Page
1
of
5
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
Chemical:
MCPB,
MCPB
Sodium
PC
Code:
019202,
019201
DP
Barcodes:
D314042,
D314043,
D314045
MEMORANDUM
DATE:
19
October
2005
SUBJECT:
Error
Corrections
First
Phase
for
Reregistration
of
MCPB
and
MCPB
Sodium
FROM:
Marie
Janson,
Environmental
Scientist
Ed
Odenkirken,
Senior
Scientist
Kevin
Costello,
Acting
Branch
Chief
Environmental
Risk
Branch
1
Environmental
Fate
and
Effects
Division
(
7507C)

TO:
Susan
Lewis,
Branch
Chief
Demson
Fuller,
CRM
James
Parker,
CRM
Registration
Branch
1
SRRD
Division
(
7505C)

Attached
please
find
the
Environmental
Fate
and
Effects
Division's
(
EFED)
revised
error
only
corrected
comments
environmental
risk
assessment
for
the
proposed
registration
of
MCPB
as
an
herbicide
on
peas.
Supported
formulations
of
MCPB
are
Thistrol
®
Herbicide
(
71368­
5)
and
Sodium
MCPB
Solution
(
71368­
7).

Only
errors
were
corrected
in
this
Phase
I
of
the
public
process.
The
registrant
offered
other
comments
on
the
draft
risk
assessment
which
dealt
with
substantive
questions
on
science
or
interpretation.
Such
comments
will
not
be
addressed
in
this
phase,
but
will
be
addressed
in
Phase
III,
the
response
to
public
comment.
Page
2
of
5
Location
of
Error
Error
Identified
in
Draft
Corrected
Throughout
document
chemical
name
for
MCPB
(
4­(
2­
methyl­
4­
chlorophenoxy)
butyric
acid
Page
1,
paragraph
2,
line
3
this
is
rate
converts
this
rate
converts
Page
2,
paragraph
1,
lines
3­
4
4
­(
4­
hydroxy­
otolyloxy
butyric
acid...
this
is
a
transformation
product.
4
­
(
4­
chloro­
o­
tolyloxy)
butyric
acid
is
the
IUPAC
for
MCPB
acid
which
was
changed
in
table
#
II.
a.
4
­(
4­
chloro­
otolyloxy
butyric
acid
is
the
IUPAC
for
MCPB
acid
which
was
changed
in
table
#
II.
a.
.
The
IUPAC
was
changed
in
table
II.
b.
to
N/
A.

Page
5
last
line
Consequently;
Consequently,

Page
7,
paragraph
3,
line
1
summarizes
data
gaps
summarize
data
gaps
Page
8
&
9
table
I.
d.
Vegetative
Vigor
Tier
I
(
is
more
data
needed
column)
..
Yes
Vegetative
Vigor
(
is
more
data
needed
column)
..
No
Page
8
&
9
table
I.
d.
Vegetative
Vigor
Tier
II
(
is
more
data
needed
column)
..
Yes
Vegetative
Vigor
Tier
II
(
is
more
data
needed
column)
..
No
Page
10,
paragraph
2,
line
3
Is
formulated
only...
It
is
formulated
only...

Page
14,
Table
II.
b.
Vapor
Pressure,
pka
and
Log
Kow
values
were
for
MCPB
acid
Deleted
Vapor
Pressure,
pka
and
Kow
for
MCPB
acid.

Page
15,
paragraph
1,
line
8
N/
A
Page
15,
paragraph
3,
lines
2­
3
The
registrants
include
BASF
Corporation,
Dow
AgroSciences,
NuFarm
UK
and
A.
H.
Marks
and
Company
Ltd.
The
registrants
include
A.
H.
Marks
and
Company
Ltd.,
Nufarm
BV
and
Nufarm,
Inc.
Page
3
of
5
Page
20,
table
II­
g
Under
RQ
column
for
Acute
Endangered
Species
(
NOEC/
EC05
or
NOEC)
Under
RQ
column
for
Acute
Endangered
Species
(
EEC/
EC05
or
NOEC)

Page
22,
paragraph
4,
line2
...
statement
in
included
to
avoid
spray
drift...
...
statement
is
included
to
avoid
spray
drift...

Page
28,
paragraph
2,
last
line
...
the
residue
study
a
default
value...
...
the
residue
study,
a
default
value...

Page
32,
paragraph
1
Freshwater
Fish,
Chronic
A
freshwater
fish
early
lifestage
test
using
the
TGAI
is
normally
required
for
pesticide
registration.
However,
EFED
did
not
request
this
study
or
the
full
life­
cycle
fish
study.
Thus,
the
guidelines
(
72­
4a;
72­
5)
are
not
fulfilled.
Freshwater
Fish,
Chronic
A
freshwater
fish
early
lifestage
test
and
life
cycle
fish
test
using
the
TGAI
were
not
submitted
by
the
registrant.
Therefore,
the
guidelines
(
72­
4a;
72­
5)
were
not
fulfilled.

Page
32,
paragraph
2
Freshwater
Invertebrate,
Chronic
A
freshwater
aquatic
invertebrate
life­
cycle
test
using
the
TGAI
is
normally
required
for
pesticide
registration.
However,
EFED
did
not
request
this
study.
The
preferred
test
is
a
21­
day
life
cycle
study
with
Daphnia
magna.
The
guideline
(
72­
4b)
is
not
fulfilled.
Freshwater
Invertebrate,
Chronic
A
freshwater
aquatic
invertebrate
life­
cycle
test
using
the
TGAI
was
not
submitted
by
the
registrant.
The
preferred
test
is
a
21­
day
life
cycle
study
with
Daphnia
magna.
The
guideline
(
72­
4b)
was
not
fulfilled.

Page
34,
paragraph
1,
line
4
...
is
categorized
as
practically
non­
toxic
to
avian
species
on
a
acute
dietary
basis.
...
is
categorized
as
practically
non­
toxic
to
avian
species
on
an
acute
dietary
basis.
Page
4
of
5
Page
35,
paragraph
3
In
2­
generation
teratology
studies...
In
the
developmental
toxicity
studies...(
Also
replaced
throughout
the
document
where
it
pertained)

Page
40,
paragraph
2,
line
3
As
describe
in
exposure
characterization,...
As
described
in
exposure
characterization,...

Page
40,
paragraph
3
No
reference
in
paragraph
to
Table
IV.
a.
Inserted
reference
in
preceding
paragraph
as
follows.......
Table
IV.
a.
has
summarized
the
risk
quotients
for
freshwater
fish
and
invertebrates
with
Oregon
and
California
PRZM
3.12/
EXAMS
2.98
scenarios.

Page
41,
Section
2.
No
reference
in
paragraph
to
Table
IV.
c.
Inserted
reference
preceding
Table
IV.
c.
as
follows.....
The
following
Table
IV.
c.
summarizes
the
endpoints
used
in
this
assessment
for
RQ
evaluation
for
non­
target
terrestrial
animals
and
plants:

Page
48,
paragraph
5,
line1
...
determine
a
NOAEC
to
be
used
to
chronic
risk
quotients....
...
determine
a
NOAEC
to
be
used
in
chronic
risk
quotients....

Page
49,
paragraph
2,
lines
5­
6
...
dermal
contact,
and
inhalation
is
not
considered....
...
dermal
contact,
and
inhalation
are
not
considered....

Page
52,
paragraph
2,
line
3
...
locations
of
use
sites
and
could
be
considered....
...
locations
of
use
sites
could
be
considered....

Page
54,
paragraph1,
line
5
...
calculated
RQ
value(.
01)
result
in
an
estimated
chance...
...
calculated
RQ
value(.
01)
results
in
an
estimated
chance...

Page
55,
paragraph
1,
line
3
and
paragraph1,
line
5
eatting
eating
Page
56,
paragraph
4,
line2
dependant
dependent
Page
5
of
5
Page
71,
paragraph
1,
line
3­
4
...
screeningmodeldesigned
to
estimate
pesticide
concentrations
found
in
water
at
the
edge
of
atreated
field.
...
screening
model
designed
to
estimate
pesticide
concentrations
found
in
water
at
the
edge
of
a
treated
field.

Page
104,
paragraph
1,
line
2
The
NOECS
for
the
corn
and
oats
were
1.5
lb/
acre
and
1/
3
lb
ai/
acre.
The
NOECS
for
the
corn
and
oats
were
1.5
lb/
acre
and
1.3
lb
ai/
acre.

Page
105,
last
paragraph
141­
5
Acute
Honey
Bee
Contact
141­
1
Acute
Honey
Bee
Contact
Page
114,
first
reference
Hoberg,
J.
R.
1992.....
10566.0392.6230.42
0
MRID
42532603
Hoberg,
J.
R.
1992.....
10566.0392.6230.44
0
MRID
42532609
Page
114,
fourth
reference
Holsing,
G.
1969
Acute
Oral
­
Rats.....
Unpublished
study
performed
by
Rhodia,
Inc.,
New
Brunswick,
NJ
and
sponsored
by
TRW,
Inc.
Holsing,
G.
1969
Acute
Oral
­
Rats.....
Unpublished
study
performed
by
TRW,
Inc.
and
sponsored
by
Rhodia,
Inc.
