophenoxy) acetic Acid Isopropyl Ester: Final Report: Lab Project Number: CCQC 00-01: 6578-708: 101-014. Unpublished study prepared by Western EcoSystems Technology (WEST, Inc.) and Covance Laboratories. 176 p.

45512701 Arsenovic, M. (2001) 2,4-D: Magnitude of the Residue on Hops: Lab Project Number: A5024: A5024.99-CAR22: A5024.99-WA48. Unpublished study prepared by IR-4 Western Region Leader Laboratory; WSU, FEQL; Western Biochemical Consulting, Inc. and University of Idaho. 124 p.

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45665801 Tieu, H. (2001) Magnitude of Weedaxe ( 2,4-D) Residues in Grapes: Lab Project Number: ERS21075: CA01: 21-075. Unpublished study prepared by Primus Labs. 110 p. {OPPTS 860.1500, 860.1000}

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Product Chemistry MRID References

40443301 Collins, R. (1987) Product Chemistry: 2,4-D Isopropyl Ester: Labo- ratory Project ID: 2,4-D ISOPROPYL ESTER. Unpublished study prepared by Gilmore, Inc. 11 p.

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40808301 Allen, W.; Mahlburg, W. (1988) Clean Crop 2,4-D Acid: Product Chemistry Data: Study No. 88-9A. Unpublished study prepared by Transbas, Inc. Laboratory. 64 p.

41978001 DowElanco (1991) 2,4-D Isopropylamine Salt: Response to 2,4-D Task 4: Registrant's Response to Product Chemistry Data Requirements DEB Nos. 5454-5455, 5489, 5440-5544 Dated September 22, 1989. Unpublished study prepared by DowElanco. 16 p.

41978002 Schriber, C. (1991) Chemical Stability of 2,4-D Isopropylamine Salt Solution: Lab Project Number: 90088. Unpublished study prepared by DowElanco 17 p.

41308901 Reim, R. (1989) Dissociation of 2,4-Dichlorophenoxyacetic Acid (2,4-D) and 2,4-D Dimethylamine Salt in Water: Lab Project Number: ML AL 89 041014. Unpublished study prepared by Dow Chemical U.S.A. 25 p.

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41431301 Chadrabarti, A. (1989) Vapor Pressure of the Butoxyethyl Ester of (2,4- Dichlorophenoxy) Acetic Acid Measured by the Knudsen-Effu- sion/Weight Loss Method: Lab Project Number: ML-AL-89-020197. Unpublished study prepared by Dow Chemical U.S.A. 12 p.

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42021002 Hopkins, D. (1987) 2,4-Dichlorophenoxyacetic Acid Dimethylamine Salt: Determination of the Water Solubility: Lab Project Number: ES-DR-0008- 3556-3. Unpublished study prepared by The Dow Chemi- cal Company. 15 p.

42227501 Sawyer, R. (1990) Product Chemistry: Riverdale Sodium Salt of 2,4-D. Unpublished study prepared by Riverdale Chemical Co. 8 p.

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41968301 DowElanco. (1991) 2,4,D Isooctyl Ester (2-ethylhexyl ester): Response to 2,4-D Task 4: Registrant's Response to Product Chemistry Data Requirements DEB No. 5454-5455, 5489, 5440-5544 dated September 22, 1989. Unpublished study. 11 p.

41968302 Helmer, D. (1987) Determination of the Water Solubility of 2,4- dichlorophenoxy Acetic Acid, 2-ethylhexyl Ester: Lab Project No: ML-AL-87- 70817. Unpublished study prepared by Dow Chemical USA. 13 p.

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42831101 Murphy, G. (1993) Determination of Boiling Point and Solubility of 2,4- Dichlorophenoxyacetic Acid 2-Ethylhe xyl Ester (2,4-D 2-EHE) Technical Grade of Active Ingredient (TGAI): Lab Project Number: FOR93055. Unpublished study prepared by Formulation Science and Technology Lab, DowElanco. 17 p.

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42857201 Malone, S. (1992) Characterization of Technical Diethanolamine Salt of (2,4- Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0055-AS: 4102- 92-0055-AS-001. Unpublished study prepared by Ricerca, Inc. 47 p.

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42857203 Wojcieck, B. (1992) Color, Physical State, Odor of the Diethanolamine Salt of (2,4-Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0082-AS: 4102-92-0082-AS-001. Unpublished study prepared by Ricerca, Inc. 24 p.

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42857209 Malone, S. (1993) Technical Diethanolamine Salt of (2,4-Dichlorophenoxy) Acetic Acid--Stability: Lab Project Number: 4102-92-0085-AS: 4102-92-0085- AS-001. Unpublished study prepared by Ricerca, Inc. 51 p.

41961301 DowElanco (1991) 2,4-D Butoxyethyl Ester: Response to 2,4-D Task 4: Registrants Response to Product Chemistry Data Requirements DEB No.5454- 5455, 5440-5544 Dated September 22, 1989. Unpublished study. 11 p.

42786501 Feiler, W. (1993) Technical Isopropyl Ester of 2,4-D: Product Chemistry. Unpublished study prepared by Amvac Chemical Corp. 14 p.

43260501 Krause, R.; Jones-Jefferson, T.; Wallace, T. (1994) Storage Stability of 2,4-D Acid: One Year Ambient Temperature Storage Study Results: Lab Project Number: FOR93069. Unpublished study prepared by DowElanco, Formulation Science & Technology. 14 p.

43325001 Kinnunen, C. (1994) Series 63: Determination of the Boiling Point of 2,4- Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) TGAI: Lab Project Number: FOR94079. Unpublished study prepared by DowElanco. 9 p.

43325002 Kinnunen, C. (1994) Series 63: Determination of the Boiling Point of 2,4- Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester (2,4-D 2-EHE) TGAI: Lab Project Number: FOR94080. Unpublished study prepared by DowElanco. 9 p.

43325003 Kinnunen, C. (1994) Series 63: Determination of the Melting Point of 2,4- Dichlorophenoxyacetic Acid Triisopropanolamine Salt (2,4-D) TGAI: Lab Project Number: FOR93132. Unpublished study prepared by DowElanco. 9 p.

43302001 Braden, G. (1994) Solubility of Isopropyl Ester of 2,4-D in Selected Organic Solvents: Lab Project Number: SOL/018. Unpublished study prepared by Amvac Chemical Corp. R & D Labs. 16 p.

43516401 Haefele, L. (1995) Identity and Composition for Albaugh 2,4-D Technical Acid: Final Report: Lab Project Number: 95-ALBG-012. Unpublished study prepared by AC RN Labs. 37 p.

43516402 Willis, C. (1994) Preliminary Analysis and Precision and Accuracy of Analytical Method Used to Validate Certified Limits: (2,4-Dichlorophenoxy) Acetic Acid: Final Report: Lab Project Number: 810-17. Unpublished study prepared by Case Consulting Labs., Inc. 114 p.

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Page 233 of 304 43516403 Willis, C. (1994) 2,4-D (2,4-Dichlorophenoxyacetic acid): Physical and Chemical Characteristics of 2,4-D: Color, Physical State, Odor, Melting Point, Bulk Density, Solubility, Vapor Pressure, Dissociation Constant, Octanol/Water Partition Coefficient, pH, Stability, Oxidizing or Reducing and Explodability: Final Report: Lab Project Number: 810-18. Unpublished study prepared by Case Consulting Labs., Inc. 25 p.

43516404 Willis, C. (1994) 2,4-D (2,4-Dichlorophenoxyacetic acid): Physical and Chemical Characteristics of 2,4-D: Storage Stability and Corrosion Characteristics: Interim Report: Lab Project Number: 810-19. Unpublished study prepared by Case Consulting Labs., Inc. 14 p.

43314701 Kinnunen, C. (1994) Series 62-1: Preliminary Analysis of Product Sample of 2,4-Dichlorophenoxy Acetic Acid, Dimethylamine-6 (2,4-D DMA-6) Sequestered for Dimethyl Nitrosamine: Lab Project Number: FOR93133. Unpublished study prepared by DowElanco. 19 p.

43516401 Haefele, L. (1995) Identity and Composition for Albaugh 2,4-D Technical Acid: Final Report: Lab Project Number: 95-ALBG-012. Unpublished study prepared by AC RN Labs. 37 p.

43516402 Willis, C. (1994) Preliminary Analysis and Precision and Accuracy of Analytical Method Used to Validate Certified Limits: (2,4-Dichlorophenoxy) Acetic Acid: Final Report: Lab Project Number: 810-17. Unpublished study prepared by Case Consulting Labs., Inc. 114 p.

43358801 Kinnunen, C. (1994) Determination of Solubility of 2,4-Dichlorophenoxyacetic Acid, Dimethylamine Salt: Lab Project Number: FOR94078. Unpublished study prepared by DowElanco. 25 p.

43358802 Kinnunen, C. (1994) Determination of Solubility of 2,4-Dichlorophenoxyacetic Acid, Isopropylamine Salt: Lab Project Number: FOR94081: GH-C 3356. Unpublished study prepared by DowElanco. 24 p.

43981801 Willis, C. (1996) 2,4-D: Analyses for Te tra- Through Octa-Chlorinated Dioxins and Furans: Final Report: Lab Project Number: 810-24. Unpublished study prepared by Case Consulting Labs, Inc. 1053 p.

44149301 Armbruster, J. (1996) Product Identity and Manufacturing Process: (2,4-D). Unpublished study prepared by PBI/Gordon Corp. 59 p.

44149302 Morrissey, M. (1996) Preliminary Analysis of 2,4-Dichlorophenoxyacetic Acid: Final Report: Lab Project Number: CHW 6747-100. Unpublished study prepared by Corning Hazleton Inc. 176 p.

43777501 Kinnunen, C. (1995) Preliminary Analysis of Product Sample of Flake 2,4- Dichlorophenoxyacetic Acid: Lab Project Number: FOR95091. Unpublished study prepared by DowElanco. 39 p.

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Page 234 of 304 43777502 Kinnunen, C. (1995) Preliminary Analysis of Product Sample of Molten 2,4- Dichlorophenoxyacetic Acid: Lab Project Number: FOR95090. Unpublished study prepared by DowElanco. 39 p.

43874601 Krause, R.; Jones-Jefferson, T. (1995) Storage Stability of 2,4-D; IPA Salt Manufacturing-Use-Concentrate One Year Ambient Temperature Storage Study Results: Lab Project Number: FOR94149. Unpublished study prepared by DowElanco. 14 p.

44184201 Sanson, D. (1996) Product Identity and Composition of EH1330 Herbicide. Unpublished study prepared by PBI/Gordon Corp. 8 p.

44543502 Pryce, A. (1998) 2,4-D Acid: Product Chemistry: Analysis Methods: Final Report: Lab Project Number: AHM/E PA/98/AP/05: 97/0014. Unpublished study prepared by A H Marks and Company Limited. 41 p. {OPPTS 830.1800}

44543503 Pryce, A. (1998) 2,4-D Acid: Product Chemistry: 5 Batch Analysis: Final Report: Lab Project Number: AHM/EPA/98/AP/06. Unpublished study prepared by A H Marks and Co. Limited. 154 p. {OPPTS 830.1700}

44543504 Hutchinson, N. (1998) 2,4-D TGAI: Product Chemistry: Physical/Chemical Properties: Final Report: Lab Pr oject Number: AHM/EPA/98/NDH/01: 94/0010. Unpublished study prepared by A H Marks and Company Limited. 69 p. {OPPTS 830.6302, 830.6303, 830.6304, 830/6313, 830.7000, 830.7050, 830.7200, 830.7300, 830.7370, 830.7550, 830.7840, 830.7950}

44547901 Pryce, A. (1998) 2,4-D Acid: Product Chemistry: Existing Manufacturing Process: Final Report: Lab Project Number: AHM/EPA/98/AP/02. Unpublished study prepared by A H Marks and Co., Ltd. 29 p. {OPPTS 830.1550, 830.1600, 830.1670, 830.1700, 830.1750}

44584501 Hamilton, T. (1998) Group A: Product Identity and Composition of 2,4-D Butoxyethyl Ester Technical: Lab Project Number: GH-C 4680. Unpublished study prepared by Dow AgroSciences LLC. 58 p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670, 830.1750}

44228601 Pruitt, P. (1996) Series 62-1, Preliminary Analysis and Series 62-2, Certified Limits for 2,4-D Acid Molten: Lab Project Number: GH-C 4238. Unpublished study prepared by DowElanco. 40 p.

44807001 Madsen, S. (1999) Group A: Product Identity and Composition of 2,4-D Isopropylamine Salt Technical--High pH Manufacturing Use Product Containing 2,4-D Isopropylamine Salt: Lab Project Number: NAFST055. Unpublished study prepared by Dow Agrosciences, LLC. 50 p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670, 830.1750}

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Page 235 of 304 44982101 Madsen, S.; Cobb, J.; Hackett, B. et al. (1999) Group A: Product Identity and Composition of 2,4-D 2-Ethylhexyl Este r Technical Grade Active Ingredient and Manufacturing Use Product Containi ng 2,4-D 2-Ethylhexyl Ester Technical: Lab Project Number: NAFST018. Unpublished study prepared by Dow AgroSciences LLC. 54 p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670, 830.1750}

44982102 Hamilton, T. (1999) Ester Specific Analytical Method for Determination of Esters of 2,4-Dichlorophenoxyacetic Acid (2,4-D) and Related Impurities: Lab Project Number: DECO GL-AL 99-000252. Unpublished study prepared by The Dow Chemical Company. 74 p. {OPPTS 830.1800}

45014801 VanderKamp, J.; Kastl, P. (1999) Five Batch Analysis of 2,4-D 2-Ethyl-1-Hexyl Ester Technical: Lab Project Number: DECO GL-AL 99-002231. Unpublished study prepared by The Dow Chemical Co. 42 p. {OPPTS 830.1700}

44932701 Hutchinson, N. (1999) Preliminary Analysis of 5 Batches of 2,4- dichlorophenoxyacetic Acid Technical Grade Active Ingredient: Final Report: Lab Project Number: 98/0057. Unpublished study prepared by AH Marks and Company Limited. 188 p. {OPPTS 830.1700}

45642701 Sarff, P. (2002) Determination of the Storage Stability and Corrosion Characteristics for DMA-6 Sequestered (2,4-D Dimethylamine-6 Sequestered Herbicide): Lab Project Number: 46237: NAFST494: NAF-190. Unpublished study prepared by ABC Laboratories, Inc. 30 p. {OPPTS 830.6317, 830.6320}

44287101 Cramer, P. (1996) 2,4-Dichlorophenoxyacetic Acid: Analysis for Polychlorinated Dibenzo-p-dioxins and Dibenzofurans in Acid, Salt, and/orEster Technical Material: Final Report: Lab Project Number: 4199-A: MRIA\R4199-01: 4199. Unpublished study prepared by Midwest Research Institute. 811 p.

45692501 Lezotte, F.; Van Hoven, R.; Nixon, W. (2002) Determination of Water Solubility of 2,4-D Acid by the Shake Flask Method: Lab Project Number: 467C-103: 467/121801/7840/SUB467. Unpublished study prepared by Wildlife International, Ltd. 43 p. {OPPTS 830.7840}

40443301 Collins, R. (1987) Product Chemistry: 2,4-D Isopropyl Ester: Labo- ratory Project ID: 2,4-D ISOPROPYL ESTER. Unpublished study prepared by Gilmore, Inc. 11 p.

40808301 Allen, W.; Mahlburg, W. (1988) Clean Crop 2,4-D Acid: Product Chemistry Data: Study No. 88-9A. Unpublished study prepared by Transbas, Inc. Laboratory. 64 p.

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41015003 Feiler, W.; Braden, G. (1989) Technical Isopropyl Ester of 2,4-D: Produst Chemistry: Physical and Chemical Properties. Unpublish- ed study prepared by Amvac Chemical Corp. 15 p.

41055801 Dow Chemical Co. (1989) 2,4-D Acid: Product Identity and Composi- tion. Unpublished study. 40 p.

41055802 Dow Chemical Co. (1989) 2,4-D Acid: An alysis and Certification of Product Ingredients. Unpublished study. 32 p.

41055803 Dow Chemical Co. (1989) 2,4-D Acid: Physical and Chemical Charac- teristics. Unpublished study. 6 p.

41055804 Dow Chemical Co. (1989) 2,4-D Acid, Flake: Product Identity and Composition. Unpublished study. 14 p.

41055805 Dow Chemical Co. (1989) 2,4-D Acid, Flak e: Analysis and Certifica- tion of Product Ingredients. Unpublished study. 12 p.

41055806 Dow Chemical Co. (1989) 2,4-D Isooctyl (2-Ethylhexyl) Ester: Product Identity and Composition. Unpublished study. 26 p.

41055807 Dow Chemical Co. (1989) 2,4-D Isooctyl (2 -Ethylhexyl) Ester: Analy- sis and Certification of Product Ingredients. Unpublished stu- dy. 35 p.

41055808 Dow Chemical Co. (1989) 2,4-D Isooctyl (2-Ethylhexyl) Ester: Physi- cal and Chemical Characteristics. Unpublished study. 6 p.

41055809 Dow Chemical Co. (1989) 2,4,-D DMA-6 Un sequestered Weedkiller: Pro- duct Identity and Composition. Unpublished study. 23 p.

41055810 Dow Chemical Co. (1989) 2,4-D-6 Unsequestered Weedkiller: Analysis and Certification of Product Ingredients. Unpublished study. 22 p.

41055811 Dow Chemical Co. (1989) 2,4-D DMA-6 Unseqestered Weedkiller: Physical and Chemical Characteristics. Unpublished study. 6 p.

41055812 Dow Chemical Co. (1989) 2,4-D Butoxyethyl Ester: Product Identity and Composition. Unpublished study. 27 p.

41055813 Dow Chemical Co. (1989) 2,4-D Butoxyethyl Ester: Analysis and Certification of Product Ingredients. Unpublished study. 34 p.

41055814 Dow Chemical Co. (1989) 2,4-D Butoxyet hyl Ester: Physical and Chem- ical Characteristics. Unpublished study. 6 p.

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Page 237 of 304 41055815 Dow Chemical Co. (1989) 2,4-D Isopropylamine Salt: Product Identity and Composition. Unpublished study. 22 p.

41055816 Dow Chemical Co. (1989) 2,4-D Isopropylamine Salt: Analysis and Certification of Product Ingredients. Unpublished study. 26 p.

41055817 Dow Chemical Co. (1989) 2,4-D Isopropylamine Salt: Physical and Chemical Characteristics. Unpublished study. 6 p.

41055818 Dow Chemical Co. (1989) 2,4-D Triisopropanolamine Salt-4: Product Identity and Composition. Unpublished study. 23 p.

41055819 Dow Chemical Co. (1989) 2,4-D Triisopropanolamine Salt-4: Analysis and Certification of Product Ingredients. Unpublished study. 22 p.

41055820 Dow Chemical Co. (1989) 2,4-D Triisopr opanolamine Salt-4: Physical and Chemical Characteristics. Unpublished study. 6 p.

41067001 May & Baker Ltd. (1988) Product Chemistry Data Requirements under EPA Pesticide Assessment Guidelines dated Oct 1982 (2,4-Dichlor- ophenoxy)acetic Acid 2,4-D Technical Acid. Unpublished study. 138 p.

41203301 Silvestre, D. (1989) 2,4-D Determination of Polychlorinated Diben- zo-pdioxins and Dibenzofurans by GC/M S: Laboratory ID: 89-10. Unpublished study prepared by Rhone-Poulenc Industrialisation. 133 p.

41206901 Fisher, J. (1989) Product Chemistry: Agrolinz Isopropyl 2,4-D Ester Technical: Analytical Methods. Unpublished study prepared by Agrolinz, Inc. 17 p.

41219601 Armbruster, J. (1989) EPA Reg. No. 61649-001 - Certification of Limits forDibenzo-p-Dioxins/Dibenzofurans. Unpublished study prepared by AGROGOR Corp. 179 p.

41219701 Ambruster, J. (1989) Certification of Limits for Dibenzo-p-Dioxins/ Dibenzofurans. Unpublished study prepared by PBI/Gordon Corp. 179 p.

41220101 Berry, D. (1989) Final Report of the De termination of Halogenated Dibenzo-pdioxins and Dibenzofurans in 2,4-Dichlorophenoxyacetic Acid: Proj. ID AL 89- 030290. Unpublished study prepared by Dow Chemical Co., Analytical Sciences Laboratories. 168 p.

41223801 Armbruster, J. (1989) EPA Reg. No. 2217-455 - Product Chemistry ?of 2,4- Dichlorophenoxyacetic Acid|. Unpublished study prepared by Agro-Gor Corp. 30 p.

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41308901 Reim, R. (1989) Dissociation of 2,4-Dichlorophenoxyacetic Acid (2,4-D) and 2,4-D Dimethylamine Salt in Water: Lab Project Number: ML AL 89 041014. Unpublished study prepared by Dow Chemical U.S.A. 25 p.

41332002 Hopkins, D. (1987) 2,4-Dichlorophenoxyacetic Acid: Determination of the Water Solubility: Lab Project Number: ES/DR/0002/2297/8. Unpublished study prepared by The Dow Chemical Co. 14 p.

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41332009 Helmer, D. (1987) Determination of the Octanol/Water Partition Coefficient for 2,4- Dichlorophenoxy Acetic Acid, 2-Ethyl hexyl Ester: Lab Project Number: ML/AL/87/70819. Unpublished study prepared by Dow Chemical Co. 14 p.

41349001 Fiene, J.; Mahlburg, W. (1990) Determination of Halogenated Dibenzo -pDioxins and Dibenzofurans in 2,4-D Acid: Lab Project Number: 90-1. Unpublished study prepared by Chemserv Industries Service Ges.m.b.H. 323 p.

41349002 Fiene, J.; Mahlburg, W. (1989) Determination of Halogenated Dibenzo -pDioxins and Dibenzofurans in 2,4-D Isooctyl Ester Technical: Lab Project Number: 90/2. Unpublished study prepared by Chem- serve Industries Service Ges.m.b.H. 325 p.

41376701 Fisher, J. (1989) Manufacturing Process for the Production of Esters of 2,4- Dichlorophenoxyacetic Acid: Lab Project ID: P89030L. Unpublished study prepared by Agrolinz, Inc. 15 p.

41431101 Chakrabarti, A. (1990) Vapor Pressure of the Isopropyl Amine Salt of 2,4- Dichlorophenoxy Acetic Acid Measured by the Knudsen-Effu- sion/Weight Loss Method: Lab Project Number: ML-AL 89-020235. Unpublished study prepared by Dow Chemical U.S.A. 11 p.

41431301 Chadrabarti, A. (1989) Vapor Pressure of the Butoxyethyl Ester of (2,4- Dichlorophenoxy) Acetic Acid Measured by the Knudsen-Effu- sion/Weight Loss Method: Lab Project Number: ML-AL-89-020197. Unpublished study prepared by Dow Chemical U.S.A. 12 p.

41496701 DowElanco (1990) 2,4-D Acid: Product Identity and Composition: "Amendment". Unpublished study prepared by The Dow Chemical Co. 51 p.

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41647001 Heimerl, J. (1990) Determination of the Octanol/Water Partition Coefficient of 2,4-D Butoxyethyl Ester (2,4-D BEE) : Lab Project Number: ML-AL 90- 080378. Unpublished study prepared by Dow Chemical USA. 22 p.

41669501 Moore, R. (1990) 2,4-Dichlorophenoxyace tic acid, butoxyethyl ester: Aqueous Solubility: Lab Project Number: 9585/F/02. Unpublished study prepared by Midwest Research Institute. 17 p.

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41724201 Landvoight, W. ; Mahlburg, W. (1990) Quality Assurance Project Plan for Determination of Halogenated Dibenzo- p-Dioxins and Dibenzo- furans... in 2,4- D...: Lab Project Number: 90-3. Unpublished study prepared by Chemserve Industries Service Ges.m.b.H. 43 p.

41724202 Landvoight, W.; Mahlburg, W. (1990) Dete rmination of Halogenated Dibenzop-Dioxins and Dibenzofurans in 2,4-D Acid by Method of Analysis 50288: Lab Project Number: 90-4. Unpublished study prepared by Chemserve Industries Service Ges.m.b.H. 561 p.

41724203 Landvoight, W.; Mahlburg, W. (1990) Dete rmination of Halogenated Dibenzop-Dioxins and Dibenzofurans in 2,4-D Isooctyl Ester by Method of Analysis 50288: Lab Project Number: 90-5. Unpublished study prepared by Chemserve Industries Service Ges.m.b.H. 423 p.

41735701 Silvestre, D. (1990) Determination of Polychorinated Dibenzo-p- Dioxins and Dibenzofurans In 2,4-D: Complementary Analytical Raw Data Relative to Study 89-10: Lab Project Number: 343-484. Unp- ublished study prepared by Rhone-Poulenc Industrialisation. 100 p.

41745301 Etchepareborda, I.; Sancrica, J. (1990) Storage Stability of Tech- nical 2,4 Dichlorophenoxyacetic Acid. Unpublished study pre- pared by Atanor S.A./ Laboratorios de Estudios Analiticos. 8 p.

41745302 Castaneda, J. (1990) 2,4 Dichlorophenoxyacetic Acid Explodability: Unpublished study prepared by Instituto de Desarrollo Tecnolo- gico/para la Industria Quimica (INTEC). 8 p.

41755701 Schriber, C. (1990) Chemical Stability of 2,4-D Dimethyl Salt Solution: Lab Project Number: GH-C 24428. Unpublished study prepared by DowElanco. 17

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41790601 Armbruster, J. (1991) Product Chemistr y: 61 & 63 Series: (2,4-D Acid, Reg. No. 2217-455). Unpublished study prepared by PBI Gordon Corp. 8 p.

41790602 Armbruster, J. (1989) Certificati on of Limits for Dibenzo-p-Dioxins/Dibenzofurans. Unpublished study prepared by PBI/Gordon Corp. 489 p.

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41796202 Armbruster, J. (1989) EPA REG No. 6149-001-Certification of Limits for Dibenzo-p-Dioxins/Dibenzofurans. Unpublished study prepar- ed by Agro-Gor Corp. 489 p.

41855701 Buddle, G.; Mills, E. (1991) 2,4-Dichlorophenoxyacetic Acid (2,4-D) Physical and Chemical Characteristics: Density and Stability (Supplement to MRID 41599401): Lab Project Number: P-91-016. Unpublished study prepared by Rhone-Poulenc Ag., Ltd. 27 p.

41880601 Cicotti, M. (1991) Determination of the Solubility of 2,4-D in Organic Solvents in accordance with EPA 63-8 and BBA Guidelines: Lab Project Number: BE/P/1/91/01/BG. Unpublished study prepared by Battelle Europe. 15 p.

41926201 Etchepareborda, I.; Sancricca, J. (1991) Preliminary Analysis of 2,4 Dichlorophenoxyacetic acid 97%. Unpublished study prepared by Atanor S. A. 17 p.

41926202 Etchepareborda, I. (1991) pH of 2,4-Dichlorophenoxyacetic acid 97%. Unpublished study prepared by Atanor S. A. 5 p.

41926203 Etchepareborda, I.; Sancricca, J. (1991) Storage Stability (1 year in commercial packaging) of 2,4 Dichlorophenoxyacetic acid 97%. Unpublished study prepared by Atanor S. A. 7 p.

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41964401 DowElanco (1991) Response to 2,4-D Task 4: Registrant's Response to Product Chemistry Data Requirements DEB No. 5454-5455, 5440-5544 Dated Sep. 22, 1989 (Tinsworth Letter Dated January 23, 1990) 2,4-Dimethylamine Salt. Unpublished study prepared by DowElanco . 17 p.

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41968302 Helmer, D. (1987) Determination of the Water Solubility of 2,4- dichlorophenoxy Acetic Acid, 2-ethylhexyl Ester: Lab Project No: ML-AL-87- 70817. Unpublished study prepared by Dow Chemical USA. 13 p.

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41972501 Gallacher, A. (1991) Dissociation of 2,4-Dichlorophenoxyacetic Acid (2,4-D) and 2,4-D Diethanolamine Salt in Water: Lab Project Num- ber: 4102-90-0304- AS: 4102-90-0304-AS-001. Unpublished study prepared by Ricerca, Inc. 231 p.

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41973502 Schriber, C. (1991) Chemical Stability of 2,4-Dichlorophenoxyacetic Acid: Lab Project Number: 90089. Unpublished study prepared by DowElanco. 17 p.

41978001 DowElanco (1991) 2,4-D Isopropylamine Salt: Response to 2,4-D Task 4: Registrant's Response to Product Chemistry Data Requirements DEB Nos. 5454-5455, 5489, 5440-5544 Dated September 22, 1989. Unpublished study prepared by DowElanco. 16 p.

41978002 Schriber, C. (1991) Chemical Stability of 2,4-D Isopropylamine Salt Solution: Lab Project Number: 90088. Unpublished study prepared by DowElanco 17 p.

42021001 MacDaniel, R.; Weiler, D. (1987) Vapor Pressure Determination of 2,4- Dichlorophenoxyacetic Acid: Dimethylamine Salt: Lab Project Number: 41023. Unpublished study prepared by Rhone-Poulenc Inc. 9 p.

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42023601 Desai, L. (1991) Technical 2,4-D Acid: Physical and Chemical Char- acteristics: Lab Project Number: 91-GR-0004. Unpublished study prepared by Toxicon Corp. 120 p.

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42227501 Sawyer, R. (1990) Product Chemistry: Riverdale Sodium Salt of 2,4-D. Unpublished study prepared by Riverdale Chemical Co. 8 p.

42487901 Schriber, C. (1992) Chemical Stability of 2, 4-Dichlorophenoxyacetic Acid, Butoxyethyl Ester Solution: Lab Project Number: 90090. Unpublished study prepared by DowElanco. 16 p.

42537501 Sawyer, R. (1992) Product Chemistry--Addendum: Riverdale Sodium Salt of 2,4-D. Unpublished study prepared by Riverdale Chemical Co. 14 p.

42786501 Feiler, W. (1993) Technical Isopropyl Ester of 2,4-D: Product Chemistry. Unpublished study prepared by Amvac Chemical Corp. 14 p.

42795401 Murphy, J. (1993) Determination of Stability of 2,4-Dichlorophenoxyacetic Acid (2,4-D) Technical Grade of Ac tive Ingredient (TGAI): Lab Project Number: FOR93058. Unpublished study prepared by Formulation Science and Technology Lab. 9 p.

42798101 Murphy, G. (1993) Response to the Letter Written by Lois A. Rossi (10/05/02): Subject: Product Chemistry Review for DowElanco 2,4-D DMA FI: Lab Project Number: GM052793A. Unpublished study prepared by DowElanco. 7 p.

42798201 Murphy, G. (1993) Product Chemistry Re view for DowElanco 2,4-D TIPA FI: Lab Project Number: GM052993A. Unpublished study prepared by DowElanco. 4 p.

42798301 Murphy, G. (1993) Response to Letter Written by Lois A. Rossi (1/08/93): Subject: Product Chemistry Review for DowElanco 2,4-D IPA FI: Lab Project Number: GM052793B. Unpublished study prepared by DowElanco. 7 p.

42829901 Murphy, G. (1993) Determination of Melting Point of 2,4- Dichlorophenoxyacetic Acid Dimethylamine Salt (2,4-D DMA) Technical Grade of Active Ingredient (TGAI): Lab Project Number: FOR93053. Unpublished study prepared by Formulation Science and Technology Lab. DowElanco. 9 p.

42830901 Murphy, G. (1993) Determination of Boiling Point and Solubility of 2,4- Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) Technical Grade Active Ingredient (TGAI): Lab Project Number: FOR93057. Unpublished study prepared by Formulation Science and Technology Lab. DowElanco. 17 p.

42831001 Murphy, G. (1993) Determination of Melting Point of 2,4- Dichlorophenoxyacetic Acid Isopropylamine Salt (2,4-D IPA) Technical Grade of Active Ingredient (TGAI): Lab Project Number: FOR93054. Unpublished study prepared by Formulation Science and Technology Lab. DowElanco. 9 p.

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Page 243 of 304 42831101 Murphy, G. (1993) Determination of Boiling Point and Solubility of 2,4- Dichlorophenoxyacetic Acid 2-Ethylhe xyl Ester (2,4-D 2-EHE) Technical Grade of Active Ingredient (TGAI): Lab Project Number: FOR93055. Unpublished study prepared by Formulation Science and Technology Lab, DowElanco. 17 p.

42857201 Malone, S. (1992) Characterization of Technical Diethanolamine Salt of (2,4- Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0055-AS: 4102- 92-0055-AS-001. Unpublished study prepared by Ricerca, Inc. 47 p.

42857202 Malone, S. (1992) Characterization of Purified Diethanolamine Salt of (2,4- Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0056-AS: 4102- 92-0056-AS-001. Unpublished study prepared by Ricerca, Inc. 73 p.

42857203 Wojcieck, B. (1992) Color, Physical State, Odor of the Diethanolamine Salt of (2,4-Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0082-AS: 4102-92-0082-AS-001. Unpublished study prepared by Ricerca, Inc. 24 p.

42857204 Wojcieck, B. (1992) Bulk Density of the Diethanolamine Salt of (2,4- Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0083-AS: 4102- 92-0083-AS-001. Unpublished study prepared by Ricerca, Inc. 22 p.

42857205 Douglass, M. (1993) Technical Diet hanolamine Salt of (2,4-Dichlorophenoxy) Acetic Acid--Solubility: Lab Project Number: 4102-92-0057-AS: 4102-92- 0057-AS-001. Unpublished study prepared by Ricerca, Inc. 92 p.

42857206 Douglass, M. (1993) Purified Diet hanolamine Salt of (2,4-Dichlorophenoxy) Acetic Acid--Vapor Pressure: Lab Project Number: 4102-92-0058-AS: 4102- 92-0058-AS-001. Unpublished study prepared by Ricerca, Inc. 68 p.

42857207 Douglass, M. (1993) Purified Diet hanolamine Salt of (2,4-Dichlorophenoxy) Acetic Acid--Octanol/Water Partition Coefficient: Lab Project Number: 4102- 92-0059-AS: 4102-92-0059-AS-001. Unpublished study prepared by Ricerca, Inc. 55 p.

42857208 Furlong, K. (1992) pH of the Diethanolamine Salt of (2,4-Dichlorophenoxy) Acetic Acid: Lab Project Number: 4102-92-0088-AS: 4102-92-0088-AS-001. Unpublished study prepared by Ricerca, Inc. 27 p.

42857209 Malone, S. (1993) Technical Diethanolamine Salt of (2,4-Dichlorophenoxy) Acetic Acid--Stability: Lab Project Number: 4102-92-0085-AS: 4102-92-0085- AS-001. Unpublished study prepared by Ricerca, Inc. 51 p.

43260501 Krause, R.; Jones-Jefferson, T.; Wallace, T. (1994) Storage Stability of 2,4-D Acid: One Year Ambient Temperature Storage Study Results: Lab Project Number: FOR93069. Unpublished study prepared by DowElanco, Formulation Science & Technology. 14 p.

### 2,4-D Bibliography

Page 244 of 304 43302001 Braden, G. (1994) Solubility of Isopropyl Ester of 2,4-D in Selected Organic Solvents: Lab Project Number: SOL/018. Unpublished study prepared by Amvac Chemical Corp. R & D Labs. 16 p.

43314701 Kinnunen, C. (1994) Series 62-1: Preliminary Analysis of Product Sample of 2,4-Dichlorophenoxy Acetic Acid, Dimethylamine-6 (2,4-D DMA-6) Sequestered for Dimethyl Nitrosamine: Lab Project Number: FOR93133. Unpublished study prepared by DowElanco. 19 p.

43325001 Kinnunen, C. (1994) Series 63: Determination of the Boiling Point of 2,4- Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) TGAI: Lab Project Number: FOR94079. Unpublished study prepared by DowElanco. 9 p.

43325002 Kinnunen, C. (1994) Series 63: Determination of the Boiling Point of 2,4- Dichlorophenoxyacetic Acid 2-Ethylhexyl Ester (2,4-D 2-EHE) TGAI: Lab Project Number: FOR94080. Unpublished study prepared by DowElanco. 9 p.

43325003 Kinnunen, C. (1994) Series 63: Determination of the Melting Point of 2,4- Dichlorophenoxyacetic Acid Triisopropanolamine Salt (2,4-D) TGAI: Lab Project Number: FOR93132. Unpublished study prepared by DowElanco. 9 p.

43358801 Kinnunen, C. (1994) Determination of Solubility of 2,4-Dichlorophenoxyacetic Acid, Dimethylamine Salt: Lab Project Number: FOR94078. Unpublished study prepared by DowElanco. 25 p.

43358802 Kinnunen, C. (1994) Determination of Solubility of 2,4-Dichlorophenoxyacetic Acid, Isopropylamine Salt: Lab Project Number: FOR94081: GH-C 3356. Unpublished study prepared by DowElanco. 24 p.

43516401 Haefele, L. (1995) Identity and Composition for Albaugh 2,4-D Technical Acid: Final Report: Lab Project Number: 95-ALBG-012. Unpublished study prepared by AC RN Labs. 37 p.

43516402 Willis, C. (1994) Preliminary Analysis and Precision and Accuracy of Analytical Method Used to Validate Certified Limits: (2,4-Dichlorophenoxy) Acetic Acid: Final Report: Lab Project Number: 810-17. Unpublished study prepared by Case Consulting Labs., Inc. 114 p.

43516403 Willis, C. (1994) 2,4-D (2,4-Dichlorophenoxyacetic acid): Physical and Chemical Characteristics of 2,4-D: Color, Physical State, Odor, Melting Point, Bulk Density, Solubility, Vapor Pressure, Dissociation Constant, Octanol/Water Partition Coefficient, pH, Stability, Oxidizing or Reducing and Explodability: Final Report: Lab Project Number: 810-18. Unpublished study prepared by Case Consulting Labs., Inc. 25 p.

43516404 Willis, C. (1994) 2,4-D (2,4-Dichlorophenoxyacetic acid): Physical and Chemical Characteristics of 2,4-D: Storage Stability and Corrosion Characteristics: Interim Report: Lab Project Number: 810-19. Unpublished study prepared by Case Consulting Labs., Inc. 14 p.

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Page 245 of 304 43777501 Kinnunen, C. (1995) Preliminary Analysis of Product Sample of Flake 2,4- Dichlorophenoxyacetic Acid: Lab Project Number: FOR95091. Unpublished study prepared by DowElanco. 39 p.

43777502 Kinnunen, C. (1995) Preliminary Analysis of Product Sample of Molten 2,4- Dichlorophenoxyacetic Acid: Lab Project Number: FOR95090. Unpublished study prepared by DowElanco. 39 p.

43874601 Krause, R.; Jones-Jefferson, T. (1995) Storage Stability of 2,4-D; IPA Salt Manufacturing-Use-Concentrate One Year Ambient Temperature Storage Study Results: Lab Project Number: FOR94149. Unpublished study prepared by DowElanco. 14 p.

43981801 Willis, C. (1996) 2,4-D: Analyses for Te tra- Through Octa-Chlorinated Dioxins and Furans: Final Report: Lab Project Number: 810-24. Unpublished study prepared by Case Consulting Labs, Inc. 1053 p.

44149301 Armbruster, J. (1996) Product Identity and Manufacturing Process: (2,4-D). Unpublished study prepared by PBI/Gordon Corp. 59 p.

44149302 Morrissey, M. (1996) Preliminary Analysis of 2,4-Dichlorophenoxyacetic Acid: Final Report: Lab Project Number: CHW 6747-100. Unpublished study prepared by Corning Hazleton Inc. 176 p.

44184201 Sanson, D. (1996) Product Identity and Composition of EH1330 Herbicide. Unpublished study prepared by PBI/Gordon Corp. 8 p.

44228301 Cobb, J. (1997) Product Identity and Composition of TIPA-4: Manufacturing Use Product Containing 2,4-D Triisopropanolamine Salt: Lab Project Number: GH-C 4321. Unpublished study prepared by DowElanco. 76 p.

44228601 Pruitt, P. (1996) Series 62-1, Preliminary Analysis and Series 62-2, Certified Limits for 2,4-D Acid Molten: Lab Project Number: GH-C 4238. Unpublished study prepared by DowElanco. 40 p.

44287101 Cramer, P. (1996) 2,4-Dichlorophenoxyacetic Acid: Analysis for Polychlorinated Dibenzo-p-dioxins and Dibenzofurans in Acid, Salt, and/orEster Technical Material: Final Report: Lab Project Number: 4199-A: MRIA\R4199-01: 4199. Unpublished study prepared by Midwest Research Institute. 811 p.

44543502 Pryce, A. (1998) 2,4-D Acid: Product Chemistry: Analysis Methods: Final Report: Lab Project Number: AHM/E PA/98/AP/05: 97/0014. Unpublished study prepared by A H Marks and Company Limited. 41 p. {OPPTS 830.1800}

44543503 Pryce, A. (1998) 2,4-D Acid: Product Chemistry: 5 Batch Analysis: Final Report: Lab Project Number: AHM/EPA/98/AP/06. Unpublished study prepared by A H Marks and Co. Limited. 154 p. {OPPTS 830.1700}

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Page 246 of 304 44543504 Hutchinson, N. (1998) 2,4-D TGAI: Product Chemistry: Physical/Chemical Properties: Final Report: Lab Pr oject Number: AHM/EPA/98/NDH/01: 94/0010. Unpublished study prepared by A H Marks and Company Limited. 69 p. {OPPTS 830.6302, 830.6303, 830.6304, 830/6313, 830.7000, 830.7050, 830.7200, 830.7300, 830.7370, 830.7550, 830.7840, 830.7950}

44547901 Pryce, A. (1998) 2,4-D Acid: Product Chemistry: Existing Manufacturing Process: Final Report: Lab Project Number: AHM/EPA/98/AP/02. Unpublished study prepared by A H Marks and Co., Ltd. 29 p. {OPPTS 830.1550, 830.1600, 830.1670, 830.1700, 830.1750}

44584501 Hamilton, T. (1998) Group A: Product Identity and Composition of 2,4-D Butoxyethyl Ester Technical: Lab Project Number: GH-C 4680. Unpublished study prepared by Dow AgroSciences LLC. 58 p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670, 830.1750}

44620501 Hamilton, T. (1998) Group A: Product Identity and Composition of TIPA-4 Herbicide, a Manufacturing Use Product: Lab Project Number: GH-C 4743. Unpublished study prepared by Dow Agrosciences LLC. 13 p. {OPPTS 830.1550, 830.1750, 830.1700}

44727101 Cobb, J. (1998) Group A: Product Identity and Composition of 2,4-D Isopropylamine Technical Manufacturing Use Product Containing 2,4-D Isopropylamine Technical: Lab Project Number: NAFST017. Unpublished study prepared by Dow AgroSciences LLC 47 p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670, 830.1750}

44807001 Madsen, S. (1999) Group A: Product Identity and Composition of 2,4-D Isopropylamine Salt Technical--High pH Manufacturing Use Product Containing 2,4-D Isopropylamine Salt: Lab Project Number: NAFST055. Unpublished study prepared by Dow Agrosciences, LLC. 50 p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670, 830.1750}

44932701 Hutchinson, N. (1999) Preliminary Analysis of 5 Batches of 2,4- dichlorophenoxyacetic Acid Technical Grade Active Ingredient: Final Report: Lab Project Number: 98/0057. Unpublished study prepared by AH Marks and Company Limited. 188 p. {OPPTS 830.1700}

44963801 Sanson, D. (1999) Preliminary Analysis of Technical 2,4- Dichlorophenoxyacetic 2-Ethylhexyl Ester: Lab Project Number: 98-019. Unpublished study prepared by Ricerca, Inc. and University of Missouri Biochemistry Department. 153 p. {OPPTS 830.1700}

44963802 Hughes, D. (1999) Determination of Physico-Chemical Properties of 2,4-D IOE Technical Grade Active Ingredient (TGAI) and 2,4-D IOE Purified Active Ingredient (PAI) (Color, Physical State, Odor, Boiling Point, Density, Solubility, Vapor Pressure, Octanol/Water Partition Coefficient, pH, Stability): Lab Project Number: 6993-100. Unpublished study prepared by Covance Laboratories Inc. 12 p.

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Page 247 of 304 44963803 Sanson, D. (1999) Product Identity, Composition and Analysis of Technical 2,4- Dichlorophenoxyacetic Acid, 2-Ethylhexyl Ester. Unpublished study prepared by PBI/Gordon Corporation. 35 p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670}

44963804 Sanson, D. (1999) Certified Limits of Technical 2,4-Dichlorophenoxyacetic Acid, 2-Ethylhexyl Ester and Enforcemen t Analytical Method of Technical 2,4- Dichlorophenoxyacetic Acid, 2-Ethylhexyl Ester. Unpublished study prepared by PBI/Gordon Corporation. 6 p. {OPPTS 830.1750 and 830.1800}

44982101 Madsen, S.; Cobb, J.; Hackett, B. et al. (1999) Group A: Product Identity and Composition of 2,4-D 2-Ethylhexyl Este r Technical Grade Active Ingredient and Manufacturing Use Product Containi ng 2,4-D 2-Ethylhexyl Ester Technical: Lab Project Number: NAFST018. Unpublished study prepared by Dow AgroSciences LLC. 54 p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670, 830.1750}

44982102 Hamilton, T. (1999) Ester Specific Analytical Method for Determination of Esters of 2,4-Dichlorophenoxyacetic Acid (2,4-D) and Related Impurities: Lab Project Number: DECO GL-AL 99-000252. Unpublished study prepared by The Dow Chemical Company. 74 p. {OPPTS 830.1800}

45014801 VanderKamp, J.; Kastl, P. (1999) Five Batch Analysis of 2,4-D 2-Ethyl-1-Hexyl Ester Technical: Lab Project Number: DECO GL-AL 99-002231. Unpublished study prepared by The Dow Chemical Co. 42 p. {OPPTS 830.1700}

45642701 Sarff, P. (2002) Determination of the Storage Stability and Corrosion Characteristics for DMA-6 Sequestered (2,4-D Dimethylamine-6 Sequestered Herbicide): Lab Project Number: 46237: NAFST494: NAF-190. Unpublished study prepared by ABC Laboratories, Inc. 30 p. {OPPTS 830.6317, 830.6320}

45692501 Lezotte, F.; Van Hoven, R.; Nixon, W. (2002) Determination of Water Solubility of 2,4-D Acid by the Shake Flask Method: Lab Project Number: 467C-103: 467/121801/7840/SUB467. Unpublished study prepared by Wildlife International, Ltd. 43 p. {OPPTS 830.7840}

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41388204 Samson, Y.; Gollapudi, B. (1989) Evaluation of 2,4-D Butoxyethyl Ester in the Ames Salmonella/Mammalian-Microsome Bacterial Muta- genicity Assay: Lab Project Number: TXT:K-007722-011. Unpub- lished study prepared by The Dow Chemical Co. 27 p.

41407901 Mizell, M.; Atkin, L.; Crissman, J. (1990) 2,4-Dichlorophenoxyace- tic Acid Butoxyethyl Ester: 21-Day Dermal Toxicity Study in New Zealand White Rabbits: Final Report: Study ID: HET K-007722-008. Unpublished study prepared by Dow Chemical Co., Toxicology Research Laboratory. 167 p.

41407902 Mizell, M.; Atkin, L.; Haut, K.; et al. (1990) 2,4-D Triisopropan- olamine Salt: 21-Day Dermal Toxicity Study in New Zealand White Rabbits: Final Report: Study ID: K-008866-004. Unpublished study prepared by Dow Chemical Co., Toxicology Research Labora- tory. 168 p.

### 2,4-D Bibliography

Page 252 of 304 41407903 Mizell, M.; Atkin, L.; Haut, K.; et al. (1990) 2,4-D Isopropyla- mine Salt: 21- Day Dermal Toxicity Study in New Zealand White Rabbits: Lab Project Number: M-004725-004. Unpublished study prepared by Dow Chemical Co., Toxicology Research Laboratory. 166 p.

41409801 Lawlor, T.; Valentine, D. (1990) Mutagenicity Test on 2,4-Dichlorophenoxyacetic Acid (2,4-D) in the Salmonella-Microsome Reverse Mutation Assay (Ames Test): Rev. Final Rept.: Lab Study No. 10979-0-401. Unpublished study prepared by Hazleton Laborator- ies America, Inc. 34 p.

41409802 Lawlor, T.; Valentine, D. (1990) Mutagenicity Test on 2,4-D-Di- methylamine Salt in the Salmonella/Mammalian-Microsome Reverse Mutation Assay (Ames Test): Revised Final Report: Lab Project No. 10981-0-401. Unpublished study prepared by Hazleton Labora- tories America, Inc. 34 p.

41409803 Lawlor, T.; Valentine, D. (1990) Mu tagenicity Test on 2,4-D-2- Ethylhexyl Ester in the Salmonella/Mammalian-Microsome Reverse Mutation Assay (Ames Test): Revised Final Report: Lab Project No. 10980-0-401. Unpublished study prepared by Hazleton Labora- tories America, Inc. 34 p.

41409804 Ivett, J. (1990) Mutagenicity Test on 2,4-D-2-Dichlorophenoxyacetic Acid in vivo Mouse Micronucleus Assay: Revi sed Final Report: Lab Project No. 10979- 0-455. Unpublished study prepared by Hazleton Laboratories America, Inc. 39

p.

41409805 Ivett, J. (1990) Mutagenicity Test on 2,4-D Dimethylamine Salt in vivo Mouse Micronucleus Assay: Revised Final Report: Lab Project Number: 10981-0-455. Unpublished study prepared by Hazleton Laboratories America, Inc. 40 p.

41409806 Ivett, J. (1990) Mutagenicity Test on 2,4-D-2-Ethylhexyl Ester in vivo Mouse Micronucleus Assay: Revised Fina l Report: Lab Project No. 10980-0-455. Unpublished study prepared by Hazleton Labora- tories, Inc. 39 p.

41409807 Cifone, M. (1990) Mutagenicity Test on 2,4-Dichlorophenoxyacetic Acid (2,4- D) in the in vitro Rat Primary Hepatocyte Unscheduled DNA Synthesis Assay: Revised Final Report: Lab Project No. 10979-0-447. Unpublished study prepared by Hazleton Labora- tories America, Inc. 43 p.

41409808 Cifone, M. (1990) Mutagenicity Test on 2,4-D Dimethylamine Salt in the in vitro Rat Primary Hepatocyte Unscheduled DNA Synthesis Assay: Revised Final Report: Lab Project Number: 10981-0-447. Unpublished study prepared by Hazleton Laboratories America, Inc. 44 p.

41409809 Cifone, M. (1990) Mutagenicity Test on 2,4-D-2-Ethylhexyl Ester in the in vitro Rat Primary Hepatocyte Unscheduled DNA Synthesis Assay: Revised Final Report: Lab Project Number: 10980-0-447. Unpublished study prepared by Hazleton Laboratories America, Inc. 44 p.

### 2,4-D Bibliography

Page 253 of 304 41413501 Berdasco, N.; Schuetz, D.; Jersey, G. et al. (1989) 2,4-Dichloro- phenoxyacetic Acid Triisopropanolamine Salt: Acute Oral Toxicity Study in Fischer 344 Rats: Lab Project Number: K-008866-002A. Unpublished study prepared by The Dow Chemical Co. 33 p.

41413502 Berdasco, N.; Schuetz, B.; Yano, B. et al. (1989) 2,4-Dichlorophe- noxyacetic Acid Triisopropanolamine Salt: Acute Dermal Toxicity Study in New Zealand White Rabbits: Lab Project Number: K-008866 -002D. Unpublished study prepared by The Dow Chemical Co. 19 p.

41413503 Nitschke, K.; Lomax, L. (1990) 2,4-D Triisopropanolamine: Acute Ae- rosol LC50 Study in Fischer 344 Rats: Lab Project Number: HET K- 008866-010. Unpublished study prepared by The Dow Chemical Co. 30 p.

41413504 Berdasco, N.; Mizell, M. (1989) 2,4-Dichorophenoxyacetic Acid Triisopropanolamine Salt: Primary Eye Irritation Study in New Zea- land White Rabbits: Lab Project Number: K-008866-002C. Unpub- lished study prepared by The Dow Chmemical Co. 14 p.

41413505 Mizell, M. (1989) 2,4-Dichlorophenoxyacetic Acid, Triisopropanol- amine Salt: Primary Dermal Irritation Study in New Zealand White Rabbits: Lab Project Number: K-008866-002B. Unpublished study prepared by The Dow Chemical Co. 13 p.

41413506 Berdasco, N. (1989) 2,4-Dichlorophenoxyacetic Acid Triisopropanol- amine Salt: Dermal Sensitization Potential in the Hartley Albino Guinea Pig: Lab Project Number: K-008866-002E. Unpublished study prepared by The Dow Chemical Co. 14 p.

41420004 Ivett, J. (1989) Single Acute Exposure Dose Selection Study on 2,4- D Dimethylamine Salt: Lab Project Number: 10981-0-459-PO. Un- published study prepared by Hazleton Laboratories America, Inc. 15 p.

41420005 Ivett, J. (1989) Single Acute Exposure Dose Selection Study on 2,4- D-2- Ethylhexyl Ester: Lab Project Number: 10980-0-459-PO. Un- published study prepared by Hazleton Laboratories America, Inc. 15 p.

41478301 Gollapudi, B. ; Samson, Y. ; McClintock, M. (1990) Evaluation of 2,4- Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) in the Mouse Bone Marrow Micronucleus Test: Lab Project Number: K-O07722-012. Unpublished study prepared by Dow Chemical Co., Lake Jackson Research Ctr. 29 p.

41478302 Gollapudi, B.; Samson, Y.; McClintock, M. (1990) Evaluation of a Formulation Containing 2,4-Dichlorophenoxyacetic Acid Triisopro- panolamine Salt (2,4-D TIPA) in the Mouse Bone Marrow Micronu- cleus Test: Lab Project Number: K-008866-009. Unpublished study prepared by Dow Chemical Co., Lake Jackson Research Center. 30 p.

### 2,4-D Bibliography

Page 254 of 304 41478303 Gollapudi, B.; Samson, Y.; McClintock, M. (1990) Evaluation of a Formulation Containing 2,4-Dichlorophenoxyacetic Acid Isopropyl- amine Salt (2,4-D IPA)in the Mouse Bone Marrow Micronucleus Test: Lab Project Number: M004725-009. Unpublished study pre- pared by Dow Chemical Co., Lake Jackson Research Ctr. 30 p.

41498101 McClintock, M.; Gollapudi, B. (1990) Evaluation of 2,4-Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) in the Rat Hepato- cyte: Unscheduled DNA Synthesis (UDS) A ssay: Lab Project Number: TXT:K007722-013. Unpublished study prepared by The Dow Chem- ical Co. 46 p.

41498102 McClintock, M.; Gollapudi, B. (1990) Evaluation of a Formulation Containing 2,4-Dichlorophenoxyacetic Acid Triisopropylamine Salt (2,4-D TIPA) in the Rat Hepatocyte Unscheduled DNA Synthesis (UDS) Assay: Lab Project Number: TXT:K-008866-008. Unpublished study prepared by The Dow Chemical Co. 46 p.

41498103 McClintock, M.; Gollapudi, B. (1990) Evaluation of a Formulation Containing 2,4-Dichlorophenoxyacetic Acid Isopropylamine Salt (2,4-D IPA) in the Rat Hepatocyte: Unscheduled DNA Synthesis (UDS) Assay: Lab Project Number: TXT:M-004725-008. Unpublished study prepared by The Dow Chemical Co. 46 p.

41527102 Schroeder, R. (1990) A Teratogenicity Study in Rats with 2,4-D Triisopropanolamine: Lab Project Number: HET K0008866-012: 89-3463. Unpublished study prepared by Bio/dynamics, Inc. 478 p.

41527103 Schroeder, R. (1990) A Teratogenicity Study in Rats with 2,4-D Isopropylamine Salt: Lab Project Number: HET K-004725-011: 89-3465. Unpublished study prepared by Bio/dynamics, Inc. 441 p.

41527104 Schroeder, R. (1990) A Range-Finding St udy to Evaluate the Toxicity of 2- Butoxyethyl Ester of 2,4-D in the Pre gnant Rat: Lab Project Number: HET K007722-016: 89-3468. Unpublished study prepared by Bio/dynamics, Inc. 154

p.

41527105 Schroeder, R. (1990) A Range-Finding St udy to Evaluate the Toxicity of 2,4-DTriisopropanolamine Salt in the Pregnant Rat: Lab Pro- ject Number: HET K008866-011: 89-3464. Unpublished study pre- pared by Bio/dynamics, Inc. 246

p.

41527106 Schroeder, R. (1990) A Range-Finding St udy to Evaluate the Toxicity of 2,4-D Isopropylamine Salt in the Pregnant Rat: Lab Project Number: HET K-004725- 010: 89-3466. Unpublished study prepared by Bio/dynamics, Inc. 141 p.

41642803 Robbins, G. (1989) Primary Eye Irritation Study in Rabbits: Dri-D Amine: Lab Project Number: D2013. Unpublished study prepared by Cosmopolitan Safety Evaluation, Inc. (C.S.E.) 19 p.

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Page 255 of 304 41642804 Robbins, G. (1989) Primary Dermal Irritation Study in Rabbits: Dri- D Amine: Lab Project Number: E2013. Unpublished study prepared by Cosmopolitan Safety Evaluation, Inc. 14 p.

41642805 Robbins, G. (1989) Guinea Pig Sensitiz ation Study (Buehler): Dri-D Amine: Lab Project Number: F2013. Unpublished study prepared by Cosmopolitan Safety Evaluation, Inc. (C.S.E.) 17 p.

41709901 Lilja, H. (1990) Acute Oral Toxicity Study (LD50): Hivol-44: Amended Report: Lab Project Number: 88G-0274. Unpublished study prepared by Toxikon Corp. 17 p.

41709902 Lilja, H. (1990) Single Dose Dermal Toxicity: Hivol-44: Amended Report: Project Number: 88G-0272. Unpublished study prepared by Toxikon Corp. 14

p.

41735201 Lochry, E. (1990) Developmental Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-Dimethylamine Salt (2,4-D- DMA Administered Orally via Gavage to CRL: CD BR VAF/Plus Pre- sumed Pregnant Rats: Final Report: Lab Project Number: 320-001. Unpublished study prepared by Argus Research Labs. 436 p.

41735304 Schulze, G. (1990) 21-Day Dermal Irritation and Dermal Toxicity Study in Rabbits with 2,4 Dichlorophenoxyacetic Acid: Lab Pro- ject Number: 2184-109. Unpublished study prepared by Hazleton Labs America, Inc. 186 p.

41735301 Schulze, G. (1990) 21-Day Dermal Irritation and Range-finding Study in Rabbits with 2,4-Dichlorophenoxyacetic Acid: Final Report:Lab Project Number: 2184-106. Unpublished study prepared by Hazle- ton Labs America, Inc. 39 p.

41735302 Schulze, G. (1990) 21-Day Dermal Irr itation and Dermal Range- finding Study in Rabbits with 2,4-Dichlorophenoxyacetic Acid-2- Ethylhexyl Ester: Lab Project Number: 2184-107. Unpublished study prepared by Hazleton Labs America, Inc. 44 p.

41735303 Schulze, G. (1990) 21-Day Dermal Irrita tion and Dermal Range-find- ing Study in Rabbits with Dimethylamine Salt of 2,4-Dichloro- phenoxyacetic Acid: Lab Project Number: 2184-108. Unpublished study prepared by Hazleton Labs America, Inc. 46 p.

41735304 Schulze, G. (1990) 21-Day Dermal Irritation and Dermal Toxicity Study in Rabbits with 2,4 Dichlorophenoxyacetic Acid: Lab Pro- ject Number: 2184-109. Unpublished study prepared by Hazleton Labs America, Inc. 186 p.

41735305 Schulze, G. (1990) 21-Day Dermal Irritation and Dermal Toxicity Study in Rabbits with 2,4-Dichlorophenoxyacetic Acid-2-ethyl- hexyl Ester: Lab Project Number: 2182-110. Unpublished study prepared by Hazleton Labs America, Inc. 200 p.

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Page 256 of 304 41735306 Schulze, G. (1990) 21-Day Dermal Irritation and Dermal Toxicity Study in Rabbits with the Dimethylamine Salt of 2,4-Dichloro- phenoxyacetic Acid: Lab Project Number: 2184-111. Unpublished study prepared by Hazleton Labs America, Inc. 212 p.

41737301 Schulze, G. (1990) Subchronic Toxicity Study in Dogs with 2,4- Dichlorophenoxyacetic Acid: Final Report: Lab Project Number: 2184-115. Unpublished study prepared by Hazleton Laboratories America, Inc. 332 p.

41737302 Timchalk, C.; Dryzga, M.; Brzak, K. (1990) 2,4-Dichlorophenoxy- acetic, Tissue Distribution and Metabolism of (Carbon 14)- Labeled, 2,4- Dichlorophenoxyacetic Acid in Fischer 344 Rats: Final Report: Lab Project Number: K-2372-47. Unpublished study prepared by the Dow Chemical Co. 70

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41747601 Hoberman, A. (1990) Development Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-Dichlorophenoxyacetic Acid (2,4-D Acid) Administered Orally via Stomach Tube to New Zealand White Rabbits: Lab Project Number: 320-003. Unpublished study prepared by Argus Research Laboratories, Inc. 478 p.

41797901 Samson, Y.; Gollapudi, B. (1990) Response to the Comments by the U. S. EPA on the Study Entitled: Evaluation of 2,4-D Triisopropa- nolamine Salt in the Ames Salmonella/Mammalian-Microsome Bacte- rial Mutagenicity Assay: Lab Project Number: TXT:K-008866-007. Unpublished study prepared by The Dow Chemical Co. 12 p.

41797902 Samson, Y.; Gollapudi, B. (1990) Response to the Comments by the U. S. EPA on the Study Entitled: Evaluation of 2,4-D Isopropylamine Salt in the Ames Salmonella/Mammalian-Microsome Bacterial Muta- genicity Assay: Lab Project Number: TXT:K-004725-007. Unpub- lished study prepared by The Dow Chemical Co. 12 p.

41797903 Samson, Y.; Gollapudi, B. (1990) Response to the Comments by the U. S. EPA on the Study Entitled: Evaluation of 2,4-D Butoxyethyl Ester in the Ames Salmonella/Mammalian-Microsome Bacterial Muta- genicity Assay: Lab Project Number: TXT:K-007722-011. Unpub- lished study prepared by The Dow Chemical Co. 11 p.

41870101 Ivett, J. (1990) Mutagenicity Test on 2,4-Dichlorophenoxyacetic Acid in vivo Mouse Assay: Lab Project Number: 10979-0-455. Un- published study prepared by Hazleton Laboratories America, Inc. 6 p.

41870102 Ivett, J. (1990) Mutagenicity Test on 2,4-Dimethylamine Salt in vivo Mouse Micronucleus Assay: Supplement to 41409805: Proj. No. 10981-0-455. Rev. Final Report. Unpublished study prepared by Hazleton Laboratories America, Inc. 6 p.

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Page 257 of 304 41870103 Ivett, J. (1990) Mutagenicity Test on 2,4-D-2-Ethylhexyl Ester in vivo Mouse Micronucleus Assay: Lab Project Number: 10980/0/455. Supplement to 41409806. Rev. Final Report. Unpublished study prepared by Hazleton Laboratories America, Inc. 6 p.

41896701 Schulze, G. (1991) Subchronic Toxicity Study in Rats with 2,4-Dichlorophenoxyacetate Acid-2-Ethylhexyl Ester: Final Report: Lab Project Number: 2184-112. Unpublished study prepared by Hazle- ton Laboratories America, Inc. 484 p.

41896702 Schulze, G. (1991) Subchronic Toxicity Study in Rats with the Di- methylamine Salt of 2,4-Dichlorophenoxyacetic Acid: Final Report: Lab Project Number: 2184/113. Unpublished study pre- pared by Hazleton Laboratories America, Inc. 481 p.

41920901 Shults, S.; Brock, A.; Killeen, J. (1990) Acute Oral Toxicity (LD50) Study in Rats with Diethanolamine Salt of 2,4- D: Lab Pro- ject Number:90-0161: 3592- 90-0161-TX-001. Unpublished study prepared by Ricerca, Inc. 37 p.

41920902 Shults, S.; Brock,A.; Killeen, J. (1990) Primary Eye Irritation Study in Albino Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number 90-0164: 3592- 90-0164-TX-001. Unpublished study prepared by Ricerca, Inc. 30 p.

41920903 Shults, S.; Brock, A.; Killeen, J. (1990) Primary Dermal Irritation Study in Albino Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number: 90- 0165: 3592-90-0165-TX-001. Unpublished study prepared by Ricerca, Inc. 18 p.

41920904 Shults, S.; Brock, A.; Killeen, J. (1990) Dermal Sensitization Study (Closed Patch Repeated Insult) in Guinea Pigs with Di- ethanolamine Salt of 2,4-D: Lab Project Number: 90-0166: 3592- 90-0166-TX-001. Unpublished study prepared by Ricerca, Inc. 37 p.

41920905 Siglin, J. (1991) 21-DAy Dermal Toxicity Study in Rabbits with Diethanolamine Salt of 2,4-D DEA: Final Report: Lab Project Num- ber: 3229.1. Unpublished study prepared by Springborn Labs, Inc. 412 p.

41920906 Siglin, J. (1990) Teratology Study in Rats with Diethanolamine Salt of 2,4-D: Final Report: Lab Project Number: 3229.3. Unpublished study prepared by Springborn Labs, Inc. 257 p.

41920907 Ivett, J. (1990) Single Acute Exposure Dose Selection Study on Diethanolamine Salt of 2,4-D: Final Report: Lab Project Number: 12216-0-459- PO. Unpublished study prepared by Hazleton Labs America, Inc. 15 p.

41920908 Ivett, J. (1990) Mutagenicity Test on Diethanolamine Salt of 2,4-D Acid in vivo Mouse Micronucleus Assay: Final Report: Lab Project Number 12216-0-455. Unpublished study prepared by Hazleton Labs America, Inc. 38 p.

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Page 258 of 304 41920909 McKeon, M. (1990) Mutagenicity Test on Diethanolamine Salt of 2,4-D in the In vitro Rat Primary Hepatocyte Unscheduled DNA Synthesis Assay: Final Report: Lab Project Number: HLA 12216-0-447. Un- published study prepared by Hazleton Labs America, Inc. 45 p.

41920910 Lawlor, T.; Holloway, P. (1990) Mutagenicity Test on Diethanolamine Salt of 2,4-D in the Salmonella Mammalian-Microsome Reverse Mu- tation Assay (Ames Test): Final Report: Lab Project Number: HLA 12216-0-401. Unpublished study prepared by Hazleton Labs America, Inc. 51 p.

41920911 Shults, S.; Brock, A.; Killeen, J. (1991) Acute Dermal Toxicity Study in Albino Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number: 90-0162: 3592-90-0162-TX-001. Unpublished study prepared by Ricerca, Inc. 25 p.

41928101 Szabo, J.; Rachunek, B. (1991) 2,4-D, Bu toxyethyl Ester: 13-Week DietaryToxicity Study in Fischer 344 Rats: Lab Project Number: DECO-TXT: K007722-015. Unpublished study prepared by Dow Chem- ical Co. 258 p.

41986601 Jackson, G.; Hardy, C. (1991) Diethanolamine Salt of 2,4-D: Acute Inhalation Toxicity in Rats/4-Hour Exposure: Lab Project Number RIC 15/901290: 90- 0163. Unpublished study prepared by Huntingdon Research Centre Ltd. 26 p.

41986602 Siglin, J. (1991) Range-Finding Teratol ogy Study in Rats with Diethanolamine Salt of 2,4-D: Final Report:Lab Project Number 3229.2. Unpublished study prepared by Springborn Labs, Inc. 136 p.

41991501 Schulze, G. (1991) Subchronic Toxicity Study in Rats with 2,4-Dichlorophenoxyacetic Acid: Lab Project Number: 2184-116. Unpubl- ished study prepared by Hazleton Laboratories America. 529 p.

41994001 Serrone, D.; Killeen, J.; Benz, G. (1991) A Subchronic Toxicity Study in Rats with the Diethanolamine Salt of 2,4-Dichloropheno- xyacetic Acid: Lab Project Number: 3579-90-0186-TX-003. Unpubl- ished study prepared by Ricerca, Inc. 798 p.

42013501 Rodwell, D. (1991) Range Finding Teratology Study in Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number: 3229.12. Un- published study prepared by Springborn Labs, Inc. 134 p.

42015701 Gollapudi, B. (1991) Response to Comments by U.S. EPA: Evaluation of 2,4-DBEE, 2,4-D IPA and 2,4-D TIPA in the Ames Salmonella/ MammalianMicrosome Bacterial Mutagenicity Assay. Unpublished study prepared by The Dow Chemical Co. 10 p.

42015702 Gollapudi, B. (1991) Response to Comments by U. S. EPA: Evaluation of 2,4- Dichlorophenoxyacetic Acid Triisopropanolamine Salt (2,4- D TIPA) in the Mouse Bone Marrow Micronuleus Test: Lab Project Number: TXT:K-008866- 009. Unpublished study prepared by The Dow Chemical Co. 9 p.

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Page 259 of 304 42015703 Gollapudi, B. (1991) Response to Comments by U. S. EPA: Evaluation of 2,4- Dichlorophenoxyacetic Acid Isopropylamine Salt (2,4-D IPA) in the Mouse Bone Marrow Micronuleus Test: Lab Project Num- ber: TXT:M-004725-009. Unpublished study prepared by The Dow Chemical Co. 9 p.

42015704 Gollapudi, B. (1991) Response to Comments by U. S. EPA: Evaluation of 2,4- Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) in the Mouse Bone Marrow Micronuleus Test: Lab Project Number: TXT:K-007722-012. Unpublished study prepared by The Dow Chemi- cal Co. 9 p.

42015705 Gollapudi, B. (1991) Response to Comments by U. S. EPA: Evaluation of 2,4- Dichlorophenoxyacetic Acid Triisopropanolamine Salt (2,4- D TIPA) in the Mouse Bone Marrow Micronuleus Test: Lab Project Number: TXT:K-008866- 008. Unpublished study prepared by The Dow Chemical Co. 30 p.

42015706 Gollapudi, B. (1991) Response to Comments by U.S. EPA: Evaluation of 2,4- Dichlorophenoxyacetic Acid Isopropylamine Salt (2,4-D IPA) in the Mouse Bone Marrow Micronuleus Test: Lab Project Num- ber: TXT:M-004725-008. Unpublished study prepared by The Dow Chemical Co. 30 p.

42015707 Gollapudi, B. (1991) Response to Comments by U.S. EPA: Evaluation of 2,4- Dichlorophenoxyacetic Acid Butoxyethyl Ester (2,4-D BEE) in the Mouse Bone Marrow Micronuleus Test: Lab Project Number: TXT:K-007722-013. Unpublished study prepared by The Dow Chemi- cal Co. 30 p.

42021401 Yano, B.; Cosse, P.; Corley, R. (1991) 2,4-D Isopropylamine Salt (2,4-D IPA): A 13-Week Dietary Toxicity Study in Fischer 344 Rats: Lab Project Number: HET M-004725-006. Unpublished study prepared by The Dow Chemical Co. 321 p.

42021402 Yano, B.; Cosse, P.; Markham, D. (1991) 2,4-D Triisopropylamine Salt (2,4-D TIPA): A 13-Week Dietary Toxicity Study in Fischer 344 Rats: Lab Project Number: K-008866-006. Unpublished study prepared by The Dow Chemical Co. 322 p.

42055501 Rodwell, D. (1991) Teratology Study in Rabbits with Diethanolamine Salt of 2,4-D: Final Report: Lab Project Number: 3229.13. Unpu- blished study prepared by Springborn Labs, Inc. 228 p.

42158701 Liberacki, A.; Breslin, W.; Yano, B. (1991) Triisopropanolam- ine Salt of 2,4-D: Oral Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project Number: K-008866-014. Un- published study prepared by Dow Chemical Co. 78 p.

42158702 Liberacki, A.; Breslin, W.; Yano, B. (1991) Isopropylamine Salt of 2,4-D: Oral Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project Number: M-004725-012. Unpublished study prepared by Dow Chemical Co. 74

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Page 260 of 304 42158703 Breslin, W.; Zablotny, C.; Yano, B. ( 1991) 2,4-D 2-Butoxyethyl Ester: Oral Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project Number: K-007722-020. Unpublished study prepared by Dow Chemical Co. 93

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42158704 Breslin, W.; Liberacki, A.; Yano, B. (1991) Isopropylamine Salt of 2,4-D: Oral Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project Number: M-004725-013. Unpublished study prepared by Dow Chemical Co. 270 p.

42158705 Breslin, W.; Liberacki, A.; Yano, B. (1991) Triisopropanolamine Salt of 2,4-D: Oral Gavage Teratology Probe Study in New Zeal- and White Rabbits: Lab Project Number: K-008866-016. Unpubli- shed study prepared by Dow Chemical Co. 253 p.

42158706 Zablotny, C.; Yano, B.; Breslin, W. ( 1991) 2,4-D 2-Butoxyethyl Ester: Oral Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project Number: K-007722-021. Unpublished study prepared by Dow Chemical Co. 320 p.

42220301 Dryzga, M.; Bormett, G.; Nolan, R. (1992) 2,4-Dichlorophenoxyacetate, Triisopropanolamine Salt: Dissociation and Metabolism in Male Fischer 344 Rats: Lab Project Number: K-008866-013. Unpublished study prepared by Dow Chemical Co., Tox Res. Lab. 41 p.

42224001 Martin, T. (1991) Developmental Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-D Dimethylamine Salt (2,4-D-DMA) Administered Orally via Stomach Tube to New Zealand White Rabbits: Lab Project Number: 320-004. Unpublished study prepared by Argus Research Labs., Inc. 502 p.

42232701 Berdasco, N. (1992) 2,4-Dichlorophenoxyacetic Acid: Primary Dermal Irritation Study in New Zealand White Rabbits: Lab Project Number: K-002372-060. Unpublished study prepared by Dow Chemical Co. 14 p.

42261801 Dryzga, M.; Brzak, K.; Nolan, R. (1992) 2,4-Dichlorophenoxyacetate 2-Ethylhexyl Ester: Metabolism in Fischer 344 Rats: Lab Project Number: K020054-009. Unpublished study prepared by The Dow Chemical Co. 47 p.

42304601 Martin, T. (1992) Developmental Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-D 2- Ethylhexyl Ester (2,4-D Isooctyl Ester) Administered Orally Via Gavage to Crl:CD BR VAF/Plus Presumed Pregnant Rats: Lab Project Number: 320-005. Unpublished study prepared by Argus Research Laboratories, Inc. 469 p.

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Page 261 of 304 42304602 Martin, T. (1992) Dosage-Range Developmental Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-D 2-Ethylhexyl Ester (2,4-D Isooctyl Ester) Administered Orally Via Gavage to Crl:CD BR VAF/Plus Presumed Pregnant Rats: Lab Project Number: 320-005P. Unpublished study prepared by Argus Research Laboratories, Inc. 111 p.

42304603 Martin, T. (1992) Developmental Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-D 2- Ethylhexyl Ester (2,4-D Isooctyl Ester) Administered Orally (Stomach Tube) to New Zealand White Rabbits: Lab Project Number: 320-006. Unpublished study prepared by Argus Research Laboratories, Inc. 503 p.

42304604 Martin, T. (1992) Dose-Range Developmental Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-D 2-Ethylhexyl Ester (2,4-D Isooctyl Ester) Administered Orally (Stomach Tube) to New Zealand White Rabbits: Lab Project Number: 320-006P. Unpublished study prepared by Argus Research Laboratories, Inc. 112 p.

42579701 Dryzga, M.; Bormett, G.; Stewart, H.; et al. (1992) 2,4-Dichlorophenoxyacetate, Butoxyethyl Ester: Hydrolysis In vitro and In vivo in Fischer 344 Rats: Lab Project Number: K-007722-018. Unpublished study prepared by The Dow Chemical Co. 59 p.

42605202 Cieszlak, F. (1992) 2,4-Dichlorophenoxyace tic Acid, 2-Ethylhexyl Ester: Acute Aerosol Inhalation Toxicity Study with Fischer 344 Rats: Lab Project Number: K-020054-015. Unpublished study prepared by Dow Chemical Co. 37 p.

42780001 Dalgard, D. (1993) 13-Week Dietary T oxicity Study of 2,4-D in Dogs: Final Report: Lab Project Number: HWA 2184-125. Unpublished study prepared by Hazleton Washington, Inc. 302 p.

42780002 Dalgard, D. (1993) 13-Week Dietary Toxicity Study with the Dimethylamine Salt of 2,4-D in Dogs: Final Report: Lab Project Number: HWA 2184-126. Unpublished study prepared by Hazleton Washington, Inc. 267 p.

42780003 Dalgard, D. (1993) 13-Week Dietary Toxi city Study with the 2-Ethylhexyl Ester of 2,4-D in Dogs: Final Report: Lab Project Number: HWA 2184-127. Unpublished study prepared by Hazleton Washington, Inc. 271 p.

42780004 Dalgard, D. (1992) 4-Week Explorator y Rangefinding Study in Dogs with 2,4- D: Final Report: Lab Project Number: HWA 2184-121. Unpublished study prepared by Hazleton Washington, Inc. 85 p.

42780005 Dalgard, D. (1992) 4-Week Explorator y Rangefinding Study in Dogs with 2- Ethylhexyl Ester of 2,4-D: Final Re port: Lab Project Number: HWA 2184-122. Unpublished study prepared by Hazleton Washington, Inc. 99 p.

42780006 Dalgard, D. (1992) 4-Week Explorator y Rangefinding Study in Dogs with the Dimethylamine Salt of 2,4-D: Final Report: Lab Project Number: HWA 2184- 123. Unpublished study prepared by Hazleton Washington, Inc. 98 p.

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Page 262 of 304 42865301 Dryzga, M.; Freshour, N.; Nolan, R. (1993) 2,4-Dichlorophenoxy- acetate, Isopropylamine Salt: Dissociation and Metabolism in Male Fischer 344 Rats: Lab Project Number: M-004725-014. Unpub- lished study prepared by The Toxicology Research Lab., Dow Chemical Co. 64 p.

43049001 Dalgard, D. (1993) 52-Week Dietary Toxicity Study with 2,4-D in Dogs: Final Report: Lab Project Number: HWA 2184-124: 2184124. Unpublished study prepared by Hazleton Washington, Inc. 447 p.

43115201 Mattsson, J.; McGuirk, R.; Yano, B. (1994) 2,4-Dichlorophenoxyacetic Acid (2,4-D): Acute Neurotoxicity Study in Fischer 344 Rats: Lab Project Number: K-002372-066. Unpublished study prepared by The Dow Chemical Co. 451 p.

43327301 Linscombe, V.; Lick, S. (1994) Evaluation of 2,4-D Triisopropanolamine Salt in an In vitro Chromosomal Aberration Assay Utilizing Rat Lymphocytes: Amended Final Report: Lab Project Number: K-008866-017: 10233. Unpublished study prepared by Dow Chemical Co. 46 p.

43327302 Linscombe, V.; Lick, S. (1994) Evaluation of 2,4-D Triisopropanolamine Salt in the Chinese Hamster Ovary Cell/Hypoxanthine-Guanine-Phosphoribosyl Transferase (CHO/HGPRT) Forward Mutation Assay: Amended Final Report: Lab Project Number: K-008866-018: 10233. Unpublished study prepared by Dow Chemical Co. 43 p.

43327303 Linscombe, V.; Lick, S. (1994) Evaluation of 2,4-Dichlorophenoxyacetic Acid Isopropylamine Salt in an In vitro Chromosomal Aberration Assay Utilizing Rat Lymphocytes: Lab Project Number: M-004725-016: 10233. Unpublished study prepared by Dow Chemical Co. 45 p.

43327304 Linscombe, V.; Lick, S. (1994) Evaluation of 2,4-Dichlorophenoxyacetic AcidIsopropylamine Salt in the Chinese Hamster Ovary Cell/HypoxanthineGuanine-Phosphoribosyl Transferase (CHO/HGPRT) Forward Mutation Assay: Lab Project Number: M-004725-017: 10233. Unpublished study prepared by Dow Chemical Co. 43 p.

43327305 Linscombe, V.; Lick, S. (1994) Evaluation of the 2,4-Dichlorophenoxyacetic Acid Butoxyethyl Ester in an In vitro Chromosomal Aberration Assay Utilizing Rat Lymphocytes: Lab Project Number: K-007722-022: 10233. Unpublished study prepared by Dow Chemical Co. 45 p.

43394201 Linscombe, V.; Lick, S. (1994) Evaluation of 2,4-Dichlorophenoxyacetic AcidButoxyethyl Ester in the Chinese Hamster Ovary Cell/Hypoxanthine-GuaninePhosphoribosyl Transferase (CHO/HGP RT) Forward Mutation Assay: Lab Project Number: K-007722-023. Unpublished study prepared by Dow Chemical Co. 44 p.

43515501 Tompkins, E. (1994) A 90-Day Oral (Capsule) Toxicity Study of 2,4-D Isopropyl Ester in Dogs: Final Report: Lab Project Number: WIL-233001. Unpublished study prepared by WIL Research Labs, Inc. 572 p.

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Page 263 of 304 43515901 Tompkins, E. (1995) A 90-Day Dietar y Subchronic Toxicity Study of 2,4-D Isopropyl Ester in Rats: Final Report: Lab Project Numbers: WIL-233002. Unpublished study prepared by WIL Research Labs, Inc. 597 p.

43523001 Nemec, M. (1994) A Dose Range-findi ng Developmental Toxicity Study of 2,4- D Isopropyl Ester in Rats: Final Report: Lab Project Number: WIL-233003. Unpublished study prepared by WIL Research Labs, Inc. 279 p.

43523101 Nemec, M. (1995) A Developmental Toxicity Study of 2,4-D Isopropyl Ester in Rats: Final Report: Lab Project Number: WIL/233004. Unpublished study prepared by WIL Research Labs., Inc. 321 p.

43597201 Stott, W.; Johnson, K.; Gilbert, K.; et al. (1995) 2,4-Dichlorophenoxyacetic Acid: Dietary Oncogenicity Study in B6C3F1 Mice--Two Year Final Report: Lab Project No. K-002372- 063F. Unpublished study prepared by the Dow Chemical Co. 724 p.

43612001 Jeffries, T.; Yano, B.; Ormand, J. et al. (1995) 2,4-Dichlorophenoxyacetic Acid: Chronic Toxicity/Oncogenicity Study in Fischer 344 Rats: Final Report: Lab Project Number: K/002372/064. Unpublished study prepared by The Dow Chemical Co., Health and Environmental Sciences. 2020 p.

43879801 Stott, W.; Johnson, K.; Gilbert, K.; et al. (1995) 2,4-Dichlorophenoxyacetic Acid: Dietary Oncogenicity Study in Male B6C3F1 Mice--Two Year Final Report: Lab Project Number: K-002372-063M: 33475: 913. Unpublished study prepared by Dow Chemical Co. 704 p.

43930501 Ham, A. (1996) Genotoxicity Test on Isopropyl Ester of 2,4-DichloroPhenoxyacetic Acid in the Assay for Unscheduled DNA Synthesis in Rat Liver Primary Cell Cultures: Lab Project Number: 16692-0-447: 2731-100: 615. Unpublished study prepared by Corning Hazleton (CHV). 39 p.

43930801 Murli, H. (1996) Mutagenicity Test on Isopropyl Ester of 2,4-Dichloro Phenoxy Acetic Acid in an in vivo Mouse Micronucleus Assay: Lab Project Number: 16692-0-455: 616. Unpublished study prepared by Hazleton Washington, Inc. 40 p.

43935101 Lawlor, T. (1996) Mutagenicity Test on Isopropyl Ester of 2,4-Dichlorophenoxy Acetic Acid in the Salmonella/Mammalian-Microsome Reverse Mutation Assay: (Ames Test): Final Report: Lab Project Number: 16692-0-401. Unpublished study prepared by Corning Hazleton Inc. 46 p.

44284501 Yano, B. (1997) 2,4-Dichlorophenoxyacetic Acid: Chronic Toxicity/Oncogenicity Study in Fischer 344 Rats: Supplemental Histopathology--Brains from Low- and Mid-Dose Level Rats Sacrificed for the 2-Year Necropsy: Revised (Final Report): Lab Project Number: K-002372- 064FR: K-002372-064. Unpublished study prepared by The Dow Chemical Co. 14 p.

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Page 264 of 304 44725303 Cieszlak, F.; Brooks, K. (1998) Esteron 6E: Acute Primary Eye Irritation Study in New Zealand White Rabbits: Lab Project Number: 971165. Unpublished study prepared by The Dow Chemical Company. 16 p.

45761201 Garabrant, D.; Philbert, M. (2002) Review of 2,4-Dichlorophenoxyacetic Acid (2,4-D) Epidemiology and Toxicology. Cr itical Reviews in Toxicology 32(4):
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45761204 Charles, J.; Hanley, T.; Wilson, R.; et al. (2001) Developmental Toxicity Studies in Rats and Rabbits on 2,4-Dichlorophenoxyacetic Acid and Its Forms. Toxicological Sciences 60:121-131.

45761208 Charles, J.; Cunny, H.; Wilson, R.; et al. (1999) Ames Assays and Unscheduled DNA Synthesis Assays on 2,4-Dichlorophenoxyacetic Acid and Its Derivatives. Mutation Research 444:207-216.

45761209 Charles, J.; Cunny, H.; Wilson, R.; et al. (1999) In Vivo Micronucleus Assays on 2,4-Dichlorophenoxyacetic Acid and Its Derivatives. Mutation Research
444:227-234.

45761210 Gollapudi, B.; Charles, J.; Linscombe, V.; et al. (1999) Evaluation of the Genotoxicity of 2,4-Dichlorophenoxyacetic Acid And Its Derivatives in Mammalian Cell Cultures. Mutation Research 444:217-225.

45761211 Mattsson, J.; Charles, J.; Yano, B.; et al. (1997) Single-Dose and Chronic Dietary Neurotoxicity Screening Studi es on 2,4-Dichlorophenoxyacetic Acid in Rats. Fundamental and Applied Toxicology 40:111-119.

45761213 Charles, J.; Cunny, H.; Wilson, R.; et al. (1996) Comparative Subchronic Studies on 2,4-Dichlorophenoxyacetic Acid, Amine and Ester in Rats. Fundamental and Applied Toxicology 33:161-165.

45761214 Charles, J.; Bond, D.; Jeffries, T.; et al. (1996) Chronic Dietary Toxicity/Oncogenicity Studies on 2,4-Dichlorophenoxyacetic Acid in Rodents. Fundamental and Applied Toxicology 33:166-172.

45761215 Charles, J.; Dalgard, D.; Cunny, H.; et al. (1996) Comparative Subchronic and Chronic Dietary Toxicity Studies on 2,4-Dichlorophenoxyacetic Acid, Amine, and Ester in the Dog. Fundamental and Applied Toxicology 29:78-85.

45840901 Hardwick, T. (2002) The Pharmacokinetics of (Carbon-14)-2,4-D in the Rat and Dog: Lab Project Number: 1149/40: 1149/40-D1145. Unpublished study prepared by Covance Laboratories Ltd. 364 p. {OPPTS 870.7485}

45897102 Hardwick, T. (2003) (Carbon 14)-2,4-D: Metabolite Identification in the Rat and Dog: Final Report: Lab Project Number: 1149/042: 1149/042-D1145. Unpublished study prepared by Covance Laboratories Ltd. 74 p. {OPPTS 870.7485}

Occupational and Residential MRID References

### 2,4-D Bibliography

Page 265 of 304 44972201 Klonne, D. (1999) Integrated Report for Evaluation of Potential Exposures to Homeowners and Professional Lawn Care Operators Mixing, Loading, and Applying Granular and Liquid Pesticides to Residential Lawns: Lab Project Number: OMAOO5: OMAOO1: OMAOO2. Unpublished study prepared by Ricerca, Inc., and Morse Laboratories. 2213 p.

44655701 Wilson, R. (1998) Comparison of Transferable Turf Residues from the Application of Various Forms of Phenoxy Herbicides and the Effects from the Application of Various Spray Volumes Per Acre: Lab Project Number: RDW98-0903. Unpublished study prepared by Broadleaf Turf Herbicide TFR Task Force LLC. 40 p. {OPPTS 875.2100}

44655704 Hughes, D.; Read, S. (1998) Validation of a Method for the Determination of 2,4-D 2-EHE (2,4-dichlorophenoxyacetic acid 2-ethylhexyl ester); 2,4-DP 2- EHE ?2-(2,4-dichlorophenoxy) propionic acid 2-ethylhexyl ester|; MCPA 2- EHE (4-chloro-2-methylphenoxyacetic acid 2-ethylhexyl ester); 2,4-D (2,4- dichlorophenoxyacetic acid), MCPP ?(RS)-2-(4-chloro-methylphenoxy) propionic acid|, and Dicamba (3,6-dichloro-2-methoxybenzoic acid)(In Combination); and MCPA (4-chloro-2-methylphenoxyacetic acid), MCPP ?(RS)-2-(4-chloro-2-methylphenoxy) pr opionic acid|, and 2,4-DP ?(RS)-2-(2,4- dichlorophenoxy) propionic acid| (In Comb ination on Percale Cloth: Lab Project Number: 6926-102. Unpublished study prepared by Covance Laboratories. 236

p.

44655703 Barney, W. (1998) Determination of Transferable Turf Residues on Turf Treated with 2,4-D DMA + MCPP-p DMA + Dicamba DMA in Various Spray Volumes: Lab Project Number: 98-314: 6956-104: BTH TFR TF 002. Unpublished study prepared by Grayson Research, LCC. and Covance Laboratories Inc. 235 p. {OPPTS 875.2100}

45033101 Hughes, D.; Bomkamp, D. (2000) Determination of Transferable Turf Residues on Turf Treated with 2,4-D, MCPA DMA, 2,4-D DMA + MCPP-p DMA + Dicamba DMA and MCPA DMA + MCPP-p DMA + 2,4-DP-p DMA: Lab Project Number: BTH TFR TF 003: 6926-105. Unpublished study prepared by Covance Laboratories. 394 p. {OPPTS 875.2100}

44459801 Merricks, D. (1997) Carbaryl Mixer/ Loader/Applicator Exposure Study During Application of RP-2 Liquid (21%), Sevin Ready to Use Insect Spray or Sevin 10 Dust to Home Garden Vegetables: Lab Project Number: 1519: 10564: ML97- 0676-RHP. Unpublished study prepared by Agrisearch Inc., Rhone-Poulenc Ag Co. and Morse Labs., Inc. 358 p.

Hazard Identification MRID References

46147201 Hammond, L. (2003) Error Review of 2,4-D-Report of the Hazard Identification Assessment Review Committee. Project Number: 0051866. Unpublished study prepared by Industry Task Force II on 2,4-D Research Data. 5 p

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Page 266 of 304 43115201 Mattsson, J.; McGuirk, R.; Yano, B. (1994) 2,4-Dichlorophenoxyacetic Acid (2,4-D): Acute Neurotoxicity Study in Fischer 344 Rats: Lab Project Number: K-002372-066. Unpublished study prepared by The Dow Chemical Co. 451 p.

43293901 Mattsson, J.; Jeffries, T.; Yano, B. (1994) 2,4-Dichlorophenoxyacetic Acid:Chronic Neurotoxicity Study in Fischer 344 Rats: Lab Project Number: K002372-064N: K-002372-064. Unpublished study prepared by The Dow Chemical Co. 1091 p.

41527101 Schroeder, R. (1990) A Teratogenicity St udy in Rats with 2-Butoxy- ethyl Ester of 2,4-D: Lab Project Number: HET K-007722-017: 89- 34677. Unpublished study prepared by Bio/dynamics, Inc. 452 p.

41920906 Siglin, J. (1990) Teratology Study in Rats with Diethanolamine Salt of 2,4-D: Final Report: Lab Project Number: 3229.3. Unpublished study prepared by Springborn Labs, Inc. 257 p.

41735201 Lochry, E. (1990) Developmental Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-Dimethylamine Salt (2,4-D- DMA Administered Orally via Gavage to CRL: CD BR VAF/Plus Pre- sumed Pregnant Rats: Final Report: Lab Project Number: 320-001. Unpublished study prepared by Argus Research Labs. 436 p.

42304601 Martin, T. (1992) Developmental Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-D 2- Ethylhexyl Ester (2,4-D Isooctyl Ester) Administered Orally Via Gavage to Crl:CD BR VAF/Plus Presumed Pregnant Rats: Lab Project Number: 320-005. Unpublished study prepared by Argus Research Laboratories, Inc. 469 p.

41527103 Schroeder, R. (1990) A Teratogenicity Study in Rats with 2,4-D Isopropylamine Salt: Lab Project Number: HET K-004725-011: 89-3465. Unpublished study prepared by Bio/dynamics, Inc. 441 p.

41527102 Schroeder, R. (1990) A Teratogenicity Study in Rats with 2,4-D Triisopropanolamine: Lab Project Number: HET K0008866-012: 89-3463. Unpublished study prepared by Bio/dynamics, Inc. 478 p.

41747601 Hoberman, A. (1990) Development Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-Dichlorophenoxyacetic Acid (2,4-D Acid) Administered Orally via Stomach Tube to New Zealand White Rabbits: Lab Project Number: 320-003. Unpublished study prepared by Argus Research Laboratories, Inc. 478 p.

42055501 Rodwell, D. (1991) Teratology Study in Rabbits with Diethanolamine Salt of 2,4-D: Final Report: Lab Project Number: 3229.13. Unpu- blished study prepared by Springborn Labs, Inc. 228 p.

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Page 267 of 304 42224001 Martin, T. (1991) Developmental Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-D Dimethylamine Salt (2,4-D-DMA) Administered Orally via Stomach Tube to New Zealand White Rabbits: Lab Project Number: 320-004. Unpublished study prepared by Argus Research Labs., Inc. 502 p.

42304603 Martin, T. (1992) Developmental Toxicity (Embryo-Fetal Toxicity and Teratogenic Potential) Study of 2,4-D 2- Ethylhexyl Ester (2,4-D Isooctyl Ester) Administered Orally (Stomach Tube) to New Zealand White Rabbits: Lab Project Number: 320-006. Unpublished study prepared by Argus Research Laboratories, Inc. 503 p.

42158704 Breslin, W.; Liberacki, A.; Yano, B. (1991) Isopropylamine Salt of 2,4-D: Oral Gavage Teratology Probe Study in New Zealand White Rabbits: Lab Project Number: M-004725-013. Unpublished study prepared by Dow Chemical Co. 270 p.

42158705 Breslin, W.; Liberacki, A.; Yano, B. (1991) Triisopropanolamine Salt of 2,4-D: Oral Gavage Teratology Probe Study in New Zeal- and White Rabbits: Lab Project Number: K-008866-016. Unpubli- shed study prepared by Dow Chemical Co. 253 p.

43225201 Biever, R. (1994) (Carbon 14)-Acrolein (Magnacide H): Nature and Magnitude of Residues Study Using Freshwater Fi sh and Shellfish: Final Report: Lab Project Number: 93-3-4701: 12167-0691-6102-145. Unpublished study prepared by Springborn Labs., Inc. 389 p.

43612001 Jeffries, T.; Yano, B.; Ormand, J. et al. (1995) 2,4-Dichlorophenoxyacetic Acid: Chronic Toxicity/Oncogenicity Study in Fischer 344 Rats: Final Report: Lab Project Number: K/002372/064. Unpublished study prepared by The Dow Chemical Co., Health and Environmental Sciences. 2020 p.

41991501 Schulze, G. (1991) Subchronic Toxicity Study in Rats with 2,4-Dichlorophenoxyacetic Acid: Lab Project Number: 2184-116. Unpubl- ished study prepared by Hazleton Laboratories America. 529 p.

43049001 Dalgard, D. (1993) 52-Week Dietary Toxicity Study with 2,4-D in Dogs: Final Report: Lab Project Number: HWA 2184-124: 2184124. Unpublished study prepared by Hazleton Washington, Inc. 447 p.

43879801 Stott, W.; Johnson, K.; Gilbert, K.; et al. (1995) 2,4-Dichlorophenoxyacetic Acid: Dietary Oncogenicity Study in Male B6C3F1 Mice--Two Year Final Report: Lab Project Number: K-002372-063M: 33475: 913. Unpublished study prepared by Dow Chemical Co. 704 p.

43597201 Stott, W.; Johnson, K.; Gilbert, K.; et al. (1995) 2,4-Dichlorophenoxyacetic Acid: Dietary Oncogenicity Study in B6C3F1 Mice--Two Year Final Report: Lab Project No. K-002372- 063F. Unpublished study prepared by the Dow Chemical Co. 724 p.

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Page 268 of 304 00101605 Johnson, D.; Myer, J.; Moxon, P.; et al. (1981) Determination of Acute Oral LD50 in Fischer 344 Rats: 2,4-Dichlorophenoxyacetic Acid, Technical: 490- 001. Rev. (Unpublished study received Dec 21, 1981 under unknown admin. no.; prepared by International Research and Development Corp., submitted by Dow Chemical U.S.A., Midland, MI; CDL:247499-C)

00101596 Mayhew, D.; Johnson, Y.; Kingery, A. (1981) Acute Dermal Toxicity Study in Albino Rabbits with ITF-5; 2, 4-Dichlorophenoxyacetic Acid, Sodium Salt: Project No. WIL-81233. (Unpublished study received Jul 23, 1981 under unknown admin. no.; prepared by WIL Research Laboratories, Inc., submitted by Dow Chemical U.S.A., Midland, MI; CDL:247496-F)

00161660 Auletta, C.; Daly, I. (1986) An Acute Inhalation Toxicity Study of 2,4- Dichlorophenoxyacetic Acid in the Rat: Final Report: Proj- ect No. 86-7893. Unpublished study prepared by Bio/dynamics Inc. 39 p.

41125302 Kirsch, P. (1983) Report on the Study of the Irritation to the Eye of the White Rabbit Based on Draize of 2,4-D: Doc. No. BASF: 83/ 0192. Unpublished study prepared by BASF Aktiengesellschaft. 10 p.

42232701 Berdasco, N. (1992) 2,4-Dichlorophenoxyacetic Acid: Primary Dermal Irritation Study in New Zealand White Rabbits: Lab Project Number: K-002372-060. Unpublished study prepared by Dow Chemical Co. 14 p.

00161659 Gargus, J. (1986) Dermal Sensitization Study in Guinea Pigs: 2,4- Dichlorophenoxyacetic Acid: Final Report: Project No. 2184-105. Unpublished study prepared by Hazleton Laboratories, Inc. 10 p.

41920901 Shults, S.; Brock, A.; Killeen, J. (1990) Acute Oral Toxicity (LD50) Study in Rats with Diethanolamine Salt of 2,4- D: Lab Pro- ject Number:90-0161: 3592- 90-0161-TX-001. Unpublished study prepared by Ricerca, Inc. 37 p.

41642801 Robbins, G. (1989) Acute Oral Toxic ity Study in Rats: Dri-D Amine: Lab Project Number: A2013. Unpublished study prepared by Cosmo- politan Safety Evaluation, Inc. (C.S.E.) 36 p.

41413501 Berdasco, N.; Schuetz, D.; Jersey, G. et al. (1989) 2,4-Dichloro- phenoxyacetic Acid Triisopropanolamine Salt: Acute Oral Toxicity Study in Fischer 344 Rats: Lab Project Number: K-008866-002A. Unpublished study prepared by The Dow Chemical Co. 33 p.

40629801 Jeffrey, M.; Battjes, J.; Lomax. L. (1987) 2,4-D Butoxyethyl Ester, Technical: Acute Oral Toxicity Study in Fisc her 344 Rats: Lab. Proj. ID K-007722-006A. Unpublished study prepared by Dow Chemical Co. 30 p.

41209001 Mahlburg, W. (1988) Acute Oral Toxic ity Study of DPD Ester in SpragueDawley Rats: Project ID: 88.3505.002; Study No. 89-19A. Unpublished study prepared by Food & Drug Research Laboratories. 95 p.

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Page 269 of 304 41920911 Shults, S.; Brock, A.; Killeen, J. (1991) Acute Dermal Toxicity Study in Albino Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number: 90-0162: 3592-90-0162-TX-001. Unpublished study prepared by Ricerca, Inc. 25 p.

41413502 Berdasco, N.; Schuetz, B.; Yano, B. et al. (1989) 2,4-Dichlorophe- noxyacetic Acid Triisopropanolamine Salt: Acute Dermal Toxicity Study in New Zealand White Rabbits: Lab Project Number: K-008866 -002D. Unpublished study prepared by The Dow Chemical Co. 19 p.

40629802 Jeffrey, M.; Battjes, J.; Zimmer, M. ( 1987) 2,4-D Butoxyethyl Ester Technical:Acute Dermal Toxicity Study in New Zealand White Rab- bits: Lab. Proj. ID K007722-006D. Unpublished study prepared by Dow Chemical Co. 27 p.

41209002 Mahlburg, W. (1988) Acute Dermal Toxicity Study of DPD Ester in New Zealand White Rabbits: Project ID: 88.3505.003; Study No. 89-19A. Unpublished study prepared by Food & Drug Research Laboratories. 39 p.

41986601 Jackson, G.; Hardy, C. (1991) Diethanolamine Salt of 2,4-D: Acute Inhalation Toxicity in Rats/4-Hour Exposure: Lab Project Number RIC 15/901290: 90- 0163. Unpublished study prepared by Huntingdon Research Centre Ltd. 26 p.

40085501 Heydens, W. (1986) Acute Toxicity of Landmaster II Administered by Inhalation to Male and Female Sprage-Dawley Rats: Monsanto Refe- rence No. EHL 86125. Unpublished study prepared by Monsanto Co., Environmental Health Laboratory. 45 p.

41957601 Nitschke, K.; Stebbins, K. (1991) 2,4-D TIPA: Acute Inhalation Tox- icity Study with Fischer 344 Rats: Lab Project Number: K-008866- 015. Unpublished study prepared by Dow Chemical Co. 33 p.

40629803 Streeter, C.; Battjes, J.; Yano, B. (1987) 2,4-D Butoxyethyl Ester, Technical: An Acute Aerosol Inhalation Study in Fischer 344 Rats: Lab. Proj. ID K-007722- 007. Unpublished study prepared by Dow Chemical Co. 22 p.

42605202 Cieszlak, F. (1992) 2,4-Dichlorophenoxyace tic Acid, 2-Ethylhexyl Ester: Acute Aerosol Inhalation Toxicity Study with Fischer 344 Rats: Lab Project Number: K-020054-015. Unpublished study prepared by Dow Chemical Co. 37 p.

41920902 Shults, S.; Brock,A.; Killeen, J. (1990) Primary Eye Irritation Study in Albino Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number 90-0164: 3592- 90-0164-TX-001. Unpublished study prepared by Ricerca, Inc. 30 p.

41642803 Robbins, G. (1989) Primary Eye Irritation Study in Rabbits: Dri-D Amine: Lab Project Number: D2013. Unpublished study prepared by Cosmopolitan Safety Evaluation, Inc. (C.S.E.) 19 p.

41920902 Shults, S.; Brock,A.; Killeen, J. (1990) Primary Eye Irritation Study in Albino Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number 90-0164: 3592- 90-0164-TX-001. Unpublished study prepared by Ricerca, Inc. 30 p.

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Page 270 of 304 41413504 Berdasco, N.; Mizell, M. (1989) 2,4-Dichorophenoxyacetic Acid Triisopropanolamine Salt: Primary Eye Irritation Study in New Zea- land White Rabbits: Lab Project Number: K-008866-002C. Unpub- lished study prepared by The Dow Chmemical Co. 14 p.

41125302 Kirsch, P. (1983) Report on the Study of the Irritation to the Eye of the White Rabbit Based on Draize of 2,4-D: Doc. No. BASF: 83/ 0192. Unpublished study prepared by BASF Aktiengesellschaft. 10 p.

41920903 Shults, S.; Brock, A.; Killeen, J. (1990) Primary Dermal Irritation Study in Albino Rabbits with Diethanolamine Salt of 2,4-D: Lab Project Number: 90- 0165: 3592-90-0165-TX-001. Unpublished study prepared by Ricerca, Inc. 18 p.

41642804 Robbins, G. (1989) Primary Dermal Irritation Study in Rabbits: Dri- D Amine: Lab Project Number: E2013. Unpublished study prepared by Cosmopolitan Safety Evaluation, Inc. 14 p.

41413505 Mizell, M. (1989) 2,4-Dichlorophenoxyacetic Acid, Triisopropanol- amine Salt: Primary Dermal Irritation Study in New Zealand White Rabbits: Lab Project Number: K-008866-002B. Unpublished study prepared by The Dow Chemical Co. 13 p.

40629805 Jeffrey, M. (1987) 2,4-D Butoxyethyl Ester, Technical: Primary Der- mal Irritation Study in New Zealand White Rabbits: Lab. Proj. ID K-007722-006B. Unpublished study prepared by Dow Chemical Co. 10 p.

41920904 Shults, S.; Brock, A.; Killeen, J. (1990) Dermal Sensitization Study (Closed Patch Repeated Insult) in Guinea Pigs with Di- ethanolamine Salt of 2,4-D: Lab Project Number: 90-0166: 3592- 90-0166-TX-001. Unpublished study prepared by Ricerca, Inc. 37 p.

41642805 Robbins, G. (1989) Guinea Pig Sensitiz ation Study (Buehler): Dri-D Amine: Lab Project Number: F2013. Unpublished study prepared by Cosmopolitan Safety Evaluation, Inc. (C.S.E.) 17 p.

41413506 Berdasco, N. (1989) 2,4-Dichlorophenoxyacetic Acid Triisopropanol- amine Salt: Dermal Sensitization Potential in the Hartley Albino Guinea Pig: Lab Project Number: K-008866-002E. Unpublished study prepared by The Dow Chemical Co. 14 p.

40629806 Jeffrey, M. (1986) Butoxy Ethyl 2,4-Dichlorophenoxyacetate: DermalSensitization Potential in the Hartley Albino Guinea Pig: Lab. Proj. ID K007722-005. Unpublished study prepared by Dow Chemi- cal Co. 10 p.

41233701 Carreon, R.; Wall, J. (1984) XRM-4725 Herbicide Formulation: Dermal Sensitization Potential in the Guinea Pig: Project Study ID: HET M-004725- 003. Unpublished study prepared by Dow Chemical U.S.A. 11 p.

Environmental Fate and Effects MRID References

### 2,4-D Bibliography

Page 271 of 304 42059601 Doyle, R. (1991) Laboratory Volatility of the 2-Ethylhexyl Ester of 2,4- Dichloro-phenoxyacetic Acid: Lab Project Number: T08037T601. Unpublished study prepared by IIT Research Institute. 257 p.

42749702 Concha, M.; Shepler, K. (1993) Photodegradation of (carbon 14)2,4-D 2- Ethylhexyl Ester in a Buffered Aqueous Solution at pH 5 by Natural Sunlight: Lab Project Number: 390W-1: 390W. Unpublished study prepared by PTRL West, Inc. 104 p.

42735401 Concha, M.; Shepler, K.; Erhardt-Zabik, S. (1993) Hydrolysis of (carbon 14)2,4- D Ethylhexyl ester at pH 5, 7, and 9: Lab Project Number: 387W-1: 387W. Unpublished study prepared by PTRL-West, Inc. 95 p.

43914701 Hatfield, M. (1995) Field Soil Dissipati on of the 2-Ethylhexyl Ester of 2,4-D in Bare Ground in California: Final Report: Lab Project Number: AA940021: RES94006: HWI 6397-144. Unpublished study prepared by American Agricultural Services, Inc.; Agvise Labs and Hazleton Wisconsin, Inc. 584 p.

43762402 Hatfield, M. (1995) Field Soil Dissipati on of the 2-Ethylhexyl Ester of 2,4-D in Turf in California: Final Report: Lab Project Number: AA940019: 6397-142: HWI 6397-142. Unpublished study prepared by American Agricultural Services, Inc.; Agvise Labs; and Hazleton Wisconsin, Inc. 614 p.

43705201 Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D on Turf in California: Final Report: Lab Project Number: AA940018: 6397-141: RES94003. Unpublished study prepared by American Agricultural Services, Inc.; Agvise, Inc.; and Hazleton Wisconsin, Inc. 593 p.

43849101 Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D on Bare Soil in a Corn Use Pattern in Nebraska: Final Report: Lab Project Number: AA940010: HWI 6397-133: RES94007. Unpublished study prepared by American Agricultural Services, Inc.; Agvise Labs and Hazleton Wisconsin, Inc. 576 p.

43872702 Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D Granules in Bare Soil in North Dakota: Final Report: Lab Project Number: RES94024: HWI 6397-146: AA940023. Unpublished study prepared by Agvise Labs; Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc. 393 p.

00116625 McCall, P.; Vrona, S.; Kelley, S. (1981) Fate of uniformly carbon- 14 ring labeled 2,4,5-trichlorophenoxyacetic acid and 2,4-Di- chlorophenoxyacetic acid. ?Source unknown|. (Also In unpub- lished submission received Oct 21, 1982 under 11683-EX-2; sub- mitted by U.S. Dept. of the Interior, Washington, DC; CDL: 248614-U)

43167501 Concha, M.; Shepler, K. (1994) Aerobic Soil Metabolism of (carbon 14)2,4- Dichlorophenoxyacetic Acid: Lab Project Number: 391W: 391W-1. Unpublished study prepared by PTRL West, Inc. 95 p.

### 2,4-D Bibliography

Page 272 of 304 42045301 Cohen, S. (1991) Aerobic Aquatic Metabolism of 2,4-Dichlorophenoxy- acetic Acid: Lab Project Number: C28- 306-01: 002/011/008/89: 6197A. Unpublished study prepared by Center for Hazardous Mate- rials Research. 159 p.

42979201 Concha, M.; Shepler, K. (1993) Aerobic Aquatic Metabolism of (carbon 14)2,4- D Acid: Lab Project Number: 393W-1: 393W. Unpublished study prepared by PTRL West, Inc. 112 p.

43356001 Concha, M.; Shepler, K. (1994) Anaerobic Aquatic Metabolism of (carbon 14)- 2,4-D Acid: Lab Project Number: 394W-1: P394W. Unpublished study prepared by PTRL West, Inc. 162 p.

41125306 Center for Hazardous Materials Research (1989) Aqueous Photodegra- dation of 2,4-Dichlorophenoxyacetic Acid in ph 7 Buffered Solu- tion: Rept. No. 5488A. Unpublished study. 128 p.

41007301 Center for Hazardous Materials Research (1989) Hydrolysis of 2,4-D in Aqueous Solutions Buffered at pH 5, 7, and 9: Project ID: 002/001/001/88. Unpublished study. 197 p.

42045302 Cohen, S. (1991) Mobility of Unaged 2,4-Dichlorophenoxyacetic Acid Using Batch Equilibrium Technique: Lab Project Number: 012/011/ 006/89: 6224A: C28-306-1. Unpublished study prepared by Center for Hazardous Materials Research. 76 p.

00112937 Brandau, E.; Goertler, M.; Otsa, H.; et al. (1975) Carbofuran, FMC 33297, FMC 25213 and Endosulfan Soil Adsorption/Desorption Studies: Analytical Report M-3785. (Unpublished study received Jan 3, 1978 under 279-3013; submitted by FMC Corp., Philadel- phia, PA; CDL:096699-T)

44117901 Fathulla, R. (1996) The Adsorption and Desorption of (carbon 14)-2,4-D on Representative Agricultural Soils: Final Report: Lab Project Number: CHW 6397-166. Unpublished study prepared by Corning Hazleton Inc. 84 p.

43908302 Hatfield, M. (1995) Aquatic Dissipation of the Dimethylamine Salt of 2,4-D in a Small Pond in North Dakota: Final Report: Lab Project Number: AA940027: RES94027: HWI 6397-150. Unpublished study prepared by Agvise Labs; American Agricultural Services, Inc.; and Hazleton Wisconsin, Inc. 719 p.

43954701 Hatfield, M. (1995) Aquatic Dissipation of the Dimethylamine Salt of 2,4-D in a Small Pond in North Carolina: Final Report: Lab Project Number: RES94026: RES944226: HWI6397-149. Unpublished study prepared by Agvise Labs; Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc. 713 p.

43491601 Barney, W. (1994) Aquatic Field Dissipation Study of 2,4-D DMAS in Louisiana: Lab Project Number: 2001RI: F93154-032: F93309-517. Unpublished study prepared by Environmental Technologies Institute, Inc. 580

p.

### 2,4-D Bibliography

Page 273 of 304 45897101 Jacobson, B. (2003) Dispersion and Dissipation of the Herbicide 2,4-D in Lake Woodruff, Florida: (Final Report): Lab Project Number: 243.01: 445S01: RES944226. Unpublished study prepared by Waterborne Environmental, Inc. and EPL Bio-Analytical Services. 423 p.

45931801 Jacobson, B. (2003) Dispersion and Dissipa tion of the Herbicide 2,4-D in Green Lake, Minnesota: Lab Project Number: 243.03: 467C-105: RES944226. Unpublished study prepared by Waterborne Environmental, Inc. and Wildlife International, Ltd. 469 p.

43491601 Barney, W. (1994) Aquatic Field Dissipation Study of 2,4-D DMAS in Louisiana: Lab Project Number: 2001RI: F93154-032: F93309-517. Unpublished study prepared by Environmental Technologies Institute, Inc. 580

p.

43908302 Hatfield, M. (1995) Aquatic Dissipation of the Dimethylamine Salt of 2,4-D in a Small Pond in North Dakota: Final Report: Lab Project Number: AA940027: RES94027: HWI 6397-150. Unpublished study prepared by Agvise Labs; American Agricultural Services, Inc.; and Hazleton Wisconsin, Inc. 719 p.

43954701 Hatfield, M. (1995) Aquatic Dissipation of the Dimethylamine Salt of 2,4-D in a Small Pond in North Carolina: Final Report: Lab Project Number: RES94026: RES944226: HWI6397-149. Unpublished study prepared by Agvise Labs; Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc. 713 p.

43491601 Barney, W. (1994) Aquatic Field Dissipation Study of 2,4-D DMAS in Louisiana: Lab Project Number: 2001RI: F93154-032: F93309-517. Unpublished study prepared by Environmental Technologies Institute, Inc. 580

p.

45897101 Jacobson, B. (2003) Dispersion and Dissipation of the Herbicide 2,4-D in Lake Woodruff, Florida: (Final Report): Lab Project Number: 243.01: 445S01: RES944226. Unpublished study prepared by Waterborne Environmental, Inc. and EPL Bio-Analytical Services. 423 p.

45931801 Jacobson, B. (2003) Dispersion and Dissipa tion of the Herbicide 2,4-D in Green Lake, Minnesota: Lab Project Number: 243.03: 467C-105: RES944226. Unpublished study prepared by Waterborne Environmental, Inc. and Wildlife International, Ltd. 469 p.

44525001 Norris, F. (1998) 2,4-D: Dissipation Afte r Application of the Granular Ester Formulation to Farm Ponds: Final Study Report: Lab Project Number: 96P10380: 45503: 10380-02. Unpublished study prepared by Rhone-Poulenc Ag Co., Covance Labs., Inc. and Agvise Labs., Inc. 1488 p.

43864002 Hatfield, M. (1995) Field Soil Dissipati on of the Dimethylamine Salt of 2,4-D in Pasture in California: Final Repor t: Lab Project Number: AA940016: RAM 8862-93-001: AASI 11/95. Unpublished study prepared by Agvise Labs; American Agricultural Services, Inc.; and Hazleton Wisconsin, Inc. 463 p.

### 2,4-D Bibliography

Page 274 of 304 43831703 Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D on Turf in California: Final Report: Lab Project Number: AA940018: 6397-141: RES94003. Unpublished study prepared by American Agricultural Services, Inc.; Agvise, Inc.; and Hazleton Wisconsin, Inc. 593 p.

43500301 Silvoy, J. (1994) Terrestrial Field Dissipation Study of 2,4-D DMAS on Bare Soil in Colorado Conducted According to a Wheat Use Pattern: Lab Project Number: 2000WH01: F93286/526. Unpublished study prepared by Environmental Technologies Institute, Inc. and Agvise Labs. 717 p.

43470401 Silvoy, J. (1994) Terrestrial Field Di ssipation Study of 2,4-D DMAS on Wheat in Colorado: Lab Project Number: 2000WH05. Unpublished study prepared by Environmental Technologies, Inc.; AGVISE; and A&L Lab., Inc. 703 p.

43612101 Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D DMAS on Bare Soil in North Carolina, Conducted According to a Wheat Use Pattern: Lab Project Number: 2000WH02: SC930170. Unpublished study prepared by Environmental Technologies Institute, Inc., Agvise Laboratories, Inc., and other facilities. 707 p.

43592802 Barney, W. (1995) Terrestrial Fiel d Dissipation Study of 2,4-D DMAS on Wheat in North Carolina: Lab Project Numbers: 2000WH06: SC930174: RES.07.05.01. Unpublished study prepared by Environmental Technologies Institute (ETI), Inc. 713 p.

43810701 Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D DMAS on Bare Soil in North Carolina Conducted According to a Turf Use Pattern: Lab Project Number: 6397-127: 6397-128: 2000BS02. Unpublished study prepared by Hazleton Wisconsin and Environmental Technologies Institute, Inc. 600 p.

43797902 Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D DMAS on Turf in North Carolina: Lab Project Number: 2000TF02: HWI 6397-128. Unpublished study prepared by Environmental Technologies Institute, Inc. 708

p.

43872401 Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D on a Bare Soil in a Wheat Use Pattern in North Dakota: Final Report: Lab Project Number: AA940014: AASI 12/95: HWI6397-137. Unpublished study prepared by Agvise Labs; Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc. 426 p.

43676803 Barney, W. (1995) Terrestrial Fiel d Dissipation Study of 2,4-D DMAS on Pasture in Texas: Lab Project Number: 2000PA02: 10-9305-02. Unpublished study prepared by ETI Inc. and AGVISE Labs, Inc. 590 p.

43872701 Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D Granules on Turf in North Dakota: Final Report: Lab Project Number: RES94023: HWI 6397-145: AA940022. Unpublished study prepared by Agvise Labs; Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc. 463 p.

### 2,4-D Bibliography

Page 275 of 304 43872702 Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D Granules in Bare Soil in North Dakota: Final Report: Lab Project Number: RES94024: HWI 6397-146: AA940023. Unpublished study prepared by Agvise Labs; Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc. 393 p.

43834301 Hatfield, M. (1995) Field Soil Dissipation of the Dimethylamine Salt of 2,4-D on Bare Soil in a Corn Use Pattern in Ohio: Final Report: Lab Project Number: AA940012: HWI 6397-135: RES94009. Unpublished study prepared by American Agricultural Services, Inc.; Hazleton Wisconsin, Inc.; and Agvise Labs. 552 p.

43954702 Barney, W. (1995) Forest Field Dissi pation of 2,4-Dichlorophenoxyacetic Acid, Dimethylamine Salt in Oregon: Lab Project Number: 2002FO01: F9331-523: F9331-527. Unpublished study prepared by Collins Ag Consultants; Agvise Labs; and Environmental Technologies Institute, Inc. 1309 p.

43779601 Reynolds, J. (1995) Aerobic Aquatic Metabolism of (Carbon-14)- Dimethylamine: Lab Project Number: XBL95031: RPT00231: 8437. Unpublished study prepared by XenoBiotic Labs, Inc. 118 p.

43908301 Reynolds, J. (1995) Anaerobic Aquatic Metabolism of (Carbon 14)- Dimethylamine: Lab Report No. RPT00246; Study No. XBL95032. Unpublished study prepared by XenoBiotic Labs., Inc. 128 p.

41353702 Reim, R. (1989) Dissociation of 2,4-Di chlorophenoxyacetic Acid (2,4-D), 2,4-D Isopropylamine Salt (IPA) and 2,4-D Triisopropa- nolamine (TIPA) Salt in Water: Lab Project Number: ML/AL/89/ 041189. Unpublished study prepared by Dow Chemical U.S.A. 31 p

43821501 Hawes, K. (1995) The Aerobic Soil Metabolism of Isopropylamine: Lab Project Number: ENV94100. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 47 p.

43799107 Hawes, K. (1995) The Aerobic Aquatic Metabolism of Isopropylamine: Lab Project Number: ENV94101. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 78 p.

43799104 Hawes, K. (1995) The Anaerobic Aquatic Metabolism of Isopropylamine: Lab Project Number: ENV94099. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 67 p.

43799102 Cleveland, C.; Ulmer, J. (1995) Aerobic Soil Metabolism Study for Triisopropanolamine (TIPA): a 2,4-D Requested Moiety Study: Lab Project Number: ENV94142. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 70 p.

### 2,4-D Bibliography

Page 276 of 304 43799108 Krieger, M. (1995) Aerobic Aquatic Metabolism of (Carbon 14)- Triisopropanolamine (TIPA): Lab Project Number: ENV94123. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 75 p.

43799105 Cleveland, C.; Ulmer, J. (1995) Anaerobic Aquatic Metabolism Study for Triisopropanolamine (TIPA): Requested 2,4-D Moiety Study: Lab Project Number: ENV94144. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 62 p.

43685901 Reynolds, J. (1995) Aerobic Soil Metabolism of (carbon 14) (inert ingredient): Lab Project Number: XBL94082: RPT00214. Unpublished study prepared by XenoBiotic Lab., Inc. 118 p.

43685902 Reynolds, J. (1995) Aerobic Aquatic Metabolism of (carbon 14) (inert ingredient): Lab Project Number : XBL94084: RPT00216. Unpublished study prepared by XenoBiotic Lab., Inc. 120 p.

44439401 Reynolds, J. (1996) Anaerobic Aquatic Metabolism of (carbon 14)- Diethanolamine: Lab Project Number: XBL94083: RPT00215: 94083. Unpublished study prepared by XenoBiotic Labs., Inc. 151 p.

43882901 Reynold, J. (1995) Anaerobic Aquatic Metabolism of (carbon 14)-(Inert Ingredient): Lab Project Nu mber: XBL94083: RPT00215: SR940016-8. Unpublished study prepared by XenoBiotic Labs, Inc. 141 p.

42770502 Concha, M.; Shepler, K.; Erhardt-Zabik, S. (1993) Hydrolysis of (carbon 14) 2,4-D Ethylhexyl Ester in Natural Water: Lab Project Number: 395W-1: 395W. Unpublished study prepared by PTRL West, Inc. 69 p.

42770501 Concha, M.; Shepler, K.; Erhardt-Zabik, S. (1993) Hydrolysis of (carbon 14) 2,4-D Ethylhexyl Ester in Soil Slurries: Lab Project Number: 403W-1: 403W. Unpublished study prepared by PTRL West, Inc. 79 p.

43514601 Silvoy, J. (1995) Terrestrial Field Dissipation Study of 2,4-D 2-EHE on Bare Soil in Colorado: Lab Project Number: 2000WH03-COLORADO: SC930169: RAM 8862-93-001. Unpublished study prepared by ETI; Agvise; and A&L Labs, Inc. 780 p.

43533401 Silvoy, J. (1995) Terrestrial Field Dissipation Study of 2,4-D 2-EHE on Wheat in Colorado: Lab Project Number: 2000WH07-COLORADO: 2000WH07. Unpublished study prepared by Agvise; A&L Labs, Inc.; and Battelle. 733 p.

43846001 Walter, J. (1995) WRC-AP-1 Nontarget Plant Data: Lab Project Number: 4695- GL21-NTP. Unpublished study prepared by Grace Biopesticides. 164 p.

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Page 277 of 304 43592801 Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D 2-EHE on Bare Soil in North Carolina: Conducted According to a Wheat Use Pattern: Lab Project Numbers: 2000WH04: SC930172: F93076-050. Unpublished study prepared by Environmental Technologies Institute (ETI), Inc. 749 p.

43762403 Barney, W. (1995) Terrestrial Field Soil Dissipation Study of 2,4-D 2-EHE on Bare Soil in North Carolina Conducted According to a Turf Use Pattern: Lab Project Number: 2000BS04. Unpublished study prepared by Environmental Technologies, Inc. 748 p.

43762404 Barney, W. (1995) Terrestrial Field Dissipation Study of 2,4-D 2-EHE on Turf in North Carolina: Lab Project Number: 2000TF04. Unpublished study prepared by Environmental Technologies, Inc. 865 p.

43640601 Barney, W. (1995) Terrestrial Fiel d Dissipation Study of 2,4-D 2-EHE on Wheat in North Carolina: Lab Project Number: SC930176: 2000WH08. Unpublished study prepared by Environmental Technologies Institute, Inc.; Agvise Labs, Inc.; and DowElanco. 744 p.

43831702 Hatfield, M. (1995) Field Soil Dissipati on of the 2-Ethylhexyl Ester of 2,4-D on Bare Soil in a Wheat Use Pattern in North Dakota: Final Report: Lab Project Number: AA940015: 6397-138: RES94022. Unpublished study prepared by American Agricultural Services, Inc.; Agvise, Inc.; and Hazleton Wisconsin, Inc. 445 p.

43872703 Hatfield, M. (1995) Field Soil Dissipati on of the 2-Ethylhexyl Ester of 2,4-D Granules in Bare Soil in Ohio: Final Report: Lab Project Number: RES94012: HWI 6397-148: AA940025. Unpublished study prepared by Agvise Labs; Hazleton Wisconsin, Inc.; and American Agricultural Services, Inc. 404 p.

43849102 Hatfield, M. (1995) Field Soil Dissipati on of the 2-Ethylhexyl Ester of 2,4-D on Bare Soil in a Corn Use Pattern in Ohio: Final Report: Lab Project Number: AA940013: HWI 6397-136: RES94010. Unpublished study prepared by American Agricultural Services, Inc.; Agvise Labs and Hazleton Wisconsin, Inc. 570 p.

43831701 Hatfield, M. (1995) Field Soil Dissipati on of the 2-Ethylhexyl Ester of 2,4-D Granules on Turf in Ohio: Final Report: Lab Project Number: AA940024: 6397- 147: RES94011. Unpublished study prepared by American Agricultural Services, Inc.; Agvise, Inc.; and Hazleton Wisconsin, Inc. 513 p.

43705202 Barney, W. (1995) Terrestrial Fiel d Dissipation Study of 2,4-D 2-EHE on Pasture in Texas: Lab Project Numbers: 2000PA04: 10-9305-04: F93351-525. Unpublished study prepared by Environmental Technologies Institute (ETI), Inc. and Minnesota Valley Testing Labs. 692 p.

43762401 Hatfield, M. (1995) Field Soil Dissipati on of the 2-Ethylhexyl Ester of 2,4-D in Pasture in California: Final Repor t: Lab Project Number: AA940017: 6397-140: HWI 6397-140. Unpublished study prepared by American Agricultural Services, Inc.; Agvise Labs; and Hazleton Wisconsin, Inc. 507 p.

### 2,4-D Bibliography

Page 278 of 304 43762402 Hatfield, M. (1995) Field Soil Dissipati on of the 2-Ethylhexyl Ester of 2,4-D in Turf in California: Final Report: Lab Project Number: AA940019: 6397-142: HWI 6397-142. Unpublished study prepared by American Agricultural Services, Inc.; Agvise Labs; and Hazleton Wisconsin, Inc. 614 p.

43908303 Barney, W. (1995) Forest Field Dissi pation of 2,4-Dichlorophenoxyacetic Acid Isooctyl (2-Ethylhexyl) Ester in Georgia: Interim Report: Lab Project Number: 2002FO02: 6397-162: 011-02. Unpublished study prepared by Environmental Technologies Institute, Inc. 152 p.

43927101 Barney, W. (1996) Forest Field Di ssipation Study of 2,4-Dichlorophenoxyacetic Acid, Isooctyl (2-Ethylhexyl) Ester in Georgia: Lab Project Number: 2002FO02: F93356-533: F93312-510. Unpublished study prepared by Environmental Technologies Institute, Inc. 1355 p.

43415901 Reynolds, J. (1994) Aerobic Soil Metabolism of (carbon 14)-2-Ethylhexanol: Lab Project Numbers: XBL93131: RPT00177. Unpublished study prepared by XenoBiotic Labs, Inc. 111 p.

43691001 Reynolds, J. (1995) Anaerobic Aquatic Metabolism of (carbon 14)-2- Ethylhexanol: Lab Project Number: XBL 93132: RPT00182. Unpublished study prepared by XenoBiotic Labs, Inc. 115 p.

41353701 Racke, K. (1989) Hydrolysis of 2,4-Dichlorophenoxyacetic Acid-2- Butoxyethyl Ester to 2,4-Dichlorophenoxyacetic Acid in a Soil/ Water System: Lab Project Number: GH/C/2198. Unpublished study prepared by Dow Chemical U.S.A. 29

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41483101 Shepler, K.; Estigoy, L.; Ruzo, L. (1990) Hydrolysis of ?Carbon 14|2,4 Dbutoxyethyl Ester (2,4 D-BEE) at pH5,7, and 9: Lab Project No.: 193W1;PTRL Project No. 193W. Unpublished study prepared by Pharmacology and Toxicology Research Laboratory, West. 75 p.

41483103 Marx, M.; Shepler, K. (1990) Vapor Phase Photolysis of (Carbon 14)-Phenyl} 2,4-Dichlorophenoxyacetic Acid, Butoxyet hyl Ester (2D-BEE): PTRL Report No. 195W-1: PTRL Project No. 195W. Unpublished study prepared by Pharmacology & Toxicology Research Laboratories, West. 92 p.

42574701 Lawrence, B.; Mobley, S.; Kesterson, A. (1992) Anaerobic Aquatic Metabolism of (carbon 14)2,4-D-2-Butoxyethyl Ester: Re-Issue: Lab Project Number: 453: 1428: 1623-90-43-06-28G-01. Unpublished study prepared by PTRL East, Inc. 78 p.

43799101 Batzer, F. (1995) Aerobic Soil Metabolism of (Carbon 14)-2- Butoxyethanol: Lab Project Number: ENV94094. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 117 p.

43799106 Batzer, F. (1995) Aerobic Aquatic Metabolism of (Carbon 14)-2- Butoxyethanol: Lab Project Number: ENV94096. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 88 p.

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Page 279 of 304 43799103 Batzer, F. (1995) Anaerobic Aquatic Metabolism of (Carbon 14)- 2- Butoxyethanol: Lab Project Number: ENV94095. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 89 p.

41349601 Simoneaux, B. (1989) Uptake and Metabolism of 2?Delta|-?Carbon 14|- Diazinon in Field Grown Apples : Lab Project Number: ABR-89058. Unpublished study prepared by Ciba-Geigy Corp. 104 p.

43441201 Burke, B. (1994) Hydrolysis of (Ring-(carbon 14)) (2,4-Dichlorophenoxy)acetic Acid Isopropyl Ester: Lab Project Number: PRT/22/4WNA/02: PRT/22/4WNA/02/003. Unpublished study prepared by Plant Research Technologies, Inc. 118 p.

43149601 Burke, B. (1994) Rate of De-esterification of (Ring-(carbon 14)) (2,4- Dichlorophenoxy)acetic Acid Isopropyl Ester: Lab Project Number: PRT/22/3WNA/01: PRT/22/3WNA/01/008. Unpublished study prepared by Plant Research Technologies, Inc. 122 p.

43606301 Reynolds, J. (1995) Anaerobic Aquatic Metabolism of 2-(carbon 14)- Isopropanol: Lab Project Number: XBL 94081: RPT00196. Unpublished study prepared by XenoBiotic Labs, Inc. 100 p.

41125305 Center for Hazardous Materials Res earch (1989) Photodegradation of 2,4- Dichlorophenoxyacetic Acid on Soil: Rept. No. 5485A. Un- published study. 127 p.

44188601 Fathulla, R. (1996) Aerobic Aquatic Metabolism of (carbon 14)-2,4-D: Final Report: Lab Project Number: CHW 6397-172. Unpublished study prepared by Corning Hazleton, Inc. 83 p.

41557901 Levine, A. (1990) Anaerobic Aquatic Metabolism of 2,4-Dichlorophenoxyacetic Acid: Lab Project Number: 002/001/007/88. Unpub- lished study prepared by Center for Hazardous Materials Research. Transmittal of 1 study.

44105201 Fathulla, R. (1996) The Adsorption and Desorption of (carbon 14)-2,4-DCP on Representative Agricultural Soils: Lab Project Number: CHW 6397-168. Unpublished study prepared by Corning Hazleton Inc. 82 p.

44158501 Fathulla, R. (1996) The Adsorption and Desorption of (carbon 14)-2,4-DCA on Representative Agricultural Soils: Final Report: Lab Project Number: CHW 6397-170. Unpublished study prepared by Corning Hazleton, Inc. 84 p.

41158301 Alexander, H.; Mayes, M.; Gersich, F. (1983) The Acute Toxicity of (2,4 - Dichlorophenoxy)acetic Acid to Representative Aquatic Organisms: Project Study ID: ES-DR-0002-2297-4. Unpublished study prepared by Dow Chemical U.S.A. 26 p.

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41975105 Graves, W.; Peters, G. (1991) Diethanol amine Salt of 2,4-D: A 96- Hour FlowThrough Acute Toxicity Test With the Rainbow Trout (Oncorhynchus mykiss): Final Report: Lab Project Number: 281A- 101A. Unpublished study prepared by Wildlife International. 37 p.

41975104 Graves, W.; Peters, G. (1991) Diethanol amine Salt of 2,4-D: A 96- Hour FlowThrough Acute Toxicity Test With the Bluegill (Lepomis macrochirus): Final Report: Lab Project Number: 281A-105A. Unp- ublished study prepared by Wildlife International. 37 p.

41158311 Alexander, H.; Mayes, M.; Gersich, F.; et al. (1983) The Acute Toxicity of (2,4- Dichlorophenoxy) Acetic Acid Dimethylamine Salt to Representative Aquatic Organisms: Project Study ID: ES-DR-0008-3556-2. Unpublished study prepared by Dow Chemical U.S.A. 24 p.

41353803 Mayes, M.; Barron, M.; Hopkins, D. (1989) 2,4-Dichlorophenoxyacetic Acid, Trisopropanolamine Salt: Evaluation of the Toxicity to the Rainbow Trout, Oncorhynchus mykiss: Final Report: Project ES-DR- 0100-2400-1A. Unpublished study prepared by The Dow Chemical Co. 16 p.

41353804 Mayes, M.; Barron, M.; Hopkins, D. (1989) 2,4-Dichlorophenoxyacetic Acid, Trisopropanolamine Salt: Evaluation of the Toxicity to the Bluegill, Lepomis macrochirus: Final Report: Project No. ES-DR- 2400/1B. Unpublished study prepared by The Dow Chemical Co. 16 p.

41353801 Alexander, H.; Gersich, F.; Mayes, M. et al. (1983) The Acute Toxi- city of 2- Butoxyethyl (2,4-Dichlorophenoxy) Acetate to Represen- tative Aquatic Organisms: Final Report: Lab Project Number: ES - 586. Unpublished study prepared by Dow Chemical U.S.A. 23 p.

50674 Pitcher, F.G. (1974) Weed-Rhap LV OXY 6D: Rainbow Trout (~Salmo~ ?~gairdneri~): Test No. 683. (U.S. Environmental Protection Agency, Pesticides Regulation Div., Animal Biology La boratory, unpublished study; CDL:128512- A)

40098001 Mayer, F.; Ellersieck, M. (1986) Manual of Acute Toxicity: Inter- pretation and Data Base for 410 Chemicals and 66 Species of Freshwater Animals. US Fish & Wildlife Service, Resource Pub- lication 160. 579 p.

45068 Buccafusco, R.J. (1976) Acute Toxicity of the Iso-octyl ester of 2,4-D D # 10498 to Rainbow Trout (?~Salmo gairdneri~?). (Unpub- lished study received Oct 28, 1976 under 400-134; prepared by EG&G Bionomics, submitted by Uniroyal Chemical, Bethany, Conn.; CDL:226397-C)

### 2,4-D Bibliography

Page 281 of 304 45069 Buccafusco, R.J. (1976) Acute Toxicity of the Iso-octyl ester of 2,4-D D # 10498 to Bluegill (?~Lepomis macrochirus~?). (Unpub- lished study received Oct 28, 1976 under 400-134; prepared by EG&G Bionomics, submitted by Uniroyal Chemical, Bethany, Conn.; CDL:226397-D)

43933101 Drottar, K.; Swigert, J. (1996) 2,4-D Isopropyl Ester: A 96-Hour Flow-Through Acute Toxicity Test with the Rainbow Trout (Oncorhynchus mykiss): Final Report: Lab Project Number: 435A-103A: 435/100295/RBT-96H2A/CHP105. Unpublished study prepared by Wildlife International Ltd. 69 p.

43933201 Drottar, K.; Swigert, J. (1996) 2,4-D Isopropyl Ester End Use Product: A 96- Hour Flow-Through Acute Toxicity Test with the Rainbow Trout (Oncorhynchus mykiss): Final Report: Lab Project Number: 435A-101: 435/100295/RBT-96H2B/CHP105. Unpublished study prepared by Wildlife Int'l. Ltd. 68 p.

43930701 Drottar, K.; Swigert, J. (1996) 2,4-D Isopropyl Ester: A 96-Hour Flow-Through Acute Toxicity Test with the Bluegill (Lepomis macrochirus): Final Report: Lab Project Number: 435A-105: 435/100295/BLU-96H2A/CHP105. Unpublished study prepared by Wildlife International Ltd. 67 p.

43910301 Drottar, K.; Swigert, J. (1996) 2,4-D Isopropyl Ester End Use Product: A 96- Hour Flow Through Acute Toxicity Test with the Bluegill (Lepomis macrochirus): Final Report: Lab Pr oject Number: 435A-102: 435/100295/BLU96H2B/CHP 105. Unpublished study prepared by Wildlife International Ltd. 66

p.

41737307 Vaishnav, D.; Yurk, J.; Wade, B. (1990) 2,4-Dichlorophenoxyacetic Acid:Acute Toxicity to Tidewater Silverside (Menidia Beryllina) Under Flowthrough Conditions: Lab Project Number: 3903008000- 0210-3140. Unpublished study prepared by Environmental Science and Engineering Inc. 37

p.

42018301 Graves, W.; Peters, G. (1991) Diethanol amine Salt of 2,4-D: A 96- Hour Flowthrough Acute Toxicity Test with the Atlantic Silver- side (Menidia menidia): Final Report: Lab Project Number: 281A/ 102A. Unpublished study prepared by Wildlife International Ltd. 37 p.

41835209 Ward, G. (1991) 2,4-D, Dimethylamine Salt: Acute Toxicity to the Tidewater Silverside, Menidia beryllina, Under Flow-through Test Conditions: Lab Project Number: J9002003B. Unpublished study prepared by Toxikon Environmental Sciences. 41 p.

41429001 Sousa, J. (1990) Acute Toxicity to Tidewater Silversides (Menidia Beryllina) Under Flow-Through Conditions: (2,4-D IP A): Lab Pro- ject Number: 89-11- 3140: 236.0689.6101.506: ES-2231. Unpublish- ed study prepared by Springborn Laboratories, Inc. 35 p.

### 2,4-D Bibliography

Page 282 of 304 41429004 Sousa, J. (1990) Acute Toxicity to Tidewater Silversides (Menidia beryllina) under Flow-through Conditions: (2,4-D TIPA ): Lab Pro- ject Number: 89-11- 3141: 236.0689.6100.506: ES-2230. Unpublished study prepared by Springborn Laboratories, Inc. 38 p.

41835205 Ward, T.; Boeri, R. (1991) Acute Flow -through Toxicity of 2,4-D, 2- Ethylhexyl Ester to the Tidewater Silverside, Menidia beryllina: Lab Project Number: 9035- D. Unpublished study prepared by Re- source Analysts, Inc./EnviroSystems Inc. 25 p.

41835202 Ward, T.; Boeri, R. (1991) Acute Flow-through Toxicity of Esteron 99 Herbicide to the Tidewater Silverside, Menidia beryllina: Lab Project Number: 9038-D. Unpublished study prepared by Resource Analysts, Inc./EnviroSystems Div. 25 p.

41737304 Mayes, M.; Gorzinski, S.; Potter, R.; et al. (1990) 2,4-Dichloro- phenoxyacetic Acid: Evaluation of the Toxicity to Early Life Stages of the Fathead Minnow, Pimephales promelas Rafinesque: Lab Project Number: ES-DR-0002-2297-10. Unpublished study pre- pared by The Dow Chemical Co. 48 p.

42018304 Graves, W.; Peters, G. (1991) Diethanolamine Salt of 2,4-D: An Early LifeStage Toxicity Test with the Fathead Minnow (Pime- phale promelas): Final Report: Lab Project Number: 281A/103A. Unpublished study prepared by Wildlife International Ltd. 55 p.

41767701 Dill, C.; Gorzinski, S.; Potter, R.; et al. (1990) 2,4-Dichloro- phenoxyacetic Acid Dimethylamine Salt: Evaluation of the Toxi- city to Early Life Stages of theFathead Minnow, Pimephales promelas Rafinesque: Lab Project Number: ESDR-0008-3556-4. Un- published study prepared by Dow Chemical Co., Environmental Tox. and Chem. Research. 39 p.

41345701 Mayes, M.; Gorzinski, S.; Harms, D.; et al. (1989) 2,4-Dichloro- phenoxyacetic Acid,2-Butoxyethyl Ester: Evaluation of th e Toxi- city to Early Life Stages of the Fathead Minnow, Pimephales promelas Rafinesque: Lab Project Number: ES/DR/0131/3037/1. Un- published study prepared by Dow Chemical Co. 53 p.

41737305 Mayes, M.; Gorzinski, S.; Potter, R.; et al. (1990) 2,4-Dichloro- phenoxyacetic Acid (2-Ethylhexyl Ester): Evaluation of the Toxi- city to Early Life Stages of the Fathead Minnow, Pimephales promelas Rafinesque: Lab Project Number: ES-DR-0019-1208-7. Un- published study prepared by The Dow Chemical Co. 51 p.

44517307 Palmer, S.; Krueger, H. (1997) 2,4-D (2,4-Dichlorophenoxyacetic Acid): A 96- Hour Static Acute Toxicity Test with the Leopard Frog Tadpoles (Ranapipiens): Final Report: Lab Project Number: 467A-102: 467/060297/LF96H1A/SUB467. Unpublished study prepared by Wildlife International Ltd. 57

p.

### 2,4-D Bibliography

Page 283 of 304 44517306 Palmer, S.; Krueger, H. (1997) 2,4-D Dimethylamine Salt: A 96-Hour Static Acute Toxicity Test with the Leopard Frog Tadpoles (Rana pipiens): Final Report: Lab Project Number: 467A-103: 467/060297/LF-96H1B/SUB467. Unpublished study prepared by Wildlife International Ltd. 57 p.

44517305 Palmer, S.; Krueger, H. (1997) 2,4-D 2-Ethylhexyl Ester: A 96-Hour Static Acute Toxicity Test with the Leopard Frog Tadpoles (Rana pipiens): Final Report: Lab Project Number: 467A-101: 467/060297/LF-96H1C/SUB467. Unpublished study prepared by Wildlife International Ltd. 70 p.

41975106 Graves, W.; Peters, G. (1991) Diethanol amine Salt of 2,4-D: A 48- Hour FlowThrough Acute Toxicity Test With the Cladoceran (Daph- nia magna): Final Report: Lab Project Number: 281A-107. Unpubl- ished study prepared by Wildlife International. 37 p.

138869 Alexander, H.; Mayes, M.; Gersich, F.; et al. (1983) The Acute Tox- icity of (2,4-Dichlorophenoxy) Acetic Acid Isopropylamine Salt to Representative Aquatic Organisms: ES-626. (Unpublished study received Jan 18, 1984 under 464-596; submitted by Dow Chemical U.S.A., Midland, MI; CDL:252291-D)

41353805 Mayes, M. (1989) 2,4-Dichlorophenoxyacetic Acid, Trisopropanolamine Salt: Evaluation of the Toxicity to the Water Flea, Daphnia magna Straus: Final Report: Lab Project Number: ES/DR/0100/2400/1C. Unpublished study prepared by The Dow Chem- ical Co. 17 p.

67328 Kuc, W.J. (1977) The Acute Toxicity of 2,4-D Isooctyl Ester Tech D-10498 to the Water Flea~Daphnia magna~Straus: UCES Proj. # 11506-29-07. (Unpublished study received Aug 19, 1977 under 400-134; prepared by Union Carbide Corp., submitted by Uniroyal Chemical, Bethany, Conn.; CDL:231359- A)

41158306 Alexander, H.; Gersich, F.; Mayes, M.; et al. (1983) The Acute Toxicity of (2,4- Dichlorophenoxy) Acetic Acid Isooctyl Ester to Representative Aquatic Organisms: Project Study ID: ES-DR-0019- 1208-3. Unpublished study prepared by Dow Chemical U.S.A. 15 p.

43930601 Drottar, K.; Swigert, J. (1996) 2,4-D Isopropyl Ester: A 48-Hour Flow-Through Acute Toxicity Test with the Cladoceran (Daphnia magna): Final Report: Lab Project Number: 435A-104A. Unpublished study prepared by Wildlife International Ltd. 68 p.

41835211 Ward, T.; Boeri, R. (1991) Chronic Toxicity of 2,4-D to the Daphnid Daphnia magna: Lab Project Number: 9040-D. Unpublished study prepared by Resource Analysts, Inc./EnviroSystems Div. 38 p.

42018303 Holmes, C.; Peters, G. (1991) Diethanolamine Salt 2,4-D: A Flow- through Life-Cycle Toxicity Test with the Cladoceran (Daphnia magna): Final Report: Lab Project Number: 281A/106. Unpublished study prepared by Wildlife International Ltd. 51 p.

### 2,4-D Bibliography

Page 284 of 304 41835210 Ward, G. (1991) 2,4-D, Dimethylamine Salt: Chronic Toxicity to the Water Flea, Daphnia magna, Under Flow-through Test Conditions: Lab Project Number: J9002003D. Unpublished study prepared by Toxikon Environmental Sciences. 45 p.

41353802 Gersich, F.; Gorzinski, S.; Harms, D.; et al. (1989) 2,4-Dichloro- phenoxy Acetic Acid (2-Butoxyethyl Ester): Evaluation of the Chronic Toxicity to Daphnia magna Straus: Final Report: Project No. ES-DR-0131-3037-2. Unpublished study prepared by The Dow Chemical Co. 36 p.

42979701 Ward, T.; Magazu, J.; Boeri, R. (1993) 2,4-D: Acute Flow-Through Mollusc Shell Deposition Test: Lab Project Number: 286-DE. Unpublished study prepared by T.R. Wilbury Labs, Inc. 38 p.

41737306 Vaishnav, D.; Yurk, J.; Wade, B. (1990) 2,4-Dichlorophenoxyacetic Acid: Acute Toxicity to Pink Shrimp (Penaeus Duorarum) Under Flow-through Conditions: Lab Project Number: 3903008000-0200- 3140. Unpublished study prepared by Environmental Science and Engineering Inc. 37 p.

42018302 Graves, W.; Peters, G. (1991) Diethanol amine Salt of 2,4-D: A 96- Hour Shell Deposition Test with the Eastern Oyster (Crassostrea virginica): Lab Project Number: 281A/115. Unpublished study prepared by Wildlife International Ltd. 39 p.

41975107 Graves, W.; Peters, G. (1991) Diethanol amine Salt of 2,4-D: A 96- Hour FlowThrough Acute Toxicity Test With the Pink Shrimp (Pen- aeus Duorarum): Final Report: Lab Project Number: 281A-104A. Unpublished study prepared by Wildlife International. 37 p.

41158310 Heitmuller, T. (1975) Acute Toxicity of DMA-4 to Larvae of the Eastern Oyster (Crassostrea virginica), Pink Shrimp (Penaeus duorarum), and Fiddler Crabs (UCA pugilator): Project Study ID: GH-RC-10. Unpublished study prepared by Bionomics--EG&G, Inc. 12 p.

41973401 Ward, G. (1991) 2,4-D, Dimethylamine Salt: Acute Effect on New Shell Growth of, the Eastern Oyster, Crassostrea vi rginica, Under Floow-through Conditions: Lab Project Number: J9002003C. Unpublished study prepared by Toxikon Environmental Sciences. 41 p.

41429003 Dionne, E. (1990) Acute Toxicity to Eastern Oyster (Crassostrea virginica) under Flow-through Conditions: (2,4-D IPA): Lab Proj- ject Number: 89-11- 3134: 236.0689.6101.504: ES-2227. Unpublish- ed study prepared by Springborn Laboratories, Inc. 39 p.

41429002 Sousa, J. (1990) Acute Toxicity to Pink Shrimp (Penaeus duorarum) Under Flow-through Conditions: (2,4-D IPA): Lab Project Number: 89-11-3154: 236. 0689. 6101. 516: ES-2229. Unpublished study prepared by Springborn Laboratories, Inc. 40 p.

### 2,4-D Bibliography

Page 285 of 304 41429006 Dionne, E. (1990) Acute Toxicity to Eastern Oyster (Crassostrea virginica) under Flow-through Conditions: (2,4-D TIPA ): Lab Pro- ject Number: 89-9- 3092: 236.0689.6100.504: ES-2226. Unpublished study prepared by Springborn Laboratories, Inc. 37 p.

41429005 Sousa, J. (1990) Acute Toxicity to Pink Shrimp (Penaeus duorarum) Under Flow-through Conditions: (2,4-D TIPA ): Lab Project Number: 89-12-3169: 236.0689.6100.516: ES-2228. Unpublished study pre- pared by Springborn Laboratories, Inc. 37 p.

41835204 Ward, T.; Boeri, R. (1991) Acute Flow-through Mollusc Shell Deposi- tion Test with 2,4-D, 2-Ethylhexyl Ester: Lab Project Number: 9034-D. Unpublished study prepared by Resource Analysts, Inc./ EnviroSystems Div. 25 p.

41835201 Ward, T.; Boeri, R. (1991) Acute Flow-through Mollusc shell Deposi- tion Test with Esteron 99 Herbicide: Lab Project Number: 9037-D. Unpublished study prepared by Resource Analysts, Inc./Enviro- Systems Div. 25 p.

41835206 Ward, T.; Boeri, R. (1991) Acute Flow-t hrough Toxicity of 2,4-D, 2- Ehtylhexyl Ester to the Grass Shrimp, Palaemonetes pugio: Lab Project Number: 9036-D. Unpublished study prepared by Resource Analysts, Inc. 25 p.

41835203 Ward, T.; Boeri, R. (1991) Acute Flow-through Toxicity of Esteron 99 Herbicide to the Grass Shrimp, Palaemonetes pugio: Lab Pro- ject Number: 9039-D. Unpublished study prepared by Resource Analysts, Inc./EnviroSystems Div. 25 p.

41420001 Hughes, J. (1989) The Toxicity of 2,4-D to Selenastrum capricorn- utum: Lab Project Number: 0460-05-1100-1. Unpublished study prepared by Malcolm Pirnie, Inc. 33 p.

43307901 Hughes, J.; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D to Anabaena flos-aquae: Lab Project Number: 10/01/1. Unpublished study prepared by Carolina Ecotox, Inc. 57 p.

43307902 Hughes, J.; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D to Navicula pelliculosa: Lab Project Number: 10/01/2. Unpublished study prepared by Carolina Ecotox, Inc. 55 p.

43307903 Hughes, J.; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D to Skeletonema costatum: Lab Project Number: 10/01/3. Unpublished study prepared by Carolina Ecotox, Inc. 57 p.

43768001 Hughes, J.; Williams, T.; Alexander, M. (1995) The Toxicity of Isopropyl Ester of 2,4-Dichlorophenoxyacetic Acid to Selenastrum capricornutum: Lab Project Number: 17-01-1. Unpublished study prepared by Carolina Ecotox, Inc. 56 p.

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Page 286 of 304 44295101 Hughes, J.; Williams, T.; Conder, L. (1997) Effect of 2,4- Dichlorophenoxyacetic Acid on the Growth and Reproduction of Lemna gibba G3: (Final Report): Lab Project Number: 10-05-1. Unpublished study prepared by Carolina Ecotox, Inc. 72 p.

42712204 Thompson, S.; Swigert, J. (1993) Diethanolamine Salt of 2,4-D: A 14-Day Toxicity Test with Duckweed (Lemna gibba G3): Final Report: Lab Project Number: 281A-116. Unpublished study prepared by Wildlife International, Ltd. 45 p.

42712205 Thompson, S.; Swigert, J. (1993) Diethanolamine Salt of 2,4-D: A 5-Day Toxicity Test with the Freshwater Alga (Selenastrum capricornutum): Final Report: Lab Project Number: 281A-117A. Unpublished study prepared by Wildlife International, Ltd. 39 p.

42712201 Thompson, S.; Swigert, J. (1993) Diethanolamine Salt of 2,4-D: A 5-Day Toxicity Test with the Marine Diatom (Skeletonema costatum): Final Report: Lab Project Number: 281A-119. Unpublished study prepared by Wildlife International, Ltd. 38 p.

42712202 Thompson, S.; Swigert, J. (1993) Diethanolamine Salt of 2,4-D: A 5-Day Toxicity Test with the Freshwater Diatom (Navicula pelliculosa): Final Report: Lab Project Number: 281A-120. Unpublished study prepared by Wildlife International, Ltd. 39 p.

42712203 Thompson, S.; Swigert, J. (1993) Diethanolamine Salt of 2,4-D: A 5-Day Toxicity Test with the Freshwater Alga (Anabaena flos-aquae): Final Report: Lab Project Number: 281A-118. Unpublished study prepared by Wildlife International, Ltd. 39 p.

41505904 Hughes, J. (1989) The Toxicity of 2,4-D, Dimethylamine Salt to Lemna gibba: Lab Project Number: 0460-05-1100-7. Unpublished prepared by Malcolm Pirnie, Inc. 33 p.

41420002 Hughes, J. (1989) The Toxicity of 2,4-D, Dimethylamine Salt to Selenastrum capricornutum: Lab Project Number: 0460-05-1100-3. Unpublished study prepared by Malcolm Pirnie, Inc. 33 p.

41505901 Hughes, J. (1990) The Toxicity of 2,4-D, Dimethylamine Salt to Skeletonema costatum: Lab Project Number: 0460-05-1100-6. Un- published study prepared by Malcolm Pirnie, Inc. 34 p.

41505903 Hughes, J. (1990) The Toxicity of 2,4-D, Dimethylamine Salt to Navicula pelliculosa: Lab Project Number: 0460-05-1100-5. Unpub- lished study prepared by Malcolm Pirnie, Inc. 32 p.

41505902 Hughes, J. (1989) The Toxicity of 2,4-D, Dimethtylamine Salt to Anabaena flosaquae: Lab Project Number: 0460-05-1100-4. Unpub- lished study prepared by Malcolm Pirnie, Inc. 33 p.

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Page 287 of 304 41732102 Hughes, J. (1990) The Toxicity of 2,4-D, Isopropylamine Salt to Selenastrum capricornutum: Lab Project Number: B460-10-1. Un- published study prepared by Malcolm Pirnie, Inc. 34 p.

43488602 Hughes, J.; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D TIPA to Lemna gibba: Lab Project Number: 10-02-4: ES-2838. Unpublished study prepared by Carolina Ecotox, Inc. 66 p.

41732101 Hughes, J. (1990) The Toxicity of 2,4-D, Triisopropanolamine Salt to Selenastrum capricornutum: Lab Project Number: B460-09-1. Unpublished study prepared by Malcolm Pirnie, Inc. 34 p.

43488603 Hughes, J.; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D TIPA to Skeletonema costatum: Lab Project Number: 10-02-3: ES-2837. Unpublished study prepared by Carolina Ecotox, Inc. 65 p.

43488601 Hughes, J.; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D TIPA to Navicula pelliculosa: Lab Project Number: 10-02-2: ES-2836. Unpublished study prepared by Carolina Ecotox, Inc. 66 p.

43488604 Hughes, J.; Williams, T.; Conder, L. (1994) The Toxicity of 2,4-D TIPA to Anabaena flos-aquae: Lab Project Number: 10-02-1: ES-2807. Unpublished study prepared by Carolina Ecotox, Inc. 64 p.

43188201 Selim, S. (1994) Hydrolysis of Pyrethrin 1 as a Function of pH at 25 degrees C: Lab Project Number: P1092011: 93-1147.BTC. Unpublished study prepared by Biological Test Center. 83 p.

42068403 Hughes, J. (1990) The Toxicity of 2,4-D, Butoxyethyl Ester to Navi- cula pelliculosa: Lab Project Number: B460-08-2. Unpublished study prepared by Malcolm Pirnie, Inc. 35 p.

41735203 Hughes, J. (1990) The Toxicity of 2,4-D,2-Ethylhexyl Ester to Lemna gibba: Lab Project Number: B460-07-4. Unpublished study pre- pared by Malcolm Pirnie, Inc. 36 p.

41735206 Hughes, J. (1990) The Toxicity of 2,4-D,2-Ethylhexyl Ester to Sele- nastrum capricornutum: Lab Project Number: 0460-05-1100-2. Un- published study prepared by Malcolm Pirnie, Inc. 38 p.

41735204 Hughes, J. (1990) The Toxicity of 2,4-D ,2-Ethylhexyl to Skeletonema costatum: Lab Project Number: B460-07-3. Unpublished study pre- pared by Malcolm Pirnie, Inc. 38 p.

41735205 Hughes, J. (1990) The Toxicity of 2,4-D,2-Ethylhexyl Ester to Navi- cula pelliculosa: Lab Project Number: B460-07-2. Unpublished study prepared by Malcolm Pirnie, Inc. 38 p.

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Page 288 of 304 41735202 Hughes, J. (1990) The Toxicity of 2,4-D,2-Ethylhexyl Ester to Ana- baena flosaquae: Lab Project Number: B460-07-1. Unpublished study prepared by Malcolm Pirnie, Inc. 37 p.

0016000 Shell Chemical Company (1975) Data Supporting the Use of Nudrin 1.8 Insecticide Solution for the Control of Insect Pests on Squash. Summary of studies 232410-T through 232410-V. (Unpublished study received Jun 29, 1976 under 201-347; CDL:232410-B)

41975101 Campbell, S.; Grimes, J.; Smith, G. (1991) Diethanolamine Salt of 2,4-D: An Acute Toxicity Study with the Northern Bobwhite: Lab Project Number: 281- 109. Unpublished study prepared by Wildlife International. 29 p.

41546201 Hoxter, K.; Culotta, J.; Jaber, M. (1990) An Acute Oral Toxicity Study with the Northern Bobwhite: Final Report: Lab Project Num- ber: 103-310. Unpublished study prepared by Wildlife Inter- national Ltd. 21 p.

00138871 Beavers, J.; Jaber, M.; Joiner, G.; et al. (1983) An Acute Oral Toxicity Study in the Mallard with 2,4-D Isopropylamine Salt: Project No. 103-226. Final rept. (Unpublished study received Jan 18, 1984 under 464-596; prepared by Wildlife International Ltd., submitted by Dow Chemical U.S.A., Midland, MI; CDL: 252291-F)

41644401 Culotta, J.; Campbell, S.; Hoxter, K. et al. (1990) 2,4-Dichloro- phenoxyacetic Acid, Triisopropanolamine Salt: An Acute Oral Toxicity Study with the Northern Bobwhite: Lab Project Number: 103/329. Unpublished study prepared by Wildlife International Ltd. 19 p.

41454101 Lloyd, D.; Grimes, J.; Hoxter, K. (1990) 2, 4-Dichlorophenoxy- acetic Acid, Butoxyethyl Ester: An Acute Oral Toxicity Study with the Northern Bobwhite: Final Report: Lab Project Number: 103-318. Unpublished study prepared by Wildlife International Ltd. 20 p.

41158303 Beavers, J. (1984) (2,4-Dichlorophenoxy) Acetic Acid Isooctyl Ester: An Acute Oral Toxicity Study with the Mallard: Project Study ID: 103-229. Unpublished study prepared by Wildlife International Ltd. 20 p.

72472 Gleich, J.; Wei?ss|e, G.; Unkelbach, H.D.; et al. (1981) Teratogen- icity Study in Himalayan Rabbits after Oral Administration: Experiment No. T 9127. (Translation; unpublished study re- ceived Mar 31, 1981 under 21137-4; prepared by E. Merck, W. Germany, submitted by EM Laboratories, Inc., Elmsford, N.Y.; CDL:244977-A)

43935001 Palmer, S.; Beavers, J. (1996) 2,4-D Isopropyl Ester: An Acute Oral Toxicity Study with the Northern Bobwhite: Lab Project Number: 435-103: 435/100295/QLD.NC/CHP105. Unpublished study prepared by Wildlife International Ltd. 50 p.

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Page 289 of 304 41586101 Culotta, J.; Hoxter, K.; Foster, J.; et al. (1990) 2,4-D (2,4-Dich- loroxyacetic Acid): A Dietary LC50 Study with the Northern Bob- white. Lab Project Number: 103-306. Unpublished study prepared by Wildlife International Ltd. 55

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41546202 Culotta, J.; Foster, J.; Grimes, J. et al. (1990) A Dietary LC50 Study with the Mallard: Lab Project Number: 103-307. Unpub- lished study prepared by Wildlife International Ltd. 42 p.

41975102 Hoxter, K.; Grimes, J.; Smith, G. ; et al. (1991) Diethanolamine Salt of 2,4-D: A Dietary LC50 Study with the Northhern Bobwhite: Lab Project Number: 281- 107. Unpublished study prepared by Wil- dlife International. 32 p.

41975103 Hoxter, K.; Grimes, J.; Smith, G.; et al. (1991) Diethanolamine Salt of 2,4-D: A Dietary LC50 Study with the Northern Bobwhite: Lab Project Number: 281- 108. Unpublished study prepared by Wil- dlife International. 32 p.

41749501 Long, R.; Foster, J.; Hoxter, K.; et al. (1990) 2,4-D Dimethylamine Salt: A Dietary LC50 Study with the Northern Bobwhite: Lab Pro- ject Number: 103- 308. Unpublished study prepared by Wildlife International Ltd. 42 p.

41749502 Long, R.; Foster, J.; Hoxter, K.; et al. (1990) 2,4-D Dimethylamine Salt: A Dietary LC50 Study with the Northern Bobwhite: Lab Pro- ject Number: 103- 309. Unpublished study prepared by Wildlife International Ltd. 42 p.

00138870 Beavers, J.; Jaber, M.; Joiner, G.; et al. (1983) A Dietary LC50 in the Bobwhite with 2,4-D Isopropylamine Salt: Project No. 103- 224. Final rept. (Unpublished study received Jan 18, 1984 un- der 464-596; prepared by Wildlife International Ltd., submitted by Dow Chemical U.S.A., Midland, MI; CDL:252291-E)

00138872 Beavers, J.; Jaber, M.; Joiner, G.; et al. (1983) A Dietary LC50 in the Mallard with 2,4-D Isopropylamine Salt: Project No. 103-225. Final rept. (Unpublished study received Jan 18, 1984 under 464- 596; prepared by Wildlife International Ltd., submitted by Dow Chemical U.S.A., Midland, MI; CDL:252291-G)

41644402 Driscoll, C.; Foster, J.; Hoxter, K. et al. (1990) 2,4-Dichlorophe- noxyacetic Acid, Triisopropanolamine Salt: A Dietary LC50 Study with the Northern Bobwhite: Lab Project Number: 103/327. Unpub- lished study prepared by WildLife International Ltd. 17 p.

41644403 Driscoll, C.; Foster, J.; Hoxter, K. et al. (1990) 2,4-Dichlorophe- noxyacetic Acid, Triisopropanolamine Salt: A Dietary LC50 Study with the Mallard: Lab Project Number: 103/328. Unpublished study prepared by Wildlife International Ltd. 17 p.

41448401 Grimes, J.; Culotta, J.; Hoxter, K.; et al. (1990) 2,4-Dichloro- phenoxyacetate Acid, Butoxyethyl Ester: A Dietary LC 50 Study with the Northern Bobwhite: Lab Project Number: 103-316. Unpub- lished study prepared by Wildlife International Ltd. 20 p.

### 2,4-D Bibliography

Page 290 of 304 41429007 Grimes, J.; Culotta, J.; Hoxter, K. et al. (1990) 2,4-Dichlorophe- noxyacetic Acid, Butoxyethyl Ester: A Dietary LC 50 Study with the Mallard: Lab Project Number: 103-317. Unpublished study prepared by Wildlife International Ltd. 20

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41158305 Beavers, J. (1984) (2,4-Dichlorophenoxy) Acetic Acid Isooctyl Ester: A Dietary LC50 Study with the Bobwhite Quail: Project Study ID: 103-227. Unpublished study prepared by Wildlife International Ltd. 16 p.

45070 Fink, R. (1976) Final Report: Eight-Day Dietary LC50--Mallard Duck: Project No. 117-114. (Unpublished study received Oct 28, 1976 under 400-134; prepared by Wildlife International, Ltd., sub- mitted by Uniroyal Chemical, Bethany, Conn.; CDL:226397-E)

41158304 Beavers, J. (1984) (2,4-Dichlorophenoxy) Acetic Acid Isooctyl Ester: A Dietary LC50 Study with the Mallard: Project Study ID: 103-228. Unpublished study prepared by Wildlife International Ltd. 17 p.

43934901 Palmer, S.; Beavers, J. (1996) 2,4-D Isopropyl Ester: A Dietary LC50 Study with the Northern Bobwhite: Lab Project Number: 435-101: WIL-233002: 435/100292/QLCSDT.WC/CHP105. Unpublished study prepared by Wildlife International Ltd. 68 p.

43935201 Palmer, S.; Beavers, J. (1996) 2,4-D Isopropyl Ester: A Dietary LC50 Study with the Mallard: Lab Project Number: 435-102: 435/100295/MLCSDT.WC/CHP105. Unpublished study prepared by Wildlife International Ltd. 68 p.

45336401 Mitchell, L.; Beavers, J.; Martin, K. et al. (1999) 2,4-D Acid: A Reproduction Study with the Northern Bobwhite: Final Report: Lab Project Number: 467-106. Unpublished study prepared by Wildlife International, Ltd. 181 p.

44517304 Palmer, S.; Krueger, H. (1997) 2,4-D Dimethylamine Salt: An Acute Contact Toxicity Study with the Honey Bee: Lab Project Number: 467-102: 467/052297/BLDNC.EFA/SUB467. Unpublished study prepared by Wildlife International Ltd. 32 p. {OPPTS 850.3020}

44517301 Palmer, S.; Krueger, H. (1997) 2,4-D 2-Ethylhexyl Ester: An Acute Contact Toxicity Study with the Honey Bee: Lab Project Number: 467-104. Unpublished study prepared by Wildlife International Ltd. 34 p._{OPPTS 850.3020}

42416802 Backus, P. (1992) Effect of 2,4-D Acid on Seed Germination/Seedling Emergence: Tier II: Lab Proj ect Number: 5097-91-0389-BE-001: 91-0389. Unpublished study prepared by Ricerca, Inc. 223 p.

42416801 Backus, P. (1992) Effect of 2,4-D Acid on Vegetative Vigor of Plants: Tier II: Lab Project Number: 91-0390: 5097-91-0390-BE-001. Unpublished study prepared by Ricerca, Inc. 124 p.

### 2,4-D Bibliography

Page 291 of 304 42609101 Backus, P. (1992) Effect of 2,4-D DEAS on Seed Germination/Seedling Emergence (Tier II): Lab Project Number: 5283-92-0155-BE-001: 92-0155. Unpublished study prepared by Ricerca, Inc. 210 p.Page 292 of 304 Appendix E. Generic Data Call-InPage 293 of 304 Appendix E.

The generic data call-in will be posted at a later date.Page 294 of 304 Appendix F. Product Specific Data Call-InPage 295 of 304 Appendix F.

The product specific data call-in will be posted at a later date.Page 296 of 304 Appendix G. EPA’s Batching of 2,4-D Pr oducts for Meeting Acute Toxicity Data Requirements for ReregistrationPage 297 of 304 Appendix G.

The batching of 2,4-D products for meeting acute toxicity data requirements for reregistration will be posted at a later date.Page 298 of 304 Appendix H. List of Registrants Sent This Data Call-InPage 299 of 304 Appendix H.

A list of registrants sent this data call-in will be posted at a later date.Page 300 of 304 Appendix I. List Of Available Related Docu ments And Electronically Available FormsPage 301 of 304 Appendix I. LIST OF AVAILABLE RELATED DOCUMENTS AND ELECTRONICALLY AVAILABLE FORMS

Pesticide Registration Forms are available at the following EPA internet site:

http://www.epa.gov/opprd001/forms/

Pesticide Registration Forms (These forms are in PDF format and require the Acrobat reader)

Instructions

1. Print out and complete the forms. (Note: Form numbers that are bolded can be filled out on your computer then printed.)

2. The completed form(s) should be submitted in hardcopy in accord with the existing policy.

3. Mail the forms, along with any additional documents necessary to comply with EPA regulations covering your request, to the address below for the Document Processing Desk.

DO NOT fax or e-mail any form containing 'Confidential Business Information' or 'Sensitive Information.'

If you have any problems accessing these forms, please contact Nicole Williams at (703) 308-5551 or by e-mail at williams.nicole@epa.gov.

The following Agency Pesticide Registration Forms are currently available via the internet: at the following locations:

8570-1 Application for Pesticide Registration/Amendment http://www.epa.gov/opprd001/forms/8570-1.pdf

8570-4 Confidential Statement of Formula http://www.epa.gov/opprd001/forms/8570-4.pdf

8570-5 Notice of Supplemental Registration of Distribution of a Registered Pesticide Product http://www.epa.gov/opprd001/forms/8570-5.pdf

8570-17 Application for an Experimental Use Permit http://www.epa.gov/opprd001/forms/8570-17.pdf

8570-25 Application for/Notification of State Registration of a Pesticide To Meet a Special Local Need http://www.epa.gov/opprd001/forms/8570-25.pdf

8570-27 Formulator's Exemption Statement http://www.epa.gov/opprd001/forms/8570-27.pdf

8570-28 Certification of Compliance with Data Gap Procedures http://www.epa.gov/opprd001/forms/8570-28.pdf

8570-30 Pesticide Registration Maintenance Fee Filing http://www.epa.gov/opprd001/forms/8570-30.pdf

8570-32 Certification of Attempt to Enter into an Agreement with other Registrants for Development of Data http://www.epa.gov/opprd001/forms/8570-32.pdf

8570-34 Certification with Respect to Citations of Data (PR Notice 98-5) http://www.epa.gov/opppmsd1/PR_Notices/pr98- 5.pdfPage 302 of 304 8570-35 Data Matrix (PR Notice 98-5) http://www.epa.gov/opppmsd1/PR_Notices/pr98- 5.pdf
8570-36 Summary of the Physical/Chemical Properties (PR Notice 98-1) http://www.epa.gov/opppmsd1/PR_Notices/pr98- 1.pdf

8570-37 Self-Certification Statement for the Physical/Chemical Properties (PR Notice 98-1) http://www.epa.gov/opppmsd1/PR_Notices/pr98- 1.pdf

Pesticide Registration Kit www.epa.gov/pesticides/registrationkit/

Dear Registrant:

For your convenience, we have assembled an online registration kit which contains the following pertinent forms and information needed to register a pesticide product with the U.S. Environmental Protection Agency's Office of Pesticide Programs (OPP):

1. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug and Cosmetic Act (FFDCA) as Amended by the Food Quality Protection Act (FQPA) of 1996.

2. Pesticide Registration (PR) Notices

a. 83-3 Label Improvement Program--Storage and Disposal Statements b. 84-1 Clarification of Label Improvement Program c. 86-5 Standard Format for Data Submitted under FIFRA d. 87-1 Label Improvement Program for Pesticides Applied through Irrigation Systems (Chemigation) e. 87-6 Inert Ingredients in Pesticide Products Policy Statement f. 90-1 Inert Ingredients in Pesticide Products; Revised Policy Statement g. 95-2 Notifications, Non-notifications, and Minor Formulation Amendments h. 98-1 Self Certification of Product Chem istry Data with Attachments (This document is in PDF format and requires the Acrobat reader.)

Other PR Notices can be found at http://www.epa.gov/opppmsd1/PR_Notices

3. Pesticide Product Registration Application Forms (These forms are in PDF format and will require the Acrobat reader).

a. EPA Form No. 8570-1, Application for Pesticide Registration/Amendment b. EPA Form No. 8570-4, Confidential Statement of Formula c. EPA Form No. 8570-27, Formulator's Exemption Statement d. EPA Form No. 8570-34, Certification w ith Respect to Citations of Data e. EPA Form No. 8570-35, Data Matrix

4. General Pesticide Information (Some of these forms are in PDF format and will require the Acrobat reader).

a. Registration Division Personnel Contact List b. Biopesticides and Pollution Prevention Division (BPPD) Contacts c. Antimicrobials Division Organi zational Structure/Contact List d. 53 F.R. 15952, Pesticide Registration Procedures; Pesticide Data Requirements (PDF format) e. 40 CFR Part 156, Labeling Requirements for Pesticides and Devices (PDF format)

f. 40 CFR Part 158, Data Requirements for Registration (PDF format) g. 50 F.R. 48833, Disclosure of Reviews of Pesticide Data (November 27, 1985)Page 303 of 304 Before submitting your application for registration, you may wish to consult some additional sources of information. These include:

1. The Office of Pesticide Programs' website.

2. The booklet "General Information on Applying for Registration of Pesticides in the United States", PB92-221811, available through the National Technical Information Service (NTIS) at the following address:

National Technical Information Service (NTIS) 5285 Port Royal Road Springfield, VA 22161

The telephone number for NTIS is (703) 605-6000.

3. The National Pesticide Information Retrieval System (NPIRS) of Purdue University's Center for Environmental and Regulatory Information Systems. This service does charge a fee for subscriptions and custom searches. You can contact NPIRS by telephone at (765) 494-6614 or through their website.

4. The National Pesticide Telecommunications Network (NPTN) can provide information on active ingredients, uses, toxicology, and chemistry of pesticides. You can contact NPTN by telephone at (800) 858-7378 or through their website: ace.orst.edu/info/nptn.

The Agency will return a notice of receipt of an application for registration or amended registration, experimental use permit, or amendment to a petition if the applicant or petitioner encloses with his submission a stamped, self-addressed postcard. The postcard must contain the following entries to be completed by OPP:

• Date of receipt; • EPA identifying number; and • Product Manager assignment.

Other identifying information may be included by the applicant to link the acknowledgment of receipt to the specific application submitted. EPA will stamp the date of receipt and provide the EPA identifying file symbol or petition number for the new submission. The identifying number should be used whenever you contact the Agency concerning an application for registration, experimental use permit, or tolerance petition.

To assist us in ensuring that all data you have submitted for the chemical are properly coded and assigned to your company, please include a list of all synonyms, common and trade names, company experimental codes, and other names which identify the chemical (including "blind" codes used when a sample was submitted for testing by commercial or academic facilities). Please provide a chemical abstract system (CAS) number if one has been assigned.

Documents Associated with this RED

The following documents are part of the Administrative Record for this RED document and may be included in the EPA's Office of Pesticid e Programs Public Docket. Copies of these documents are not available electronically, but may be obtained by contacting the person listed on the respective Chemical Status Sheet.

1. Detailed Label Usage Information System (LUIS) Report.Page 304 of 304