UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASH INGTO N, D.C. 20460 OFFIC E OF CHEMICAL SAFETY AND POLLUTION PRE V ENT ION

MEMORANDUM Date: November 7, 2013 SUBJECT: Dichlorprop , 2,4 -DP-p, 2,4

-DP-p, amine salt, Dimethyl amine-2-(2 , 4- dich lorophenoxy) propionate, Isooctyl 2-(2 , 4-dichlorphenoxy)propionate, Propionic acid, 2-(2,4

- dichlorophenoxy)- , 2-ethylhexyl ester, and 2 ,4 -DP-p , 2

- ethylhexy l ester: Tier I Rev iew of Human Incidents PC Code: 03 14 0 I, 03 1402,03 140 3 ,031419 , 031463,03 1464 ,03 1 465 Decision No .: 481240 Petition No.: NA DP Barcode : 0415950 Reg istration No .: NA Regu latory Action: NA Case No.: NA Risk Assess m en t Type: NA TXRNo.: NA CAS No.: 120-36

- 5 , 15165-67

- 0 , 104786-87-0 , 53404-32-3 , 28631

- 35-8 , 79270-78-3 M RID No.: NA 40 CFR: NA Ver.Apr.08 FROM: S hanna Recore , Industrial Hy gienis t 

### A**.** II**~** . • A 

# p- ... /,\
. n Toxico logy and Epidem i o lo gy Branch 

### \...).:t1A.JJJ 'y\
....**t-JJ_ ;(JJ,C/()A~**  Health Effect Di v ision (7509P) and Elizabeth Evans, Environmental Protection Specialist Toxico logy and Ep idemiology Branch Health Effects Division (7509P) 

## Iii

# ;J THROUGH: David Mill er , Acting Branch Chief
.

# -1.**.;~ /** **~~** Toxico logy and Epidemiology Brand( Health Effects Division (7509P) TO: ld eli z Encarn ac ion, Risk Assessor Risk Assessment Branch V Health Effects Division (7509P) and Kaitlin Keller, Chem ical Review Manager Risk Management & Impl ementation Branch 3 Pesticide Re-evaluation Division (7508P)

Page 1 of6Summary and Conclusions Based on the low frequency and severity of incident cases reported for Dichlorprop, 2,4-DP-p, 2,4-DP-p, amine salt, Dimethylamine-2-(2,4-dichlorophenoxy) propionate , Isoocty l 2-(2,4- dichlorphenoxy) propionate, Propionic acid, 2-(2,4-dichlorophenoxy)-, 2-ethylhexyl ester, and 2,4-DP-p, 2-ethylhexyl ester, there does not appear to be a concern at this time that would warrant further investigation. The Agency will continue to monito r the incident information and if a concern is triggered, additional analysis will be included in th e risk assessment. The Agricultural Health Study (AHS) is also a potential source of information associated with human health effects associated with certain pesticides. Dichlorprop, 2,4-DP-p, 2,4-DP-p, amine salt, Dimethylamine-2-(2,4-dichlorophenoxy) propionate, Isooctyl 2-(2,4-dichlorphenoxy) propionate, Propionic acid, 2-(2,4-dichlorophenoxy)-, 2-ethylhexyl ester, and 2 ,4 -DP-p, 2- ethylhexyl ester are not included in the AHS, and therefore this study does not provide information for this report.
Detailed Review 

### I . ACTION REQUESTED Thi s review is intended to fulfill our requirement to docket summaries of incident data that were reported to the Agency, as well as to ensure human incident data and the Agricultural Healt h Study (AHS) are part of the problem formulation phase of registration review. Reports of adverse health effects alle gedly due to a specific pesticide exposure (i.e., an "'incident") are largely self-reported and therefore, generally speaking, neither exposure to a pesticide or repo rted symptom (or the connection between the two) is validated or otherwise confirmed. T ypi cally, causation cannot be dete rmined based on incident data. However, incident information can be an important source of feedback to the Agency: incident s of severe outcome, or a suggested pattern or trend among less severe incidents, can signal the Agency to further investigate a particular chemical or product. Observational epidemiology studies relate the risk of disease, 

### e.g., cancer, and exposure to an agent such as a pesticide product in the general population or specific sub-groups like pesticide applicators. 

### II . BACKGROUND Dichlorprop, 2,4-DP-p, 2,4-DP-p, amine salt, Dimethylamine-2-(2,4-dichlorophenoxy) propionate, Isooct yl2-(2,4-dichlorphenoxy)propionate, Propionic acid, 2-(2,4-dichlorophenoxy)-

, 2-ethylhexyl es ter, and 2,4

- DP-p, 2-ethylhexyl ester are all considered in thi s incident memo. Dichlorprop, Isooc tyl 2 -(2,4-dichlorphenoxy) propionate, and Propionic acid, 2-(2,4- dichlorophenoxy)-, 2-ethylhexyl ester (PC Codes: 031401,031463, 031464) currently have no active registratio ns. These chemicals are herbicides used to control actively growing annual and perennial broad le af weeds, trees, and brush. Their uses include lawns, gol f courses , turf, sod farms , pasture, roadsides, industrial sites, forest lands, and rights of way.

Page 2 of6For this evaluation, both th e OPP Incident Data System (ID S) and the Center s for Disease Control and Prevention/National Institute for Occupational Safety and Health (CDC/NIOSH) Sentinel Event Notification System for Occupational Risk-Pesticides (SENSOR) databases were consulted for pesticide incident data on the active ingredients Dichlorprop, 2,4-DP-p, 2,4-DP-p, amine salt, Dimethylamine-2-(2,4-dichlorophenoxy) propionate , Isooctyl 2-(2,4

- dichlorphenoxy)propionate, Propionic acid, 2-(2,4- dichlorophenoxy)-, 2

- ethylhexyl ester, and 2,4-DP-p, 2-et hylhexyl ester (pc codes: 031401 ,03 1402,031403,03 1419 , 031463 ,03 1464 , 031465). The purpose of the database search is to identify potential pattern s in the frequency and severity of the health effects attributed to exposure from this group of chemicals. These chemicals are not included in the AHS, and therefore this study does not provide informatio n for this report. 

### III. RESULTS/DISCUSSION
a. IDS (Incident Data System) OPP's ID S includes reports of alleged human health incidents from various sources, including mandato ry Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Section 6(a)(2) reports from reg istrants, other federal and state health and environmental agencies, and individual consumers. Since 1992 , OPP has compiled these reports in IDS. IDS contains reports from across the U.S. and most incidents have all relevant product information recorded. Reports submitted to the IDS represent anecdotal reports or allegations only, unless otherwise stated in the report. It should be noted there are three incidents reported as lawsuits to IDS that are not considered in this report. IDS records incidents in one of two modules: Main IDS and Aggregate IDS:
o Main I DS contains incidents resulting in higher severi ty outcomes and provides more detail with regard to case specifics. This system stores incident data for death, major and moderate in cidents, and it includes information about the location, date and nature of the incident. Main IDS incidents involving only one active ingredient (as opposed to pesticide products with multiple active ingredients) are considered to provide more certain information about the potential effects of exposure from the p esticide.

o Aggregate IDS contains incidents resultin g in less severe human incidents (minor, unknown, or no effects outcomes). These are reported by regi strants only as counts in what are aggregate summaries
. For the Main IDS, from J anuary 1, 2008 to June 11, 2013, there were no incidents reported for single chemical only in the database. Ho wever, there were 22 in cidents reported involving more than one chemical. 1 One of these incidents was classified as major severity. This incident was

1 There was also one moderate inc i dent reported that occurred in England. Foreign inc idents a re not r eviewed in detail because of the potential differences in the exposure patterns, use practices, and produ ct formulation.
Page 3 of6determined to be appendicitis and not related to active ingredient (further described 

### in Table 1 )
. T wenty one of th ese incidents were classified as moderate severity. In Aggregate IDS, from January 1, 2008 to June 11, 2013, the re were 122 reported incidents. Overall , there are few incidents involving Dichlorprop, 2,4-DP-p, 2,4-DP-p, amine salt, Dimethylamine-2-(2,4-dichlorophenoxy) propionate, lsooctyl 2

- (2,4-dichlorphenoxy)propionate, Propionic acid , 2-(2,4-dichlorophenoxy)

- , 2

- ethylhexyl ester, and 2,4 -DP -p, 2-ethylhexyl ester reported to IDS
. Table 1. Main IDS Major Incidents for Dichlorprop , 2,4-DP-p, 2,4-DP-p, amine salt, Dimethylamine-2-(2,4-dichlorophenoxy) propionate, Isooctyl 2-(2,4

- dichlorphenoxy)propionate, P
. . "d 2 (2 4 d" hl h ) 2 h 11 1 d 2 4 DP 2 h lh I t

ropwmc act , 

### - , - IC orop enoxy - , -et y 1exy ester, an 

### , 

## - -p, -et y exy es er Chemical: Dichlorprop, 2 ,4 -DP-p , 2,4-DPp, amine salt, Dimethylamine-2-(2,4- dichlorophenoxy) propionate, Isooctyl 2- (2,4- dichlorpheno xy)propionate, Propionic acid, 2-(2,4-dichlorophenoxy)-, 2-etbylhexyl PC Codes: 03 1 40 1, 031402 , 031403,031419 , Human Incident ester, and 2,4-DP-p, 2-ethylbexyl ester 031463 ,0 31464.031 46 5 Incident Exposure Package Incident Reg Severity Report Date Location Number Product Name Codes In cident Description A 68 year old male got some of the product on his hands while applying it. The product was on his hands for only 10 TURF minutes and then it was washed off. The KANSAS 000239- BUILDER patient did not have any rubber gloves or 020813 4/17/20 09 CITY, 02640- WI T H PLUS 2 HB a mask on when he app li ed the product. -00176 MO 000538 WEED Three hours later he experienced waves CONTROL of nausea and stomach cramping. He took some charcoal and vomited once . He had to have his appendix removed and his symptoms were unrelated to the product.



### b
. SENSOR-Pest icides The SENSOR-Pesticides database covers 11 states from 1998-2009, although reporting varies from state to state. Cases of pesticide -r elate d illnesses are ascertained from a variety of sources, including: reports from local Poison Control Centers, state Department of La bor workers' compensation claims when reported by physicians, reports from Sta te Departments of Agriculture, and physician reports to state Departments of Health. Although both occupational and non-occupational incidents are included in the database, SENSOR-Pesticides focuses on occupational pesticide incidents, and is of particular value in providing that informa tion. The state coordinator at each of the 11 respective state Departments of Health conducts case fo ll owup activities such as obtaining medical record s to verify symptoms and severity. Using standardized protocol and case definitions derived from poison center reporting, the state SENSOR-Pesticide coordinator enters the incident information into the s tate-based system which is sent to NIOSH annually to be aggregated. Page 4 of6TX0322 3 TX03203 TX03209 TX032 10 TX03213 TX03219 TX03225 TX01983 Expose d at work , lawn treaded the previo u s day, fumes seeped into t he build ing via th e vent. TX03228 TX03229 TX03230 TX0323 1 T X03232 TX03218



### c. Agricultural Health Study (AHS) The AHS is a high quality , prospective epidemiology study evaluating the link between pe sticide use and various health outcomes inc luding cancer. The AHS includes private and commercial pesticide app licators and th eir spouses. If there are AHS findings re levant to a particul ar pesticide go ing through re gistration review , the Agency will ensure they are considered in the problem formulation!scoping phase of the process and, if appropri ate, full y revi ewed in the risk assessment phase of the process. The AHS includes information on use of 50 d iffe rent pesticide active in gredie nts commonly us ed in agric u lture. D ichlorprop, 2,4-D P- p , 2,4-DP-p , amine salt , Dimethy l amine-2-(2 , 4

- dich lorophenoxy) propionate, Isooctyl 2-(2,4-dichlorphenoxy)propionate , Propionic acid, 2

- (2,4

- dich lorophenoxy)-, 2-ethylhexyl ester, and 2,4-DP-p, 2-ethylhexy l ester are not included in the AHS , an d therefore this s tudy does not provide information for this report.


### IV. CONCLUSION Based on the low frequency and severity of incident cases reported for Dichlorprop, 2,4

- DP-p , 2,4

- DP-p , amine**salt~** Dimethylamine

- 2- (2,4 -dichlorophenoxy) propionate, Isooctyl 2

- (2,4

- dichlorphenoxy)propionate , Propionic ac id , 2

- (2,4-dichlorophenoxy)

- , 2

- ethy lhexyl ester, and 2,4-DP

- p , 2-ethy lhexy l ester in both ID S and SENSO R- Pesticides, there does n ot appear to be a concern at this time that would warrant furth er investigation. The Agency will continue to monitor the incident information and if a concern i s triggered , add iti on al analys is wi ll be included in the risk assessment.

Page 6 of6A query of SENSOR

- Pesticides indentifies 59 cases involving Dichlorprop, 2,4-DP-p; 2,4-DP-p; amine salt, Dimethyl amine-2-(2,4

- dichlorophenoxy) propionate, Isooctyl 2-(2,4-dichlorphenoxy) propionate , Propionic acid, 2-(2,4-dichlorophenoxy)-, 2-ethylhexy l ester, or 2,4

- DP -p , 2

- ethylhexyl ester, s temming from 20 events, and only one sing le AI case. Case symptoms are s ummarize d in T able 2 below.

Tab le 2. SENSOR-Pesticides 1998-2009: Reported Health Effects for 2 , 4-DP Cases (N=59)

Health Effect # of Times Reported D erma l 12 Ocular 19 Resp iratory 40 Gastro intes tinal 26 Renal 0 Nervous System 44 Cardiovascu lar 16 Miscellaneous 2 

### * Cases may report multiple health effects Ofthe 59 cases, one was high in severity, 16 were moderate in severity, and 42 were low in severity
. The high severity case was a suicide attempt. Of the 16 moderate severity cases, 13 cases occurred following one event in Texas in 2000. Thi s event involved a total of 39 cases, 13 moderate severi ty and the remaining 26 were low in severity
. The case description for these 39 cases is as follows, "Expo sed at work, lawn trea ted previous day, fumes seeped in bui lding v i a vent. " The moderate severity cases and event descrip tions are provided in Tab le 3 below.

Table 3. SENSOR-Pesticides 1 998-2009 : Moderate Severity Case Descriptions for 2,4 -DP Cases (N = l6)

Case lD Event ID Narrative Certified applicator, maintenance for schoo l s. No eye or resp. protect ion. Could be Ml00708 MI00630 heat related
. Temp in van over 95. Man using weed & fe ed attachment on his hose when plastic on top of container split, NY00657 NY00454 drenching him. Tried anoth er and had s ame result. WA0\1 76 WA00964 She said spray hit side of her truck/sm e lled spray Page 5 of6