Test Material: Propyzamide (Pronamide, RH-23315) 

 

MRID: 48599205 

 

Title: Terminal Pronamide Preliminary Residue Analytical Method for Soil 

 

MRID: 48599206 

 

Title: Method Validation for "Residue Analytical 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 Signature: 

 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 (pronamide, Kerb, RH-23315) and its transformation 

products RH-24644 (RH-4644) and RH-24580 (RH-4580) in soil 

Reports: ECM: EPA MRID No.: 48599205. Hofmann, C., K. Kurilla, and W. 

Zogorski III. 1995. Terminal Pronamide Preliminary Residue Analytical 

Method for Soil. Rohm and Haas Technical Report No.: 34-95-34. Report 

prepared and sponsored by Rohm and 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 Terminal Pronamide RH-23315 in Soil (TR 

34-95-34)". Centre Analytical Laboratories 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) standards 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 Certification statements were provided (pp. 2-3, 13 of MRID 

48599205). 

ILV: The study was conducted in accordance 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 Certification 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 procedures. 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 those 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 Technical Report No. 34-95-34, is designed for the 

quantitative determination of propyzamide and 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 ILV did not provide any performance data at 10x 

LOQ. The LOQ is less than the lowest toxicological level of concern in soil. The method 

specifies the correction of procedural recoveries for residues in the controls. Sufficient results to 

validate the confirmatory method were not provided. The soils used in the ECM and ILV were 

not characterized. No major modifications were made by the independent 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 remaining 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). The 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). The 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 separately taken to dryness (rotary evaporation, 

≤30°C), then reconstituted in 5.0 mL hexane (Appendix C, p. 116). 

Samples were analyzed for propyzamide and 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 methane in argon P-10, gas flow rates 8.6 mL/minute 

through column and 64.7 mL/minute through detector, injector temperature 250°C, detector 

temperature 300°C, initial column temperature 100°C and hold time 2 minutes, ramp rate 
Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV) 

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20°C/minute, final temperature 270°C and hold time 14 minutes (Appendix C, p. 116). Injection 

volumes were 4 μL (Appendix C, p. 117). 

As a confirmatory method, samples were analyzed 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/minute, 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 were implemented to improve analyte recoveries 

and GC chromatography (Appendix D, p. 150). The 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 acetate (75:25, v:v, pp. 13-14). 

For the primary GC method, injection 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/kg for RH-24644 (RH-4644; 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. 

II. Recovery Findings 

ECM (MRID 48599205 & 48599206): Mean recoveries and relative standard deviations (RSDs) 

were within guideline requirements (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 (LOQ), recoveries (n = 1) of propyzamide and 

RH-24644 were 76.5% and 86.5%, respectively (Appendix 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 for any background in the 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 propyzamide, RH-24644 and RH-24580 in soil RAR # 94-

0119-001 and RH-24580 in soil RAR # 94-0015-001; performance 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). Performance data for the three analytes at 0.1 mg/kg 

(10x LOQ) were not reported. At fortification 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), mean 
Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV) 

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recoveries and RSDs were within guideline criteria with the 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. Insufficient 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 Soil1

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 deviations were reviewer-calculated from the data in the study 

report since the study author only reported overall (per fortification level) means and SDs (see DER Attachment 

2). 

Table 3. Independent Validation Method Recoveries for Propyzamide and Its 

Transformation Products in Soil1
Propyzamide (PC 101701) MRIDs 48599205 (ECM)/ 48599206 (ECM & ILV) 

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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 6.8 
Propyzamide (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 deviations were reviewer-calculated 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 (Appendix C, pp. 118-119). In the ILV, the LOQ 

for all three analytes was reported at 0.01 mg/kg (p. 17). No justification for the selected LOQs 

were reported. LOD values for the three analytes 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 r2

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 by 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 r2

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

Page 8 of 12 

1. For both the ECM and ILV, insufficient performance data were reported to validate the 

method. A validation sample set should consist 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 quantitative GC method, results were reported for one replicate at 

the LOQ for propyzamide and RH-24644, no replicates at the LOQ for RH-24580, and 

eight replicates for each analyte at 10x LOQ (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 (Appendix 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, results 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 arbitrarily 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 quantitative GC method did not 

meet OCSPP Guideline 850.6100 criteria for precision 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%, RSD 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 (RSD 21.4%) and 0.5 mg/kg fortified RH24580 (mean 69.3%) in soil RAR # 94-0019-001 (DER Attachment 2). For both the ECM 

and ILV, insufficient performance data (all replicates n = 1) were provided to validate the 

confirmation GC method. 

4. For the ECM using the quantitative GC method, 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 background was present (Appendix C, Figure 16, p. 

137); RH-24580 samples spiked at the LOQ were 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 significant responses (i.e. >30% LOQ) in the region in the 

chromatograms corresponding to the retention times of propyzamide (Kerb) and RH24644 (RH-4644) in the control sample extract using both the quantitative and 

confirmation GC methods (Appendix C, Figure 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 extract 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 significant 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 (Figure 11, p. 37; Figures 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 corrected for any background in the matrix controls in the ECM 

and ILV (p. 16; Appendix C, p. 117; Figures 10-16, pp. 131-137; Figures 24-27, pp. 145-

148). 

6. For the ECM, standard curves for both the quantitative and confirmation GC methods 

were provided, but chromatograms at all calibration 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 tabulated and linearity (correlation 

coefficient, r2

) 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; Figures 22-24, pp. 48-50); individual calibration 

data were not tabulated and linearity (correlation coefficient, r2) of the regression 

analyses were not reported. 

7. For the ILV, the study author reported that, in some cases, the standard curves used were 

not appropriate for the 0.01 mg/kg (LOQ) fortified 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 laboratory 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 (originating laboratory) and 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 extraction 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 and Associated Independent Laboratory 

Validation. Office of Chemical Safety and Pollution Prevention, Washington, DC. EPA 

712-C-001. 

40 CFR Part 136. Appendix B. Definition and Procedure 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-dimethyl-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.