ECOLOGICAL
HAZARD
AND
ENVIRONMENTAL
RISK
ASSESSMENT
2­
Phenylphenol
and
Salts
CASE
2575
PC
CODES
064103,
064104,
064108,
064116
April
10,
2006
Kathryn
V.
Montague,
M.
S.
Antimicrobials
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
Table
of
Contents
I.
Executive
Summary.
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1
Data
gaps.
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1
Label
Hazard
Statements
and
Use
Recommendations.
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.2
II.
Ecological
Toxicity
Data
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A.
Toxicity
to
Terrestrial
Animals
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1.
Birds,
Acute
and
Subacute
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3
2.
Mammals,
Acute
and
Chronic
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B.
Toxicity
to
Aquatic
Animals
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1.
Freshwater
Fish,
Acute
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2.
Freshwater
Invertebrates,
Acute
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3.
Estuarine
and
Marine
Organisms,
Acute
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7
4.
Aquatic
Organisms,
Chronic
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C.
Toxicity
to
Plants
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8
III.
Environmental
Fate
and
Exposure
Assessment
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.10
A.
Environmental
Fate
Assessment
Summary
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10
B.
Environmental
Exposure
Assessment
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10
1.
Indoor
uses.
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.10
2.
Antisapstain
use.
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IV.
Risk
Assessment
and
Characterization.
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A.
Indoor
uses.
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.18
B.
Antisapstain.
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.19
C
Endangered
Species
Considerations
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20
D.
Endocrine
Disruption.
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.21
E.
Label
Hazard
Statements
and
Use
Recommendations.
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V.
References.
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.23
Ecological
Effects
Hazard
and
Environmental
Risk
Assessment
2­
Phenylphenol
and
Salts
I.
Executive
Summary:

2­
phenylphenol
and
its
salts
(
sodium,
potassium
and
ammonium)
are
used
as
sporicides,
bacteriostats,
water
purifier
bacteriostats,
microbiocides,
microbiostats,
nematicides,
fumigants,
incan
preservatives,
and
bacteriocides
on
a
variety
of
use
sites,
most
of
which
are
indoor.
Sodium
2­
phenylphenate
is
also
used
as
an
antisapstain
treatment
on
cut
wood,
which
is
an
outdoor
use.

2­
phenylphenol
and
its
salts
demonstrate
low
toxicity
to
birds,
and
moderate
toxicity
to
mammals,
freshwater
fish,
freshwater
invertebrates,
and
algae.

The
low
exposure
potential
from
the
indoor
uses
of
2­
phenylphenol
and
salts,
coupled
with
the
tendency
for
the
compounds
to
degrade
under
environmental
conditions,
result
in
low
likelihood
of
adverse
acute
effects
to
wildlife
and
aquatic
organisms
from
the
indoor
uses.
Based
on
the
results
of
the
antisapstain
modeling,
runoff
from
antisapstain
treating
facilities
will
exceed
acute
high
risk,
restricted
use,
and
endangered
species
LOCs
for
freshwater
fish,
freshwater
invertebrates,
and
aquatic
plants.
Chronic
risks
cannot
be
assessed
at
this
time
due
to
a
lack
of
chronic
toxicity
data.

The
model
used
to
estimate
exposure
from
antisapstain
uses
is
intended
as
a
Tier
I
screening
model,
and,
as
such,
has
inherent
assumptions
and
uncertainties
that
may
result
in
over­
or
under­
estimation
of
exposure
levels.
Since
the
model
is
only
intended
as
a
screening­
level
model,
further
refinement
of
the
model
is
recommended
to
more
accurately
assess
risks
from
the
antisapstain
uses
of
2­
phenylphenol.

Methods
to
reduce
the
amount
of
2­
phenylphenol
potentially
released
from
antisapstain­
treated
wood
could
potentially
mitigate
the
risks.
Possible
mitigation
methods
might
include,
but
are
not
limited
to,
lowering
the
application
rate
or
requiring
specific
storage
conditions
to
prevent
exposure
of
recently
treated
wood
to
weather
(
e.
g.,
full
covering)
and/
or
prevent
the
release
of
any
associated
runoff
into
aquatic
habitats
(
e.
g.,
drip
pads).
2­
phenylphenol
is
not
very
mobile
in
soils,
so
any
2­
phenylphenol
leached
outdoors
will
likely
bind
to
soils
and
not
reach
aquatic
habitats
as
free
2­
phenylphenol.
An
environmental
monitoring
study
of
runoff
from
antisapstain
facilities
is
needed
to
address
the
potential
risks
of
concern
and
provide
estimated
environmental
concentrations
(
EEC)
to
use
in
a
refined
risk
assessment.
In
the
interim,
precautions
to
limit
leaching
and
runoff
from
antisapstain
treatment
facilities
areas
(
see
Label
Hazard
Statements
and
Use
Recommendations
section,
below)
should
prevent
exposure
to
aquatic
organisms.

For
certain
use
categories,
the
Agency
assumes
there
will
be
minimal
environmental
exposure,
and
only
a
minimal
toxicity
data
set
is
required
(
Overview
of
the
Ecological
Risk
Assessment
Process
in
the
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
­
Endangered
and
Threatened
Species
Effects
Determinations,
1/
23/
04,
Appendix
A,
Section
IIB,
pg.
81).
Chemicals
in
these
categories
therefore
do
not
undergo
a
full
screening­
level
risk
assessment,
and
are
considered
2
to
fall
under
a
A
no
effect
@

determination.
The
active
ingredient
uses
of
2­
phenylphenol,
with
the
exception
of
the
antisapstain
wood
preservation
use,
fall
into
this
category.
Using
Tier
I
screening
modeling
to
assess
potential
exposure
from
antisapstain
wood
preservation
uses
of
2­
phenylphenol,
risks
to
Listed
Species
are
indicated.
Since
the
model
is
only
intended
as
a
screening­
level
model,
and,
as
such,
has
inherent
uncertainties
and
limitations
which
may
result
in
inaccurate
exposure
estimations,
further
refinement
of
the
model
is
recommended
before
any
regulatory
action
is
taken
regarding
the
antisapstain
uses
of
2­
phenylphenol
.
Additionally,
impacts
from
the
antisapstain
use
could
potentially
be
mitigated
with
precautions
to
prevent
leaching
and
runoff
when
wood
is
stored
outdoors
(
see
Label
Hazard
Statements/
Use
Recommendations,
below).
Due
to
these
circumstances,
the
Agency
defers
making
a
determination
for
the
antisapstain
uses
of
2­
phenylphenol
until
additional
data
and
modeling
refinements
are
available.
At
that
time,
the
environmental
exposure
assessment
of
the
antisapstain
use
of
2­
phenylphenol
will
be
revised,
and
the
risks
to
Listed
Species
will
be
reconsidered.

Laboratory
studies
indicate
that
2­
phenylphenol
(
aka
2­
hydroxybiphenol)
demonstrates
some
potential
to
act
as
an
endocrine
disruptor.
When
the
appropriate
screening
and/
or
testing
protocols
being
considered
under
the
Agency's
Endocrine
Disruptor
Screening
and
Testing
Advisory
Committee
(
EDSTAC)'
s
Endocrine
Disruptor
Screening
Program
(
EDSP)
have
been
developed,
2­
phenylphenol
may
be
subjected
to
additional
screening
and/
or
testing
to
better
characterize
effects
related
to
endocrine
disruption.

Data
Gaps:

The
following
ecological
effects
data
gaps
exist
for
the
registered
uses
of
2­
phenylphenol
and
salts:

Marine/
estuarine
organism
acute
testing
(
72­
3/
850.1075,
850.1035/
1045,
and
850.1025/
1055)
(
These
studies
have
recently
been
submitted
to
the
Agency
and
are
currently
undergoing
review).

Aquatic
organism
chronic
toxicity
testing
(
72­
4a/
850.1300
and
72­
4b/
850.1400)

Terrestrial
plant
toxicity
testing
using
rice
(
123­
1/
850.4225
and
850.4250)
(
These
studies
have
recently
been
submitted
to
the
Agency
and
are
currently
undergoing
review).

Aquatic
plant
toxicity
testing
on
four
species
(
123­
2/
850.4400
and
850.5400)
(
These
studies
have
recently
been
submitted
to
the
Agency
and
are
currently
undergoing
review).

Monitoring
study
of
runoff
from
antisapstain
facilities
to
establish
EEC's
for
risk
assessment
Label
Hazard
Statements/
Use
Recommendations
2­
phenylphenol
and
salts
labels
must
state:

"
Do
not
discharge
effluent
containing
this
product
into
lakes,
streams,
ponds,
estuaries,
3
oceans,
or
other
waters
unless
in
accordance
with
the
requirements
of
a
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
and
the
permitting
authority
has
been
notified
in
writing
prior
to
discharge.
Do
not
discharge
effluent
containing
this
product
to
sewer
systems
without
previously
notifying
the
local
sewage
treatment
plant
authority.
For
guidance
contact
your
State
Water
Board
or
Regional
Office
of
the
EPA."

Antisapstain
labels
must
state:
"
Treated
lumber
must
not
be
stored
outdoors
without
precautions
to
prevent
to
prevent
leaching
by
rainfall
to
the
environment.
Suitable
precautions
include:
covering
wood
with
plastic
or
other
impervious
covering,
installation
of
berms
and
placement
of
plastic
under
the
wood
to
prevent
surface
water
runoff
away
from
the
storage
area."

II.
Ecological
Toxicity
Data
The
toxicity
endpoints
presented
below
are
based
on
the
results
of
ecotoxicity
studies
submitted
to
EPA
to
meet
the
Agency
=

s
data
requirements
for
the
uses
of
2­
phenylphenol
and
salts,
as
well
as
several
studies
obtained
using
EPA's
ECOTOX
database.
Since
the
salts
are
the
more
soluble
forms
of
2­
phenylphenol,
data
on
these
will
suffice
to
address
toxicity
on
2­
phenylphenol.

A.
Toxicity
to
Terrestrial
Animals
(
1)
Birds,
Acute
and
Subacute
In
order
to
establish
the
toxicity
of
2­
phenylphenol
to
avian
species,
the
Agency
required
an
acute
oral
toxicity
study
using
the
TGAI.
The
preferred
test
species
is
either
mallard
duck
(
a
waterfowl)
or
bobwhite
quail
(
an
upland
game
bird).
The
results
of
one
toxicity
study
are
provided
in
the
following
table
(
Table
1).

Table
1.
Acute
Oral
Toxicity
of
2­
phenylphenol
to
Birds
Species
%
Active
Ingredient
(
ai)
Endpoint
(
mg/
kg)
Toxicity
Category
(
TGAI)
Satisfies
Guidelines/
Comments
Reference
Mallard
(
Anas
platyrhynchos)
Orthophenylphenol
(
99.2%)
LD50
>
2250
mg
ai/
kg;
NOEL
=
2250
mg
ai/
kg
Practically
nontoixc
Yes
MRID
#
160150
(
Grimes,
1986b)

Northern
bobwhite
(
Colinus
virginianus)
Sodium
2­
phenylphenol,
75.9%
LD50
=
1000
mg
ai/
kg)
NOEL
=
62.5
mg
ai
/
kg)
Slightly
toxic
Yes
$
core
study
$
14­
day
test
duration
$
NOEL
based
on
reduced
body
weight
and
feed
consumption
MRID
#
42500204
(
Campbell
and
Jaber,
1992)
4
The
results
indicate
that
2­
phenylphenol
is
slightly
toxic
to
avian
species
on
an
acute
oral
basis.
The
studies
are
acceptable
and
fulfill
guideline
requirements
(
71­
1/
OPPTS
850.2100).

A
subacute
dietary
study
using
the
TGAI
may
be
required
on
a
case­
by­
case
basis
depending
on
the
results
of
lower­
tier
ecological
studies
and
pertinent
environmental
fate
characteristics
in
order
to
establish
the
toxicity
of
a
chemical
to
avian
species.
This
testing
was
required
for
the
wood
preservation
use
of
2­
phenylphenol.
Results
of
these
studies
are
provided
in
Table
2.

Table
2.
Subacute
Dietary
Toxicity
of
2­
phenylphenol
to
Birds
Species
%
Active
Ingredient
(
ai)
Endpoint
(
ppm)
Toxicity
Category
Satisfies
Guidelines/
Comments
Reference
Mallard
duck
(
Anas
platyrhynchos)
Orthophenylphenol
(
99.2%)
LC50
>
5620
ppm;
NOEC
=
3160
ppm
Practically
nontoxic
Yes
NOEC
based
on
reduction
in
body
weight
gain
at
higher
test
levels
MRID#
160151
(
Grimes,
1986c).

Bobwhite
quail
(
Colinus
virginianus)
Orthophenylphenol
(
99.2%)
LC50
>
5620
ppm;
NOEC
=
3160
ppm
Practically
nontoxic
Yes
NOEC
based
on
reduction
in
body
weight
gain
at
higher
test
levels
MRID
#
160149
(
Grimes,
1986a)

Bobwhite
quail
(
Colinus
virginianus)
sodium
2­
phenylphenate,
75.9%
ai
LC50
>
5620
ppm
ai
NOEC
=
5620
ppm
ai
Practically
nontoxic
Yes
42500205
(
Campbell
and
Lynn,
1992)

Mallard
duck
(
Anas
platyrhynchos)
sodium
2­
phenylphenate,
75.9%
ai
LC50
>
5620
ppm
ai
NOEC
1780
ppm
ai
Practically
nontoxic
(
TGAI)
Yes
NOEC
based
on
reduction
in
body
weight
gain
42500206
(
Campbell
and
Jaber,
1992)

The
results
indicate
that
2­
phenylphenol
is
practically
non­
toxic
to
avian
species
on
a
subacute
dietary
basis.
The
studies
are
all
acceptable
and
fulfill
guideline
requirements
(
71­
2/
OPPTS
850.2200).

(
2)
Mammals,
Acute
and
Chronic
Toxicity
Wild
mammal
testing
was
not
required
by
the
Agency.
In
most
cases,
mammalian
toxicity
values
obtained
from
studies
conducted
to
support
data
requirements
for
human
health
risk
assessments
substitute
for
wild
mammal
testing.
These
toxicity
values
are
reported
below
(
Table
3).
Further
information
on
the
mammalian
toxicology
of
2­
phenylphenol
may
be
found
in
the
Toxicology
Disciplinary
Chapter
of
this
RED
document.

Table
3.
Acute
Mammalian
Toxicity
Profile
for
2­
Phenylphenol
and
Salts
5
Guideline
Number
Study
Type/
Test
substance
(%
a.
i.)
MRID
Number/
Citation
Results
Toxicity
Category
870.1100
(
§
81­
1)
Acute
Oral
Toxicity
­
Rat
2­
phenylphenol,

purity
99.9%
43334201
LD50
=
2733
mg/
kg
III
870.1100
(
§
81­
1)
Acute
Oral
Toxicity
­
Rat
2­
phenylphenol,

sodium
salt
purity
99.1%
433342402
LD50
=
846
mg/
kg
(
male)
LD50
=
591
mg/
kg
(
female)
III
870.1200
(
§
81­
2)
Acute
Dermal
Toxicity
NS
NS
­­­

870.1300
(
§
81­
3)
Acute
Inhalation
Toxicity
NS
NS
­­­

870.2400
(
§
81­
4)
Acute
Eye
Irritation
NS
NS
­­­

870.2500
(
§
81­
5)
Acute
Dermal
Irritation­
Rabbit
2­
phenylphenol
purity
99.9%
43334202
Dermal
irritant
I
870.2600
(
§
81­
6)
Dermal
Sensitization
­
Guinea
pig
2­
phenylphenol,

purity
99.9%
43334203
Non
sensitizer.
NA
870.2600
(
§
81­
6)
Dermal
Sensitization
­
Guinea
pig
2­
phenylphenol,

sodium
salt
purity
99.1%
43334205
Non
sensitizer.
NA
NS
=
Not
submitted
NA
=
Not
applicable
Acute
Toxicity:
2­
phenylphenol
has
a
moderate
order
of
acute
toxicity
via
the
oral
route
of
exposure
(
toxicity
Category
III).
For
dermal
irritation,
2­
phenylphenol
and
its
sodium
salts
are
severe
(
toxicity
Category
I)
and
moderate
to
severe
(
Toxicity
Category
II)
irritants,
respectively.
2­
Phenylphenol
and
its
sodium
salts
are
not
dermal
sensitizers.

Reproductive
Toxicity:
A
two
generation
reproductive
toxicity
study
was
conducted
on
Sprague­
Dawley
rats
(
MRID#:
43928801).
The
parental/
offspring
LOAEL
is
500
mg/
kg/
day.
No
treatment­
related
reproductive
toxicity
occurred
in
male
or
female
rats;
hence
the
parental/
offspring
reproductive
NOAEL
is
greater
than
or
equal
to
500
mg/
kg/
day.

Chronic
Toxicity:
A
chronic
dog
study
(
MRID#:
41656401)
on
99.77%
OPP
estimates
the
systemic
toxicity
NOAEL
of
100
mg/
kg/
day
and
systemic
toxicity
LOAEL
of
300
mg/
kg/
day.
6
B.
Toxicity
to
Aquatic
Animals
(
1)
Freshwater
Fish,
Acute
In
order
to
establish
the
acute
toxicity
of
pesticides
to
freshwater
fish,
the
Agency
requires
freshwater
fish
toxicity
studies
using
the
TGAI.
The
preferred
test
species
are
rainbow
trout
(
a
coldwater
fish)
and
bluegill
sunfish
(
a
warmwater
fish).
Results
of
submitted
studies
are
presented
in
Table
4.

Table
4.
Acute
Toxicity
of
2­
phenylphenol
to
Freshwater
Fish
Species
%
Active
Ingredient
(
ai)
Endpoints
(
ppm)
Toxicity
Category
Satisfies
Guidelines/
Comments
Reference
Rainbow
Trout
(
Oncorhynchus
mykiss)
orthophenyl
phenol,
95%
96­
hr
LC50
=
2.75
mg/
L
Moderately
Toxic
Supplemental
­
only
10
fish
used
Bentley,
1975
Fathead
minnow
(
Pimephales
promelas)
orthophenyl
phenol
96­
hr
LC50
=
3.40
mg/
L
Moderately
Toxic
No
­
from
literature,
insufficient
details
to
evaluate
per
Guidelines
requirements
Broderius
et
al.,
1995
Fathead
minnow
(
Pimephales
promelas)
Orthopheny
lphenol
(
99.25%
a.
i.)
96­
hour
LC50
=
4.7
(
3.6
 
6.0)
mg/
L
;
NOEC
<
2.6
mg/
L
Moderately
Toxic
Yes
NOEC
based
on
mortality
MRID#
156044
(
Dill
et
al.,
1985)

Bluegill
sunfish
(
Lepomis
macrochirus)
Orthopheny
lphenol
(
99.25%
a.
i.)
96­
hr
LC50
=
4.6
(
4.4­
4.9)
mg/
L;
NOEC
=
3.2
mg/
L
Moderately
Toxic
Yes
NOEC
based
on
abnormal
swimming/
immobilizat
ion
MRID#
156044
(
Dill
et
al.,
1985)

Rainbow
Trout
(
Oncorhynchus
mykiss)
Orthopheny
lphenol
(
99.25%
a.
i.)
96­
hr
LC50
=
4.0
(
3.6
 
4.5)
mg/
L;
NOEC
=
1.8
mg/
L
Moderately
Toxic
Yes
NOEC
based
on
melanization
of
fish
at
next
higher
test
level
MRID#
156044
(
Dill
et
al.,
1985)

Bluegill
sunfish
(
Lepomis
macrochirus)
orthophenyl
phenol,
95%
96­
hr
LC50
=
2.74
mg/
L
Moderately
Toxic
Supplemental
­
only
10
fish
used
Bentley,
1975
(
MRID#
110232)

Bluegill
sunfish
(
Lepomis
macrochirus)
Sodium­
ophenylphen
ate,
97%
96­
hr
LC50
=
6.2
mg/
L
Moderately
Toxic
No
­
supplemental
study
McCann
(
Beltsville
ABL
study)

These
supplemental
data
indicate
that
orthophenylphenol
and
its
sodium
salt
are
moderately
toxic
to
freshwater
fish.
The
guideline
requirements
for
freshwater
fish
acute
studies
(
850.1075/
72­
1a
and
c)
have
been
fulfilled.
7
(
2)
Freshwater
Invertebrates,
Acute
The
Agency
requires
a
freshwater
aquatic
invertebrate
toxicity
study
using
the
TGAI
to
establish
the
acute
toxicity
of
a
pesticide
to
freshwater
invertebrates.
The
preferred
test
species
is
Daphnia
magna.
Results
of
studies
for
orthophenylphenol
and
its
sodium
salt
are
provided
in
the
following
table
(
Table
5).

Table
5.
Acute
Toxicity
of
2­
phenylphenol
to
Freshwater
Invertebrates
Species
Active
Ingredient
Endpoints
(
ppm)
Toxicity
Category
Satisfies
Guidelines/
Comments
Reference
Waterflea
(
Daphnia
magna)
Sodium
2­
phenylphenate,
97%
48­
hr
EC50
=
3.8
ppm
(
3.1
­
4.6);
NOEC
<
0.56
ppm
moderately
toxic
Yes
MRID
#
110222
Batchelder
and
McCarty,
1977
Waterflea
(
Daphnia
magna)
Sodium
2­
phenylphenate
48h
EC50
=
3.2;
NOEC
=
1.6
Moderately
toxic
No
 
published
data,
insufficient
information
to
evaluate
per
Guidelines
Davoren
and
Fogarty,
2005
Waterflea
(
Daphnia
magna)
orthophenylphenol
48h
EC50
=
1.5
(
1.0­
2.4)
mg/
L;
NOEC
=
0.38
mg/
L
Moderately
toxic
No
 
published
data,
insufficient
information
to
evaluate
per
Guidelines
Kuhn
et
al.,
1989
Waterflea
(
Daphnia
magna)
Orthophenylphenol
(
99.25%)
48­
h
EC50
=
2.51
(
2.2
 
2.9)
mg/
L;
NOEC
=
0.78
mg/
L
Moderately
Toxic
Yes
NOEC
based
on
mortality
MRID
#
156044
(
Dill
et
al.,
1985)

The
results
of
this
study
indicate
that
sodium
2­
phenylphenate
is
moderately
toxic
to
freshwater
invertebrates.
The
guideline
requirement
(
850.1010/
72­
2)
has
been
fulfilled
(
MRID#
156044
and
ACC.

(
3)
Estuarine
and
Marine
Organisms,
Acute
Acute
toxicity
testing
with
estuarine
and
marine
organisms
using
the
TGAI
is
required
when
the
end­
use
product
is
intended
for
direct
application
to
the
marine/
estuarine
environment
or
effluent
containing
the
active
ingredient
is
expected
to
reach
this
environment.
Since
2­
phenylphenol
and
salts
are
used
as
wood
preservative
products
(
antisapstain
treatment),
there
is
potential
for
these
chemicals
to
reach
marine/
estuarine
environments
through
runoff
from
treatment
facilities
or
use
of
the
treated
wood
in
aquatic
habitats.
This
testing
(
72­
3/
850.1075,
850.1035/
1045,
and
850.1025/
1055)
is
therefore
required.
No
studies
on
this
topic
have
been
submitted
to
support
the
antisapstain
use
of
this
chemical.
One
study
found
in
the
open
literature
indicates
that
clam
eggs
were
able
to
develop
normally
at
up
to
5.0
ppm
Dowicide
A
Antimicrobial
(
a
sodium
2­
8
phenylphenate
product)
(
Davis,
1961),
but
the
study
did
not
determine
a
numerical
endpoint
(
EC50
or
LC50)
which
could
be
used
to
calculate
a
risk
quotient.

(
4)
Aquatic
Organisms,
Chronic
Chronic
toxicity
testing
(
Fish
early
life
stage,
850.1300/
72­
4a
and
aquatic
invertebrate
life
cycle,
850.1400/
72­
4b)
using
the
technical
grade
of
the
active
ingredient
are
required
for
a
pesticide
when
it
may
be
applied
directly
to
water
or
if
the
end­
use
product
is
expected
to
be
transported
to
water
from
the
intended
use
site,
and
any
of
the
following
conditions
are
met:
(
1)
the
pesticide
is
intended
for
use
such
that
its
presence
in
water
is
likely
to
be
continuous
or
recurrent
regardless
of
toxicity,
(
2)
any
aquatic
acute
LC50
or
EC50
is
less
than
1
mg/
l,
(
3)
the
EEC
in
water
is
equal
to
or
greater
than
0.01
of
any
acute
LC50
or
EC50
value,
or,
(
4)
the
actual
or
estimated
environmental
concentration
in
water
resulting
from
use
is
less
than
0.01
of
any
acute
LC50
or
EC50
value
and
any
one
of
the
following
conditions
exist:
studies
of
other
organisms
indicate
the
reproductive
physiology
of
fish
or
invertebrates
may
be
affected,
physicochemical
properties
indicate
cumulative
effects,
or
the
pesticide
is
persistent
in
water
(
e.
g.,
half­
life
greater
than
4
days).
The
preferred
test
species
are
rainbow
trout
(
Oncorhynchus
mykiss)
and
water
flea
(
Daphnia
magna),
but
other
species
may
be
used.
The
antisapstain
use
of
2­
phenylphenol
and
salts
is
likely
to
result
in
continuous
or
repeated
presence
in
water,
so
this
testing
(
850.1300/
72­
4a
and
850.1400/
72­
4b)
is
required
to
support
the
wood
preservative
use.
No
data
on
these
topics
have
been
submitted
to
the
Agency
C.
Toxicity
to
Plants
To
support
outdoor
uses
of
2­
phenylphenol
(
e.
g.,
antisapstain
wood
preservation),
Tier
II
(
doseresponse
toxicity
testing
with
terrestrial
and
aquatic
plants
is
required.
For
terrestrial
plants,
seedling
emergence
and
vegetative
vigor
tests
are
required
on
rice
(
Oryza
sativa)
(
Guidelines
850.4225
and
850.4250).
For
aquatic
plants,
testing
on
one
vascular
plant
species
(
preferably
the
duckweed,
Lemna
gibba),
and
four
alga
species
(
freshwater
green
alga,
blue­
green
alga,
freshwater
diatom,
and
marine
diatom)
is
required
(
Guidelines
850.4400
and
850.5400).

Terrestrial
plant
testing
has
not
been
submitted
for
2­
phenylphenol
and
salts.
This
data
is
required
to
support
the
antisapstain
wood
preservation
use
of
these
chemicals.

One
alga
test
has
been
submitted
and
reviewed
by
the
Agency.
The
results
of
this
test
are
provided
in
Table
6,
below.

Table
6.
Acute
Toxicity
of
2­
phenylphenol
to
Aquatic
Plants
Species
Active
Ingredient,
%
ai
Endpoints
(
ppm)
Satisfies
Guidelines/
comm
ents
Reference
Freshwater
green
alga,
Selenastrum
2­
phenylphenol,
99.91
%
96­
h
cell
density
EC50
1.39
mg/
L
­
Core
study.
­
NOEC
based
on
MRID
45688201
9
capricornutum
NOEC
0.432
mg/
L
inhibition
of
cell
growth.

This
study
is
scientifically
sound
and
was
conducted
in
accordance
with
Guideline
requirements.
The
data
requirement
for
aquatic
plant
testing
is
not
fulfilled,
however,
as
testing
with
the
remaining
four
required
species
has
not
been
submitted.
These
data
are
required
to
support
the
antisapstain
use
of
2­
phenylphenol
and
salts
(
850.4400
and
850.5400).
10
III.
Environmental
Fate
and
Exposure
Assessment
A.
Environmental
Fate
Assessment
Summary
(
excerpted
from
the
Environmental
Fate
Science
Chapter,
of
this
RED
document)

2­
phenylphenol
(
orthophenylphenol)
is
stable
and
persistent
in
abiotic
aqueous
medium
at
pHs
5,
7
and
9.
It
degrades
completely
in
14
days
when
exposed
to
sunlight
and
is
therefore
photolytically
unstable
in
neutral
aqueous
medium.
When
exposed
to
UV
light
(
253.7
nm),
it
degrades
into
phenyl
benzoquinone,
pehnylhydroquinone,
and
2­
hydroxy
benzofuran.
Its
half
life
(
measured
against
hydroxyl
radical)
is
14
hours,
and
it
is
unstable
in
the
atmosphere.
It
has
a
high
KOC
value
of
10,000,
and
is
immobile
in
soils.
It
is
not
likely
to
migrate
into
ground
water.
Its
major
degradation
pathway
appears
to
be
through
biodegradation
under
aerobic
and
anaerobic
conditions.
The
observed
half
lives
of
2­
phenylphenol
vary
from
a
few
hours
to
three
weeks.

B.
Environmental
Exposure
Assessment
1.
Indoor
Uses
Most
uses
of
2­
phenylphenol
are
considered
to
be
indoor
uses.
The
discharge
of
any
effluents
which
might
contain
2­
phenylphenol
residues
is
regulated
by
the
NPDES
program;
facilities
discharging
any
such
effluents
are
required
to
have
an
NPDES
permit
prior
to
discharging
effluents
into
receiving
waters.
EPA/
ORD/
NRML's
Treatability
Database
shows
that
wastewater
treatment
technologies
have
a
95%
removal
efficiency
for
phenolic
compounds.
This,
coupled
with
2­
phenylphenol's
tendency
to
degrade
under
aerobic
and
anaerobic
conditions
in
the
environment,
indicates
that
environmental
exposure
from
the
indoor
uses
of
2­
phenylphenol
is
likely
to
be
low.

2.
Antisapstain
Uses
No
model
is
available
to
estimate
the
exposure
to
terrestrial
wildlife
from
the
use
of
2­
phenylphenol­
treated
wood.
It
is
assumed
that
risk
to
aquatic
organisms
from
runoff
of
2­
phenylphenol
from
antisapstain
treating
facilities
is
the
greater
concern
from
this
use
of
2­
phenylphenol;
therefore,
the
risk
assessment
for
the
antisapstain
uses
of
2­
phenylphenol
focuses
on
aquatic
organisms.

Runoff
concentrations
of
sodium
phenylphenol
(
SOPP)
were
estimated
for
facilities
that
treat
wood
with
antisapstain
chemicals
containing
SOPP.
The
concentrations
were
estimated
using
an
approach
developed
to
determine
runoff
concentrations
of
pesticides
from
antisapstain
facilities
in
British
Columbia,
Canada
(
Krahn
and
Strub,
1990).
Krahn
and
Strub
used
the
following
equation
to
determine
leaching
behavior
for
a
rainfall
event:

D
C
C
leachate
runoff
=
Eq.
1
where:
11
Crunoff
=
Concentration
of
chemical
in
runoff
from
the
facility
(
ppm)
Cleachate
=
Concentration
of
chemical
in
leachate
(
i.
e.,
the
rainwater
dripping
directly
off
the
wood
(
ppm)
D
=
Dilution
Factor
(
unitless)

Use
of
this
equation
implies
that
the
leachate
concentration
is
directly
proportional
to
the
runoff
concentration,
regardless
of
the
rainfall
intensity
or
duration.
The
methods
for
determining
Cleachate
and
D
are
discussed
below.
The
following
general
assumptions
were
made
in
estimating
Crunoff:

 
Softwood
lumber
is
being
treated
at
the
facility
with
a
4%
solution
of
SOPP.
 
Wood
is
stored
in
a
manner
similar
to
that
described
in
Krahn
and
Strub
(
1990)
(
i.
e.,
wood
is
stored
outdoors,
stacked
into
lumber
packages
24"
x
48"
x
16')
 
Precipitation
in
British
Columbia
is
similar
to
that
experienced
in
the
United
States.
 
Krahn
and
Strub
(
1990)
measured
the
dilution
rates
of
runoff
at
a
British
Columbian
antisapstain
facility.
It
is
assumed
that
these
dilution
rates
are
similar
to
the
rates
for
facilities
in
the
United
States.

Krahn
and
Strub
(
1990)
suggest
calculating
the
leachate
concentration
using
the
following
equation:

 
=
=
16
1
16
i
i
leachate
C
C
Eq.
2
where:

Cleachate
=
Concentration
of
chemical
in
leachate
(
ppm)
Ci
=
Concentration
from
a
leaching
study
associated
with
leaching
cycle
i.

Use
of
this
equation
implies:

 
The
lumber
yard
consists
of
wood
of
various
ages.
For
any
given
storage
yard,
the
inventory
can
be
split
into
16
sections.
Prior
to
any
rain
event,
1/
16th
of
the
yard
inventory
has
never
been
exposed
to
rain,
1/
16th
of
the
yard
inventory
has
been
exposed
to
1
rain
event,
1/
16th
of
the
yard
inventory
has
been
exposed
to
2
rain
events,
etc.
 
Leaching
data
are
available
for
a
given
chemical.
Krahn
and
Strub
(
1990)
describe
a
study
protocol
that
can
be
used
to
obtain
such
data,
and
it
is
assumed
that
the
leachate
concentrations
that
can
be
generated
using
the
Krahn
and
Strub
protocol
would
work
in
conjunction
with
Equation
2
to
give
a
reliable
estimate
of
Cleachate.

A
leaching
study
following
the
Krahn
and
Strub
(
1990)
protocol
was
not
performed
for
SOPP;
however,
Dow
has
submitted
a
leaching
study
following
a
different
method
(
Davis
12
and
Gonsior,
2005).
In
order
to
use
Equation
2,
the
data
from
the
Dow
study
have
been
used
to
predict
the
Ci
values
that
would
be
determined
if
a
study
were
to
follow
the
Krahn
and
Strub
(
1990)
protocol.

In
the
Dow
study,
small
samples
of
wood
(
southern
yellow
pine
sapwood)
were
immersed
in
a
SOPP
solution
for
one
minute.
The
samples
included
9
blocks
treated
with
a
4%
SOPP
solution
(
0.2785
g/
block)
and
9
blocks
treated
with
a
1%
solution
(
0.2737
g/
block).
After
dipping,
the
samples
were
dried
for
24
hours,
and
immersed
in
deionized
water
(
leaching
water)
for
14
days
with
slow
mixing.
Samples
were
grouped
into
sets
of
three
(
i.
e.,
3
sets
for
1%
and
3
sets
for
4%
solution)
and
each
set
was
placed
in
75­
mL
of
leaching
water.
Leachate
was
collected
and
replaced
with
clean
water
after
1
hour,
5
hours,
and
after
days
1,
2,
3,
5,
7,
9,
and
14.
The
collected
leachate
was
analyzed
for
SOPP.

For
the
purposes
of
this
model,
it
is
conservatively
assumed
that
the
wood
in
a
lumber
yard
will
be
treated
with
a
4%
SOPP
solution.
Results
of
the
test
for
4%
solution
are
shown
in
Table
7.
The
sample
blocks
leached
52%
of
the
original
quantity
of
chemical
applied
after
one
day
of
leaching,
and
78%
after
day
14.

Table
7.
Leaching
Rates
for
Wood
Treated
with
4%
SOPP
Solution
Day
SOPP
Leached
(
Cumulative,
µ
g)
Quantity
Remaining
on
Samples
(
µ
g)
Fraction
of
Chemical
Leached
Fraction
of
Chemical
Remaining
0
­­
24,300
0.00
1.00
0.04
6,440
17,800
0.265
0.735
0.21
9,670
14,600
0.398
0.602
1
12,500
11,800
0.515
0.485
2
14,400
9,850
0.594
0.406
3
15,700
8,580
0.647
0.353
5
16,900
7,410
0.695
0.305
7
17,700
6,530
0.731
0.269
9
18,400
5,880
0.758
0.242
14
19,000
5,230
0.784
0.216
Source:
Davis
and
Gonsior
(
2005)

Krahn
and
Strub
(
1990),
in
their
protocol
for
a
leaching
study,
suggest
that
16
leaching
cycles
be
applied
at
a
rate
of
15
mm/
day
every
other
day,
with
each
rain
duration
lasting
5
hours
and
a
target
intensity
of
3
mm/
hr.
These
values
are
based
on
the
average
precipitation
that
occurs
in
British
Columbia
in
the
worst­
case
month
of
the
year.
The
treated
samples
should
be
stacked
into
lumber
packages
of
0.61
m
x
1.22
m
x
4.88
m.
These
packages
are
to
be
placed
over
a
leachate
collection
tray
(
1.52
m
x
5.2
m).
In
contrast,
the
SOPP
leaching
study
was
performed
over
14
days
of
continuous
leaching,
using
much
smaller
samples
(
19
mm
x
19
mm
x
19
mm).
In
order
to
reconcile
these
two
approaches,
some
assumptions
were
made:

 
Each
cycle,
as
defined
by
Krahn
and
Strub
(
1990),
is
assumed
to
correspond
to
a
5­
hour
period
of
leaching
in
the
Dow
study.
Therefore,
16
cycles
of
leaching
corresponds
to
16x5=
80
hours
of
the
Dow
study.
The
fraction
of
chemical
13
remaining
on
wood
at
any
given
time
was
determined
by
linearly
interpolating
between
the
values
shown
in
Table
10
for
"
Fraction
Remaining".
 
It
is
assumed
that
leaching
in
a
lumber
yard
occurs
at
the
surface
of
the
wood,
no
deeper
than
the
thickness
of
the
Dow
study
samples
(
19
mm).
Chemical
product
that
is
initially
located
in
the
wood
beneath
this
surface
thickness
is
assumed
to
be
permanently
fixed
for
the
16
leaching
cycles.
 
It
is
conservatively
assumed
that
the
rates
of
leaching
in
both
the
Dow
study
samples
and
in
a
real
lumber
yard,
as
measured
in
terms
of
mass
of
chemical
per
volume
of
leachable
wood
(
Qi
in
Equation
8),
are
identical.

Based
on
these
assumptions,
the
following
equations
were
derived:

leachate
wood
i
i
V
V
Q
C
=
Eq.
3
where:

Ci
=
Concentration
of
leachate
during
leaching
cycle
i
Qi
=
Rate
of
leaching
from
wood
(
mg/
cm3
wood),
during
leaching
cycle
i
Vwood
=
Volume
of
leachable
wood
in
one
lumber
pile
(
i.
e.,
the
19
mm
of
wood
at
the
surface)
Vleachate
=
Volume
of
leachate
associated
with
one
lumber
pile
Calculations
for
a
number
of
parameters,
including
Ci,
are
shown
in
Tables
8
and
9.
Using
the
Ci
values
in
Table
9
in
conjunction
with
Equation
2,
Cleachate
was
estimated
to
be
127
ppm.

Table
8.
Miscellaneous
Calculations
for
Leaching
Studies
Parameter
Value
Rationale
Volume
of
sample
blocks
6.86
cm3/
sample
Surface
area
of
sample
blocks
21.7
cm2/
sample
Blocks
are
19
mm
cubes
(
Davis
and
Gonsior,
2005)
Dow
Quantity
of
chemical
used
to
treat
each
sample
(
for
samples
treated
with
4%
SOPP)
8.09
mg/
sample
Davis
and
Gonsior
(
2005)
measured
24,270
µ
g
SOPP
in
a
three­
sample
set.
Dimensions
of
wood
(
width,
height,
length)
0.61
m
x
1.22
m
x
4.88
m
per
lumber
package
Krahn
and
Strub
(
1990)

Surface
area
of
leachable
wood
16.4
m2/
package
All
surfaces
except
the
bottom
will
be
exposed
to
rainwater
Volume
of
leachable
wood
3.11x105
cm3/
package
It's
assumed
that
leachable
wood
is
wood
that
is
19
mm
from
the
surface
that
is
exposed
to
rainwater.
As
an
approximation,
this
is
equivalent
to
SAleachable
x19mm.
1.19x105
cm3/
package
Krahn
and
Strub
(
1990)

Protocol
Quantity
of
leachate
collected
per
lumber
package
119
L/
package
The
standard
leachate
collection
tray
is
1.52
m
x
5.2
m.
15
mm/
day
of
rain
is
collected.
14
Table
9.
Using
Dow
Study
Data
(
Davis
and
Gonsior,
2005)
to
Estimate
Results
for
a
Study
Following
Krahn
and
Strub
(
1990)

Protocol
Dow
Study
(
Davis
and
Gonsior,
2005)
Krahn
and
Strub
(
1990)
Protocol
Leaching
Cycle
Hours
of
Leachinga
Days
of
Leaching
Fraction
Remaining
in
Woodb
Cumulative
Fraction
Leachedc
Fraction
Leached
Since
Previous
Cycled
Mass
Leached
per
Cycle
per
Volume
of
Woode
(
mg/
cm3)
Mass
Leached
in
Lumber
Packagef
(
mg/
package)
Concentration
of
Leachate
(
Ci)
g
(
mg/
L)

1
5
0.208
0.603
0.397
0.397
0.468
1.46x105
1,230
2
10
0.417
0.571
0.429
0.0317
0.0374
11,600
98.2
3
15
0.625
0.540
0.460
0.0307
0.0362
11,300
94.9
4
20
0.833
0.510
0.490
0.0307
0.0362
11,300
94.9
5
25
1.04
0.482
0.518
0.0278
0.0328
10,200
86.2
6
30
1.25
0.465
0.535
0.0166
0.0195
6,080
51.2
7
35
1.46
0.449
0.551
0.0166
0.0195
6,080
51.2
8
40
1.67
0.432
0.568
0.0166
0.0195
6,080
51.2
9
45
1.88
0.416
0.584
0.0166
0.0195
6,080
51.2
10
50
2.08
0.401
0.599
0.0143
0.0169
5,250
44.2
11
55
2.29
0.391
0.609
0.0109
0.0129
4,000
33.7
12
60
2.50
0.380
0.620
0.0109
0.0129
4,000
33.7
13
65
2.71
0.369
0.631
0.0109
0.0129
4,000
33.7
14
70
2.92
0.358
0.642
0.0109
0.0129
4,000
33.7
15
75
3.12
0.350
0.650
0.00737
0.00870
2,710
22.8
16
80
3.33
0.345
0.655
0.00502
0.00592
1,840
15.5
aBased
on
assumption
that
one
leaching
cycle
in
the
Krahn
and
Strub
protocol
corresponds
to
5
hours
of
leaching
in
the
Dow
study.

bValues
were
linearly
interpolated
from
Davis
and
Gonsior
(
2005).
Refer
to
the
column
"
Fraction
of
Chemical
Remaining"
in
Table
7.

cCumulative
Fraction
Leached
=
1
 
Fraction
Remaining
in
Wood
dFraction
Leached
Since
Previous
Cycle
is
the
difference
between
the
cumulative
fraction
leached
between
the
current
and
previous
cycles.

eMass
leached
=
Mass
of
chemical
applied
(
8.09
mg/
sample)
x
Fraction
Leached
Since
Previous
Cycle
/
Volume
of
Sample
Blocks
(
6.86
cm3/
sample).

fEstimated
mass
leached
from
lumber
packages
in
Krahn
and
Strub
protocol
=
Volume
of
leachable
wood
(
311,000
cm3/
package)
*
Mass
Leached
per
Cycle
per
Volume
(
mg/
cm3).
See
Table
2
for
calculation
of
the
volume
of
leachable
wood.

gConcentration
of
Leachate
in
Krahn
and
Strub
protocol
=
Mass
Leached
from
Lumber
Packages
/
Quantity
of
leachate
(
119
L/
package).
See
Table
8
for
calculation
of
the
quantity
of
leachate.
15
Dilution
Factor
Krahn
and
Strub
(
1990)
assume
that
leachate
entering
the
storm
drain
is
diluted
with
extra
runoff
water
at
a
1:
15
ratio.
This
is
based
on
measurements
of
runoff
in
storm
drains
at
facilities
using
antisapstain
chemicals
in
British
Columbia.
Use
of
the
ratios
1:
6
and
1:
23
were
also
suggested
by
Krahn
and
Strub
(
1990)
to
determine
a
"
general
industry
wide"
predicted
runoff
concentration.
These
values
were
used
in
this
assessment.
The
estimated
leachate
concentration
(
126.6
ppm)
was
used
in
conjunction
with
these
dilution
factors
to
estimate
runoff
concentrations
(
Table
10).

Table
10.
Estimated
Runoff
Concentrations
Parameter
Dilution
Factor
Estimated
Runoff
Concentration
(
ppm)
a
High­
end
dilution
23
5.50
Typical
dilution
15
8.44
Low­
end
dilution
6
21.1
aEstimated
Runoff
Concentration
=
Estimated
Leachate
Concentration
(
138
ppm)
/
Dilution
Factor
SOPP
is
believed
to
be
stable
to
hydrolysis
under
normal
environmental
conditions
(
Davis
and
Gonsior,
2005).
Therefore,
modeling
did
not
account
for
degradation
of
the
chemical
via
hydrolysis.

Uncertainties
and
Limitations
 
Krahn
and
Strub
(
1990)
note
that
the
concentrations
of
antisapstain
chemical
in
runoff
will
be
affected
by
numerous
variables,
including:
chemical
formulation,
chemical
retention
in
wood,
rough
vs.
planed
lumber
cut,
lumber
packaging
and
stacking,
drying
time
prior
to
exposure
to
precipitation,
precipitation
duration,
precipitation
intensity,
precipitation
frequency,
precipitation
pH,
quantity
of
treated
lumber
on
the
storage
site,
species
of
lumber
treated,
general
house
keeping
practices,
whether
the
lumber
is
1st,
2nd,
or
3rd
growth,
solubility
of
the
chemical
in
water,
diffusion
of
the
chemical
into
the
wood,
additives
in
the
formulations,
exposure
and
degradation
due
to
ultraviolet
light,
microbial
action,
ambient
temperatures,
and
affinity
of
the
chemical
to
soils
and
to
yard
surfaces.
 
Information
regarding
the
leaching
behavior
of
SOPP­
treated
wood
is
limited.
It
is
unclear
how
closely
the
SOPP
leaching
study
(
Davis
and
Gonsior,
2005)
matches
the
protocol
described
by
Krahn
and
Strub
(
1990),
or
how
effectively
the
assumptions
used
in
this
report
account
for
the
differences.
 
It
was
assumed,
for
this
assessment,
that
rain
events
are
of
equal
intensity
and
duration.
Variations
in
the
intensities
and
durations
of
rain
events
would
affect
the
results.
 
Krahn
and
Strub
(
1990)
obtained
a
dilution
factor
of
15
based
on
a
study
of
antisapstain
facilities
in
British
Columbia.
The
dilution
factor
is
dependent
on
the
intensity
of
rainfall
events.
It
is
unknown
if
the
average
rainfall
intensity
in
British
Columbia
would
be
representative
of
the
average
rainfall
intensity
of
the
United
States;
however,
for
lack
of
better
data,
the
value
was
used.
16
 
Krahn
and
Strub
(
1990)
assume
that
any
batch
of
treated
wood
remains
in
the
yard
for
16
rain
cycles.
The
frequency
of
rainfall
events
in
British
Columbia
may
not
be
representative
of
the
frequency
of
rainfall
events
in
the
United
States;
therefore,
the
use
of
16
rain
cycles
may
not
be
an
accurate
description
of
treatment
facilities
in
the
United
States.

IV.
Risk
Assessment
and
Characterization
Risk
assessment
integrates
the
results
of
the
exposure
and
ecotoxicity
data
to
evaluate
the
likelihood
of
adverse
ecological
effects.
One
method
of
integrating
the
results
of
exposure
and
ecotoxicity
data
is
called
the
quotient
method.
For
this
method,
risk
quotients
(
RQs)
are
calculated
by
dividing
exposure
estimates
by
ecotoxicity
values,
both
acute
and
chronic:

RQ
=
EXPOSURE/
TOXICITY
RQs
are
then
compared
to
OPP's
levels
of
concern
(
LOCs).
These
LOCs
are
criteria
used
by
OPP
to
indicate
potential
risk
to
nontarget
organisms
and
the
need
to
consider
regulatory
action.
The
criteria
indicate
that
a
pesticide
used
as
directed
has
the
potential
to
cause
adverse
effects
on
nontarget
organisms.
LOCs
currently
address
the
following
risk
presumption
categories:
(
1)
acute
high
­
potential
for
acute
risk
is
high,
and
regulatory
action
may
be
warranted
in
addition
to
restricted
use
classification;
(
2)
acute
restricted
use
­
the
potential
for
acute
risk
is
high,
but
this
may
be
mitigated
through
restricted
use
classification;
(
3)
acute
endangered
species
­
the
potential
for
acute
risk
to
endangered
species
is
high,
and
regulatory
action
may
be
warranted;
and
(
4)
chronic
risk
­
the
potential
for
chronic
risk
is
high,
and
regulatory
action
may
be
warranted.
Currently,
AD
does
not
perform
assessments
for
chronic
risk
to
plants,
acute
or
chronic
risks
to
nontarget
insects,
or
chronic
risk
from
granular/
bait
formulations
to
mammalian
or
avian
species.

The
ecotoxicity
test
values
(
i.
e.,
measurement
endpoints)
used
in
the
acute
and
chronic
risk
quotients
are
derived
from
the
results
of
required
studies.
Examples
of
ecotoxicity
values
derived
from
the
results
of
short­
term
laboratory
studies
that
assess
acute
effects
are:
(
1)
LC50
(
fish
and
birds)
(
2)
LD50
(
birds
and
mammals)
(
3)
EC50
(
aquatic
plants
and
aquatic
invertebrates)
and
(
4)
EC25
(
terrestrial
plants).
Examples
of
toxicity
test
effect
levels
derived
from
the
results
of
long­
term
laboratory
studies
that
assess
chronic
effects
are:
(
1)
LOEC
(
birds,
fish,
and
aquatic
invertebrates)
and
(
2)
NOEC
(
birds,
fish
and
aquatic
invertebrates.
Other
values
may
be
used
when
justified.

Risk
presumptions,
along
with
the
corresponding
RQs
and
LOCs
are
tabulated
below.

Table
11:
Risk
Presumptions
for
Terrestrial
Animals
Risk
Presumption
RQ
LOC
Birds
and
Wild
Mammals
Acute
High
Risk
EEC1/
LC50
or
LD50/
sqft2
or
LD50/
day3
0.5
17
Acute
Restricted
Use
EEC/
LC50
or
LD50/
sqft
or
LD50/
day
(
or
LD50
<
50
mg/
kg)
0.2
Acute
Endangered
Species
EEC/
LC50
or
LD50/
sqft
or
LD50/
day
0.1
Chronic
Risk
EEC/
NOEC
1
1
abbreviation
for
Estimated
Environmental
Concentration
(
ppm)
on
avian/
mammalian
food
items
2
mg/
ft2
3
mg
of
toxicant
consumed/
day
LD50
*
wt.
of
bird
LD50
*
wt.
of
bird
Table
12:
Risk
Presumptions
for
Aquatic
Animals
Risk
Presumption
RQ
LOC
Acute
High
Risk
EEC1/
LC50
or
EC50
0.5
Acute
Restricted
Use
EEC/
LC50
or
EC50
0.1
Acute
Endangered
Species
EEC/
LC50
or
EC50
0.05
Chronic
Risk
EEC/
MATC
or
NOEC
1
1
EEC
=
(
ppm
or
ppb)
in
water
Table
13:
Risk
Presumptions
for
Plants
Risk
Presumption
RQ
LOC
Terrestrial
and
Semi­
Aquatic
Plants
Acute
High
Risk
EEC1/
EC25
1
Acute
Endangered
Species
EEC/
EC05
or
NOEC
1
Aquatic
Plants
Acute
High
Risk
EEC2/
EC50
1
Acute
Endangered
Species
EEC/
EC05
or
NOEC
1
1
EEC
=
lbs
ai/
A
2
EEC
=
(
ppb/
ppm)
in
water
A.
Indoor
Uses
The
low
exposure
potential
from
the
indoor
uses
of
2­
phenylphenol
and
salts,
coupled
with
the
tendency
for
the
compounds
to
degrade
under
environmental
conditions,
result
in
low
likelihood
of
adverse
acute
effects
to
wildlife
and
aquatic
organisms
from
the
indoor
uses.
18
B.
Antisapstain
uses:

The
lowest
LC50
or
EC50
values
for
each
representative
taxa
were
used
in
conjunction
with
the
estimated
runoff
concentrations
reported
in
Table
13
to
calculate
risk
quotients
(
RQs)
for
each
aquatic
taxa.
The
RQs
were
then
compared
to
Agency
levels
of
concern
(
LOCs),
as
described
above.
The
following
table
lists
the
RQs
calculated
for
various
taxa:

Table
14:
Aquatic
Organism
Risk
Quotients
for
Antisapstain
Uses
of
2­
Phenylphenol
Taxa/
Endpoint
Antisapstain
EEC:
Low
dilution
Typical
dilution
High
dilution
Antisapstain
RQ
Freshwater
fish
Acute
2.74
mg/
L
5.50
mg/
L
8.44
mg/
L
21.1
mg/
L
2.01
3.08
7.70
Freshwater
Invertebrates
Acute
1.5
mg/
L
5.50
mg/
L
8.44
mg/
L
21.1
mg/
L
3.67
5.63
14.10
Marine/
Estuarine
Fish
Acute
DATA
GAP*
5.50
mg/
L
8.44
mg/
L
21.1
mg/
L
Marine/
Estuarine
Bivalve
Acute
DATA
GAP*
5.50
mg/
L
8.44
mg/
L
21.1
mg/
L
Marine/
Estuarine
Invertebrate
Acute
DATA
GAP*
5.50
mg/
L
8.44
mg/
L
21.1
mg/
L
Green
Algae
Acute
EC50
1.39
mg/
L
5.50
mg/
L
8.44
mg/
L
21.1
mg/
L
3.96
6.07
15.18
Green
Algae
NOEC
0.432
mg/
L
5.50
mg/
L
8.44
mg/
L
21.1
mg/
L
12.73
19.54
48.84
Fish
Chronic
DATA
GAP
5.50
mg/
L
8.44
mg/
L
21.1
mg/
L
Invertebrate
Chronic
DATA
GAP
5.50
mg/
L
8.44
mg/
L
21.1
mg/
L
*
Studies
addressing
these
have
been
submitted
and
are
currently
in
review
RQs
in
bold
have
exceeded
one
or
more
LOCs.

Based
on
the
results
of
the
antisapstain
modeling,
runoff
from
antisapstain
treating
facilities
will
exceed
acute
high
risk,
restricted
use,
and
endangered
species
LOCs
for
freshwater
fish,
freshwater
invertebrates,
and
aquatic
plants.
Chronic
risks
cannot
be
assessed
at
this
time
due
to
a
lack
of
chronic
toxicity
data.
19
The
model
used
to
estimate
exposure
from
antisapstain
uses
is
intended
as
a
Tier
I
screening
model,
and,
as
such,
has
inherent
assumptions
and
uncertainties
that
may
result
in
over­
or
under­
estimation
of
exposure
levels.
Since
the
model
is
only
intended
as
a
screening­
level
model,
further
refinement
of
the
model
is
recommended
to
more
accurately
assess
risks
from
the
antisapstain
uses
of
2­
phenylphenol.
Additionally,
an
environmental
monitoring
study
of
runoff
from
antisapstain
treatment
facilities
is
needed
to
address
the
potential
risks
and
to
provide
EECs
for
use
in
a
refined
risk
assessment.

Methods
to
reduce
the
amount
of
2­
phenylphenol
potentially
released
from
antisapstain­
treated
wood
could
potentially
mitigate
the
risks.
Possible
mitigation
methods
might
include,
but
are
not
limited
to,
lowering
the
application
rate
or
requiring
specific
storage
conditions
to
prevent
exposure
of
recently
treated
wood
to
weather
(
e.
g.,
full
covering)
and/
or
prevent
the
release
of
any
associated
runoff
into
aquatic
habitats
(
e.
g.,
drip
pads).
2­
phenylphenol
is
not
very
mobile
in
soils,
so
any
2­
phenylphenol
leached
outdoors
will
likely
bind
to
soils
and
not
reach
aquatic
habitats
as
free
2­
phenylphenol.

C.
Endangered
Species
Considerations
Section
7
of
the
Endangered
Species
Act,
16
U.
S.
C.
Section
1536(
a)(
2),
requires
all
federal
agencies
to
consult
with
the
National
Marine
Fisheries
Service
(
NMFS)
for
marine
and
anadromous
listed
species,
or
the
United
States
Fish
and
Wildlife
Services
(
FWS)
for
listed
wildlife
and
freshwater
organisms,
if
they
are
proposing
an
"
action"
that
may
affect
listed
species
or
their
designated
habitat.
Each
federal
agency
is
required
under
the
Act
to
insure
that
any
action
they
authorize,
fund,
or
carry
out
is
not
likely
to
jeopardize
the
continued
existence
of
a
listed
species
or
result
in
the
destruction
or
adverse
modification
of
designated
critical
habitat.
To
jeopardize
the
continued
existence
of
a
listed
species
means
"
to
engage
in
an
action
that
reasonably
would
be
expected,
directly
or
indirectly,
to
reduce
appreciably
the
likelihood
of
both
the
survival
and
recovery
of
a
listed
species
in
the
wild
by
reducing
the
reproduction,
numbers,
or
distribution
of
the
species."
50
C.
F.
R.
'
402.02.

To
facilitate
compliance
with
the
requirements
of
the
Endangered
Species
Act
subsection
(
a)(
2)
the
Environmental
Protection
Agency,
Office
of
Pesticide
Programs
has
established
procedures
to
evaluate
whether
a
proposed
registration
action
may
directly
or
indirectly
reduce
appreciably
the
likelihood
of
both
the
survival
and
recovery
of
a
listed
species
in
the
wild
by
reducing
the
reproduction,
numbers,
or
distribution
of
any
listed
species
(
U.
S.
EPA
2004).
After
the
Agency=
s
screening­
level
risk
assessment
is
performed,
if
any
of
the
Agency=
s
Listed
Species
LOC
Criteria
are
exceeded
for
either
direct
or
indirect
effects,
a
determination
is
made
to
identify
if
any
listed
or
candidate
species
may
co­
occur
in
the
area
of
the
proposed
pesticide
use.
If
determined
that
listed
or
candidate
species
may
be
present
in
the
proposed
use
areas,
further
biological
assessment
is
undertaken.
The
extent
to
which
listed
species
may
be
at
risk
then
determines
the
need
for
the
development
of
a
more
comprehensive
consultation
package
as
required
by
the
Endangered
Species
Act.

For
certain
use
categories,
the
Agency
assumes
there
will
be
minimal
environmental
exposure,
and
20
only
a
minimal
toxicity
data
set
is
required
(
Overview
of
the
Ecological
Risk
Assessment
Process
in
the
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
­
Endangered
and
Threatened
Species
Effects
Determinations,
1/
23/
04,
Appendix
A,
Section
IIB,
pg.
81).
Chemicals
in
these
categories
therefore
do
not
undergo
a
full
screening­
level
risk
assessment,
and
are
considered
to
fall
under
a
Ano
effect@
determination.
The
active
ingredient
uses
of
2­
phenylphenol,
with
the
exception
of
the
antisapstain
wood
preservation
use,
fall
into
this
category
Using
Tier
I
screening
modeling
to
assess
potential
exposure
from
antisapstain
wood
preservation
uses
of
2­
phenylphenol,
risks
to
Listed
Species
are
indicated.
Since
the
model
is
only
intended
as
a
screening­
level
model,
and,
as
such,
has
inherent
uncertainties
and
limitations
which
may
result
in
inaccurate
exposure
estimations,
further
refinement
of
the
model
is
recommended
before
any
regulatory
action
is
taken
regarding
the
antisapstain
uses
of
2­
phenylphenol
.
An
environmental
monitoring
study
of
runoff
from
antisapstain
treatment
facilities
is
needed
to
address
the
potential
risks
and
to
provide
EECs
for
use
in
a
refined
risk
assessment.
Additionally,
impacts
from
the
antisapstain
use
could
potentially
be
mitigated
with
precautions
to
prevent
leaching
and
runoff
when
wood
is
stored
outdoors.
Due
to
these
circumstances,
the
Agency
defers
making
a
determination
for
the
antisapstain
uses
of
2­
phenylphenol
until
additional
data
and
modeling
refinements
are
available.
At
that
time,
the
environmental
exposure
assessment
of
the
antisapstain
use
of
2­
phenylphenol
will
be
revised,
and
the
risks
to
Listed
Species
will
be
reconsidered.

D.
Endocrine
Disruption
Laboratory
studies
indicate
that
2­
phenylphenol
(
aka
2­
hydroxybiphenol)
demonstrates
some
potential
to
act
as
an
endocrine
disruptor.
The
chemical
was
tested
at
EPA's
Mid­
Continent
Ecology
Division
(
MED)
for
estrogenicity
using
the
rainbow
trout
cytosol­
estrogen
receptor
competitive
binding
assay
and
male
rainbow
trout
liver
slice/
Vtg
gene
expression
assay
(
Schmieder
et
al.,
2000
and
Schmieder
et
al.,
2004).
The
results
of
the
binding
assay
indicated
that
2­
phenylphenol
bound
to
the
trout
estrogen
receptor,
but
with
relatively
low
affinity
(
0.00065%),
compared
to
3H­
estradiol.
High
levels
of
2­
phenylphenol
(­
4
log
M)
were
capable
of
inducing
expression
of
an
estrogen
regulated
gene
(
vitellogenin,
Vtg)
in
the
trout
liver
slices,
but
the
amount
of
gene
expression
was
small,
only
0.12%
of
the
maximum
expression
induced
by
estradiol.
Additionally,
published
studies
report
similar
levels
of
receptor
binding
and
estrogenic
gene
expression
by
2­
phenylphenol
in
mammalian
systems
(
Blair
et
al.,
2000;
Hu
and
Aizawa,
2003;
Miller
et
al.,
2001;
Routledge
and
Sumpter,
1997).

EPA
is
required
under
the
FFDCA,
as
amended
by
FQPA,
to
develop
a
screening
program
to
determine
whether
certain
substances
(
including
all
pesticide
active
and
other
ingredients)
"
may
have
an
effect
in
humans
that
is
similar
to
an
effect
produced
by
a
naturally
occurring
estrogen,
or
other
such
endocrine
effects
as
the
Administrator
may
designate."
Following
the
recommendations
of
its
Endocrine
Disruptor
Screening
and
Testing
Advisory
Committee
(
EDSTAC),
EPA
determined
that
there
was
scientific
basis
for
including,
as
part
of
the
program,
the
androgen
and
thyroid
hormone
systems,
in
addition
to
the
estrogen
hormone
system.
EPA
also
adopted
EDSTAC's
recommendation
that
the
Program
include
evaluations
of
potential
effects
in
wildlife.
For
pesticide
chemicals,
EPA
will
use
FIFRA
and,
to
the
extent
that
effects
in
wildlife
may
help
determine
whether
21
a
substance
may
have
an
effect
in
humans,
FFDCA
authority
to
require
the
wildlife
evaluations.
As
the
science
develops
and
resources
allow,
screening
of
additional
hormone
systems
may
be
added
to
the
Endocrine
Disruptor
Screening
Program
(
EDSP).
When
the
appropriate
screening
and/
or
testing
protocols
being
considered
under
the
Agency's
EDSP
have
been
developed,
2­
phenylphenol
may
be
subjected
to
additional
screening
and/
or
testing
to
better
characterize
effects
related
to
endocrine
disruption.

E.
Label
Hazard
Statements
and
Use
Recommendations:

2­
phenylphenol
and
salts
labels
must
state:

"
Do
not
discharge
effluent
containing
this
product
into
lakes,
streams,
ponds,
estuaries,
oceans,
or
other
waters
unless
in
accordance
with
the
requirements
of
a
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
and
the
permitting
authority
has
been
notified
in
writing
prior
to
discharge.
Do
not
discharge
effluent
containing
this
product
to
sewer
systems
without
previously
notifying
the
local
sewage
treatment
plant
authority.
For
guidance
contact
your
State
Water
Board
or
Regional
Office
of
the
EPA."

Antisapstain
labels
must
state:
"
Treated
lumber
must
not
be
stored
outdoors
without
precautions
to
prevent
to
prevent
leaching
by
rainfall
to
the
environment.
Suitable
precautions
include:
covering
wood
with
plastic
or
other
impervious
covering,
installation
of
berms
and
placement
of
plastic
under
the
wood
to
prevent
surface
water
runoff
away
from
the
storage
area."
22
IV.
REFERENCES
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T.
L.,
and
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1977.
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Chemical
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MRID
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Campbell,
S.
M.
and
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1992.
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Chemical
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MRID
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Campbell,
S.
M.,
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1992.
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phenylphenate
(
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A):
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LC50
Study
with
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Conducted
by
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International
for
the
Dow
Chemical
Co.

MRID
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M.,
and
M
Jaber.
1992.
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phenylphenate
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Chemical
Co.

MRID
45688201.
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S.
2002.
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phenyl
Phenol:
Growth
Inhibition
Test
with
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Alga,
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capricornutum.
Unpublished
data.
Conducted
by
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Laboratories
for
The
Dow
Chemical
Co.

MRID#
110232
Bentley,
R.
E.
1975.
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Toxicity
of
Dowicide
Co
to
the
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and
Rainbow
Trout.
Unpublished
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EG&
G
Environmental
Consultants
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Chemical
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MRID#
156044
Dill,
D.
C.,
D.
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Milazzo,
E.
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the
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1
Antimicrobial,
Techincal
o­
phenylphenol,
to
Representative
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ES­
811.
Unpublished
data,
performed
and
submitted
by
Dow
Chemical,
USA,
Midland,
MI.

MRID
#
160149.
Grimes,
J.
(
1986a)
Ortho­
phenylphenol
Technical:
A
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LC50
Study
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the
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Final
Report:
Project
No.
103­
246.
Un­
published
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17
p.
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by
the
Dow
Chemical
Co.,
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MRID
#
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Grimes,
J.
(
1986b)
Ortho­
phenylphenol
Technical:
An
Acute
Oral
Toxi­
city
Study
with
the
Mallard:
Final
Report:
Project
No.
103­
248.
Unpublished
study
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18
p.
Submitted
by
the
Dow
Chemical
Co.,
Midland,
MI.

MRID
#
160151.
Grimes,
J.
(
1986c)
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phenylphenol
Technical:
A
Dietary
LC50
Study
with
the
Mallard:
Final
Report:
Project
No.
103­
247.
Un­
published
study
prepared
by
Wildlife
International
23
Ltd.
18
p.
Submitted
by
the
Dow
Chemical
Co.,
Midland,
MI.

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