OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

Ju ly 09 , 201 5

PC Code: 109303 MEMORANDUM DP Barcode: 423260

SUBJECT: Aldicarb : Transm ittal of Data Evaluation Record for Environmental Fate Stud y

FROM: Edmund Wong , Environmental Chemist E nvironmental R isk B ranch 2 E nvironmental Fate and Effects Division (7507P)

THRU : Brian Anderson

, Branch Chief Environmental Risk Branch 2 Environmental Fate and Effects Division (7507P)

TO: Susan Bartow

, Chemical Risk Manager Kevin Costello

, Acting Branch Chief Risk Management and Implementation Branch IV Office of Pesticide Programs

This memo randum is to inform you that the analytical method for aldicarb in soil (ECM & ILV) have been reviewed and finalized. S tudy MRID s and classification are listed in Table 1 below

.

Table 1

. DER for Environmental Fate Stud y of Aldicarb

MRID Study Type (OCSPP Guideline) DER Electronic File Name (s) Study Classification

49477402 4947740 3 49513501 E nvironmental Chemistry Method in Soil & Independent Laboratory Validation (850.6100) 098301_49477402_49477403_ 49513501

_ DER

Fate_850.6100_7

- 9

- 15 .doc 098301_49477402_49477403_850.6100_calculations .xls SupplementalAldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 2 of 11 Analytical method for aldi carb in Temik 15G in soil

Reports: ECM: EPA MRID No.: 49477402. DeVellis, S. R. 2014. Temik 15G (Aldicarb) – Validation of the Analyti cal Method for the Determination of a Test Substance in Soil. Smither s Viscient Study No.: 14070.6100. Report prepared by Smithers Viscient, Wa reham, Massachusetts, sponsored by Pyxis Regulatory Consulting, Inc., Gig Harbor, Washington, and submitted by AgLogic, LLC, Chapel Hill, North Carolina; 31 pages. Final report issued September 10, 2014. ILV: EPA MRID No. 49477403. Wu, X. 2014. Independent Laboratory Validation (ILV) of the Analytical Method: Temik 15G (Aldicarb) – Validation of the Analytical Method for the Determination of a Test Substance in Soil. Smithers Viscient Study No.: 14070.6102. Report prepared by Smithers Viscient, Wa reham, Massachusetts, sponsored by Pyxis Regulatory Consulting, Inc., Gig Harbor, Washington, and submitted by AgLogic, LLC, Chapel Hill, North Carolina; 38 pages. Final report issued September 24, 2014. Addendum: EPA MRID No.: 49513501. Wu, X. 2014. Technical Response Letter prepared by Smithers Viscient , Wareham, Massachusetts, sponsored by Pyxis Regulatory Consulting, Inc., Gig Harbor, Washington, and submitted by AgLogic, LLC, Chapel Hill, North Carolina; 6 pages. Dated November 6, 2014. Document No.: MRIDs 49477402, 49477403 & 49513501 Guideline: 850.6100 Statements: ECM: The study was conducted in accordance with USEPA FIFRA and OECD Good Laboratory Practice (GLP) standards (p. 3 of MRID 49477402). Signed and dated No Data C onfidentiality, GLP, and Quality Assurance statements were provide d (pp. 2-4). A statement of the authenticity of the study report was included with the quality assurance statement (p. 4). ILV: The study was conducted in accordance with USEPA FIFRA GLP standards (p. 3 of MRID 49477403). Signed and dated No Data Confidentiality, GLP, and Quality Assurance statements were provided (pp. 2-4). A statement of the authenticity of the study report was included with the quality assurance statement (p. 4). Addendum: The Technical Response Lette r did not include any No Data Confidentiality, GLP, Authenticity, and Quality Assurance statements; however, it was signed by the author (p. 2 of MRID 49513501). Classification: This analytical method is classified as supplemental . However, the study is upgradable when the acceptable performa nce data of soil fortification at the stated LOQ of 11.0 μ g/kg is submitted, along with all the performance data (including chromatograms) of the fortified soil recovery levels in the ECM and ILV, as well as sufficient informa tion to verify that the ECM laboratory was distinct from the ILV. Currently, the ECM cannot be validated with the study’s stated LOQ of 11.0 μ g/kg because the lowest level of soilAldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 3 of 11 fortification in the study is at 100 μ g/kg, which is 10X the LOQ. In the ECM and ILV, no performance data was provided at the LOQ to validate the method. The reviewer reported the L OQ for the method based on the ECM report. Insufficient information wa s provided to verify that the ECM laboratory was distinct from the ILV laboratory. An insufficient number of samples was prepared for all fortification levels in the ECM. In the ECM, no chromatograms were provided for two of the three fortification levels. PC Code: 098301 Reviewer: Edmund Wong Environmental Chemist Date: 07/09/2015

Executive Summary

This analytical method, Smithers Viscient Study No.: 14070.6100, is designed for the quantitative determination of aldicarb in soil at 11 μ g/kg using LC/MS/MS. No performance data was provided in the ECM or ILV to validate th e method at the LOQ, instead the method was validated at 10×LOQ, 100×LOQ, and 700×LOQ (ECM only). Insufficient information was provided to verify that the ECM laboratory was distinct from the ILV laboratory, although the analytical instruments used were different. The reviewer assume d that the method was validated in the first trial by the ILV laboratory.

Table 1. Analytical Method Summary

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

Chemistry

Method Independent Laboratory Validation

Aldicarb 1 49477402 & 49513501 2 49477403 & 49513501 2 Soil 10/09/2014 AgLogic LLC LC/MS/MS 11 μ g/kg 3

1 The test substance was Temik 15G, but the LOQ was established for aldicarb. 2 MRID 49513501 was an addendum to the ECM and ILV. It was a technical response letter written by the ILV study author in response to “comments...received from Susan Bartow, Chemical Review Manager at the EPA, OCSPP, OPP, PRD, regarding the aldicarb validation and ILV studies” (p. 1 of MRID 49513501). 3 Method was not validated at LOQ. See also Reviewer Comment #2.

I. Principle of the Method

The test substance was Temik 15G (14.81% aldicarb; pp. 8-11 of MRID 49477402). The fortification levels were based on the aldicarb active ingredient.

Samples (5.00 g dry weight) of soil were fortified, as necessary, then extracted twice with 0.1% formic acid in acetonitrile (2 x 20.0 mL) by shakin g via orbital shaker table for 30 minutes at 150 rpm (pp. 12-13 of MRID 49477402). Soil and extract were separated by centrifugation (10 minutes at 3000 rpm) and decanting. The volume of the combined extracts was adjusted to 50 mL using 0.1% formic acid in acetonitrile. Sa mples were further diluted (200-5000 dilutionAldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 4 of 11 factor) into calibration range with acetonitrile:purified reagent water (20:80, v:v) prior to analysis.

Samples were analyzed for aldicarb by HPLC/MS/MS (AB Sciex API 5000 mass spectrometer, equipment number: EQP5368) employ ing a XBridge C18, 2.1 mm x 50 mm, 2.5 μ m column and mobile phase of (A) purified re agent water with 0.1% formic ac id and (B) acetonitrile with 0.1% formic acid [percent A:B at 0.10- 0.50 min. 85.0:15.0, 2.50-5.00 min. 5.0:95.0, 5:10-6.50 min. 85.0:15.0) with an AB Sciex Turbo V ESI Ion Spray source (positive ionization mode and multiple reaction monitoring, MRM; p. 14 of MRID 49477402). Injection volume was 100 μ L. Aldicarb was identified using the following ion transition: 213.10 ĺ 89.00 amu. The retention time was ca . 2.9 minutes. The ECM study author noted that similar analysis columns could be used and that the injection volume c ould be changed (decreased only, 100 μ L = maximum).

In the ILV, the method was performed exactly as written in the ECM (pp. 10-15 of MRID 49477403). The extraction procedure and HPLC/M S/MS method were almost identical. However, the analytical instrument used is different (AB Sciex API 5000 mass spectrometer, equipment number: EQP5297). Two not ed differences in the analytic al conditions were that the retention time for aldicarb was ca . 1.8 minutes and that the injection volume was decreased to 50
μ L (p. 14).

In the ECM, the Limit of Quantification (LOQ) and Limit of Detection (LOD) were reported as 11.0 μ g/kg and 1 μ g/kg, respectively (p. 17 of MRID 49477402). In the ILV, the LOQ and LOD were reported as 9.39 μ g/kg and 2 μ g/kg, respectively (See Reviewer Comment #2; p. 18 of MRID 49477403).

II. Recovery Findings

ECM (MRID 49477402): Mean recoveries and relative standard deviations (RSDs) were within guideline requirements (mean 70- 56'IRUDQDO\VLVRI aldicarb in sandy loam soil at fortification levels of 100 μ g/kg (10×LOQ), 1000 μ g/kg (100×LOQ) and 7000 μ g/kg (700×LOQ; Table 1, p. 21). The number of samples was three for all fortification levels. No samples were fortified at the LOQ. Aldicarb wa s dosed as Temik 15G (14.81% as aldicarb); the fortification rate was based on aldicarb ac tive ingredient (pp. 9, 11). The soil was not characterized (Rochester Sandy Loam soil, SMV Lot No. 021814, Sample ID 2014 100 ROCH LOAM); soil moisture was determined prior to testing (11.44%; p. 10).

ILV (MRID 49477403): Mean recoveries and relative standard deviations (RSDs) were within guideline requirements (mean 70- 56'IRUDQDO\VLVRI aldicarb in sandy loam soil at fortification levels of 100 mg/kg (10×LOQ) and 1000 mg/kg (100×LOQ; Table 1, p. 21). No samples were fortified at the LOQ. Aldicarb wa s dosed as Temik 15G (14.81% as aldicarb); the fortification rate was based on aldicarb ac tive ingredient (pp. 9, 11). The soil was not characterized (Rochester Sandy Loam soil, SMV Lot No. 021814, Sample ID 2014 100 ROCH LOAM); soil moisture was determined prior to testing (27.35%; p. 10). The number of trials wasAldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 5 of 11 not specifically reported; however , the reviewer assumed that the method was validated in the first trial (pp. 8, 18).

Table 2. Initial Validation Method Recove ries for Aldicarb in Sandy Loam Soil 1

Analyte Fortification Level ( μ g/kg) Number of Tests Recovery Range (%) Mean Recovery (%) Standard Deviation (%) Relative Standard Deviation (%) Sandy Loam Soil

Aldicarb 2 100 3 75.8-82.4 79.4 3.3 4.2 1000 3 85.3-93.8 88.3 4.8 5.4 7000 3 83.3-91.0 88.0 4.1 4.7 Data (corrected recovery results) were obtained from Table 1, p. 21 of MRID 49477402 and DER Attachment 2 (means, s. d. and RSD). 1 Soil matrix was not characterized; soil moisture was determined prior to testing (11.44%; p. 10 of MRID 49477402). 2 Aldicarb was dosed as Temik 15G (14.81% as aldicarb; p. 9 of MRID 49477402). Ion transition monitored was ĺDPX

. Table 3. Independent Validation Method Recoveries for Aldicarb in Sandy Loam Soil 1

Analyte Fortification Level ( m g/kg) Number of Tests Recovery Range (%) Mean Recovery (%) Standard Deviation (%) Relative Standard Deviation (%)
Sandy Loam Soil

Aldicarb 2 0.100 5 86.5-99.3 94.6 4.84 5.12 1.00 5 111-120 114 3.72 3.27 Data (results) were obtained from Table 1, p. 21 of MRID 499477403. 1 Soil matrix was not characterized; soil moisture was determined prior to testing (27.35%; p. 10 of MRID

49477403). 2 Aldicarb was dosed as Temik 15G (14.81% as aldicarb; p. 9 of MRID 49477403). Ion transition monitored was ĺDPX

.

III. Method Characteristics

In the ECM, the LOQ and LOD were reported as 11.0 μ g/kg and 1 μ g/kg, respectively (p. 17 of MRID 49477402). The LOQ was calculated from the LO Q of the instrument (using the lowest concentration calibration standard ) and the dilution factor of the control samples (pp. 16-17; Appendix 1, p. 29). The LOD was determined by calculating the average noise level in the chromatograms of purified water control solutions and comparing them to the signal of a lowest calibration standard of known concentration. The LOD was calculated as three times the concentration equivalent of the mean noise level of peaks near the retention time of the analyte. In the ILV, the LOQ and LOD were reported as 9.39 μ g/kg and 2 μ g/kg, respectively (p. 18 of MRID 49477403). The LOQ was calculated in the sa me manner as that of the ECM (p. 17). The LOD was established by evaluating the sign al-to-noise (S:N) ratio from samples of known concentration and blank samples (Appendix 1, p. 32).Aldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 6 of 11 Table 4. Method Characteristics Aldicarb (dosed as Temik 15G) 1 Limit of Quantitation (LOQ) 11.0 μ g/kg Limit of Detection (LOD) 1 μ g/kg
Linearity (Least squares calibration curve r and concentration range) 2 Sandy loam

r 2 = 0.99635 (ECM)

r 2 = 0.99902 (ILV) (0.0500-2.0 μ g/L) Repeatable No; n =3 Reproducible Yes for 10×LOQ and 100×LOQ; No samples were dosed at LOQ in the ECM or ILV Specific No 3 Data were obtained from p. 17; Table 1, p. 21; Figure 4, p. 25 of MRID 499477402; and p. 18; Table 1, p. 21; Figure 1, p. 22 of MRID 499477403. 1 Aldicarb was dosed as Temik 15G (14.81% as aldicarb; pp. 9, 11 of MRID 49477402; pp. 9, 11 of MRID

49477403). Fortification rates were based on aldicarb active ingredient. 2 Reviewer-calculated r 2 values for the provided ECM calibration curve was 0.9958; reviewer-calculated r 2 values

for the provided ILV calibration curve was 0.9989 (DER Attachment 2). 3 No chromatograms were provided for the LOQ in the ECM or ILV since no samples were dosed at the LOQ. In

the ECM, chromatograms were only provided for a control sample, one calibration standard and one fortification level (Figures 1-3, pp. 22-24 of MRID 49477402). In the ILV, chromatograms were provided for a control sample, a reagent blank, one calibration standard and both fortification levels (Figures 2-6, pp. 23-27 of MRID 49477403).Aldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 7 of 11 III. Method Deficiencies and Reviewer’s Comments

1. The ECM cannot be validated with the study’s stated LOQ of 11.0 μ g/kg because the lowest level of soil fortification in the study is at 100 μ g/kg, which is 10X the LOQ. The study is upgradable when an acceptable perform ance data of soil fortification at the LOQ of 11.0 μ g/kg is submitted for both ECM and ILV. The reviewer reported the LOQ for the method based on the ECM repor t. The LOQ was reported as 11.0 μ g/kg in the ECM (p. 17 of MRID 49477402). In the ILV, the LOQ was reported as 0.00939 mg/kg in a table of study results; this value confir med the value reported by the ECM (p. 18 of MRID 49477403). However, the LOQ was reporte d as “approximately 0.10 mg/kg” in the Introduction Section (p. 8) of the ILV study report and "appr oximately 0.100 mg/kg" in the last sentence of the Results and Di scussion Section (p. 18). Table 1 of the ILV identified the 0.100 mg/kg samples as LOQ A-E (p. 21). Figure 3 of the ILV reported the 0.100 mg/kg recovery sample with a Sample ID of “LOQ C” (p. 24). In the sponsorapproved Study Protocol of the ILV, the LOQ was also reported as 0.100 ppm (Appendix 1, p. 32). In the ECM, this value (0.100 mg/kg) corresponded to the “Low Concentration” however, the LOQ was never reported as 0.100 mg/kg or 100 μ g/kg in the Tables or the Results section of the ECM (pp. 13, 17-18; Table 1, p. 21; Appendix 1, p. 29 of MRID 49477402).

2. The levels of LOD and LOQ cannot be veri fied and validated due to the lack of performance data. In the ECM and ILV, no performance data was provided for the LOQ to validate the method. A validation sample set should consist of, at a minimum, a reagent blank, two unspiked matrix control samples, five matr ix control samples spike at the LOQ, and five matrix control samples sp iked at 10×LOQ for each analyte and matrix. Samples were only prepared at 10×LOQ, 100×LOQ and 700×LOQ (ECM only; Table 1, p. 21 of MRID 49477402; Table 1, p. 21 of MRID 49477403).

3. The laboratory which performed the ECM, Smithers Viscient, was the same laboratory which performed the ILV (p. 1 of MRID 49477402; p. 1 of MRID 49477403). OCSPP guidelines state “If the laboratory that condu cted the validation belonged to the same organization as the originating laboratory, the analysts, study director, equipment, instruments, and supplies of the two laboratories must have been distinct and operated separately and without collusion. The analysts and study director of the ILV must have been unfamiliar with the method both in its development and subsequent use in field studies.” Based on the information reported in the ECM, ILV and Addendum MRIDs (MRIDs 49477402, 49477403 and 49513501), the reviewer concluded that insufficient information was provided to verify that th e ECM laboratory was distinct from the ILV laboratory.Aldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 8 of 11 Regarding analysts and study director: In the lists of Key Study Personnel for the ECM and ILV, the study directors were different (p. 5 of MRID 49477402; p. 5 of MRID 49477403). In addition, the ECM listed two anal ysts (chemists) while the ILV listed no analysts. However, the Technical Report Write r and Director of Chemistry were identical between the ECM and ILV. OCSPP guidelines specify "the personnel conducting the independent validation should not report to the same study director who was involved in developing the original method or who may have used the method to develop data for laboratory field studies to support pesticid e registration or reregistration actions."

Regarding equipment, instruments and supplie s: In Section 2.0 Materials and Methods of the ECM and ILV, the test and reference s ubstances, reagents, laboratory equipment and analytical instruments were identical, although not always listed in the identical order (pp. 8-10, 14 of MRID 49477402; pp. 9-10, 14-15 of MRID 49477403). In EPA MRID No. 49513501 which was a Technical Response Letter prepared by Smithers Viscient (written by the ILV study author) in respons e to comments from Susan Bartow, Chemical Review Manager at the EPA, the ILV study author “confirmed” that the analytical instruments were “totally different systems, each with its own HPLC and MS/MS detector” (p. 2 of MRID 49513501). The ILV study author reported that the Sciex 5000 system (Smithers Viscient EQP No. 5368 ) was used for the ECM while the Sciex W5000 system (Smithers Viscient EQP No. 5297 ) was used for the ILV. The reviewer could not validate the identity of the Scie x W-5000 system from the AB Sciex website ( www.absciex.com ). In the Technical Response Letter, the Equipment Lists of the ECM and ILV were also provided. The reviewer obser ved the following issues with these lists (pp. 4, 6 of MRID 49513501):

1) The ECM system was entitled “ SPS Equipment Number: EQP5368”, not

“ SMV Equipment Number: EQP5368” or “ Smithers Viscient EQP No. 5368”. The ILV system was entitled “ SMV Equipment Number: EQP5297”, as expected.

2) The Manufacturer/Model/Part Number of the Mass Spectrometer of the ILV was reported as “AB Sciex/ API 5000”. The designation “ Sciex W-5000” was not indicated anywhere on the ILV equipment lis t. However, the reviewer noted that the Serial Numbers differed for the Mass Spectrometers of the ECM and ILV.

3) The Serial Numbers of the MDS Scie x APPI Sources were identical in the ECM and ILV, “EQP 5273”.

4) The Software of the ECM was reported as “Analyst 1.4.2 ” in the equipment list, but was reported as “Analyst 1.6 ” in the ECM MRID No. 49477402 (p. 10 of MRID 49477402). “Analyst 1.6” was the Software used in the ILV.

5) The ILV study author reported on p. 2 of the Technical Response Letter that the information detailing that supplies a nd equipment used in the studies was “also included in the ILV report on pa ges 69 and 70” (p. 2 of MRID 49513501). However, the ILV MRID contained only 38 pages.Aldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 9 of 11 The communication between the ECM and ILV was also questioned by Susan Bartow, Chemical Review Manager at the EPA. The ILV report stated that “communications occurred with the Sponsor Monitor” and that the communications would be included with the raw data; however, no communications we re included in the ILV (p. 16 of MRID 49477403; p. 1 of MRID 49513501). The ILV report stated that communication included protocol and method clarifica tion, acquisition of the test ma terials and test matrix, and pre-validation evaluation a nd method establishment (p. 16 of MRID 49477403). In the Technical Response Letter, the ILV study aut hor “confirmed that th ere were no project related communications between the study personnel who performed the ILV and the sponsor monitor...[or]...the study personnel who performed method development/validation” (p. 1 of MRID 49513501). Furthermore, the ILV study author explained that communicati ons were not included in the ILV report because no communications occurred.

Overall, the reviewer determined that the information provided in EPA MRID No. 49513501 (a Technical Response Letter prepared b y Smithers Viscient, written by the ILV study author) did not provide valid, c onclusive responses to comments from Susan Bartow, Chemical Review Manager at the EP A, since the instrument lists and summary of communication in the Technical Response Letter contained in consistencies with information provided in the or iginal ECM and ILV reports.

4. In the ECM, only three samples were prepared at each fortification level (10×LOQ, 100×LOQ and 700×LOQ; Table 1, p. 21 of MRID 49477402). The OCSPP guidelines specify that five matrix control samples are prepared at each fortification level.

5. In the ECM, chromatograms were only pr ovided for a control sample, one calibration standard and one fortific ation level (Figures 1- 3, pp. 22-24 of MRID 49477402). Chromatograms were not provided for the 100 μ g/kg or 7000 μ g/kg fortification levels. A reagent blank was not included. In the ECM and ILV, no chromatograms were provided for samples dosed at the LOQ since th ey were not included in the studies.

6. In the Study Protocol, the directed test c oncentrations for the ILV were “approximately 0.1, 1 and 7 mg (a.i.)/kg” (Appendix 1, p. 29 of MRID 49477403). The omission of the 7 mg/kg test concentration was not included in the Protocol De viations section of the ILV (p. 19).

7. The soil matrix was the same in the EC M and ILV (p. 10 of MRID 49477402; p. 10 of MRID 49477403). The Lot No. and Sample ID was the same, but the soil moisture content differed between the two studies.

8. It was reported for the ILV that one set of ni neteen samples (10 for tified and 2 unfortified samples, 1 reagent blank and 6 solvent standards) required 8 hours (one working day) to complete the preparation and extraction (p. 16 of MRID 49477403). Subsequent LC/MS analysis was performed overnight.Aldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 10 of 11 V. References

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

40 CFR Part 136. Appendix B. Definition and Pr ocedure for the Determination of the Method Detection Limit-Revision 1.11, pp. 317-319.Aldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 11 of 11 Attachment 1: Chemical Names and Structures

Aldicarb

IUPAC Name: (EZ)-2-Methyl-2-(methy lthio)propionaldehyde O -methylcarbamoyloxime CAS Name: 2-Methyl-2-(methylthio)propanal O -[(methylamino)carbonyl]oxine CAS Number: 116-06-3 SMILES String: O=C(O\N=C\C(SC)(C)C)NC

Structure not availableAldicarb (PC 098301) MRIDs 49477402 (ECM)/ 49477403 (ILV)/ 49513501 (Addendum)

Page 12 of 11 Test Material: Aldicarb

MRID: 49477402

Title: Temik 15G (Aldicarb) – Validation of the Analytical Method for the Determination of a Test Substance in Soil

MRID: 49477403

Title: Independent Laboratory Validation (ILV) of the Analytical Method: Temik 15G (Aldicarb) – Validation of the Analytical Method for the Determination of a Test Substance in Soil

EPA PC Code: 098301

OCSPP Guideline: 850.6100

For CDM Smith

Primary Reviewer: Lisa Muto Signature:

Date: 2/9/15

Secondary Reviewer: Lynne Binari Signature:

Date: 2/9/15

QC/QA Manager: Joan Gaidos Signature:

Date: 2/9/15