U.S. ENVIRONMENTAL PROTECTION AGENCY

PRESENTATION OF THE APPROACH 

TO REEVALUATE ATRAZINE 

U.S. EPA 

One Potomac Yard, South Building 

2777 South Crystal Drive 

Arlington, Virginia 22202 

NOVEMBER 3, 2009 

9:03 A.M. 
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1

2 PRESENTATION OF THE APPROACH 

3 TO REEVALUATE ATRAZINE 

4 OPEN MEETING 

5 November 3, 2009 

6 MR. BAILEY: Good morning, everyone. My 

7 name is Joe Bailey, and I'll be serving as the 

8 Designated Federal Official for this FIFRA Scientific 

9 Advisory Panel meeting. 

10 The topic for this meeting is 

11 presentation of the approach to reevaluate atrazine. I 

12 might add that this is an informational meeting to 

13 present the plan for reevaluation in 2010. 

14 As the Designated Federal Official, I 

15 serve as a liaison between the Agency and the public 

16 and the panel to ensure that all FACA requirements are 

17 met. 

18 Dr. Heeringa, sitting next to me, will 

19 be serving as the chair for this meeting, and the panel 

20 only provides independent, scientific peer review and 

21 advice...and advice to the Agency on pesticide issues. 

22 The panel only provides advice and recommendations, and 

23 EPA does all the regulatory and decision making and 

24 implementation authority associated with pesticide 

25 issues. 
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1 This meeting does provide an opportunity

2 for public comment. I think it's projected to begin 

3 about 9:30 this morning. I have a number of people who 

4 have requested to make comments ahead of time, and if 

5 there's anyone else in the audience that wishes to make 

6 public comments, please let me or anybody else on the 

7 SAP staff here know, and if you do walk up and request 

8 to comment this morning, we'll have to limit your time 

9 to five minutes or...or fewer. 

10 We have a public docket associated with 

11 the meeting as well. A number of comments have been 

12 submitted to that. It is accessible to the public, 

13 and...and the presentations and any other material that 

14 is brought forward during this meeting will be placed 

15 in that docket and available to the public within a few 

16 days as well. 

17 After the meeting is over, we will 

18 prepare a meeting minutes or report, and that also will 

19 be available on the web site and...and in the public 

20 docket. 

21 And I think at this point, I will turn 

22 the meeting to the chair, Dr. Heeringa. 

23 DR. HEERINGA: Thank you very much, Joe. 

24 And as Joe mentioned, I'd like to welc...welcome all of 

25 you to this administrative meeting of the FIFRA Science 
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1 Advisory Panel with the subject and a briefing on the

2 presentation of the approach to reevaluate atrazine. 

3 Before we begin, I'd like to have the 

4 members of the permanent FIFRA Science Advisory Panel 

5 introduce themselves and begin with Dan Schlenk. 

6 DR. SCHLENK: Good morning. My name is 

7 Dan Schlenk. I'm a professor of aquatic ecotoxicology 

8 at the University of California at Riverside in the 

9 Department of Environmental Sciences. My areas of

10 expertise are primarily mechanisms of action, merging 

11 contaminants, and pesticides in aquatic organisms. 

12 DR. HEERINGA: And I am Steve Heeringa, 

13 the chair, currently, of the FIFRA Science Advisory 

14 Panel. I'm a research scientist and professor at the 

15 University of Michigan. I'm an applied statistician by 

16 training. 

17 DR. POPE: Good morning. I'm Cary Pope. 

18 I'm a professor of toxicology at Oklahoma State 

19 University Center for Veterinary Health Sciences. I'm 

20 a neurotoxicologist, and my primary interest is in 

21 toxicity of pesticides. 

22 DR. PORTIER: Good morning. I'm Ken 

23 Portier, Director of Statistics at the American Cancer 

24 Society national home office in Atlanta. I'm an 

25 applied biostatistician with 30 years of experience in 
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1 agriculture and public health.

2 DR. CHAMBERS: I'm Jan Chambers. I'm a 

3 professor at the College of Veterinary Medicine at 

4 Mississippi State University. I'm a pesticide 

5 toxicologist with emphasis on neurotoxicology and

6 metabolism. 

7 DR. BUCHER: I'm John Bucher. I'm the 

8 associate director of the National Toxicology Program 

9 in Research Triangle Park at NIEHS. I have a general 

10 interest in all kinds of issues related to toxicology 

11 and...and carcinogenesis. 

12 DR. HEERINGA: Thank you very much, 

13 members of the panel, and I think at this point, with 

14 those introductions, that we're ready to begin, and I'd 

15 like to turn first to Steve Bradbury who is deputy 

16 director of the Office of Pesticide Programs in the 

17 EPA. Good morning, Steve. 

18 DR. BRADBURY: Thank you, Dr. Heeringa, 

19 and I'd like to welcome the panel to today's meeting 

20 and also thank Joe Bailey and the staff of the Office 

21 of Science Coordination and Policy for helping to 

22 organize the meeting today. 

23 I'd also like to introduce some of the 

24 colleagues with me today before I just give a brief 

25 little background to today's meeting. Dr. Tina Levine 
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1 will be speaking after...after I finish my comments as

2 the director of our Health...Health Effects Division. 

3 Next to her is Don Brady who's the 

4 director of our Environmental Fate and Effects 

5 Division. Elaine Francis, Dr. Elaine Francis from

6 Office of Research and Development is the national 

7 program director for ORD's pesticides and toxics 

8 research. And Dr. Ed Ohanian, to my left, is the 

9 director of the Health and Ecological Criteria Division 

10 in the Office of Water. 

11 As we'll be discussing briefly this 

12 morning, the science review plan that will be 

13 undertaken during 2010 includes close collaboration 

14 with our colleagues in the Office of Research and 

15 Development and the Office of Water, so I wanted to 

16 make sure they were here with us today as...as we go 

17 forward and outline what we'll be doing over the course 

18 of the next year or so. 

19 Tina...when...when Dr. Levine gives her 

20 comments, she'll introduce the members of our team or 

21 our team leaders who will be taking the point in...in 

22 going through the...the peer review process over the 

23 next year or so. 

24 As Joe indicated, today's meeting is an 

25 informational meeting. It's a meeting where we're...we 
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1 want to share with you in words to complement what's in

2 text with the paper that you all received about a month 

3 ago which is describing the...the science review plan 

4 over the course of the next year. So, the purpose of 

5 today's meeting isn't to get into the scientific issues 

6 associated with the upcoming peer review but to provide 

7 some context to the peer review and discuss, broadly, 

8 sort of the scope of each of the three peer reviews 

9 that we'll be having during the course of the 

10 coming...coming year. 

11 What I'd like to do is just spend a few 

12 minutes providing a little context on...on atrazine and 

13 its regulatory history. We'll touch on some of the 

14 previous Science Advisory Panel reviews that we've had, 

15 and then I'll turn it...turn it over to Dr. Levine who 

16 can go into a little bit more detail on the context 

17 of...of the upcoming year. 

18 Atrazine was first registered, actually, 

19 by USDA back in 1958 as a herbicide, a broad spectrum 

20 herbicide. It's used both at plant and post-plant, 

21 and, currently, it's primarily used in corn, sorghum 

22 production, sugarcane and, to some degree, in turf, 

23 especially in the southeast. 

24 In the early '80s, in 1983, EPA issued a 

25 registration standard which was some of the early 
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1 phrases associated with the registration process and

2 the re-registration process, and at that time, the 

3 Agency indicated that it wanted to keep track of the 

4 potential of cancer, carcinogenicity of atrazine, and 

5 also indicated the importance of groundwater and 

6 surface water protection with the use of atrazine. 

7 Throughout the 1990s, there were a 

8 series of voluntary adjustments to the label or to the 

9 use practices of atrazine, and these primarily focused 

10 on risk reduction measures to ensure minimal exposure 

11 to surface water and groundwater, particularly in the 

12 context of drinking water sources. 

13 And associated during the time frame of 

14 the 1990s, there were rate reductions, setbacks from 

15 wells, setbacks from stream banks and...and water 

16 bodies. Also at that time, the compound received a 

17 restricted use classification for just about all of its 

18 uses, and in large part, that was involving the need to 

19 try to keep the product from getting into the water due 

20 to runoff. 

21 In 1994, the Agency initiated a special 

22 review for not only atrazine but the other triazine 

23 herbicides, and the focus of that special review was 

24 around the potential for atrazine to cause cancer as 

25 well as the importance of minimizing exposure of
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1 atrazine to groundwater and surface water.

2 As we move from the '90s into the early 

3 2000s, there were two SAPs that were held, one in 2000 

4 and one in 2003. Essentially, the outcome of those 

5 Science Advisory Panel reviews was that atrazine was 

6 not likely to be carcinogenic in humans, and so, the 

7 concern about carcinogenicity was researched and 

8 studied during the '80s, during the '90s, leading to 

9 the SAP recommendations in 2000 and 2003 looking at 

10 prostate cancer, but sort of reaching the conclusion 

11 that it was not likely that atrazine was carcinogenic 

12 in humans. 

13 In January of...of 2003, the Agency 

14 issued an IRED, an Interim Re-registration Eligibility 

15 Decision which culminated much of the science that had 

16 been developing over the last ten years. In that

17 decision, we re-registered the product and incorporated 

18 some of the additional mitigations that I've described 

19 before in terms of protecting groundwater and surface 

20 water, also some additional protections for workers as 

21 well. And at that time, we also...the Agency also 

22 established a drinking water monitoring program to 

23 ensure the concentrations of atrazine in drinking water 

24 source waters as well as finished water did not reach 

25 our levels of concern. 
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1 In October of 2003, we issued a revised

2 IRED or Interim Re-registration Eligibility Decision 

3 which included a memorandum of agreement with the

4 registrants to sort of memorialize the monitoring

5 programs for drinking water. It also established a 

6 monitoring program associated with ecological systems, 

7 in particular, assessing whether or not atrazine was 

8 reaching levels of concern in terms of protecting

9 aquatic communities. Also, that IRED in October of 

10 2003 summarized where we were in terms of looking at 

11 the potential effects of atrazine on amphibian gonadal 

12 development as well. 

13 In 2006, the Agency issued a triazine 

14 cumulative risk assessment, and so, the atrazine

15 Interim Re-registration Eligibility Decision became a 

16 Registration Eligibility Decision, because the 

17 cumulative assessment had been completed for the

18 triazine herbicides. 

19 Right now, atrazine is scheduled to 

20 initiate registration review in...in 2013. 

21 Now, through all this time frame of the 

22 '80s and '90s into...into where we are today, as you 

23 all know, if not directly at least from your 

24 colleagues, your predecessors on the Science Advisory 

25 Panel, we spent a lot of time going through a number of 
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1 issues with the Science Advisory Panel to help guide us

2 in...in interpreting the science and...and, ultimately, 

3 to inform our decisions, and let me just do a quick 

4 snapshot on some of those previous SAPs. 

5 I mentioned the...the efforts to better 

6 understand the potential of atrazine to cause cancer 

7 and what some of its mechanisms and mode of action may 

8 be. There were peer reviews in 1998 as well as 2000 

9 that led us to the conclusion, with your advice and 

10 counsel, that the neuroendocrine mechanisms of action 

11 likely associated with atrazine with the cancer 

12 observed in rodents is probably not...is likely not to 

13 be operable in humans. However, the neuroendocrine 

14 mode of action was an important mechanism for us to 

15 focus on in terms of our risk assessment in human 

16 health protection. 

17 So, we went through that 2000 SAP, the 

18 conclusion that atrazine's mechanism of action was 

19 likely associated with the neuroendocrine mechanism of 

20 action. The cancer observed in rodents probably was 

21 not likely relevant in humans because of the 

22 differences in the biological models but focusing on 

23 that neuroendocrine mechanism of action as initiating 

24 events as being the focus of...of the risk assessment 

25 which was the focus, then, of that IRED in 2003.
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1 In 2002, we also had a Science Advisory

2 Panel looking at the cancer issue in, for example, 

3 prostate cancer, looking at a study in a manufacturing 

4 plant where atrazine was manufactured to determine 

5 whether or not there was an association between 

6 prostate cancer and atrazine exposure. The conclusion 

7 of that SAP in followup work was that it was not likely 

8 that atrazine was associated with the prostate cancer 

9 for the workers in that plant. However, the Agency 

10 continues to monitor the literature in terms of 

11 atrazine's potential cancer effects which I'll touch 

12 upon in a little bit. 

13 In addition to the...the reviews 

14 regarding human health, we also through the 2000s met 

15 with you four times to discuss atrazine's potential 

16 role in terms of ecological effects and risk, and there 

17 were two Science Advisory Panels discussing...exploring 

18 the potential of atrazine to cause gonadal 

19 developmental effects in amphibians. 

20 In 2003, we had an SAP that looked at 

21 literature that had been published at the time and 

22 proposed that the literature established a strong 

23 hypothesis that atrazine may be able to cause amphibian 

24 gonadal development effects, and we proposed a research 

25 or a study design to you to follow up on that 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 13

 

1 hypothesis, and we sort of worked through that.

2 And then, with your advice on that study 

3 protocol, asked the registrant, required the registrant 

4 to do that study protocol and then came back in 2007 

5 with the results from that study as well as other

6 literature that had been published in the open 

7 literature since that time and concluded from that peer 

8 review that at least up to 100 ppb atrazine, we weren't 

9 seeing effects on gonadal development. But again,

10 focusing on ongoing research as it gets published in 

11 the literature since 2007. 

12 We also spent some time, two SAPS, one 

13 in 2007 and one just this last spring, looking at the 

14 effects of atrazine on aquatic communities, in 

15 particular, getting feedback on how to interpret

16 effects of atrazine on aquatic communities and how to 

17 integrate that with the monitoring program to help 

18 elucidate where there may be vulnerable watersheds in 

19 terms of...of atrazine exposure. 

20 Given sort of where we are in the state 

21 of the science, our focus for 2010 is to focus on the 

22 human health effects as our...as our area of emphasis 

23 as we go into 2010, and we'll revisit some of the 

24 ecological effects after we get through the...the human 

25 health effect risk assessments. 
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1 So, what will be...if I could have the

2 next slide forwarded please...what our white paper 

3 describes is a series of...of three peer reviews 

4 over...over 2010. We'll just wait a second and see if 

5 this slide will come up. There you go...so there will 

6 be a series of three Science Advisory Panel meetings, 

7 one in February 2010, one in April of 2010, and one in 

8 September of 2010. 

9 As we put forth our science...our review 

10 plan, we wanted to take advantage of...of SAPs that we 

11 already had scheduled. As you know, in February 2010, 

12 we already had a Science Advisory Panel meeting 

13 scheduled on the issue of how to incorporate 

14 epidemiological studies with experimental studies and 

15 how to develop those lines of evidence and integrate 

16 those lines of evidence. 

17 And what we've done is added a case 

18 study to that February SAP which will look at some 

19 recent epidemiological studies associated with atrazine 

20 and get some advice not only on those studies but also, 

21 more broadly, methodological insights into how to 

22 integrate different kinds of epidemiological study 

23 designs as well as, more broadly, how to integrate 

24 epidemiological studies with experimental studies. 

25 So, in a sense a building block as we 
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1 move throughout...through the year. That panel meeting

2 will also include some discussion around the 

3 agricultural health study and how to take a look at 

4 different ways of estimating exposure in different 

5 kinds of epidemiological studies and how to integrate 

6 some of that information. 

7 In April 2010, we'll focus on 

8 experimental studies, both in vitro and in vivo 

9 studies, and review the previous risk assessment,

10 review any new information that's come out since that 

11 time, and take a look at some of the critical aspects 

12 of hazard identification, dose response relationships, 

13 as Tina will describe in a bit more detail. 

14 We'll also take a look at how our 

15 toxicological interpretation influences sampling

16 designs in terms of monitoring drinking water sources 

17 to ensure the frequency of sampling matches the 

18 dosimetry that we're elucidating through the 

19 toxicological studies. 

20 So, that's a new review that wasn't 

21 scheduled previously. 

22 The September 2010 SAP, again, will 

23 build on an SAP that was already scheduled. As I

24 mentioned before, we continue to look at the potential 

25 of atrazine to cause cancer. As I said, we've 
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1 determined that atrazine is not likely a human

2 carcinogen. 

3 However, we wanted to keep track of 

4 epidemiological studies as they progress and, 

5 particularly, the ag health study which has two or 

6 three studies that we anticipate being published this 

7 spring or summer which will be very important to take a 

8 look at the cancer issue. 

9 So, in 2010, we'll not only take a look 

10 at the ag health study; we'll look at other epi studies 

11 in terms of cancer, non-cancer, integrate that with the 

12 animal or the experimental toxicology studies, and try 

13 to bring it all together in September, 2010. 

14 In closing, before I turn it over to 

15 Tina, I just want to indicate that as we approach this 

16 peer review process, we'll be taking advantage of 

17 Agency guidance in terms of how we do risk assessments, 

18 in terms of the NAS. 

19 And the risk assessment paradigm, using 

20 our risk characterization handbook in terms of ensuring 

21 transparency and clarity, consistency, reasonableness 

22 in how we interpret our assumptions and integrate the 

23 data and also be taking a look at the National Academy 

24 report on 21st century toxicology, the importance of 

25 toxicity pathways, and how to interpret the information 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 17

 

1 that will be before us.

2 So, with that, unless there are any 

3 clarifying questions, I'll turn it over to Dr. Levine 

4 now. 

5 DR. HEERINGA: Thank you, Dr. Bradbury. 

6 Dr. Levine? 

7 DR. LEVINE: Thank you. I would also 

8 like to thank the panel for all the time and effort you 

9 bring to bear on our risk assessments, and your input 

10 is critical to ensuring that our risk assessments are 

11 transparent and are based on strong science. 

12 And I would like to introduce at least 

13 the shell of the team. There's going to be a lot of 

14 people in HED working on this over the next year. I 

15 would like to introduce the...the leads for the 

16 project. First, Dr. Anna Lowit who's to the left of 

17 Steve Bradbury is going to be the overall lead for the 

18 three SAPS, and she also has the lead on the February 

19 meeting. 

20 And next to her is Dr. Elizabeth Mendez 

21 who is taking the lead for the April meeting that's 

22 going to look at the laboratory data. 

23 And to the left of Ed Ohanian is soon24 to-be Dr. Carol Christiansen who's finishing her Ph.D. 

25 in epidemiology and is going to take the lead on the 
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1 September meeting.

2 So, this is going to be...these are 

3 going to be our principal players, but there are going 

4 to be a lot of people going through a lot of studies 

5 and working through the issues. 

6 And I...a lot of this I think Steve has 

7 touched upon and I will be brief, but as Steve said, we 

8 signed the...the atrazine RED in 2003, and we used the 

9 best available science at the time to support the RED, 

10 and we used well accepted and publicly vetted Agency 

11 guidance in the way we approached it and also had three 

12 SAPS on the human health side, the one in 1998 that 

13 looked at the mammary gland tumors in rats, the one in 

14 2000 that looked at the neuroendocrine mode of action, 

15 and the 2003 SAP on epidemiology of prostate cancer. 

16 We based our...our science on a mode of 

17 action approach as the foundation for our dose response 

18 and extrapolation from animals to humans and among 

19 humans, and the 2000 SAP supported this approach, and, 

20 basically, we believe that atrazine works via a 

21 neuroendocrine mode of action which ultimately leads to 

22 the various toxic effects that are seen in the animal 

23 data. 

24 And as our point of departure, we used 

25 attenuation of the pre-ovulatory luteinizing hormone 
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1 surge as a biomarker of disruption of hypothalamic

2 function, and that's what we are basing...based our 

3 risk assessments of various scenarios on. 

4 In this year-long review, we'll be 

5 looking at a thorough, objective review of new science 

6 and integrating it into the existing science that we 

7 based our 2003 RED on. 

8 We'll be placing emphasis on evaluating 

9 mode of action and action pathways to toxicity, because 

10 we believe that understanding how a chemical works in 

11 the body will help us better interpret dose response 

12 data, life stage susceptibility, and the factors that 

13 lead to susceptibility, and also that mode of action 

14 provides a strong science for explicitly considering 

15 human relevance, the relevance of animal data to...to 

16 human health effects. 

17 We'll be reconsidering all aspects of 

18 the hazard assessment, specifically, the critical 

19 effects used to extrapolate risk, the points of 

20 departure used for the margin of exposure calculation 

21 and the relevant durations of exposure, and, finally, 

22 the...the life stage susceptibility and what impacts 

23 the statutory requirement for the 10x factor to protect 

24 infants and children unless we have strong science 

25 that, data that allows us to change that.. 
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1 And as Steve mentioned, we're doing this

2 through three SAPs, and so the rest of this talk is to 

3 basically try to provide a little bit more detail on 

4 the three SAPs. 

5 Again, the February meeting has...has 

6 always been on the schedule, and it really has a 

7 broader purpose than just atrazine, but some of the 

8 atrazine data fits very well into the broad purpose of 

9 the February meeting. 

10 We had planned to do this meeting for a 

11 while, because especially with all of the data coming 

12 out of the Ag Health Study which is a rather major 

13 prospective study of 90,000 certified pesticide 

14 applicators from North Carolina and Iowa, that's a 

15 collaboration between NCI and NIHS and EPA, both the 

16 pesticide program and the ORD scientists, we've been 

17 getting information and we're getting regular updates 

18 on various outcomes of the epidemiological prospective 

19 study, and we realized that we needed to develop a 

20 framework for incorporating this data...these data into 

21 our risk assessments. 

22 So, what we plan to do in February is 

23 develop a white paper framework based upon...building 

24 on the human relevancy framework that the Agency

25 already has, and...and that was a big part of what we 
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1 were planning to do in February, and we wanted to

2 basically vet this framework with some case studies. 

3 And our framework is going to use, you know, weight of 

4 evidence approach and best available information for 

5 humans and animals, and will again, as I said, 

6 emphasize mode of action and toxicity pathways, and 

7 it's quite consistent with guidance that's already out 

8 there that maybe doesn't specifically address a little 

9 of the epidemiology data that may be coming down the 

10 pike. 

11 And we also wanted to take advantage 

12 of...of increases of incident data. We've been beefing 

13 up our ability to analyze the data that we have 

14 from...from our 6A2 incident reporting and also from 

15 poison control center data, and so, we wanted to use 

16 this SAP to try and evaluate that, too. 

17 So, we're going to have three case 

18 studies, and the first case study will be the atrazine19 related case study, a review of several recent 

20 epidemiology studies that have been fairly well 

21 publicized and have come to our attention. And most of 

22 these, I think, are in the category of 

23 hypothesized...hypothesis generating, some, a lot of 

24 them are ecologic, and we will be soliciting comments 

25 from the panel on ways to consider these types of 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 22

 

1 studies in risk assessment.

2 And then, the second case study is going 

3 to involve the Ag Health, but it's not...it's going to 

4 be actually the exposure part of the Ag Health. We're 

5 going to be...we're in the early stages of performing a 

6 side by side comparison of the exposure assessment 

7 approaches used in the Ag Health study to those that 

8 OPP routinely uses. And the second component of the 

9 exposure assessment case study involved evaluating co10 exposure to multiple pesticides. 

11 The third case study will involve a 

12 retrospective analysis of reported human incidents from 

13 exposure to an organophosphate pesticide that 

14 historically has been used in residential settings. 

15 It's important for the panel and the 

16 public to keep in mind that although the February SAP 

17 will explicitly involve consideration of some atrazine 

18 epidemiologic studies, there really is a broader intent 

19 for this meeting. 

20 The second SAP in 2010 is planned for 

21 April and will focus on experimental laboratory 

22 studies, from both in vitro and in vivo situations, and 

23 we will discuss our preliminary considerations for the 

24 updated hazard identification and dose response 

25 characterization. And as I will discuss in a few
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1 minutes, we will also be discussing...and, actually,

2 Steve mentioned it... that we'll also discuss some of 

3 the drinking water monitoring issues. 

4 We will be performing a comprehensive 

5 literature review of studies related to human health 

6 for atrazine. The April meeting will focus on our

7 preliminary evaluation of these studies. 

8 As I noticed...I noted a few minutes 

9 ago, we're going to emphasize mode of action as a

10 starting point for thinking about the dose response and 

11 life stage susceptibility, and we will also consider 

12 those studies used in the 2003 assessment as well as 

13 more recent studies investigating a variety of 

14 hypotheses. For example, we have identified new 

15 studies on mammary gland development, neurotoxicity, 

16 endocrine disruption, immunotoxicity, and studies on 

17 atrazine metabolites that we will be considering. 

18 In April, we will be soliciting comments 

19 on our preliminary review of the updated critical 

20 effects and our preliminary evaluation of dose 

21 response. And one of the key areas of interest in the 

22 new analysis will be evaluating life stage effects and 

23 considering the factors that lead to life stage 

24 susceptibility as we think about the science that 

25 informs the FQPA 10x factor. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 24

 

1 As Steve told you a few minutes ago, the

2 temporality of the critical effect is an important 

3 aspect of this risk assessment. This is because 

4 monitoring frequency for community water systems should 

5 be related to toxic effects being used to develop the 

6 human health risk assessment. 

7 In light of this, we'll be putting a lot 

8 of focus during our analysis on considering 

9 developmental windows of susceptibility, time course of 

10 toxicokinetic and toxicodynamic factors. 

11 Drinking water exposure is the major 

12 pathway by which people are exposed in the United 

13 States to atrazine. Temporal window is relevant for 

14 toxicity endpoints that inform the exposure assessment. 

15 Specifically, in a case where acute effects are of 

16 greatest concern, monitoring must be done more 

17 frequently to ensure that the peaks are detected and 

18 also if chronic effects, like cancer, are of greatest 

19 concern, then monitoring can be done less frequently. 

20 For the September meeting, the Agency 

21 will solicit comments from the SAP on three areas, 

22 epidemia out...epidemiological studies on cancer and 

23 non-cancer effects, experimental studies/laboratory 

24 studies on cancer and non-cancer effects, and pulling 

25 it all together, the integrated weight of evidence, 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 25

 

1 hazard dose response and exposure assessment and

2 characterization. 

3 The epidemiology studies, we expect to 

4 have new studies from the Ag Health study. It's 

5 expected, I think, in the spring, and there will be 

6 other scientific reports, and there also will be the 

7 epidemiology studies that we first raise in February, 

8 in the February meeting next...that's coming up early 

9 next year, and other scientific reports. 

10 We will discuss a weight of evidence 

11 approach in February which involves using the best 

12 available science from humans and animals, and we plan 

13 to apply this approach at the September meeting.

14 Specifically, we will integrate all of the information 

15 in February and April along with additional 

16 epidemiology studies and do a new hazard 

17 characterization for atrazine. 

18 In the event that new studies come out 

19 between April and September from in vitro or in vivo 

20 studies, we'll also include these. And at the 

21 September meeting, we'll provide our proposals for 

22 updated points of departure and FQPA safety factors. 

23 We will also update our thoughts on 

24 sampling frequency considerations based on the April 

25 SAP and if there are any potential revisions in 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 26

 

1 sampling design options, or if any changes in the

2 atrazine risk assessment are proposed, those will be 

3 discussed at the September meeting. 

4 And in light of the new science and the 

5 feedback we get from the panel, the Agency will 

6 determine if the risk assessment for atrazine should be 

7 revised and whether the drinking water monitoring

8 frequency requirements should be changed. 

9 So, again, here is the summary slide 

10 that Steve gave you at the end of his talk. At the 

11 February meeting, we're incorporating the epidemiology 

12 study and human health incident data and risk 

13 assessment. We're also going to be doing some stuff 

14 on...work on exposure assessments in epidemiology and 

15 comparing them to other...other ways in which we assess 

16 exposure, and we're going to do a case study using 

17 recent atrazine hypothesis generating epidemiology 

18 studies. 

19 In April will be the preliminary 

20 evaluation of in vitro and in vivo lab studies, 

21 preliminary identification of critical effects and dose 

22 response assessment and some discussion of the 

23 frequency of atrazine monitoring in drinking water 

24 sources. 

25 And in September, we will focus on the 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 27

 

1 epidemiology studies for cancer and non-cancer,

2 integrate everything into a weight of evidence and 

3 hazard characterization, and, again, revisit the 

4 frequency of atrazine monitoring in drinking water 

5 sources. 

6 And with that, I thank the panel for 

7 their time and attention. 

8 DR. HEERINGA: Thank you very much, Dr. 

9 Levine. 

10 Just an opportunity for quick questions 

11 of clarification from the...the panel members for 

12 either Steve Bradbury or Tina Levine? 

13 (No response.) 

14 DR. HEERINGA: With that, I think we'll 

15 have an opportunity after the period of public comment, 

16 too. They will be here. Are we ready to move on then? 

17 At this point in our meeting, then, I 

18 believe we're ready to move on to the period of public 

19 comment. I just want... 

20 OFF THE RECORD 

21 (WHEREUPON, there was a pause in the proceedings.) 

22 DR. HEERINGA: Okay, let's return to the 

23 proceedings of our meetings. For anyone who has joined 

24 us through the teleconference line to...as a companion 

25 to the webcast, welcome to this morning's informational 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 28

 

1 meeting of the FIFRA Science Advisory Panel on the

2 presentation of the approach to reevaluate atrazine. 

3 We are at the point in the morning 

4 meeting where we have an opportunity for public 

5 comment, and we have eight parties that have registered 

6 with Joe Bailey to present public comment, but before 

7 we begin those, I would like to draw your attention 

8 also to the docket for this meeting in which there 

9 are...I won't try to count it but approximately eight 

10 double-spaced pages of registered docket comments from 

11 various parties who have submitted public comment, 

12 written form public comment and supporting materials 

13 for this meeting. 

14 This morning, though, we're going to 

15 hear from eight public commenters representing various 

16 groups and various interests, and they will be called 

17 up to present in order that they were registered with 

18 Joe Bailey, and I'd like to begin with Scott Slaughter 

19 of the Center for Regulatory Effectiveness. So, Scott, 

20 are you here? 

21 It could be possible to use any one of 

22 these microphones on the side. 

23 MR. SLAUGHTER: That works. I'm Scott 

24 Slaughter, and I'm here commenting on behalf of the 

25 Center for Regulatory Effectiveness. We have three 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 29

 

1 comments at this point.

2 First, any alleged endocrine effects 

3 from atrazine should be reviewed and assessed by the 

4 endocrine disruptor screening program, not these SAPs, 

5 not any other process within EPA. 

6 Second, these SAPs are not motivated by 

7 science. They are politically motivated. 

8 Third, the EPA political appointees need 

9 to defend the SAPs and the EPA staff who've worked on 

10 atrazine in the past from the personal attacks on their 

11 competency that have been waged by various NGOs, blogs, 

12 and media and individuals. 

13 The first point is that any alleged 

14 endocrine effects from atrazine should be reviewed and 

15 assessed in EDSP, not in EPA's proposed SAPs and not in 

16 some other context at EPA. EPA has already send out 

17 EDSP test orders for atrazine. 

18 EPA told the EDSP SAP that the EDSP 

19 process would identify any endocrine effects by 

20 pesticides, including atrazine. If so, then 

21 additional review of endocrine effects by these SAPs or 

22 by any other parts of EPA would be an unnecessary and 

23 duplicative waste of resources. 

24 If what EPA told the EDSP staff is not 

25 correct, then EPA should withdraw and rethink its EDSP 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 30

 

1 test orders for atrazine, because they do not do what

2 EPA said they would do. 

3 A second point is that EPA's new 

4 proposed SAPs have nothing to do with new science. 

5 They're all about politics. Atrazine had a clean 

6 review from EPA as of July, '09 on the EPA web site. 

7 Then, the NRDC published a propaganda piece about

8 atrazine. A dying newspaper, the New York Times, then 

9 ran an unbalanced opinion piece based on the propaganda 

10 piece by NRDC. And, according to the Huffington Post, 

11 Senator Boxer then ordered EPA to go after atrazine, 

12 and EPA followed orders. 

13 These SAPs are bad politics, and they're 

14 a colossal waste of scientific time. EPA hasn't even 

15 given this SAP any SAP charges. Consequently, we

16 suggest that the SAP consider making its own charges 

17 and tell EPA not to propose any further atrazine SAPs 

18 until and unless the Agency can justify them on the 

19 basis of EPA-reviewed data that meet Agency quality 

20 standards, including the Information Quality Act

21 predissemination review standards. 

22 Our third and last point is that various 

23 blogs, NGOs, and individuals have attacked the 

24 competence and integrity of EPA career staff that have 

25 worked on atrazine in the past. Some of their attacks 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 31

 

1 have been directly at named EPA individuals and violate

2 all civilized standards of professional debate. 

3 Because EPA's assessment and regulation 

4 of atrazine has always been based on review by SAP 

5 scientists, these attacks also challenge the competence 

6 and integrity of the seven SAPs who have reviewed

7 atrazine over the last 15 years under four 

8 administrations, including President Clinton's 

9 Democratic administration. 

10 We ask the current EPA political 

11 appointees to publicly state their competent...their 

12 confidence in the competence and integrity of the EPA 

13 career staff and the SAP scientists who have reviewed 

14 and regulated atrazine in the past. This public 

15 statement of support is necessary to protect Agency 

16 staff and scientists who are being bullied and to 

17 demonstrate that science and civil discourse are still 

18 the rule at EPA. 

19 Thank you. 

20 DR. HEERINGA: Thank you very much, Mr. 

21 Slaughter. 

22 At this point, we have a second public 

23 comment presentation which, in agreement and 

24 prearrangement with Joe Bailey, the Designated Federal 

25 Official, will run a little longer. This is a 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 32

 

1 presentation by Syngenta Crop Protection and includes

2 Janice McFarland, Dr. Janice McFarland, Dr. Peter

3 Hurdle, and Dr. Charles Breckenridge. 

4 And if they would like to come forward, 

5 and why don't we use these chairs here on the side? I 

6 believe there is a presentation set of slides for the 

7 panel members that should be in your packet. Dr. 

8 McFarland will take the lead. 

9 DR. MCFARLAND: Thank you, Mr. Chairman, 

10 for the opportunity to be here today and to the panel 

11 and also to EPA. 

12 We look forward to...I'm Janice...I'm 

13 Dr. Janice McFarland, and my background is that I 

14 started with our company 23 years ago as a metabolism 

15 chemist doing guideline studies for...for...in the 

16 environmental animal and plant metabolism, guideline 

17 studies under EPA. 

18 I then in 1994 was the manager of the 

19 atrazine, triazine special review at the initiation of 

20 that...at the initiation of that review and then stayed 

21 involved in the science regulatory process for the 

22 triazines since that time. I'm currently...and since 

23 2000 have been the head of regulatory affairs for 

24 Syngenta for the U.S. and Canada and Mexico. 

25 Syngenta, for a little background for 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 33

 

1 those who don't know the company, is a world leader in

2 the discovery and development, registration and 

3 stewardship of agricultural tools. We currently 

4 steward approximately 75 different fungicides, 

5 herbicides, and insecticides. Atrazine we have been 

6 the principal steward of for the past 51 years and have 

7 greatly appreciated the thorough and comprehensive 

8 scientific reviews of that product. 

9 I'm happy to be here today with two of 

10 our top leading scientists and all who have many, many 

11 years of experience on the atrazine safety profiles. 

12 They are Dr....to my far left, Dr. Charles 

13 Breckenridge. He's a senior research fellow with

14 Syngenta, and he has been the leading mammalian 

15 toxicologist and the lead scientist on the mode of 

16 action of atrazine. 

17 I also have Dr. Peter Hurdle with us. 

18 He is Syngenta's head of product safety for the U.S., 

19 Canada, and Mexico and has been the lead environmental 

20 exposure and monitoring and characterization scientist. 

21 We're all happy to be here today. 

22 We'd like to thank the SAP for...I'd 

23 like to thank the SAPs for all the contributions on the 

24 work and review of atrazine over the last 20 years as 

25 well as the extensive work of the Agency scientists 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 34

 

1 who, throughout that process, there's been an

2 advancement of not only basic research but the 

3 understanding of safety testing for both atrazine and 

4 for all products. 

5 The thorough review that's been well 

6 documented in the white paper has been going on for 

7 some...for 20 years. It's an unprecedented state of 

8 the art science data base, and as Dr. Breckenridge will 

9 share with you, the regulatory endpoints are 

10 conservative and very protective. 

11 Independent reviews, you often don't 

12 hear about the other regulatory authorities around the 

13 world have also confirmed atrazine's safety in recent 

14 years, and I'll go over that a little bit, but the 

15 process in the U.S. EPA has been very transparent, and 

16 since 2000 alone, there have been opportunities for 

17 more than 16 public comment periods. And as many of 

18 you know and have been involved with, there have been 

19 six SAPs alone since 2007 since the re-registration. 

20 This time line we don't need to go into, 

21 because Dr. Bradbury and also Dr. Levine discussed 

22 various aspects of it. This is a time line just 

23 documenting all the different work since 2000, the key 

24 milestones and key regulatory milestones with the U.S. 

25 EPA, and if you go back, it was in the, as they 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 35

 

1 mentioned prior, it was '88 when the re-registration

2 started. 

3 An SAP was held in '88. In '88, also 

4 health advisory limits were established by the Office 

5 of Water, and the NCL was promulgated for the water 

6 standard for...was promulgated by EPA's Office of Water 

7 in 1991. The special review started in 1994. 

8 There are some public comment periods 

9 that people don't realize have happened that...that 

10 really add to the transparency of the last 20 year 

11 review. 

12 For instance, if you look at that '02 

13 time frame and you see the public technical briefing on 

14 atrazine, prior to that, in '01 when EPA completed 

15 their preliminary health reviews and the preliminary 

16 science...environmental science reviews, those are put 

17 out for people to review and there are 60-day public 

18 comments. So, throughout this time line, there's

19 extensive opportunity for transparent public comment 

20 and information exchange. 

21 Around the world, there has been a 

22 systematic review. So not only by U.S. EPA, but a 

23 systematic comprehensive review by different regulatory 

24 authorities, and in this time...this particular graph 

25 is focused on the cancer decisions for the 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 36

 

1 International Agency on Research in Cancer. Looked at

2 atrazine in 1999. 

3 Different regulatory bodies to look at 

4 the registration, the registerability of atrazine and 

5 the cancer classification began with the European

6 Union. The United Kingdom was the science rapporteur, 

7 and...and they looked at atrazine thoroughly in both 

8 '96, 2000, and then again in 2003. 

9 The U.S. EPA, we all know here. 

10 Canada...Canada just completed their review of 

11 atrazine, and they came out with documents in 2003, 

12 '04, and then '07. And Australia came out with 

13 documents and reports and conclusions of reviews in '04 

14 and '08. 

15 If you look at the World Health 

16 Organization, the last column there, the World Health 

17 Organization and the United Nations Food and Ag 

18 organizations...that's a joint meeting for pesticide 

19 residues...was held in 2007. 

20 For all of these different 

21 regulatory...regulatory authority reviews and 

22 decisions, they determined that it was non- genotoxic, 

23 atrazine was not genotoxic, that its mode of action was 

24 not relevant to humans, and gave the cancer 

25 classification as not likely to cause cancer in the 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 37

 

1 language of the different regulatory, that the

2 different regulatory authorities use. Either not 

3 classifiable or not likely to cause cancer. 

4 If you...when the reviews are extensive 

5 of many different studies. This is one just from the 

6 World Health Organization. It documents that the 

7 reviews are comprehensive, that the mode of action is 

8 well understood, that epidemiology research was 

9 reviewed and looked at, that atrazine is non10 development...developmental toxicant or and...and it 

11 does not cause harm to fetuses, infants, and children. 

12 Other quotes just from some of these 

13 reviews, often because atrazine is not registered in 

14 Europe, people erroneously conclude that that was due 

15 to science or health reviews, and that...that is not 

16 true. The science and health assessments conducted by 

17 European Union authorities, with the United Kingdom 

18 being their science rapporteur and France also held 

19 their own review, all determined that atrazine could be 

20 safely used. And so, the quote from France, they don't 

21 represent a public health. The United Kingdom, that 

22 atrazine can be used without harm to animal health or 

23 the environment. 

24 And then, the most recent regulatory 

25 authority review around the world outsi...since the 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 38

 

1 cumulative risk assessment conducted by EPA in 2006 was

2 done by the Australian regulatory authorities and

3 determined that atrazine was not...not carcinogenic and 

4 also did not have developmental effects and could be 

5 safely used as a weed control tool. 

6 With that as a backdrop, I'm going to 

7 turn over the...turn over the presentation to Dr.

8 Breckenridge who is going to give a brief overview of 

9 the human safety assessment of...of atrazine. 

10 DR. BRECKENRIDGE: Thank you, Janice. 

11 My name is Charles Breckenridge. I'm a senior research 

12 fellow with Syngenta. I have been involved with the 

13 atrazine safety profile and exposure characterization 

14 for more than 22 years now. 

15 We at Syngenta were the first ones to 

16 discover that atrazine caused mammary tumors in 1986, 

17 and since that time, we have been working with a group 

18 of outside researchers to assist us to understand the 

19 processes associated with the cancer response in

20 animals and, subsequently, other...other effects that 

21 we have proposed as the mode of action underlying that 

22 tumor response. 

23 Some of my colleagues that are not here 

24 with me today and who have contributed substantially to 

25 the development of knowledge on atrazine include the 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 39

 

1 head of our endocrinology team, Dr. James Simpkins.

2 He's from the University of North Texas, and you all 

3 have probably met him at earlier SAPs. 

4 Dr. Robert Handa who's at...now at the 

5 University of Arizona, previously at Colorado State 

6 University, has continued to work on the mode of action 

7 relative to the effects on GnRH neurons. Dr. Russ

8 Holvey from the University of California Davis is

9 working with us today, currently on mammary gland

10 development studies. 

11 Evan Simpson is an aromatase expert from 

12 Prince Henry Institute in Australia, is working with us 

13 on stereogenic factor 1 and the postulate that atrazine 

14 regulates that factor and is responsible for aromatase 

15 expression. Jack Mandel, who's served with us on a 

16 number of epidemiology SAPs, particularly, the 

17 prostate cancer SAP, and has also done a critical case 

18 control study at our production facility relative to 

19 prostate cancer. 

20 Jim Slinberg is an expert in weight of 

21 evidence characterization now at the University of 

22 North Carolina, Chapel Hill, has also been working with 

23 us over the years, and undoubtedly, you will hear from 

24 all of these gentlemen as we move forward with...with 

25 new data as it pertains to questions that are raised by 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 40

 

1 the EPA and the published literature.

2 For today, we intend to...to not take 

3 our standard approach of presenting data and reasoned 

4 logic and reaching conclusions. Rather, we intend to 

5 sort of summarize in a captioned way what has been 

6 known as we've gone through the development of 

7 knowledge on the atrazine hazard profile, exposure 

8 characterization and risk. 

9 So, that is not the way we will operate 

10 in subsequent SAPs. We will present data. We will 

11 reason through logic, and we will reach scientific 

12 conclusions, and, hopefully, you'll concur with our 

13 interpretation of our own data and other data, but for 

14 today, we're just going to summarize in a nutshell what 

15 we believe to be true based on more than 22 years of 

16 research on atrazine. 

17 And I should say, just as a...a 

18 first...they don't seem to be advancing...okay...so 

19 that we will give just a brief description of the 

20 comprehensive database that exists, the safety profiles 

21 that have been characterized, the safety standards that 

22 EPA has endeavored to set based on the effects that 

23 have been observed with atrazine in animal models, and 

24 the perspective of exposure relative to those safety 

25 standards, especially as it pertains to exposure via 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 41

 

1 drinking water.

2 This slide represents a...a picture 

3 of...of our database within the company, and each of 

4 these is not necessarily a single study, but it 

5 represents a project, and it comprises areas of study, 

6 including herbicidal properties, physicochemical 

7 properties, environmental fate transport, environmental 

8 effects, toxicity, mode of action, metabolism, 

9 kinetics, dynamics, risk assessment methodologies. So, 

10 that over the course of...of near 50 years, many

11 studies have been conducted, and some of those have 

12 been brought forward and have shown to be greatly 

13 critical for this risk characterization for atrazine. 

14 Other people have, obviously, developed 

15 an interest in atrazine as well. In the public domain, 

16 we keep track of published...any new published studies 

17 as, apparently, others do, and we note that there is an 

18 exponential growth in publications. We do pay 

19 attention to that literature, and to the extent that we 

20 see a study has implications that are critical for the 

21 human safety, we endeavor to investigate those studies 

22 and perhaps even try to replicate them and understand 

23 what they're telling us. 

24 These are in vitro, in vivo, mode of 

25 action across the whole spectrum, and that's basically 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 42

 

1 our strategy of continuing to keep updated on what is

2 happening in the literature relative to atrazine and 

3 whether or not the concepts that are developing in the 

4 literature that are at odds with the regulatory 

5 standards are our own perception of...of what atrazine 

6 does. 

7 Now, in regard to regulatory standards, 

8 obviously, Syngenta and other registrants are obligated 

9 to provide specific high-quality studies that are well 

10 documented in terms of standards of excellence, and our 

11 database on atrazine has repeatedly grown and been 

12 updated as new concepts and new protocols have been 

13 developed and new approaches have been taken. In the 

14 areas of mutagenicity, we have within our own database 

15 and within the published literature, there are more 

16 than 50 studies. 

17 When I speak of atrazine, I speak of 

18 atrazine in the mono and dealkylated metabolites as 

19 well as hydroxyatrazine, because effectively, EPA 

20 reached a conclusion which we concur with that atrazine 

21 should belong to a common mode of action group with the 

22 chlorotriazines, and so, when you speak of atrazine, 

23 you should speak of the chloro metabolites. We did 

24 lifetime studies on hydroxy metabolite as well which 

25 happens to be a...a major plant metabolite, and we 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 43

 

1 demonstrated that it, in fact, had a different mode of

2 action distinct from the chlorotriazines. 

3 So, in the course of studies that we've 

4 done, we've done full databases or part databases on 

5 the metabolites and as well as the parent. We've done 

6 mode of action studies in parent and we've done cross7 over studies to metabolites so we can appreciate, in 

8 fact, where the toxicity might be coming from. 

9 You should be aware that for a human 

10 that is exposed to atrazine, atrazine's half-life in 

11 the body is very short. It actually gets converted 

12 very quickly to the dealkylated metabolites and 

13 conjugated metabolites so that, in fact, the issue 

14 isn't atrazine. It's...it's the biotransformation 

15 products in the body, and we've been involved in that, 

16 in those investigations. 

17 Overall mode of action work on the 

18 cancers led us to the first question, is it 

19 carcino...is it a mutagen, and the answer seems to be 

20 resoundingly clear that it is not, and that is pretty 

21 well, from our viewpoint, no matter how many additional 

22 studies might or might not get published, is off the 

23 table as a serious consideration for its mode of

24 action. 

25 We have studied whether atrazine 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 44

 

1 directly mimics estrogen, androgen, or the thyroid

2 hormone. EPA's own research lab has been very much 

3 involved with this work. There are now more than 40 

4 published studies on whether atrazine has estrogenic or 

5 anti-estrogenic properties, and in 2008, Aldridge, 

6 et.al. reviewed those studies and wrote up a...a weight 

7 of evidence on that. The conclusions are that atrazine 

8 does not operate as a direct hormone mimic in any of 

9 these vectors, and these are the principal targets for 

10 the endocrine disruption screening. 

11 I think in 1994 when we first began this 

12 work, we kind of predated the concern for endocrine 

13 disruption. It turns out that atrazine had a mode of 

14 action relating to the endocrine system. We discovered 

15 that and today, I think, we're hearing a lot more 

16 interest in potential chemicals to do with effects on 

17 the endocrine system. 

18 As has been stated, the cancer mode of 

19 action has been well characterized. We've been 

20 involved with that research over the years. So has 

21 critical labs in EPA's ORD. And from these studies 

22 have been developed the critical no effect levels that 

23 currently set the standard of exposure to atrazine, and 

24 this is based on the suppression of luteinizing hormone 

25 which was mentioned as a surrogate for the endocrine 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 45

 

1 effects of atrazine.

2 Just so briefly we can say what 

3 that...that comprises is that atrazine seems to 

4 modulate the GnRH neurons which are a small set of 

5 neurons located in the preoptic area in the 

6 hypothalamic region of the brain. They are pulse 

7 generators that lead to pulsatile release of GnRH which 

8 travels to the pituitary and causes LH and FSH actually 

9 to be released. 

10 These have effects on the gonads, 

11 especially in females, to...to lead to ovulatory events 

12 and, in males, to regulate testosterone levels. And 

13 these processes play a critical role during onset of 

14 puberty in the sense that GnRH pulse generator plays a 

15 role in puberty onset as well as regulating 

16 reproductive function in the adult animal. 

17 So, the LH suppression that we see with 

18 atrazine at high doses is actually a decent surrogate 

19 for its effects on the endocrine system. We've been 

20 working with Dr. Handa for a number of years to try to 

21 understand precisely how and where atrazine operates on 

22 the GnRH system, and you'll hear more about that

23 research in...in subsequent meetings. 

24 (W(WHEREUPON, there was a pause in the proceedings.) 

25 DR. BRECKENRIDGE: So, the LH endpoints 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 46

 

1 that EPA utilized for short and long-term duration

2 exposures in their 2006 chlortriazine cumulative risk 

3 assessment, I will focus on two of them. The first one 

4 is the...for covering 90-day exposures and exposures 

5 that extend throughout a lifetime. This is based on an 

6 LH effect, that is, LH LH suppression in the Sprague7 Daly rat at 6 months of age or at 6 months of dosing, I 

8 should say, and this represents a no effect level, a 

9 1.8 milligrams per kg with 1000-fold uncertainty 

10 factor, including a 10x FQPA factor leads to a 

11 reference dose of 0.0018 mg/kg, and that is the basis 

12 for what we believe would be an acceptable standard for 

13 setting the...the chronic exposure to atrazine in 

14 drinking water. We'll come to what the current 

15 standard is in a minute. 

16 The second endpoint that was selected 

17 was 6.25 mg/kg no effect level from a study by Tammy 

18 Stoker in the ORD, a group in Research Triangle Park. 

19 She was studying a surrogate for LH suppression. She 

20 was looking at preputial separation in males, that is, 

21 the onset of sexual maturation in males which is

22 dependent on testosterone and, in turn, dependent on LH 

23 release. She established a no effect level in this 

24 study, and this was about a 20 or 30-day study. 

25 We have taken the liberty of plotting 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 47

 

1 the various studies available in the literature that we

2 could find on the Sprague-Daly rat in terms of duration 

3 of dosing and effect on LH. So, these NOELs are 

4 actually LH no effect levels in animals at different 

5 durations of treatment. So that Ralph Cooper has done 

6 a study in 2000 where he dosed animals for either 1 

7 day, 3 days, or 21 days. 

8 The no effect level for effects on the 

9 LH system at 1 and 3 days was 300 mg/kg. We have 

10 recently, through collaborators in Dr. Handa's lab, 

11 published a study with Fidori that the no effect level 

12 for, I believe it was, a 4 or 5-day treatment was 

13 around about 100. Cooper at 21 days showed it was less 

14 than 100. Our own study, Morrisette in 1996...I think 

15 that was a 28-day study, Stoker's around about 21 days, 

16 at 6.25 mg/kg, and as I stated, the Stoker study

17 actually sets the short-term reference dose for 

18 atrazine in regard to the LH effect. 

19 And, finally, the long-term LH effect. 

20 Now, you may think that this actually 

21 represents continuous effects of atrazine treatment on 

22 this LH system, but, in fact, it actually simply might 

23 reflect that the neuroendocrine system is very robust 

24 in the young adult animal, and as Sprague-Daly rats age 

25 endocrinologically, it becomes progressively damaged as 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 48

 

1 a result of continuous estrogen exposure.

2 It actually damages the arcuate nucleus 

3 and its regulatory process so that, in fact, this might 

4 simply reflect age-dependent deterioration of a control 

5 mechanism in the brain, and one would need a special 

6 set of studies to...to illustrate that point. 

7 So, the aspect of the young being more 

8 sensitive in regard to this effect, it does not seem to 

9 be supported by existing data where the actual aged, 

10 endocrinologically aged animal has the lowest no effect 

11 levels, whereas the young animals tend to have less of 

12 a response. 

13 Nevertheless, we come to finally taking 

14 those endpoints and establishing standards for drinking 

15 water, and the Agency has expressed concern about have 

16 we been able to properly characterize the frequency or 

17 the...the spikiness of atrazine exposure in drinking 

18 water. So, the postulate would be that somehow during 

19 a runoff event in agricultural season, we would miss a 

20 critical peak if we hadn't had very frequent 

21 monitoring. 

22 But put that in the context of the 

23 actual no effect levels in single day NOELs and we 

24 derive DW LOC, you can see that, in fact, in the short 

25 term, the animal tolerates the...the dose much better. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 49

 

1 So that single-day developmental NOEL, the Agency

2 actually didn't use LH. They used a developmental NOEL 

3 from a rapporteur ecology study which is 13 days of 

4 treatment. That NOEL is 10 mg/kg. 

5 The Stoker study for 30 days at 6.25, 

6 and the MCL was set in 1991 based on a chronic dog 

7 study where, in fact, that no effect level has been 

8 outdated to a...a higher level. That MCL, basically, 

9 has been in need of updating for...for more than 25 

10 years. 

11 Today, under the TCT cumulative risk 

12 assessment, EPA reached a viewpoint that 1.8 mg/kg is 

13 the no effect level of record for the most sensitive 

14 species in strength, and if you take that into a child, 

15 a child's body weight and water intake, you get a 

16 standard of 12.5 ppb considered to be safe in drinking 

17 water for lifetime exposure. 

18 Those limits are brought forward to you 

19 today so that you can see them in the context of the 

20 subsequent presentation by Dr. Hurdle who will 

21 characterize the presence and amount of atrazine in 

22 drinking water over the course of many years of 

23 monitoring. So, with that, I'll turn the lectern over 

24 to Dr. Hurdle unless there's any questions. Dr. 

25 Hurdle? 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 50

 

1 DR. HEERINGA: I think we'll wait. Thank

2 you, Dr. Breckenridge. Dr. Hurdle? 

3 DR. HURDLE: My name is Peter Hurdle. I 

4 thank the panel for the opportunity to comment, and 

5 without much ado, I would like to jump into the next 

6 slide which is entitled comprehensive drinking water 

7 exposure assessment. 

8 And very much like the presentation that 

9 Dr. Breckenridge gave about the number of studies that 

10 have been conducted, I have to say that drinking water 

11 exposure has been characterized by a huge number of 

12 research teams which include our own internal Syngenta 

13 research efforts, and we'll be speaking about that in a 

14 couple of minutes but also includes a huge body of data 

15 that has been generated under the Safe Drinking Water 

16 Act by the states, by universities, by academia, and by 

17 other research organizations. 

18 So, what I will try to show you in the 

19 next couple of minutes is the comprehensiveness of the 

20 monitoring database, that impact exists and has been 

21 generated over the last 20-plus years. The...our

22 ability to fully define the exposure protocols 

23 that...that consumers are potentially exposed to, we 

24 will actually show you that the current drinking water 

25 exposure levels demonstrate that we do achieve a large 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 51

 

1 margin of...of safety, and we will also show you that

2 the stewardship measures that have been undertaken over 

3 the last 15 years since the mid '90s, the label change, 

4 the setbacks and other mitigation language 

5 effectively...have been quite effective in reducing 

6 environmental concentrations in both well and finished 

7 water. 

8 So, if you...if you look at databases 

9 for drinking water exposure, data are generated, first 

10 and foremost, are the state drinking water monitoring 

11 programs which are community water systems that ensure 

12 quality control in their drinking water supplies to 

13 their consumers. You have about 51,000 community water 

14 systems in the...in the United States. About 40,000 of 

15 them are community systems and groundwater. 

16 If you look at the actual analytical 

17 record that has been generated since '93, to date, 

18 there are about 212,000 samples analyzed in those 

19 programs. These are all finished drinking water, and 

20 the bottom line is that detects in groundwater systems 

21 are extremely infrequent. Less than 1 percent of the 

22 system has a detect of atrazine, and if you find it, 

23 it's very low. The resulting, resulting margins of 

24 exposure greatly exceed 20,000. 

25 The margin of exposure would be here. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 52

 

1 The actual maximum concentration people might be

2 exposed to in a day or chronically as compared to the 

3 no effect level that was established for the 

4 appropriate time period. 

5 Which leaves us about 11,000 systems on 

6 surface water that do provide drinking water to, in the 

7 United States. Again, all these 11,000 systems were 

8 candidates for drinking water monitoring under the Safe 

9 Drinking Water Act, and they do sample finished water. 

10 They typically take quarterly samples, so four samples 

11 per year, sometimes less, and most of the systems that 

12 are in areas of potential high atrazine exposure have a 

13 record of about 16 years of data, because they 

14 initiated the sampling program in 1993 and it's still 

15 active today. 

16 So, this is the...the state database. 

17 The state database is supplemented by two high 

18 intensity sampling monitoring programs. The first one 

19 was voluntarily initiated by Syngenta in 1993 and 

20 continued until February, 2003. It included the most 

21 vulnerable community water systems that were producing 

22 surface water and supplying it as drinking water, 

23 mainly in water systems in the Midwest and in the 

24 South. We had up to 120 community water systems in 

25 that program. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 53

 

1 It was a high sampling intensity

2 program. It took between 40 and 60 samples per year in 

3 both raw and finished water which enabled us to fully 

4 characterize exposure protocols in the raw waters as 

5 well as in the finished water supply to consumers. 

6 This program was replaced in spring of 

7 2003 by the atrazine monitoring program which was a 

8 condition of the MOA Dr. Bradbury referred to earlier, 

9 and we have now a formal entry criteria for systems 

10 joining the monitoring program which was more 

11 conservative. Any system that had a single exceedance 

12 of 2.6 ppb total for triazines. AMP also looks for 

13 metabolites which is about the equivalent of 1.6 ppb 

14 atrazine joins the system. 

15 And so, that program then included up to 

16 151 community water systems in intensive monitoring. 

17 Took about 64 to 70 samples per year in both raw and 

18 finished water, mainly weekly and also some bi-weekly 

19 sampling during Q3 and Q4 and Q1. So, in a nutshell, 

20 if we look at surface water systems which are the ones 

21 with potential exposure to atrazine, we have a subset, 

22 a small percentage, of the high...most highly exposed 

23 systems in the U.S. under a high frequency, continuous 

24 monitoring program. 

25 Systems will stay in the program for a 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 54

 

1 minimum of five years period.

2 So, what did we get from those programs? 

3 I summarize quickly the Safe Drinking Water Act 

4 monitoring program time record 1993 to '08. We have 

5 data for 47,000 community water systems. That's both 

6 ground and finished water. We have 212,000 samples in 

7 groundwater. We have 68 samples in finished surface 

8 water. 

9 This data set is complemented by 

10 Syngenta's intensive monitoring data which included up 

11 to 151 vulnerable community water systems in a year. 

12 It looks into raw and finished. Both programs 

13 generated 64,000 finished surface water analyses in the 

14 most highly exposed systems. 

15 Now, in a nutshell, if we look at the 

16 finished water samples, none of the more than 340,000 

17 data we have on record from finished drinking water 

18 exceeded 100 ppb ever. By that, they didn't exceed the 

19 209 ppb that Dr. Breckenridge mentioned earlier for 

20 short-term exposure as DW LOC. They did also not

21 exceed the 298 ppb DW LOC that was published by EPA in 

22 their 2003 IRED. 

23 If you look at it chronically, no 

24 community water systems in the AMP program which

25 includes the most vulnerable systems with a very high 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 55

 

1 sampling frequency has exceeded 3 pb as an annual

2 average in finished water since 2006. 

3 So, we strongly believe that drinking 

4 water supply is safe. 

5 Now, if we look at effectiveness of 

6 label changes and mitigation, what I'm giving you here 

7 is a view on the most vulnerable systems, surface water 

8 with high intense monitoring, so this is very precise 

9 data, and what we see here is the overall average of 

10 atrazine concentrations between 1994 and 2008. The 

11 years between '94 and 2002 are the voluntary monitoring 

12 program, and then we have the AMP which includes a few 

13 more systems. 

14 So, what we see, that overall in those 

15 most vulnerable systems, finished water concentrations 

16 were at about 1.5 ppb in the mid '90s, and they 

17 consistently declined and have reached a level of about 

18 0.5 ppb in finished drinking water by 2008. 

19 If we look at well water in those same 

20 systems...we also took well water samples, high 

21 frequency...we see a very similar trend. We see a high 

22 level in the early '90s in well water which does not 

23 quite reach 3 ppb on average, and we see a consistent 

24 decline to levels just below 1 ppb. 

25 So, both in raw and in surface water, as 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 56

 

1 a total average in those systems that are the most

2 highly exposed in the U.S., we have had a 60 to 70 

3 percent decline in concentrations in well water as well 

4 as in...as in finished water. 

5 Peaks have been quite a bit of 

6 discussion and hype recently, and we do believe that we 

7 actually have a second program in place that gives us a 

8 good view on what peak concentrations could potentially 

9 be and how peaks could be characterized. This is the 

10 eco monitoring program that I'm referring to. Dr. 

11 Bradbury mentioned it as well as one of the conditions 

12 of the memorandum of agreement. 

13 This is not drinking water. I am giving 

14 you here a little snapshot result. You might have seen 

15 this slide already. So, these are 45 watersheds in 

16 highly vulnerable settings, ecologically very 

17 vulnerable and with high atrazine use volume. We look 

18 in second and third order headwater streams, so these 

19 are not drinking water water bodies, but they might 

20 feed into some. 

21 That program was initiated in 2004 and 

22 is still active today. We have over 10,000 samples 

23 analyzed. And the program was set up to focus on the 

24 run-off seas, and we run it for about four to five 

25 month right after the atrazine application season, so 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 57

 

1 we have a very good profile and characterization of

2 potential exposure peaks. 

3 This program has generated 190 site 

4 seasons of well resolved concentration time profiles 

5 for atrazine. Again, this is not drinking water, but 

6 the data, sampling data, we believe, can be used to 

7 serve as a worst case surrogate to describe peaks. 

8 What do we see in those programs? Let 

9 me quickly talk about the eco monitoring program which 

10 is in the left upperhand box. We have about 10,000 

11 data points. We have had a sampling schedule in 2004 

12 and 2006, four days, grab samples. This was 

13 supplemented at about 25 percent of the sites with 

14 autosamples which were event driven. 

15 And then, in 2007, we changed the 

16 program in order to be able to better describe peak 

17 concentration profiles to a daily sampling program. 

18 So, 2008, '07, 2008, 2009 generates data...daily

19 samples, very tight time resolution. 

20 This data set is, again, supplemented by 

21 a huge database that is available and has been 

22 generated over the last 40 years in surface water 

23 bodies. These are mainly studies that both were done 

24 under the USGS's monitoring program and other USGS 

25 programs. Heidelberg College has done a substantial 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 58

 

1 body of work.

2 Most of these programs were sampled on, 

3 the ones you see were sampled on characterizing runoff 

4 events. So, what did we see in those almost 120,000 

5 environmental samples over the last 20 years? 

6 We see that we have the peaks well 

7 characterized. We have a large body of data that is 

8 available for analysis, and we have never seen an

9 exceedance of the 298 ppb drinking water level of

10 concern in any of those environmental monitoring

11 programs. 

12 So, let me quickly talk about the 

13 concentration frames. You have seen this slide before. 

14 This is the overall average concentrations in the 

15 high...most highly exposed systems that grew in the 

16 voluntary monitoring program and the atrazine 

17 monitoring program. 

18 If you analyze those data a little bit 

19 more thoroughly as statisticians would do and take 

20 only those community water systems that have a 

21 continuous record of at least nine years and reported 

22 both programs, you do get a highly significant 

23 statistical trend that shows you that concentrations in 

24 those systems have been declining between 1994 and 

25 2006, and they have been declining more for systems 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 59

 

1 that were more highly exposed in 1994 than for a group

2 that never exceeded an MCL of 3 ppb in 1994 and later. 

3 Overall, the numbers are quite the same. 

4 We see a decline of about 60 percent to 70 percent in 

5 '06 relative to the baseline that we have in the mid 

6 '90s, and this was achieved without reducing the use 

7 volume of atrazine in those areas where these systems 

8 are located. So, the line at the top of the graph is 

9 the actual use volume of atrazine in those years.

10 Now, what that...what does that mean in 

11 terms of margins of exposure and...and human safety? 

12 What I, you know, give you here on this slide is an 

13 attempt to describe the worst case margin of exposure 

14 resulting from a single day exposure based on the data 

15 we have generated. So, you have the single day no 

16 effect level of 10 mg/kg/day which EPA used to define 

17 short-term exposure drinking water level of concern 

18 with a safety factor of 1000. You get...and the 

19 appropriate body weight and intake numbers. You get a 

20 concentration of 298 ppb. 

21 What you have on the bottom right-hand 

22 of the graph is the probability of this situation of 

23 all samples that was generated in the AMP and BMP 

24 finished drinking water monitoring program. So, this 

25 is the full distribution of all the data, single day 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 60

 

1 values that were measured in those programs in finished

2 water. 

3 And if you do a margin of exposure 

4 calculation to be a single day no effect level, the 

5 resulting margin of exposure is in excess of 10,000 at 

6 the 99.9 percentile. If you do the same exercise for 

7 chronic and, just for simplicity's sake, I took the 

8 median here and compare it to the chronic no effect 

9 level of 1.8 mg/kg/day and the safety factor of 1000 

10 which leads you if you want to reference those, if you 

11 look at the actual exposure resulting in the 

12 most...resulting from the most vulnerable systems, 

13 we're talking a margin of exposure as in excess of 

14 200,000. 

15 Please keep in mind these are the most 

16 vulnerable systems where you see exposure in drinking 

17 water. 

18 So, in summary, we have a huge 

19 monitoring database. We have about 340,000 finished 

20 drinking water samples and 60,000 samples in ground 

21 water. We have 118,000 environmental water samples. 

22 We have broad geographic and temporal coverage in that 

23 data set. We have high sampling frequency in a 

24 significant number of data sets which is focused on 

25 monitoring locations. You have well characterized 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 61

 

1 peaks in runoff events based on daily sampling.

2 And if you take those data and put them 

3 into context of current no effect levels, all those 

4 data indicate that we have large margins of exposure 

5 which are in excess of 10,000. What we also see is 

6 that the label changes actually did have an effect. We 

7 had significant reduction in environmental 

8 concentrations. This is not only our own data. Also, 

9 USGS and state monitoring studies show that. 

10 And with that, I hand it back to Dr. 

11 McFarland. 

12 DR. HEERINGA: Thank you, Dr. Hurdle. 

13 DR. MCFARLAND: The concerns about the 

14 process for this SAP are documented in our written 

15 comments that went into the docket, but as...but we 

16 know that it's an unusual situation for both the SAP to 

17 be in as well as us, because normally, we're providing 

18 basic research, data information that is actually 

19 addressing charge questions or specific reviews of 

20 scientific assessments, and in this case, we...we 

21 strongly feel that the new information that has been 

22 sparked by the attacks of the anti-atrazine group and 

23 also in the press do not justify opening a 

24 comprehensive re-review of atrazine. 

25 But we are...we do remain confident and 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 62

 

1 will be really working hard, committed to fully and

2 openly to contribute in the scientific process that lie 

3 ahead. We do ask that EPA be accountable for the 

4 scientific integrity of the pro...the regulatory 

5 review, and we appreciate and thank the SAP to help 

6 ensure that...that it goes through a scientifically 

7 rigorous process. 

8 We have an unparalleled commitment to 

9 advancing the research in the safety assessments and 

10 stewardship of atrazine, and the past comprehensive 

11 reviews, we're appreciative of all of the efforts that 

12 went into those. It is an unprecedented data set on 

13 all levels of...of toxicology, risk assessment, 

14 exposure, and...and health assessments. 

15 The regulatory endpoints, as you saw 

16 from both Dr. Breckenridge and Dr. Hurdle, are 

17 conservative and protective. They're...we are...we 

18 feel very fortunate and blessed, actually, to be part 

19 of such a transparent, open review process that has 

20 gone on for this product, and we also appreciate all 

21 the work from the past SAPs. 

22 People, as I mentioned, often forget 

23 that the favorable registration decisions or safety 

24 assessments were...were not...not concluded only by EPA 

25 but by regulatory authorities around the world, and we 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 63

 

1 look forward to...to contributing science throughout

2 the next part of this process, and are happy to 

3 entertain any questions from the panel now or if there 

4 are other questions after other public commenters. 

5 DR. HEERINGA: Quick opportunity for 

6 panel members to ask questions of clarification of the 

7 Syngenta representatives. Dr. Bucher? 

8 DR. BUCHER: John Bucher. Just out of 

9 curiosity, the specific technical part of water 

10 disinfection that would reduce atrazine levels, 

11 what...what can you tell me about that? 

12 DR. HEERINGA: Dr. Hurdle? 

13 DR. HURDLE: Well, as you probably could 

14 glean from the slides, there is an effect of water 

15 processing. As you process a lot of raw water to

16 finished water, you see reduced levels in those 

17 finished water sources. 

18 Therefore, I have...however, I have to 

19 point out so that there is an effect of water 

20 processing, water processing technologies do reduce 

21 atrazine levels. However, one of the remarkable points 

22 is if you look at the MCL which is the current standard 

23 that even the most exposed systems, on average, you do 

24 see that in all those sources, an average of far below 

25 that...that...that MCL to date which was wholly a 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 64

 

1 consequence of, you know, all the label changes that

2 have been in the last 15 years. 

3 DR. BUCHER: Thank you, but that wasn't 

4 exactly quite what I was asking. The aspect of the 

5 drinking water disinfection byproduct or the 

6 disinfection process that reduces atrazine levels, do 

7 you know what that, technically, what that might be? 

8 DR. HEERINGA: Dr. Breckenridge? 

9 DR. BRECKENRIDGE: I don't believe I 

10 could comment on the effect of disinfection byproducts 

11 modulating atrazine concentration. We know that the 

12 carbon filtration systems will modulate atrazine

13 concentrations, if that's what you're getting at, but 

14 disinfection byproducts and their presence really 

15 don't... 

16 DR. BUCHER: No, I'm sorry, I misspoke. 

17 I have that on my mind, because we deal with that all 

18 the time. 

19 DR. HEERINGA: Dr. Hurdle? 

20 DR. HURDLE: Well, I have just one add 

21 on to it. While we do know the hydrology stability 

22 under different pH conditions of atrazine, but...you 

23 know, and that's evident, so, there is data available 

24 that, you know, might instruct to that, but I'm not 

25 prepared to, you know, answer that question right away. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 65

 

1 DR. HEERINGA: Dr. Portier.

2 DR. PORTIER: You talked a lot about 

3 community water systems. Has there been any 

4 measurement of...of well water, non-community water 

5 systems, residential wells in rural areas where there 

6 would be vulnerability? 

7 DR. HURDLE: We have, in fact, done a 

8 pretty comprehensive rural well monitoring study in '92 

9 to '94. We sampled about 1505 rural wells, if I'm

10 correct, recall that correctly. We analyzed the well 

11 water for both atrazine and atrazine metabolites, and 

12 that data are available and have been related by EPA, 

13 so they're part of the atrazine database. 

14 We did some resampling campaigns in 2000 

15 and then again in 2007 to look at the most vulnerable 

16 wells and that could confirm exactly the same trend 

17 that you have seen here with the surface water systems. 

18 Levels have been declining significantly and 

19 consistently. 

20 DR. HEERINGA: Okay, I'd like to move 

21 on, but I'd like to also thank Syngenta representatives 

22 for their presentation. Thank you. 

23 Our next scheduled public commenter is 

24 Dr. Jennifer Sass who is representing the National 

25 Resources Defense Council. Jennifer, are you here? 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 66

 

1 Jennifer...Dr. Sass, are you here?

2 (No response.) 

3 DR. HEERINGA: Not seeing Dr. Sass, we 

4 will move on to Dr. Joel Nelson who is representing 

5 California Citrus Mutual. Dr. Nelson? Take this chair 

6 where the mike's lit up there, if you want. 

7 MR. NELSON: Well, thank you, ladies and 

8 gentlemen for this opportunity to participate in 

9 another SAP. For the record, I'm not a Ph.D., not a 

10 doctor. I'm not a lawyer, either, so I think I'm in 

11 pretty good shape. 

12 My name is Joel Nelson. I'm president 

13 of California Citrus Mutual which is a citrus 

14 producers' trade association from California. 

15 Now, you're probably wondering why I'm 

16 here, and last night or yesterday afternoon as I was 

17 flying into Washington, I was wondering the same thing. 

18 Been here, done that on several occasions, in my

19 particular case, about four times relative to atrazine. 

20 But our industry is a user of simazine, a derivative of 

21 atrazine. And as goes atrazine, so goes simazine, and 

22 we know that. 

23 So, a number of years ago...and our 

24 chairman will be testifying shortly...agriculture 

25 across the country formed an entity called the Triazine 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 67

 

1 Network, and we became part of the steering committee,

2 and we began working with colleagues across the country 

3 on this particular issue, because we felt we had a 

4 responsibility, a responsibility to address the 

5 concerns, the legitimate concerns associated with

6 herbicide use in agriculture. 

7 For our industry, the citrus industry, 

8 we are weed free. We have to be. Our fruit stores on 

9 the tree. It constitutes a problem when weeds are

10 pervasive in a grove. Creates a home for invasive 

11 pests, but just as importantly if not more so, we keep 

12 our groves warm without weeds by running water and wind 

13 machines. Weeds will make a grove colder by 3 to 4 

14 degrees, according to scientific studies at the 

15 University of California. 

16 So, it's in our best interests to keep 

17 our groves weed free. We don't till. Warmth is a

18 serious, serious issue for us in the months of November 

19 15th through, roughly, March 1st. 

20 So, simazine has become an important 

21 product for our arsenal and our growers, 38...3500 

22 producers, 285,000 acres, $1.8 billion worth of 

23 product. We're the number one citrus producing state 

24 in the nation. We got that way because of disease in 

25 Florida. They've lost their value. Ours continues to 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 68

 

1 increase, and we're proud of it.

2 But as I flew back here again, ladies 

3 and gentlemen, I wondered, why are we here again? And 

4 I was struck by the similarity of the occurrence in 

5 reading the documents from EPA. I was around when

6 Fenton Communications started the Alar situation in 

7 public relations. 

8 I was around when we had an adverse 

9 kneejerk effect with that public relations fiasco. It 

10 took a long time for the public relations industry to 

11 recover their credibility as a result of that, and 

12 there were a lot of chastened individuals as a result 

13 of that entire episode. 

14 And I was around and went and saw Straw 

15 Dogs with Al...Al Pacino, and I remember what happened 

16 in that particular movie. 

17 Well, ladies and gentlemen, as I read 

18 the documentation creating this effort, knowing that we 

19 have gone through this so many times and we're 

20 scheduled to go through it again under a normal 

21 process, why are we here again? 

22 Well, we're here because government 

23 asked us to participate once again in a science 

24 advisory committee. So, all I say to you now is that 

25 the citrus industry from California, Citrus Mutual will 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 69

 

1 participate where appropriate.

2 I will admit I don't understand three3 fourths of what you just...three-fourths of what you 

4 just heard. I'm a policy person. I can read 

5 conclusions. I have read your conclusions at EPA.

6 Atrazine is safe. I have read your conclusions for 14 

7 years. Atrazine, when used according to the label

8 restrictions, is safe. I've read it relative to water. 

9 I've read it relative to carcinogens. 

10 I've read it over and over and over 

11 again, and I'll wait for a conclusion, and I'll 

12 participate in a process, because that's what this is 

13 all about. It's another process. Let's be honest

14 about it. 

15 So, we have an obligation to 

16 participate, but on behalf of the citrus industry in 

17 California, you know we will be here. Again, when 

18 appropriate, call upon our industry, but please, don't 

19 ever address me as Doctor, because I can't wear that 

20 hat. 

21 Thank you very much. 

22 DR. HEERINGA: Thank you, Mr. Nelson. 

23 Somebody felt you earned it, but we'll track them down. 

24 Our next public commenter is Gary 

25 Marshall who is here today representing Missouri Corn 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 70

 

1 Growers Association. Gary?

2 MR. MARSHALL: Thank you, Mr. Chairman. 

3 It is, I guess, good to be back here again. Seems like 

4 I was just here a couple of months ago, maybe three 

5 months ago, whenever it was, in June. 

6 Again, my name is Gary Marshall, and I'm 

7 the CEO for the Missouri Corn Growers Association, and 

8 I also serve as chairman of a group that we have in 

9 Missouri called the Environmental Resources Coalition, 

10 ERC. 

11 Environmental Resources Coalition 

12 is...is a group that we helped put together along with 

13 several government entities, including our Department 

14 of Natural Resources, the University of Missouri, a 

15 number of farmers in the State of Missouri, the farmers 

16 that I represent. And we used, over the years, some of 

17 EPA's 319 dollars to help address some of the areas of 

18 concern that we're talking about today, and talking 

19 about it again today, I must say. 

20 You know, we have about 15,000 growers 

21 in the State of Missouri and over 300,000 farmers 

22 nationwide who utilize atrazine as a product. 

23 And...and I realize this is more about the science, but 

24 there's also the user community out there which I 

25 represent. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 71

 

1 In Missouri, we use it on over...between

2 3 and 3.5 million acres, because the product works. 

3 It's better than anything else that we have access to 

4 today. Combining atrazine with other herbicides allows 

5 us to minimize weeds which compete for the nutrients 

6 and the water in our soils. 

7 Beyond that, I have about 15 years' 

8 worth of experience in utilizing atrazine. In a 

9 previous life, we spread probably in excess of 200,000 

10 acres over a 6 to 8-year period as a commercial 

11 applicator. So, I've utilized atrazine. I've utilized 

12 other products that are out there. I know what it 

13 does, and I know that it works. 

14 And the farmers in Missouri tell us that 

15 it does work. It continues to work. In fact, in the 

16 last survey that we had, about $60...or $20 per acre, 

17 $60 million worth of savings by utilizing atrazine 

18 instead of switching to another product that doesn't 

19 work as well and that has a higher cost. 

20 So, bottom line, it's right and 

21 appropriate for us to engage in this process. And 

22 we've submitted comments previous to this, and I'm not 

23 going to read those comments, but, you know, Halloween 

24 was just a few days ago, and it almost feels like 

25 Halloween again. Here we are again one more time. 
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1 It...it's scary, because I'd like to know when is

2 enough enough. 

3 You know, I've worked with scientists 

4 back in our state, and sometimes, 98 percent is good, 

5 and sometimes, 99 percent, and sometimes, I think here 

6 we're talking about 99.89, 99.92 percent. When is

7 enough enough? We've got thousands of studies now, over 

8 6000 studies, I think, reams of paper. I think the 

9 agreement is out there. 

10 In fact, let me read just a quote to you 

11 that...that we found in EPA's own web site, and that 

12 is, the Agency has found that there is a reasonable 

13 certainty that no harm will result to the general U.S. 

14 population, infants, children, or other major 

15 identifiable subgroups of consumers from aggregate 

16 exposure from food, drinking water, and non17 occupational sources to cumulative residues of atrazine 

18 and the other chlorinated triazine pesticides. 

19 Now, that's what we go on. We trust the 

20 EPA. There's a process here that we've been involved 

21 with for a number of years. As...as Joel just 

22 mentioned, I'm going up, I think, on 14 years with the 

23 triazine network as a steering committee member, 13 or 

24 14 years. I think it's been around for 15 years. And, 

25 again, I would say, when is enough enough? 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 73

 

1 We think that the science is there.

2 We've seen it. We've looked at some of the new science 

3 that's out there. We don't believe that it tells us 

4 that we need to be looking again at more science.

5 So, I guess my comments would be that 

6 there's nothing new. This is kind of unprecedented. I 

7 think it's being driven by some folks out there that 

8 are anti-farming. They're anti-agriculture, and if 

9 that's true, you own it. If it is an activist agenda 

10 that is to ban all pesticides, well, we're going to be 

11 here. Just like Joel, we're going to be here. We're 

12 going to fight that. 

13 We're going to use our connections 

14 wherever we have them to...to get our point across, 

15 because, again, we believe that the credibility of the 

16 EPA is at risk whenever we go back and we review, 

17 again, based on some...some new science that's out 

18 there that hasn't went through the same review process 

19 as the other science has that we've talked about over 

20 the last 12 to 14 years. 

21 So, we look for the EPA to be non22 biased, and...and we hope that the science, in the end, 

23 dictates the process. If the science dictates it, 

24 we're good to go. If it's politics, we're good to 

25 fight. 
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1 Thank you.

2 DR. HEERINGA: Thank you, Mr. Marshall. 

3 I believe that Dr. Sass has arrived, and given her 

4 earlier priority on the list, I call on her one more 

5 time. Jennifer Sass, Jennifer, are you here? 

6 SPEAKER: She's here, maybe outside. 

7 DR. HEERINGA: Okay. Maybe she just 

8 stepped...let's...I'm going to move on, then, to Mr. 

9 Jerry White who is representing the Kansas Corn Growers 

10 Association and Kansas Grain and Sorghum Producers 

11 Association. 

12 Mr. White? I believe we have heard you 

13 before, too. Welcome back. 

14 MR. WHITE: Yes, it's good to be back 

15 again. 

16 DR. HEERINGA: Next up, Jennifer. Mr. 

17 White, please, and then we'll go to Dr. Sass. Yes. 

18 MR. WHITE: Mr. Chairman and members of 

19 the committee, I guess it's good to be back again. My 

20 name is Jerry White. I'm the executive director for 

21 Kansas Corn and Grain Sorghum associations and serve as 

22 chairman of the triazine network. 

23 The network did submit comments into 

24 the...into the docket, and so, I certainly won't go 

25 through all of...all of those, but to echo the comments 
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1 that were made earlier by Mr. Nelson and Mr. Marshall,

2 we certainly are concerned that not only does it appear 

3 but I think in some of the not...been documented and 

4 reported that the SAP...it's not just the three that 

5 we're talking about in 2010 but also, according to a 

6 stakeholder conference call that several of us were on, 

7 there are additional SAPs, at least one additional SAP 

8 beyond September, 2010 that are scheduled in regards to 

9 atrazine. 

10 And...and, certainly, we understand the 

11 process, that as new science comes out, new reports 

12 come out, that the Agency has a responsibility and 

13 obligation to review the new stuff that comes out and 

14 determine if it...or not it warrants a further review 

15 by their Science Advisory Panel, and we understand and 

16 appreciate that. 

17 What we're not sure in this case is how 

18 we bypass some of that, what I call more formal 

19 internal review by Agency staff and, instead, have gone 

20 to a peer review by the New York Times. It seems

21 hardly appropriate. The Agency itself, the assistant 

22 administrator, has indicated that...that the media 

23 reports are quite a bit of the driver for this. 

24 Quite frankly, I'm confused about an SAP 

25 topic that's considered a kick-off meeting. It's
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1 almost like it's a United Way campaign or, or something

2 like that. It's...it's unusual, and at least from my 

3 standpoint, which probably doesn't go back as far

4 as...as many of you, but this is SAP number six for me. 

5 So, it's not exactly a new experience. 

6 You know, the agricultural community has 

7 participated for 15 years on this subject, will 

8 continue to participate. We do think the Agency and 

9 the SAP has done a...a tremendous job in the past. 

10 We've not always liked the positions taken. 

11 The positions asserted by the Agency 

12 have not always been supported by the SAP, you know, I 

13 take you back to a previous administration and the 

14 issue of cancer. The...the presentations by the EPA at 

15 the time, widely reported again in the media the day 

16 before the SAP really began substantive discussions, 

17 suggested that, in fact, atrazine should be a 

18 carcinogen. 

19 At the end of the process, it was not, 

20 but let's face it, the media had already had their 

21 field day, and they did not go back and readdress it in 

22 the same substance that they did report the initial 

23 presentations from EPA. 

24 So, we've been there. We've seen the 

25 process work. We think we'll continue to see the
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1 process work, and...and we'll be back, but we...we do

2 point out that there are some very unusual things that 

3 seem to be going on. 

4 We can appreciate that, but the sanctity 

5 of the science that's been a part of this review,

6 it...it's...some of the most concerning things that I 

7 guess I've observed is a reference to things like the 

8 Bush EPA. And I'm just going to come straight out and 

9 say it. 

10 In my mind, some of the most substantial 

11 science that occurred did not occur during the Bush 

12 EPA, if you want to call it that. The cancer issue was 

13 number one with a bullet when the special review was 

14 initiated, and, quite frankly, the body of science 

15 under that was done under the Clinton EPA, if we want 

16 to use those targets, and, in fact, the most 

17 substantial statement, I think, on public safety

18 probably came out and on the review in total in July of 

19 this year by the Obama EPA. 

20 So, it's a science that has carried the 

21 day through many administrations, and...and we 

22 certainly expect that to occur in the future, and I 

23 guess we'll look forward to seeing you again. 

24 I'm...I'm a little disappointed. I thought maybe I was 

25 going to be able to get a chance to hear his comments 
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1 some more, but I guess I should pass on that.

2 DR. HEERINGA: Thank you very much, Mr. 

3 White. 

4 Just a note for myself as chair that 

5 this morning's meeting is a public meeting which is a 

6 public meeting of an annual update that the SAP, the 

7 permanent members you see here, receive from the EPA. 

8 And, generally, it is a...a general coverage of the 

9 topics that we expect to come down the pike in the next 

10 year and two years. 

11 It is a little unusual that it's focused 

12 on one topic, but the fact that it's public, I think, 

13 in my view, reflects the EPA's interest in making this 

14 initial presentation which would, again, just be an 

15 administrative discussion with...with the permanent 

16 panel about upcoming things, to make that information 

17 open and available to the public. 

18 At this point, Dr. Sass, we have your 

19 public comment. 

20 DR. SASS: Thank you. I'm glad to be 

21 here, and I'm sorry that I was late. I will be here 

22 for the rest of the day. So, I will be looking forward 

23 to hearing your thoughts as well as the public 

24 commenters. 

25 My name is Jennifer Sass, and I'm with 
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1 the Natural Resources Defense Council which is an

2 environmental non-profit, and I'm based here in 

3 Washington, D.C., and I'm a senior scientist in the 

4 health program. My comments were submitted to the

5 docket about a week ago or whenever they were. As

6 well, I brought 30 copies in with Dr. Bailey to be 

7 distributed. So, hopefully, you know, you, at least, 

8 can access them at some point if you so desire. 

9 So, I'm going to touch on some of the 

10 points in the comments. First of all, we're very

11 pleased that the EPA and the scientific advisory panel 

12 will be taking a look at the atrazine issue for a 

13 number of reasons that are based on some new 

14 information that's come in, first of all, some of the 

15 monitoring, both water, ecological water monitoring as 

16 well as drinking or tap water monitoring information 

17 and some new science that's come out in the last few 

18 years. 

19 As well, this science that was 

20 previously available to SAPs in earlier determinations 

21 is still very relevant, of course. There's no statute 

22 of limitations on the truth, and in this case, I think 

23 that the science has been increasing, making a stronger 

24 argument supporting the concern that atrazine in our 

25 waterways, both drinking water and particularly in the 
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1 wat...in open and surface water systems is a concern

2 for wildlife. 

3 So, first of all, at NRDC, we analyzed 

4 the drinking water and the ecological water monitoring 

5 data, and we have a report that's available, and I've 

6 also provided a summary in my comments. 

7 Some of the main points are that the 

8 water monitoring from the watersheds, the surface

9 water, showed that all 40 watersheds that were tested 

10 had detectable levels of atrazine, and this supports 

11 USGS water monitoring also that found widespread

12 atrazine contamination in surface water. 25 of the 

13 watersheds that were looked at had average 

14 concentrations above 1 ppb which is the concentration 

15 at which primary production of aquatic, non-vascular 

16 plants such as algae is reduced. So, one would expect 

17 or predict that there might be harm to the ecosystem 

18 because of that. 

19 Nine of the monitored watersheds, which 

20 is 22 percent of the total, had at least one sample 

21 showing atrazine levels above 50 ppb. This...this 

22 isn't an average, but it's a spike or one sample above 

23 50 ppb, and four watersheds, representing 10 percent of 

24 the total, had peak maximum concentrations that 

25 exceeded 100 ppb. 
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1 So, this is a concern for us for aquatic

2 wildlife as well as aquatic plants that provide oxygen 

3 and nutrients to the wildlife in the water. 

4 One...at one place, the annual average 

5 concentration, that is, an average over the entire 

6 year, was 7.5 ppb. This is surface water at Little 

7 Pidgeon Creek in Indiana. And the maximum 

8 concentration in that location was 237.5 ppb. That was 

9 detected in May of '05. 

10 We also looked at the drinking water 

11 monitoring data, and it also revealed some disturbingly 

12 high spikes or short-term peaks. More than 90 percent 

13 of the samples taken in the 139 water systems had 

14 measurable levels of atrazine over both sampling years. 

15 That was '03 and '04. And three water systems had 

16 running annual averages for atrazine in the finished or 

17 tap water that exceeded the 3 ppb drinking water

18 standard. 

19 54 of the water systems, representing 39 

20 percent, had a one-time peak atrazine concentration 

21 that was above 3, and the highest peak in one of the 

22 systems was 36...39.69 in Evansville. 

23 So, the...the peaks are a real concern 

24 to us because of potential effects on wildlife even 

25 during those short-term exposures which might be days 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 82

 

1 or weeks long. They don't actually...they aren't

2 actually considered as peaks, per se, in the regulatory 

3 system for drinking water, and that doesn't fall under 

4 the Office of Pesticides' jurisdiction in any case. 

5 And there's some new science as well 

6 that's worth taking a look at. In 2009, there was a 

7 number of studies published, and I want to just touch 

8 on some highlights from a...a meta analysis that was 

9 published by Drs. Rohrer and McCoy. Atrazine in that 

10 study...and that was a study on a wildlife species, 

11 frogs...found that atrazine reduced size at or near 

12 metamorphosis in 19 of the 19 studies that were looked 

13 at in the meta analysis. Responses were non-monotonic, 

14 meaning that sometimes metamorphosis was delayed, and 

15 sometimes it was accelerated. 

16 Atrazine reduced anti-predator behavior 

17 in six out of seven studies that were looked at, and 

18 atrazine is associated with impaired immune function in 

19 35 of 42 endpoints. There was an increased rate of 

20 infection in 13 of 16 endpoints. And atrazine altered 

21 gonadal development in eight out of ten studies that 

22 were examined. It impaired gonad function by altering 

23 spermatogenesis in two of the two studies that were 

24 looked at and altered sex hormone concentrations in six 

25 out of seven studies that were examined. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 83

 

1 So...I'm not going to go through the

2 strengths and weaknesses of meta analyses except to say 

3 that it raises some points that I think are worth

4 taking a deeper look at in terms of the potential

5 effects for atrazine on wildlife species, even in

6 spikes or short-term durations. 

7 There are some other significant studies 

8 that were published in 2009. One study, by Laws, 

9 et.al., found that even a single dose of atrazine...it 

10 was 200 mg/kg given to male oyster rats...caused a 

11 measurable increase in steroid hormone release within 

12 15 minutes after dosing, so a rapid response to a 

13 short-term spike. 

14 In another study, a different study, 

15 published in 2009, rats that were fed atrazine 

16 contaminated feed for one or two weeks had a dose17 dependent reduction in sperm number and impaired daily 

18 sperm production. And in another study published in 

19 2009, rats that were fed atrazine contaminated feed for 

20 25 days had a dose-dependent reduction in steroid 

21 production in the leydig cells of the testes. 

22 Finally, in another 2009 study, rats 

23 that were treated for five months with atrazine-laced 

24 drinking water at 330 or 300 ppb, which were within the 

25 range of the spikes or peaks that we're seeing in the 
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1 monitoring program, had associated insulin resistance

2 leading to obesity. I think that one's very 

3 interesting, because it's so directly relevant because 

4 it was atrazine-laced drinking water was the dosing 

5 method, and the dose was just in the ranges of what we 

6 see in the monitoring program. 

7 So, we are very pleased that EPA and the 

8 SAP is willing to take the time to look at this issue 

9 again. We have some recommendations for your 

10 scientific advisory panel as you put them together. 

11 First of all, to gain assurances that 

12 EPA will provide all the published peer reviewed

13 studies of relevant data, including but not limited to 

14 the animal bioassays, in vitro data, human 

15 epidemiology, incident data, and ecological 

16 epidemiology, that the questions and...the charge 

17 questions and the data provided to you should be broad 

18 so that your decision, your determination and your 

19 conclusions can be based on...on a broad sweep of the 

20 literature. 

21 We recommend that SAP get assurances 

22 from EPA that it will...its review will not be limited 

23 to only studies published since the last review, given 

24 that previous SAP reviews did not do comprehensive 

25 literature reviews. They were...the charge questions 
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1 were more limited in those ones.

2 And we recommend that the SAP get 

3 assurances that the cancer and non-cancer review will 

4 include both human and animal data from published peer 

5 reviewed studies, including but not limited to the 

6 animal bioassays, in vitro studies, occupational 

7 epidemiology, and ecological epidemiology. 

8 All data endpoints...all...sorry...all 

9 endpoints relevant to cancer, including endocrine

10 endpoints, should be considered in order to help the 

11 SAP make a determination that considers the full sweep 

12 of the data. 

13 Thank you very much for your time to do 

14 this. 

15 DR. HEERINGA: Thank you very much, Dr. 

16 Sass. 

17 We'd like to move on to our next public 

18 commenter. We have three more this morning, and then 

19 we'll take a break. It's a little different format. 

20 We've gone a little longer than we typically do, but we 

21 want to try to get through this period of public

22 comment. 

23 At this point, I'd like to ask Rob 

24 Schneider who is with the National Corn Growers 

25 Association. Mr. Schneider? 
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1 The remaining discussants in order, just

2 so you can prepare, would be Alex Avery and then Wayne 

3 McAllister. 

4 MR. SCHNEIDER: Good morning. It's good 

5 to be with you all today again. My name is Rob 

6 Schneider, director of public policy with the National 

7 Corn Growers Association, providing comment on behalf 

8 of NCGA which represents more than 36,000 members in 48 

9 states, 47 affiliated state organizations, and more 

10 than 300,000 corn farmers who contribute to state 

11 checkoff programs across the country. 

12 NCGA's members strongly support the 

13 continued use of atrazine as an agronomic necessity on 

14 about two-thirds of all U.S. corn. U.S. farmers rely 

15 on atrazine for cost-effective broad-leaf weed control. 

16 First of all, NCGA is disappointed with 

17 EPA's decision to not extend the recent comment period 

18 on the atrazine reevaluation approach. According to 

19 the Agency, atrazine is one of the most widely used 

20 agricultural pesticides in the U.S., with approximately 

21 7...70 million pounds of active ingredient applied 

22 domestically per year. 

23 The chemical has been safely used in the 

24 U.S. since 1958, yet the Agency provided only 15 days 

25 for interested parties to submit written comments. If 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 87

 

1 EPA was interested in adhering to principles of

2 transparency and sound science, it would have given 

3 adequate time for the public to review relevant 

4 materials and provide input. 

5 In addition, the timing of this proposal 

6 in the midst of harvest made it particularly difficult 

7 for corn growers to meet the abbreviated deadline for 

8 comment submission. EPA's current course of action 

9 would suggest that it is prejudging the safety of

10 atrazine, holding this meeting and determining the 

11 Agency's course of action within six business days of 

12 the close of the condensed comment period. 

13 This week's meeting comes on the heels 

14 of almost continuous EPA review of atrazine over the 

15 past 10 years. The scientific advisory panels convened 

16 in 2000 and 2003, 2007, and 2009. There were 

17 additional studies already scheduled for 2010 before 

18 this current comprehensive review was announced last 

19 month. 

20 During EPA's recent special review of 

21 atrazine, more than 6000 studies were considered in 

22 determining that atrazine's registration can be safely 

23 maintained. Perhaps what is most alarming is the

24 precedent that is being established by the Agency's 

25 current action. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 88

 

1 Before convening a scientific advisory

2 panel, EPA would typically review any new applicable 

3 data or information, weigh its scientific integrity and 

4 regulatory significance, and determine the necessity of 

5 a new SAP. 

6 This...there is no evidence that EPA has 

7 thoroughly evaluated any new underlying studies before 

8 proceeding with this particular panel. In fact, the 

9 Agency is attempting to review a host of issues in the 

10 next 12 months that previously took more than a decade 

11 to consider. 

12 This creates a false sense of urgency 

13 and causes our members to question the motivation 

14 behind this process. 

15 Our growers have always been committed 

16 to leaving our environment in better shape than we 

17 found it. Stewardship measures ensure that atrazine is 

18 used in accordance with the label and applied in a 

19 judicious and cost-efficient manner. 

20 At the same time, NCGA believes that 50 

21 years of safe use and extensive monitoring data support 

22 atrazine's continued registration in the U.S. In

23 short, we are simply asking the EPA to stand by its own 

24 science. 

25 NCGA and myself would like to thank you 
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1 for the opportunity to comment here this morning.

2 DR. HEERINGA: Thank you very much, Mr. 

3 Schneider. 

4 For our next public comments, I would 

5 like to call up Alex Avery of the Hudson Institute 

6 where he is director of research. 

7 MR. AVERY: Thank you for allowing us 

8 to...to be here and to comment. I've been in this

9 arena for more than 15 years. I cut my teeth on the 

10 infamous Alar scare...scandal, really...that was

11 perpetrated by the perpetrators of this current 

12 scandal. And I'm going to call a spade a spade today. 

13 The announcement of this review a scant 

14 three months after the conclusions that were announced 

15 from the last decades-long review does not strongly 

16 suggest that this process is being entirely motivated 

17 by politics. It gives us a virtual high definition 

18 video of the politicization of the regulatory process. 

19 It should be noted, as others have, that 

20 there was another review scheduled for next fall. 

21 There is not a shred of science that's been presented 

22 to suggest that a new, urgent, full evaluation is 

23 warranted or necessary, but the politics sure...sure do 

24 suggest urgency. 

25 We all know if the Democrats lose the 
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1 next presidential election in 2012 that they will also

2 lose the reins on the political machine with which to 

3 ban atrazine on political grounds. Hence, a new 

4 scientific review of atrazine must start immediately if 

5 the Agency and its, more importantly, its political 

6 directors are to have a fig leaf of science with which 

7 to hide their politically motivated ban or severe

8 restrictions of atrazine. 

9 And as the EPA is well aware, a ban or 

10 severe restriction on atrazine will mean higher food 

11 costs, more soil erosion, less sustainable farming, and 

12 more environmental degradation and damage. It will 

13 mean putting more of our farming eggs in fewer baskets, 

14 and with the inevitable return of bedbugs to our major 

15 cities, we've learned the hard way, just recently, how 

16 needlessly restricting the tools that we have to fight 

17 the scourges of Mother Nature hamstrings our efforts. 

18 The world's population is continuing to 

19 grow, and world food demand is set to at least double 

20 over the next 40 years. We need every single tool we 

21 have and then some just to keep our heads above the 

22 rising tide of agricultural demand. 

23 Atrazine is a critical tool in that 

24 process. It's also a critical tool in protecting the 

25 environment and keeping our agricultural system 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 91

 

1 sustainable. Atrazine and other herbicides are

2 integral. 

3 They're at the heart of the no plow, no 

4 tillage farming revolution that has caused soil erosion 

5 to drop precipitously, thankfully so. Research by the 

6 USDA at Beltsville has demonstrated conclusively that 

7 no tillage farming suffers less than 20 percent of the 

8 soil loss that organic and old-style conventional

9 chillage, tillage plowing methods suffer. 

10 And atrazine is a critical tool in that 

11 process. It helps us to combat resistance to other 

12 weed killers, maintain high...higher soil organic 

13 matter contents which is something that EPA is 

14 supposedly in favor of when it comes to climate change, 

15 and it protects our rivers and streams from 

16 sediment...sediment pollution which is also a major 

17 concern of the EPA under normal circumstances. 

18 The witch hunt against atrazine has been 

19 perpetrated for more than a decade by the Natural 

20 Resources Defense Council, and they will not take no 

21 for an answer. And they realize that they don't need 

22 sound science or any good scientific evidence to

23 justify a ban on atrazine. All they know...they know 

24 full well that, based on the Alar scandal, that all 

25 they need is innuendo. All they need is the suggestion 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 92

 

1 and enough concocted public fear.

2 And, hence, suggestions today from 

3 the...the one who came before me that atrazine is now 

4 responsible for the obesity epidemic in the United 

5 States. 

6 So, back in the 21st century, the 

7 Natural Resources Defense Council was trying to do to 

8 atrazine what they did to Alar. Make no mistake, the 

9 NRDC and the political operators running the EPA today 

10 will go back to the scientific wishing well until they 

11 create enough innuendo and fear to cover a politically 

12 motivated, ideological effort to ban or severely

13 restrict atrazine. 

14 We are watching. We will fight it. We 

15 are not going away. 

16 Thank you. 

17 DR. HEERINGA: Thank you, Mr. Avery. 

18 And now, not Wayne McAllister but Ray McAllister from 

19 Croplife America. 

20 MR. MCALLISTER: Thank you. I apologize 

21 for not having copies of my comments, but I'll make 

22 those available through the Agency. 

23 Croplife America is a trade association 

24 which represents the common interests of manufacturers, 

25 formulators, and distributors of virtually all the 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 93

 

1 active ingredients used in crop protection products in

2 the United States. We're commenting today because of 

3 our concern about the Agency initiating a...a review of 

4 a compound that has been reviewed almost continuously 

5 for more than 20 years, and the Agency has put a great 

6 deal of effort into this already. 

7 In the course of making regulatory 

8 evaluations and decisions on individual products, the 

9 potential exists to set new policies and alter existing 

10 ones which will affect subsequent decisions across the 

11 board. That's our concern about the initiation of this 

12 review today which does not appear to be entirely 

13 motivated by science-based principles. We are not 

14 aware of any basis in...in real fact or law to reopen 

15 the long series of Agency decisions which are based on 

16 years of data on record and many years of the Agency 

17 analysis. 

18 We're concerned that this...this 

19 decision for a new year-long review has been taken 

20 rather hastily and is based on un...unsubstantiated 

21 media...media reporting and reports of an activist 

22 organization over alleged human health effects and 

23 concerns and criticisms of EPA's regulatory oversight. 

24 The Agency announces as much in its public docket. 

25 The Agency is well aware of the 
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1 importance of basing its rulings on sound science and a

2 transparent progress, allowing adequate time for public 

3 participation. That is their statutory obligation, to 

4 adhere to these principles and frequently re..restate 

5 them in their communications regarding such actions 

6 and...and activities of the Agency. 

7 Yet, this year-long review of atrazine 

8 involves a compound which has been in use for 50 years. 

9 It's been under a number of different types of reviews, 

10 many of them or some of them only recently concluded. 

11 The Administrative Procedures Act 

12 requires notice and comment on actions by Federal 

13 agencies for a number of reasons. Public participation 

14 and fairness to affected parties is a principal reason. 

15 It ensures that the agency will have before it the 

16 facts and information relevant to a particular 

17 administrative problem, and it allows an agency to 

18 reconsider and sometimes change its proposals based on 

19 the comments of affected persons. 

20 It doesn't specify a minimum comment 

21 period, but even providing 30 days to comment for 

22 the...from the publication of a Notice in the Federal 

23 Register might not be an adequate period of time to 

24 respond to proposals that are complex or based on 

25 significant scientific and technical data. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 95

 

1 In this case, the compressed time

2 schedule between publication of the notice of the

3 meeting on October 7th and the call for public 

4 comments, a little more than two weeks later, for a 

5 meeting even just two weeks after that precluded 

6 considered and thoughtful comments on the review of the 

7 proposal by the public. 

8 This compressed schedule also 

9 affected...gives the impression that EPA has prejudged 

10 the critical aspects of the year-long review of this 

11 compound and leaves no time for reasoned comment

12 development by commenters, much less review of such 

13 comments by the EPA and adequate time for you, the SAP, 

14 to...to review and make appropriate recommendations to 

15 the Agency. 

16 Under these circumstances, are we, as 

17 regulated entities and the regulated community, to 

18 conclude that EPA is establishing a new paradigm to 

19 take groundless and unsub...unsubstantiated information 

20 from the press and from activist organizations to start 

21 a new review of a compound? NRDC cites studies that 

22 have been reviewed numerous times and discounted by the 

23 experienced EPA scientists due to defects, flaws, or 

24 lack of quality in those studies. 

25 We're concerned that this is a...this is 
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1 a divergence from the science-based process under FIFRA

2 FQPA. EPA has done special reviews of triazines that 

3 took place over 12 years, concluded just 3 years ago. 

4 It has planned a registration review of atrazine to 

5 begin in just a few years from now. So, dropping 

6 another comprehensive year-long review in the midst of 

7 these other reviews in progress or recently concluded 

8 or on the schedule appears to be politically motivated, 

9 and we're concerned that this sets a precedent for 

10 other...other products in the marketplace where a 

11 review may be unjustified. 

12 Thank you. 

13 DR. HEERINGA: Thank you, Mr. 

14 McAllister. 

15 A note to the presenters here during the 

16 public comment period. If you have a written version 

17 of your comments, including the version that you used 

18 to read from, and have not provided it for the docket, 

19 I would encourage you to do that, to provide it to 

20 ...to Joe Bailey who is the Designated Federal Official 

21 for this meeting. 

22 At this point in time, I'd like to draw 

23 the period of public comment to a close and call for a 

24 15-minute break at which time our meeting will 

25 reconvene, and we will have an opportunity, as we would 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 97

 

1 typically in our permanent panel administrative

2 meeting, to address some questions to the scientific 

3 and administrative staff of the EPA. 

4 So, let's all rejoin here about...oh, 

5 let's say 11:25, and we'll continue until about the 

6 noon hour. 

7 (WHEREUPON, a brief recess was taken.) 

8 DR. HEERINGA: Okay, welcome back, 

9 everybody, to the second half of our...our morning 

10 session, our morning meeting in which the panel is 

11 hearing from the EPA and from public commenters on the 

12 topic of the presentation of the approach to reevaluate 

13 atrazine. 

14 At this point in time, we have on the 

15 agenda a period of time for the...the panel to discuss 

16 the material that we've heard this morning and to maybe 

17 ask questions of Dr. Bradbury and Dr. Levine, Dr. 

18 Lowit, and others on the staff who will be working on 

19 this particular effort. 

20 I would like, if we could, to bring out 

21 the slide number 1 from Dr. Bradbury's presentation 

22 which is the...the columns are the three monthly

23 meetings, and the rows are sort of a summary of content 

24 in each of those three meetings if we could. 

25 And while that's...while that's coming 
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1 up, I guess I'd like to open up to my fellow panel

2 members the floor to ask questions based on, again, the 

3 presentations this morning on the nature of this 

4 initiative. Does anyone want to take a leap? Dr. 

5 Portier? 

6 DR. PORTIER: So, thinking about 

7 these...these upcoming meetings and, in particular, 

8 looking at the February meeting, we had a...we had a 

9 meeting last year where we looked at the three 

10 epidemiology studies from California. I don't know if 

11 you remember that meeting. Was it last year or 

12 year...late year before last? It was last year, early 

13 last year. 

14 The community health work...the 

15 bystander exposure in epidemiology, but I just remember 

16 that panel and remember having a lot of discussion. I 

17 think it's going to be of importance for the panel to 

18 kind of see the questions for that meeting a little bit 

19 early so we can really understand what you're trying to 

20 get at in those questions. 

21 It's been my experience on the panel 

22 that every time epidemiology studies come up, there's a 

23 lot of discussion and a lot of confusion. We spend a 

24 lot of time trying to understand the value of those 

25 studies, and sometimes, they're underpowered or 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 99

 

1 undersized, and then we're trying to figure out what

2 are we really getting out of these...out of the 

3 studies. 

4 And then, I guess, the second thing is 

5 if...if what we're going to be looking at is the 

6 agricultural workers study design, if you're going to 

7 be asking the panel to look at that design, to 

8 anticipate what we might be getting from that, it would 

9 be nice to be able to see those design parameters. 

10 We...we were talking at the break about 

11 things like at this point, they should know roughly 

12 what their...their data collection rates look like, 

13 missing data, what kind of things it characterized, 

14 what kind of...what...what they actually measured, so 

15 we can be looking at those parameters and 

16 anticipating...I don't know if February's linked to 

17 September. In September, I'm thinking we're looking at 

18 the results of those studies. Right? Of whatever's 

19 published out of that study over the spring and the 

20 summer. 

21 But if we're looking at kind of the 

22 value of epidemiology, we're going to need to 

23 understand up front what that...what was...what went 

24 into that particular study. 

25 DR. HEERINGA: Dr. Chambers? 
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1 DR. CHAMBERS: With respect to the

2 February study, it sounds like incorporating epi 

3 studies and human health incident data into risk 

4 assessment is a very important generic topic, and I 

5 assume that was what was on the table for February, 

6 anyway. I guess my question would be, is the atrazine 

7 data set really relevant to those particular questions, 

8 or are we going to get bogged down on just the 

9 individual atrazine data set? Because the generic

10 questions, I think, might be broader than just the 

11 individual studies and... 

12 DR. LEVINE: Well, actually, in my 

13 remarks, I think I tried to stress that we don't want 

14 that session to get bogged down to...into just being 

15 about atrazine, but...but we always envisioned 

16 this...this, the February session to have some case 

17 study examples. 

18 And...and, in actuality, we had thought 

19 that they would be more of the data out of the Ag 

20 Health study that we could use, but that wasn't 

21 happening which is part of the reason it seems to get 

22 postponed and postponed, and since there were a number 

23 of different designs, designs that are different from 

24 the Ag Health study that were...were...have been cited 

25 in the media about atrazine risk and there are 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 101

 

1 other...probably other studies, too, we thought they

2 would make good case studies. And, in addition, we 

3 have some incident case studies, and we'd always 

4 planned to do it that way. 

5 So, it's really going to be one of the 

6 illustrations, but it's going to be about the more 

7 generic issue. 

8 DR. LOWIT: And, Dr. Chambers, the only 

9 thing I would add to that...Anna Lowit. The only thing 

10 I would add to that is...is that the atrazine studies 

11 that we'll talk about are not, although they're unique 

12 to atrazine, those questions are not unique to 

13 atrazine, and there's not a unique situation where 

14 studies are published in the open literature that, on a 

15 pesticide chemical. 

16 There's...questions always arise of how 

17 to incorporate that into our risk characterization. 

18 So, we share a concern of having atrazine not overwhelm 

19 that meeting and to focus on the broader intent, but I 

20 think the answer to your question is simply yes, the 

21 questions that we'll ask about those studies fit very 

22 well in that meeting, I think. 

23 DR. HEERINGA: Dr. Bucher? 

24 DR. BUCHER: John Bucher. I think the 

25 same kinds of comments could be made about the 
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1 references that you made, Dr. Bradbury, to the

2 toxicology in the 21st century with respect to the 

3 ToxCast program that...the generation of data from in 

4 vitro assays and how that's used in risk assessment, 

5 and I'm...I'm not...I don't know exactly...in my own 

6 mind, I'm not sure exactly how mature that, the 

7 appreciation of all that information is going to be 

8 with respect to also inserting the atrazine issues in 

9 that regard. 

10 So, I...I guess I just had some of the 

11 same concerns with that, that were just expressed. 

12 DR. BRADBURY: With regard to...if I 

13 could read a little bit more into your question with 

14 regard, especially, to the April SAP, what we want to 

15 ensure that, consistent with Agency guidance on using 

16 best available information and developing of lines of 

17 evidence and weight of evidence to try to characterize 

18 the risk as best we can, think about the uncertainty 

19 either qualitatively or quantitatively. 

20 We want to ensure that we're taking 

21 advantage of any in vitro information in the course of 

22 the data quality review of that data to see to what 

23 extent it can help inform us as to the mechanisms of 

24 action, mode of action of atrazine and how is that 

25 information concurrent with other experimental 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 103

 

1 toxicology information we review in April to see can we

2 put together a coherent picture, maybe update the

3 picture or maybe it's a new picture, in terms of what 

4 do we know about the mechanisms of action, toxicity 

5 pathways associated with atrazine and/or its 

6 metabolites and how does that lead to adverse outcomes, 

7 which we feel is an important part of doing a risk 

8 assessment today. 

9 And we'll continue to advance that...the 

10 ability to try to integrate that information, to use 

11 toxicity pathways, mode of action to help inform dose 

12 response relationships, to help inform what may be 

13 similar or dissimilar across species and understand 

14 aspects of...of exposure considerations in terms of 

15 characterizing the risk. 

16 So, that...April will be atrazine, but I 

17 think it's fair to say we'll not only advance 

18 our...and...and update our understanding of atrazine, 

19 but we'll probably get some other insights that can be 

20 more broadly applicable to integrating diverse sets of 

21 information together, especially as these go from April 

22 to...to September where experimental studies are being 

23 integrated with epidemiology studies. 

24 If I could just comment a little bit on 

25 the earlier question about February/September, the 
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1 epidemiology studies, to...to reinforce what Dr. Levine

2 was saying, our goal all along in February was to have 

3 a risk assessment to look at approaches for including 

4 incident data, as appropriate, as well as epidemiology 

5 studies, as appropriate, based on data quality and 

6 designs, all those issues, into a robust risk 

7 characterization and integrating this information. 

8 February, in a sense, is a building 

9 block step as we move forward. And so, atrazine 

10 provides us some opportunity to explore some 

11 epidemiology designs as well as get some insights on 

12 some specific studies. I'm not an epidemiologist. I 

13 mean, I don't wear that hat, but my colleagues are 

14 explaining to me that there's a spectrum of design 

15 types from ecologic studies to retrospective case 

16 studies to prospective studies, and what we want to 

17 look at in February, in particular, are ecologic

18 designs and retrospective designs and get some sense as 

19 to how you interpret that kind of information along 

20 with other kinds of information. 

21 As we move to September, we'll be 

22 looking at the Ag Health study which is a prospective 

23 study which is a different design. We'll ultimately 

24 get some advice from you on how do we integrate these 

25 different kinds of epidemiology studies, designs or 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 105

 

1 strengths and limitations in the context of the animal

2 or experimental toxicology data that we'll also have 

3 available. 

4 DR. HEERINGA: Steve Heeringa. I'd like 

5 to introduce just a few comments of my own and...and 

6 these are my own views here and don't necessarily

7 reflect those of the complete panel. 

8 In the over...over a decade that I've 

9 been involved in the process with the ad hoc panels as 

10 a person who sat and provided advice or serving on the 

11 permanent panel, this is a little out of the ordinary, 

12 but I...certainly, it's not my position right now to 

13 question your judgment or the motivation on this. 

14 We are an advisory panel and here to 

15 serve you objectively to help interpret science, and I 

16 think I certainly have worked with you long enough and 

17 have enough confidence to know that when you come to 

18 us, it's for a purpose to seek out scientific review on 

19 new information. 

20 That said, this is going to be a very 

21 busy year, and these are going to be very demanding 

22 reviews not only for the permanent panel but also for 

23 the ad hoc members. And you know that the ad hoc

24 members play a key role in these reviews. And it's 

25 going to be essential in this process, as it goes 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 106

 

1 forward...it's...it has some pretty broad aims, and I

2 think, scientifically, as I say, we're prepared to help 

3 you evaluate those aims, and that's what we're going to 

4 do. 

5 But it does mean that data sources, 

6 materials, background materials should be ready early 

7 in this process for review. The amount of data 

8 alone...if I think about even the April meeting with 

9 the sort of reassessment and look at the experimental 

10 toxicology studies could easily overwhelm reviewers, 

11 and I want to make sure that, as we go through this 

12 process as a panel, to be fair to you and to be fair to 

13 us, that we, in fact, have time to prepare. 

14 And looking ahead to September with the 

15 Agricultural Health study...I have some knowledge of 

16 this because of participations in the meeting, but I 

17 don't know anything about the design. 

18 Maybe it's a simple trip to the...to the 

19 web to learn some of that information, but I would 

20 say...ask of you in terms of your working with the 

21 permanent panel and also with the ad hoc panels that 

22 are formed that as soon as you have data and 

23 documentation that you can provide to us, it would be 

24 important for us to receive this even in advance of 

25 receiving the charge questions. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 107

 

1 Because while the charge questions will

2 help focus our scientific response to your concerns and 

3 your issues, I think it's very important in this very 

4 data intensive set of reviews for us to be able to 

5 become directly familiar with most of these information 

6 sources. 

7 And...and we can communicate on that, 

8 too, but I just want to emphasize that, again, what 

9 you've presented here in terms of a scientific review, 

10 and we anticipate your request of us as an advisory 

11 panel on that science as we move ahead, please help us 

12 be prepared to do this. And we'll keep a close eye, 

13 too, because we want to make sure that there is 

14 adequate time for these reviews and for consideration 

15 of all of the information. 

16 Additional comments? Dr. Chambers? 

17 DR. CHAMBERS: As just a followup to 

18 Steve's remarks, then, if...if the data really can't be 

19 compiled in a well organized and well analyzed manner 

20 in time for those particular meetings, you've put 

21 meetings off before when they haven't been prepared, 

22 and maybe you should put those off, because we really 

23 do absolutely, the same thing Steve said, we absolutely 

24 need enough time to look at the materials. 

25 DR. HEERINGA: Any other comments or 
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1 information? Steve?

2 DR. BRADBURY: Seeing if any of my 

3 colleagues had any followup questions. I want to take 

4 the opportunity to maybe clarify a few things and a 

5 little bit of feedback and, you know, move on. 

6 First of all, I want to thank you all 

7 for spending the time with us this morning on an 

8 informational session just to share with you where we 

9 are, where our vision is in terms of taking a look at 

10 the science around atrazine. 

11 As we mentioned before many times, 

12 administrative sessions are not public sessions, but we 

13 felt it was very important for this particular topic, 

14 as we look forward to the 2010 season, that we have a 

15 transparent session, we have an open meeting so people 

16 could provide some of their initial thoughts and

17 clearly as we move forward through these three peer 

18 reviews. 

19 And I certainly appreciate the timing 

20 and the need to get information in the docket as we 

21 form the charge questions. 

22 But I just want to reaffirm that the 

23 process we use for each of these three SAPs will be 

24 like the process we typically use where information is 

25 put in the docket, there's opportunity for the public 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 109

 

1 to provide nominations to our colleagues and the

2 designated official, federal officials, to vet a robust 

3 panel as well as the opportunity for people to look at 

4 the materials going into the docket and provide their 

5 insights on the information as well as their views 

6 on...on the charge questions as they're formulated as 

7 well as to offer you other issues that they think, the 

8 public thinks, are important to...to focus on. 

9 And so, I just want to reassure the 

10 public as well as the panel that we will be using that 

11 same process that we've always done in terms of 

12 transparency and openness to get information. And, 

13 clearly, we will have a number of people working very 

14 hard to provide information as soon as we can, and 

15 we'll be working with Laura Bailey and others to ensure 

16 we have a good process in doing that, in getting

17 information to you ahead of time. 

18 And clearly, we value the input that 

19 you're going to be providing over the coming 12 months 

20 or so as we take a look at these issues. 

21 The last comment I wanted to make was 

22 just to make it really clear again that when we come to 

23 the Science Advisory Panel it's to get advice on

24 important scientific issues, and, clearly, scientific 

25 issues are the foundation for any and all of our
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 110

 

1 regulatory decisions, and we don't make regulatory

2 decisions without having a good understanding of the 

3 science. 

4 And so, coming to you is an important 

5 step in evaluating this compound and ensuring that we 

6 have the most current and accurate insights as to how 

7 to interpret the risk characterization of atrazine. 

8 And it's clearly our process consistent with 

9 Administrator Jackson's process of very strong science, 

10 the rule of law and transparency in how we make 

11 decisions, and the Science Advisory Panel looking, the 

12 scientists in OBT and ORD and Office of Water is an 

13 important foundation to...to how we take a look at this 

14 chemical and...and just to reassure everyone that the 

15 first step is making sure we're current with the

16 science, we understand the science well and have

17 the...the advice and input from this panel to help 

18 guide us in thinking about the science and that's the 

19 step that we're at right now. 

20 So, I just want to close by thanking you 

21 all for spending time with us this morning and...and 

22 into the future, and we're very conscious of the

23 aggressive schedule and the need to provide information 

24 in a timely manner. 

25 Thank you. 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 111

 

1 DR. HEERINGA: Well, the lights dimmed

2 because there was no activity. There was thought 

3 process going on, but I...apparently, it dropped to a 

4 certain level and it cut the juice. 

5 So, Dr. Bradbury, if I could, just one 

6 more question. With regard to the epidemiology 

7 studies, the non-cancer that we'll consider in February 

8 and the cancer that we'll consider in...in September, 

9 are you aware of current work? Have you seen draft 

10 manuscripts on studies on ag health that motivate those 

11 agenda items? Or is it just the anticipation of the 

12 data release itself, the final data cleaning at a 

13 certain stage opens this up for reanalysis and 

14 publication? 

15 DR. BRADBURY: With regard to the...the 

16 cancer effects in epidemiology, I mentioned in my 

17 opening remarks some of the regulatory process that 

18 atrazine is, is in. And atrazine is still in special 

19 reviews. The special review for atrazine hasn't been 

20 closed. 

21 And the special review for atrazine and 

22 its primary focus was the extent to which atrazine 

23 could be a carcinogen and the potential carcinogenicity 

24 of atrazine. So, throughout our...our regulatory game 

25 plan time line for atrazine which includes closing the 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 112

 

1 special review, before we can close the special review,

2 we needed to take a final look at atrazine and its 

3 potential for carcinogenicity. 

4 And consistent with the 2003 IRED, it 

5 indicated that the Ag Health study that was ongoing, 

6 getting started at the time, and the forecasting for 

7 when the last atrazine studies would be completed would 

8 be roughly in this time frame. 

9 So, that 2010 SAP was always scheduled 

10 to deal with the Ag Health study and the cancer studies 

11 within the Ag Health study as that last critical step 

12 of the science to then determine if we can close the 

13 special review for atrazine which had this remaining 

14 step in it. 

15 Our colleagues in ORD and R&D and our 

16 individuals here in OBT with Carol, are working closely 

17 with colleagues in the National Cancer Institute and 

18 NIEHS, and it's our understanding that those final, I 

19 think it's two or three studies should be getting 

20 completed in the spring time frame, hence that's why we 

21 had scheduled September. 

22 With regard to the other epidemiology 

23 studies, right now, we're focusing on studies that have 

24 been published in the peer reviewed journals. To the 

25 extent the Ag Health studies are looking at non-cancer 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 113

 

1 issues and they're coming to bear at the time, we

2 would...we would fold those in as well. 

3 So, our primary focus for Ag Health 

4 study was largely cancer, the last science step to 

5 determine if we can close the special review for 

6 atrazine. The other studies is more consistent with 

7 our holistic look at...at atrazine, epidemiology 

8 studies have been published since 2003 on non-cancer. 

9 We want to take a look at those. See how the different 

10 designs should be considered. 

11 Again, we will be focusing on 

12 information that's been published in the peer review 

13 literature. To the extent something hasn't been 

14 published in the peer review literature, by definition, 

15 it's very difficult for us to review that. To the 

16 extent, I suppose if an individual or a research group 

17 wanted to submit their studies to the docket before 

18 they submit it into a journal, we would certainly take 

19 a look at them. 

20 DR. HEERINGA: Thank you very much. Any 

21 other questions? 

22 (No response.) 

23 DR. HEERINGA: Well, at this point, I 

24 guess I'd like to turn the morning's proceedings over 

25 to Joe Bailey to see if there's any final 
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1 administrative notes, and then we'll wrap up.

2 I'd just remind everybody that the FIFRA 

3 SAP will reconvene...it's a larger group this 

4 afternoon...to address the topic of nanosilver, and 

5 that meeting will be chaired by Gary Pope, my colleague 

6 this afternoon, so we hope to see many of you back here 

7 for that this afternoon. 

8 Joe? 

9 MR. BAILEY: Thank you, Dr. Heeringa. 

10 One note. Security has come forward and 

11 said there is a Toyota Forerunner on lower level 2 with 

12 the interior lights on, so if it's yours...it has 

13 Maryland plates. If it's yours, you might want to 

14 check it, or you will have to stay here for the rest of 

15 the meeting. If you weren't planning to. 

16 And in closing, I just want to thank 

17 everyone for attending and express my appreciation to 

18 EPA staff and to the public commenters for their

19 presentations. And I want to thank the panel and Dr. 

20 Heeringa for being here. 

21 Thanks. 

22 DR. HEERINGA: Yes, thank you, everyone, 

23 and we appreciate all of the participation, to the EPA 

24 scientific staff for their initial presentations and 

25 for bringing us to an open and public, transparent 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 115

 

1 discussion and for all of the public commenters for

2 their input, and we look forward to seeing everyone 

3 over the course of the next year on this topic. 

4 (WHEREUPON, the Meeting was adjourned at 11:55 a.m.) 

5 

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1 CAPTION

2 The foregoing matter was taken on the date, and at the 

3 time and place set out on the Title page hereof. 

4 It was requested that the matter be taken by the 

5 reporter and that the same be reduced to typewritten 

6 form. 

7 Further, as relates to depositions, it was agreed by 

8 and between counsel and the parties that the reading 

9 and signing of the transcript, be and the same is

10 hereby waived. 

11 

12 

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1 CERTIFICATE OF REPORTER

2 COMMONWEALTH OF VIRGINIA 

3 AT LARGE: 

4 I do hereby certify that the witness in the foregoing 

5 transcript was taken on the date, and at the time and 

6 place set out on the Title page hereof by me after 

7 first being duly sworn to testify the truth, the whole 

8 truth, and nothing but the truth; and that the said 

9 matter was recorded stenographically and mechanically 

10 by me and then reduced to typewritten form under my 

11 direction, and constitutes a true record of the 

12 transcript as taken, all to the best of my skill and 

13 ability. 

14 I further certify that the inspection, reading and 

15 signing of said deposition were waived by counsel for 

16 the respective parties and by the witness. 

17 I certify that I am not a relative or employee of 

18 either counsel, and that I am in no way interested 

19 financially, directly or indirectly, in this action. 

20 

21 

22 

23 

24 MARK REIF, COURT REPORTER / NOTARY 

25 SUBMITTED ON NOVEMBER 3, 2009 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 118

 

$ 

$1.8 67:22 

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1

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1000-fold 46:9 

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46:10 

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151 53:16 54:11 

15-minute 96:24 

15th 67:19 

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82:20 

19 82:12 82:12 

190 57:3 

1958 7:19 86:24 

1983 7:24 

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2.6 53:12 

20 33:24 34:7 

35:10 46:24 58:5 

91:7 93:5 

20,000 51:24 

200 83:10 

200,000 60:14 

71:9 

2000 9:3 9:9 11:8 

11:17 18:14 

18:19 32:23 

34:16 34:23 36:8 

47:6 65:14 87:16 

2000s 9:3 12:14 

2002 12:1 55:11 

2003 9:4 9:9 9:13 

10:1 10:10 11:25 

12:20 18:8 18:15 

19:7 23:12 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 119

 

36:8 36:11 52:20 

53:7 54:22 87:16 

112:4 113:8 

2004 56:21 57:11 

2006 10:13 38:1 

46:2 55:2 

57:12 58:25 

2007 13:4 13:11 

13:13 34:19 

36:19 57:15 

65:15 87:16 

2008 44:5 55:10 

55:18 57:18 

57:18 

2009 2:5 57:18 

82:6 83:8 

83:15 83:19 

83:22 87:16 

2010 2:13 6:13 

13:21 13:23 14:4

80:20 

23 32:14 

237.5 81:8 

25 49:9 57:13 

80:12 83:20 

285,000 67:22 

28-day 47:15 

298 54:21 58:9 

59:20 

3

3 2:5 47:7 47:9 

55:1 55:23 

59:2 67:13 

71:2 81:17 81:21 

96:3 

3.5 71:2 

30 4:25 49:5 79:6 

94:21 

4 47:12 67:13 

40 44:3 53:2 

57:22 80:9 90:20 

40,000 51:14 

42 82:19 

45 56:15 

47 86:9 

47,000 54:5 

48 86:8 

5

50 41:10 42:16 

80:21 80:23 

88:20 94:8 

51 33:6 

51,000 51:13 

54 81:19 

5-day 47:12

14:7 14:7 14:8 

14:11 15:7 15:22

300 47:9 83:24 

6

16:9 16:13 22:20 

75:5 75:8 

87:17 108:14 

112:9 

2012 90:1 

2013 10:20 

209 54:19 

20-plus 50:21 

21 47:7 47:13 

47:15 

212,000 51:18 

54:6 

21st 16:24 92:6 

102:2 

22 38:14 40:15 

300,000 70:21

86:10 

30-day 46:24 

319 70:17 

330 83:24 

340,000 54:16 

60:19 

35 82:19 

36,000 86:8 

36...39.69 81:22 

38...3500 67:21 

39 81:19 

4

6 46:7 46:7 71:10 

6.25 46:17 

47:16 49:5 

60 53:2 56:2 59:4 

60,000 60:20 

6000 72:8 87:21 

60-day 35:17 

64 53:17 

64,000 54:13 

68 54:7 

6A2 21:14 

7

7...70 86:21 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 120

 

7.5 81:6 

70 53:17 56:2 

59:4 

75 33:4 

7th 95:3 

8

80s 7:24 9:8 

10:22 

88 35:1 35:3 35:3 

8-year 71:10 

9

9:30 3:3 

90 81:12 

90,000 20:13 

90-day 46:4 

90s 9:2 9:8 10:22 

51:3 55:16 55:22 

59:6 

92 65:8

a...this 95:25 

a...we 98:8 

a.m 115:4 

abbreviated 87:7 

ability 21:13 

50:22 103:10 

able 12:23 

48:16 57:16 

77:25 99:9 107:4 

about...oh 97:4 

absolutely 107:23 

107:23 

academia 50:16 

Academy 16:23 

accelerated 82:15 

acceptable 46:12 

accepted 18:10 

access 71:3 79:8 

accessible 3:12 

accordance 88:18

103:13 

Act 30:20 50:16 

52:9 54:3 94:11 

action 4:10 

11:7 11:10 11:14 

11:18 11:20 

11:23 18:14 

18:17 18:21 19:9 

19:9 19:13 

21:6 23:9 

33:16 36:23 37:7 

38:21 39:6 

41:8 41:25 42:21 

43:2 43:6 

43:17 43:24 

44:14 44:19 87:8 

87:11 87:25 

102:24 102:24 

103:4 103:11 

actions 94:5 

94:12 

active 52:15 

56:22 86:21 93:1 

activist

93 51:17 

94 55:11 65:9 

96 36:8 

98 72:4 

99 72:5 

99.89 72:6 

99.9 60:6 

99.92 72:6 

A

a...a 40:17 

41:2 42:25 

44:6 49:8 76:9 

78:8 82:8 93:3 

according 30:10 

67:14 69:7 

75:5 86:18 

accountable 62:3 

accurate 110:6 

achieve 50:25 

achieved 59:6 

acre 71:16 

acres 67:22 

71:2 71:10 

across 41:25 

66:25 67:2 73:14 

86:11 93:10 

73:9

93:21 95:20 

activities 94:6 

activity 111:2 

actual 48:9 48:23 

51:16 52:1 

59:9 60:11 

actuality 100:18 

actually 7:18 

22:4 23:1 

43:11 45:8 45:18 

47:4 47:17 47:20 

47:22 48:2 

49:2 50:24 

56:7 61:6 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 121

 

61:18 62:18 82:2 

99:14 100:12 

actually...they

82:1 

acute 24:15 

ad 105:9 105:23 

105:23 106:21 

add 2:12 35:10 

64:20 101:9 

101:10 

added 14:17 

addition 12:13 

87:5 101:2 

additional 9:18 

9:20 25:15 29:21 

43:21 75:7 

75:7 87:17 

107:16 

address 21:8 67:4 

69:19 70:17 97:2 

114:4 

addressing 61:19 

adequate 87:3 

94:2 94:23 95:13 

107:14 

adhere 94:4 

adhering 87:1 

adjourned 115:4 

adjustments 8:8 

administration

31:9 76:13 

administrations

31:8 77:21 

administrative

3:25 78:15 94:11 

94:17 97:1 

97:3 108:12 

114:1 

administrator

75:22 110:9 

admit 69:2 

ado 50:5 

adult 45:16 47:24 

advance 103:9 

103:17 106:24 

advancement 34:2 

advancing 62:9 

advancing... 

okay...so 40:18 

advantage 14:10 

16:16 21:11 

102:21 

adverse 68:8 

103:6 

advice 2:21 

2:22 11:9 13:2 

14:20 104:24 

105:10 109:23 

110:17 

advice...and 2:21 

advisory 2:9 

4:1 4:4 4:13 

7:14 9:5 10:24 

11:1 12:1 

12:17 14:6 14:12 

28:1 35:4 

68:24 75:15 

79:11 84:10 

87:15 88:1 

105:14 107:10 

109:23 110:11 

affairs 32:23 

affect 93:10 

affected 94:14 

94:19 

affected... 

gives 95:9 

affiliated 86:9 

after...after 6:1 

afternoon 66:16 

114:6 114:7 

afternoon...to

114:4 

ag 16:5 16:10 

20:12 22:3 

22:4 22:7 25:4 

36:17 100:19 

100:24 104:22 

111:10 112:5 

112:10 112:11 

112:25 113:3 

against 91:18 

age 46:7 47:24 

aged 48:9 48:10 

age-dependent

48:4 

agencies 94:13 

agency 2:15 

2:21 8:3 8:21 

9:13 9:21 

10:13 12:9 16:17 

18:10 20:24 

24:20 26:5 30:18 

30:19 31:15 

33:25 36:1 48:15 

49:1 72:12 75:12 

75:19 75:21 76:8 

76:11 86:19 

86:24 88:9 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 122

 

90:5 92:22 

93:3 93:5 

93:15 93:16 

93:24 93:25 94:6 

94:15 94:17 

95:15 102:15 

Agency's 87:11 

87:24 

agenda 73:9 97:15 

111:11 

aggregate 72:15 

aggressive 110:23 

ago 7:3 23:9 24:1 

32:14 70:4 

70:5 71:24 

79:5 96:3 

ago...and 66:23 

agreement 10:3 

31:23 56:12 72:9 

agricultural 15:3 

33:3 48:19 

76:6 86:20 90:22 

90:25 99:6 

106:15 

agriculture 5:1 

67:6 

agronomic 86:13 

ahead 3:4 62:3 

106:14 107:11 

109:17 

aims 106:1 106:3 

Al...Al 68:15 

Alar 68:6 89:10 

91:24 92:8 

alarming 87:23 

Aldridge 44:5 

Alex 86:2 89:5 

algae 80:16 

alleged 29:2 

29:13 93:22 

allowing 89:7 

94:2 

allows 19:25 71:4 

94:17 

alone 34:16 34:19 

alone...if 106:8 

already 14:11 

14:12 15:23 

20:25 21:7 29:16 

56:15 76:20 

87:17 93:6 

also...the 9:21 

alter 93:9 

altered 82:20 

82:24 

altering 82:22 

am 4:12 56:13 

America 92:19 

92:23 

American 4:23 

among 18:18 

amount 49:21 

106:7 

AMP 53:12 54:24 

55:12 59:23 

amphibian 10:11 

12:23 

amphibians 12:19 

analyses 54:13 

83:2 

analysis 22:12 

23:22 24:8 

58:8 82:8 

82:13 93:17 

analytical 51:16 

analyze 21:13 

58:18 

analyzed 51:18 

56:23 65:10 80:3 

107:19 

and...and 3:13 

3:19 5:11 8:15 

11:2 20:25 

36:7 37:10 59:11 

62:14 70:23 

73:22 75:10 77:1 

77:21 94:6 

100:18 105:5 

107:7 110:14 

110:21 

and...the 84:16 

and/or 103:5 

androgen 44:1 

animal 16:12 

18:22 19:15 

32:16 37:22 

40:23 45:16 

47:24 48:10 

48:25 84:14 85:4 

85:6 105:1 

animals 18:18 

21:5 25:12 38:20 

47:4 47:6 48:11 

Anna 17:16 

announced 87:18 

89:14 

announcement
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 123

 

89:13 

announces 93:24 

annual 55:1 

78:6 81:4 81:16 

answer 43:19 

64:25 91:21 

101:20 

antiagriculture 73:8 

anti-atrazine

61:22 

anticipate 16:6 

99:8 107:10 

anticipating...

I 99:16 

anticipation

111:11 

anti-estrogenic

44:5 

anti-farming 73:8 

anti-predator

82:16 

anybody 3:6 

anyone 3:5 

27:23 98:4 

anything 71:3 

106:17 

anyway 100:6 

apologize 92:20 

apparently 41:17 

appear 75:2 93:12 

appears 96:8 

applicable 88:2

103:20 

application 56:25 

applicator 71:11 

applicators 20:14 

applied 4:15 4:25

86:21 88:18 

apply 25:13 

appointees 29:8 

31:11 

appreciate 43:7 

62:5 62:20 75:16 

77:4 108:19 

114:23 

appreciated 33:7 

appreciation

102:7 114:17 

appreciative

62:11 

approach 2:2 2:11 

4:2 16:15 

18:17 18:19 21:4 

25:11 25:13 28:2 

40:3 86:18 97:12 

approached 18:11 

approaches 22:7 

42:13 104:3 

appropriate

52:4 59:19 

69:1 69:18 71:21 

75:21 95:14 

104:4 104:5 

approximately

28:9 33:4 86:20 

April 14:7 15:7 

17:21 22:21 23:6 

23:18 25:15 

25:19 25:24 

26:19 102:14 

103:1 103:21 

106:8 

aquatic 4:7 

4:11 10:9 

13:14 13:16 

80:15 81:1 81:2 

arcuate 48:2 

are...I 28:9 

are...we 61:25 

62:17 

area 13:22 45:5 

areas 4:9 23:21 

24:21 41:5 42:14 

52:12 59:7 

65:5 70:17 

arena 89:9 

aren't 82:1 

argument 79:24 

arise 101:16 

Arizona 39:5 

aromatase 39:11 

39:14 

arrived 74:3 

arsenal 67:21 

art 34:8 

as...as 6:16 

72:21 76:4 

as...but 61:15 

aspect 24:3 

48:7 64:4 

aspects 15:11 

19:17 34:22 

95:10 103:14 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 124

 

assays 102:4 

asserted 76:11 

assess 26:15 

assessed 29:3

29:15 

assessing 10:7 

assessment

10:14 10:17 

11:15 11:24 15:9 

16:19 19:18 22:1 

22:6 22:9 

23:12 24:3 

24:6 24:14 

25:1 26:2 26:6 

26:13 26:22 31:3 

38:1 38:9 41:9 

46:3 49:12 

50:7 62:13 100:4 

102:4 103:8 

104:3 

assessments 13:25 

16:17 17:9 17:10 

19:3 20:21 26:14 

37:16 61:20 62:9 

62:14 62:24 

assist 38:18 

assistant 75:21 

associate 5:8 

associated 2:24 

3:10 7:6 8:1 

8:13 10:6 

11:11 11:19 12:8 

14:19 38:19 67:5 

82:18 84:1 103:5 

association

12:5 66:14 

70:1 70:7 

74:10 74:11 

85:25 86:7 92:23 

associations

74:21 

assume 100:5 

assumptions 16:22 

assurances

84:11 84:21 85:3 

at...at 113:7 

at...now 39:4 

Atlanta 4:24 

atrazine 2:3 2:11 

4:2 7:12 7:18 

8:4 8:6 8:9 8:22 

8:24 9:1 9:5 

9:11 9:23 10:7 

10:11 10:14 

10:19 11:6 11:11 

12:4 12:6 12:8 

12:18 12:23 13:8 

13:14 13:16 

13:19 14:19 

15:25 16:1 

18:8 18:20 

20:7 20:8 

21:18 22:17 23:6 

23:17 24:13 

25:17 26:2 

26:6 26:17 26:23 

27:4 28:2 29:3 

29:10 29:14 

29:17 29:20 30:1 

30:5 30:8 

30:11 30:17 

30:25 31:4 

31:7 31:14 32:19 

33:5 33:11 33:16 

33:24 34:3 35:14 

36:2 36:4 36:7 

36:11 36:23 37:9 

37:13 37:19 

37:22 38:3 

38:9 38:13 38:16 

38:25 39:13 40:7 

40:16 40:23 

41:13 41:15 42:2 

42:5 42:11 42:17 

42:18 42:20 

42:22 43:10 

43:14 43:25 44:4 

44:7 44:13 44:23 

45:1 45:3 

45:18 45:21 

46:13 47:18 

47:21 48:17 

49:21 51:22 

52:12 53:7 53:14 

53:21 55:10 

56:17 56:25 57:5 

58:16 59:7 

59:9 61:24 62:10 

63:10 63:21 64:6 

64:11 64:12 

64:22 65:11 

65:11 65:13 

66:19 66:21 

66:21 69:6 

69:7 70:22 

71:4 71:8 

71:11 71:17 

72:17 75:9 76:17 

79:12 79:24 

80:10 80:12 

80:21 81:14 

81:16 81:20 82:9 

82:11 82:16 

82:18 82:20 83:5 

83:15 83:19 

86:13 86:15 

86:18 86:19 

87:10 87:14 

87:21 88:17 90:3 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 125

 

90:4 90:8 

90:10 90:23 91:1 

91:10 91:18 

91:23 92:3 

92:8 92:13 

94:7 96:4 

97:13 100:6 

100:9 100:15 

100:25 101:10 

101:12 101:13 

101:18 102:8 

102:24 103:5 

103:16 103:18 

104:9 108:10 

110:7 111:18 

111:18 111:19 

111:21 111:22 

111:24 111:25 

112:2 112:7 

112:13 113:6 

113:7 

atrazine...it

83:9 

atrazine-laced

83:23 84:4 

atrazine's

11:18 12:11 

12:15 34:13 

43:10 87:22 

88:22 

attacked 30:23 

attacks 29:10 

30:25 31:5 61:22 

attempt 59:13 

attempting 88:9 

attending 114:17 

attention 21:21 

27:7 28:7 41:19 

attenuation 18:25 

audience 3:5 

Australia 36:12 

39:12 

Australian 38:2 

authorities 34:12 

35:24 37:2 37:17 

38:2 62:25 

authority 2:24 

36:21 37:25 

autosamples 57:14 

available 3:15 

3:19 18:9 21:4 

25:12 47:1 57:21 

58:8 64:23 65:12 

78:17 79:20 80:5 

92:22 102:16 

105:3 

average 55:2 55:9 

55:23 56:1 58:14 

63:23 63:24 

80:13 80:22 81:4 

81:5 

averages 81:16 

Avery 86:2 89:5 

89:7 92:17 

aware 43:9 90:9 

93:14 93:25 

111:9 

away 64:25 92:15 

B

backdrop 38:6 

background 5:25 

32:13 32:25 

106:6 

bad 30:13 

Bailey 2:6 2:7 

5:20 28:6 

28:18 31:24 79:6 

96:20 109:15 

113:25 114:9 

ban 73:10 90:3 

90:7 90:9 

91:23 92:12 

banks 8:15 

base 34:8 

based 17:11 18:16 

19:7 20:23 25:24 

30:9 31:4 

40:15 40:22 

44:24 46:5 

49:6 59:14 

61:1 73:17 

79:2 79:13 84:19 

91:24 93:15 

93:20 94:18 

94:24 98:2 104:5 

baseline 59:5 

basic 34:2 61:18 

basically 18:20 

20:3 21:2 

41:25 49:8 

basing 94:1 

basing...based

19:2 

basis 30:19 46:11 

93:14 

baskets 90:13 

be...if 14:1 

be...these 18:2 

be...we're 22:5 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 126

 

bear 17:9 113:1 

became 10:15 67:1 

become 67:20 

107:5 

becomes 47:25 

bedbugs 90:14 

beefing 21:12 

begin 3:2 4:3 4:5

5:14 28:7 

28:18 96:5 

behalf 28:24 

69:16 86:7 

behavior 82:16 

behind 88:14 

believe 18:20 

19:10 27:18 32:6 

40:15 46:12 

47:12 55:3 

56:6 57:6 64:9 

73:3 73:15 

74:3 74:12 

believes 88:20 

belong 42:21 

Beltsville 91:6 

best 18:9 21:4 

25:11 67:16 

102:16 102:18 

better 11:5 19:11 

48:25 57:16 71:3 

88:16 

beyond 71:7 75:8 

biased 73:22 

billion 67:22 

bioassays 84:14 

85:6 

biological 11:22 

biomarker 19:1 

biostatistician

4:25 

biotransformation

43:14 

bit 7:16 12:12 

15:13 20:3 34:14 

56:5 58:18 75:23 

98:18 102:13 

103:24 108:5 

bi-weekly 53:18 

blessed 62:18 

block 14:25 104:9 

blogs 29:11 30:23 

BMP 59:23

board 93:11 

bodies 8:16 

36:3 56:19 57:23 

body 19:11 

43:11 43:15 

49:15 50:14 58:1 

58:7 59:19 77:14 

bogged 100:8 

100:14 

bottom 51:20 

59:21 71:20 

box 57:10 

Boxer 30:11 

Bradbury 5:15 

5:18 17:5 

17:17 27:12 

34:21 53:8 56:11 

97:17 102:1 

102:12 108:2 

111:5 111:15 

Bradbury's 97:21 

Brady 6:3 

brain 45:6 48:5 

break 85:19 96:24 

99:10 

Breckenridge 32:3 

33:13 34:8 

38:8 38:10 38:11 

45:25 50:2 

50:9 54:19 62:16 

64:8 64:9 

brief 5:24 18:7 

38:8 40:19 97:7 

briefing 4:1 

35:13 

briefly 6:11 45:2 

bring 16:13 

17:9 97:20 

bringing 114:25 

broad 7:19 20:8 

60:22 84:17 

84:19 106:1 

broader 20:7 

22:18 100:10 

101:19 

broad-leaf 86:15 

broadly 7:7 14:21 

14:23 103:20 

brought 3:14 

41:12 49:18 79:6 

Bucher 5:7 5:7 

63:7 63:8 63:8 

64:3 64:16 

101:23 101:24 

101:24 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 127

 

build 15:23 

building 14:25 

104:8 

bullet 77:13 

bullied 31:16 

Bush 77:8 77:11 

business 87:11 

busy 105:21 

but...but 100:15 

but...you 64:22 

bypass 75:18 

byproduct 64:5 

byproducts

64:10 64:14 

bystander 98:15 

C 

calculation 19:20 

60:4 

California 4:8 

39:8 66:5 

66:13 66:14 

67:15 68:25 

69:17 98:10 

campaign 76:1 

campaigns 65:14 

Canada 32:24 

33:19 

Canada...Canada

36:10 

cancer 4:23 8:4 

8:24 9:10 11:6 

11:11 11:20 12:2 

12:3 12:6 12:8 

12:11 15:25 16:8 

16:11 18:15 

24:18 24:22 

24:24 27:1 35:25 

36:1 36:5 

36:24 36:25 37:3 

38:19 39:17 

39:19 44:18 

76:14 77:12 85:3 

85:9 111:8 

111:16 112:10 

112:17 113:4 

cancers 43:18 

candidates 52:8 

captioned 40:5 

carbon 64:12 

carcino...is

43:19 

carcinogen 16:2 

76:18 111:23 

carcinogenesis

5:11 

carcinogenic

9:6 9:11 38:3 

carcinogenicity

8:4 9:7 111:23 

112:3 

carcinogens 69:9 

career 30:24 

31:13 

Carol 17:24 

112:16 

Carolina 20:14 

39:22 

carried 77:20 

Cary 4:17 

case 14:17 21:2 

21:17 21:18 

21:19 22:2 

22:9 22:11 24:15 

26:16 39:17 57:7 

59:13 61:20 

66:19 75:17 

79:22 82:4 

95:1 100:16 

101:2 101:3 

104:15 

category 21:22 

cause 8:24 11:6 

12:18 12:23 

15:25 36:25 37:3 

37:11 

caused 38:16 91:4 

causes 45:8 88:13 

cells 83:21 

center 4:19 21:15

28:19 28:25 

century 16:24 

92:6 102:2 

CEO 70:7 

certain 111:4 

111:13 

certainly 74:24 

75:2 75:10 77:22 

105:16 108:19 

113:18 

certainty 72:13 

certified 20:13 

chair 2:19 3:22 

4:13 66:5 78:4 

chaired 114:5 

chairman 32:9 

66:24 70:2 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 128

 

70:8 74:18 74:22 

chairs 32:5 

challenge 31:5 

Chambers 5:2 

5:2 99:25 

100:1 101:8 

107:16 107:17 

chance 77:25 

change 19:25 51:3 

91:14 94:18 

changed 26:8 

57:15 

changes 26:1 55:6 

61:6 64:1 

Chapel 39:22 

characterization

16:20 22:25 25:2 

25:17 27:3 33:20 

38:13 39:21 40:8 

41:13 57:1 

101:17 104:7 

110:7 

characterize

48:16 49:21 53:4 

102:17 

characterized

40:21 44:19 

50:11 56:9 

58:7 60:25 99:13 

characterizing

58:3 103:15 

charge 61:19 

84:16 84:25 

106:25 107:1 

108:21 109:6 

charges 30:15 

30:16 

Charles 32:3 

33:12 38:11 

chastened 68:12 

check 114:14 

checkoff 86:11 

chemical 19:10 

86:23 101:15 

110:14 

chemicals 44:16 

chemist 32:15 

child 49:14 

children 19:24 

37:11 72:14 

child's 49:15 

chillage 91:9 

chlorinated 72:18 

chloro 42:23 

chlorotriazines

42:22 43:2 

chlortriazine

46:2 

Christiansen

17:24 

chronic 24:18 

46:13 49:6 

60:7 60:8 

chronically

52:2 54:23 

circumstances

91:17 95:16 

cited 100:24 

cites 95:21 

cities 90:15 

citrus 66:5 66:13 

66:13 67:7 67:23 

68:25 68:25 

69:16 

civil 31:17 

civilized 31:2 

clarification

27:11 63:6 

clarify 108:4 

clarifying 17:3 

clarity 16:21 

classifiable 37:3 

classification

8:17 36:5 36:25 

clean 30:5 

cleaning 111:12 

clear 43:20 

109:22 

clearly 108:17 

109:13 109:18 

109:24 110:8 

climate 91:14 

Clinton 77:15 

Clinton's 31:8 

close 6:13 

87:12 96:23 

107:12 110:20 

112:1 112:12 

113:5 

closed 111:20 

closely 112:16 

closing 16:14 

111:25 114:16 

co 22:9 

Coalition 70:9 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 129

 

70:11 

coherent 103:2 

colder 67:13 

collaboration

6:13 20:15 

collaborators

47:10 

colleague 114:5 

colleagues 5:24 

6:14 10:24 38:23 

67:2 104:13 

108:3 109:1 

112:15 112:17 

collection 99:12 

College 5:3 57:25 

Colorado 39:5 

colossal 30:14 

column 36:16 

columns 97:22 

combat 91:11 

Combining 71:4

comes 75:11 75:13 

87:13 91:14 

coming 20:11 21:9 

25:8 43:8 

97:25 109:19 

110:4 113:1 

coming...coming

7:10 

comment 3:2 3:8 

27:15 27:19 28:5 

28:6 28:11 28:12 

31:23 34:17 35:8 

35:19 50:4 64:10 

78:19 85:22 86:7 

86:17 87:8 87:12 

89:1 89:8 

94:12 94:20 

94:21 95:11 

96:16 96:23 

103:24 109:21 

commenter 65:23 

69:24 85:18 

commenters

28:15 63:4 78:24 

95:12 97:11 

114:18 115:1 

commenting

28:24 93:2 

comments 3:4 

3:6 3:11 6:1 

6:20 21:24 23:18 

24:21 28:10 29:1 

35:18 61:15 

71:22 71:23 73:5 

74:23 74:25 

77:25 79:4 79:10 

80:6 86:25 

89:4 92:21 94:19 

95:4 95:6 

95:13 96:17 

101:25 105:5 

107:16 107:25 

commercial 71:10 

commitment 62:8 

committed 62:1 

88:15 

committee 67:1 

68:24 72:23 

74:19 

common 42:21 

92:24 

communicate 107:7 

communications

68:6 94:5 

communities

10:9 13:14 13:16 

community 24:4 

51:11 51:13 

51:15 52:21 

52:24 53:16 54:5 

54:11 54:24 

58:20 65:3 70:24 

76:6 95:17 98:14 

companion 27:24 

company 32:14 

33:1 41:3 

compare 60:8 

compared 52:2 

comparing 26:15 

comparison 22:6 

compete 71:5 

competence

30:24 31:5 31:12 

competency 29:11 

competent...their

31:11 

compiled 107:19 

complement 7:1 

complemented 54:9 

complete 105:7 

completed 10:17

35:14 36:10 

112:7 112:20 

complex 94:24 

component 22:8 

compound 8:16 

93:4 94:8 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 130

 

95:11 95:21 

110:5 

comprehensive

23:4 33:7 

35:23 37:7 40:20 

50:6 61:24 62:10 

65:8 84:24 87:18 

96:6 

comprehensiveness

50:19 

compressed 95:1 

95:8 

comprises 41:5 

45:3 

concentration

52:1 57:4 

57:17 58:13 

59:20 64:11 

80:14 81:5 

81:8 81:20 

concentrations

9:23 51:6 

55:10 55:15 56:3 

56:8 58:14 58:23 

61:8 64:13 80:14 

80:24 82:24 

concepts 42:3 

42:12 

concern 9:7 

9:25 10:8 

24:16 24:19 

44:12 48:15 

58:10 59:17 

70:18 79:24 80:1 

81:1 81:23 91:17 

93:3 93:11 

101:18 

concerned 75:2 

93:18 95:25 96:9 

concerning 77:6 

concerns 61:13 

67:5 67:5 

93:23 102:11 

107:2 

conclude 37:14 

95:18 

concluded 13:7 

62:24 94:10 96:3 

96:7 

conclusion 9:10 

11:9 11:18 

12:6 42:20 69:11 

conclusions 36:13 

40:4 40:12 

44:7 69:5 69:5 

69:6 84:19 89:14 

conclusively 91:6 

concocted 92:1 

concur 40:12 

42:20 

concurrent 102:25 

condensed 87:12 

condition 53:8 

conditions

56:11 64:22 

conducted 37:16 

38:1 41:11 50:10 

conference 75:6 

confidence

31:12 105:17 

confident 61:25 

confirm 65:16 

confirmed 34:13 

confused 75:24 

confusion 98:23 

conjugated 43:13 

connections 73:13 

conscious 110:22 

consequence 64:1 

Consequently

30:15 

conservative

34:10 53:11 

62:17 

consider 21:25 

23:11 30:16 

88:11 111:7 

111:8 

consideration

22:17 43:23 

107:14 

considerations

22:23 25:24 

103:14 

considered

49:16 75:25 82:2 

85:10 87:21 95:6 

113:10 

considering 19:14 

23:17 23:23 24:8 

considers 85:11 

consistency 16:21 

consistent 21:7 

55:23 102:15 

110:8 112:4 

113:6 

consistently

55:17 65:19 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 131

 

constitutes 67:9 

consumers 50:23 

51:13 53:5 72:15 

contaminants 4:11 

contaminated

83:16 83:19 

contamination

80:12 

content 97:23 

contents 91:13 

context 7:7 

7:12 7:16 8:12 

29:16 48:22 

49:19 61:3 105:1 

continue 15:24 

76:8 76:25 

97:5 103:9 

continued 39:6 

52:20 86:13 

88:22 

continues 12:10 

67:25 71:15 

continuing 42:1 

90:18 

continuous

47:21 48:1 53:23 

58:21 87:14 

continuously 93:4 

contribute 62:2 

86:10 

contributed 38:24 

contributing 63:1 

contributions

33:23 

control 21:15 

38:5 39:18 

48:4 51:12 86:15 

convened 87:15 

convening 88:1 

conventional 91:8 

converted 43:11 

Cooper 47:5 47:13 

Coordination 5:21 

copies 79:6 92:21 

corn 7:21 69:25 

70:7 74:9 

74:21 85:24 86:7 

86:10 86:14 87:7 

correct 29:25 

65:10 

correctly 65:10 

cost 71:19 

cost-effective

86:15 

cost-efficient

88:19 

costs 90:11 

Council 65:25 

79:1 91:20 92:7 

counsel 11:10 

count 28:9 

country 66:25 

67:2 86:11 

couple 50:14 

50:19 70:4 

course 6:17 7:4 

7:9 24:9 41:10 

43:3 49:22 79:21 

87:8 87:11 

93:7 102:21 

115:3 

cover 92:11 

coverage 60:22 

78:8 

covering 46:4 

create 92:11 

creates 67:10 

88:12 

creating 68:18 

credibility 68:11 

73:15 

Creek 81:7 

criteria 6:9 53:9 

critical 15:11 

17:10 19:18 

23:19 24:2 26:21 

39:17 41:13 

41:20 44:21 

44:22 45:13 

48:20 90:23 

90:24 91:10 

95:10 112:11 

criticisms 93:23 

crop 32:1 93:1 

Croplife 92:19 

92:23 

cross 43:6 

culminated 9:15 

cumulative

10:14 10:17 38:1 

46:2 49:11 72:17 

curiosity 63:9 

current 31:10 

46:14 50:24 61:3 

63:22 87:8 87:18 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 132

 

87:25 89:11 

110:6 110:15 

111:9 

currently 4:13 

7:21 33:3 39:9 

44:23 

currently...and

32:22 

cut 89:9 111:4 

D

D.C 79:3 

daily 57:17 

61:1 83:17 

Daly 46:7 

damage 90:12 

damaged 47:25 

damages 48:2 

Dan 4:5 4:7 

data 16:23 

17:22 18:23 

19:12 19:15 

19:25 20:8 20:11 

20:20 21:9 21:12 

21:13 21:15 

26:12 30:19 34:8 

39:25 40:3 40:10 

40:13 40:13 48:9 

50:14 51:9 52:13 

54:5 54:9 

54:10 54:17 55:9 

57:6 57:6 

57:11 57:20 58:7 

58:18 59:14 

59:25 60:23 

60:24 61:2 

61:4 61:8 

61:18 62:12 

64:23 65:12 80:5 

81:11 84:13 

84:14 84:15 

84:17 85:4 

85:8 85:12 

88:3 88:21 93:16 

94:25 99:12 

99:13 100:3 

100:7 100:9 

100:19 102:3 

102:22 102:22 

104:4 104:5 

105:2 106:5 

106:7 106:22 

107:4 107:18 

111:12 111:12 

data...daily

57:18 

data...these

20:20 

database 40:20 

41:3 42:11 42:14 

50:20 52:16 

52:17 57:21 

60:19 65:13 

databases 43:4 

43:4 51:8 

date 51:17 63:25 

Davis 39:8 

day 47:7 48:23 

52:2 59:14 59:15 

59:25 60:4 76:15 

76:21 77:21 

78:22 

days 3:16 47:7 

47:7 47:9 

47:13 47:15 49:3 

49:5 57:12 71:24 

81:25 83:20 

86:24 87:11 

94:21 

deadline 87:7 

deal 64:17 93:6 

112:10 

dealkylated 42:18 

43:12 

debate 31:2 

decade 88:10 

91:19 105:8 

decades-long

89:15 

decent 45:18 

decision 2:23 

9:15 9:17 10:2 

10:15 10:16 

84:18 86:17 

93:19 

decisions 11:3 

35:25 36:22 

62:23 93:8 93:10 

93:15 110:1 

110:2 110:11 

decline 55:24 

56:3 59:4 

declined 55:17 

declining 58:24 

58:25 65:18 

deeper 83:4 

defects 95:23 

defend 29:9 

Defense 65:25 

79:1 91:20 92:7 

define 50:22 

59:16 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 133

 

definition

89:17 113:14 

degradation 90:12 

degree 7:22 

degrees 67:14 

delayed 82:14 

demand 90:19 

90:22 

demanding 105:21 

Democratic 31:9 

Democrats 89:25 

demonstrate 31:17 

50:25 

demonstrated 43:1 

91:6 

Department 4:9 

70:13 

departure 18:24 

19:20 25:22 

dependent 46:22 

46:22 83:17 

deputy 5:15 

derivative 66:20 

derive 48:24 

describe 15:13 

57:7 57:16 59:13 

described 9:18 

describes 14:3 

describing 7:3 

description 40:19 

design 12:25 26:1 

99:6 99:7 99:9 

104:14 104:23 

106:17 

designated 2:8 

2:14 31:24 96:20 

109:2 

designs 14:23 

15:16 100:23 

100:23 104:6 

104:11 104:18 

104:18 104:25 

113:10 

desire 79:8 

detail 7:16 15:13 

20:3 

detect 51:22 

detectable 80:10 

detected 24:17 

81:9 

detects 51:20 

deterioration

48:4 

determination

84:18 85:11 

determinations

79:20 

determine 12:4 

26:6 75:14 

88:4 112:12 

113:5 

determined 16:1 

36:22 37:19 38:3 

determining 87:10 

87:22 

develop 14:15 

20:19 20:23 24:5 

developed 41:14 

42:13 44:22 

developing 9:16 

42:3 102:16 

development 6:6 

6:15 10:12 12:24 

13:9 23:15 

33:2 38:25 39:10 

40:6 82:21 95:12 

development... 

developmental

37:10 

developmental

12:19 24:9 

38:4 49:1 49:2 

dictates 73:23 

73:23 

differences 11:22 

different 14:22 

15:4 15:4 33:4 

34:23 35:23 36:3 

36:20 37:1 

37:2 37:5 43:1 

47:4 64:22 83:14 

85:19 94:9 

100:23 100:23 

104:23 104:25 

113:9 

difficult 87:6 

113:15 

dimmed 111:1 

direct 44:8 

directly 10:23 

31:1 44:1 84:3 

107:5 

director 4:23 5:8 

5:16 6:2 6:4 6:7 

6:9 74:20 86:6 

89:6 

directors 90:6 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 134

 

disappointed

77:24 86:16 

discounted 95:22 

discourse 31:17 

discover 38:16 

discovered 44:14 

discovery 33:2 

discuss 7:7 12:15 

22:23 22:25 23:2 

25:10 97:15 

discussants 86:1 

discussed 26:3 

34:21 

discussing 6:11 

discussing... 

and 23:1 

discussing... 

exploring 12:17 

discussion 15:2 

26:22 56:6 78:15 

98:16 98:23 

115:1 

discussions 76:16 

disease 67:24 

disinfection

63:10 64:5 

64:6 64:10 64:14 

disruption 19:1 

23:16 44:10 

44:13 

disruptor 29:4 

dissimilar 103:13 

distinct 43:2 

distributed 79:7 

distribution

59:25 

distributors

92:25 

disturbingly

81:11 

divergence 96:1 

diverse 103:20 

Division 6:2 

6:5 6:9 

docket 3:10 

3:15 3:20 28:8 

28:10 61:15 

74:24 79:5 93:24 

96:18 108:20 

108:25 109:4 

113:17 

doctor 66:10 

69:19 

documentation

68:18 106:23 

documented 34:6 

42:10 61:14 75:3 

documenting 34:23 

documents 36:11 

36:13 37:6 68:5 

dog 49:6 

Dogs 68:15 

dollars 70:17 

domain 41:15 

domestically

86:22 

Don 6:3 

done 14:17 

24:16 24:19 38:2 

39:17 43:4 

43:4 43:5 43:6 

47:5 57:23 57:25 

65:7 66:18 

76:9 77:15 

96:2 109:11 

dose 15:12 

18:17 19:11 

22:24 23:10 

23:20 25:1 26:21 

46:11 47:17 

48:25 83:9 83:16 

84:5 103:11 

dosed 47:6 

dose-dependent

83:20 

doses 45:18 

dosimetry 15:18 

dosing 46:7 

47:3 83:12 84:4 

double 90:19 

double-spaced

28:10 

Dr 2:18 3:22 3:23 

4:6 4:12 4:17 

4:22 5:2 5:7 

5:12 5:18 5:18 

5:25 6:5 6:8 

6:19 7:15 17:3 

17:5 17:5 17:6 

17:7 17:16 17:20 

17:24 27:8 

27:8 27:14 27:22 

31:20 32:2 

32:2 32:3 32:7 

32:9 32:13 33:12 

33:17 34:8 34:21 

34:21 38:7 38:10 

39:1 39:4 39:7 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 135

 

45:20 45:25 

47:10 49:20 

49:24 49:24 50:1 

50:2 50:2 50:3 

50:9 53:8 

54:19 56:10 

61:10 61:12 

61:12 61:13 

62:16 62:16 63:5 

63:7 63:8 

63:12 63:12 

63:13 64:3 

64:8 64:8 64:9 

64:16 64:19 

64:19 64:20 65:1 

65:1 65:2 65:7 

65:20 65:24 66:3 

66:3 66:4 66:5 

69:22 74:2 

74:3 74:7 

74:16 74:17 78:2 

78:18 78:20 79:6 

85:15 85:15 89:2 

92:17 96:13 97:8 

97:17 97:17 

97:17 97:21 98:4 

98:6 99:25 99:25 

100:1 100:12 

101:8 101:8 

101:23 101:23 

101:24 102:1 

102:12 104:1 

105:4 107:16 

107:17 107:25 

108:2 111:1 

111:5 111:15 

113:20 113:23 

114:9 114:19 

114:22 

Dr....to 33:12 

draft 111:9 

draw 28:7 96:22 

drinking 8:12 

9:22 9:23 10:5 

15:16 23:3 24:11 

26:7 26:23 

27:4 41:1 

46:14 48:14 

48:17 49:16 

49:22 50:6 50:10 

50:15 50:24 51:9 

51:10 51:12 

51:19 52:6 

52:8 52:9 

52:22 54:3 54:17 

55:3 55:18 56:13 

56:19 57:5 

58:9 59:17 59:24 

60:16 60:20 64:5 

72:16 79:16 

79:25 80:4 81:10 

81:17 82:3 83:24 

84:4 

driven 57:14 73:7 

driver 75:23 

drop 91:5 

dropped 111:3 

dropping 96:5 

Drs 82:9 

due 8:19 37:14 

95:23 

duplicative 29:23 

duration 46:1 

47:2 

durations 19:21 

47:5 83:6 

during 3:14 

6:13 7:9 8:13 

9:8 9:8 24:8 

45:13 48:18 

53:19 77:11 

81:25 87:20 

96:15 

DW 48:24 54:20 

54:21 

dying 30:8 

dynamics 41:9 

E

earlier 39:3 53:8 

54:19 74:4 

75:1 79:20 

103:25 

early 7:24 7:25 

9:2 22:5 25:8 

55:22 98:12 

98:19 106:6 

earned 69:23 

easily 106:10 

echo 74:25 

eco 56:10 57:9 

ecologic 21:24 

104:15 104:17 

ecological 6:9 

10:6 12:16 13:24 

79:15 80:4 84:15 

85:7 

ecologically

56:16 

ecology 49:3 

ecosystem 80:17 

ecotoxicology 4:7 

Ed 6:8 17:23 

EDSP 29:15 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 136

 

29:17 29:18 

29:18 29:24 

29:25 

effect 13:25 24:2 

44:22 46:6 

46:8 46:17 46:23 

47:3 47:4 47:8 

47:11 47:18 

47:19 48:8 48:10 

48:23 49:7 49:13 

52:3 59:16 

60:4 60:8 61:3 

61:6 63:14 63:19 

64:10 68:9 

effective 51:5 

effectively 42:19 

effectively... 

have 51:5 

effectiveness

28:19 28:25 55:5 

effects 6:2 6:4 

10:11 12:11 

12:16 12:19 

12:24 13:9 13:14 

13:16 13:22 

13:24 18:22 

19:16 19:19 

23:20 23:22 24:5 

24:15 24:18 

24:23 24:24 

26:21 29:2 29:14 

29:19 29:21 38:4 

38:20 39:7 40:22 

41:8 44:16 

45:1 45:10 45:19 

47:8 47:21 81:24 

83:5 93:22 

111:16 

effort 17:8 68:18 

92:12 93:6 97:19 

efforts 11:5 

50:13 62:11 

90:17 

eggs 90:13 

eight 28:5 28:9 

28:15 82:21 

either 27:12 37:2 

47:6 66:10 

102:19 

Elaine 6:5 6:5 

election 90:1 

Eligibility

9:14 10:2 

10:15 10:16 

Elizabeth 17:20 

else 3:5 3:6 71:3 

elucidate 13:18 

elucidating 15:18 

emphasis 5:5

13:22 19:8 

emphasize 21:6 

23:9 107:8 

enabled 53:3 

encourage 96:19 

endeavor 41:21 

endeavored 40:22 

endocrine 23:16 

29:2 29:4 

29:14 29:19 

29:21 44:10 

44:12 44:14 

44:17 44:25 

45:19 85:9 

endocrinologicall

y 47:25 48:10 

endocrinology

39:1 

endpoint 46:16 

endpoints 24:14 

34:9 45:25 48:14 

62:15 82:19 

82:20 85:9 85:10 

endpoints... 

all...sorry... 

all 85:8 

engage 71:21 

ensure 2:16 

8:10 9:23 

15:17 24:17 

51:11 62:6 88:17 

102:15 102:20 

109:15 

ensures 94:15 

ensuring 16:20 

17:10 110:5 

entertain 63:3 

entire 68:13 81:5 

entirely 89:16 

93:12 

entities 70:13 

95:17 

entitled 50:6 

entity 66:25 

entry 53:9 

environment 37:23 

88:16 90:25 

environmental 4:9 

6:4 32:16 

33:19 41:7 

41:7 51:6 58:5 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 137

 

58:10 60:21 61:7 

70:9 70:11 

79:2 90:12 

envisioned 100:15 

EPA 2:23 5:17 

7:24 20:15 

29:5 29:8 29:9 

29:16 29:16 

29:18 29:22 

29:24 29:25 30:2 

30:6 30:6 

30:11 30:12 

30:14 30:17 

30:24 31:1 31:10 

31:12 31:18 

32:11 32:17 

34:15 34:25 

35:14 35:22 36:9 

38:1 40:1 

40:22 42:19 46:1 

49:12 54:21 

59:16 62:3 62:24 

65:12 68:5 

69:5 72:20 73:16 

73:21 76:14 

76:23 77:8 77:12 

77:15 77:19 78:7 

79:11 84:7 84:12 

84:22 87:1 87:14 

88:2 88:6 

88:23 90:9 91:13 

91:17 92:9 

95:9 95:13 95:18 

95:23 96:2 

97:3 97:11 

114:18 114:23 

EPA-reviewed

30:19 

EPA's 29:15 

30:3 31:3 35:6 

44:2 44:21 70:17 

72:11 78:13 

86:17 87:8 87:20 

93:23 

epi 16:10 100:2 

epidemia 24:22 

epidemic 92:4 

epidemiologic

22:18 

epidemiological

14:14 14:19 

14:22 14:24 15:5 

16:4 20:18 

epidemiologist

104:12 

epidemiology

17:25 18:15 21:9 

21:20 25:3 

25:7 25:16 26:11 

26:14 26:17 27:1 

37:8 39:16 84:15 

84:16 85:7 

85:7 98:10 98:15 

98:22 99:22 

103:23 104:1 

104:4 104:11 

104:25 111:6 

111:16 112:22 

113:7 

episode 68:13 

equivalent 53:13 

ERC 70:10 

erosion 90:11 

91:4 

erroneously 37:14 

especially 7:23 

20:11 40:25 

45:11 102:14 

103:21 

essential 105:25 

Essentially 9:4 

established

9:22 10:5 

12:22 35:4 46:23 

52:3 87:24 

establishing

48:14 95:18 

estimating 15:4 

estrogen 44:1 

48:1 

estrogenic 44:4 

et.al 44:6 83:9 

Europe 37:14 

European 36:5 

37:17 

evaluate 21:16 

106:3 

evaluated 88:7 

evaluating 19:8 

22:9 23:22 110:5 

evaluation 23:7 

23:20 26:20 

89:22 

evaluations 93:8 

Evan 39:11 

Evansville 81:22 

event 25:18 48:19 

57:14 

events 11:24 

45:11 58:4 61:1 

everybody 97:9 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 138

 

114:2 

everyone 2:6 

110:14 114:17 

114:22 115:2 

everything 27:2 

evidence 14:15 

14:16 21:4 24:25 

25:10 27:2 39:21 

44:7 88:6 

91:22 102:17 

102:17 

evident 64:23 

exactly 64:4 

65:16 76:5 102:6 

exactly...in

102:5 

examined 82:22 

82:25 

example 12:2 

23:14 

examples 100:17 

exceed 51:24 

54:18 54:21 

exceedance

53:11 58:9 

exceeded 54:18 

55:1 59:2 

80:25 81:17 

excellence 42:10 

except 83:2 

excess 60:5 60:13 

existing 19:6 

48:9 93:9 

exists 40:20 

50:20 93:9 

expect 25:3 77:22 

78:9 80:16 

expected 25:5 

experience 4:25 

33:11 71:8 

76:5 98:21 

experienced 95:23 

experimental

14:14 14:24 15:8 

16:12 22:21 

24:23 102:25 

103:22 105:2 

106:9 

expert 39:11 

39:20 

expertise 4:10 

explaining 104:14 

explicitly

19:14 22:17 

explore 104:10 

exponential 41:18 

exposed 24:12 

43:10 50:23 52:2 

53:22 54:14 56:2 

58:15 59:1 63:23 

exposure 8:10 

8:25 12:6 

33:20 38:13 40:7 

40:24 40:25 

44:23 46:13 48:1 

48:17 49:17 50:7 

50:11 50:22 

50:25 51:9 51:24 

51:25 52:12 53:4 

53:21 54:20 57:2 

59:11 59:13 

59:14 59:17 60:3 

60:5 60:11 60:13 

60:16 61:4 62:14 

72:16 98:15 

103:14 

exposures 46:2 

46:4 46:4 81:25 

express 114:17 

expressed 48:15 

102:11 

expression 39:15 

extend 46:5 86:17 

extensive 33:25 

35:19 37:4 88:21 

extent 41:19 

102:23 111:22 

112:25 113:13 

113:16 

extrapolate 19:19 

extrapolation

18:18 

extremely 51:21 

eye 107:12 

61:5 71:9 13:19 15:4 19:20 

exchange 35:20 

executive 74:20 

exercise 60:6 

19:21 22:4

22:6 22:9 

22:10 22:13 

24:11 24:14 25:1 

26:14 26:16 

F

FACA 2:16 

face 76:20 

facility 39:18 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 139

 

fact 43:1 43:8 

43:13 47:22 48:3 

48:24 49:7 

65:7 71:15 72:10 

76:17 77:16 

78:12 88:8 93:14 

106:13 

factor 19:23 

23:25 39:13 

39:14 46:10 

46:10 59:18 60:9 

factors 19:12 

23:23 24:10 

25:22 

facts 94:16 

fair 103:17 

106:12 106:12 

fairly 21:20 

fairness 94:14 

fall 82:3 89:20 

false 88:12 

familiar 107:5 

farmers 70:15 

70:15 70:21 

71:14 86:10 

86:14 

farming 90:11 

90:13 91:4 91:7 

fate 6:4 41:7 

favor 91:14 

favorable 62:23 

fear 92:1 92:11 

February 14:7 

14:11 14:18 

17:18 20:5 

20:9 20:22 

21:1 22:16 

25:7 25:8 

25:11 25:15 

26:11 52:20 98:8 

100:2 100:5 

100:16 104:2 

104:8 104:17 

111:7 

February/

September 103:25 

February's 99:16 

fed 83:15 83:19 

federal 2:8 

2:14 31:24 94:12 

94:22 96:20 

109:2 

feed 56:20 

83:16 83:19 

feedback 13:15 

26:5 108:5 

feel 61:21 

62:18 103:7 

feels 71:24 

fellow 33:13 

38:12 98:1 

felt 67:3 69:23 

108:13 

females 45:11 

Fenton 68:6 

fetuses 37:11 

fewer 3:9 90:13 

fiasco 68:9 

Fidori 47:11 

field 76:21 

FIFRA 2:8 3:25 

4:4 4:13 28:1 

96:1 114:2 

fig 90:6 

fight 73:12 73:25 

90:16 92:14 

figure 99:1 

filtration 64:12 

final 111:12 

112:2 112:18 

113:25 

finally 19:21 

47:19 48:13 

83:22 

finish 6:1 

finished 9:24 

51:6 51:19 

52:9 53:3 53:5 

53:18 54:6 

54:7 54:12 54:13 

54:16 54:17 55:2 

55:15 55:18 56:4 

59:24 60:1 60:19 

63:16 63:17 

81:16 

finishing 17:24 

first 5:15 7:18 

17:16 21:18 25:7 

29:2 29:13 38:15 

43:18 44:11 46:3 

51:9 52:18 79:10 

79:14 80:3 84:11 

86:16 108:6 

110:15 

first...they

40:18 

fit 101:21 

fits 20:8 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 140

 

five 3:9 54:1 

56:24 83:23 

flaws 95:23 

flew 68:2 

floor 98:2 

Florida 67:25 

flying 66:17 

focus 8:23 

11:15 11:24 

11:25 13:21 

13:21 15:7 22:21 

23:6 24:8 

26:25 46:3 56:23 

101:19 107:2 

109:8 111:22 

113:3 

focused 8:9 35:25 

60:24 78:11 

focusing 11:22 

13:10 112:23 

113:11 

fold 113:2 

folks 73:7 

followup 12:7 

107:17 108:3 

food 36:17 

72:16 90:10 

90:19 

for...for 49:9 

for...for...in

32:15 

for...I'd 33:22 

for...was 35:6 

forecasting 112:6 

foremost 51:10 

Forerunner 114:11 

forget 62:22 

form 28:12 108:21 

formal 53:9 75:18 

format 85:19 

formed 66:25

106:22 

formulated 109:6 

formulators 92:25 

forth 14:9 

fortunate 62:18 

forward 3:14 6:17 

32:4 32:12 39:24 

41:12 49:18 63:1 

77:23 78:22 

104:9 108:14 

108:17 114:10 

115:2 

forward... 

it's...it 106:1 

forwarded 14:2 

foundation

18:17 109:25 

110:13 

fourths 69:3 

FQPA 23:25 

25:22 46:10 96:2 

frame 8:13 

10:21 35:13 

112:8 112:20 

frames 58:13 

framework 20:20 

20:23 20:24 21:2 

21:3 

France 37:18 

37:20 

Francis 6:5 6:5 

frankly 75:24 

77:14 

free 67:8 67:17 

frequency 15:17 

24:4 25:24 

26:8 26:23 

27:4 48:16 53:23 

55:1 60:23 

frequency...we

55:21 

frequent 48:20 

frequently

24:17 24:19 94:4 

frogs...found

82:11 

from...from 21:14 

front 99:23 

fruit 67:8 

FSH 45:8 

full 43:4 59:25 

85:11 89:22 

91:24 

fully 50:22 

53:3 62:1 

function 19:2 

45:16 82:18 

82:22 

fungicides 33:4 

future 77:22 

110:22 

G

gain 84:11 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 141

 

game 111:24 

Gary 69:24 70:1 

70:6 114:5 

general 5:9 72:13 

78:8 

generally 78:8 

generated 50:15 

50:21 51:9 51:17 

54:13 57:3 57:22 

59:15 59:23 

generates 57:18 

generating

21:23 26:17 

generation 102:3 

generator 45:14 

generators 45:7 

generic 100:4 

100:9 101:7 

genotoxic 36:22 

36:23 

gentlemen 39:24 

66:8 68:3 68:17 

geographic 60:22 

get...and 59:18 

gets 13:10 43:11 

getting 8:19 

13:15 20:17 

20:17 64:13 99:2 

99:8 109:16 

112:6 112:19 

given 13:20 30:15 

74:3 83:10 84:23 

87:2 

gives 6:19 56:7 

89:17 

giving 55:6 56:13 

glad 78:20 

gland 18:13 23:15 

39:9 

glean 63:14 

GnRH 39:7 45:4 

45:7 45:14 45:22 

go...so 14:5 

goal 104:2 

gonad 82:22 

gonadal 10:11

12:18 12:24 13:9 

82:21 

gonads 45:10 

gone 40:6 62:20 

68:19 75:19 

85:20 

government

68:22 70:13 

grab 57:12 

Grain 74:10 74:21 

graph 35:24 

59:8 59:22 

great 93:5 

greatest 24:16 

24:18 

greatly 33:7 

41:12 51:24 

grew 58:15 

ground 54:6 60:20 

groundless 95:19 

grounds 90:3 

groundwater 8:5 

8:11 9:1 9:19 

51:15 51:20 54:7 

group 38:17 42:21 

46:18 59:1 61:22 

70:8 70:12 

113:16 114:3 

groups 28:16 

grove 67:10 67:13 

groves 67:12 

67:17 

grow 90:19 

growers 67:21 

70:1 70:7 

70:20 74:9 85:24 

86:7 87:7 88:15 

grown 42:11 

growth 41:18 

guess 70:3 73:5 

74:19 77:7 77:23 

78:1 98:1 99:4 

100:6 102:10 

113:24 

guidance 16:17 

18:11 21:7 

102:15 

guide 11:1 110:18 

guideline 32:15 

32:16 

H

half 97:9 

half-life 43:10 

Halloween 71:23 

71:25 

hamstrings 90:17 

hand 61:10 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 142

 

Handa 39:4 45:20 

Handa's 47:10 

handbook 16:20 

happened 35:9 

68:15 

happens 42:25 

happy 33:9 

33:21 63:2 

hard 62:1 90:15 

109:14 

hardly 75:21 

harm 37:11 

37:22 72:13 

80:17 

harvest 87:6 

has...has 20:5 

hastily 93:20 

hat 69:20 104:13

have...however

63:18 

haven't 107:21 

having 7:9 

92:21 98:16 

101:18 110:2 

hazard 15:12 

19:18 22:24 25:1 

25:16 27:3 40:7 

head 32:23 

33:18 39:1 

heads 90:21 

headwater 56:18 

health 4:19 5:1 

6:9 11:16 

12:14 13:22 

13:25 15:3 

16:5 16:10 18:12 

19:16 20:12 22:3 

22:4 22:7 23:5 

24:6 25:4 

26:12 35:4 35:15 

36:15 36:16 37:6 

37:15 37:16 

37:21 37:22 

62:14 79:4 93:22 

98:14 100:3 

100:20 100:24 

104:22 106:15 

111:10 112:5 

112:10 112:11 

112:25 113:3 

Health...Health

6:2 

hear 28:15 

34:12 39:23 

45:22 77:25 

heard 69:4 

74:12 97:16 

hearing 44:15 

78:23 97:11 

heart 91:3 

HED 17:14 

heels 87:13 

Heeringa 2:18 

3:22 3:23 4:12 

4:12 5:12 5:18 

17:5 27:8 

27:14 27:22 

31:20 50:1 61:12 

63:5 63:12 

64:8 64:19 

65:1 65:20 

66:3 69:22 

74:2 74:7 

74:16 78:2 85:15 

89:2 92:17 96:13 

97:8 99:25 

101:23 105:4 

105:4 107:25 

111:1 113:20 

113:23 114:9 

114:20 114:22 

Heidelberg 57:25 

held 9:3 35:3 

36:19 37:18 

help 11:1 13:17 

19:11 62:5 70:17 

85:10 102:23 

103:11 103:12 

105:15 106:2 

107:2 107:11 

110:17 

helped 70:12 

helping 5:21 

helps 91:11 

hence 90:3 92:2 

112:20 

Henry 39:12 

herbicidal 41:6 

herbicide 7:19 

7:20 67:6 

herbicides 8:23 

10:18 33:5 

71:4 91:1 

He's 33:13 39:2 

hide 90:7 

high 45:18 

52:12 52:17 53:1 

53:23 54:25 55:8 

55:20 55:21 

56:17 60:23 

81:12 89:17 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 143

 

high...higher

91:12 

high...most 53:22 

58:15 

higher 49:8 71:19 

90:10 

highest 81:21 

highlights 82:8 

highly 53:22 

54:14 56:2 56:16 

58:15 58:22 59:1 

high-quality 42:9 

Hill 39:22 

historically

22:14 

history 7:13 

hoc 105:9 

105:23 105:23 

106:21 

holding 87:10 

holistic 113:7 

Holvey 39:8 

home 4:24 67:10 

honest 69:13 

hope 73:22 114:6 

hopefully 40:12 

79:7 

hormone 18:25 

44:2 44:8 

44:24 82:24 

83:11 

host 88:9 

hour 97:6 

Hudson 89:5 

Huffington 30:10 

huge 50:11 

50:14 57:21 

60:18 

human 11:15 12:14 

13:22 13:24 16:1 

18:12 19:15 

19:16 20:24 

22:12 23:5 

24:6 26:12 

38:9 41:21 

43:9 59:11 84:14 

85:4 93:22 100:3 

humans 9:6 9:12 

11:13 11:21 

18:18 18:19 21:5 

25:12 36:24 

hunt 91:18 

Hurdle 32:3 33:17 

49:20 49:24 

49:25 50:2 

50:3 50:3 

61:12 62:16 

63:12 63:13 

64:19 64:20 65:7 

hydrology 64:21 

hydroxy 42:24 

hydroxyatrazine

42:19 

hype 56:6 

hypothalamic 19:1 

45:6 

hypotheses 23:14 

hypothesis

12:23 13:1 26:17 

hypothesized... 

hypothesis 21:23 

I

I...a 18:6 

I...apparently

111:3 

I...certainly

105:12 

I...I 102:10 

I'd 3:24 4:3 5:14 

5:19 5:23 7:11 

28:18 65:20 

65:21 72:1 85:23 

96:22 98:1 105:4 

113:24 114:2 

identifiable

72:15 

identification

15:12 22:24 

26:21 

identified 23:14 

identify 29:19 

ideological 92:12 

if...if 99:5 

107:18 

I'll 2:7 7:15 

12:11 17:3 34:14 

49:23 69:11 

69:11 92:21 

illustrate 48:6 

illustrations

101:6 

I'm 4:7 4:14 4:15 

4:17 4:18 4:19 

4:22 4:24 5:2 

5:2 5:4 5:7 

5:7 28:23 

28:24 32:22 33:9 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 144

 

38:6 38:11 

55:6 56:10 64:16 

64:24 65:9 

66:9 66:10 66:10 

66:12 66:15 69:4 

70:6 71:22 72:22 

74:20 75:24 77:8 

78:20 78:21 

78:25 79:2 

79:3 79:9 

89:12 99:17 

102:6 104:12 

I'm...I'm 77:24 

102:5 

immediately 90:4 

immune 82:18 

immunotoxicity

23:16 

impact 50:20 

impacts 19:22 

impaired 82:18 

82:22 83:17 

implementation

2:24 

implications

41:20 

importance 8:5 

8:25 16:24 

94:1 98:17 

important 11:14 

16:7 22:15 

24:2 67:20 100:4 

103:7 106:24 

107:3 108:13 

109:8 109:24 

110:4 110:13 

importantly 67:11 

90:5 

impression 95:9 

in...as 56:4 

in...in 6:21 

10:20 11:2 45:23 

93:14 111:8 

incident 21:12 

21:14 26:12 

84:15 100:3 

101:3 104:4 

incidents 22:12 

include 15:2 

25:20 38:25 

50:12 85:4 

included 10:3 

52:20 53:15 

54:10 

includes 6:13 

32:1 50:14 54:25 

55:12 111:25 

including 29:20 

30:20 31:8 

41:6 46:10 70:13 

84:13 85:5 

85:9 96:17 104:3 

incorporate 14:13 

101:17 

incorporated 9:17 

incorporating

20:20 26:11 

100:2 

increase 68:1 

83:11 

increased 82:19 

increases 21:12 

increasing 79:23 

independent

2:20 34:11 

Indiana 81:7 

indicate 16:15 

61:4 

indicated 6:24 

8:3 8:5 75:22 

112:5 

individual 93:8 

100:9 100:11 

113:16 

individuals 29:12 

30:23 31:1 68:12 

112:16 

industry 66:20 

67:7 67:7 

68:10 68:25 

69:16 69:18 

inevitable 90:14 

infamous 89:10 

infants 19:24 

37:11 72:14 

infection 82:20 

influences 15:15 

inform 11:3 24:14 

102:23 103:11 

103:12 

information

15:6 15:10 16:25 

20:17 21:4 25:14 

30:20 35:20 

61:18 61:21 

78:16 79:14 

79:16 88:3 94:16 

95:19 102:7 

102:16 102:21 

102:25 103:1 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 145

 

103:10 103:21 

104:7 104:19 

104:20 105:19 

106:19 107:5 

107:15 108:1 

108:20 108:24 

109:5 109:12 

109:14 109:17 

110:23 113:12 

informational

2:12 6:25 

27:25 108:8 

informs 23:25 

infrequent 51:21 

ingredient 86:21 

ingredients 93:1 

initial 76:22 

78:14 108:16 

114:24 

initiate 10:20 

initiated 8:21 

52:14 52:19 

56:21 77:14 

initiating

11:23 93:3 

initiation

32:19 32:20 

93:11 

initiative 98:4 

innuendo 91:25 

92:11 

input 17:9 87:4 

109:18 110:17 

115:2 

insecticides 33:5 

inserting 102:8 

insights 14:21 

103:19 104:11 

109:5 110:6 

instance 35:12 

instead 71:18 

75:19 

Institute 39:12 

89:5 112:17 

instruct 64:24 

insulin 84:1 

intake 49:15 

59:19 

integral 91:2 

integrate 13:17 

14:15 14:22 

14:23 15:5 16:11 

16:22 25:14 27:2 

103:10 104:24 

integrated

24:25 103:23 

integrating

19:6 103:20 

104:7 

integrity 30:24 

31:6 31:12 

62:4 88:3 

intend 40:2 40:4 

intense 55:8 

intensity 52:18 

53:1 

intensive 53:16 

54:10 107:4 

intent 22:18 

101:19 

interest 4:20 

5:10 23:21 41:15 

44:16 78:13 

interested

86:25 87:1 

interesting 84:3 

interests 28:16 

67:16 92:24 

Interim 9:14 10:2 

10:15 

interior 114:12 

internal 50:12 

75:19 

International

36:1 

interpret 13:15 

16:22 16:25 

19:11 104:19 

105:15 110:7 

interpretation

15:15 40:13 

interpreting 11:2 

into...into 10:22 

introduce 4:5 

5:23 6:20 

17:12 17:15 

105:5 

introductions

5:14 

invasive 67:10 

investigate 41:21 

investigating

23:13 

investigations

43:16 

involve 22:3 

22:11 22:17 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 146

 

involved 22:9 

32:21 34:18 

38:12 43:15 44:3 

44:20 72:20 

105:9 

involves 25:11 

94:8 

involving 8:18 

Iowa 20:14 

IRED 9:14 10:2 

10:9 11:25 54:22 

112:4 

is...is 70:12 

101:10 

isn't 7:5 43:14 

80:22 

issue 12:2 

14:13 16:8 43:13 

67:3 67:18 76:14 

77:12 79:12 84:8 

101:7 

issued 7:24 

9:14 10:1 10:13 

issues 2:21 

2:25 5:10 7:5 

11:1 18:5 23:3 

88:9 102:8 104:6 

107:3 109:7 

109:20 109:24 

109:25 113:1 

It...it's 72:1 

it...it's... 

some 77:6 

it...or 75:14 

it...turn 7:15 

items 111:11 

it's 3:2 6:25 

7:20 7:21 21:7 

22:3 22:15 

25:4 34:7 

51:23 52:14 

61:16 67:16 

69:13 71:3 71:20 

72:24 73:7 73:24 

74:14 74:19 

75:25 76:1 

76:5 77:20 78:11 

78:12 80:22 84:3 

85:19 86:4 90:24 

94:9 98:17 98:21 

101:5 101:6 

103:3 103:17 

105:12 105:18 

105:24 106:18 

107:3 109:23 

110:8 112:18 

112:19 113:15 

114:12 114:13 

It's...it's 43:14 

76:2 

I've 9:18 69:8 

69:9 69:10 71:11 

71:11 72:3 

77:7 80:5 89:8 

105:8 

J

Jack 39:15 

Jackson's 110:9 

James 39:1 

Jan 5:2 

Janice 32:2 

32:2 32:13 38:10 

Janice...I'm

32:12 

January 9:13 

Jennifer 65:24 

65:25 74:5 

74:5 74:16 78:25 

Jennifer...Dr

66:1 

Jerry 74:9 74:20 

Jim 39:20 

job 76:9 

Joe 2:7 3:23 3:24 

5:20 6:24 28:6 

28:18 31:24 

96:20 113:25 

114:8 

Joel 66:4 66:12 

72:21 73:11 

John 5:7 63:8 

101:24 

joined 27:23 

joining 53:10 

joins 53:14 

joint 36:18 

journal 113:18 

journals 112:24 

judgment 105:13 

judicious 88:19 

juice 111:4 

July 30:6 77:18

jump 50:5 

June 70:5 

jurisdiction 82:4 

just...threefourths 69:3 

justify 30:18 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 147

 

61:23 91:23 

K

Kansas 74:9 74:10 

74:21 

Ken 4:22 

key 23:21 34:23 

34:24 105:24 

kg 46:9 

kick-off 75:25 

killers 91:12 

kinds 5:10 

14:22 15:5 

101:25 104:20 

104:25 

kinetics 41:9 

Kingdom 36:6 

37:17 37:21 

kneejerk 68:9 

know...they 91:23 

knowledge 38:25 

40:7 106:15 

known 40:6 

L

lab 26:20 44:2 

47:10 

label 8:8 51:3 

55:6 61:6 64:1 

69:7 88:18 

laboratory

17:22 22:21 

labs 44:21 

lack 95:24 

ladies 66:7 

68:2 68:17 

language 37:1 

51:4 

large 8:18 

50:25 58:7 61:4 

largely 113:4 

larger 114:3 

last 9:16 13:13 

30:22 31:7 33:24 

35:10 36:16 

50:21 51:3 57:22 

58:5 64:2 

66:16 71:16 

73:20 79:17 

84:23 87:18 

89:15 98:9 98:11 

98:12 98:12 

98:13 109:21 

112:7 112:11 

113:4 

late 78:21 

later 59:2 95:4 

Laura 109:15 

law 93:14 110:10 

Laws 83:8 

lawyer 66:10 

lead 17:17 

17:18 17:21 

17:25 19:13 

23:23 32:8 33:15 

33:19 45:7 45:11 

103:6 

leader 33:1 

leaders 6:21 

leading 9:8 33:10 

33:14 84:2 

leads 17:15 18:21 

46:10 60:10 

leaf 90:6 

leap 98:4 

learn 106:19 

learned 90:15 

least 10:23 

13:8 17:12 58:21 

75:7 76:2 79:7 

80:20 90:19 

leaves 52:5 95:11 

leaving 88:16 

lectern 49:23 

led 11:9 43:18 

legitimate 67:5 

less 24:19 

47:13 48:11 

51:21 52:11 

90:11 91:7 95:12 

let's 27:22 69:13 

76:20 97:4 97:5 

level 46:8 

46:17 46:23 47:8 

47:11 49:7 

49:8 49:13 

52:3 55:17 55:22 

58:9 59:16 59:17 

60:4 60:9 

111:4 114:11 

levels 9:25 

10:8 44:22 45:12 

47:4 48:11 48:23 

50:25 55:24 61:3 

62:13 63:10 

63:16 63:21 64:6 

65:18 80:10 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 148

 

80:21 81:14 

Levine 5:25 

6:19 7:15 17:3 

17:6 17:7 27:9 

27:12 34:21 

97:17 100:12 

104:1 

leydig 83:21 

LH 45:8 45:17 

45:25 46:6 

46:6 46:6 

46:19 46:22 47:3 

47:4 47:9 

47:18 47:19 

47:22 49:2 

liaison 2:15 

liberty 46:25 

lie 62:2 

life 19:12 

19:22 23:11 

23:22 23:23 71:9 

lifetime 42:24 

46:5 49:17 

light 24:7 26:4 

lights 111:1 

114:12 

likely 9:6 9:11 

11:11 11:12 

11:19 11:21 12:7 

16:1 36:25 37:3 

limit 3:8 

limitations 79:22 

105:1 

limited 84:13 

84:22 85:1 85:5 

limits 35:4 49:18 

line 27:24 

34:20 34:22 

35:18 51:20 59:8 

71:20 111:25 

lines 14:15 14:16 

102:16 

linked 99:16 

list 74:4 

lit 66:6 

literature

12:10 12:21 

12:22 13:6 

13:7 13:11 

23:5 40:1 

41:19 42:2 

42:4 42:15 

47:1 84:20 84:25 

101:14 113:13 

113:14 

little 5:25 

7:12 7:16 

12:12 20:3 

21:8 31:25 32:25 

34:14 56:14 

58:18 77:24 

78:11 81:6 85:19 

85:20 95:4 98:18 

102:13 103:24 

105:11 108:5 

LOC 48:24 54:20 

54:21 

located 45:5 59:8 

location 81:8 

locations 60:25 

logic 40:4 40:11 

long 68:10 82:1

93:15 105:16 

longer 31:25 

85:20 

long-term 46:1 

47:19 

lose 89:25 90:2 

loss 91:8 

lost 67:25 

lot 10:25 17:13 

18:4 18:4 18:6 

21:23 24:7 44:15 

63:15 65:2 68:12 

98:16 98:23 

98:23 98:24 

low 51:23 

lower 114:11 

lowest 48:10 

Lowit 17:16 97:18 

101:8 101:9 

luteinizing 18:25 

44:24 

M

machine 90:2 

machines 67:13 

main 80:7 

mainly 52:23

53:18 57:23 

maintain 91:12 

maintained 87:23 

major 20:12 24:11 

42:25 72:14 

90:14 91:16 

male 83:10 

males 45:12 46:20 

46:21 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 149

 

mammalian 33:14 

mammary 18:13 

23:15 38:16 39:9 

manager 32:18 

Mandel 39:15 

manner 88:19 

107:19 110:24 

manufactured 12:4 

manufacturers

92:24 

manufacturing

12:3 

manuscripts

111:10 

March 67:19 

margin 19:20 51:1 

51:25 59:13 60:3 

60:5 60:13 

margins 51:23 

59:11 61:4 

marketplace 96:10 

Marshall 69:25 

70:2 70:6 74:2 

75:1 

Maryland 114:13 

matches 15:17 

material 3:13 

97:16 

materials 28:12 

87:4 106:6 106:6 

107:24 109:4 

matter 43:21 

91:13 

maturation 46:21 

mature 102:6 

maximum 52:1 

80:24 81:7 

may 11:7 12:23 

13:18 21:9 47:20 

81:9 96:11 

103:12 

maybe 21:8 70:4 

74:6 74:7 

77:24 97:16 

103:2 103:3 

106:18 107:22 

108:4 

McAllister 86:3 

92:18 92:18 

92:20 96:14 

McCoy 82:9 

McFarland 32:2 

32:2 32:8 32:9 

32:13 61:11 

61:13 

MCL 49:6 49:8 

59:2 63:22 63:25 

mean 59:10 

90:10 90:13 

104:13 106:5 

meaning 82:14 

measurable

81:14 83:11 

measured 60:1 

99:14 

measurement 65:4 

measures 8:10 

51:2 88:17 

mechanism 11:14 

11:18 11:19 

11:23 48:5 

mechanisms 4:10 

11:7 11:10 

102:23 103:4 

media 29:12 75:22 

76:15 76:20 

100:25 

media...media

93:21 

median 60:8 

Medicine 5:3 

meet 30:19 87:7 

meeting 2:4 2:9 

2:10 2:12 2:19 

3:1 3:11 3:14 

3:17 3:18 3:22 

3:25 5:19 5:22 

5:25 6:24 6:25 

6:25 7:5 14:12 

15:1 17:19 17:21 

18:1 20:5 20:9 

20:10 22:19 23:6 

24:20 25:8 25:13 

25:21 26:3 26:11 

27:17 28:1 

28:4 28:8 

28:13 36:18 

75:25 78:5 

78:5 78:6 

87:10 87:13 95:3 

95:5 96:21 96:24 

97:2 97:10 

98:8 98:9 

98:11 98:18 

101:19 101:22 

106:8 106:16 

108:15 114:5 

114:15 115:4 

meetings 14:6 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 150

 

27:23 45:23 

97:23 97:24 98:7 

107:20 107:21 

member 72:23 

members 4:4 

5:13 6:20 

27:11 32:7 

63:6 74:18 

78:7 86:8 

86:12 88:13 98:2 

105:23 105:24 

memorandum 10:3 

56:12 

memorialize 10:4 

Mendez 17:20 

mentioned 3:24 

11:5 15:24 

20:1 23:2 35:1 

44:25 54:19 

56:11 62:22 

72:22 108:11 

111:16 

merging 4:10 

met 2:17 12:14 

39:3 

meta 82:8 82:13 

83:2 

metabolism 5:6 

32:14 32:16 41:8 

metabolite

42:24 42:25 

metabolites 23:17 

42:18 42:23 43:5 

43:7 43:12 43:13 

53:13 65:11 

103:6 

metamorphosis

82:12 82:14 

method 84:5 

methodological

14:21 

methodologies

41:9 

methods 91:9 

Mexico 32:24 

33:19 

mg/kg 46:11 46:17 

47:9 47:16 

49:4 49:12 83:10 

mg/kg/day 59:16 

60:9 

Michigan 4:15 

microphones 28:22 

mid 51:3 55:16 

59:5 

midst 87:6 96:6 

Midwest 52:23 

mike's 66:6 

milestones

34:24 34:24 

milligrams 46:9 

million 71:2 

71:17 86:21 

mimic 44:8 

mimics 44:1 

mind 22:16 

60:15 64:17 

77:10 102:6 

minimal 8:10 

minimize 71:5 

minimizing 8:25 

minimum 54:1 

94:20 

minute 46:15 

minutes 3:9 

3:18 7:12 23:1 

23:8 24:1 

50:14 50:19 

83:12 

miss 48:19 

missing 99:13 

Mississippi 5:4 

Missouri 69:25 

70:7 70:9 

70:14 70:15 

70:21 71:1 71:14 

misspoke 64:16 

mistake 92:8 

mitigation 51:4 

55:6 

mitigations 9:18 

MOA 53:8 

mode 11:7 11:14 

18:14 18:16 

18:21 19:9 19:13 

21:6 23:9 

33:15 36:23 37:7 

38:21 39:6 

41:8 41:24 42:21 

43:1 43:6 

43:17 43:23 

44:13 44:18 

102:24 103:11 

models 11:22 

40:23 

modulate 45:4 

64:12 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 151

 

modulating 64:11 

monitor 12:10 

monitored 80:19 

monitoring 9:22

10:4 10:6 

13:17 15:16 23:3 

24:4 24:16 24:19 

26:7 26:23 

27:4 33:20 48:21 

49:23 50:20 

51:10 52:8 52:18 

53:7 53:10 53:16 

53:24 54:4 54:10 

55:8 55:11 56:10 

57:9 57:24 58:10 

58:16 58:17 

59:24 60:19 

60:25 61:9 

65:8 79:15 79:15 

79:16 80:4 

80:8 80:11 81:11 

84:1 84:6 88:21 

mono 42:18 

month 7:2 56:25 

87:19 

monthly 97:22 

months 46:7 

46:7 67:18 

70:4 70:5 

83:23 88:10 

89:14 109:19 

morning 2:6 3:3 

3:8 4:6 4:17 

4:22 5:17 6:12 

28:3 28:14 85:18 

86:4 89:1 97:9 

97:10 97:16 98:3 

108:7 110:21 

morning's 27:25 

78:5 113:24 

Morrisette 47:14 

most...

resulting 60:12 

Mother 90:17 

motivate 111:10 

motivated 29:6 

29:7 89:16 

90:7 92:12 93:13 

96:8 

motivation

88:13 105:13 

move 9:2 15:1 

27:16 27:18 

39:24 65:20 66:4 

74:8 85:17 104:9 

104:21 107:11 

108:5 108:17 

movie 68:16 

multiple 22:10 

mutagen 43:19 

mutagenicity

42:14 

Mutual 66:5 66:13 

68:25 

myself 78:4 88:25 

N

nanosilver 114:4 

NAS 16:18 

nation 67:24 

national 4:24 5:8 

6:6 16:23 

65:24 85:24 86:6 

112:17 

Nations 36:17 

nationwide 70:22 

Natural 70:14 

79:1 91:19 92:7 

nature 90:17 98:3 

NCGA 86:8 86:16 

88:20 88:25 

NCGA's 86:12 

NCI 20:15 

NCL 35:5 

necessarily

41:4 105:6 

necessary 31:15 

89:23 

necessity 86:13 

88:4 

needlessly 90:16 

Nelson 66:4 

66:5 66:7 

66:12 69:22 75:1 

network 67:1 

72:23 74:22 

74:23 

neuroendocrine

11:10 11:13 

11:19 11:23 

18:14 18:21 

47:23 

neurons 39:7 45:4 

45:5 

neurotoxicity

23:15 

neurotoxicologist

4:20 

neurotoxicology
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 152

 

5:5 

Nevertheless

48:13 

newspaper 30:8 

next...that's

25:8 

NGOs 29:11 30:23 

nice 99:9 

NIEHS 5:9 112:18 

night 66:16 

NIHS 20:15 

nine 58:21 80:19 

NOEL 49:1 49:2 

49:4 

NOELs 47:3 48:23 

nominations 109:1 

non 36:22 37:9 

72:16 73:21 

non-cancer

16:11 24:23 

24:24 27:1 

85:3 111:7 

112:25 113:8 

non-community

65:4 

none 54:16 

non-monotonic

82:13 

non-profit 79:2 

non-vascular

80:15 

noon 97:6 

normal 68:20 

91:17 

normally 61:17 

North 20:14 

39:2 39:22 

not...been 75:3 

not...I 102:5 

not...is 11:12 

not...it's 22:3 

not...not 38:3 

62:24 

note 41:17 78:4 

96:15 114:10 

noted 23:8 89:19 

notes 114:1 

nothing 30:4 73:6 

notice 94:12 

94:22 95:2 

noticed...I 23:8 

November 2:5 

67:18 

NRDC 30:7 30:10 

80:3 92:9 95:21 

nucleus 48:2 

numerous 95:22 

nutrients 71:5 

81:3 

nutshell 40:14 

53:19 54:15 

O

Obama 77:19 

obesity 84:2 92:4 

objective 19:5 

objectively

105:15 

obligated 42:8 

obligation

69:15 75:13 94:3 

OBT 110:12 112:16 

obviously 41:14 

42:8 

occasions 66:18 

occupational

72:17 85:6 

occur 77:11 77:22 

occurred 77:11 

occurrence 68:4 

October 10:1 10:9

95:3 

odds 42:4 

of...all 74:25 

of...of 7:17 9:13 

11:24 13:19 14:3 

14:10 21:12 38:9 

41:3 41:10 

42:5 51:1 

62:13 65:4 

103:14 

of...what... 

what 99:14 

offer 109:7 

office 4:24 

5:16 5:20 6:6 

6:10 6:14 6:15 

35:4 35:6 82:4 

110:12 

official 2:8 2:14 

31:25 96:20 

109:2 

officials 109:2 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 153

 

Ohanian 6:8 17:23 

Okay 27:22 

65:20 74:7 97:8 

Oklahoma 4:18 

old-style 91:8 

on...on 7:12 

84:19 109:6 

on...work 26:14 

One...at 81:4 

ones 38:15 

53:20 58:3 

85:1 93:10 

one's 84:2 

one-time 81:20 

ongoing 13:10 

112:5 

onset 45:13 45:15 

46:21 

open 2:4 13:6 

62:19 78:17 80:1 

98:1 101:14 

108:15 114:25 

opening 61:23 

111:17 

openly 62:2 

openness 109:12 

opens 111:13 

operable 11:13 

operate 40:9 44:8 

operates 45:21 

operators 92:9 

opinion 30:9 

OPP 22:8 

opportunities

34:16 

opportunity 3:1 

27:10 27:15 28:4 

32:10 35:19 50:4 

63:5 66:8 89:1 

96:25 104:10 

108:4 108:25 

109:3 

options 26:1 

or...or 3:9 

ORD 20:16 44:21 

46:18 110:12 

112:15 

order 28:17 56:18 

57:16 85:10 86:1 

ordered 30:11 

orders 29:17 30:1 

30:12 

ordinary 105:11 

ORD's 6:7 

organic 91:8 

91:12 

organisms 4:11 

organization

36:16 36:17 37:6 

93:22 

organizations

50:17 86:9 95:20 

organizations... 

that's 36:18 

organize 5:22 

organized 107:19 

organophosphate

22:13 

other...other

26:15 38:20 

96:10 

other...

probably 101:1 

others 41:17 

89:19 97:18 

109:15 

our...and...and

103:18 

our...as 13:22 

our...our 18:16 

97:9 111:24 

Ours 67:25 

out... 

epidemiological

24:22 

outcome 9:4 

outcomes 20:18 

103:6 

outdated 49:8 

outline 6:17 

outsi...since

37:25 

outside 38:18 

74:6 

over...between

71:1 

over...over

14:4 105:8 

overall 17:17 

43:17 55:9 55:14 

58:14 59:3 

oversight 93:23 

overview 38:8 

overwhelm
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 154

 

101:18 106:10 

ovulatory 45:11 

oxygen 81:2 

oyster 83:10 

P

Pacino 68:15 

packet 32:7 

pages 28:10 

panel 2:9 2:16 

2:19 2:22 4:1 

4:4 4:14 5:13 

5:19 7:14 9:5 

10:25 11:1 

12:2 14:6 

14:12 15:1 

17:8 21:25 22:15 

26:5 27:6 

27:11 28:1 

32:7 32:10 

50:4 63:3 63:6 

75:15 78:16 

79:11 84:10 88:2 

88:8 97:1 

97:10 97:15 98:1 

98:16 98:17 

98:21 99:7 105:7 

105:11 105:14 

105:22 106:12 

106:21 107:11 

109:3 109:10 

109:23 110:11 

110:17 114:19 

panels 12:17 

87:15 105:9 

106:21 

paper 7:2 14:2 

20:23 34:6 72:8 

paradigm 16:19 

95:18 

parameters 99:9 

99:15 

parent 43:5 43:6 

Park 5:9 46:18 

participate

66:8 68:23 

69:1 69:12 69:16 

76:8 

participated 76:7 

participation

94:3 94:13 

114:23 

participations

106:16 

particular 10:7 

13:15 35:24 

66:19 67:3 68:16 

88:8 94:16 97:19 

98:7 99:24 100:7 

104:17 107:20 

108:13 

particularly 8:11 

16:5 39:16 79:25 

87:6 

parties 28:5 

28:11 86:25 

94:14 

pass 78:1 

past 29:10 

30:25 31:14 33:6 

62:10 62:21 76:9 

87:15 

pathway 24:12 

pathways 16:25 

19:9 21:6 

103:5 103:11 

pause 27:21 45:24 

pay 41:18 

pb 55:1 

peak 48:20 56:8 

57:16 80:24 

81:20 81:21 

peaks 24:17 

56:5 56:9 57:2 

57:7 58:6 61:1 

81:12 81:23 82:2 

83:25 

peer 2:20 6:22 

7:6 7:7 7:8 11:8 

13:7 14:3 

16:16 75:20 

84:12 85:4 

108:17 112:24 

113:12 113:14 

people 3:3 

17:14 18:4 24:12 

35:9 35:17 37:14 

41:14 52:1 62:22 

108:15 109:3 

109:13 

per 46:9 52:11 

53:2 53:17 71:16 

82:2 86:22 

percent 51:21 

56:3 57:13 

59:4 59:4 72:4 

72:5 72:6 

80:20 80:23 

81:12 81:20 91:7 

percentage 53:22 

percentile 60:6 

perception 42:5 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 155

 

performing 22:5 

23:4 

perhaps 41:22 

87:23 

period 27:15 

27:18 52:4 

54:1 71:10 85:21 

86:17 87:12 

94:21 94:23 

96:16 96:23 

97:15 

periods 34:17 

35:8 

permanent 4:4 

78:7 78:15 

97:1 105:11 

105:22 106:21 

perpetrated 89:11 

91:19 

perpetrators

89:11 

person 69:4 

105:10 

personal 29:10 

persons 94:19 

perspective 40:24 

pertains 39:25 

40:25 

pervasive 67:10 

pesticide 2:21 

2:24 5:4 5:16 

20:13 20:16 

22:13 36:18 

101:15 

pesticides 4:11 

4:21 6:7 22:10 

29:20 72:18 

73:10 82:4 86:20 

pests 67:11 

Peter 32:2 

33:17 50:3 

pH 64:22 

Ph.D 17:24 66:9 

phrases 8:1 

physicochemical

41:6 

picture 41:2 

103:2 103:3 

103:3 

Pidgeon 81:7 

piece 30:7 30:9 

30:10 

pike 21:10 78:9 

pituitary 45:8 

placed 3:14 

placing 19:8 

plan 2:13 6:12

7:3 14:10 

20:22 25:12 

111:25 

planned 20:10 

22:20 96:4 101:4 

planning 21:1 

114:15 

plant 7:20 12:4 

12:9 32:16 42:25 

plants 80:16 81:2 

plates 114:13 

play 45:13 105:24 

players 18:3 

plays 45:14 

please 3:6 

60:15 69:18 

74:17 107:11 

please...what

14:2 

pleased 79:11 

84:7 

plotting 46:25 

plow 91:3 

plowing 91:9 

point 3:21 5:13

6:21 18:24 23:10 

27:17 28:3 

29:1 29:13 

30:3 30:22 31:22 

48:6 63:19 73:14 

77:2 78:18 

79:8 85:23 96:22 

97:14 99:11 

113:23 

points 19:19 

25:22 57:11 

63:21 79:10 80:7 

83:3 

poison 21:15 

policies 93:9 

policy 5:21 

69:4 86:6 

political 29:8 

31:10 90:2 

90:3 90:5 92:9 

politically

29:7 90:7 

92:11 96:8 

politicization

89:18 

politics 30:5 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 156

 

30:13 73:24 

89:17 89:23 

pollution 91:16 

Pope 4:17 4:17 

114:5 

population

72:14 90:18 

Portier 4:22 4:23 

65:1 65:2 98:5 

98:6 

position 105:12 

positions 76:10 

76:11 

possible 28:21 

Post 30:10 

post-plant 7:20 

postponed

100:22 100:22 

postulate 39:13 

48:18 

potential 8:4 

8:24 10:11 

11:6 12:11 12:15 

12:18 15:24 

25:25 44:16 

52:12 53:21 57:2 

81:24 83:4 

93:9 111:23 

112:3 

potentially 50:23 

56:8 

pounds 86:21 

ppb 13:8 49:16 

53:12 53:13 

54:18 54:19 

54:21 55:16 

55:18 55:23 

55:24 58:9 

59:2 59:20 80:14 

80:21 80:23 

80:25 81:6 

81:8 81:17 83:24 

practices 8:9 

prearrangement

31:24 

precedent 87:24 

96:9 

precipitously

91:5 

precise 55:8 

precisely 45:21 

precluded 95:5 

predated 44:12 

predecessors

10:24 

predict 80:17 

predissemination

30:21 

prejudged 95:9 

prejudging 87:9 

preliminary 22:23 

23:7 23:19 23:20 

26:19 26:21 

35:15 35:15 

preoptic 45:5 

pre-ovulatory

18:25 

prepare 3:18 86:2 

106:13 

prepared 64:25 

106:2 107:12 

107:21 

preputial 46:20 

presence 49:21 

64:14 

present 2:13 28:6 

28:17 40:10 

presentation

2:2 2:11 4:2 

28:2 31:23 

32:1 32:6 38:7 

49:20 50:8 65:22 

78:14 97:12 

97:21 

presentations

3:13 76:14 76:23 

98:3 114:19 

114:24 

presented 89:21 

107:9 

presenters 96:15 

presenting 40:3 

president 31:8 

66:12 

presidential 90:1 

press 61:23 95:20 

pretty 43:20 65:8 

66:11 106:1 

previous 7:14 

11:4 15:9 71:9 

71:22 76:13 

84:24 

previously

15:21 39:5 79:20 

88:10 

primarily 4:10 

7:21 8:9 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 157

 

primary 4:20 

80:15 111:22 

113:3 

Prince 39:12 

principal 18:3 

33:6 44:9 94:14 

principles 87:1 

93:13 94:4 

prior 35:1 35:14 

priority 74:4 

pro...the 62:4 

probability 59:22 

probably 11:12

11:20 39:3 63:13 

66:15 71:9 

76:3 77:18 

103:19 

problem 67:9 

94:17 

Procedures 94:11 

proceeding 88:8 

proceedings 27:21 

27:23 45:24 

113:24 

process 6:22 

8:1 8:2 16:16 

29:5 29:19 32:21 

34:1 34:15 

48:3 61:14 

62:2 62:7 

62:19 63:2 63:15 

64:6 68:21 69:12 

69:13 71:21 

72:20 73:18 

73:23 75:11 

76:19 76:25 77:1 

88:14 89:16 

89:18 90:24 

91:11 96:1 105:9 

105:25 106:7 

106:12 108:23 

108:24 109:11 

109:16 110:8 

110:9 111:3 

111:17 

processes 38:19 

45:13 

processing

63:15 63:20 

63:20 

producers 66:14 

67:22 74:10 

producing 52:21 

67:23 

product 8:19 9:17 

33:8 33:18 62:20 

67:21 67:23 

70:22 71:2 71:18 

production 7:22 

39:18 80:15 

83:18 83:21 

products 34:4 

43:15 71:12 93:1 

93:8 96:10 

professional 31:2 

professor 4:7 

4:14 4:18 5:3 

profile 38:13 

40:7 57:1 

profiles 33:11 

40:20 57:4 57:17 

program 5:8 6:7 

9:22 10:6 

13:17 20:16 29:4 

52:14 52:25 53:2 

53:6 53:7 

53:10 53:15 

53:24 53:25 54:4 

54:24 55:12 56:7 

56:10 56:21 

56:23 57:3 

57:9 57:16 57:17 

57:24 58:16 

58:17 59:24 79:4 

84:1 84:6 102:3 

programs 5:16 

10:5 51:11 51:19 

52:18 54:2 54:12 

57:8 57:25 

58:2 58:11 58:22 

60:1 86:11 

progress 16:4 

94:2 96:7 

progressively

47:25 

project 17:16 

41:5 

projected 3:2 

promulgated

35:5 35:6 

propaganda 30:7 

30:9 

properly 48:16 

properties 41:6 

41:7 44:5 

proposal 87:5 

95:7 

proposals 25:21 

94:18 94:24 

propose 30:17 

proposed 12:22 

12:24 26:2 29:15 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 158

 

30:4 38:21 

prospective 20:13 

20:18 104:16 

104:22 

prostate 9:10 

12:3 12:6 12:8 

18:15 39:17 

39:19 

protect 19:23 

31:15 

protecting 9:19 

10:8 90:24 

protection 8:6 

11:16 32:1 93:1 

protections 9:20 

protective

34:10 62:17 

protects 91:15 

protocol 13:3 

13:4 

protocols 42:12 

50:22 53:4 

proud 68:1 

provide 3:1 7:6 

20:3 25:21 

42:9 52:6 81:2 

84:12 87:4 96:19 

106:23 108:16 

109:1 109:4 

109:14 110:23 

provided 80:6 

84:17 86:24 

96:18 105:10 

provides 2:20 

2:22 19:14 

104:10 

providing 7:12 

61:17 86:7 94:21 

109:19 

puberty 45:14 

45:15 

public 2:15 3:2 

3:6 3:10 3:12 

3:15 3:19 5:1 

22:16 27:15 

27:18 28:4 

28:6 28:11 28:12 

28:15 31:14 

31:22 34:17 35:8 

35:13 35:17 

35:19 37:21 

41:15 63:4 65:23 

68:7 68:9 

68:10 69:24 

77:17 78:5 

78:6 78:12 78:17 

78:19 78:23 

85:17 85:21 86:6 

87:3 89:4 92:1 

93:24 94:2 94:13 

95:3 95:7 

96:16 96:23 

97:11 108:12 

108:25 109:8 

109:10 114:18 

114:25 115:1 

publication 94:22 

95:2 111:14 

publications

41:18 

publicized 21:21 

publicly 18:10 

31:11 

published 12:21 

13:6 13:10 

16:6 30:7 40:1 

41:16 42:15 

43:22 44:4 47:11 

54:21 82:7 

82:9 83:8 

83:15 83:18 

84:12 84:23 85:4 

99:19 101:14 

112:24 113:8 

113:12 113:14 

published...any

41:16 

pulling 24:24 

pulsatile 45:7 

pulse 45:6 45:14 

purpose 7:4

20:7 20:8 105:18 

putting 24:7 

90:13 

Q

Q1 53:19 

Q3 53:19 

Q4 53:19 

qualitatively

102:19 

quality 30:19 

30:20 51:12 

95:24 102:22 

104:5 

quantitatively

102:19 

quarterly 52:10 

question 43:18 

64:25 88:13 

100:6 101:20 

102:13 103:25 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 159

 

105:13 111:6 

questions 17:3 

27:10 39:25 

49:24 61:19 63:3 

63:4 63:6 

84:16 84:17 

84:25 97:2 97:17 

98:2 98:18 98:20 

100:7 100:10 

101:12 101:21 

106:25 107:1 

108:3 108:21 

109:6 113:21 

quick 11:3 

27:10 63:5 

quickly 43:12 

54:3 57:9 58:12 

quite 21:7 51:5 

55:23 56:5 

59:3 64:4 

75:23 75:24 

77:14 

quote 37:20 72:10 

quotes 37:12 

R

R&D 112:15 

raise 25:7 

raised 39:25 

raises 83:3 

Ralph 47:5

ran 30:9 

range 83:25 

ranges 84:5 

rapid 83:12 

rapporteur 36:6 

37:18 49:3 

rat 46:7 47:2 

rate 8:14 82:19 

rates 99:12 

rather 20:12 40:4 

93:20 

rats 18:13 

47:24 83:15 

83:19 83:22 

rats...caused

83:10 

raw 53:3 53:4 

53:17 54:12 

55:25 63:15 

Ray 92:18 

re..restate 94:4 

reach 9:24 

40:11 55:23 

reached 42:20 

49:12 55:17 

reaching 9:10 

10:8 40:4 

readdress 76:21 

reading 68:5 

ready 5:14 

27:16 27:18 

106:6 

reaffirm 108:22 

real 81:23 93:14 

realize 35:9 

70:23 91:21 

realized 20:19 

really 20:6 22:18 

35:10 62:1 64:14 

76:16 98:19 99:2 

100:7 101:5 

107:18 107:22 

109:22 

really...that

89:10 

reams 72:8 

reanalysis 111:13 

reason 40:11 

94:14 100:21 

reasonable 72:12 

reasonableness

16:21 

reasoned 40:3 

95:11 

reasons 79:13 

94:13 

reassessment

106:9 

reassure 109:9 

110:14 

recall 65:10 

receive 78:7 

106:24 

received 7:2 8:16 

receiving 106:25 

recent 14:19 

21:19 23:13 

26:17 34:13 

37:24 86:17 

87:20 

recently 47:10 

56:6 90:15 94:10 

96:7 

recess 97:7 

recommend 84:21 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 160

 

85:2 

recommendations

2:22 9:9 84:9 

95:14 

reconsider 94:18 

reconsidering

19:17 

reconvene 96:25 

reconvene... 

it's 114:3 

record 27:20 

49:13 51:17 

52:13 54:4 54:17 

58:21 66:9 93:16 

recover 68:11 

RED 18:8 18:9 

19:7 

reduce 63:10 

63:20 

reduced 63:16 

80:16 82:11 

82:16 

reduces 64:6 

reducing 51:5 

59:6 

reduction 8:10 

61:7 83:17 83:20 

reductions 8:14 

reevaluate 2:3 

2:11 4:2 28:2 

97:12 

reevaluation 2:13 

86:18 

reference 46:11 

47:17 60:10 77:7 

references 102:1 

referred 53:8 

referring 56:10 

reflect 47:23

48:4 105:7 

reflects 78:13 

regard 42:7 47:18 

48:8 102:9 

102:12 102:14 

111:6 111:15 

112:22 

regarding 12:14 

94:5 

regards 75:8 

region 45:6 

Register 94:23 

registerability

36:4 

registered 7:18 

28:5 28:10 28:17 

37:13 

registrant 13:3 

13:3 

registrants

10:4 42:8 

registration 7:25 

8:1 10:16 

10:20 33:2 

36:4 62:23 87:22 

88:22 96:4 

regular 20:17 

regulate 45:12 

regulated 31:14 

95:17 95:17 

regulates 39:14 

regulating 45:15 

regulation 31:3 

regulatory 2:23 

7:13 28:19 28:25 

32:21 32:23 34:9 

34:12 34:24 

35:23 36:3 

37:1 37:2 

37:24 38:2 

42:4 42:7 48:3 

62:4 62:15 62:25 

82:2 88:4 

89:18 93:7 93:23 

110:1 110:1 

111:17 111:24 

regulatory... 

regulatory 36:21 

reinforce 104:1 

reins 90:2 

rejoin 97:4 

related 5:10 

21:19 23:5 

24:5 65:12 

relating 44:14 

relations 68:7 

68:9 68:10 

relationships

15:12 103:12 

relative 39:7 

39:18 40:24 42:2 

59:5 66:19 

69:8 69:9 

release 45:7 

46:23 83:11 

111:12 

released 45:9 

relevance 19:15 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 161

 

19:15 

relevancy 20:24 

relevant 11:21 

19:21 24:13 

36:24 79:21 84:3 

84:13 85:9 

87:3 94:16 100:7 

rely 86:14 

remain 61:25 

remaining 86:1 

112:13 

remarkable 63:21 

remarks 100:13 

107:18 111:17 

remember 68:15 

98:11 98:15 

98:16 

remind 114:2 

reopen 93:14 

repeatedly 42:11 

replaced 53:6 

replicate 41:22 

report 3:18 16:24

76:22 80:5 

reported 22:12 

58:21 75:4 76:15 

reporting 21:14 

93:21 

reports 25:6 25:9 

36:13 75:11 

75:23 93:21 

represent 37:21 

70:16 70:25 

representatives

63:7 65:21 

representing

28:15 65:24 66:4 

69:25 74:9 80:23 

81:19 

represents 41:2 

41:5 46:8 

47:21 86:8 92:24 

reproductive

45:16 

request 3:7 

107:10 

requested 3:4 

required 13:3 

requirement 19:23 

requirements 2:16 

26:8 

requires 94:12 

re-registered

9:17 

re-registration

8:2 9:14 10:2 

10:15 34:19 35:1 

re-review 61:24 

resampling 65:14 

research 4:14 5:9 

6:6 6:8 6:14 

12:24 13:10 

33:13 34:2 

36:1 37:8 

38:11 40:16 44:2 

44:20 45:23 

46:18 50:12 

50:13 50:17 

61:18 62:9 

89:6 91:5 113:16 

researched 9:7 

researchers 38:18 

residential 22:14 

65:5 

residues 72:17 

residues...was

36:19 

resistance 84:1 

91:11 

resolution 57:19 

resolved 57:4 

resoundingly

43:20 

resources 29:23 

65:25 70:9 70:11 

70:14 79:1 91:20 

92:7 

respect 100:1 

102:2 102:8 

respond 94:24 

response 15:12 

18:17 19:11 

22:24 23:10 

23:21 25:1 26:22 

27:13 38:19 

38:22 48:12 66:2 

83:12 103:12 

107:2 113:22 

Responses 82:13 

responsibility

67:4 67:4 75:12 

responsible 39:14 

92:4 

rest 20:2 78:22 

114:14 

restrict 92:13 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 162

 

restricted 8:17 

restricting 90:16 

restriction 90:10 

restrictions 69:8

90:8 

result 48:1 56:14 

68:11 68:12 

72:13 

resulting 51:23 

51:23 59:14 60:5 

60:11 

results 13:5 

99:18 

rethink 29:25 

retrospective

22:12 104:15 

104:18 

return 27:22 

90:14 

revealed 81:11 

review 2:20 

6:12 6:22 7:3 

7:6 7:7 8:22 

8:23 10:20 

13:8 14:9 15:9 

15:10 15:20 

16:16 19:4 

19:5 21:19 

23:5 23:19 29:21 

30:6 30:21 

31:4 32:19 32:20 

33:24 34:5 

35:7 35:11 35:17 

35:22 35:23 

36:10 37:19 

37:25 62:5 62:19 

73:16 73:18 

75:13 75:14 

75:19 75:20 77:5 

77:13 77:18 

84:22 84:23 85:3 

87:3 87:14 87:18 

87:20 88:2 

88:9 89:13 89:15 

89:20 90:4 

93:3 93:12 93:19 

94:7 95:6 

95:10 95:12 

95:14 95:21 96:4 

96:6 96:11 

102:22 103:1 

105:18 106:7 

107:9 111:19 

111:21 112:1 

112:1 112:13 

113:5 113:12 

113:14 113:15 

reviewed 29:3 

29:14 31:6 31:13 

37:9 44:6 

84:12 85:5 

93:4 95:22 

112:24 

reviewers 106:10 

reviews 7:8 

7:14 9:5 11:8 

12:13 14:3 

33:8 34:11 35:15 

35:16 36:13 

36:21 37:4 

37:7 37:13 37:15 

61:19 62:11 

84:24 84:25 94:9 

96:2 96:7 105:22 

105:24 107:4 

107:14 108:18 

111:19 

revised 10:1 26:7 

revisions 25:25 

revisit 13:23 

27:3 

revolution 91:4 

right-hand 59:21 

rigorous 62:7 

rising 90:22 

risk 8:10 10:14

11:15 11:24 

12:16 13:25 15:9 

16:17 16:19 

16:20 17:9 17:10 

19:3 19:19 20:21 

22:1 24:3 24:6 

26:2 26:6 

26:12 38:1 

40:8 41:9 

41:13 46:2 49:11 

62:13 73:16 

100:3 100:25 

101:17 102:4 

102:18 103:7 

103:15 104:3 

104:6 110:7 

rivers 91:15 

Riverside 4:8 

Rob 85:23 86:5 

Robert 39:4 

robust 47:23 

104:6 109:2 

rodents 11:12 

11:20 

Rohrer 82:9 

role 12:16 

45:13 45:15 

105:24 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 163

 

roughly 67:19 

99:11 112:8 

routinely 22:8 

rows 97:23 

rule 31:18 110:10 

rulings 94:1 

run 31:25 56:24 

running 67:12 

81:16 92:9 

runoff 8:20 48:19 

58:3 61:1 

run-off 56:24 

rural 65:5 65:8 

65:9 

Russ 39:7 

S

safe 49:16 

50:15 52:8 

54:3 55:4 69:6 

69:8 88:21 

safely 37:20 38:5 

86:23 87:22 

safety 25:22 

33:11 33:18 34:3 

34:13 38:9 38:13 

40:20 40:21 

40:24 41:21 51:1 

59:11 59:18 60:9 

62:9 62:23 77:17 

87:9 

sake 60:7 

sample 52:9 80:20 

80:22 

sampled 58:2 58:3 

65:9 

samples 51:18 

52:10 52:10 53:2 

53:17 54:6 

54:7 54:16 55:20 

56:22 57:12 

57:19 58:5 59:23 

60:20 60:20 

60:21 81:13 

sampling 15:15 

15:17 25:24 26:1 

52:14 52:18 53:1 

53:19 55:1 

57:6 57:11 57:17 

60:23 61:1 81:14 

sanctity 77:4 

SAP 3:7 9:9 11:17 

12:7 12:20 14:18 

15:22 15:23 

18:15 18:19 

21:16 22:16 

22:20 24:21 

25:25 29:18 

30:15 30:15 

30:16 31:4 31:13 

33:22 35:3 39:17 

61:14 61:16 62:5 

66:9 75:7 

75:24 76:4 

76:9 76:12 76:16 

78:6 84:8 

84:21 84:24 85:2 

85:11 88:5 95:13 

102:14 112:9 

114:3 

SAP...it's 75:4 

SAPs 9:3 11:4 

13:12 14:10 

17:18 18:12 20:2 

20:4 29:4 29:6 

29:9 29:15 29:21 

30:4 30:13 30:17 

31:6 33:23 34:19 

39:3 39:16 40:10 

62:21 75:7 79:20 

108:23 

Sass 65:24 66:1 

66:3 74:3 74:5 

74:17 78:18 

78:20 78:25 

85:16 

sat 105:10 

savings 71:17 

saw 62:15 68:14 

say...ask 106:20

scandal 89:12 

91:24 

scant 89:13 

scare...scandal

89:10 

scary 72:1 

scenarios 19:3 

schedule 20:6 

57:11 95:2 

95:8 96:8 110:23 

scheduled 10:19 

14:11 14:13 

15:21 15:23 

65:23 68:20 75:8 

87:17 89:20 

112:9 112:21 

Schlenk 4:5 4:6 

4:7 

Schneider 85:24 

85:25 86:4 

86:6 89:3 

science 3:25 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 164

 

4:4 4:13 5:21 

6:12 7:3 7:14 

9:5 9:15 10:24 

11:1 11:2 12:1 

12:17 13:21 14:6 

14:12 17:11 18:9 

18:16 19:5 

19:6 19:14 19:24 

23:24 25:12 26:4 

28:1 29:7 30:4 

31:17 32:21 34:8 

35:16 36:6 37:15 

37:16 37:18 63:1 

68:23 70:23 73:1 

73:2 73:4 

73:17 73:19 

73:22 73:23 

75:11 75:15 77:5 

77:11 77:14 

77:20 79:17 

79:19 79:23 82:5 

87:2 88:24 89:21 

90:6 91:22 

94:1 105:15 

107:11 108:10 

109:23 110:3 

110:9 110:11 

110:16 110:16 

110:18 112:12 

113:4 

science... 

environmental

35:16 

science...our

14:9 

science-based

93:13 96:1 

Sciences 4:9 4:19 

scientific 2:8 

2:20 7:5 25:6 

25:9 30:14 

33:8 40:11 61:20 

62:2 62:4 

67:14 79:11 

84:10 87:15 88:1 

88:3 90:4 

91:22 92:10 

94:25 97:2 

105:18 107:2 

107:9 109:24 

109:24 114:24 

scientifically

62:6 106:2 

scientist 4:14 

33:15 33:20 79:3 

scientists

20:16 31:5 31:13 

31:16 33:10 

33:25 72:3 95:23 

110:12 

scope 7:8 

Scott 28:18 28:19 

28:23 

scourges 90:17 

screening 29:4 

44:10 

se 82:2 

seas 56:24 

season 48:19 

56:25 108:14 

seasons 57:4 

second 14:4 

22:2 22:8 

22:20 29:6 

30:3 31:22 46:16 

56:7 56:18 

97:9 99:4 

Security 114:10 

sediment... 

sediment 91:16 

seeing 13:9 

66:3 77:23 83:25 

108:2 115:2 

seek 105:18 

seem 40:18 48:8 

77:3 

seems 43:19 

45:3 70:3 

75:20 100:21 

seen 18:22 

56:14 58:8 58:13 

65:17 73:2 76:24 

111:9 

selected 46:16 

Senator 30:11 

send 29:16 

senior 33:13 

38:11 79:3 

sense 14:25 45:14 

88:12 104:8 

104:18 

sensitive 48:8 

49:13 

separation 46:20 

September 14:8 

15:22 16:13 18:1 

24:20 25:13 

25:19 25:21 26:3 

26:25 75:8 99:17 

99:17 103:22 

104:21 106:14 

111:8 112:21 

series 8:8 14:3 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 165

 

14:6 93:15 

serious 43:23 

67:18 67:18 

serve 2:15 57:7 

70:8 74:21 

105:15 

served 39:15 

serving 2:7 

2:19 105:10 

session 97:10 

100:14 100:16 

108:8 108:15 

sessions 108:12 

108:12 

setbacks 8:14 

8:15 51:4 

sets 47:17 

60:24 96:9 

103:20 

setting 46:13 

settings 22:14 

56:16 

seven 31:6 

82:17 82:25 

several 21:19 

66:18 70:13 75:6 

severe 90:7 90:10 

severely 92:12 

sex 82:24 

sexual 46:21 

shape 66:11 88:16 

share 7:1 34:9 

101:18 108:8 

shell 17:13 

she'll 6:20 

She's 74:6 

short 43:11 

46:1 48:24 88:23 

shortly... 

agriculture

66:24 

short-term

47:17 54:20 

59:17 81:12 

81:25 83:6 83:13 

showed 47:13 80:9 

showing 80:21 

shown 41:12 

shows 58:23 

shred 89:21 

signed 18:8 

significance 88:4

significant 58:22 

60:24 61:7 

83:7 94:25 

significantly

65:18 

simazine 66:20 

66:21 67:20 

similar 55:21 

103:13 

similarity 68:4 

Simpkins 39:1 

simple 106:18 

simplicity's 60:7 

simply 47:22 48:4

88:23 101:20 

Simpson 39:11 

single 41:4 48:23 

53:11 59:14 

59:15 59:25 60:4 

83:9 90:20 

single-day 49:1 

site 3:19 30:6 

57:3 72:11 

sites 57:13 

sitting 2:18 

situation 59:22 

61:16 68:6 

101:13 

situations 22:22 

six 34:19 76:4 

82:17 82:24 

87:11 

size 82:11 

Slaughter 28:18 

28:23 28:24 

31:21 

slide 14:2 14:5 

26:9 41:2 50:6 

56:15 58:13 

59:12 97:21 

slides 32:6 63:14 

Slinberg 39:20 

small 45:4 53:22 

snapshot 11:4 

56:14 

So...I'm 83:1 

Society 4:24 

soil 90:11 91:4 

91:8 91:12 

soils 71:6 

solicit 24:21 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 166

 

soliciting

21:24 23:18 

some...for 34:7 

some...some 73:17 

Somebody 69:23 

somehow 48:18 

sorghum 7:21 

74:10 74:21 

sorry 64:16 78:21 

sort 7:8 9:10 

10:4 13:1 

13:20 40:5 97:23 

106:9 

sound 87:2 

91:22 94:1 

sounds 100:2 

source 9:24 

sources 8:12 

15:16 26:24 27:5 

63:17 63:24 

72:17 106:5 

107:6 

South 52:24 

southeast 7:23 

spade 89:12 89:12 

sparked 61:22 

speak 42:17 42:17 

42:22 42:23 

SPEAKER 74:6 

speaking 6:1 

50:13 

special 8:21 8:23 

32:19 35:7 

48:5 77:13 87:20 

96:2 111:18 

111:19 111:21 

112:1 112:1 

112:13 113:5 

species 49:14 

82:10 83:5 

103:13 

specific 42:9 

61:19 63:9 

104:12 

specifically

19:18 21:8 24:15 

25:14 

specify 94:20 

spectrum 7:19 

41:25 104:14 

spend 7:11 98:23 

spending 108:7 

110:21 

spent 10:25 13:12 

sperm 83:17 83:18 

spermatogenesis

82:23 

spike 80:22 83:13 

spikes 81:12 83:6 

83:25 

spikiness 48:17 

Sprague 46:6 

Sprague-Daly 47:2 

47:24 

spread 71:9 

spring 13:13 16:7 

25:5 53:6 

99:19 112:20 

stability 64:21 

staff 3:7 5:20 

29:9 29:24 30:24 

31:13 31:16 

75:19 97:3 97:18 

114:18 114:24 

stage 19:12 19:22 

23:11 23:22 

23:23 111:13 

stages 22:5 

stakeholder 75:6 

stand 88:23 

standard 7:25 

35:6 40:3 

44:23 46:12 

46:15 49:16 

63:22 81:18 

standards 30:20 

30:21 31:2 40:21 

40:25 42:5 

42:7 42:10 48:14 

standpoint 76:3 

start 90:4 95:20 

started 32:14 

35:2 35:7 68:6 

112:6 

starting 23:10 

state 4:18 5:4 

13:20 31:11 34:7 

39:5 51:10 52:16 

52:17 61:9 67:23 

70:15 70:21 72:4 

86:9 86:10 

stated 44:18 

47:16 

statement 31:15 

77:17 

states 24:13 

50:16 51:14 52:7 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 167

 

86:9 92:5 93:2 

statistical 58:23 

statistician 4:15 

statisticians

58:19 

Statistics 4:23 

statute 79:21 

statutory 19:23 

94:3 

stay 53:25 114:14 

stayed 32:20 

steering 67:1 

72:23 

step 104:9 

110:5 110:15 

110:19 112:11 

112:14 113:4 

stepped... 

let's...I'm 74:8 

stereogenic 39:13 

steroid 83:11 

83:20 

Steve 4:12 5:15 

5:17 17:17 

18:6 18:7 20:1 

23:2 24:1 

26:10 27:12 

105:4 107:23 

108:1 

Steve's 107:18 

steward 33:4 33:6 

stewardship

33:3 51:2 

62:10 88:17 

Stoker 46:18 

47:16 49:5 

Stoker's 47:15 

stores 67:8 

straight 77:8 

strategy 42:1 

Straw 68:14

stream 8:15 

streams 56:18 

91:15 

strength 49:14 

strengths 83:2 

105:1 

stress 100:13 

strong 12:22 

17:11 19:14 

19:24 110:9 

stronger 79:23 

strongly 55:3 

61:21 86:12 

89:15 

struck 68:4 

studied 9:8 43:25 

studies 14:14 

14:14 14:19 

14:20 14:24 

14:24 15:5 

15:8 15:9 

15:19 16:4 

16:6 16:10 16:12 

18:4 21:2 

21:18 21:20 22:1 

22:18 22:22 23:5 

23:7 23:12 23:13 

23:15 23:16 

24:22 24:24 25:3 

25:4 25:7 

25:16 25:18 

25:20 26:18 

26:20 27:1 32:15 

32:17 37:5 39:10 

41:11 41:16 

41:21 42:9 42:16 

42:24 43:3 

43:6 43:7 

43:22 44:4 

44:6 44:21 

47:1 48:6 50:9 

57:23 61:9 67:14 

72:7 72:8 82:7 

82:12 82:17 

82:21 82:23 

82:25 83:7 84:13 

84:23 85:5 

85:6 87:17 87:21 

88:7 95:21 95:24 

98:10 98:22 

98:25 99:3 99:18 

100:3 100:11 

101:1 101:2 

101:3 101:10 

101:14 101:21 

103:22 103:23 

104:1 104:5 

104:12 104:15 

104:16 104:16 

104:25 106:10 

111:7 111:10 

112:7 112:10 

112:19 112:23 

112:23 112:25 

113:6 113:8 

113:17 

studies/

laboratory 24:23 

study...and 82:10 

study...I 106:15 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 168

 

studying 46:19 

stuff 26:13 75:13 

subgroups 72:15 

subject 4:1 76:7 

submission 87:8 

submit 74:23

86:25 113:17 

113:18 

submitted 3:12 

28:11 71:22 79:4 

subsequent

40:10 45:23 

49:20 93:10 

subsequently

38:20 

subset 53:21 

substance 76:22 

substantial 57:25 

77:10 77:17 

substantially

38:24 

substantive 76:16 

suffer 91:9 

suffers 91:7 

sugarcane 7:22 

suggest 30:16

87:9 89:16 89:22 

89:24 

suggested 76:17 

suggestion 91:25 

suggestions 92:2 

summarize 40:5

40:14 54:3 

summarized 10:10 

summary 26:9 

60:18 80:6 97:23 

summer 16:7 99:20 

supplemented

52:17 57:13 

57:20 

supplies 51:12 

supply 53:5 55:4 

supplying 52:22 

support 18:9

31:15 86:12 

88:21 

supported 18:19 

48:9 76:12 

supporting

28:12 79:24 

supports 80:10 

suppose 113:16 

supposedly 91:14 

suppression 44:24 

45:17 46:6 46:19 

sure 6:16 75:17 

102:6 106:11 

107:13 110:15 

sure...sure 89:23 

surface 8:6 

8:11 9:1 9:19 

52:6 52:22 53:20 

54:7 54:13 

55:7 55:25 57:22 

65:17 80:1 

80:8 80:12 81:6 

surge 19:1 

surrogate 44:25 

45:18 46:19 57:7 

survey 71:16 

susceptibility

19:12 19:13 

19:22 23:11 

23:24 24:9 

sustainable 90:11 

91:1 

sweep 84:19 85:11 

switching 71:18 

Syngenta 32:1 

32:24 32:25 

33:14 38:12 

38:15 42:8 50:12 

52:19 63:7 65:21 

Syngenta's

33:18 54:10 

system 44:14 

44:17 45:19 

45:22 47:9 47:22 

47:23 51:22 

53:11 53:14 82:3 

90:25 

systematic

35:22 35:23 

systems 10:6 24:4 

51:11 51:14 

51:15 51:20 52:5 

52:7 52:11 52:21 

52:23 52:24 53:9 

53:16 53:20 

53:23 53:25 54:5 

54:11 54:14 

54:24 54:25 55:7 

55:13 55:15 56:1 

58:15 58:20 

58:24 58:25 59:7 

60:12 60:16 

63:23 64:12 65:3 

65:5 65:17 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 169

 

80:1 81:13 81:15 

81:19 81:22 

systems...we

55:20 

T

table 43:23 100:5 

taking 6:21 16:16 

16:23 17:21 

48:13 79:12 82:6 

83:4 102:20 

108:9 

talk 20:2 26:10 

57:9 58:12 

101:11 

talked 65:2 73:19 

talking 60:13 

70:18 70:18 72:6 

75:5 99:10 

Tammy 46:17 

tap 79:16 81:17 

targets 44:9 

77:16 

TCT 49:11 

team 6:20 6:21 

17:13 39:1 

teams 50:12 

technical 35:13 

63:9 94:25 

technically 64:7 

technologies

63:20 

teeth 89:9 

teleconference

27:24 

temporal 24:13 

60:22 

temporality 24:2 

ten 9:16 82:21 

tend 48:11 

term 48:25 

terms 9:19 10:8 

10:10 11:15 

12:10 12:16 

13:19 15:16 

16:11 16:17 

16:18 16:20 

42:10 47:2 59:11 

83:4 103:3 

103:14 106:20 

107:9 108:9 

109:11 

test 29:17 30:1 

tested 80:9 

testes 83:21 

testifying 66:24 

testing 34:3 

testosterone

45:12 46:22 

Texas 39:2 

text 7:2 

thank 3:23 5:12 

5:18 5:20 17:5 

17:7 17:8 27:6 

27:8 31:19 31:20 

32:9 33:22 33:23 

38:10 50:1 

50:4 61:12 

62:5 64:3 

65:21 65:22 66:7 

69:21 69:22 70:2 

74:1 74:2 78:2 

78:20 85:13 

85:15 88:25 89:2 

89:7 92:16 92:17 

92:20 96:12 

96:13 108:6 

110:25 113:20 

114:9 114:16 

114:19 114:22 

thankfully 91:5 

thanking 110:20 

Thanks 114:21 

that...Anna 101:9 

that...April

103:16 

that...at 32:20 

that...that

35:9 37:15 

45:3 50:23 

62:6 72:11 75:22 

that...that... 

that 63:25 

that...the

102:3 103:9 

that...what 59:10 

99:23 

that's 15:10 

15:20 17:21 19:2 

20:14 21:7 

34:5 41:25 

54:5 64:13 64:23 

69:12 72:19 73:3 

73:9 73:17 75:25 

77:5 79:14 79:17 

80:5 82:6 

89:21 93:11 

97:25 102:4 

106:3 110:18 

112:20 113:12 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 170

 

that's...while

97:25 

the...for 46:4 

the...from 94:22 

the...in 51:14 

the...into 74:24 

The...our 50:21

the...the 6:22 

7:3 11:5 12:13 

13:24 17:15 18:8 

19:22 27:11 

46:13 48:17 

48:25 52:16 

76:14 81:23 92:3 

97:15 97:22 

110:17 111:15 

the...to 106:18 

the...turn 38:7 

their...their

99:12 

themselves 4:5 

Therefore 63:18 

there's 3:5 17:13 

34:1 35:18 49:24 

70:24 72:20 73:6 

79:21 82:5 98:22 

101:13 104:14 

108:25 113:25 

There's... 

questions 101:16 

these...out 99:2 

these...these

98:7 

they're 30:5 

30:13 41:23 

65:13 73:8 

91:3 98:25 

101:11 109:6 

113:1 

They're...we

62:17 

They've 67:25 

third 22:11 

29:8 30:22 56:18 

This...there 88:6 

this...this 80:21 

93:18 100:16 

thorough 19:5 

33:7 34:5 

thoroughly 36:7 

58:19 88:7 

thoughtful 95:6 

thoughts 25:23 

78:23 108:16 

thousands 72:7 

throughout 8:7 

34:1 35:18 

46:5 63:1 111:24 

throughout... 

through 15:1 

thyroid 44:1 

tide 90:22 

tight 57:19 

till 67:17 

tillage 91:4 91:7

91:9 

time...this 35:24 

timely 110:24 

Tina 5:25 15:13 

16:15 27:12 

Tina...when... 

when 6:19 

to...as 27:24 

to...if 102:12 

to...I'm 32:12 

to...into 100:14 

to...to 19:15

40:2 45:11 

48:6 63:1 

73:14 89:8 95:14 

103:22 104:1 

109:8 110:13 

to-be 17:24 

today 5:22 5:24 

6:16 10:22 32:10 

33:9 33:21 38:24 

39:9 40:2 

40:14 44:15 

49:11 49:19 

52:15 56:22 

69:25 70:18 

70:19 71:4 

86:5 89:12 

92:2 92:9 93:2 

93:12 103:8 

today's 5:19 5:25 

6:24 7:5 

tolerates 48:25 

tool 38:5 90:20 

90:23 90:24 

91:10 

tools 33:3 90:16 

top 33:10 59:8 

topic 2:10 

75:25 78:12 

97:12 100:4 

108:13 114:4 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 171

 

115:3 

topics 78:9 

total 53:12 

56:1 77:18 80:20 

80:24 

touch 7:13 

12:11 79:9 82:7 

touched 18:7 

ToxCast 102:3 

toxic 18:22 24:5 

toxicant 37:10 

toxicity 4:21

16:25 19:9 

21:6 24:14 

41:8 43:8 

103:4 103:11 

toxicodynamic

24:10 

toxicokinetic

24:10 

toxicological

15:15 15:19 

toxicologist

5:5 33:15 

toxicology 4:18 

5:8 5:10 16:12 

16:24 62:13 

102:2 103:1 

105:2 106:10 

toxics 6:7 

Toyota 114:11 

track 8:3 16:3 

41:16 69:23 

trade 66:14 92:23 

training 4:16 

transparency

16:21 35:10 87:2 

109:12 110:10 

transparent 17:11 

34:15 35:19 

62:19 94:2 

108:15 114:25 

transport 41:7 

travels 45:8 

treated 83:23 

treatment 47:5 

47:12 47:21 49:4 

tree 67:9 

tremendous 76:9 

trend 55:21 58:23 

65:16 

Triangle 5:9 

46:18 

triazine 8:22 

10:13 10:18 

32:19 66:25 

72:18 72:23 

74:22 

triazines 32:22 

53:12 96:2 

tried 100:13 

trip 106:18 

true 37:16 

40:15 73:9 

trust 72:19 

truth 79:22 

try 8:19 16:12 

20:3 21:16 

28:9 41:22 45:20 

50:18 85:21 

102:17 103:10 

trying 92:7 98:19 

98:24 99:1 

tumor 38:22 

tumors 18:13 

38:16 

turf 7:22 

turn 3:21 5:15 

7:15 16:14 

17:3 38:7 

46:22 49:23 

113:24 

turns 44:13 

two-thirds 86:14 

types 21:25 

94:9 104:15 

typically 52:10 

85:20 88:2 

97:1 108:24 

U

U.S 32:24 33:18 

34:15 34:24 

35:22 36:9 53:23 

56:2 72:13 86:14 

86:14 86:20 

86:24 88:22 

ultimately 11:2 

18:21 104:23 

un... 

unsubstantiated

93:20 

unbalanced 30:9 

uncertainty

46:9 102:18 

underlying
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 172

 

38:21 88:7 

underpowered

98:25 

undersized 99:1 

understand 11:6 

38:18 41:22 

45:21 69:2 75:10 

75:15 98:19 

98:24 99:23 

103:13 110:16 

understanding

19:10 34:3 

103:18 110:2 

112:18 

understood 37:8 

undertaken 6:13 

51:2 

undoubtedly 39:23 

Union 36:6 37:17 

unique 101:11 

101:12 101:13 

United 24:12 36:6 

36:17 37:17 

37:21 51:14 52:7 

76:1 92:4 93:2 

universities

50:16 

University 4:8 

4:15 4:19 5:4 

39:2 39:5 39:6 

39:8 39:21 67:15 

70:14 

unjustified 96:11 

unless 17:2 19:24 

30:18 49:24 

unnecessary 29:22 

unparalleled 62:8 

unprecedented

34:7 62:12 73:6 

unsub... 

unsubstantiated

95:19 

unusual 61:16 

76:2 77:2 78:11 

upcoming 7:6 7:17 

78:16 98:7 

update 25:23 78:6 

103:2 103:18 

updated 22:24 

23:19 25:22 42:1 

42:12 

updates 20:17 

updating 49:9 

upon 12:12 18:7 

69:18 

upon...building

20:23 

upperhand 57:10 

urgency 88:12 

89:24 

urgent 89:22 

USDA 7:19 91:6 

user 66:20 70:24 

USGS 57:24 61:9 

80:11 

USGS's 57:24 

utilize 70:22 

utilized 46:1 

71:11 71:11 

utilizing 71:8 

71:17 

V

value 67:25 98:24 

99:22 109:18 

values 60:1 

variety 23:13 

various 18:22 

19:3 20:18 28:11 

28:15 28:16 

29:11 30:22 

34:22 47:1 

vectors 44:9 

version 96:16 

96:17 

vet 21:2 109:2 

Veterinary 4:19 

5:3 

vetted 18:10 

via 18:20 40:25 

video 89:18 

view 55:7 56:8 

78:13 

viewpoint 43:21 

49:12 

views 105:6 109:5 

violate 31:1 

virtual 89:17 

virtually 92:25 

vision 108:9 

vitro 15:8 

22:22 25:19 

26:20 41:24 

84:14 85:6 102:4 

102:21 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 173

 

vivo 15:8 22:22 

25:19 26:20 

41:24 

volume 56:17 59:7 

59:9 

voluntarily 52:19 

voluntary 8:8 

55:11 58:16 

vulnerability

65:6 

vulnerable

13:18 52:21 

54:11 54:25 55:7 

55:15 56:16 

56:17 60:12 

60:16 65:15 

W

W(WHEREUPON 45:24 

waged 29:11 

wait 14:4 50:1 

69:11 

walk 3:7 

warm 67:12 

Warmth 67:17 

warranted 89:23 

warrants 75:14 

was...what 99:23 

Washington

66:17 79:3 

wasn't 15:20 64:3 

100:20 

waste 29:23 30:14 

wat...in 80:1 

watching 92:14 

water 6:10 6:15 

8:6 8:11 8:12 

8:15 8:19 9:1 

9:20 9:22 9:23 

9:24 10:5 

15:16 23:3 

24:4 24:11 

26:7 26:23 

27:4 35:5 35:5 

35:6 41:1 

46:14 48:15 

48:18 49:15 

49:17 49:22 50:6 

50:10 50:15 

50:24 51:7 

51:9 51:10 51:11 

51:12 51:13 

51:19 52:6 

52:6 52:8 52:9 

52:9 52:21 52:22 

52:22 52:23 

52:24 53:3 

53:5 53:16 53:18 

53:20 54:3 

54:5 54:6 54:8 

54:11 54:13 

54:16 54:17 

54:24 55:2 

55:4 55:7 

55:15 55:18 

55:19 55:20 

55:22 55:25 56:3 

56:4 56:13 56:19 

56:19 57:5 57:22 

58:9 58:20 59:17 

59:24 60:2 60:17 

60:20 60:21 

60:21 63:9 63:14 

63:15 63:16 

63:17 63:19 

63:20 64:5 

65:3 65:4 65:4 

65:11 65:17 

67:12 69:8 

71:6 72:16 79:15 

79:15 79:16 

79:25 80:1 

80:4 80:4 80:8 

80:9 80:11 80:12 

81:3 81:6 

81:10 81:13 

81:15 81:17 

81:17 81:19 82:3 

83:24 84:4 

110:12 

waters 9:24 53:4 

watersheds

13:18 56:15 80:8 

80:9 80:13 80:19 

80:23 

waterways 79:25 

Wayne 86:2 92:18 

ways 15:4 21:25 

26:15 

we...we 61:20 

77:1 99:10 

weaknesses 83:2 

wear 69:19 104:13 

web 3:19 30:6 

72:11 106:19 

webcast 27:25 

we'd 33:22 

85:17 101:3 

weed 38:5 67:8 

67:17 86:15 

91:12 

weeds 67:9 

67:12 67:13 71:5 

week 79:5 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 174

 

weekly 53:18 

weeks 82:1 

83:16 95:4 95:5 

week's 87:13 

weigh 88:3 

weight 21:3 24:25 

25:10 27:2 39:20 

44:6 49:15 59:19 

102:17 

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welcome 5:19 

27:25 74:13 97:8 

we'll 3:8 6:11 

6:17 7:9 7:13 

13:23 14:4 

15:7 15:14 

16:9 16:10 16:16 

19:4 19:8 

19:17 23:2 

24:7 25:20 25:21 

27:14 46:14 50:1 

50:13 69:23 

74:17 76:25 77:1 

77:23 85:19 97:5 

101:11 101:21 

103:9 103:17 

103:19 104:21 

104:23 105:2 

107:12 109:15 

111:7 111:8 

114:1 

wells 8:15 65:5 

65:9 65:16 

we're 5:14 

15:18 20:1 20:17 

21:17 22:4 

23:9 26:11 26:13 

26:16 27:18 

28:14 33:21 

40:14 44:15 

60:13 61:17 

62:11 67:23 68:1 

68:19 68:22 

70:18 72:6 73:10 

73:11 73:11 

73:13 73:24 

73:24 75:5 75:17 

79:10 83:25 93:2 

93:18 95:25 96:9 

99:1 99:5 

99:17 99:21 

99:22 102:20 

106:2 106:3 

110:15 110:19 

110:22 112:23 

were...the 84:25 

we're...we 6:25 

were...were 62:24 

were...were... 

have 100:24 

we've 7:14 

14:17 15:25 

20:16 21:12 40:6 

43:3 43:4 43:5 

43:6 43:15 44:19 

45:19 71:22 72:7 

72:20 73:2 

73:2 73:19 76:10 

76:24 76:24 

85:20 90:15 

97:16 109:11 

what...what 63:11 

whatever's 99:18 

whenever 70:5 

73:16 79:5 

whereas 48:11 

WHEREUPON 27:21 

97:7 115:4 

wherever 73:14 

whether 10:7 12:5 

26:7 42:3 

43:25 44:4 

white 14:2 

20:23 34:6 

74:9 74:12 74:14 

74:17 74:18 

74:20 78:3 

whole 41:25 

wholly 63:25 

who's 6:3 17:16 

17:24 39:4 39:15 

who've 29:9 

widely 76:15 

86:19 

widespread 80:11 

wildlife 80:2 

81:2 81:3 

81:24 82:10 83:5 

will...its 84:22 

willing 84:8 

wind 67:12 

window 24:13 

windows 24:9 

wishes 3:5 

wishing 92:10 

witch 91:18 

with...with 39:24 

78:15 

withdraw 29:25 

wondered 68:3 
 THE APPROACH TO REEVALUATE ATRAZINE 11/03/09 CCR#16343-1 175

 

wondering 66:15 

66:17 

96:16 

wrote 44:6

work 12:7 33:24 

33:25 34:23 39:6 

43:17 44:3 44:12 

58:1 62:21 71:15 

71:15 71:19 

76:25 77:1 111:9 

work...the 98:14 

worked 13:1 

29:9 30:25 

72:3 105:16 

workers 9:20 12:9 

99:6 

working 17:14 

18:5 38:17 

39:9 39:12 39:22 

45:20 62:1 

67:2 97:18 

106:20 109:13 

109:15 112:16 

works 18:20 19:10 

28:23 71:2 71:13 

world 33:1 

34:13 35:21 

36:15 36:16 37:6 

37:25 62:25 

90:19 

world's 90:18 

worst 57:7 59:13 

worth 67:22 

71:8 71:17 

82:6 83:3 

would...we 113:2 

wrap 114:1 

written 28:12 

61:14 86:25 

Y

year...late 98:12 

year-long 19:4 

93:19 94:7 95:10 

96:6 

yesterday 66:16 

yet 86:24 94:7 

York 30:8 75:20 

you...if 51:8 

you...when 37:4 

you'll 40:12

45:22 

young 47:24 

48:7 48:11 

yours 114:13 

yours...it 114:12 

you've 107:9 

107:20