1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
May12,
2004
Memorandum
SUBJECT:
Review
of
"
Dissipation
of
Transferable
Residues
of
Benefin
and
Trifluralin
on
Turf
Treated
with
a
Formulation
of
the
Pesticides"

FROM:
Shanna
Recore,
Industrial
Hygienist
Reregistration
Branch
II
Health
Effects
Division
(
7509C)

THRU:
Al
Nielsen,
Branch
Senior
Scientist
Reregistration
Branch
II
Health
Effects
Division
(
7509C)

TO:
John
Pates,
Chemical
Review
Manager
Reregistration
Branch
Special
Review
and
Reregistration
Division
(
7508W)

DP
Barcode:
D300239
PC
Code:
036101
EPA
MRID
No.:
457456­
01
Attached
is
a
review
of
the
trifluralin
turf
transferable
residue
data
submitted
by
Dow
AgroSciences
LLC.
This
review
was
completed
by
Versar,
Inc.
on
April
9,
2004,
under
supervision
of
HED.
It
has
undergone
secondary
review
in
HED
and
has
been
revised
to
reflect
Agency
policies.
2
Executive
Summary
The
data
collected,
reflecting
the
turf
tranferable
residues,
meet
most
of
the
criteria
specified
by
the
U.
S.
Environmental
Protection
Agency's
(
US­
EPA)
OPPTS
Series
875,
Occupational
and
Residential
Exposure
Test
Guidelines,
Group
B:
Post
Application
Summary
This
study
was
designed
to
characterize
dissipation
of
benefin
and
trifluralin
transferable
turf
residues
when
applied
to
turf
at
three
test
sites
in
California,
Indiana,
and
Mississippi.
Team
2G,
formulated
as
a
granular
containing
1.33%
benefin
and
0.67%
trifluralin
was
applied
one
time
to
separate
plots
at
each
site
using
ground
application
equipment.
Each
application
was
made
at
the
maximum
target
application
rate
of
2.0
lbs
benefin/
1.0
lb
trifluralin
per
acre).
Transferable
turf
residues
(
TTR)
were
collected
using
the
modified
California
Roller
Technique.
The
application
method,
rate,
and
frequency
(
number
and
timing)
were
relevant
to
the
use
pattern
proposed
by
the
product
label.
Three
samples
from
each
treated
plot
were
collected
at
each
location
immediately
after
each
application
and
then
at
1,
2,
4,
and
7
days
after
the
application.
At
all
three
sites
(
CA,
IN,
and
MS),
the
raw
TTR
values
did
not
require
correction
for
field
fortification
recoveries,
as
the
overall
average
percent
recovery
was
>
90%.
At
the
California
site,
the
maximum
average
TTR
values
for
benefin
and
trifluralin
occurred
immediately
after
the
application
of
the
test
substance
(
0.0026

g/
cm2
and
0.00138

g/
cm2,
respectively).
After
day
0,
no
residues
were
detectable.
At
the
Indiana
site,
the
maximum
average
TTR
values
for
benefin
and
trifluralin
occurred
immediately
after
the
application
of
the
test
substance
(
0.0021

g/
cm2
and
0.0011

g/
cm2,
respectively).
After
day
0,
no
residues
were
detectable.
At
the
Mississippi
site,
the
maximum
average
TTR
values
for
benefin
and
trifluralin
occurred
immediately
after
the
application
of
the
test
substance
(
0.0012

g/
cm2
and
0.00077

g/
cm2,
respectively).
After
day
0,
no
residues
were
detectable.

Conclusion
The
study
completed
in
support
of
the
regulatory
requirements
contained
the
following
omissions
and
flaws
with
respect
to
OPPTS
Series
875
Test
Guidelines.
The
most
important
discrepancies
and
issues
of
concern
was
that:

°
separate
control
plots
were
not
established
at
each
site.

This
study
met
most
of
the
Series
875.2100
Guidelines
and
the
results
will
be
used
by
HED
in
the
trifluralin
Tolerance
Reassessment
Eligibility
Decision
Document.
3
Reviewer:
Bill
Smith
Date
April
9,
2004
STUDY
TYPE:
Determination
of
Transferable
Turf
Residue
Dissipation
from
Turf
Treated
with
Team
2G
TEST
MATERIAL:
Team
2G
is
formulated
as
a
granular
containing
1.33%
benefin
and
0.67%
trifluralin
as
the
active
ingredients.

SYNONYMS:
Benefin:
benfluralin,
B
Butyl­
N­
Ethyl­
2,6­
Dinitro­
4­(
Trofluoromethyl)
Benzenamine
Trifluralin:
Benzenamine,
2,6­
Dinitro­
N,
N­
Dipropyl­
4­(
Trofluoromethyl)­

CITATION:
Authors:
E.
M.
Bargar
Title:
Dissipation
of
Transferable
Residues
of
Benefin
and
Trifluralin
on
Turf
Treated
with
a
Formulation
of
the
Pesticides
Report
Date:
July
26,
2002
(
amended
study
date)
Analytical
Laboratory:
Global
Environmental
Chemistry
Laboratory
 
Indianapolis
Lab
Dow
AgroSciences
LLC
9330
Zionsville
Road
Indianapolis,
Indiana
46268­
1054
Identifying
Codes:
MRID
457456­
01;
Laboratory
Study
ID
RES97075
SPONSOR:
Dow
AgroSciences
LLC
EXECUTIVE
SUMMARY:

This
study
was
designed
to
characterize
dissipation
of
benefin
and
trifluralin
transferable
turf
residues
when
applied
to
turf
at
three
test
sites
in
California,
Indiana,
and
Mississippi.
Team
2G,
formulated
as
a
granular
containing
1.33%
benefin
and
0.67%
trifluralin
was
applied
one
time
to
separate
plots
at
each
site
using
ground
application
equipment.
Each
application
was
made
at
the
maximum
target
application
rate
of
2.0
lbs
benefin/
1.0
lb
trifluralin
per
acre).
Transferable
turf
residues
(
TTR)
were
collected
using
the
modified
California
Roller
Technique.
The
application
method,
rate,
and
frequency
(
number
and
timing)
were
relevant
to
the
use
pattern
proposed
by
the
product
label.
Three
samples
from
each
treated
plot
were
collected
at
each
location
immediately
after
each
application
and
then
at
1,
2,
4,
and
7
days
after
the
application.
At
all
three
sites
(
CA,
IN,
and
MS),
the
raw
TTR
values
did
not
require
correction
for
field
fortification
recoveries,
as
the
overall
average
percent
recovery
was
>
90%.
At
the
California
site,
the
maximum
average
TTR
values
for
benefin
and
trifluralin
occurred
immediately
after
the
application
of
the
test
substance
(
0.0026

g/
cm2
and
0.00138

g/
cm2,
respectively).
After
day
0,
no
residues
were
detectable.
At
the
Indiana
site,
the
maximum
average
TTR
values
for
benefin
and
trifluralin
occurred
immediately
after
the
application
of
the
test
substance
(
0.0021

g/
cm2
and
0.0011

g/
cm2,
respectively).
After
day
0,
no
residues
were
detectable.
At
the
Mississippi
site,
the
maximum
average
TTR
values
for
benefin
and
trifluralin
occurred
immediately
after
the
application
of
the
test
substance
(
0.0012

g/
cm2
and
0.00077

g/
cm2,
respectively).
After
day
0,
no
residues
were
detectable.

This
study
met
most
of
the
Series
875.2100
Guidelines
(
See
Appendix
A).
The
only
issue
of
concern
is:

°
separate
control
plots
were
not
established
at
each
site.

COMPLIANCE:
Signed
and
dated
GLP,
Quality
Assurance,
and
Data
Confidentiality
statements
were
provided.
The
study
sponsor
waived
claims
of
confidentiality
within
the
scope
of
FIFRA
Section
10
(
d)(
1)(
A),
(
B),
or
(
C).
The
Study
Report
indicated
that
the
study
was
conducted
under
EPA
Good
Laboratory
Practice
Standards
(
40
CFR
Part
160),
with
the
following
exceptions:
(
1)
documentation
is
incomplete
by
GLP
standards
for
weather/
meteorological
data
and
(
2)
documentation
is
incomplete
by
GLP
standards
for
turf
and
pesticide
history.
According
to
the
study
author,
these
GLP
deviations
did
not
compromise
the
scientific
integrity
of
the
study.

CONCURRENT
EXPOSURE
STUDY?:
No
GUIDELINE
OR
PROTOCOL
FOLLOWED:
According
the
study
authors,
an
accepted
protocol
was
used;
however,
the
protocol
was
not
provided
with
the
Study
Report.
Series
875,
Occupational
and
4
Residential
Exposure
Test
Guidelines
Group
B:
Postapplication
Exposure
Monitoring
Test
Guidelines,
875.2100,
Transferable
Residue
Dissipation,
Lawn
and
Turf
was
followed
for
the
compliance
review
of
this
study.

I.
MATERIALS
AND
METHODS
A.
MATERIALS
1.
Test
Material:

Formulation:
Team
2G
is
a
granular
formulation
that
contains
1.33%
benefin
and
0.67%
trifluralin.
Lot/
Batch
#
formulation:
No
lot
or
batch
number
was
provided
in
the
Study
Report.
Formulation
guarantee:
The
stability
and
homogeneity
of
the
active
ingredients
in
the
formulation
were
established
prior
to
the
conduct
of
this
study
(
Report
No.
FA&
PC
973042).
Detailed
results
were
not
provided
in
the
Study
Report.
CAS
#(
s):
1861­
40­
1
(
benefin)
1582­
09­
8
(
trifluarlin)
Other
Relevant
Information:
EPA
Reg
No.:
62719­
137
2.
Relevance
of
Test
Material
to
Proposed
Formulation(
s):

According
to
the
Study
Report,
the
test
product
sent
to
the
field
sites
was
Team
2G
containing
1.33%
benefin
and
0.67%
trifluralin.
No
label
was
provided
with
the
Study
Report;
however,
using
the
OPP
Pesticide
Products
Database,
Versar
located
a
label
for
EPA
Registration
No.
62719­
137.
This
label
had
the
same
product
name
(
Team
2G)
and
active
ingredients
(
1.33%
benefin
and
0.67%
trifluralin
)
as
the
test
product,
thus
they
appear
to
be
the
same
products.

B.
STUDY
DESIGN
According
to
the
Study
Report,
the
deviations
to
the
study
protocol
(
which
was
not
provided
with
the
Study
Report)
are
as
follows:
(
1)
values
of
the
percent
active
ingredient
and
last
analysis
date,
although
known
prior
to
application,
were
not
added
to
the
study
file
until
after
application
of
the
test
material;
(
2)
Application
of
the
test
materials
at
one
site
was
approximately
8­%
of
that
stated
in
the
protocol;
and
(
3)
Protective
foot
coverings
were
not
changed
during
the
daily
sampling
because
samplers
did
not
walk
in
the
treated
areas.
The
study
authors
stated
that
these
deviations
had
no
effect
on
the
integrity
of
the
data
generated
for
this
study.

As
this
report
is
an
amended
version
of
a
previous
report
(
MRID
No.
449983­
01),
the
amendment
changes
were
as
follows:
(
1)
in
the
application
section,
the
range
of
application
rates
was
changed
to
reflect
the
re­
calculated
values;
(
2)
the
applied
rate
and
percent
of
target
application
for
the
CA
site
were
changed
to
reflect
the
recalculated
values;
and
(
3)
the
actual
application
rate
and
percent
of
target
application
for
the
CA
site
were
changed
to
reflect
the
re­
calculated
values.
These
amendments
were
necessary
as
calculation
errors
on
the
application
for
the
CA
site
were
discovered
in
the
original
Study
Report.
The
study
authors
stated
that
the
corrections
had
no
impact
on
the
study
since
the
corrected
values
did
not
affect
the
interpretation
or
results
of
the
study.

1.
Site
Description
Test
locations:
The
field
portion
of
the
study
was
conducted
in
Fresno
County,
California
(
Experiment
No.
97075CA),
in
Hancock
County,
Indiana
(
Experiment
No.
97075IN),
and
Washington
County,
Mississippi
(
Experiment
No.
97075MS).

Areas
sprayed
and
sampled:
The
test
plot
at
each
site
measured
100
ft
by
10
ft
and
was
divided
into
three
subplots,
each
measuring
2.5
ft
by
6
ft.

Meteorological
Data:
California
Meteorological
data
were
collected
at
the
California
site
from
a
Campbell
weather
station
located
one
mile
from
the
site.
Measurements
were
collected
from
June
5
to
June
13,
1997.
During
this
time
period,
the
lowest
minimum
temperature
was
54

F
and
the
highest
maximum
temperature
was
93

F.
There
were
no
precipitation
events
during
the
study.
Additionally,
irrigation
was
not
used.
Conditions
during
the
application
were
as
follows:
wind
speed
averaged
2.1
miles
per
hour
(
mph)
in
a
southeast
direction;
air
5
temperatures
averaged
80

F;
relative
humidity
averaged
44%;
and
the
turf
surface
was
dry.

Indiana
Meteorological
data
were
collected
at
the
Indiana
site
from
a
Campbell
weather
station
located
on­
site.
Measurements
were
collected
from
July
30
to
August
7,
1997.
During
this
time
period,
the
lowest
minimum
temperature
was
48

F
and
the
highest
maximum
temperature
was
91

F.
There
were
no
precipitation
events
during
the
study.
Additionally,
irrigation
was
not
used.
Conditions
during
the
application
were
as
follows:
wind
speed
ranged
from
0.9
to
5.1
miles
per
hour
(
mph)
in
an
easterly
direction;
air
temperatures
averaged
82.0

F;
relative
humidity
averaged
56%;
and
the
turf
surface
was
dry.

Pennsylvania
Meteorological
data
were
collected
at
the
Mississippi
site
from
a
Campbell
weather
station
located
on­
site.
Measurements
were
collected
from
June
19
to
June
27,
1997.
During
this
time
period,
the
lowest
minimum
temperature
was
68

F
and
the
highest
maximum
temperature
was
94

F.
One
precipitation
event
occurred
on
June
24th,
totaling
0.15
inches
of
rainfall
at
the
site.
Irrigation
was
not
used
at
the
site.
Conditions
during
the
application
were
as
follows:
wind
speed
ranged
from
2.0
to
3.0
miles
per
hour
(
mph)
in
a
southerly
direction;
air
temperatures
averaged
85

F;
relative
humidity
averaged
70%;
and
the
turf
surface
was
dry.

2.
Surface
Monitored:

California
Turf
Species:
Common
Bermuda
Residential
or
Public
Area:
Not
Provided
Other
relevant
Characteristics:
The
sodding
date
for
the
treated
plots
was
unknown.
At
the
time
of
the
application,
the
grass
was
considered
established
turf
and
was
approximately
1.5
inches
in
height.
The
grass
was
mowed
just
prior
to
each
application.
Other
products
used
on
turf
(
treated
plots):
No
maintenance
chemicals
were
used
on
the
treated
plot
for
the
duration
of
the
study
(
i.
e.,
control
sampling
on
the
day
prior
to
application
through
the
last
sampling
day).

Indiana
Turf
Species:
Bonanza
Tall
Fescue
Residential
or
Public
Area:
Not
Provided
Other
relevant
Characteristics:
The
plots
at
this
site
were
established
in
1992
At
the
time
of
the
application,
the
grass
was
considered
established
turf
and
was
approximately
3.0
inches
in
height.
The
grass
was
mowed
just
prior
to
each
application.
Other
products
used
on
turf
(
treated
plots):
No
maintenance
chemicals
were
used
on
the
treated
plot
for
the
duration
of
the
study
(
i.
e.,
control
sampling
on
the
day
prior
to
application
through
the
last
sampling
day).

Mississippi
Turf
Species:
Bermuda/
Baryard
Grass
Mixture
(~
70/
30)
Residential
or
Public
Area:
Not
Provided
Other
relevant
Characteristics:
The
plots
at
this
site
were
established
in
1997.
At
the
time
of
the
application,
the
grass
was
considered
established
turf
and
was
approximately
3.0
inches
in
height.
The
grass
was
mowed
just
prior
to
each
application.
Other
products
used
on
turf
(
treated
plots):
No
maintenance
chemicals
were
used
on
the
treated
plot
for
the
duration
of
the
study
(
i.
e.,
control
sampling
on
the
day
prior
to
application
through
the
last
sampling
day).

3.
Physical
State
of
Formulation
as
Applied
The
physical
state
of
the
formulation
as
applied
was
granular.
6
4.
Application
Rates
and
Regimes
California
Residential
or
Commercial
Applicator:
Commercial
Application
rate:
The
target
application
rate
was
2.0
lbs
benefin
per
acre
and
1.0
lb
trifluralin
per
acre.
The
actual
application
rate
was
2.01
lb
benefin
per
acre
and
1.0
lb
trifluralin
per
acre.
Application
Regime:
One
application
was
made
to
the
test
site
on
June
6,
1997.
Application
Equipment:
Applications
were
made
with
a
tractor­
mounted
Gandy
Applicator,
which
was
air
powered
with
4
banders
on
30
inch
spacing.
Equipment
Calibration
Procedures:
According
to
the
Study
Report,
the
sprayer
was
calibrated
to
deposit
16
grams
of
Team
2G/
sec.;
however,
the
raw
data
for
the
calibration
procedure
was
not
provided.
Was
application
"
watered
in"?
No
Was
total
deposition
measured?
No
Indiana
Residential
or
Commercial
Applicator:
Commercial
Application
rate:
The
target
application
rates
were
2.0
lbs
benefin
per
acre
and
1.0
lb
trifluralin
per
acre.
The
actual
application
rate
was
2.02
lb
benefin
per
acre
and
1.0
lb
trifluralin
per
acre.
Application
Regime:
One
application
was
made
to
the
test
site
on
July
31,
1997.
Application
Equipment:
Applications
were
made
with
a
tractor­
mounted
Gandy
Applicator,
which
was
air
powered
with
4
banders
on
30
inch
spacing.
Equipment
Calibration
Procedures:
Sprayer
calibration
was
performed
but
the
raw
data
for
this
calibration
was
not
provided.
The
sprayer
was
calibrated
to
deposit
20.77
grams
of
Team
2G/
sec.
Was
application
"
watered
in"?
No
Was
total
deposition
measured?
No
Mississippi
Residential
or
Commercial
Applicator:
Commercial
Application
rate:
The
target
application
rates
were
2.0
lbs
benefin
per
acre
and
1.0
lb
trifluralin
per
acre.
The
actual
application
rate
was
2.02
lb
benefin
per
acre
and
1.0
lb
trifluralin
per
acre.
Application
Regime:
One
application
was
made
to
the
test
site
on
June
20,
1997.
Application
Equipment:
Applications
were
made
with
a
tractor­
mounted
Gandy
spreader
(
dropgranule
with
30
banders
on
3
inch
spacing.
Equipment
Calibration
Procedures:
Sprayer
calibration
was
performed
but
the
raw
data
for
this
calibration
was
not
provided.
The
sprayer
was
calibrated
to
deposit
64.4
grams
of
Team
2G/
sec.
Was
application
"
watered
in"?
No
Was
total
deposition
measured?
No
5.
Dislodgeable
Residue
Sampling
Procedures
Method
and
Equipment:
Samples
were
collected
using
the
California
Roller
Technique.
A
weighted
foam
covered
roller
(
2
ft
x
4
in
diameter
pipe)
weighing
about
25
lbs
was
used
in
this
study.
The
dosimeters
were
pre­
cut,
100%
cotton,
200
thread
count
percale
sheets,
measuring
2
ft
by
3
ft.

Sampling
Procedure:
The
cloth
dosimeters
were
covered
by
a
plastic
layer
and
secured
to
the
sampling
media
frame.
The
frame
was
placed
randomly
in
the
subplots.
The
roller
was
placed
on
top
of
the
plastic
sheet
and
rolled
back
and
forth
five
times
without
pushing
down.
The
cloth
dosimeter
was
then
carefully
removed
from
the
surface,
and
folded
with
the
exposed
side
inward.
They
were
then
placed
in
a
labeled
sampling
container.
Control
samples
were
collected
prior
to
treated
samples.

Surface
area(
s)
sampled:
Each
cloth
dosimeter
measured
2
ft
by
3
ft.
However,
the
laboratory­
calculated
residue
values
were
based
upon
an
area
of
24
inches
by
36
inches
(
5,574
cm2)
which
represents
the
area
of
the
cloth
in
contact
with
the
treated
turf
when
placed
in
the
sampling
frame.

Replicates
per
surface:
7
­
Replicates
per
sampling
time:
Cotton
cloth
samples
were
collected
in
duplicate
from
the
treated
plots.
One
sample
was
also
collected
from
the
control
plot.
­
Number
of
sampling
times:
There
was
a
total
of
6
sampling
events
for
each
plot
at
each
site.

Times
of
sampling
after
application:
Samples
were
collected
before
and
after
the
application
and
at
1,
2,
4,
and
7
days
after
application
(
DAT).

6.
Sample
Handling
Cotton
samples
were
folded
(
with
the
exposed
part
of
the
cloth
inward)
and
then
placed
in
a
labeled
sampling
container.
The
samples
were
put
on
dry
ice
or
in
a
freezer
within
four
hours
of
collection.
Samples
were
maintained
under
frozen
storage
until
shipped.
The
samples
were
shipped
in
insulated
boxes
with
dry
ice
by
either
an
overnight
or
hand
delivery
to
Dow
AgroSciences,
Sample
Management.
The
samples
were
stored
frozen
(
approximately
­
20

C)
at
Dow
AgroSciences
until
analysis.

7.
Analytical
Methodology:

Extraction
method:
Residues
of
benefin
and
trifluralin
were
extracted
from
the
percale
cloth
by
adding
500
mL
of
hexane
to
the
cloth
samples
in
32
ounce
plastic
coated
glass
jars.
Each
sample
was
mechanically
shaken
for
a
minimum
of
one
hour.
After
the
shaking
period,
an
aliquot
was
removed
from
each
sample
and
transferred
to
a
gas
chromatographic
vial
and
analyzed
by
gas
chromatography
(
see
Table
1).

Detection
methods:
See
Table
1.

Table
1.
Summary
of
GC
Operating
Conditions
GC
Column
J
&
W
Scientific
fused
silica
capillary
column,
30
m
x
0.25
mm,
0.25

m
film
thickness
Temperatures
Inlet:
250
oC
Detector:
325
oC
Column
Temperatures:
Initial
=
100
oC,
hold
1.5
min.;
Final
=
300
oC,
hold
2
min.

Injection
Volume
3

L
Run
Time
48.5
min.
Method
validation:
Method
validation
was
performed
prior
to
sample
analysis
through
analysis
of
matrix
blanks
(
untreated
cloth)
and
analysis
of
cloth
samples
fortified
with
6,
17,
550
and
8500

g
of
benefin
and
trifluralin
per
cloth
sample,
respectively.
Recovery
for
the
6,
17,
550
and
8500

g
benefin
fortification
levels
were
<
LOQ,
99
±
3.7%,
106
±
10.5%
and
118
±
1.4%,
respectively.
Recovery
for
the
6,
17,
550
and
8500

g
trifluralin
fortification
levels
were
<
LOQ,
100
±
4.1%,
106
±
11.1%
and
119
±
1.3%,
respectively.
Neither
benefin
or
trifluralin
were
detected
at
concentrations
above
the
LOQ
in
the
matrix
blanks.
The
target
LOQ
and
LOD
for
both
benefin
and
trifluralin
were
0.003
and
0.001

g/
cm2,
respectively.
The
calculated
LOQs
and
LODs,
based
on
the
method
validation
results,
were
defined
as
0.0012

g/
cm2
and
0.0003

g/
cm2,
respectively,
for
benefin
and
0.0011

g/
cm2
and
0.0003

g/
cm2,
respectively,
for
trifluralin.

Instrument
performance
and
calibration:
Calibration
standards
ranged
from
0.003

g/
cm2
to
1.5

g/
cm2.

8.
Quality
Control:

Lab
Recovery:
Laboratory
recovery
samples
were
analyzed
with
each
analytical
sequence
of
cloth
samples.
Laboratory
recovery
values
ranged
from
908
to
118%
for
fortification
levels
from
17

g
to
8,500

g
per
cloth
sample.
The
overall
mean
recovery
was
106
±
8%
(
n=
15)
for
benefin
and
106
±
9%
(
n=
15)
for
trifluralin.

Field
blanks:
Single
samples
were
collected
from
the
untreated
plot
at
each
field
site
before
application
occurred.
There
were
no
trifluralin
or
benefin
residues
detected
above
the
LOQ
in
any
of
these
field
blank
samples.
There
were
three
unfortified
field
blank
samples
which
were
prepared
on
each
of
three
field
fortification
dates
at
each
site.
Trifluralin
or
benefin
residues
were
not
detected
in
these
samples
at
a
concentration
above
the
LOQ.
8
Field
recovery:
Field
fortification
samples
were
prepared
in
triplicate
at
three
fortification
levels
(
50,
500
and
5,000

g/
cloth)
for
each
field
site.
The
samples
used
for
fortification
were
subjected
to
the
same
rolling
technique
required
for
the
field
samples.
The
fortification
solution
was
delivered
onto
the
cloth
and
the
solvent
was
allowed
to
dry
from
the
cloth
as
much
as
possible
prior
to
placing
the
samples
in
labeled
sample
containers
and
placing
them
in
the
freezer
prior
to
shipment
to
the
analytical
laboratory.
The
field
fortified
samples
were
shipped
and
stored
frozen
for
161
to
236
days
under
the
same
conditions
as
the
field
samples.
Table
2
provides
the
mean
recoveries
and
standard
deviations
for
each
field
fortification
event
at
each
site.
At
the
50,
500,
and
5,000

g
field
fortification
levels,
overall
average
recoveries
±
standard
deviation
were
90
±
6.2%
,
95
±
6.0%,
and
98
±
9.8%
for
benefin
and
94
±
6.5%,
96
±
6.2%,
98
±
9.8%
for
trifluralin.

Table
2.
Summary
of
Field
Fortification
Recoveries
Study
Site
50
ug
Fortification
Level
500
ug
Fortification
Level
5,000
ug
Fortification
Level
Percent
Recovery
Average
±
Std
Dev
Percent
Recovery
Average
±
Std
Dev
Percent
Recovery
Average
±
Std
Dev
Benefin
California
86
91
±
9.0
84
91
±
6.4
82
88
±
5.5
101
95
88
85
95
93
Indiana
88
92
±
6.9
96
99
±
2.5
113
110
±
7.0
88
101
115
100
99
102
Mississippi
86
86
±
0.6
92
95
±
7.6
91
92
±
1.7
87
104
91
86
90
94
Total
Average
90
95
98
Total
Std
Dev
6.2
6.0
9.8
Trifluralin
California
87
94
±
11.0
84
92
±
6.9
84
89
±
5.5
107
96
89
89
96
95
Indiana
90
95
±
6.4
94
97
±
2.5
112
109
±
6.4
92
99
114
102
97
102
Mississippi
93
93
±
0.57
95
99
±
8.1
96
97
±
2.1
93
108
95
92
93
99
Total
Average
94
96
98
Total
Std
Dev
6.5
6.2
9.8
Tank
mix:
Tank
mix
samples
were
not
discussed
in
this
Study
Report.

Travel
Recovery:
Travel
recovery
was
not
discussed
in
the
Study
Report.

Storage
Stability:
The
cloth
samples
in
this
study
were
stored
for
a
maximum
of
236
days
prior
to
analysis.
Based
on
the
results
of
the
field
fortification
samples
that
were
stored
and
analyzed
along
with
the
treated
samples,
benefin
and
trifluralin
residues
were
found
to
be
stable
for
the
length
of
frozen
storage.
9
II.
RESULTS
AND
CALCULATIONS:

The
statistical
summaries
for
the
three
sites
are
provided
in
Tables
3
and
4.
For
all
three
sites
(
CA,
IN,
and
MS),
Versar
did
not
correct
the
raw
TTR
values
for
field
fortification
recoveries,
as
the
overall
average
percent
recovery
was
>
90%.
The
raw
TTR
values
were
corrected
for
field
fortification
recovery
by
the
study
author.

At
the
California
site,
the
maximum
average
TTR
values
for
benefin
and
trifluralin
occurred
immediately
after
the
application
of
the
test
substance
(
0.0026

g/
cm2
and
0.00138

g/
cm2,
respectively).
After
day
0,
residues
were
not
quantifiable.
At
the
Indiana
site,
the
maximum
average
TTR
values
for
benefin
and
trifluralin
occurred
immediately
after
the
application
of
the
test
substance
(
0.0021

g/
cm2
and
0.0011

g/
cm2,
respectively).
After
day
0,
residues
were
not
quantifiable.
At
the
Mississippi
site,
the
maximum
average
TTR
values
for
benefin
and
trifluralin
occurred
immediately
after
the
application
of
the
test
substance
(
0.0012

g/
cm2
and
0.00077

g/
cm2,
respectively).
After
day
0,
residues
were
not
quantifiable.

III
DISCUSSION
A.
LIMITATIONS
OF
THE
STUDY:

This
study
met
most
of
the
Series
875.2100
Guidelines
(
See
Appendix
A).
The
only
issue
of
concern
is:

°
separate
control
plots
were
not
established
at
each
site.
10
B.
CONCLUSIONS:

It
was
not
necessary
to
perform
a
linear
regression
on
the
data
from
this
study
because
at
all
three
sites,
there
were
no
residues
detected
after
day
0.
This
may
be
a
result
of
dry
granular
formulations
not
being
easily
transferable.

Table
3.
Transferable
Turf
Residue
Data
for
Benefin
on
Turf
from
Team
2G
Applications
Site
Sampling
Interval
(
Days
after
treatment)
Benefin
Residue
(
ug/
sample)
Trifluralin
Residue
(
ug/
cm2)
Average
California
0
19
0.0034
0.0026
0
10.3
0.0018
1
4.8
<
LOQ
<
LOQa
1
4.3
<
LOQ
2
3.3
<
LOQ
2
3.8
<
LOQ
4
2.5
<
LOQ
4
2.2
<
LOQ
7
0
<
LOQ
7
0.7
<
LOQ
Indiana
0
9.8
0.0018
0.0021
0
12.6
0.0023
1
0.8
<
LOQ
<
LOQa
1
0.7
<
LOQ
2
1.2
<
LOQ
2
1.1
<
LOQ
4
1.3
<
LOQ
4
1.6
<
LOQ
7
0.8
<
LOQ
7
1.2
<
LOQ
Mississippi
0
7.4
0.0013
0.0012
0
5.8
0.001
1
4.4
<
LOQ
<
LOQa
1
1.6
<
LOQ
2
2
<
LOQ
2
2.3
<
LOQ
4
0.8
<
LOQ
4
1.1
<
LOQ
7
0.5
<
LOQ
7
0
<
LOQ
a
LOQ
=
0.0011

g/
cm2
11
Table
4.
Transferable
Turf
Residue
Data
for
Trifluralin
on
Turf
from
Team
2G
Applications
Site
Sampling
Interval
(
Days
after
treatment)
Trifluralin
Residue
(
ug/
sample)
Trifluralin
Residue
(
ug/
cm2)
Average
California
0
10.0
0.00179
0.00138
0
5.4
0.00097
1
2.6
<
LOQ
<
LOQa
1
2.2
<
LOQ
2
1.4
<
LOQ
2
1.7
<
LOQ
4
1.0
<
LOQ
4
1.1
<
LOQ
7
0.0
<
LOQ
7
0.0
<
LOQ
Indiana
0
5.4
0.00097
0.0011
0
6.9
0.00124
1
0.5
<
LOQ
<
LOQa
1
0.5
<
LOQ
2
0.6
<
LOQ
2
0.7
<
LOQ
4
0.7
<
LOQ
4
1.0
<
LOQ
7
0.5
<
LOQ
7
0.6
<
LOQ
Mississippi
0
4.7
0.00084
0.00077
0
3.9
0.00070
1
2.2
<
LOQ
<
LOQa
1
0.8
<
LOQ
2
0.9
<
LOQ
2
0.7
<
LOQ
4
0.0
<
LOQ
4
0.6
<
LOQ
7
0.0
<
LOQ
7
0.0
<
LOQ
a
LOQ
=
0.0012

g/
cm2
12
_________________________
____________________________
Name:
Name:
Evaluator
Peer
Reviewer
Occupational
Exposure
Assessment
Section
Occupational
Exposure
Assessment
Section
_________________________
_________________________
Date
Date
_________________________
Name:
Head,
Occupational
Exposure
Assessment
Section
_________________________
Date
13
APPENDIX
A
Compliance
Checklist
for
"
Dissipation
of
Transferable
Residues
of
Benefin
and
Trifluralin
on
Turf
Treated
with
a
Formulation
of
the
Pesticides"
14
Compliance
Checklist
Compliance
with
OPPTS
Series
875,
Occupational
and
Residential
Exposure
Test
Guidelines,
Group
B:
Post­
application
Exposure
Monitoring
Test
Guidelines,
875.2100,
Transferable
Residue
Dissipation,
Lawn
and
Turf,
is
critical.
The
itemized
checklist
below
describes
compliance
with
the
major
technical
aspects
of
OPPTS
875.2100.


The
test
substance
must
be
the
typical
end
use
product
of
the
active
ingredient.
This
criterion
was
met.


The
production
of
metabolites,
breakdown
products,
or
the
presence
of
contaminants
of
potential
toxicologic
concern,
should
be
considered
on
a
case­
by­
case
basis.
It
is
not
certain
if
this
criterion
was
met.
Metabolites,
breakdown
products,
or
the
presence
of
contaminants
of
potential
toxicological
concern
for
benefin
and
trifluralin
were
not
discussed
in
the
Study
Report.


Applications
should
occur
at
the
time
of
season
that
the
end­
use
product
is
normally
applied
to
achieve
intended
pest
control.
This
criterion
was
met.


Initiating
testing
immediately
before
a
precipitation
event
should
be
avoided.
Applications
should
be
made
after
mowing
and
watering.
This
criterion
was
met.


The
end
use
product
should
be
applied
by
the
application
method
recommended.
Formulations
which
can
be
applied
in
a
minimal
amount
of
water
and
do
not
require
"
watering
in"
should
be
used.
Information
that
verifies
that
the
application
equipment
(
e.
g.,
sprayer)
was
properly
calibrated
should
be
included.
This
criterion
was
partly
met.
The
end
use
product
was
applied
by
the
application
method
recommended.
The
calibration
data
was
not
provided
for
the
application
equipment.


The
application
rate
used
in
the
study
should
be
provided
and
should
be
the
maximum
rate
specified
on
the
label.
However,
monitoring
following
application
at
a
typical
application
rate
is
more
appropriate
in
certain
cases.
This
criterion
was
met.


If
multiple
applications
are
made,
the
minimum
allowable
interval
between
applications
should
be
used.
This
criterion
does
not
apply
to
this
Study
Report

Transferable
turf
residue
(
TTR)
data
should
be
collected
from
at
least
three
geographically
distinct
locations
for
each
formulation.
The
sites
should
be
representative
of
the
regions
(
and
turf
types)
where
the
chemical
is
used.
This
criterion
was
met.
Transferable
turf
residue
data
were
collected
from
sites
in
California,
Indiana,
and
Mississippi.


The
site(
s)
treated
should
be
representative
of
reasonable
worst­
case
climatic
conditions
expected
in
intended
use
areas.
Meteorological
conditions
including
temperature,
wind
speed,
daily
rainfall,
and
humidity
should
be
provided
for
the
duration
of
the
study.
This
criterion
was
met.
Meteorological
conditions
including
temperature
and
rainfall
were
recorded
for
the
duration
of
the
study.


Sampling
should
be
sufficient
to
characterize
the
dissipation
mechanisms
of
the
compound
(
e.
g.,
three
half­
lives
or
72
hours
after
application,
unless
the
compound
has
been
found
to
fully
dissipate
in
less
time;
for
more
persistent
pesticides,
longer
sampling
periods
may
be
necessary).
Sampling
intervals
may
be
relatively
short
in
the
beginning
and
lengthen
as
the
study
progresses.
Background
samples
should
be
collected
before
application
of
the
test
substance
occurs.
These
criteria
were
met.


Triplicate,
randomly
collected
samples
should
be
collected
at
each
sampling
interval.
This
criterion
was
met.
Triplicate
turf
sample
replicates
were
collected
at
each
sampling
interval.


Samples
should
be
collected
using
a
suitable
methodology
(
e.
g.,
California
Cloth
Roller,
Polyurethane
Roller,
Drag
Sled,
etc.)
for
turf.
This
criterion
was
met.
Turf
residue
samples
were
collected
using
the
California
Cloth
Roller
methodology.

Control
plots
should
be
established
from
which
sufficient
control
samples
can
be
collected.
Control
sites
should
be
upwind
and
a
reasonable
distance
from
the
treatment
site.
These
criteria
were
not
met.
Separate
control
plots
were
not
established
on­
site.
Control
samples
were
taken
from
the
plots
before
application
occurred.

Residues
should
be
dislodged
from
turf
within
a
reasonable
time
period
(
i.
e.,
Pennsylvania
recommends
that
dislodging
occur
within
4
hours).
Other
transferable
method
samples
should
be
handled
in
a
manner
that
is
appropriate
to
the
method
used.
This
criterion
was
met.
The
modified
California
cloth
roller
was
used
to
collect
samples.
Extraction
of
the
residues
from
the
cloth
sample
occurred
just
prior
to
analysis
of
the
samples.
15

Samples
should
be
stored
in
a
manner
that
will
minimize
deterioration
and
loss
of
analytes
between
collection
and
analysis.
Information
on
storage
stability
should
be
provided.
These
criteria
were
met.
The
samples
were
stored
frozen
shortly
after
collection
and
remained
frozen
until
analysis.
The
field
fortification
samples
verified
the
stability
of
the
pesticide.


Validated
analytical
methods
of
sufficient
sensitivity
are
needed.
Information
on
method
efficiency
(
residue
recovery),
and
limit
of
quantitation
(
LOQ)
should
be
provided.
This
criterion
was
met.


Information
on
recovery
samples
must
be
included
in
the
study
report.
A
complete
set
of
field
recoveries
should
consist
of
at
least
one
blank
control
sample
and
three
or
more
each
of
a
low­
level
and
high­
level
fortification.
These
fortifications
should
be
in
the
range
of
anticipated
residue
levels
in
the
field
study.
This
criterion
was
met.


Raw
residue
data
must
be
corrected
if
appropriate
recovery
values
are
less
than
90
percent.
Distributional
data
should
be
reported,
to
the
extent
possible.
This
criterion
was
met.
Raw
residue
data
were
not
corrected
for
all
three
sites
because
the
corresponding
average
field
fortification
values
were
greater
than
90%.


Foliar
residue
data
expressed
as
µ
g/
cm2
turf
leaf
surface
area.
This
criterion
was
met.
All
residue
data
were
provided
in

g/
cm2.
