Test Material: Propyzamide (Pronamide, RH-23315)

MRID: 48599205

Title: Terminal Pronamide Preliminar y Residue Analytical Method for Soil

MRID: 48599206

Title: Method Validation for "Residue An alytical Method for Terminal Pronamide RH-23315 in Soil (TR 34-95-34)"

EPA PC Code: 101701

OCSPP Guideline: 850.6100

For CDM Smith

Primary Reviewer: Lynne Binari Signature:

Date:

Secondary Reviewer: Lisa Muto Si g nature:

Date:

QC/QA Manager: Joan Gaidos Signature:

Date:Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 2 of 12 Analytical method for propyzamide (pronami de, Kerb, RH-23315) and its transformation products RH-24644 (RH-4644) and RH-24580 (RH-4580) in soil

Reports: ECM: EPA MRID No.: 48599205. Hofm ann, C., K. Kurilla, and W. Zogorski III. 1995. Terminal Pronamide Preliminar y Residue Analytical Method for Soil. Rohm and Haas Te chnical Report No.: 34-95-34. Report prepared and sponsored by Rohm an d Haas Company, Spring House, Pennsylvania, and submitted by Dow AgroSciences LLC, Indianapolis, Indiana; 42 pages. Final report issued April 24, 1995. ILV: EPA MRID No. 48599206. Xu, B. 1997. Method Validation for "Residue Analytical Method for Term inal Pronamide RH-23315 in Soil (TR 34-95-34)". Centre Analytical Laborat ories Project No.: 002-139. Rohm and Haas Protocol No.: 34P-95-41 and Technical Report No.: TR-34-96-51. Report prepared by Centre Analytical Laboratories, Inc., State College, Pennsylvania, sponsored by Rohm and Haas Company, Spring House, Pennsylvania, and submitted by Dow AgroSciences LLC, Indianapolis, Indiana; 150 pages. Final report issued January 3, 1997.
Document No.: MRIDs 48599205 & 48599206
Guideline: 850.6100
Statements: ECM: A statement verifying that the study was conducted in compliance with Good Laboratory Practice (GLP) st andards was not provided (p. 3 of MRID 48599205). Signed and dated No Data Confidentiality, GLP (submitter has no knowledge of GLP compliance), Quality Assurance, and Authenticity Certificatio n statements were provided (pp. 2-3, 13 of MRID 48599205). ILV: The study was conducted in acco rdance with USEPA and OECD GLP standards (pp. 3-3a of MRID 48599206). Signed and dated No Data Confidentiality, GLP, and Quality Assurance statements were provided; an Authenticity Certificatio n statement was not provided (pp. 2-4 of MRID 48599206).
Classification: This analytical method is classified as invalid. For the quantitative method (all analytes), the ECM and ILV did not provide sufficient performance data to validate the method at the LOQ, and the ILV did not provide any performance data at 10x LOQ. Sufficient results to validate the confirmatory method were not provided. The determinations of the LOQ and LOD were not based on scientifically acceptable pr ocedures. Recoveries were corrected in the ECM and ILV. The soils used were not characterized.
PC Code: 101701
Reviewer: Karen Milians, Ph.D., Chemist Signature:
Date:Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 3 of 12 All page citations refer to t hose page numbers located in the most upper right of MRID 48599206 (ILV, since this report contained the ECM and ECM Modification), unless noted otherwise.

Executive Summary

This analytical method, Rohm and Haas Techni cal Report No. 34-95-34, is designed for the quantitative determination of propyzamide a nd its transformation products RH-24644 and RH24580 in soil using GC-ECD. For all three analytes , insufficient performance data were reported to validate the method at the LOQ, and the IL V did not provide any performance data at 10x LOQ. The LOQ is less than the lowest toxico logical level of concern in soil. The method specifies the correction of procedur al recoveries for residues in th e controls. Sufficient results to validate the confirmatory method were not provi ded. The soils used in the ECM and ILV were not characterized. No major modifications were made by the inde pendent laboratory.

Table 1. Analytical Method Summary

Analyte(s) by Pesticide MRID
EPA Review Matrix Method Date (dd/mm/yyyy) Registrant Analysis Limit of Quantitation (LOQ) Environmental Chemistry

Method Independent Laboratory Validation Propyzamide 48599205 & 48599206 48599206 Soil 24/04/1995 Dow AgroSciences LLC GCECD 0.01 mg/kg

RH-24644 0.01 mg/kg

RH-24580 0.01 mg/kg

I. Principle of the Method

Samples (5.0 g) of soil were extracted once with 85 mL of acetone :water (85:15, v:v) by blending on low speed for 3 minutes (Appendix C, p. 114). Soil and extract were separated by vacuum filtration through a celite pad prepared using acetone:water (85:15, v:v, 20 mL) and Celite 545 ( ca . 1 teaspoon). The extract was partitioned once with hexane (130 mL); the aqueous phase was discarded (Appendix C, p. 115). The re maining organic phase was taken to dryness (rotary evaporation, ≤ 30°C), then reconstituted in 5.0 mL hexane. The sample was loaded onto an aluminum oxide (basic) column; 10.5 mm ID x 25 cm glass column packed with aluminum oxide (basic) powder (5.0 mL, 2.5% deactivated), topped with anhydrous sodium sulphate (1.0 mL), and preconditioned with hexane (10 mL). Th e loaded column was washed with hexane (30 mL), then propyzamide (Kerb, RH-23315) and its product RH-24644 (RH-4644) were eluted with hexane:ethyl acetate (90:10, v:v, 30 mL). Th e column was then washed with hexane:ethyl acetate (90:10, v:v, 30 mL), then product RH-24580 (RH-4580) was eluted with hexane:ethyl acetate (75:25, v:v, 20 mL). Eluates were separa tely taken to dryness (rotary evaporation,
≤ 30°C), then reconstituted in 5.0 mL hexane (Appendix C, p. 116).

Samples were analyzed for propyzamide a nd its products RH-24644 (RH-4644) and RH-24580 (RH-4580) by GC (Restek RTX-5 Megabore, 0.53 mm ID x 30 m, 0.5 df column) using electron capture detection (ECD): carrier gas methan e in argon P-10, gas flow rates 8.6 mL/minute through column and 64.7 mL/minut e through detector, injector temperature 250°C, detector temperature 300°C, initial column temperatur e 100°C and hold time 2 minutes, ramp ratePropyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 4 of 12 20°C/minute, final temperature 270°C and hold ti me 14 minutes (Appendix C, p. 116). Injection volumes were 4 μL (Appendix C, p. 117).

As a confirmatory method, samples were anal yzed by GC-ECD (Restek RTX-200 column, not further described in ECM; ILV used RTX-200, 0.53 mm ID x 60 m, 0.5 μm df column) with the following modifications: gas flow rate 3.5 mL/m inute, injector temperature 265°C, initial column temperature 230°C and hold time 5 minutes , ramp rate 5°C/minute, final temperature 250°C and hold time 15 minutes (p. 15; Appendix C, p. 118). Injection volumes were 1 μL (Appendix C, p. 117).

In the ILV, several modifications to the ECM we re implemented to improve analyte recoveries and GC chromatography (Appendix D, p. 150). Th e aluminum oxide column was wet-packed with 10 mL aluminum oxide (2.5% deactivated ) in 20 mL hexane (p. 13). Propyzamide (RH23315) and RH-24644 (RH-4644) were eluted with 40 mL of hexane:ethyl acetate (90:10, v:v), and RH-24580 (RH-4580) was eluted with 30 mL of hexane:ethyl acetat e (75:25, v:v, pp. 13-14). For the primary GC method, inje ction volumes were modified to 3 μL for propyzamide (RH23315) and RH-24622 and 2 μL for RH-24580 (p. 14). The modifications were not considered substantial changes to the ECM (Appendix D, p. 150 of MRID 48599206).

In the ECM, tentative LOQs were reported at 0.01 mg/kg for propyzamide (Kerb, RH-23315) and RH-24580 (RH-4580) and at 0.01-0.02 mg/k g for RH-24644 (RH-4644; Appendix C, pp. 118-119). In the ILV, the LOQ for all three anal ytes was reported at 0.01 mg/kg (p. 17). There was no justification for the selected LOQ in eith er the ECM or ILV. LODs were not reported in the ECM or ILV.

II. Recovery Findings

ECM (MRID 48599205 & 48599206): Mean recoveries and relative standard de viations (RSDs) were within guideline requi rements (mean 70-120%; RSD ≤ 20%) for analysis of propyzamide, RH-24644 and RH-24580 in soil at fortification levels of 0.1 mg/kg (10x LOQ) and 0.2 mg/kg (20x LOQ, DER Attachment 2). At 0.01 mg/kg (L OQ), recoveries (n = 1) of propyzamide and RH-24644 were 76.5% and 86.5%, respectively (A ppendix C, Figure 16, p. 137). Performance data for RH-24580 at the LOQ (0.01 mg/kg) were not reported. Insufficient performance data were provided to validate the confirmation GC method (Appendix C, Figure 25, p. 146; Figure 27, p. 148). Recovery values were corrected fo r any background in th e matrix controls (Appendix C, p. 117; Figures 12-14, pp. 133-135; Figure 16, p. 137; Figure 25, p. 146; Figure 27, p. 148). The soil was not characterized.

ILV (MRID 48599206): At 0.01 mg/kg (LOQ), mean recoveries and RSDs were within guideline requirements for analysis of propy zamide, RH-24644 and RH-24580 in soil RAR # 94- 0119-001 and RH-24580 in soil RAR # 94-0015-001; pe rformance data for propyzamide (RSD 34.9%) and RH-24644 (mean 58.0%, RSD 101.8%) were not within guideline criteria in soil RAR # 94-0015-001 (DER Attachment 2). Performan ce data for the three analytes at 0.1 mg/kg (10x LOQ) were not reported. At fortificati on levels of 0.05 mg/kg (5x LOQ), 0.25 mg/kg (25x LOQ), 0.4 mg/kg (40x LOQ), 0.5 mg/kg (50x LOQ) and 4.0 mg/kg (400x LOQ), meanPropyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 5 of 12 recoveries and RSDs were with in guideline criteria with th e following exceptions: 0.4 mg/kg fortified RH-24580 (mean 66.0%) in soil RAR # 94-0015-001; 0.4 mg/kg fortified propyzamide (mean 68.5%), 0.5 mg/kg fortified propyzamide (RSD 21.4%) and 0.5 mg/kg fortified RH-24580 (mean 69.3%) in soil RAR # 94-0019-001. Insufficien t performance data were provided to validate the confirmation GC method (Table 5, p. 25). Recovery values were corrected for any background in the matrix controls (p. 16). The soils were not characterized.

Table 2. Initial Validation Method Recoveries for Propyzamide and Its Transformation Products in Soil 1

Analyte Fortification Level (mg/kg) Number of Tests Recovery Range (%) Mean Recovery (%) 2 Standard Deviation (%) 2 Relative Standard Deviation (%) 2

Quantitative GC Method (RXT-5)

Propyzamide 0.01 (LOQ) 1 76.5 NA NA NA

0.1 8 85.9-113.3 96.2 8.7 9.0

0.2 8 89.8-105.5 98.0 6.4 6.5

RH-24664 0.01 (LOQ) 1 86.5 NA NA NA

0.1 8 75.5-117.0 94.1 14.4 15.3

0.2 8 87.0-104.0 96.9 6.5 6.7

RH-24580 0.01 (LOQ) No results reported.

0.1 8 80.8-142 116.1 21.5 18.5

0.2 8 84.0-99.9 94.3 5.5 5.8 Confirmation GC Method (RTX-200) Propyzamide 0.1 1 95.8 NA NA NA

RH-24664 0.1 1 68.5 NA NA NA

RH-24580 0.1 1 140.0 NA NA NA Data were obtained from Tables 1-2, p. 121; Figure 16, p. 137; Figure 25, p. 146; Figure 27, p. 148 of Appendix C. NA = Not applicable. 1 Soil was uncharacterized. 2 Means, standard deviations and relative standard devia tions were reviewer-calculate d from the data in the study

report since the study author only reported overall (per fortification level) means an d SDs (see DER Attachment 2).

Table 3. Independent Validation Method Recoveries for Propyzamide and Its Transformation Products in Soil 1Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 6 of 12 Analyte Fortification Level (mg/kg) Number of Tests Recovery Range (%) Mean Recovery (%) 2 Standard Deviation (%) 2 Relative Standard Deviation (%) 2

Soil RAR # 94-0015-001 Quantitative GC Method (RXT-5)

Propyzamide 0.01 (LOQ) 3 68.3-133.0 95.8 33.4 34.9

0.05 3 71.6-88.2 82.6 9.5 11.5

0.25 3 79.6-83.2 81.6 1.8 2.2

0.4 3 80.0-83.5 81.3 1.9 2.3

0.5 3 79.2-106.0 88.3 15.4 17.4

4.0 3 79.5-90.5 83.7 6.0 7.1

RH-24644 0.01 (LOQ) 3 0-118.0 58.0 59.0 101.8

0.05 3 66.8-96.6 84.3 15.6 18.5

0.25 3 78.8-86.8 81.6 4.5 5.5

0.4 3 78.0-94.5 85.2 8.5 9.9

0.5 3 82.0-105.0 91.9 11.8 12.9

4.0 3 75.0-94.0 83.3 9.7 11.7

RH-24580 0.01 (LOQ) 3 66.2-87.1 75.0 10.8 14.5

0.05 3 85.4-91.4 87.8 3.2 3.6

0.25 3 75.6-81.2 79.3 3.2 4.1

0.4 3 55.5-71.5 66.0 9.1 13.8

0.5 3 64.8-79.2 73.9 7.9 10.7

4.0 3 80.0-87.0 83.0 3.6 4.3 Confirmation GC Method (RTX-200)

Propyzamide 0.01 (LOQ) 1 82.2 NA NA NA

0.5 1 77.2 NA NA NA

RH-24644 0.01 (LOQ) 1 63.4 NA NA NA

0.5 1 84.4 NA NA NA

RH-24580 0.01 (LOQ) 1 59.9 NA NA NA

0.5 1 82.4 NA NA NA
Soil RAR # 94-0019-001 Quantitative GC Method (RXT-5)

Propyzamide 0.01 (LOQ) 3 92.3-101.0 96.6 4.4 4.5

0.05 3 84.2-91.6 87.5 3.8 4.3

0.25 3 88.8-89.6 89.2 0.4 0.4

0.4 3 63.4-72.5 68.5 4.6 6.8

0.5 3 53.6-82.8 70.3 15.0 21.4

4.0 3 79.0-101.0 88.6 11.3 12.7

RH-24644 0.01 (LOQ) 3 86.9-112.0 97.4 13.1 13.4

0.05 3 98.6-102.0 100.0 1.8 1.8

0.25 3 82.8-92.0 87.6 4.6 5.3

0.4 3 81.0-120.0 98.2 19.9 20.3

0.5 3 70.0-87.6 77.7 9.0 11.6

4.0 3 82.0-94.5 87.8 6.3 7.2

RH-24580 0.01 (LOQ) 3 71.6-76.9 74.7 2.7 3.7

0.05 3 77.2-90.8 82.7 7.1 8.6

0.25 3 68.0-84.4 76.8 8.3 10.8

0.4 3 69.5-79.0 73.3 5.0 6.8Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 7 of 12 Analyte Fortification Level (mg/kg) Number of Tests Recovery Range (%) Mean Recovery (%) 2 Standard Deviation (%) 2 Relative Standard Deviation (%) 2

0.5 3 61.2-79.2 69.3 9.1 13.2

4.0 3 72.5-86.0 80.7 7.2 8.9 Confirmation GC Method (RTX-200)

Propyzamide 0.01 (LOQ) 1 112.0 NA NA NA

0.5 1 72.8 NA NA NA

RH-24644 0.01 (LOQ) 1 85.5 NA NA NA

0.5 1 91.6 NA NA NA

RH-24580 0.01 (LOQ) 1 60.1 NA NA NA

0.5 1 82.0 NA NA NA Data were obtained from Table 2, pp. 20-21; Table 4, pp. 23-24; Table 5, p. 25. NA = Not applicable. 1 Soils were uncharacterized. 2 Means, standard deviations and relative standard devia tions were reviewer-calculate d from the data in the study

report since the study author only reported overall (all fortification levels) means and SDs (see DER Attachment 2).

III. Method Characteristics

In the ECM, tentative LOQ values for propyzamide and RH-24580 in soil were reported at 0.01 mg/kg and for RH-24644 at 0.01-0.02 mg/kg (Appe ndix C, pp. 118-119). In the ILV, the LOQ for all three analytes was reporte d at 0.01 mg/kg (p. 17). No justif ication for the selected LOQs were reported. LOD values for the three analyt es were not reported in the ECM or ILV.

Table 4. Method Characteristics Propyzamide RH-24644 RH-24580

Limit of Quantitation (LOQ) 0.01 mg/kg 0.01 mg/kg 0.01 mg/kg Limit of Detection (LOD) Not reported. Not reported. Not reported. Linearity (calibration curve r 2 and concentration range) 1 r 2 = Not reported. (0.01-0.4 μg/mL) r 2 = Not reported. (0.01-0.4 μg/mL) r 2 = Not reported. (0.01-0.4 μg/mL) Repeatable No. The ILV failed to analyze a minimum of five matrix control samples fortified at the LOQ. Additionally, there was no justification for the LOQs proposed b y the initial validation (ECM). Reproducible

Specific No. The ILV did not provide sufficient performance data to validate the quantitative and confirmation GC methods. Data were obtained from p. 17; Table 2, pp. 20-21; Table 4, pp. 23-24; Table 5, p. 25; Appendix A, pp. 54-66, pp. 73-86. 1 Reviewer-calculated r 2 values were 0.9923-0.9981 for the provided ILV calibration curves (DER Attachment 2).

Complete calibration data were not reported in the ECM (Appendix C, Figures 1-9, pp. 122-130; Figures 17-23, pp. 138-144).

IV. Method Deficiencies and Reviewer’s CommentsPropyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 8 of 12 1. For both the ECM and ILV, insufficient perfor mance data were repor ted to validate the method. A validation sample set should consis t of, at a minimum, a reagent blank, two unspiked matrix control samples, five matrix control samples spike at the LOQ, and five matrix control samples spiked at 10x LOQ for each matrix.

For the ECM using the quantitat ive GC method, results were reported for one replicate at the LOQ for propyzamide and RH-24644, no re plicates at the LOQ for RH-24580, and eight replicates for each analyte at 10x L OQ (Appendix C, Tables 1-2, p. 121; Figure 16, p. 137). For the ECM using the confirmation GC method, results were reported for one replicate for each analyte at 10x LOQ (Appe ndix C, Figure 25, p. 146; Figure 27, p. 148); no results were reported at the LOQ.

For the ILV using the quantitative GC method, results were reported for three replicates at the LOQ for all three analytes (Table 2, p. 20; Table 4, p. 23); no results were reported at 10x LOQ. For the confirmation GC method, re sults were reported for one replicate for each analyte at the LOQ (Table 5, p. 25); no results were reported at 10x LOQ.

2. The determination of the LOQ and LOD were not based on scientifically acceptable procedures. In the ECM, tentative LOQs were reported at 0.01 mg/kg for propyzamide and RH-24580 and at 0.01-0.02 mg/kg for RH-24644 (Appendix C, pp. 118-119). In the ILV, the LOQ for all three analytes was reported at 0.01 mg/kg (p. 17). There was no justification for the selected LOQ in either the ECM or ILV. LODs were not reported in the ECM or ILV.

Detection limits should not be based on the ar bitrarily selected lowest concentration in the spiked samples. Additionally, the lowest toxicological level of concern in soil was not reported. An LOQ above toxicological levels of concern results in an unacceptable method classification.

3. For the ILV, the following fortifications (n = 3) using the quantita tive GC method did not meet OCSPP Guideline 850.6100 criteria for prec ision and accuracy (mean recoveries for replicates at each spiking level between 70% and 120% and relative standard deviations (RSD) ≤ 20%): 0.01 mg/kg (LOQ) fortified propyzamide (RSD 34.9%), 0.01 mg/kg (LOQ) fortified RH-24644 (mean 58.0%, RS D 101.8%) and 0.4 mg/kg fortified RH24580 (mean 66.0%) in soil RAR # 94-0015-001; 0.4 mg/kg fortified propyzamide (mean 68.5%), 0.5 mg/kg fortified propyzamide (R SD 21.4%) and 0.5 mg/kg fortified RH24580 (mean 69.3%) in soil RAR # 94-0019-001 (D ER Attachment 2). For both the ECM and ILV, insufficient performance data (all replic ates n = 1) were provi ded to validate the confirmation GC method.

4. For the ECM using the quantitative GC me thod, the peaks for propyzamide (Kerb, RH3315) and RH-24644 (RH-4644) at the lowest spiking level (0.01 mg/kg, LOQ) were discernable, but a large amount of bac kground was present (Appendix C, Figure 16, p. 137); RH-24580 samples spiked at the LOQ we re not reported. The ILV modifications appeared to have reduced background noise (Figures 5-6, pp. 31- 32; Figures 15-16, pp.Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 9 of 12 41-42). Analysis of RH-24580 samples spiked at the LOQ using the confirmation GC method were not reported.

5. For the ECM, there were sign ificant responses (i.e. >30% LOQ) in the region in the chromatograms corresponding to the retenti on times of propyzamide (Kerb) and RH24644 (RH-4644) in the control sample ex tract using both th e quantitative and confirmation GC methods (Appendix C, Fi gure 1, p. 122; Figure 11, p. 132; Figures 16- 17, pp. 137-138; Figure 24, p. 145). For RH-24580 (RH-4580), there were significant responses (i.e. >30% LOQ) in the region in the chromatograms corresponding to the retention time in the control sample extrac t using the quantitative GC method, but not the confirmation method (Appendix C, Figure 6, p. 127; Figure 10, p. 131; Figure 19, p. 140; Figure 26, p. 147).

For the ILV, there was a si gnificant response (i.e. >50% LOQ) in the region in the chromatogram corresponding to the retention time of RH-24580 in the control sample extract (Figure 1, p. 27; Figures 5-6, pp. 31- 32), but not for propyzamide (RH-23315) and RH-24644 in the control sample extract (F igure 11, p. 37; Figu res 15-16, pp. 41-42). No chromatograms (matrix blank, spiked samples or calibration standards) from analyses using the confirmation GC method were provided.

Sample recoveries were corre cted for any background in the matrix controls in the ECM and ILV (p. 16; Appendix C, p. 117; Fi gures 10-16, pp. 131-137; Figures 24-27, pp. 145- 148).

6. For the ECM, standard curves for both th e quantitative and conf irmation GC methods were provided, but chromatograms at all calib ration standard concentrations were not provided (Appendix C, Figures 1- 9, pp. 122-130; Figures 17-23, pp. 138-144). Additionally, individual calibration data were not tabul ated and linearity (correlation coefficient, r 2 ) of the regression analyses were not reported.

For the ILV, standard curves were only provided for the quantitative GC method (Figures 1-4, pp. 27-30; Figures 11-14, pp. 37-40; Figur es 22-24, pp. 48-50); individual calibration data were not tabulated and linearity (correlation coefficient, r 2 ) of the regression analyses were not reported.

7. For the ILV, the study author re ported that, in some cases, th e standard curves used were not appropriate for the 0.01 mg/kg (LOQ) for tified samples (p. 17; Table 2, p. 20; Table 5, p. 25).

8. The soils used in the ECM and ILV were not characterized.

9. Communications between the independent labo ratory and the developers or previous users of the ECM were not fully documented. The study author reported that there was no contact between Rohm and Haas Company (ori ginating laboratory) a nd Centre Analytical Laboratories (CAL, independent laboratory) on the technical aspects of the validation, and that communications were only concerning changes in the fortification levels (pp. 11,Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 10 of 12 17). Communications between CAL and Rohm and Haas were not otherwise documented.

10. It was reported for the ILV that extracti on time for one set of eight samples required approximately 16 person-hours (p. 11).

V. References

U.S. Environmental Protection Agency. 2012. Ecological Effects Test Guidelines, OCSPP 850.6100, Environmental Chemistry Methods an d Associated Independent Laboratory Validation. Office of Chemical Safety a nd Pollution Prevention, Washington, DC. EPA 712-C-001.

40 CFR Part 136. Appendix B. Definition and Pro cedure for the Determination of the Method Detection Limit-Revision 1.11, pp. 317-319.Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 11 of 12 Attachment 1: Chemical Names and Structures

Propyzamide (Kerb, pronamide, RH-23315, RH-3315, RH-315)

IUPAC Name: 3,5-Dichloro-N-(1,1-dimethylprop-2-ynyl)benzamide
CAS Name: 3,5-Dichloro-N-(1,1-dimethyl-2-propynyl)-benzamide
CAS Number: 23950-58-5 SMILES String: CC(C)(NC(=O)c1cc(Cl)cc(Cl)c1)C#C (EPI Suite, v3.12 SMILES).

RH-24644 (RH-4644)

IUPAC Name: 3,5-Dichloro-N-(1,1,2-trimethylprop-2-enyl)benzamide
CAS Name: 2-(3,5-Dichlorophenyl)-4,4-dime thyl-5-methylene oxozoline
CAS Number: 29918-40-9 SMILES String: Not reported.Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV)

Page 12 of 12 RH-24580 (RH-4580)

IUPAC Name: 3,5-Dichloro-N-(1,1-dimethyl-2-oxopropyl)benzamide
CAS Name: N-(1,1-Dimethyl acetonyl )-3,5-dichloro-benzamide
CAS Number: 29918-41-0 SMILES String: Not reported.