BIOPESTICIDES REGISTRATION ACTION DOCUMENT 

Salicylic Acid

PC Code: 076602

U.S. Environmental Protection Agency

Office of Pesticide Programs

Biopesticides and Pollution Prevention Division

January 10, 2012
Salicylic Acid Page 2 

Biopesticides Registration Action Document

TABLE OF CONTENTS

I. EXECUTIVE SUMMARY .................................................................................................... 4

II. ACTIVE INGREDIENT OVERVIEW................................................................................. 5

III. REGULATORY BACKGROUND........................................................................................ 5

 

A. Classification................................................................................................................................................5

B. Food Clearances/Tolerances.......................................................................................................................6

IV. RISK ASSESSMENT ............................................................................................................. 6

A. Product Analysis Assessment .....................................................................................................................7

B. Human Health Assessment .........................................................................................................................8

C. Environmental Assessment.......................................................................................................................15

V. ENVIRONMENTAL JUSTICE ............................................................................................ 18

VI. RISK MANAGEMENT AND REGISTRATION DECISIONS ....................................... 18

A. Determination of Eligibility ......................................................................................................................19

B. Regulatory Decision...................................................................................................................................19

C. Labeling......................................................................................................................................................19

VII. ACTIONS REQUIRED OF THE REGISTRANT ........................................................... 19

A. Reporting of Adverse Effects and Hypersensitivity Incidents...............................................................20

VIII. GLOSSARY OF ACRONYMS AND ABBREVIATIONS............................................... 20

IX. BIBLIOGRAPHY STUDIES SUBMITTED IN SUPPORT OF THESE 

REGISTRATIONS ............................................................................................................... 21

A. Studies Submitted in Support of Salicylic Acid. .....................................................................................21

B. EPA Risk Assessment Memoranda..........................................................................................................28

C. References ..................................................................................................................................................28
Salicylic Acid Page 3 

Biopesticides Registration Action Document

BIOPESTICIDES REGISTRATION ACTION DOCUMENT TEAM

Office of Pesticide Programs

Biopesticides and Pollution Prevention Division

Biochemical Pesticides Branch (BPB)

Chris Pfeifer Regulatory Action Leader

Linda Hollis Branch Chief

Angela Gonzales Lead Science Reviewer

Russell Jones, Ph.D. Senior Biologist
Salicylic Acid Page 4 

Biopesticides Registration Action Document

I. EXECUTIVE SUMMARY

Salicylic Acid is a naturally occurring plant regulator present in most plants. Data indicate that it 

triggers immune responses in plants and acts as a mild antibiotic. Humans consume Salicylic Acid 

regularly as it is naturally present in most fruits and vegetables. In its concentrated state, it is a 

white crystalline powder with a sweetish acrid taste. It is known for its many useful ester 

derivatives and can be found in a range of commercial products such as antiseptics, preservatives, 

and medicines. Salicylic Acid is perhaps best known as the principal metabolite and component of 

aspirin. Humans have a long history of natural exposure to Salicylic Acid without incident.

As an active ingredient, it is intended for use as a treatment for seeds that are not meant for human 

or animal consumption. Its mode of action is as a Systemic Acquired Resistance (SAR) inducer for 

seedlings – i.e. a trigger for invoking a seedling’s natural defenses against pathogens, allowing for 

greater plant vigor and survivability. Because there are no residues taken up systemically, and 

treated seeds are not allowed for food or feed uses, this seed treatment is not considered to be a 

food use. 

Negligible dietary exposures to the pesticidal active ingredient notwithstanding, there are few 

apparent risks related to regular exposure to this natural acid. Data from a Dutch Food 

Consumption Survey show the average daily intake (ADI) for this chemical has been estimated to 

be 0-5 milligrams per day from the consumption of fruits and vegetables. Also, consumption of 

Salicylic Acid in aspirin exposes a person to greater doses than would any potential residues 

associated with seed treatment. (HSDB, 2008) Furthermore, Salicylic Acid is approved for use by 

the U.S. Food and Drug Administration (FDA) as an indirect food additive under 21 CFR 175.105; 

and the U.S. Environmental Protection Agency (EPA or Agency) has approved the use of the 

chemical as an ‘other ingredient’ in pesticide products. In sum, no hazards have been identified yet

with regard to any of these regular exposures.

Moreover, data demonstrate that Salicylic Acid poses minimal hazards for humans and the 

environment. Acute human health toxicity data indicate negligible human toxicity for all routes of 

exposure. Acute nontarget organism toxicology data indicate marginal toxicity for aquatic

organisms, birds, mammals, insects and plants. Subchronic and chronic toxicity data suggest no 

hazard relative to longer term exposures, although no long-term exposures to Salicylic Acid 

formulated as a pesticidal active ingredient are anticipated given that Salicylic Acid biodegrades 

rapidly. No human health or environmental risks are anticipated for Salicylic Acid due to its low 

toxicity and minimal opportunity for significant exposure. 

On October 1, 2009, the EPA announced a new policy to provide a more meaningful opportunity

for the public to participate in major registration decisions before they occur. According to this 

policy, EPA intends to provide a public comment period prior to making a registration decision 

for, at minimum, the following types of applications: new active ingredients; first food uses; first 

outdoor uses; first residential uses; or any other registration actions for which EPA believes there 

may be significant public interest.

 
Salicylic Acid Page 5 

Biopesticides Registration Action Document

Consistent with the policy of making registration actions more transparent, the proposed pesticide 

products containing Salicylic Acid, a new active ingredient, are subject to a 30-day comment 

period. In addition to containing a new active ingredient, the registration of these products would 

result in the first outdoor use for Salicylic Acid. The docket identification number associated with 

these registration actions, EPA-HQ-OPP-2011-0009, can be accessed through 

http://www.regulations.gov/. The following documents are available for comment in the docket: 

(1) Salicylic Acid Biopesticides Registration Action Document; (2) a draft label for the 

Manufacturing-use Product, EPA File Symbol 34704-RNLT; and (3) draft labels for the End-use 

Products, EPA File Symbols 34704-RNLL and 34704-RNLA. While a final decision on 

registration is contingent upon review and consideration of public comments, EPA presently

believes that, based upon the risk assessment and information submitted in support of Salicylic 

Acid, it is in the best interest of the public and the environment to issue these registrations. The 

basis for this preliminary decision can be found in the risk assessment for Salicylic Acid, which is 

presented in this document. 

II. ACTIVE INGREDIENT OVERVIEW

Common Name: Salicylic Acid

Chemical Names: 2-Hydroxybenzoic acid, Carboxylic Acid

Trade & Other Names: Salicylic Acid, SA

CAS Registry Number: 69-72-7

OPP Chemical Code: 076602

Type of Pesticide: Plant Regulator 

III. REGULATORY BACKGROUND

On February 2, 2011, EPA published in the Federal Register (76 FR 5805) a notice announcing 

that Loveland Products, Inc., c/o Pyxis Consulting, Inc., 4110 136th St., NW., Gig Harbor, WA 

98332, submitted an application to register a Manufacturing-use Product (MP), EPA File Symbol 

34704-RNLT, and two End-use Products (EPs), EPA File Symbols 34704-RNLL and 34704-

RNLA, containing a new active ingredient (Salicylic Acid) not included in any currently registered 

products. No comments were received following publication of the notice.

A. CLASSIFICATION 

Salicylic Acid was classified as a Biochemical Pesticide by the Classification Committee on 

November 20, 1997. The Classification Committee confirmed its nontoxic mode of action, its 
Salicylic Acid Page 6 

Biopesticides Registration Action Document

natural occurrence in the environment, and its history of exposure to humans and the environment 

without known toxicity. 

Salicylic Acid is a naturally occurring plant hormone present in all terrestrial plants. Historically, it 

has been commercially distilled from willow bark, where it is found in high concentration. With 

regard to its active properties, Salicylic Acid is a plant regulator that has mediating roles on plant 

growth, photosynthesis, transpiration, and ion uptake. When applied to seeds as an active 

ingredient, Salicylic Acid acts as a SAR inducer – i.e. it triggers a plants immuno-defense system 

to defend against pathogens, allowing for greater survivability of seedlings.

B. FOOD CLEARANCES/TOLERANCES 

Salicylic Acid is intended for use as a seed treatment for nonfood and nonfeed uses (i.e. treated 

seeds are not for animal or human consumption). Because no residues are systemically expressed 

through the planted seed to the fruit and vegetables, the use of Salicylic Acid is not considered to 

be a food use.

IV. RISK ASSESSMENT

On October 26, 2007, the Agency issued a Final Rule in the Federal Register on the data 

requirements to support registration of biochemical and microbial pesticides, and updated the 

definitions for biochemical and microbial pesticides (72 FR 61002). The rule became effective on 

December 26, 2007. The data and information evaluated for this Biopesticides Registration Action 

Document (BRAD) were considered in light of these requirements.

The classifications that are found for each data submission are assigned by EPA science reviewers 

and are an indication of the usefulness of the information contained in the documents for risk 

assessment. A rating of “ACCEPTABLE” indicates the study is scientifically sound and is useful 

for risk assessment. A “SUPPLEMENTAL” rating indicates the data provide some information 

that can be useful for risk assessment. The studies may have certain aspects determined not to be 

scientifically acceptable (“SUPPLEMENTAL: UPGRADABLE”). If a study is rated as 

“SUPPLEMENTAL: UPGRADABLE,” EPA always provides an indication of what is lacking or 

what can be provided to change the rating to “ACCEPTABLE.” If there is simply a 

“SUPPLEMENTAL” rating, the reviewer will often state that the study is not required by the 

current 40 CFR Part 158. Both “ACCEPTABLE” and “SUPPLEMENTAL” studies may be used 

in the risk assessment process as appropriate. An “UNACCEPTABLE” rating indicates that new 

data need to be submitted.

For the acute toxicity data requirements, Toxicity Categories are assigned for providing the 

appropriate precautionary labeling statements and are based on the hazard(s) identified from 

studies and/or other information submitted to EPA in support of a pesticide registration. The active 

ingredient or a particular product is classified into Toxicity Category I, II, III, or IV, where 

Toxicity Category I indicates the highest toxicity and Toxicity Category IV indicates the lowest 

toxicity. 
Salicylic Acid Page 7 

Biopesticides Registration Action Document

A. PRODUCT ANALYSIS ASESSMENT

1. Product Chemistry and Composition

Salicylic Acid (2-hydroxybenzoic acid) is an aromatic carboxylic acid that is commercially derived 

from the bark of the willow tree. It is a naturally occurring plant regulator with various roles 

regulating photosynthesis and transpiration and mediating plant defenses against pathogens (U.S. 

EPA. 2011b.). In purest form, it is a white crystalline powder with a sweetish acrid flavor. It is 

used in a variety of topical cosmetics and pharmaceutical products as a mild antibiotic (HDSB, 

2011). Salicylic Acid is naturally found in significant concentrations in a wide variety of foods 

such as apples, plums, grapes, oranges, tomatoes, cinnamon, oregano, thyme, beer, honey and 

raisins (HDSB, 2011). 

All product chemistry data requirements for Salicylic Acid have been satisfied. As a manufactured

active ingredient, Salicylic Acid extract is indistinguishable from the plant hormone that is 

produced naturally in plants (MRID 47206713). The extract has a high degree of purity and 

contains no impurities of toxicological significance (MRID 47206713, 47760931 and 47206714). 

All data requirements for physical and chemical characteristics have been adequately addressed

(U.S. EPA. 2011b.). 

2. Analysis and Certification of Limits

The submitted data satisfied the requirements for Analysis and Certification of Limits. Five-batch 

analyses and the analytical method used to determine the purity of Salicylic Acid were examined 

and determined to be acceptable by the Agency. The information submitted on the analyses and 

certified limits are summarized in Table 1.

TABLE 1. Product Chemistry Data Requirements for Salicylic Acid Technical (40 CFR § 158.2030)

OSCPP Guideline No. Study Results MRID No.

880.1100

880.1200

880.1400

Product identity;

Manufacturing process;

Discussion of formation of 

impurities

Submitted data satisfy the requirements 

for product identity, manufacturing 

process, and discussion of formation of 

impurities. 

47206713

47760931

830.1700 Analysis of samples Submitted data satisfy the requirements 

for analysis of samples. 

47206714

830.1750 Certification of limits Limits listed in the confidential 

statement of formula are acceptable

47206714

830.1800 Analytical method Acceptable. 47206714

3. Physical and Chemical Characteristics

The Agency has determined that the submitted data adequately describe the physical and chemical 

characteristics of Salicylic Acid. See Table 2 below for details.

 
Salicylic Acid Page 8 

Biopesticides Registration Action Document

TABLE 2. Physical and Chemical Properties of Salicylic Acid Technical (40 CFR § 158.2030)

OCSPP 

Guideline No. 

Property Description of Result MRID No.

830.6302 Color White 48225202

830.6303 Physical State Solid crystalline powder 48225202

830.6304 Odor Odorless 48225202

830.6313

Stability to Normal and 

Elevated Temperatures, 

Metals and Metal Ions

Stable for 14 days at room temperature, degrades 

slightly (below certified limits) after 4 days at 

54oC. Data on metals were not submitted; SA is 

not stored in or expected to come into contact with 

metal or metal ions during storage or use.

48225201

48225202

830.6315 Flammability Flash point: 315oF (157oC) HSDB, 2008

830.6317 Storage Stability In progress 48225202

830.6319 Miscibility N/A: not an emulsifiable liquid that will be diluted 

with petroleum solvents. 48225202

830.6320 Corrosion Characteristics In progress 48225202

830.7000 pH 2.56 48225201

48225202

830.7050 UV/Visible Light 

Absorption

Neutral: 231 nm (ε1= 6794), 296 nm (ε = 3567)

Basic: 219.5 nm (ε = 7046), 296.5 nm (ε = 3535)

Acidic: 236.5 nm (ε = 8538), 302 nm (ε = 3632)

48225201

48225202

830.7100 Viscosity N/A: product is a solid 48225202

830.7200 Melting Point/Range 159.3-161.5 oC 48225202

830.7220 Boiling Point/Range N/A: SA is a solid 48225202

830.7300 Density 1.429 g/mL 48225202

830.7520 Particle Size, Fiber Length 

and Diameter Distribution

N/A: SA is not water insoluble nor is it a fibrous 

substance with a diameter ≥ 0.1μm.

48225202

830.7550

830.7560

830.7570

Partition Coefficient (nOctanol/Water) Log Pow = 2.148225201

48225202

830.7840 Water Solubility 1.71 mg/mL in water

0.05 g/100 mL in hexane

32.12 g/100 mL in methanol

16.02 g/100 mL in n-octanol

48225201

48225202

830.7950 Vapor Pressure 114 Pa at 130oC

8.2X10-5 mm Hg at 25oC

48225202

B. HUMAN HEALTH ASSESSMENT

1. Toxicological Hazard Assessment 

Adequate mammalian toxicology studies were provided in support of the registration of Salicylic 

Acid for each data requirement. Acute toxicology data indicates that the active ingredient is 

virtually nontoxic to mammals, and that there are no toxicological endpoints relative to its use as a

SAR-inducer in plants. Accordingly, the data submitted demonstrate that the proposed uses of 

Salicylic Acid pose no significant risks to human health and support a finding of reasonable 

certainty that no harm to the general U.S. population, including infants and children, will result 

from exposure to this active ingredient (U.S. EPA. 2011b; MRIDs 48225203-48225208).

 
Salicylic Acid Page 9 

Biopesticides Registration Action Document

Table 3. Mammalian Toxicology Data for Salicylic Acid Technical (40 CFR § 158.2050)

Study/OCSPP Guideline No. Results Toxicity 

Description MRID No.

Acute oral toxicity (rat)

(870.1100) LD50 = 890 mg/kg III 47206707

Acute dermal toxicity (rabbit)

(870.1200) LD50 > 5,050 mg/kg IV 47206711

Acute inhalation toxicity (rat)

(870.1300) LC50 > 2.21 mg/L IV 47206710

Primary eye irritation (rabbit)

(870.2400) Moderately irritating III 47206706

Primary dermal irritation (rabbit)

(870.2500) Non-irritating IV 47206709

Dermal sensitization (guinea pig)

(870.2600) Not a sensitizer N/A 47206708

Hypersensitivity incidents

(None)

Must be reported N/A

90-Day oral toxicity 

(870.3100)

Proposed products are nonfood use. Subchronic and chronic oral 

toxicity studies were submitted for methyl salicylate and 

acetylsalicylic acid, which are rapidly converted to SA and/or an SA 

ester in the body. Data indicate negligible toxicity. Risk to humans is 

not anticipated based on the lack of repeat oral exposure to SA due 

to the use pattern. 

48225204

48225206

90-Day dermal toxicity

(870.3250)

Purposeful application and prolonged exposure to the human skin is 

not anticipated based on the use pattern (seed treatment). Significant 

dermal exposure to handlers/applicators is unlikely as End-use 

Product (EP) labels require appropriate personal protective 

equipment (PPE) to mitigate dermal exposure. Risk is expected to be 

negligible based on the lack of anticipated exposure and dermal 

toxicology data. 

48225204

48225206

90-Day inhalation toxicity

(870.3465)

Significant repeat inhalation exposure to SA as a gas, vapor or 

aerosol is unlikely based on use pattern as a seed treatment and 

physical properties of the active ingredient in that it degrades rapidly 

in the environment. 

48225204

48225206

Mutagenicity-bacterial reverse 

mutation test (modified Ames)

(870.5100)

Significant human exposure is unlikely based on use pattern as a 

seed treatment and rapid biodegradation in the environment. The risk 

of mutagenicity is expected to be negligible based on the lack of 

anticipated exposure and mutagenicity data. 

HSDB, 

2011

Mutagenicity-in vitro

mammalian cell assay (870.5300 

and 870.5375)

Significant human exposure is unlikely based on use pattern as a 

seed treatment and rapid biodegradation in the environment. The risk 

of mutagenicity is expected to be negligible based on the lack of 

anticipated exposure and mutagenicity data. 

48225207

Developmental toxicity

(870.3700)

Significant exposure to female humans is unlikely based on use 

pattern as a seed treatment. Significant exposure to 

handlers/applicators is unlikely as EP labels require appropriate PPE

to mitigate exposure. Risk is expected to be negligible based on the 

lack of anticipated exposure and the available developmental 

toxicology data. 

48225205

a. Acute Toxicity – Tier I (40 CFR § 158.2050) 

Acute Oral Toxicity – Rat (OCSPP Guideline 870.1100; MRID No. 47206707): An acute oral 

toxicity study shows that the active ingredient, Salicylic Acid, has an acute oral median lethal dose

(LD50) of greater than 890 milligrams per kilogram (mg/kg) in rats. The study was found 
Salicylic Acid Page 10 

Biopesticides Registration Action Document

“ACCEPTABLE,” and Salicylic Acid was classified as TOXICITY CATEGORY III for this route 

of exposure when used as a seed treatment. 

Acute Dermal Toxicity – Rabbit (OCSPP Guideline 870.1200; MRID No. 47206711): An acute 

dermal toxicity study shows that the active ingredient, Salicylic Acid, has an LD50 of greater than 

5,050 mg/kg in rabbits, which is considered to be virtually nontoxic. Data substantiate the active 

ingredient’s relative dermal nontoxicity to both occupational users and the general public. The 

study was found “ACCEPTABLE,” and Salicylic Acid was classified as TOXICITY CATEGORY 

IV for this route of exposure when used as a seed treatment.

Acute Inhalation Toxicity – Rat (OCSPP Guideline 870.1300; MRID No. 47206710): An acute 

oral inhalation study shows that the active ingredient, Salicylic Acid, has a median lethal

concentration (LC50) of greater than 2.21 milligrams per liter (mg/L) in rats, which shows no 

significant inhalation toxicity. This was the maximum dose rate, and no toxicological effects were 

observed on the test subjects. The study was found “ACCEPTABLE,” and Salicylic Acid was 

classified as TOXICITY CATEGORY IV for this route of exposure when used as a seed 

treatment. 

Primary Eye Irritation – Rabbit (OCSPP Guideline 870.2400; MRID No. 47206706): A primary

eye irritation study on rabbits demonstrated Salicylic Acid to be moderately irritating to the eye; 

however, all iritis and conjunctivitis cleared after 24 hours. The study was found 

“ACCEPTABLE,” and Salicylic Acid was classified as TOXICITY CATEGORY III for this route 

of exposure when used as a seed treatment.

Primary Dermal Irritation – Rabbit (OCSPP Guideline 870.2500; MRID No. 47206709): A skin 

irritation study on rabbits demonstrated that Salicylic Acid was not irritating to the skin. The 

findings are consistent with the other dermal studies and confirm that Salicylic Acid is not toxic 

through this route of exposure. The study was found “ACCEPTABLE,” and Salicylic Acid was 

classified as TOXICITY CATEGORY IV for this route of exposure when used as a seed 

treatment.

Skin Sensitization – Guinea Pig (OCSPP Guideline 870.2600; MRID No. 47206708): Data 

indicate Salicylic Acid is not a dermal sensitizer. Any reported incidents, however, may cause this 

position to be reconsidered. 

Subchronic Testing (OCSPP Guidelines 870.3100, 870.3250, and 870.3465; MRID Nos. 48225204

and 48225206): In accordance with footnotes six, seven and eight in the Biochemical Pesticides 

Human Health Assessment Data Requirements table in 40 CFR § 158.2050, subchronic oral, 

subchronic dermal and subchronic inhalation testing were not required in this case because of a 

lack of exposure. Nonetheless, two subchronic oral tests, two subchronic dermal tests and one 

subchronic inhalation study were submitted. These studies are considered “SUPPLEMENTAL.” 

One subchronic oral test used methyl salicylate as its test substance; and the other study used 

acetylsalicylic acid as its test substance. Both test substances readily metabolize into Salicylic Acid 

and are considered applicable to this risk assessment. The subchronic oral toxicity studies confirm

that Salicylic Acid is not subchronically toxic through the oral route of exposure. With regard to 
Salicylic Acid Page 11 

Biopesticides Registration Action Document

subchronic dermal tests on Salicylic Acid, two studies on a Salicylic Acid test substance showed 

no systemic toxicity and indicated no subchronic toxicity through a dermal route of exposure. With 

regard to subchronic inhalation toxicity, a subchronic inhalation test on methyl salicylate was 

submitted in lieu of a study on Salicylic Acid. The supplemental information suggests that there is 

no subchronic toxicity for Salicylic Acid through an inhalation route of exposure. All this 

supplemental information is secondary to the determination that there is virtually no exposure to 

this active ingredient when it is used as a seed treatment.

Developmental Toxicity (OCSPP Guideline 870.3700; MRID No. 48225205): Developmental 

toxicity data are conditionally required if significant exposure to female humans is expected from 

the proposed product’s use under widespread and commonly recognized practice. Significant 

exposure to females is unlikely: Salicylic Acid is to be applied in a closed system that precludes 

significant exposure. Exposure to handlers/applicators is negligible as applications are seasonal,

and EP labels require appropriate PPE. Additionally, exposure during planting is unlikely because 

planting is done mechanically, users are required to wear PPE and Salicylic Acid biodegrades 

rapidly in the environment, further mitigating exposure (HSDB, 2011). Although risk to humans is 

anticipated to be negligible because significant human exposure is not anticipated, 

“SUPPLEMENTAL” developmental toxicity studies were submitted from the open scientific 

literature with MRID No. 48225205. Each study suggested that the risk for developmental toxicity

was negligible. The maternal no observed effect level (NOEL) in the study was 75 mg/kg Salicylic 

Acid, and the lowest observed effect level (LOEL) was 150 mg/kg. These findings suggest 

negligible developmental toxicity relative to any potential exposures to Salicylic Acid when used 

as a seed treatment

Mutagenicity Testing (OCSPP Guidelines 870.5100, 870.5300, and 870.5375; MRID No. 

48225207): Mutagenicity data are conditionally required to support nonfood uses if the use is 

likely to result in significant human exposure or if the active ingredient or its metabolites are 

structurally related to a known mutagen or belong to any chemical class of compounds containing 

a known mutagen. Significant exposure to humans is unlikely based on Salicylic Acid’s use pattern 

as a seed treatment. Significant exposure to handlers/applicators is unlikely as EP labels require 

PPE to further mitigate exposure. Finally, Salicylic Acid biodegrades rapidly in the environment, 

further mitigating exposure (HSDB, 2008). Although risk to humans has been determined to be 

negligible because significant human exposure is not anticipated, “SUPPLEMENTAL” 

mutagenicity data were submitted. Results were negative in a modified Ames mutagenicity assay

with and without metabolic activation at 1, 10, and 100 μg SA/plate using Salmonella typhimurium

strains TA1535, TA1537, TA1538, and TA1536 (HSDB, 2011). Furthermore, a study from the 

open scientific literature was provided in which Salicylic Acid and other Salicylic Acid derivatives 

were tested for their capacity to induce sister chromatid exchange (SCE) and chromosomal 

aberrations (CA) in the bone marrow of Swiss albino male mice. There was no increased incidence 

of SCE in the assay, indicating that Salicylic Acid is not anticipated to be mutagenic. The 

information submitted was determined to be adequate to support this seed treatment use. 

b. Acute Toxicity – Tier II and Tier III (40 CFR § 158.2050)

No Tier II and Tier III studies were required, based on a lack of acute toxicity in the Tier I studies 
Salicylic Acid Page 12 

Biopesticides Registration Action Document

and a lack of exposure relative to Salicylic Acid’s pre-planting use pattern as a seed treatment.

c. Effects on the Endocrine System

As required under Federal Food, Drug, and Cosmetic Act (FFDCA) section 408(p), EPA has 

developed the Endocrine Disruptor Screening Program (EDSP) to determine whether certain 

substances (including pesticide active and other ingredients) may have an effect in humans or 

wildlife similar to an effect produced by a “naturally occurring estrogen, or other such endocrine 

effects as the Administrator may designate.” The EDSP employs a two-tiered approach to making 

the statutorily required determinations. Tier 1 consists of a battery of 11 screening assays to 

identify the potential of a chemical substance to interact with the estrogen, androgen, or thyroid (E, 

A, or T) hormonal systems. Chemicals that go through Tier 1 screening and are found to have the 

potential to interact with E, A, or T hormonal systems will proceed to the next stage of the EDSP 

where EPA will determine which, if any, of the Tier 2 tests are necessary based on the available 

data. Tier 2 testing is designed to identify any adverse endocrine-related effects caused by the 

substance, and establish a quantitative relationship between the dose and the E, A, or T effect. 

Between October 2009 and February 2010, EPA issued test orders/data call-ins for the first group 

of 67 chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. This list of 

chemicals was selected based on the potential for human exposure through pathways such as food 

and water, residential activity, and certain post-application agricultural scenarios. This list should 

not be construed as a list of known or likely endocrine disruptors.

Salicylic Acid is not among the group of 58 pesticide active ingredients on the initial list to be 

screened under the EDSP. Under FFDCA section 408(p), EPA must screen all pesticide chemicals. 

Accordingly, EPA anticipates issuing future EDSP orders/data call-ins for all pesticide active 

ingredients. For further information on the status of the EDSP, the policies and procedures, the list 

of 67 chemicals, the test guidelines and the Tier 1 screening battery, please visit our website: 

http://www.epa.gov/endo/.

2. Dose Response Assessment 

No toxicological endpoints were identified; therefore, a dose response assessment was not 

required. 

3. Dietary Exposure and Risk Characterization

Salicylic Acid is intended for use as a pre-planting seed treatment, and is considered to be a 

nonfood use. Exposure to residues of Salicylic Acid is not expected. Data indicate that Salicylic 

Acid is not taken up into the plant systemically, and that endogenous applications biodegrade

rapidly, long before a plant might fruit. Even in the incidental event of exposure to residues, no 

dietary risks are anticipated. Acute, subchronic, and teratogenicity studies support Salicylic Acid’s 

nontoxic profile. It is already present in the human diet – in all fruits and vegetables – without any

known detrimental effect. Furthermore, there is no information in the public literature suggesting 

any health issues to either animals or plants relative to this compound. In sum, no dietary exposure 
Salicylic Acid Page 13 

Biopesticides Registration Action Document

is expected; and any potential dietary exposures would not be expected to pose any quantifiable 

risk, due to Salicylic Acid’s nontoxic profile.

4. Drinking Water Exposure Risk Characterization

No residues are expected in drinking water as a result of the use of Salicylic Acid as a seed 

treatment. Applications of Salicylic Acid are to be made directly to seeds in a closed system. Seeds 

are then planted directly into the soil. Because these seeds are contained in the soil, run-off due to 

watering seems unlikely. Even in the incidental event of exposure to residues, no dietary risks are 

anticipated. Acute, subchronic, and teratogenicity studies support Salicylic Acid’s nontoxic profile. 

It is already present in the human diet – in all fruits and vegetables – without any known 

detrimental effect. Furthermore, there is no information in the public literature suggesting any

health issues to either animals or plants relative to this compound. Negligible residues might 

migrate through the soil after a rain event or watering but would not be expected to reach surface

water or percolate through the soil to ground water given the rapid biodegradation of Salicylic 

Acid and the rapid metabolization of Salicylic Acid by soil microbes. Therefore, the Agency

concludes that the use of Salicylic Acid as a pre-planting seed treatment is not expected to result in 

any significant drinking water exposure. Altogether, drinking water exposure is not expected to 

pose any quantifiable risk, due to both a lack of residues and the nontoxicity of Salicylic Acid.

5. Acute and Chronic Dietary Exposure and Risks for Sensitive Subpopulations, 

Particularly Infants and Children

Dietary exposure to humans, including infants and children, is not anticipated with regard to the 

pesticidal use of Salicylic Acid as a seed treatment. The application is considered a nonfood use

because the residue is not expressed systemically into the plant; and the active ingredient is 

expected to biodegrade soon after planting. In the event that there are any residues, acute toxicity

studies indicate that Salicylic Acid has negligible toxicity. It is ubiquitous in nature and present in 

all edible plants, and there is no history of toxicological incident involving its consumption. While 

no dietary exposures are expected, the Agency has determined there is a reasonable certainty of no 

harm to the general U.S. population, including infants and children, from exposure to this active 

ingredient.

6. Occupational, Residential, School and Day Care Exposure and Risk 

Characterization

Occupational exposure to Salicylic Acid is anticipated to be minimal when Salicylic Acid is used 

as a seed treatment. It is expected to be de minimis for residential, school, or day care areas. In the 

event of incidental exposure, health risks to humans, including infants and children, are considered 

negligible, given Salicylic Acid’s nontoxic profile. 

a. Occupational Exposure and Risk Characterization

An occupational exposure assessment was not conducted for Salicylic Acid. Based on the 

proposed use pattern and toxicity data available to the Agency, there are no exposure scenarios
Salicylic Acid Page 14 

Biopesticides Registration Action Document

likely to result in unreasonable risk to humans. With regard to risks to incidental exposure, no 

relevant toxicological endpoints were identified.

The rationale follows: Seeds are treated in a closed system; and then seeds are incorporated 

directly into the soil. Pre-planting seed treatments are infrequent and seasonal. Workers treating 

seeds and workers planting treated seed will have PPE. Finally, given the rapid rate of 

biodegradation, incidental exposures related to reentry into a newly planted area are anticipated to 

be negligible (U.S. EPA. 2011b.). But even in the event of occupational exposure, any health risks 

associated with regular exposure seem unlikely. People regularly consume Salicylic Acid in their 

fruits and vegetables, and apply it topically in many over-the-counter antiseptics, antibiotics and 

cleaners. With regard to these regular exposures, there is no history of detrimental effects. 

Moreover, all acute, subchronic, and developmental toxicity data submitted to support the 

registration applications for Salicylic Acid confirm its lack of toxicity through all routes of 

exposure. 

b. Residential, School, and Day Care Exposure and Risk Characterization

A residential, school and day care exposure assessment was not conducted for Salicylic Acid. 

Products containing Salicylic Acid will be used in an agricultural setting. Based on the use pattern, 

residential, school and day care exposures are unlikely. In the remote event of incidental exposure 

to residues, the active ingredient has a nontoxic profile for all routes of exposure and a long history

of consumption without incident. Due to limited exposure scenarios and negligible toxicity

hazards, no risks are expected relative to these exposure scenarios. 

7. Aggregate Exposure from Multiple Routes Including Dermal, Oral, and 

Inhalation

The potential for aggregate exposure is expected to be insignificant. No exposures are anticipated 

in non-occupational environments. Seeds treated with Salicylic Acid are incorporated into the soil 

directly. It has been established that Salicylic Acid biodegrades rapidly in soil; and the residues are 

not taken up into the plant systemically (HDSB, 2008). (Indeed, no residues are expected to be 

present in the seedlings.) Given a lack of any significant non-occupational exposure, a lack of 

concern regarding its naturally occurring background levels, and a lack of any acute toxicological 

endpoints for Salicylic Acid, the aggregate exposure scenario presents no significant concerns for 

risk.

8. Cumulative Effects

Pursuant to FFDCA section 408(b)(2)(D)(v), EPA has considered available information 

concerning the cumulative effects of Salicylic Acid residues and other substances that have a 

common mechanism of toxicity. These considerations include the potential for cumulative effects 

on infants and children of Salicylic Acid residues and other substances with a common mechanism 

of toxicity. Because Salicylic Acid has a long history of dietary consumption without incident, and 

because no toxicological endpoints have been established, the Agency concludes that Salicylic 
Salicylic Acid Page 15 

Biopesticides Registration Action Document

Acid does not share a common mechanism of toxicity, and that there are no potential cumulative 

effects arising from incidental exposures to Salicylic Acid residues in or on food commodities.

9. Risk Characterization

The Agency considered human exposure to Salicylic Acid in light of the standard for registration 

in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the relevant safety factors 

in FFDCA. A determination has been made that no unreasonable adverse effects to the U.S. 

population in general, and to infants and children in particular, will result from the use of Salicylic 

Acid when label instructions are followed. 

C. ENVIRONMENTAL ASSESSMENT

1. Ecological Hazards (Relative to the Biochemical Pesticides Nontarget Organisms 

and Environmental Fate Data Requirements - 40 CFR § 158.2060)

Adequate nontarget toxicology data/information are available to support registration of Salicylic 

Acid. All nontarget toxicology data requirements for Salicylic Acid have been satisfied. There are 

no concerns for any nontarget organisms when Salicylic Acid is applied as a seed treatment. No 

toxic endpoints have been identified for nontarget mammals, nontarget birds, nontarget aquatic 

organisms and nontarget insects. 
Salicylic Acid Page 16 

Biopesticides Registration Action Document

Avian Testing (OCSPP Guidelines 850.2100 and 850.2200; MRID Nos. 47206704 and 47206702): 

No avian toxicity is expected with regard to the pesticidal use of Salicylic Acid. Two acute oral 

toxicity studies were found “ACCEPTABLE.” The studies established the following thresholds:

LD50 = 494 mg/kg, an LC50 > 5,000 ppm, and an NOAEL = 2,500 ppm. Each threshold is far in 

excess of any anticipated exposure; and no toxicological endpoints were established. The data 

indicate that Salicylic Acid is practically nontoxic to birds.

Aquatic Organism Testing (OCSPP Guidelines 850.1010 and 850.1075; MRID Nos. 47206703 and 

47206705): No risks are expected with regard to the exposure of aquatic organisms to Salicylic 

Acid. Aquatic exposure is unlikely because seed treatments are conducted in closed systems, 

treated seeds are incorporated directly into soil, and Salicylic Acid is known to rapidly biodegrade 

in soil. In the event of any aquatic exposures, the data indicate that Salicylic Acid is practically 

nontoxic to aquatic organisms. A nontarget aquatic invertebrate study and a freshwater fish study

were found “ACCEPTABLE.” The studies established the following thresholds: LC50 = 134.8 

mg/L and an EC50 > 184.88 mg/L. Each threshold is far in excess of any anticipated exposure; and 

no toxicological endpoints were established. The data indicate that Salicylic Acid is practically

nontoxic to aquatic nontarget organisms.

TABLE 4. Nontarget Organism Toxicity Requirements for Salicylic Acid Technical (40 CFR § 158.2060)

Study/OCSPP Guideline No. Results Toxicity 

Category/Description

MRID

No.

Avian acute oral toxicity

Colinus virginianus

(850.2100)

LD50 = 494 mg/kg

(95% confidence interval = 396-614 mg/kg) Moderately toxic 47206704

Avian dietary toxicity

Colinus virginianus and Anas 

platyrhynchos

(850.2200)

LC50 > 5,000 ppm

NOAEL = 2,500 ppm 

(for both species)

Practically nontoxic 47206702

47229501

Aquatic invertebrate acute toxicity

(Daphnia magna)

(850.1010)

48-hour EC50 = 184.88 mg/L

(95% confidence interval = 182.1-187.7 mg/L) Practically nontoxic 47206703

Freshwater fish LC50

(Oncorhynchus mykiss)

(850.1075)

96-hour LC50 = 134.8 mg/L

(95% confidence interval = 125-145 mg/L) Practically nontoxic 47206705

Nontarget plant studies-seedling 

emergence

(850.4100)

Based on the proposed use pattern (SA is directly 

applied to target seeds only prior to planting) and 

that SA biodegrades rapidly in the environment, 

seedling emergence in nontarget plants is not 

anticipated to be adversely impacted. 

48225210

Nontarget plant studies-vegetative vigor 

(850.4150)

The proposed use of SA a seed treatment is not 

expected to result in adverse effects to vegetative 

vigor, as the active ingredient will not be used on 

seedlings or mature plants. SA is directly applied 

to target seeds only prior to planting.

Additionally, the active ingredient biodegrades 

quickly in the environment, which further 

precludes exposure to nontarget plants. 

48225211

Nontarget insect testing (Apis mellifera)

(880.4350) 96-hour acute contact LD50 > 100 μg/bee Practically nontoxic 48225212
Salicylic Acid Page 17 

Biopesticides Registration Action Document

Nontarget Plant Testing (OCSPP Guidelines 850.4100 and 850.4150; MRID Nos. 4825210 and 

4825211 ): Two nontarget plant studies were conducted. In one study, a solution containing 

0.039% Salicylic Acid (the maximum dose for the proposed EP) was tested for effects on seedling 

emergence in ten species of plants for 21 days, during which time seedling emergence and plant 

height were observed. Based on the findings, there were no attributable effects to seedling 

emergence on nontarget plants. In the second study, a solution containing 0.039% Salicylic Acid 

(the maximum dose for the proposed EP) was tested for effects on vegetative vigor in ten species 

of plants for 21 days, during which time plant survival, growth and condition were observed. There 

were no reported adverse effects (25% or greater) in nine of the ten species tested when compared 

to controls. A statistically significant (p<0.05) reduction of 25% was reported for the mean dry

weight of ryegrass. Phytotoxic effects such as chlorosis, insect damage, leaf curl, necrosis and wilt 

were noted on some plants but were infrequent, generally not severe and present in both treatment 

and control groups. Although some phytotoxic effects were noted in this study, the proposed use of 

Salicylic Acid as a seed treatment is not expected to result in adverse effects to vegetative vigor, as 

the active ingredient will not be used on seedlings or mature plants. Moreover, the active 

ingredient biodegrades quickly in the environment, which further precludes exposure to nontarget 

plants. No toxic effects are anticipated to nontarget plants when Salicylic Acid is applied as a seed 

treatment. 

 

Nontarget Insect Testing (OCSPP Guidelines 880.4350; MRID No. 48225212): An acute contact 

toxicity test was conducted to evaluate the toxicity to the honey bee from exposure to Salycylic 

Acid. Groups of young adult honey bees (Apis mellifera) were dosed topically with the active 

ingredient at 100, 50, 25, 12.5 and 6.25 μg/bee. Bees were observed for mortality and other toxic 

effects twice within the four hours post-treatment and at 24, 48, 72 and 96 hours. Based on the 

observed effects, the NOEC was determined to be 25 μg/bee and the 96-hour acute contact LD50 > 

100 μg/bee. No such exposures are anticipated for nontarget insects. Nevertheless, the findings 

indicate that Salicylic Acid is practically nontoxic to nontarget insects.

2. Environmental Fate and Ground Water Data

Environmental fate and groundwater data are not required at this time because the results of the 

nontarget organism toxicity assessment (Tier I data requirements) did not trigger these Tier II data 

requirements. 

3. Ecological Exposure and Risk Characterization

No significant exposure to nontarget organisms is anticipated when Salicylic Acid is applied as a 

seed treatment. Treatment occurs in a closed environment; and treated seeds are incorporated 

directly into the soil. Additionally, the active ingredient biodegrades rapidly in the environment,

further precluding exposure. Regardless, the risk to nontargets is minimal. Salicylic Acid is 

practically nontoxic to fish, birds, mammals, aquatic invertebrates and insects. While some 

phytotoxicity was observed in one species of plant (of the ten tested), the effects were minimal and 

not attributable to Salicylic Acid. 
Salicylic Acid Page 18 

Biopesticides Registration Action Document

The Agency was able to quantify the risk to terrestrial nontarget organisms through modeling. 

Using the Agency’s Terrestrial Residue Exposure model (T-REX) version 1.4.1, risk quotients 

(RQs) were calculated to assess potential risk to birds. The risk quotients that were conservatively 

calculated using the hazard data and estimated dietary exposure (calculated using T-REX) were 

determined to be significantly less than the Agency’s level of concern (LOC) of 0.1 for threatened 

and endangered avian species. This information is summarized in Table 5 below. Anticipated 

exposures are unlikely to result in unreasonable risk to avian species when Salicylic Acid is used 

as a seed treatment. 

TABLE 5. Determination of Avian Risk Quotients (RQs) for Salicylic Acid Technical

Species LD50/NOEL Acute RQ 

([mg/kg bw-day]/LD50) 

Crops

Colinus

virginian

LD50 = 494 mg/kg

(95% confidence

interval =

396-614 mg/kg)

0.03 (for all crops)

Barley, beans, dried beans, lima 

beans, snap beans, canola, corn, 

cotton, oats, onion, blackeyed peas, 

pea, lupine, grain lupine, field peas, 

peanuts, rice, rye, safflower, 

sorghum, soybeans, soybeans 

(edible), sugar beets, triticale, wheat.

4. Threatened and Endangered Species Assessment

The Agency has not conducted a risk assessment that supports a complete endangered species 

determination. The ecological risk assessment planned during registration review will allow the 

Agency to determine whether Salicylic Acid’s use has “no effect” or “may effect” federally listed 

threatened or endangered species (listed species) or their designated critical habitats. When an 

assessment concludes that a pesticide’s use “may affect” a listed species or its designated critical 

habitat, the Agency will consult with the U.S. Fish and Wildlife Service and/or National Marine 

Fisheries Services (the Services) as appropriate. 

V. ENVIRONMENTAL JUSTICE

EPA seeks to achieve environmental justice, the fair treatment and meaningful involvement of all 

people, regardless of race, color, national origin, or income, in the development, implementation, 

and enforcement of environmental laws, regulations, and policies. To help address potential 

environmental justice issues, the Agency seeks information on any groups or segments of the 

population who, as a result of their location, cultural practices, or other factors, may have atypical, 

unusually high exposure to Salicylic Acid, compared to the general population. Please comment if 

you are aware of any sub-populations that may have atypical, unusually high exposure compared 

to the general population.

VI. RISK MANAGEMENT AND REGISTRATION DECISIONS
Salicylic Acid Page 19 

Biopesticides Registration Action Document

A. Determination of Eligibility

Section 3(c)(5) of FIFRA provides for the registration of new active ingredients if it is determined 

that (A) its composition is such as to warrant the proposed claims for it; (B) its labeling and other 

materials required to be submitted comply with the requirements of FIFRA; (C) it will perform its 

intended function without unreasonable adverse effects on the environment; and (D) when used in 

accordance with widespread and commonly recognized practice, it will not generally cause 

unreasonable adverse effects on the environment. 

The four criteria of the Eligibility Determination for Pesticidal Active Ingredients are satisfied by 

the science assessments supporting products containing Salicylic Acid. Such products are not 

expected to cause unreasonable adverse effects and are likely to provide protection as claimed 

when used according to label instructions. Therefore, EPA concludes that Salicylic Acid is eligible 

for registration for the labeled uses.

B. Regulatory Decision

On October 1, 2009, the EPA announced a new policy to provide a more meaningful opportunity

for the public to participate in major registration decisions before they occur. According to this 

policy, EPA intends to provide a public comment period prior to making a registration decision 

for, at minimum, the following types of applications: new active ingredients; first food uses; first 

outdoor uses; first residential uses; or any other registration actions for which EPA believes there 

may be significant public interest. Accordingly, this pesticide is subject to a 30-day comment 

period as a new active ingredient with outdoor uses. 

At this time, EPA believes, the data submitted fulfill the requirements of registration for products 

containing Salicylic Acid for use as a seed treatment and SAR inducer. Acute toxicity data for 

Salicylic Acid demonstrate that it is toxicity category III and IV for all routes of exposure. (No 

toxicological endpoints were established.) Data confirm that Salicylic Acid does not demonstrate 

subchronic or developmental toxicity, and it is not mutagenic or genotoxic. EPA has no concerns 

for any nontarget organisms exposed to Salicylic Acid in accordance with its approved uses. EPA 

has not identified any toxic endpoints for nontarget mammals, birds, plants, aquatic, or soil 

organisms. Nor are there any anticipated concerns for any threatened and endangered species. 

Given the nontoxic character of Salicylic Acid and because all applicable data requirements have 

been fulfilled, EPA supports its registration under FIFRA section 3(c)(5). 

C. Labeling

Before releasing pesticide products containing Salicylic Acid for shipment, the applicant is 

required to provide appropriate labels.

VII. ACTIONS REQUIRED OF THE REGISTRANT
Salicylic Acid Page 20 

Biopesticides Registration Action Document

The Agency evaluated the data submitted in connection with the initial registration of Salicylic

Acid and determined that these data fulfill current registration guideline requirements. No 

additional data are required to be submitted to the Agency at this time. Additional data may be 

required for new uses and/or changes to existing uses. 

Notwithstanding the information stated in the previous paragraph, it should be clearly understood 

that certain, specific data are required to be reported to the Agency as a requirement for 

maintaining the Federal registration for a pesticide product. A brief summary of these types of data 

are listed below. 

A. Reporting of Adverse Effects and Hypersensitivity Incidents

Reports of all incidents of adverse effects to the environment must be submitted to the Agency

under the provisions stated in FIFRA section 6(a)(2).

Additionally, all incidents of hypersensitivity (including both suspected and confirmed incidents) 

must be reported to the Agency under the provisions of 40 CFR § 158.2050(e).

VIII. GLOSSARY OF ACRONYMS AND ABBREVIATIONS

ADI average daily intake

BPB Biochemical Pesticides Branch

BRAD Biopesticides Registration Action Document

CA chromosomal aberrations

CAS Chemical Abstracts Service

CFR Code of Federal Regulations

EDSP Endocrine Disruptor Screening Program

EP End-use Product

EPA United States Environmental Protection Agency (Agency)

FDA United States Food and Drug Administration 

FFDCA Federal Food, Drug, and Cosmetic Act

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FR Federal Register

g gram

g/mL gram per milliliter

Hg mercury

HSDB Hazardous Substances Data Bank

LC50 median lethal concentration. A statistically derived concentration of a 

substance that can be expected to cause death in 50% of test 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, or inhalation). It is expressed as a weight of 
Salicylic Acid Page 21 

Biopesticides Registration Action Document

substance per unit weight of animal (e.g., mg/kg).

LOC level of concern

LOEL lowest observed effect level

μg microgram

μm micrometer

MRID No. Master Record Identification Number

mg/kg milligram per kilogram

mg/L milligram per liter

mg/ml milligram per milliliter

ml milliliter

mm millimeter

MP Manufacturing-use Product

nm nanometer

NOAEL no observed adverse effect level

NOEC no observed effect concentration

NOEL no observed effect level

OCSPP Office of Chemical Safety and Pollution Prevention

OPP Office of Pesticide Programs

Pa pascal

PC Code Pesticide Chemical Code

ppb parts per billion

PPE personal protective equipment

ppm parts per million

RQ risk quotient

SA Salicylic Acid

SAR Systemic Acquired Resistance

SCE sister chromatid exchange

IX. BIBLIOGRAPHY STUDIES SUBMITTED IN SUPPORT OF THESE

 REGISTRATIONS

A. Studies Submitted in Support of Salicylic Acid

MRID

No. Citation Receipt Date

47206700 NCA Biotech, Inc. (2007) Submission of Product Chemistry and Toxicity Data in Support of the 

Application for Registration of Technical Salicylic Acid. Transmittal of 14 Studies.

14-Aug2007

47206701 Kaminsky, M. (2007) Salicylic Acid Technical: Product Chemistry: Final Report. Project Number: 

10913/07. Unpublished study prepared by Stillmeadow, Inc. 14 p.

14-Aug2007

47206702 Gallagher, S.; Martin, K.; Beavers, J. (2006) Salicylic Acid Technical: A Dietary LC50 Study with the 

Mallard. Project Number: 627/102. Unpublished study prepared by Wildlife International, Ltd. 56 p.

14-Aug2007

47206703 Rodrigue, N. (2006) Salicylic Acid Technical: Daphnia magna 48-Hour Acute Toxicity Test: Final 

Report. Project Number: 9599/05. Unpublished study prepared by Stillmeadow, Inc. 12 p.

14-Aug2007
Salicylic Acid Page 22 

Biopesticides Registration Action Document

MRID

No. Citation Receipt Date

47206704

Gallagher, S.; Beavers, J. (2006) Salicylic Acid Technical: An Acute Oral Toxicity Study with the 

Northern Bobwhite. Project Number: 627/103. Unpublished study prepared by Wildlife International, 

Ltd. 50 p.

14-Aug2007

47206705 Rodrigue, N. (2006) Salicylic Acid Technical: Rainbow Trout 96-Hour Acute Toxicity Test: Final 

Report. Project Number: 9600/05. Unpublished study prepared by Stillmeadow, Inc. 14 p.

14-Aug2007

47206706 Jia, S. (2006) Salicylic Acid Technical: Acute Eye Irritation Study in Rabbits: Amended Final Report. 

Project Number: 9583/05. Unpublished study prepared by Stillmeadow, Inc. 23 p.

14-Aug2007

47206707 Jia, S. (2006) Salicylic Acid Technical: Acute Oral Toxicity Study (UDP) in Rats: Amended Final 

Report. Project Number: 9580/05. Unpublished study prepared by Stillmeadow, Inc. 19 p.

14-Aug2007

47206708 Jia, S. (2006) Salicylic Acid Technical: Skin Sensitization Study in Guinea Pigs: Amended Final 

Report. Project Number: 9585/05. Unpublished study prepared by Stillmeadow, Inc. 24 p.

14-Aug2007

47206709 Jia, S. (2006) Salicylic Acid Technical: Acute Dermal Irritation Study in Rabbits: Amended Final 

Report. Project Number: 9584/05. Unpublished study prepared by Stillmeadow, Inc. 18 p.

14-Aug2007

47206710 Jia, S. (2006) Salicylic Acid Technical: Acute Inhalation Toxicity Study in Rats: Amended Final 

Report. Project Number: 9582/05. Unpublished study prepared by Stillmeadow, Inc. 24 p.

14-Aug2007

47206711 Jia, S. (2006) Salicylic Acid Technical: Acute Dermal Toxicity Study in Rabbits: Amended Final 

Report. Project Number: 9581/05. Unpublished study prepared by Stillmeadow, Inc. 18 p.

14-Aug2007

47206712 Kaminsky, M. (2006) Salicylic Acid Technical: Accelerated Storage Stability: Final Report. Project 

Number: 9578/05. Unpublished study prepared by Stillmeadow, Inc. 12 p.

14-Aug2007

47206713

Aiguo, Z.; Wang, D. (2005) Product Identity and Composition, Description of the Materials Used, 

Description of the Production Process and Discussion of the Formation of Impurities for Salicylic Acid 

(SA) Technical. Project Number: LTB/02018. Unpublished study prepared by LT Biosyn, Inc. 20 p.

14-Aug2007

47206714 Shi, X.; Xu, F. (2005) Preliminary Analysis, Certified Limits and Enforcement Analytical Method for 

Salicylic Acid Technical. Project Number: NCA/02018. Unpublished study by LT Biosyn, Inc. 34 p.

14-Aug2007

47229500 NCA Biotech, Inc. (2007) Submission of Toxicity Data in Support of the Application for Registration 

of Technical Salicylic Acid. Transmittal of 1 Study.

13-Sep2007

47229501

Gallagher, S.; Martin, K.; Beavers, J. (2006) Salicylic Acid Technical: A Dietary LC50 Study with the 

Northern Bobwhite. Project Number: 627/101. Unpublished study prepared by Wildlife International, 

Ltd. 56 p.

13-Sep2007

47464500 U.S. Environmental Protection Agency (2008) Submission of Risk, Exposure, Toxicity and Safety 

Data. Transmittal of 50 Studies.

02-Jul2008

47464504 Ridout, G.; Guy, R. (1988) Structure-Penetration Relationships in Percutaneous Absorption. Pesticide 

Formulations: Innovations and Developments: 112-123.

02-Jul2008

47760900 NCA Biotech, Inc. (2009) Submission of Fate, Toxicity and Product Chemistry Data in Support of the 

Application for Registration of Technical Salicylic Acid. Transmittal of 46 Studies.

22-May2009

47760901 Millar, R.; Kay, J. (2009) Background Information of Salicylic Acid. Project Number: NCA/200901. 

Unpublished study prepared by NCA Biotech, Inc. 7 p.

22-May2009
Salicylic Acid Page 23 

Biopesticides Registration Action Document

MRID

No. Citation Receipt Date

47760902 Raskin, I. (1992) Salicylic, A New Plant Hormone. Plant Physiology 99: 799-803. 22-May2009

47760903 Metraux, J. (2002) Recent Breakthroughs in the Study of Salicylic Acid Biosynthesis. Trends in Plant 

Science 7(8): 332-334.

22-May2009

47760904 Silverman, P; Seskar, M.; Kanter, D.; et al. (1995) Salicylic Acid in Rice. Plant Physiology 108: 633-

639.

22-May2009

47760905 Coquoz, J.; Buchala, A.; Metraux, J. (1998) The Biosynthesis of Salicylic Acid in Potato Plants. Plant 

Physiology 117: 1095-1101.

22-May2009

47760906

Chen, Z.; Klessig, D. (1991) Identification of a Soluble Salicylic Acid-Binding Protein that may 

Function in Signal Transduction in the Plant Disease-Resistance Response . National Academy of 

Science, USA 88: 8179-8183.

22-May2009

47760907

Delaney, T.; Friedrich, L.; Ryals, J. (1995) Arabidopsis Signal Transduction Mutant Defective in 

Chemically and Biologically Induced Disease Resistance. Proceedings, National Academy of Science 

USA 92(JUL): 6602-6606.

22-May2009

47760909 Gaffney, T.; Friedrich, L.; Vernooij, B.; et al. (1993) Requirement of Salicylic Acid for the Induction 

of Systemic Acquired Resistance. Science 261: 754-755.

22-May2009

47760910 Hunt, M.; Neuenschwander, R.; Delaney, T.; et al. (1996) Recent Advances in Systemic Acquired 

Resistance Research - A Review. Gene 179: 89-95.

22-May2009

47760911

Jirage, D.; Tootle, T.; Reuber, T.; et al. (1999) Arabidopsis Thaliana PAD4 Encodes a Lipase-Like 

Gene that is Important for Salicylic Acid Signaling. National Academy of Sciences 96(23): 13583-

13588.

22-May2009

47760912

Kumar, D.; Klessig, D. (2003) High-Affinity Salicylic Acid-Binding Protein 2 is Required for Plant 

Innate Immunity and Has Salicylic Acid-Stimulated Lipase Activity. National Academy of Science 

100(26): 16101-16106.

22-May2009

47760913 Metraux, J.; Signer, H.; Ryals, J.; et al. (1990) Increase in Salicylic Acid at the Onset of Systemic 

Aquired Resistance in Cucumber. Science 250: 1004-1006.

22-May2009

47760914

Nawrath, C.; Metraux, J. (1999) Salicylic Acid Induction-Deficient Mutants of Arabidopsis Express 

PR-2 amd PR-5 and Accumulate High Levels of Camalexin after Pathogen Inoculation. The Plant Cell 

11: 1393-1404.

22-May2009

47760915 Rairdan, G.; Delaney, T. (2002) Role of Salicylic Acid and N1M1/NPR1 in Race-Specific Resistance 

in Arabidopsis. Genetics 161: 803-811.

22-May2009

47760916

Rasmussen, J.; Hammerschmidt, R.; Zook, M. (1991) Systemic Induction of Salicylic Acid 

Accumulation in Cucumber after Inoculation with Pesudomonas Syringae PV Syringae. Plant 

Physiology 97: 1342-1347.

22-May2009

47760917 Ryals, J.; Neuenschwander, U.; Willits, M.; et al. (1996) Systemic Acquired Resistance. The Plant Cell 

8: 1809-1819.

22-May2009

47760918 Shah, J. (2003) The Salicylic Acid Loop in Plant Defense. Current Opinion in Plant Biology 6: 365-

371.

22-May2009
Salicylic Acid Page 24 

Biopesticides Registration Action Document

MRID

No. Citation Receipt Date

47760919 Shulaev, V.; Leon, J.; Raskin, I. (1995) Is Salicylic Acid a Translocated Signal of Systemic Acquired 

Resistance in Tobacco? The Plant Cell 7: 1691-1701.

22-May2009

47760920 Yalpani, N.; Silverman, P.; Wilson, T.; et al. (1991) Salicylic Acid is a Systemic Signal and an Inducer 

of Pathogenesis-Related Proteins in Virus-Infected Tobacco. The Plant Cell 3: 809-818.

22-May2009

47760921

Zhang, Y.; Tessaro, M.; Lassner, M.; et al. (2003) Knockout Analysis of Arabidopsis Transcription 

Factors TGA2, TGA5 and TGA6 Reveals Their Redundant and Essential Roles in Systemic Acquired 

Resistance. The Plant Cell 15: 2647-2653.

22-May2009

47760922

Zhang, Y.; Fan, W.; Kinkema, M.; et al. (1999) Interaction of NPR1 with Basic Leucine Zipper Protein 

Transcription Factors that Bind Sequences Required for Salicylic Acid Induction of PR-1 Gene. 

Proceedings of the National Academy od Sciences 96: 6523-6528.

22-May2009

47760923 Wildermuth, M.; Dewdnwy, J.; Wu, G.; et al. (2001) Isochorismate Synthase is Required to Synthesize 

Salicylic Acid for Plant Defense. Nature 414: 562-571.

22-May2009

47760924 Gutierrez-Coronado, M.; Trejo-Lopez, C.; Larque-Saavedra, A. (1998) Effects of Salicylic Acid on the 

Growth of Roots and Shoots in Soybean. Plant Physiology and Biochemistry 36(8): 563-565.

22-May2009

47760925

Abreu, M.; Munne-Bosch, S. (2008) Salicylic acid may be Involved in the Regulation of DroughtInduced Leaf Senescence in Perennials: A Case Study in Field Grown Salvia Oficinalis L. Plants. 

Environmental and experimental Botany 64: 105-112.

22-May2009

47760926 Srivastava, M.; Dwivedi, U. (1999) Delayed Ripening of Banana Fruit by Salicylic Acid. Plant Science 

158: 87-96.

22-May2009

47760927

Babalar, M.; Asghari, M.; Talaei, A.; et al. (2006) Effect of Pre- and Postharvest Salicylic Acid 

Treatment on Ethylene Production, Fungal Decay and Overall Quality of Selva Strawberry Fruit. Food 

Chemistry 105: 449-453.

22-May2009

47760928 Zhang, Y.; Chen, K.; Zhang, S.; et al. (2002) The Role of Salicylica Acid in Postharvest Ripening of 

Kiwifruit. Postharvest Biology and Technology 28: 67-74.

22-May2009

47760929

Rajjou, L.; Belghazi, M.; Huguet, R.; et al. (2006) Proteomic Investigation of the Effect of Salicylic 

Acid on Arabidopsis Seed Germination and Establishment of Early Defense Mechanisms. Plant 

Physiology 141: 910-923.

22-May2009

47760930 Janssen, K.; Hollman, P.; Venema, D.; et al. (1996) Salicylates in Foods. Nutrition Reviews 54: 357-

359.

22-May2009

47760931 Kay, J. (2009) Supplement to 47206713; Additional Manufacturing Process Information (Salicylic 

Acid). Project Number: NCA/200902. Unpublished study prepared by NCA Biotech, Inc. 33 p.

22-May2009

47760932 Kay, J. (2009) Summary of Salicylic Acid Toxicity Data. Project Number: NCA/200903. Unpublished 

study prepared by NCA Biotech, Inc. 8 p.

22-May2009

47760933

Fiume, M. (2003) Safety Assessment of Salicylic Acid, Butyloctyl Salicylate, Calcium Salicylate, 

C12-15 Alkyl Salicylate, Capryloyl Salicylic Acid, Hexyldodecyl Salicylate, Isocetyl Salicylate, 

Isodecyl Salicylate, Magnesium Salicylate, MEA-Salicylate, Ethylhexyl Salicylate, Potassium 

Salicylate, Methyl Salicylate, Myristyl Salicylate, Sodium Salicylate, TEA-Salicylate, and Tridecyl 

Salicylate. International Journal of Toxicology 22: 1-108.

22-May2009
Salicylic Acid Page 25 

Biopesticides Registration Action Document

MRID

No. Citation Receipt Date

47760934

Scientific Committee on Cosmetic Products and Non-Food Products (2002) Opinion of the Scientific 

Committee on Cosmetic Products and Non-Food Products Intended for Consumers Concerning 

Salicylic Acid. 36p.

22-May2009

47760935 Rocher, F.; Chollet, J.; Jousse, C.; et al. (2006) Salicylic Acid, an Ambimobile Molecule Exhibiting a 

High Ability to Accumulate in the Phloem. Plant Physiology 141: 1684-1693.

22-May2009

47760936 Metwally, A.; Finkemeier, I.; Georgi, M.; et al. (2003) Salicylic Acid Alleviates the Cadmium Toxicity 

in Barley Seedlings. Plant Physiology 132: 272-281.

22-May2009

47760937 Scotter, M.; Roberts, D.; Wilson, L.; et al. (2006) Free Salicylic Acid and Acetyl Salicylic Acid 

Content of Foods Using Gas Chromatography-Mass Spectrometry. Food Chemistry 105: 273-279.

22-May2009

47760938 Amann, R.; Peskar, B. (2002) Anti-Inflammatory Effects of Aspirin and Sodium Salicylate. European 

Journal of Pharmacology 447: 1-9.

22-May2009

47760939 Shakirova, F. (2007) Role of Hormonal System in the Manifestation of Growth Promoting and 

Antistress Action of Salicylic Acid. Biochemistry. The Netherlands: Springer.

22-May2009

47760941 Foltinova, P.; Grones, J. (1996) Euglena gracilis as an Eukaryotic Test Organism for Detecting 

Mutagens and Antimutagens (Salicylic Acid). Mutation Research 393: 1-6.

22-May2009

47760942 San, R.; Chan, R. (1986) Inhibitory Effect of Phenolic Compounds on Aflatoxin B1 Metabolism and 

Induced Mutagenesis (Salicylic Acid). Mutation Research 177: 229-239.

22-May2009

47760943 Sheu, C.; Salomon, D.; Simmons, J.; et al. (1974) Inhibitory Effects of Lipophilic Acids and Related 

Compounds on Bacteria and Mammalian Cells. Antimicrobial Agents and Chemotherapy 7: 349-363.

22-May2009

47760944 Kleinerman, E.; Louie, J.; Wahl, L.; et al. (1980) Pharmacology of Human Spontaneous MonocyteMediated Cytotoxicity. Arthritis and Rheumatism 24: 774-780.

22-May2009

47760946 Waltman, R.; Tricomi, V.; Shabanah, E.; et al. (1973) The Effect of Anti-Inflammatory Drugs on 

Parturition Parameters in the Rat. Prostaglandins 4: 93-106.

22-May2009

47760947 Tanaka, S.; Kawashima, K.; Nakaura, S.; et al. (1973) Studies on Teratogenic Effects of Salicylic Acid 

and Aspirin in Rats as Related to Fetal Distribution. Cong. Anom. 13: 73-84. 

22-May2009

47760948 Jones, A. (1994) Surprising Signals in Plant Cells. Science 263(Jan 14): 183-184. 22-May2009

47760949 Morris, K.; Mackerness, S.; Page, T.; et al. (2000) Salicylic Acid Has a Role in Regulating Gene 

Expression During Leaf Senescence. The Plant Journal 23: 677-685.

22-May2009

47775300 NCA Biotech, Inc. (2009) Submission of Toxicity Data in Support of the Registration of Technical 

Salicylic Acid. Transmittal of 3 Studies.

11-Jun2009

47775301 Delaney, T.; Uknes, S.; Vernooij, B.; et al. (1994) A Central Role of Salicylic Acid in Plant Disease 

Resistants. Science 266: 1247-1249.

11-Jun2009

47775302

McCann, J.; Choi, E.; Yamasaki, E.; et al. (1995) Detection of Carcinogens as Mutagens in the 

Salmonella/ Microsome Test: Assay of 300 Chemicals. Proceedings of National Academy of Science 

72(12): 5135-5139.

11-Jun2009
Salicylic Acid Page 26 

Biopesticides Registration Action Document

MRID

No. Citation Receipt Date

47775303

Commoner, B. (1976) Reliability of Bacterial Mutagenesis Techniques to Distinguish Carcinogenic 

and Noncarcinogenic Chemicals. Project Number: EPA/600/1/76/022, 68/01/2471. Unpublished study 

prepared by Washington University. 113 p.

11-Jun2009

48224600 Loveland Products, Inc. (2010) Submission of Product Chemistry, Toxicity and Fate Data in Support 

of the Application for Registration of LPI 6194 Concentrate. Transmittal of 5 Studies.

14-Sep2010

48224601

Wo, C. (2010) LPI 6194 Concentrate: Physical and Chemical Characteristics: Color, Physical State, 

Odor, Flammability, pH, Viscosity, and Density/Relative Density. Project Number: 29844, P801. 

Unpublished study prepared by Eurofins/Product Safety Laboratories. 16 p.

14-Sep2010

48224602

Knox III, D. (2010) LPI 6194 Concentrate: Enforcement Analytical Method for the Determination of 

Salicylic Acid by High Pressure Liquid Chromatography. Project Number: 29843. Unpublished study 

prepared by Eurofins/Product Safety Laboratories. 10 p.

14-Sep2010

48224603 Tillman, A. (2010) LPI 6194 Concentrate: Waiver Requests for Certain Phys-Chem Property Data. 

Project Number: LPI/2010017. Unpublished study prepared by Loveland Products, Inc. 6 p.

14-Sep2010

48224604 Tillman, A. (2010) LPI 6194 Concentrate and LPI 6194 RTU: Waiver Request for Tier I Mammalian 

Toxicity Data. Project Number: LPI/201021. Unpublished study by Loveland Products, Inc. 10 p.

14-Sep2010

48224605 Tillman, A. (2010) LPI 6194 Concentrate and LPI 6194 RTU: Summary of Tier I Nontarget Organism 

Data Requirements. Project Number: LPI/201020. Unpublished study by Loveland Products, Inc. 27 p.

14-Sep2010

48224700 Loveland Products, Inc. (2010) Submission of Product Chemistry and Toxicity Data in Support of the 

Application for Registration of LPI 6194 RTU. Transmittal of 3 Studies.

14-Sep2010

48224701

Tillman, A. (2010) Product Identity and Composition, Description of the Materials Used, Description 

of the Formulation Process, Discussion of the Formation of Impurities, Certified Limits, and 

Enforcement Analytical Method for LPI 6194 RTU. Project Number: LPI/201022. Unpublished study 

prepared by Loveland Products, Inc. 84 p.

14-Sep2010

48224702 Tillman, A. (2010) LPI 6194 RTU: Phys-Chem Characteristics Data and Waiver Requests for Certain 

Data. Project Number: LPI/2010015. Unpublished study by Loveland Products, Inc. 12 p.

14-Sep2010

48224703 Tillman, A. (2010) LPI 6194 RTU: Request to Bridge Acute Toxicity Data. Project Number: 

LPI/201016. Unpublished study prepared by Loveland Products, Inc. 21 p.

14-Sep2010

48225200 Loveland Products, Inc. (2010) Submission of Product Chemistry, Toxicity and Fate Data in Support 

of the Application for Registration of Salicylic Acid Technical. Transmittal of 13 Studies.

14-Sep2010

48225201

Sinning, D. (2010) Physical and Chemical Characteristics of 98.7% Salicylic Acid Technical: Stability, 

Oxidation/Reduction, pH, UV/Vis, Partition Coefficient (n-Octanol/Water) and Water Solubility: Final 

Report. Project Number: 4670/01. Unpublished study by Case Consulting Laboratories, Inc. 29 p.

14-Sep2010

48225202 Tillman, A. (2010) Summary of and Waiver Request for Physical and Chemical Properties of Salicylic 

Acid Technical. Project Number: LPI/201018. Unpublished study by Loveland Products, Inc. 11 p.

14-Sep2010

48225203 Hauswirth, J. (2010) Summary of the Acute Toxicity of Salicylic Acid. Project Number: LPI/201008. 

Unpublished study prepared by Loveland Products, Inc. 13 p.

14-Sep2010

48225204 Hauswirth, J. (2010) Subchronic Toxicity of Salicylic Acid. Project Number: LPI/201009. 

Unpublished study prepared by Loveland Products, Inc. 99 p.

14-Sep2010
Salicylic Acid Page 27 

Biopesticides Registration Action Document

MRID

No. Citation Receipt Date

48225205 Hauswirth, J. (2010) Developmental and Reproduction Toxicity of Salicylic Acid. Project Number: 

LPI/201012. Unpublished study prepared by Loveland Products, Inc. 175 p.

14-Sep2010

48225206 Hauswirth, J. (2010) Metabolism of Salicylic Acid. Project Number: LPI/201011. Unpublished study 

prepared by Loveland Products, Inc. 50 p.

14-Sep2010

48225207 Hauswirth, J. (2010) Mutagenicity and Genotoxicity for Salicylic Acid. Project Number: LPI/201010. 

Unpublished study prepared by Loveland Products, Inc. 137 p.

14-Sep2010

48225208 Hauswirth, J. (2010) Dermal Penetration of Salicylic Acid. Project Number: LPI/201013. Unpublished 

study prepared by Loveland Products, Inc. 45 p.

14-Sep2010

48225209 Tillman, A. (2010) Summary of Tier 1 Nontarget Organism Data Requirements for Salicylic Acid 

Technical. Project Number: LPI/201019. Unpublished study by Loveland Products, Inc. 24 p.

14-Sep2010

48225210

Porch, J.; Krueger, H. (2010) LPI 6194 Concentrate: A Toxicity Test to Determine the Effects of the 

Test Substance on Seedling Emergence of Ten Species of Plants: Final Report. Project Number: 

224/102. Unpublished study prepared by Wildlife International, Ltd. 68 p.

14-Sep2010

48225211

Porch, J.; Krueger, H. (2010) LPI 6194: A Toxicity Test to Determine the Effects of the Test 

Substance on Vegetative Vigor of Ten Species of Plants: Final Report. Project Number: 224/103. 

Unpublished study prepared by Wildlife International, Ltd. 87 p.

14-Sep2010

48225212

Porch, J.; Krueger, H. (2010) Salicylic Acid Technical: An Acute Contact Toxicity Study with the 

Honey Bee: Final Report. Project Number: 224/101. Unpublished study prepared by Wildlife 

International, Ltd. 21 p.

14-Sep2010

48225213 Tillman, A. (2010) Salicylic Acid Mode of Action. Project Number: LPI/201014. Unpublished study 

prepared by Loveland Products, Inc. 153 p.

14-Sep2010

48562300 Loveland Products, Inc. (2011) Submission of Product Chemistry Data in Support of the Application 

for Registration of LPI 6194 RTU. Transmittal of 2 Studies.

48562301

Tillman, A. (2011) Product Identity and Composition, Description of Starting Materials, Production 

and Formulation Process for LPI 6194 RTU: Supplemental Report to MRID 48224701. Project 

Number: LPI/201108. Unpublished study prepared by Loveland Products, Inc. 26p.

48562302 Wo, C. (2011) LPI 6307: Physical and Chemical Characteristics: pH. Project Number: 32722 P8001. 

Unpublished study prepared by Eurofins/Product Safety Laboratories. 11p.

48562400 Loveland Products, Inc. (2011) Submission of Product Chemistry and Toxicity Data in Support of the 

Application for Registration of LPI 6134 Concentrate. Transmittal of 7 Studies.

48562401

Tillman, A. (2011) Product Identity and Composition, Description of Starting Materials, Production 

and Formulation Process for LPI 6194 Concentrate: Supplemental Report to MRID 46964301. Project 

Number: LPI/201107. Unpublished study prepared by Loveland Products, Inc. 76p.

48562402 Durando, J. (2010) LPI 6194 Concentrate: Acute Oral Toxicity Up and Down Procedure in Rats. 

Project Number: 39845 P320/UDP. Unpublished study by Eurofins/Product Safety Laboratories. 16p.

48562403 Durando, J. (2010) LPI 6194 Concentrate: Acute Dermal Toxicity Study in Rats - Limit Test. Project 

Number: 29846 P322/RAT. Unpublished study prepared by Eurofins/Product Safety Laboratories. 15p.
Salicylic Acid Page 28 

Biopesticides Registration Action Document

MRID

No. Citation Receipt Date

48562404 Durando, J. (2010) LPI 6194 Concentrate: Acute Inhalation Toxicity Study in Rats. Project Number: 

29847 P330. Unpublished study prepared by Eurofins/Product Safety Laboratories. 23p.

48562405 Durando, J. (2010) LPI 6194 Concentrate: Primary Eye Irritation Study in Rabbits. Project Number: 

29848 P324. Unpublished study prepared by Eurofins/Product Safety Laboratories. 16p.

48562406 Durando, J. (2010) LPI 6194 Concentrate: Primary Skin Irritation Study in Rabbits. Project Number: 

28949 P326. Unpublished study prepared by Eurofins/Product Safety Laboratories. 16p.

48562407 Durando, J. (2010) LPI 6194 Concentrate:Dermal Sensitization Study-Guinea Pigs (Buehler Method). 

Project Number: 29850 P328. Unpublished study by Eurofins/Product Safety Laboratories. 25p.

B. EPA Risk Assessment Memoranda

U.S. EPA. 2011a. Gonzales, Angela L. Science Review in Support of Salicylic Acid Technical, 

Containing 98.7% Salicylic Acid as Its Active Ingredient. Memorandum dated 12/8/2011.

U.S. EPA. 2011b. Gonzales, Angela L. Science Review in Support of Salicylic Acid Technical, 

Containing 98.7% Salicylic Acid as Its Active Ingredient. Memorandum dated 06/16/2011.

C. References

Hazardous Substances Data Bank (HSDB). 2008. “Salicylic Acid”. U.S. Department of Health 

and Human Services, National Library of Medicine. March 31, 2011. 

< http://www.toxnet.nlm.nih.gov/cgi-bin/sis/search/f?./temp/~TE3afi:1>

U.S. EPA 2008. Terrestrial Residue Exposure Model (T-REX) Version 1.4.1. 

EFED/OPP/USEPA.