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INTRODUCTION

This is the Environmental Protection Agency’s (EPA 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-emergent herbicide registered 

for use to control grasses and broadleaf weeds in a variety of agricultural and non-agricultural 

use sites. Dichlobenil acts by inhibiting cell wall synthesis. 

The Agency is implementing the registration review 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 the FIFRA standard for 

registration. Changes in science, public policy, and pesticide use practices occur over time. The 

registration review program is intended to make sure that, as the ability to assess risk evolves and 

as policies and practices change, all registered pesticides continue to meet the statutory standard. 

The public phase of registration review begins when the initial docket is opened for each case. 

Information on this program is provided on the Agency’s website1. 

The FWP begins with any updates since the PWP was issued. Next is a summary of substantive 

comments received during the public comment period 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 assessments expected to be conducted, 

and the projected registration review timeline. Lastly, there is a discussion of next steps. 

UPDATES SINCE THE 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 the gap for leaching and adsorption/desorption data 

for BAM has been satisfied, the need for leaching 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 water-related organizations, the Agency intends to 

evaluate the potential impacts of dichlobenil uses that are indicated to potentially impact the 

biological processes used by municipal wastewater treatment plants during registration review. 

The results of activated sludge respiration inhibition studies (Guideline 850.3300) are used as a 

 

1

 http://www.epa.gov/oppsrrd1/registration_review/ 
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first step to evaluate the potential impact to wastewater treatment facilities. The Agency has 

added activated sludge respiration inhibition studies to the list of data requirements for 

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

formulation document for dichlobenil was updated to include a discussion of EPA’s plan to 

assess potential wastewater treatment plant exposure and require activated sludge 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/#!docketDetail;D=EPA-HQ-OPP-2012-0395. 

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 Chemtura AgroSolutions (Chemtura), Physicians 

Committee for Responsible Medicine (PCRM), and the following water-related organizations: 

San Francisco Bay Regional Water Quality Control Board (SFBWB), California Stormwater 

Quality Association (CASQA), Bay Area Clean 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 address 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 environmental justice or trade irritants, the Agency did 

receive comments on potential effects of dichlobenil on water resources. 

This section captures neither every comment made on the PWP nor all of the Agency’s 

responses. Summarized below are 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 located 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 Formulation for Registration Review, while those 

relevant to the anticipated human health risk 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 effective plant operations, it is important that EPA 

evaluate the potential impacts of dichlobenil applications on the biological processes used by 

municipal wastewater treatment plants. The dichlobenil registration review process must 

ensure that the maximum allowable application rate will not interfere with wastewater 

treatment operations. 

Response: The Agency intends to evaluate the potential impacts of dichlobenil uses that are 

indicated to potentially impact the biological processes used by municipal wastewater 

treatment plants. The results of activated sludge respiration inhibition studies are used as a 
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first step to evaluate the potential impact to wastewater treatment facilities. Therefore, 

activated sludge respiration inhibition studies on dichlobenil and BAM are required. These 

studies were not identified as potential data requirements in the 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 dichlobenil prepared in the European Union (The 

Netherlands, 2008) identifies activated sludge respiration inhibition and ready 

biodegradability studies 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 satisfy 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 information 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 both dichlobenil and BAM will be required. 

2. Comment submitted by SFBWB, CASQA, BACWA, Tri-TAC, and NACWA: Analytical 

methods should be required that would allow wastewater treatment facilities to examine 

whether a wastewater treatment interference incident may be linked to dichlobenil. It is 

appropriate that EPA is requiring independent laboratory verification of environmental 

chemistry methods (ECMs) for dichlobenil and BAM in mud, fish, and water that will provide 

method detection limits that are 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 laboratory validation for an analytical 

method in water for dichlobenil and BAM. The analytical method should be practicable in 

commercial and government laboratories. However, the Agency does not require that 

pesticide analytes be incorporated into existing multi-residue methods for ease of analysis of 

environmental media. This work is typically 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 could directly result in fish kills, along with impacts to aquatic 

plants. EPA should require that the registrants add “‘Do not use this product in a separate 

storm drain system” to dichlobenil end use product labels. If these statements are not added 

to product labels, EPA should complete a full environmental assessment” 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. 
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4. Comment submitted by SFBWB, CASQA, BACWA, Tri-TAC, and NACWA: The environment 

within a wastewater collection system differs greatly 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 processes 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-life, creating unique reaction products, or 

causing formation of different degradates. EPA should consider these possibilities during 

registration review. 

Response: The Agency considers the guideline environmental fate studies specified by the 

Code of Federal Regulations to adequately inform the degradation processes in wastewater 

collection systems. The increased microbial presence in these systems is expected to result 

in similar to shorter degradation 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 biodegradation products other than 

carbon dioxide may result in unique dichlobenil degradates. However, the potential 

production of unique dichlobenil degradates is not expected to be substantial. Therefore, it is 

not expected that the risks from these potential 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 toxicity 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 invertebrate studies for BZZ. These data are 

necessary for the Down-the-Drain 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 are 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 that 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 limiting 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 assessment 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 operators 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 multi-year registration review process for 

dichlobenil. 
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EPA has already established a wastewater treatment plant notification requirement for 

metam- sodium. EPA should work with registrants 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, including dichlobenil products. 

Response: Upon preliminary review, the available 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 systems, we believe that the Agency should address 

these specific occupational exposures. To this 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 examine potential worker inhalation exposures 

associated with wastewater collection 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 exposures/risks from dichlobenil use in 

wastewater collection systems in response to request for a dermal and inhalation exposure 

study waiver submitted by product registrants in 2003. The assessment included the 

evaluation of handler exposure from the application 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 inhalation) risks of concern. In addition, 

occupational exposures from inhalation of dichlobenil vapor when working in or near 

unventilated spaces were assessed using a high end, vapor saturation model, and no risks of 

concern were identified assuming typical daily occupational exposures. Based upon these 

assessments, which support the decision to waive the previously required dermal and 

inhalation exposure studies, the Agency is not requiring additional exposure studies at this 

time. 

8. Comment submitted by PCRM: OECD Test Guideline 223, Avian 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 review of the OECD validation report to 

determine if the TG223 effects endpoints and dose/response information adequately address 

the purposes of the avian acute oral data requirement 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 scientifically valid, is conducted using the ‘LD50- slope test' 

or 'limit dose test' guidelines (the ‘LD50 - only test' is not adequate for fulfilling data 

requirements), and meets all of the following criteria: 
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• The study is conducted using bobwhite quail (other test species may be acceptable if they 

have low background mortality in the laboratory 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 does 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 'LD50 - 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 LD50, slope and confidence 

limits for TG223 studies). 

• The study meets the same validity requirements as 850.2100 (e.g., a study should be 

invalidated if >10% of the controls die). 

• Control birds are not added during 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 Conducted Using the OECD Test Guideline 223 

is available online at: 

http://www.epa.gov/pesticides/science/efed/policy_guidance/team_authors/terrestrial_biolog

y_tech_team/review_avian_acute_oral_oecd_tg223.htm. 

9. Comment submitted by PCRM: (Q)SAR data should be used in place of the fish 

experimental data for BZZ. The Agency can use the OECD (Q)SAR Toolbox to compare the 

toxicity of both degradates BZZ and BAM to dichlobenil. Because the Agency is only looking 

to determine the relative toxicity of the degradates compared to dichlobenil, QSAR analysis, 

such as that conducted using models within the Toolbox, may prove useful in fulfilling the 

Agency’s information needs. 

Response: EPA considers SAR/QSAR (Structure Activity Relationship/Quantitative SAR) 

predicted estimates to address data requirements on a case-by-case basis. Uncertainty in 

those predicted estimates is considerably higher 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 indicated 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 parent may be made. If BZZ is less toxic than 

dichlobenil to aquatic organisms, this assumption would be overly conservative. If BZZ is 

more toxic than dichlobenil to aquatic organisms, 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 acute threshold or “limit test” approach can 

reduce the number of animals used, and provide an indication of relative toxicity. This 
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approach was first pioneered on the observation that fish are rarely more sensitive than 

algae and daphnia. The fish median lethal concentration (LC50) test is replaced with an 

acute threshold test in which fish testing would be performed at one concentration only (the 

lowest EC50 concentration obtained with previous 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 mortality occurs at test concentrations that are 

20x higher than peak estimated environmental concentrations (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/desorption 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 receiving Noon (2001) for review. If Noon (2001) 

is found to adequately validate MRID 45321801, then no additional validation data will be 

needed for the analysis of dichlobenil and BAM in water. 

PLANNED DATA NEEDS

The table below summarizes the planned data needs for dichlobenil based on the Revised EFED 

Registration Review Problem Formulation for Dichlobenil, dated December 11, 2012; 

Dichlobenil Human Health Assessment Scoping 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 Comments 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 resulted in changes to the data needs. 
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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 BZZ1

 and 

BAM2 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 

water3 

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 Test4 TGAI 24 

850.3300 Activated Sludge Respiration 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 through 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 Review 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 fungicide fluopicolide, 2,6-dichlorobenzamide (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 reviewed 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 harmonized guideline series 850 – Ecological Effects Tests – including 

renumbering and other designations or changes for some guideline studies. See “Final Test Guidelines; OCSPP 850 Series; 

Notice of Availability” 77 FR 38282, June 27, 2012. http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-

0154-0028

5

Data are required for only a microencapsulated formulation. Acceptable data for other required formulation types were 

previously submitted. 
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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 add 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 Document 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 assessment, for all uses of dichlobenil. The Agency has limited 

data on the dichlobenil aquatic degradate 4-chloro-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 organisms than dichlobenil, it will be 

considered explicitly in the ecological risk assessment. 

Additionally, the Agency will require data on the ecotoxicity and environmental fate properties 

of the common metabolite/degradate of dichlobenil 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 dietary, 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 residues resulting from uses of both 

dichlobenil and fluopicolide. Since BZZ is a major dichlobenil degradate in water, the Agency 

will include it in the human health (drinking water) risk assessment for dichlobenil. If 

toxicological endpoints or points of departure are revised based on the 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 review 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 Yes 
11 

Drinking water Yes 

Occupational 

Handlers (mixers, loaders, 

applicators) 

Yes 

Post-application Yes 

Residential 

Handlers Yes 

Post-application No Residential post-application exposure to dichlobenil is 

not anticipated. However, label clarification of 

dichlobenil use in recreational areas is needed. 

Incidental oral No Residential post-application exposure to dichlobenil is 

not anticipated. However, label clarification of 

dichlobenil use in recreational areas is needed. 

Companion animal No Not registered for pet uses. 

Recreational No Residential post-application exposure to dichlobenil is 

not anticipated. However, label clarification of 

dichlobenil use in recreational 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 expression 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 dichlobenil’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 Comment 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. – March 
12 

Registration Review for Dichlobenil – Projected Registration Review Timeline

Registration Review Decision 

60-day Public Comment Period for 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 require several environmental fate, ecological effects, 

and human health studies for dichlobenil through a DCI, expected to be issued in mid- 2013.