UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF   

PREVENTION, PESTICIDES

AND TOXIC SUBSTANCES 

		PC Code No.:	098801

DP Barcode:	336737

		Date:	Feb 27, 2007

SUBJECT:	EFED’s Responses to Phase 3 Comments for Chlorfurenol

TO:	Tracy Perry, Chemical Review Manager

	Michael Goodis, Branch Chief

Special Review and Re-registration Division (7508P)

FROM:	ERB V Team for Chlorflurenol ME:

Larry Liu, Ph.D., Chemist, Environmental Fate Reviewer

Jennifer Leyhe, M.S., Biologist, Ecological Effects Reviewer

Environmental Fate and Effects Division (7507P)

THROUGH:	Mah Shamim, Ph.D., Branch Chief

Environmental Risk Branch V

Environmental Fate and Effects Division (7507P)

This memo is in response to the Special Review and Reregistration
Division (SRRD) request for the Ecological Fate and Effects Division
(EFED) to respond Phase 3 comments for chlorflurenol.

Chlorflurenol: Phase 3 Comments

1)  Submissions from the registrant (Repar Corporation) and EFED’s
responses are presented below:

List of environmental fate and ecological effects studies (with MRIDs)
submitted to the Agency

EFED responses – 

Fate – 

The submitted list includes four environmental fate studies.  EFED has
reviewed three studies (MRIDs 43496201, 43595403, 43496202).  However,
the MRID (001208867) for the fourth study seems to be incorrect.  EFED
informed SRRD to contact the registrant on 1/17/07.  On 2/6/07, SRRD
responded that they have not heard anything from the registrant.

Eco – 

The submitted list includes nine ecotoxicology studies.  Only the first
five of those listed contain MRID numbers and/or full citations.  These
five studies (MRIDs 00119916/00120853, 43595401, 43623601, 43623602,
00140979/00120852) have been formally reviewed by EFED.  The remaining
studies listed do not include a full citation or MRID number; therefore
not enough information is presented to determine whether the study has
been submitted and reviewed.

The Photodecomposition of Flurecol-butyl

EFED responses – 

This is a publication for another chemical (flurecol-methyl).  Since
flurecol-methyl is structurally different from the major component
(2-chloro-9-hydroxyfluorene-9-carboxylate) in chlorflurenol methyl
ester, the fate of the chemical under photolysis conditions remains
unknown.  

	

Summary of Chlorflurenol Fate Data

EFED responses – 

This one-page summary contains six paragraphs (4-7 lines per paragraph
per study) to cover six very old studies.  Apparently these studies were
submitted to USDA many years ago.  Since the summary is too condensed to
be used in the risk assessment, EFED asked SRRD to request the original
reports from the registrant on 1/22/07.  On 2/6/07, SRRD responded that
they have not heard anything from the registrant.  

 

Photolysis/Hydrolysis of Chlorflurenol-Methyl Ester

EFED responses – 

This study can not be reviewed for the following reasons:

1.  The report was not signed by the study director and the facility
manager;

2.  Pages 27-43 are missing;

3.  According to the "Content" on page iii, the report contains 8 items
in Appendix (such as HPLC chromatograms, hydrolysis data, counting data
- TLC plates, etc.).  However, no appendix could be found in the report.

2) Letter from Calvin Oda re: pineapple production in Hawaii, Maui Ag
Tech LLC, December 13, 2006

EFED responses –

 

This letter was sent from a private company.  It does not contain any
useful information that could be used in the risk assessment.

