2 INTRODUCTION

This is the Environmental Protection Agency’s (E PA or the Agency) Final Work Plan (FWP) for the registration review of dichlobenil. This work plan addresses public comments received concerning the Preliminary Work Plan (PWP), which was posted in the dichlobenil registration review docket (EPA-HQ-OPP-2012-0395) . Dichlobenil is a pre-emer gent herbicide registered for use to control grasses and broadleaf weeds in a variety of agricu ltural and non-agricultural use sites. Dichlobenil acts by inhibiting cell wall synthesis.

The Agency is implementing the registration revi ew program pursuant to Section 3(g) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and will review each registered pesticide every 15 years to determine whether it continues to meet th e FIFRA standard for registration. Changes in scienc e, public policy, and pesticide us e practices occur over time. The registration review program is intended to make su re that, as the ability to assess risk evolves and as policies and practices change, al l registered pesticides continue to meet the statutory standard. The public phase of registration review begins wh en the initial docket is opened for each case. Information on this program is provided on the Agency’s website 1

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The FWP begins with any updates since the PWP wa s issued. Next is a summary of substantive comments received during the public comment peri od for the PWP concerning anticipated data needs, expected risk assessments, or the estimated timeline identified in the PWP, and a summary of the Agency’s responses to those comments. This section is followed by dichlobenil’s registration review planned data needs, risk assessm ents expected to be conducted, and the projected registration review timeline. Lastly, there is a discussion of next steps.

UPDATES SINCE TH E PWP WAS ISSUED

The Agency has completed its review of several environmental fate studies submitted for dichlobenil and its degradate, 2,6-dichlorobenzamide (BAM). EPA’s classification of these

studies is shown in the table below. While th e gap for leaching and adsorption/desorption data for BAM has been satisfied, the need for leach ing and adsorption/desorption data for BZZ has not been fulfilled, and thus, EPA will include this study in the registration review Data Call-in (DCI). In addition, EPA will include an aerobic aquatic metabolism study with BAM in the DCI as the submitted study was unacceptable.

GLN Test Compound MRID Study Type Study

Classification

835.4300 BAM 45539401 Aerobic aquatic metabolism Unacceptable

835.1230 BAM 45539402 Leaching and adsorption/desorption Acceptable

As a result of the comments received from wate r-related organizations, the Agency intends to evaluate the potential impacts of dichlobenil uses that are indicated to potentially impact the biological processes used by munici pal wastewater treatment plants during registration review. The results of activated sludge respiration inhibition studies (G uideline 850.3300) are used as a

1 http://www.epa.gov/oppsrrd1/registration_review/3 first step to evaluate the poten tial impact to wastewater trea tment facilities. The Agency has added activated sludge respirati on inhibition studies to the li st of data requirements for

dichlobenil and its metabolit e 2,6-dichlorobenzamide (BAM). The ecological problem

formulation document for dichl obenil was updated to include a discussion of EPA’s plan to assess potential wastewat er treatment plant exposure and re quire activated sl udge respiration

inhibition studies for dichlobenil and BAM. See the Revised EFED Registration Review Problem Formulation for Dichlobenil , completed 2012, available in the dichlobenil registration review docket ((EPA-HQ-OPP-2012-0395), at http://www.regulations.gov/#!doc ketDetail;D=EPA -HQ-OPP-2012-0395

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SUMMARY OF COMMENTS AND AGENCY RESPONSES

During the 60-day public comment period on the Dichlobenil Preliminary Work Plan, which opened on July 6, 2012 and closed on September 10, 2012, the Agency received 12 public comments. Comments were submitted by Chemtu ra AgroSolutions (Chemtura), Physicians Committee for Responsible Medicine (PCRM), a nd the following water-related organizations: San Francisco Bay Regional Water Quality Control Board (SFBWB), California Stormwater Quality Association (CASQA), Bay Area Clea n Water Agencies (BACWA), Tri-TAC, and National Association of Clean Water Agencies (NACWA ). The comments do not address the timeline described in the PWP, but they do addres s the planned ecological and human health risk assessments and data requirements. In the PWP, EPA also solicited comments on the specific topics of environmental justice, water quality concerns , and trade irritants. While no comments or information were received concerning environmen tal justice or trade irri tants, the Agency did receive comments on potential effect s of dichlobenil on water resources.

This section captures neither every comment made on the PWP nor all of the Agency’s responses. Summarized below ar e public comments that resulted in changes to the anticipated registration review data needs, risk assessments, or timeline, or are of a broader regulatory nature. Public comments and EPA responses in their entirety are locat ed in the docket, EPAHQ-OPP- EPA-HQ-OPP-2012-0395. Summarized public comments and Agency responses related to the anticipated ecological risk assessment or data needs are in the Dichlobenil: Response to Comments on the Problem Fo rmulation for Registration Review, while those relevant to the anticipated human health ri sk assessment or data needs are in the Dichlobenil: Response to Comments on the Human Health Scoping Document.

1. Comment submitted by SFBWB, CASQA, BACWA, Tri-TAC, and NACWA: Effective wastewater treatment plant operations are essential for compliance with the National Pollutant Discharge Elimination System (NPDES ) permits issued by wastewater treatment facilities under EPA mandates. To ensure effect ive plant operations, it is important that EPA evaluate the potential impacts of dichlobenil appl ications on the biologic al processes used by municipal wastewater treatment plants. The dichlobenil registration review process must ensure that the maximum allowable applicati on rate will not interfere with wastewater treatment operations

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Response: The Agency intends to evaluate the pote ntial impacts of dichl obenil uses that are indicated to potentially impact the biologica l processes used by m unicipal wastewater treatment plants. The results of activated sludge respiration in hibition studies are used as a4 first step to evaluate the poten tial impact to wastewater tr eatment facilities. Therefore, activated sludge respiration inhibition studies on dichloben il and BAM are required. These

studies were not identified as potential data requirements in th e original problem formulation or PWP for dichlobenil, but have been added to the list of data requirements in order to

address concerns described in comments submitted during the public comment period accompanying the registration review docket opening.

The Draft Assessment Report (DAR) for dichlobe nil prepared in the European Union (The Netherlands, 2008) identifies activated sludge respiration inhibition and ready biodegradability studie s on dichlobenil (Mead, 2002) and a ready biodegradability study on BAM (Van der Laan-Straathof and Philips-Van Loo, 1996) that may provide useful information. The Agency requests submission of these studies for review. If Mead (2002) is acceptable upon review, then these data may sati sfy the need for activated sludge respiration

inhibition data for dichlobenil. An activated sludge respiration inhibition study for BAM will likely still be required, because this informa tion regarding BAM is not identified as a component of Mead (2002). If Mead (2002) is unacceptable upon review, then activated sludge respiration inhibition studies for bot h dichlobenil and BAM will be required.

2. Comment submitted by SFBWB, CASQA, BACWA, Tri-TAC, and NACWA : Analytical methods should be required that would allo w wastewater treatment facilities to examine whether a wastewater treatment interference incident may be linked to dichlobenil

. It is appropriate that EPA is requiri ng independent laboratory veri fication of environmental chemistry methods (ECMs) for dichlobenil and BAM in mud, fish, and water that will provide

method detection limits that ar e environmentally relevant. EPA should also require ECMs for BZZ with appropriate method detection limits, and ensure that the methods are practicable in commercial and government laboratories.

Response: The Agency is requesting independent la boratory validation for an analytical

method in water for dichlobenil and BAM. Th e analytical method should be practicable in commercial and government laboratories. Ho wever, the Agency does not require that pesticide analytes be incorporated into existi ng multi-residue methods for ease of analysis of environmental media. This work is typi cally performed by laboratories that analyze monitoring samples, as indicated in the comment.

3. Comment submitted by SFBWB, CASQA, BACWA, Tri-TAC, and NACWA : There is a potential for dichlobenil to be used in storm sewers, drain lines, and drains, which usually flow directly to creeks, rivers, estuaries, or the ocean without any treatment. Use of

dichlobenil in storm drains coul d directly result in fish kills, along with impacts to aquatic plants. EPA should require that the registrants add “‘Do not us e this product in a separate storm drain system” to dichlobenil end use prod uct labels. If these statements are not added to product labels, EPA should complete a full environmental assessmen t” for this use.

Response: For dichlobenil products labeled for use in storm drains, the Agency will assess exposure to aquatic organisms from this use as part of the planned comprehensive ecological risk assessment for dichlobenil during registration review. If needed, EPA will design appropriate mitigation measures and labeling at that time.5 4. Comment submitted by SFBWB, CASQA, BACWA, Tri-TAC, and NACWA: The environment within a wastewater collection system differs gr eatly from the outdoor environment. There is little to no light, it is often cooler in summer and warmer in winter than temperatures above ground, and the air may contain more ammonia, nitrogen and sulfur-based compounds, carbon dioxide and/or methane resulting from bacteriological proce sses that already have begun to break down sewage within the lines. All of these conditions and others may affect the fate of dichlobenil, perhaps modifying its half-l ife, creating unique reaction products, or causing formation of different degradates. EPA should consider these possibilities during registration review.

Response: The Agency considers the guideline envi ronmental fate studies specified by the Code of Federal Regulations to adequately inform the degrad ation processes in wastewater collection systems. The increased microbial pres ence in these systems is expected to result in similar to shorter degradati on half-lives than in soils or surface waters, such that typical environmental fate studies would be protective. The absence of light can be assessed with available data. Lastly, the increased presence of airborne biodegrada tion products other than carbon dioxide may result in unique dichloben il degradates. However, the potential production of unique dichlobenil degradates is not e xpected to be substantial. Therefore, it is not expected that the risks from these potenti al degradates will need to be quantified.

5. Comment submitted by SFBWB, CASQA, BACWA, Tri-TAC, and NACWA: Commenters support the EPA’s plan to require acute toxici ty data for freshwater fish and aquatic plants for the degradate BZZ. In addition, EPA should require acute invertebrate, chronic fish and invertebrate, and estuarine/marine fish and in vertebrate studies for BZZ. These data are necessary for the Down-the-Dra in assessment to evaluate the potential environmental risks from BZZ, which may occur in wastewater effluent.”

Response: Environmental fate and ecotoxicity studies on BZZ are needed because its

behavior and effects in the environment ar e not well understood. However, the number of

studies to be included in the DCI is limited because the compound is not known to be more toxic than dichlobenil. EPA will require th at studies be conducted on the most acutely sensitive freshwater aquatic animal and the most sensitive aquatic plant to dichlobenil, which should provide an adequate screen while limitin g the resource burden for registrants. The

risk assessment will assume that the relative toxicity of BZZ compared to dichlobenil observed in the most sensitive species is similar across other aquatic organisms. Any uncertainty introduced into the risk assessm ent from this assumption will depend on the results of the forthcoming data and will be addressed in the risk assessment.

6. Comment submitted by SFBWB, CASQA, BACWA : To manage risk in the near term, EPA should require root control applicators to provide advance notification to wastewater treatment facility ope rators of any planned chemical root control application in the wastewater collection system. The growing use of chemical root control products and the available scientific evidence justify EPA' s immediate implementation of advance notification, prior to completion of this mu lti-year registration review process for
dichlobenil.6 EPA has already established a wastewater tr eatment plant notificat ion requirement for metam- sodium. EPA should work with regist rants to immediately implement labeling requirements for 24-hour advance notification to wastewater treatment plant operators before the application of not only metam-sodium products, but also all other chemical root control products, includi ng dichlobenil products.

Response: Upon preliminary review, the availabl e dichlobenil data [Yeung and Criddle (2007)] indicate that its use will not impede wastewater treatment processes. During registration review, the Agency will fully evaluate data relevant to the potential for

wastewater treatment interference and identify any appropriate mitigation measures, including notifications to wastewater treatment facilities, at that time.

7. Comment submitted by NACWA and BACWA : Given that the primary use for dichlobenil is for root control in wastewater collection system s, we believe that the Agency should address these specific occupational exposures. To th is end, we request that the Agency remove its waiver to the registrant for inhalation studies in confined or enclosed spaces, and instead, modify this requirement to specifically exa mine potential worker inhalation exposures
associated with wastewater co llection system applications. Further, we request that EPA also require dermal, oral, olfactory and eye sensitization studies and applicator exposure measurements that are designed to identify whether current worker safety measures are sufficient to provide appropriate protection for wastewater collection system workers.

Response: The Agency assessed occupational expos ures/risks from dichlobenil use in wastewater collection systems in response to request for a dermal and inhalation exposure study waiver submitted by product registrant s in 2003. The assessment included the evaluation of handler exposure from the applicat ion of dichlobenil sewer treatment products loaded by a foam generator and poured into the sewer line. None of the exposure scenarios assessed resulted in combined (dermal and in halation) risks of c oncern. In addition, occupational exposures from inhalation of di chlobenil vapor when working in or near unventilated spaces were assessed using a high end, vapor saturation model, and no risks of

concern were identified assu ming typical daily occupationa l exposures. Based upon these assessments, which support the decision to wa ive the previously required dermal and inhalation exposure studies, the Agency is not requiring additional expos ure studies at this

time.

8. Comment submitted by PCRM: OECD Test Guideline 223, Avi an Acute Oral Toxicity Test, should be used as the protocol instead of EPA Guideline 850.2100 in the interest of reducing the numbers of animals used by up to 61%.”

Response: The Agency recently completed its revi ew of the OECD va lidation report to determine if the TG223 effects endpoints and dos e/response information adequately address the purposes of the avian acute oral data requi rement as described in 40 CFR Part 158 and 40 CFR Part 161. The Agency determined that a study conducted using TG223 may be classified as 'acceptable' if it is scient ifically valid, is conducted using the ‘LD 50 - slope test' or 'limit dose test' guidelines (the ‘LD 50 - only test' is not adequate for fulfilling data requirements), and meets all of the following criteria:7 • The study is conducted using bobwhite quail (other test species may be acceptable if they have low background mortality in the laborator y and do not regurgitate during the study). The background mortality data for the species in question should be available from the submitting laboratory at the time of the Agency review.

• The chemical being tested doe s not cause delayed effects.

• For a 'limit dose test', it is conducted at 2,000 mg a.i./kg-bw or the environmentally relevant concentration (whichever is greater).

• For the 'LD 50 - slope test', the raw data and results are submitted electronically using the SEquential DEsign Calculator (SEDEC) (the Excel calculator that determines the placement of doses during testing and is used to estimate the LD 50 , slope and confidence limits for TG223 studies).

• The study meets the same va lidity requirements as 850.2100 (e.g., a study should be
invalidated if >10% of the controls die).

• Control birds are not added dur ing the course of the study.

Studies that deviate from the above criteria may be classified as 'acceptable' or 'supplemental' if they are considered adequate for use in risk assessment or 'invalid' if they are not scientifically sound; however, any TG223 study that deviates from the above criteria will need additional evaluation by the Agency to confirm the study’s classification. The Agency’s Guidance for Classifying Studies Co nducted Using the OECD Test Guideline 223

is available online at: http://www.epa.gov/pesticides/science/efed/pol icy_guidance/team_authors/terrestrial_biolog y_tech_team/review_avian_ acute_oral_oecd_tg223.htm

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9. Comment submitted by PCRM: (Q)SAR data should be used in place of the fish experimental data for BZZ. The Agency can us e the OECD (Q)SAR Toolbox to compare the toxicity of both degradates BZZ and BAM to dich lobenil. Because the Agency is only looking
to determine the relative toxic ity of the degradates compared to dichlobenil, QSAR analysis, such as that conducted using models within th e Toolbox, may prove useful in fulfilling the Agency’s information needs.

Response: EPA considers SAR/QSAR (Structure Ac tivity Relationship/Quantitative SAR) predicted estimates to address data requirements on a case-by- case basis. Uncertainty in those predicted estimates is considerably hi gher than in measured experimental data. Although QSAR estimates may be considered in a weight-of-evidence analysis, experimental data are generally required when risks cannot be confidently dismissed based solely on the QSAR estimates. ECOSAR results for BZZ i ndicated that BZZ may be equally or more toxic to aquatic organisms than dichlobenil. Therefore, risk could not be dismissed based on these QSAR estimates and experimental data is required. In the absence of data, an assumption of equal toxicity of BZZ to the pare nt may be made. If BZZ is less toxic than dichlobenil to aquatic organisms, this assump tion would be overly conservative. If BZZ is more toxic than dichlobenil to aquatic orga nisms, this assumption would result in an assessment that may not be protective of aquatic organisms.

10. Comment submitted by PCRM: If the Agency continues to request the Acute Fish Toxicity Study for the degradate BZZ then following an ac ute threshold or “limit test” approach can reduce the number of animals used, and provid e an indication of relative toxicity. This8 approach was first pioneered on the observation that fish are rarely more sensitive than algae and daphnia. The fish median lethal concentr ation (LC50) test is replaced with an acute threshold test in which fish testing woul d be performed at one c oncentration only (the lowest EC50 concentration obtained with pr evious algae and daphnia testing). A version of this approach has been adopted by the OECD as a guidance document.

Response: Limit tests may be acceptable if no mortalit y occurs at test con centrations that are 20x higher than peak estimated environmental con centrations (EECs). A factor of 20 is used because the endangered species LOC is 0.05, which represents a value that is 20-fold lower

than the LC50.

11. Comment submitted by Chemtura: Since adsorption/desorption coefficients are only relevant to assess the mobility of substances found in or on soil, similar studies for an artificial aqueous photolysis product (BZZ) are not required.

Response : Adsorption/desorption coefficients are also relevant to assess the mobility of chemicals and their distribution in water, as well as for comparative and modeling purposes. Therefore, a leaching and adsorption/d esorption study, Guideline GLN 835.1230, for BZZ are required for understanding its distribution in water and for exposure modeling.

12. Comment submitted by Chemtura: The problem formulations states that the analytical method in MRID 44712701 (Carter 1998) and 45321801 (Carter 2000) can be upgraded if validation by an ILV is made available. MRID 44712701 was refined and updated by MRID 45321801, which was then independently validated by Noon (2001). Chemtura will provide this independent laboratory validation study.

Response: The Agency looks forward to receivin g Noon (2001) for review. If Noon (2001) is found to adequately validate MRID 45321801, th en no additional validation data will be needed for the analysis of di chlobenil and BAM in water.

PLANNED DATA NEEDS

The table below summarizes the planned da ta needs for dichlobenil based on the Revised EFED Registration Review Problem Formulation for Dichlobenil , dated December 11, 2012; Dichlobenil Human Health Assessment Scopi ng Document in Support of Registration Review

, dated May 16, 2012; Dichlobenil: Response to Comments on the Problem Formulation for Registration Review; and the Dichlobenil: Response to Comme nts on the Human Health Scoping

Document . The table has been updated since the PWP to reflect public comments and the completed review of submitted data, which re sulted in changes to the data needs.9 Planned Data Needs for Dichlobenil’s Registration Review

Guideline

Number Study Title Test Material Estimated

Timeframe

(Months from receipt of DCI)

835.1230 Leaching and Adsorption/Desorption BZZ 1 and

BAM 2 12

835.4100 Aerobic Soil Metabolism TGAI 24
835.4300 Aerobic Aquatic Metabolism BAM 24

850.6100 Environmental Chemistry Methods and Associated Independent Laboratory Validation for soil and

water 3 TGAI; BAM 12

850.1075 Fish Acute Toxicity Test (Freshwater) BZZ 12

850.1350 Mysid Chronic Toxicity Test TGAI 12 850.1400 Fish Early Life-Stage Toxicity Test (Freshwater) TGAI 12 850.2100 Avian Acute Oral Toxicity Test (Passerine) TGAI 12

850.2300 Avian Reproduction Test 4 TGAI 24

850.3300 Activated Sludge Respirati on Inhibition TGAI; BAM 12
850.4150 Terrestrial Plant Toxicity (Vegetative Vigor) 5 TEP 12 850.4400 Aquatic Plant Growth BZZ 12

860.1340 Independent Laboratory Validation for the Analytical Method for enforcement of tolerances (ruminant commodities) TGAI; BAM 12

870.7800 Immunotoxicity TGAI 12

Special Study Evaluation of Olfactory Toxicity TGAI; BAM 24

The study listed below was previously required th rough a generic data call-in (GDCI-027401-16334), issued in March 1987, and is still outstanding. This study is listed in this document as background; it

will NOT be included in the anticipated Registration Revi ew data call-in (DCI) as it is already required through the earlier DCI.

860.1520 Processing Study for Grape TEP; BAM Past Due

1 A dichlobenil aquatic degradate 4- chloro-2(3H) benzoxazolone (BZZ).

2 The common metabolite/degradate of dichlobenil and the fung icide fluopicolide, 2,6-dichlor obenzamide (BAM). Acceptable leashing and adsorption/desorption data have been submitted for BAM. Therefore, this guideline requirement for BAM will be included in the DCI for data compensation purposes only.

3 An acceptable method (MRID 45321801) has been received and revi ewed by the Agency. However, an independent laboratory validation of the method is required before this requirement can be considered satisfied.

4 On June 27, 2012, EPA announced certain revisions in harmoni zed guideline series 850 – Ecological Effects Tests – including renumbering and other designations or ch anges for some guideline studies. See “F inal Test Guidelines; OCSPP 850 Series; Notice of Availability” 77 FR 38282, June 27, 2012. http://www.regulations.gov/#!doc umentDetail;D=EPA-HQ-OPPT-2009-

0154-0028

5 Data are required for only a microencapsu lated formulation. Acceptabl e data for other required formulation types were previously submitted.10 RISK ASSESSMENTS FOR REGISTRATION REVIEW

The most recent comprehensive human health risk assessment for dichlobenil was completed in 2008 for an amendment to registration to a dd new uses. The most recent ecological and environmental fate risk assessment was completed in 2008 for the same purpose. Findings and

conclusions from these risk assessments are summarized in the Revised EFED Registration Review Problem Formulation for Dichlobenil , dated December 11, 2012 and Dichlobenil. Human Health Assessment Scoping Docu ment in Support of Registration Review , dated May 16,

2012.

During registration review, the Agency will conduct a comprehensive ecological risk assessment, including an endangered species a ssessment, for all uses of dichl obenil. The Agency has limited data on the dichlobenil aquatic degradate 4-chlo ro-2(3H) benzoxazolone (BZZ) and will require ecotoxicity and environmental fate studies to determine the toxicity of BZZ to aquatic organisms. If BZZ is found to have equal or greater toxicity to these organism s than dichlobenil, it will be considered explicitly in the ecolo gical risk assessment.

Additionally, the Agency will require data on the ecotoxicity and environmental fate properties of the common metabolite/degradate of dichl obenil and the fungicide fluopicolide, 2,6- dichlorobenzamide (BAM). These data will be used in assessing BAM in the anticipated ecological risk assessment.

For human health, EPA will conduct revised di etary, residential, and occupational risk assessments during registration review. BAM will be assessed separately due to the difference in toxicity profile with respect to dichlobenil and to consider resi dues resulting from uses of both dichlobenil and fluopicolide. Sin ce BZZ is a major dichlobenil de gradate in water, the Agency
will include it in the human heal th (drinking water) risk assessment for dichlobenil. If toxicological endpoints or points of departure are revised based on th e data that will be required for registration review, they will be considered in the new assessments, as well as any changes to the standard operating procedures or default exposure assumptions.

The table below summarizes the registration re view risk assessments based on the Revised

EFED Problem Formulation and HED Scoping Document.

Risk Assessments for Dichlobenil’s Registration Review

Type of Risk Assessment Include? Notes

Ecological and Environmental Fate Comprehensive ecological (species to be assessed include terrestrial and aquatic organisms), including endangered species Yes

Human Health Dietary

Food Yes11 Drinking water Yes

Occupational Handlers (mixers, loaders, applicators) Yes

Post-application Yes

Residential

Handlers Yes
Post-application No Residential post-ap plication exposure to dichlobenil is not anticipated. However, label clarification of

dichlobenil use in recrea tional areas is needed. Incidental oral No Residential post-ap plication exposure to dichlobenil is not anticipated. However, label clarification of

dichlobenil use in recrea tional areas is needed. Companion animal No Not registered for pet uses. Recreational No Residential post-app lication exposure to dichlobenil is not anticipated. However, label clarification of

dichlobenil use in recrea tional areas is needed.

Other Aggregate Yes Evaluates the combined risk from dietary and residential exposures.

Cumulative No EPA has not assumed that dichlobenil or BAM have a common mechanism of toxicity with other substances and a cumulative assessment is not planned at this

time. Tolerances Yes The tolerance expr ession for dichlobenil will be

modified to ensure that it appropriately covers the metabolites and degradates of dichlobenil and that it specifies the residues to be measured for each commodity.

TIMELINE

EPA has created the following estimated timeline for the completion of di chlobenil’s registration review. The projected timeline has not changed since the PWP.

Registration Review for Dichlobenil – Projected Registration Review Timeline

Activities Estimated Date Opening the Docket Open Docket and Public Co mment Period 2012 – June

Close Public Comment 2012 – August Case Development

Final Work Plan 2012 – November Issue DCI 2013 – July – Sept. Data Submission 2015 – July – Sept. 30-day Public Comment Period for Draft Risk Assessments 2017 – Jan. – March12 Registration Review for Dichlobenil – Projected Registration Review Timeline
Registration Review Decision 60-day Public Comment Period fo r Proposed Registration Review

Decision 2017 – July – Sept.

Registration Review Decision and Begin Post-Decision Follow-up 2018 Total (years) 6

NEXT STEPS

As noted previously, the Agency plans to requir e several environmental fa te, ecological effects, and human health studies for dichlobenil through a DCI, expected to be issued in mid- 2013.