1
United
States
Prevention,
Pesticides
April
2003
Environmental
Protection
and
Toxic
Substances
Agency
(
7508C)
Publication
No.
738­
F­
03­
001
4­
CPA
TRED
Facts
EPA
has
assessed
the
risks
associated
with
the
use
of
4­
Chlorophenoxyacetic
Acid
(
4­
CPA),
and
completed
a
Report
of
the
Food
Quality
Protection
Act
(
FQPA)
Tolerance
Reassessment
Progress
and
Risk
Management
Decision
(
known
as
a
TRED)
for
this
pesticide.
As
a
result
of
the
TRED,
the
Agency
has
determined
that
the
risks
posed
by
the
used
of
4­
CPA
fits
into
its
own
"
risk
cup,"
meaning
its
risks
are
within
acceptable
levels.

The
Federal
Food,
Drug
and
Cosmetic
Act
(
FFDCA),
as
amended
by
FQPA,
requires
EPA
to
review
all
the
tolerances
(
legal
limits
for
residues
in
food)
for
registered
chemicals
in
effect
on
or
before
the
date
of
the
enactment
of
the
FQPA.
Tolerances
are
considered
reassessed
once
the
safety
finding
has
been
made
or
a
revocation
occurs.
EPA
completed
a
4­
CPA
Reregistration
Eligibility
Decision
(
RED)
prior
to
FQPA
of
1996
enactment;
therefore,
tolerances
needed
to
be
reassessed
to
meet
the
FQPA
standard.

In
reviewing
these
tolerances,
the
Agency
must
consider,
among
other
things,
aggregate
risks
from
non­
occupational
sources
of
pesticide
exposure,
whether
there
is
increased
susceptibility
to
infants
and
children,
and
the
cumulative
effects
of
pesticides
with
a
common
mechanism
of
toxicity.
However,
for
4­
CPA,
the
only
potential
exposure
anticipated
is
via
ingestion
of
food.
There
is
no
exposure
expected
through
consumption
of
drinking
water
given
the
enclosed
nature
of
the
chemical's
use,
and
there
are
no
registered
residential
uses.
So
aggregating
exposures
from
the
food,
drinking
water,
and
residential
pathways
of
exposure
is
not
necessary.

The
Agency
has
evaluated
the
dietary
risk
associated
with
4­
CPA
and
has
determined
that
there
is
a
reasonable
certainty
that
no
harm
to
any
population
subgroup
will
result
from
exposure
to
residues
of
4­
CPA.
Therefore,
no
mitigation
measures
are
needed
and
the
tolerance
established
for
residues
of
4­
CPA
in/
on
the
raw
agricultural
commodity
is
now
considered
reassessed
as
safe
under
§
408(
q)
of
the
FFDCA.

Use
Summary
°
4­
CPA
is
an
herbicide
used
specifically
as
a
plant
growth
regulator
to
restrict
root
growth
during
seed
germination
of
mung
beans.

°
4­
CPA
is
applied
to
a
water
bath
to
soak
the
beans.
After
the
beans
have
soaked
for
several
hours,
they
are
washed
to
remove
the
surface
residues,
and
are
then
germinated
indoors
for
2
several
days.
After
sprouting,
the
hulls
and
roots
are
discarded,
and
the
remaining
portion
is
canned
and
sold
for
human
consumption.

°
Approximately
20
lbs
of
4­
CPA
active
ingredient
(
a.
i.)
is
used
annually.

Health
Effects
°
The
Agency
is
not
concerned
with
any
carcinogenic
potential
of
4­
CPA.

Dietary
(
food
and
drinking
water)
Risks
°
No
effects
were
identified
for
acute
dietary
exposure.
Therefore,
due
to
the
limited
use
and
use
patterns
of
4­
CPA,
the
Agency
concluded
that
chronic
dietary
exposure
was
the
only
exposure
scenario
to
consider.

°
The
chronic
dietary
risk
for
the
most
highly
exposed
population
subgroup,
children
1
to
6
years,
is
negligible
(
less
than
0.2%
of
the
chronic
Population
Adjusted
Dose
or
cPAD)
and
therefore,
not
of
concern
to
the
Agency.

°
There
is
no
exposure
expected
through
consumption
of
drinking
water
due
to
its
limited
indoor
use.

Occupational
and
Ecological
Risks
°
Occupational
and
ecological
risk
management
decisions
were
made
as
part
of
the
1995
RED.
No
new
data
pertaining
to
these
types
of
exposures
has
been
received.

°
The
Agency
has
determined
that
given
the
limited
usage
of
this
chemical
in
total
annual
pounds
used
and
geographic
area
used,
there
are
unlikely
to
be
risks
to
endangered
species
associated
with
the
use
of
4­
CPA.

Label
Amendments/
Risk
Mitigation
°
In
completing
this
TRED,
the
Agency
did
not
identify
any
label
amendments
which
should
be
implemented.

Tolerance
Reassessment
Decisions
°
The
existing
mung
bean
tolerance
for
4­
CPA
has
been
reassessed.
It
will
be
lowered
from
2.0
ppm
to
0.2
ppm.
One
other
tolerance,
for
tomatoes,
will
be
revoked
because
4­
CPA
use
on
tomatoes
is
no
longer
supported
or
on
the
current
label.
3
Next
Steps
°
A
Notice
of
Availability
of
the
4­
CPA
TRED
and
other
supporting
documents,
including
risk
assessments
and
the
comments
on
the
preliminary
risk
assessment
will
be
published
in
the
Federal
Register.
A
copy
of
the
TRED
and
all
supporting
documents
will
also
be
available
through
the
Agency's
electronic
public
docket
and
comment
system,
EPA
Dockets,
and
in
the
OPP
public
docket
for
viewing.
You
may
access
EPA
dockets
at
www.
epa.
gov/
edocket/.
The
4­
CPA
docket
ID
number
is
OPP­
2003­
0124.
