MEMORANDUM

DATE:	26-JUL-2001

SUBJECT:	PP# 6E06209.  Dicamba (Distinct®, EPA Reg #7969-150) on Sweet
Corn.  Evaluation of Residue Data and Analytical Methods.  MRID#
451540-01.  Chemical 029801.  Barcode D275611.  Case 293383.  Submission
S590360.

FROM:	George F. Kramer, Ph.D., Chemist

Registration Action Branch 1 (RAB 1)

Health Effects Division (HED) (7509C)

THRU:	G. Jeffrey Herndon, Branch Senior Scientist

RAB1/HED (7509C)

TO:		Shaja Brothers/Robert Forrest, PM Team 5

Registration Division (RD) (7505C)

Interregional Research Project No. 4 (IR-4) has submitted a petition on
behalf of the Agricultural Experiment Stations of MN, ND and WI
proposing the following permanent tolerances for the combined residues
of the herbicide dicamba (3,6-dichloro-o-anisic acid) and its 5-hydroxy
(5-OH) metabolite (3,6-dichloro–5-hydroxy-o-anisic acid) in/on the
following raw agricultural commodities (RACs):

Corn, sweet, forage	

1.0 ppm



Corn, sweet, fresh	

0.1 ppm



Corn, sweet, stover	

1.0 ppm



Tolerances for residues of dicamba and its 5-OH metabolite have been
established for corn grain, corn forage, corn fodder, wheat grain, wheat
straw, barley grain, and barley straw at 0.5 ppm; and for field corn
forage, field corn stover and popcorn stover at 3.0 ppm (40 CFR §
180.227(a)).  Tolerances for dicamba and its 2-OH metabolite
(3,6-dichlorosalicylic acid (DCSA, or 3,6-dichloro-2-hydroxybenzoic
acid) have been established at 0.05 ppm for soybeans; 0.1 ppm for
soybean hay and soybean forage; and on cattle, goats, hogs, horses, and
sheep meat, fat, and meat byproducts at 0.2 ppm, liver and kidney at 1.5
ppm, and milk at 0.3 ppm (40 CFR §180.227(b)).  Tolerances for dicamba
and its 5-OH metabolite, resulting from the application of the sodium
salt of dicamba, have been established for cottonseed at 3.0 ppm (40 CFR
§ 180.227(c)).

Concurrently, the petitioner has submitted a request for Section 3
registration of Distinct® Herbicide (EPA Reg. No. 7969-150), a multiple
active ingredient water-dispersible granule (WDG) formulation containing
21.4% diflufenzopyr and 55% dicamba, for use on sweet corn for the
control of various weeds.  This residue chemistry review deals only with
the use of dicamba on sweet corn.  Issues pertaining to diflufenzopyr
are addressed in a separate memo (J. Tyler, in preparation; D275619).

Dicamba Registration Standard was dated 12-AUG-1983, followed by a
Dicamba Second Round Review on 24-MAY-1989.  Dicamba is a List A
chemical.

Structural Formulae:

	

Executive Summary of Chemistry Deficiencies

• Additional field residue trials.

• Revised Section F.

CONCLUSIONS

OPPTS GLN 860.1200:  Proposed Uses

1. The petitioner has provided an adequate set of directions for the
proposed use.

OPPTS GLN 860.1300:  Nature of the Residue - Plants

2. The nature of the residue in plants is adequately understood (F.
Griffith, 02-MAY-1996, PP#6F4604, D220469).  The residues to be
regulated in barley, corn, cotton, oats, wheat, and grasses are dicamba
and its 5-OH metabolite; in asparagus the residues to be regulated are
dicamba and DCSA; and in soybeans and aspirated grain fractions, the
residues to be regulated are dicamba, 5-OH dicamba and DCSA.

OPPTS GLN 860.1300:  Nature of the Residue - Livestock

3. The nature of the residue in ruminants and poultry is adequately
understood (L. Cheng, 07-MAR-1996, D204482).  The residues to be
regulated in livestock are dicamba and its DCSA metabolite.

OPPTS GLN 860.1340:  Residue Analytical Methods

4. The petitioner has presented an adequately validated capillary GC/ECD
residue analytical method to determine the magnitude of dicamba and 5-OH
dicamba residues in plant commodities (barley, corn, cotton, cotton
processed fractions, pasture grass, peanut, sorghum, soybean, sugar
cane, tomato, tomato processed fractions, wheat and wheat processed
fractions).  Pesticide Analytical Manual (PAM) Volume II lists Method I
and II, GC methods with electron capture detection (GC/ECD), for the
enforcement of tolerances on dicamba and its metabolite 5-OH dicamba
in/on plant commodities and milk.

OPPTS GLN 860.1360:  Multiresidue Method

5. Documentation from the FDA, PAM Volume I, Appendix II and Table
201-D, shows that dicamba is partially recovered (71 - 76%) using
Protocol B.

OPPTS GLN 860.1380:  Storage Stability Data

6. BASF submitted the results of a frozen storage stability study for
dicamba and its metabolite 5-OH dicamba in the following field corn
RACs:  forage, silage, grain, and fodder (S. Chun & W. Donovan,
16-JUL-1998, D228703).  The results of this study show dicamba to be
stable for up to 3 years in frozen storage, and 5-OH dicamba to be
stable for up to 2 years in frozen storage.  As the sweet corn samples
were stored for a maximum of 24 months, storage stability is not an
issue for this petition.

OPPTS GLN 860.1500:  Crop Field Trials

7a. A total of 9 field residue trials were conducted in Regions 1 (1
trial), 2 (1 trial), 3 (1 trial), 5 (3 trials), 6 (1 trial), 10 (1
trial) and 12 (1 trial).  The number and location does not match that
required for sweet corn:  12 trials conducted in Regions 1 (2 trials), 2
(1 trial), 3 (1 trial), 5 (5 trials), 10 (1 trial), 11 (1 trial) and 12
(1 trial).  The petitioner previously submitted the results of 20 field
corn residue trials.  HED can generally translate field corn forage and
stover data to sweet corn.  However, in this case, translation is not
appropriate as the application rate in the field corn trials was >10X
the maximum sweet corn application rate.  

7b. HED requests that the petitioner submit an additional 3 sweet corn
residue trials conducted in Regions 1 (1 trial), 5 (1 trial) and 11 (1
trial).  Permanent tolerances and a conditional registration may be
established while these trials are conducted.  

7c. Based on the available data, the following tolerance for residues of
the herbicide dicamba and its 5-OH metabolite are appropriate for this
petition:

Corn, sweet, forage	

0.50 ppm



Corn, sweet, kernel plus cob with husks removed	

0.04 ppm



Corn, sweet, stover	

0.50 ppm



A revised Section F is required.

OPPTS GLN:  860.1520:  Processed Food/Feed

8. As there are no processed commodities associated with sweet corn,
processing studies not are required to support the subject petition.

OPPTS GLN 860.1480:  Meat, Milk, Poultry, Eggs

9. Given that there are already dicamba tolerances established on major
livestock feed items at high levels (i.e., aspirated grain fractions at
5100 ppm, grass forage at 125 ppm and wheat forage at 20 ppm), HED
concludes that the dietary burden to livestock will not be affected by
the use of dicamba on sweet corn.

OPPTS GLN 860.1850 and 860.1900:  Confined/Field Accumulation in
Rotational Crops

10. Based on the results of a confined rotational crop study (memo S.
Chun & W. Donovan, 25-JUN-1998; D228694), HED has concluded that the
plantback intervals specified on the Distinct® label (7 days for corn
and 120 days for all other crops) are appropriate.

Other Considerations

11. There is neither a Codex proposal, nor Canadian or Mexican limits
for residues of dicamba in/on sweet corn.  Therefore, a compatibility
issue is not relevant to the proposed tolerance.  A copy of the IRLS
(International Residue Limit Status) sheet is attached to this
memorandum.

RECOMMENDATIONS

Provided Section F is revised as specified in Conclusion 7c, HED
concludes there are no residue chemistry data requirements that would
preclude the establishment of permanent tolerances for residues of
dicamba and its 5-OH metabolite in/on sweet corn RACs.  Registration of
Distinct® should be made conditional upon the submission of additional
residue data as specified in Conclusion 7b.  A human-health risk
assessment will be prepared as a separate document.

	DETAILED CONSIDERATIONS

OPPTS GLN 860.1200:  Proposed Uses

Distinct® is a selective postemergence herbicide.  The maximum
application rate for sweet corn is 0.14 lbs. ai/A and a maximum of 2
applications are permitted per season.  The maximum seasonal use rate is
0.21 lbs. ai/A with a minimum retreatment interval of 2 weeks. 
Surfactants (0.25% v/v) should be added to the postemergence finished
spray.  The spray volume is 3-50 gal/A by ground equipment.  The PHI is
32 days for fresh corn and 72 days for stover.

The rotational crop restrictions listed on the label are 7 days for corn
and 120 days for all other crops.

The petitioner has proposed an adequate set of directions for use of
Distinct® on sweet corn.

Note:  The revised Distinct® label also contains directions for use on
popcorn and grass.  Dicamba is already for use on these crops and the
use rate on the Distinct® label is less than that which is already
registered for dicamba alone.  Issues pertaining to dicamba in/on
popcorn and grass are thus not relevant to this petition.

OPPTS GLN 860.1300:  Nature of the Residue - Plants

The nature of the residue in plants is adequately understood (F.
Griffith, 02-MAY-1996, PP#6F4604, D220469).  In most plants there is
oxidation on the ring at the 5 position to form the 5-OH metabolite.  In
asparagus and soybeans there is demethylation on the ring at the 2
position to form the DCSA metabolite.  Thus, the residues to be
regulated in barley, corn, cotton, oats, wheat, and grasses are dicamba
and its 5-OH metabolite; in asparagus the residues to be regulated are
dicamba and DCSA; and in soybeans and aspirated grain fractions, the
residues to be regulated are dicamba, 5-OH dicamba and DCSA.

OPPTS GLN 860.1300:  Nature of the Residue - Livestock

The nature of the residue in ruminants and poultry is adequately
understood (L. Cheng, 07-MAR-1996, D204482).  In ruminants the metabolic
pathway is the same as in asparagus and soybeans which is demethylation
and formation of the DCSA metabolite.  The same basic metabolic pathway
exist in poultry; however there is a minor pathway producing a small
amount of 2-amino-3,6-dichlorophenol found in poultry liver.  The
residues to be regulated in livestock are dicamba and its DCSA
metabolite. 

OPPTS GLN 860.1340:  Residue Analytical Method - Plant Commodities

The petitioner has presented an adequately validated capillary GC/ECD
residue analytical method to determine the magnitude of dicamba and 5-OH
dicamba residues in plant commodities (barley, corn, cotton, cotton
processed fractions, pasture grass, peanut, sorghum, soybean, sugar
cane, tomato, tomato processed fractions, wheat and wheat processed
fractions).  This method (AM-0691B-0593-3) underwent a successful
independent laboratory validation (D. Miller, 13-DEC-1993) and a
successful EPA method validation (J. Stokes, 24-JAN-1997).  This method
was recently superceded by method AM-0691B-0297-4 (MRID 44394102), which
consists of a more detailed step-by-step description of the procedures,
GC-MS confirmatory tests, and additional recovery data.  The analytical
method has not been changed from method AM-0691B-0593-3.  The limit of
quantitation (LOQ) for dicamba and 5-OH dicamba is 0.02 ppm.  PAM Volume
II lists Method I and II, GC methods with electron capture detection
(GC/ECD), for the enforcement of tolerances on dicamba and its
metabolite 5-OH dicamba in/on plant commodities and milk.  

OPPTS GLN 860.1340:  Residue Analytical Methods - Livestock Commodities

The GC/EC method, AM-0685 (MRID 00079744) detects residues of dicamba
and 3,6-dichloro-2-hydroxybenzoic acid (both as the methyl ester of
dicamba) in milk, muscle, liver, kidney and fat.  The method has been
successfully validated by the Agency using milk and ground beef samples
(9/1/82, K. Zee, PP#1F2569).

OPPTS GLN 860.1360:  Multiresidue Method

Although the petitioner requested a waiver for dicamba multiresidue
method testing (S. Knizner, 11-JUN-1993, D189393 and D189595),
documentation from the FDA PAM, Volume I, Appendix II and Table 201-D,
shows that dicamba is partially recovered (71 - 76%) using Protocol B.

OPPTS GLN 860.1380:  Storage Stability Data

BASF submitted the results of a frozen storage stability study for
dicamba and its metabolite 5-OH dicamba in the following field corn
RACs:  forage, silage, grain, and fodder (S. Chun & W. Donovan,
16-JUL-1998, D228703).  The results of this study show dicamba to be
stable for up to 3 years in frozen storage, and 5-OH dicamba to be
stable for up to 2 years in frozen storage.  As the sweet corn samples
were stored for a maximum of 24 months, storage stability is not an
issue for this petition.

OPPTS GLN 860.1500:  Crop Field Trials

Submitted with this petition:

Sweet Corn Residues of diflufenzopyr and Dicamba Resulting From
Application of Distinct® (BAS 662 H)  MRID# 451540-01.

A total of 9 field residue trials were conducted in 1996.  These trials
were located in Regions 1 (1 trial), 2 (1 trial), 3 (1 trial), 5 (3
trials), 6 (1 trial), 10 (1 trial) and 12 (1 trial).  Four plots were
established at each site.  Treatment 1 was the untreated control. 
Treatment 2 consisted of 2 applications of diflufenzopyr at a rate of
0.05 lbs. ai/A for a total of 0.10 lbs. ai/A.  Treatment 3 consisted of
2 applications of Distinct® at a rate of 0.125 lbs. dicamba/A for a
total of 0.25 lbs. ai/A (1.2X).  Treatment 4 consisted of 2 applications
of dicamba at a rate of 0.25 lbs. ai/A for a total of 0.50 lbs. ai/A
(2.4X).  The first treatment was made when the corn was 12 inches tall;
the second, when the corn was 24 inches tall.  Two replicate samples
were harvested from each treated plot 4-7 weeks (forage and ears) and
5-16 weeks (stover) after application.  The samples were frozen and
shipped to Sandoz.  Sample analysis for and 5-OH dicamba was performed
using method AM-0691B-0593-3.  The method was validated over a range of
0.02-0.1 ppm.  The average recovery was 84 ± 13% for dicamba and 88 ±
11% for 5-OH dicamba.  Analyses of the treated samples (Tables 1 & 2)
showed that the maximum total residues at 1.2X were 0.29 ppm in forage,
0.39 ppm in stover and <0.04 ppm in ears (kernel plus cob with husk
removed).



Table 1. Residue levels of dicamba and 5-OH dicamba following Treatment
3 (0.25 a.i./A dicamba, 1.2X)



Trial Site	

PHI

(Weeks)	

Dicamba (ppm)	

5-OH Dicamba (ppm)	

Totalb (ppm)



Sweet Corn Forage



WI	

7	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



MN	

6	

<0.02	

 0.03	

<0.05





<0.02	

 0.05	

<0.07



IN	

7	

<0.02	

 0.06	

<0.08





<0.02	

 0.06	

<0.08



OR	

8	

<0.02	

 0.03	

<0.05





<0.02	

 0.04	

<0.06



CA	

6	

 0.10	

 0.11	

 0.21





<0.02	

 0.08	

<0.10



WA	

4	

 0.05	

 0.31	

 0.26





 0.05	

 0.24	

 0.29



GA	

6	

<0.02	

 0.07	

<0.09





<0.02	

 0.07	

<0.09



FL	

4	

 0.03	

 0.22	

 0.25





<0.02	

 0.13	

<0.17



NY	

4	

 0.03	

 0.13	

 0.16





 0.04	

 0.18	

 0.22



Sweet Corn Stover



WI	

10	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



MN	

9	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



IN	

11	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



OR	

16	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



CA	

13	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



WA	

10	

 0.05	

 0.34	

 0.39





 0.04	

 0.24	

 0.28



GA	

NC a	

-	

-	

-





-	

-	

--



FL	

5	

 0.05	

 0.28	

 0.33





 0.03	

 0.21	

 0.24



NY	

10	

<0.02	

 0.03	

<0.05





<0.02	

 0.03	

<0.05



Sweet Corn Ears



WI	

7	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



MN	

6	

NA	

NA	

NA





NA	

NA	

NA



IN	

7	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



OR	

8	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



CA	

6	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



WA	

4	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



GA	

6	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



FL	

4	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



NY	

4	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04

a NC = Not Collected

b NA = Not Analyzed



Table 2. Residue levels of dicamba and 5-OH dicamba following Treatment
4 (0.50 a.i./A dicamba, 2.4X)



Trial Site	

PHI

(Weeks)	

Dicamba (ppm)	

5-OH Dicamba (ppm)	

Totalb (ppm)



Sweet Corn Forage



WI	

7	

 0.054	

 0.15	

 0.20





 0.042	

 0.12	

 0.16



MN	

6	

<0.02	

 0.042	

<0.06





<0.02	

 0.058	

<0.08



IN	

7	

<0.02	

 0.10	

<0.12





0.024	

 0.16	

 0.18



OR	

8	

 0.096	

 0.30	

 0.40





 0.042	

 0.15	

 0.19



CA	

6	

 0.087	

 0.17	

 0.26





 0.038	

 0.26	

 0.30



WA	

4	

 0.14	

 0.92	

 1.1 





 0.10	

 0.66	

 0.76



GA	

6	

 0.043	

 0.14	

 0.18





 0.058	

 0.24	

 0.30



FL	

4	

 0.22	

 1.5 	

 1.7 





 0.20	

 1.3 	

 1.5 



NY	

4	

 0.099	

 0.82	

 0.92





 0.063	

 0.50	

 0.56



Sweet Corn Stover



WI	

10	

 0.047	

 0.13	

 0.18





 0.067	

 0.17	

 0.24



MN	

9	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



IN	

11	

<0.02	

<0.066	

<0.09





<0.02	

<0.051	

<0.07



OR	

16	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



CA	

13	

 0.026	

 0.093	

 0.12





 0.030	

 0.068	

 0.098



WA	

10	

 0.072	

 0.57	

 0.64





 0.083	

 0.59	

 0.67



GA	

NC a	

-	

-	

-





-	

-	

-



FL	

5	

 0.27	

 1.5	

 1.8 





 0.18	

 0.90	

 1.1 



NY	

10	

 0.028	

 0.076	

 0.10





 0.034	

 0.093	

 0.13



Sweet Corn Ears



WI	

7	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



MN	

6	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



IN	

7	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



OR	

8	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



CA	

6	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



WA	

4	

 0.064	

 0.034	

 0.098





 0.081	

 0.043	

 0.12



GA	

6	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



FL	

4	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04



NY	

4	

<0.02	

<0.02	

<0.04





<0.02	

<0.02	

<0.04

a NC = Not Collected

b NA = Not Analyzed

Conclusions:  A total of 9 field residue trials were conducted in
Regions 1 (1 trial), 2 (1 trial), 3 (1 trial), 5 (3 trials), 6 (1
trial), 10 (1 trial) and 12 (1 trial).  The number and location does not
match that required for sweet corn:  12 trials conducted in Regions 1 (2
trials), 2 (1 trial), 3 (1 trial), 5 (5 trials), 10 (1 trial), 11 (1
trial) and 12 (1 trial).  The petitioner previously submitted the
results of 20 field corn residue trials.  HED can generally translate
field corn forage and stover data to sweet corn.  However, in this case,
translation is not appropriate as the application rate in the field corn
trials was >10X the maximum sweet corn application rate.  HED thus
requests that the petitioner submit an additional 3 sweet corn residue
trials conducted in Regions 1 (1 trial), 5 (1 trial) and 11 (1 trial). 
Permanent tolerances and a conditional registration may be established
while these trials are conducted.  Based on the available data, the
following tolerance for residues of the herbicide dicamba and its 5-OH
metabolite are appropriate for this petition:

Corn, sweet, forage	

0.50 ppm



Corn, sweet, kernel plus cob with husks removed	

0.04 ppm



Corn, sweet, stover	

0.50 ppm



A revised Section F is required.

OPPTS GLN 860.1520:  Processed Food/Feed

As there are no processed commodities associated with sweet corn,
processing studies not are required to support the subject petition.

OPPTS GLN 860.1480:  Meat, Milk, Poultry, Eggs

Given that there are already dicamba tolerances established on major
livestock feed items at high levels (i.e., aspirated grain fractions at
5100 ppm, grass forage at 125 ppm and wheat forage at 20 ppm), HED
concludes that the dietary burden to livestock will not be affected by
the use of dicamba on sweet corn.

OPPTS GLN 860.1850/1900:  Confined/Field Accumulation in Rotational
Crops

Based on the results of a confined rotational crop study, HED has
concluded that the following plantback restrictions are appropriate
(memo S. Chun & W. Donovan, 25-JUN-1998; D228694):

Application Rate	

Rotational Restrictions



0.75 or less lb a.i./A	

After 120 days from time of application: no rotational cropping
restrictions apply.  

Planting within 120 days of application: only rotate to crops below.



0.75 to 2.0 lb a.i./A	

Rotate to the following crops only:  

corn, soybeans, cotton, wheat , barley, oats, grass pasture and hay or
rangeland, sorghum, asparagus, sugarcane.



As the application for sweet corn is <0.75 lb a.i./A, the plantback
intervals specified on the Distinct® label (7 days for corn and 120
days for all other crops) are appropriate.

Other Considerations:  There is neither a Codex proposal, nor Canadian
or Mexican limits for residues of dicamba in/on sweet corn.  Therefore,
a compatibility issue is not relevant to the proposed tolerance.  A copy
of the IRLS sheet is attached to this memorandum.

Attachment 1- IRLS Sheet

cc:  Kramer

RDI: G. Herndon(7/19/01), RAB1 Chemists (7/19/01)

G.F. Kramer:806T:CM#2:(703)305-5079:7509C:RAB1



INTERNATIONAL RESIDUE LIMIT STATUS



Chemical Name:

3,6-dichloro-o-anisic acid	

Common Name:

Dicamba	

( Proposed tolerance

( Reevaluated tolerance

( Other	

Date:

6/29/01



Codex Status (Maximum Residue Limits)	

U. S. Tolerances



X No Codex proposal step 6 or above

( No Codex proposal step 6 or above for the crops requested	

Petition Number:  6E06209

DP Barcode:  D271606

Other Identifier:



Residue definition: N/A	

Reviewer/Branch:  G.F. Kramer

	

Residue definition:  parent + its 5-OH metabolite



Crop (s)	

MRL (mg/kg)	

Crop(s)	

Tolerance (ppm)



	

	

Corn, sweet, forage	

1.0



	

	

Corn, sweet, fresh	

0.1



	

	

Corn, sweet, stover	

1.0



	

	

	





	

	

	





Limits for Canada	

Limits for Mexico



( No Limits

( No Limits for the crops requested	

( No Limits

( No Limits for the crops requested



Residue definition:

dicamba	

Residue definition:

dicamba



Crop(s)	

MRL (mg/kg)	

Crop(s)	

MRL (mg/kg)



corn (field and sweet)	

none (default)	

corn	

0.5



	

	

	





Notes/Special Instructions:.

S. Funk, 07/03/01.



Rev. 1998

 PAGE  14 

