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mecoprop (Chipco Turf Herb. MCPP) Herbicide Profile 12/88

EPA Pesticide Fact Sheet
Name of Chemical: 2-(2-Methyl-4-chlorophenoxy)propionic acid and its
                  salts and esters
Reason for Issuance: Registration Standard
Date Issued: December 1988
Fact Sheet Number: 192
                      1. DESCRIPTION OF CHEMICAL
- Chemical Names:  2-(2-Methyl-4-chlorophenoxy)propionic acid; potassium
  2-(2-methyl-4-chlorophenoxy)-propionate; diethanolamine 2-(2-methyl-4-
  chlorophenoxy)-propionate; dimethylamine 2-(2-methyl-4-chlorophenoxy)-
  propionate; isooctyl 2-(2-methyl-4-chlorophenoxy)-propionate 
- ANSI Common Names:  MCPP (includes MCPP acid as well as the MCPP
  potassium salt; MCPP diethanolamine salt; MCPP dimethylamine salt; and
  MCPP isooctyl ester)
- Other Common Names:  Mecoprop
- Principal Trade Names:  MCPP and Mecoprop
- EPA (Shaughnessy) Code:  031501 (acid); 031503 (potassium salt);
  031516 (diethanolamine salt); 031519 (dimethylamine salt), 031563
  (isooctyl ester).
- Chemical Abstracts Service (CAS) Number:  7085-19-0 (acid); 1929-86-8
  (potassium salt); 1432-14-0 (diethanolamine salt); 32351-70-5
  (dimethylamine salt); 28473-03-2 (isooctyl ester)
- Year of Initial
- Registration:  1964 (potassium salt)
- Pesticide Type(s):  Herbicide, postemergence
- Chemical Family:  Chlorinated phenoxy
- U.S. and Foreign Producers:  Aceto Chemical Co., Inc.; Akzo Zout
  Chemie Nederland; Dow Chemical USA; Gilmore, Inc.; A.H. Marks Co.,
  Ltd.; Rhone-Poulenc Ag Co. 
                      2. USE PATTERNS AND FORMULATIONS
- Registered Uses:  Terrestrial nonfood crop - Golf courses, lawns,
  ornamental and sports turf, wide area general indoor/outdoor
  treatments.
- Aquatic nonfood crop - Drainage ditch banks.
- Forest trees - site preparation.
- Principle Uses:  Ninety-six percent of the production is used on turf,
  including lawns, sport turf and commercial sod production. A small
  percentage (1-4%) is used in noncrop areas such as rights-of-way,
  drainage ditch banks and forest site preparation.
- Formulations:  Granular, wettable powder, emulsifiable concentrate,
  soluble concentrate/liquid, pressurized liquid.
- Methods of Application:  Foliar applications by ground equipment
  including spreader, sprayer, pressure on hose-end sprayer and
  pressurized containers.
- Application by air on specific noncropland sites.
                          3. SCIENCE FINDINGS
Summary Science Statement
     Virtually all data reviewed were on MCPP acid.  Data are needed for 
the ester and each salt, with the exception of the potassium salt, for 
which the data on the acid will suffice, before the Agency can 
completely assess the effects the forms of MCPP pesticides to organisms 
and the environment.
     The Agency's Office of Pesticide Programs (OPP) has classified MCPP 
as a teratogen, based upon results of a study in rats.  Margins of 
safety may not be adequate for some workers; additional data are 
required to refine estimates of worker exposure.  A decision on the need 
for further regulatory action will be made when these data have been 
submitted and evaluated.
     MCPP is stable to hydrolysis, had slow photodegradation in water, 
and was very mobile in sand, sandy loam, silt loam, and silty clay loam 
soils.  The submission of data are required for terrestrial nonfood and 
aquatic nonfood uses for all type formulations.
     Freshwater fish toxicity data on MCPP acid is incomplete, with a 
rainbow trout study that revealed very low acute toxicity of MCPP acid 
of 124 ppm. There were no acceptable acute freshwater aquatic 
invertebrate data submitted.
     There were no acceptable data for toxicity of any MCPP formulations 
to nontarget plants, endangered species, or nontarget insects.
     It is possible that chlorinated dibenzo-p-dioxins or dibenzofurans 
may be formed during the manufacture of MCPP.  It is also possible that 
nitrosamines may be formed during the manufacture or storage of the MCPP 
amine salts.  Thus, manufacturing process information is required to 
assess the possibility of the formation of these contaminants.
Chemical Characteristics
Physical state:  Crystalline solid
Color:  White to light brown
Odor:  Odorless
Molecular Weight:  214.7
Empirical Formula:  CloHllC103
Boiling Point:  Decomposes before reaching boiling point
Vapor Pressure:  1.4 x 10-5 mm Hg at 20 degrees C; 4.7 x 10 5 mm
                 Hg at 30 degrees C
Melting Point:  94-95 degrees C
Density, bulk:  0.6g/ml, dry uncompacted
Solubility:  0.06% in water at 20 degrees C; readily soluble in alcohol,
             benzene, acetone, chlorinated hydrocarbons
Toxicology Characteristics
Acute Toxicity                            Toxicity Category*
______________                            __________________
Acute Oral:          55% mg/kg                  III
Acute Dermal:        Not lethal to rabbits      III
                     at 2 g/kg
Acute Inhalation:    Data gap
Primary Dermal       No dermal irritation        IV
      Irritation:    in rabbits exposed for 24 hours
                     to abraded and unabraded skin
Primary Eye          Produces persistent corneal
      Irritation:    opacities, iritis, and conjunctival
                     irritation in both washed and unwashed eyes.
Dermal Sensitization:    Data gap.
________________
*For a description of Toxicity categories, see 40 CFR 156.10
- Delayed Neurotoxicity:  Data are not available. Testing is not
  required because MCPP and its derivatives and metabolites are not
  organophosphates or cholinesterase inhibitors.
- Subchronic Toxicity:  Oral exposure of rats to technical MCPP caused
  increased creatinine levels in females and decreased glucose levels in
  males at 27 mg/kg; increased relative kidney weights in both sexes at
  9 mg/kg and 27 mg/kg, respectively.  The NOEL was 3 mg/kg.
Chronic Studies
- Chronic toxicity:  No data are available and none are required because
  this pesticide does not have food uses.
- Oncogenicity:  There were no data available nor are any required.
- Teratogenicity & Developmental Toxicity:  In a rat study, oral
  exposure to 125 mg/kg of MCPP on days 6-15 of gestation caused
  increased intra-uterine deaths, decreased crown/rump lengths, and an
  increased incidence of delayed or absent ossification of the
  sternebrae.  The NOEL was 50 mg/kg/day. MCPP was not teratogenic in
  rabbits. A reproductive toxicity study is not required.
- Mutagenicity
  - Gene Mutations.  In a spot test, no increases in reverse
    mutations in 4 strains of Salmonella were seen with or without
    metabolic activation and no forward mutations to streptomycin
    resistance were seen in S. Coelicolor A3(2) in spot or standard
    plates, with or without activation.
  - Other Tests.  MCPP caused an increase in sister chromatid exchange
    after single oral doses of 470 and 3800 mg/kg in Chinese Hamsters.
    Additional data are required.
- Major Route of Exposure:  Dermal.
Physiological and Biochemical Characteristics
- MCPP is absorbed through leaves and roots and is translocated.  It
  stimulates nucleic acid and protein synthesis and affects the efficacy
  of enzymes, either stimulating or inhibiting cell division.
Environmental Characteristics
- Absorption and Leaching:  Unaged MCPP is very mobile in sand, sandy
  loam, silt loam, and silty clay loam soils.  Absorption has been
  positively correlated with the organic matter of the soils.
- Hydrolysis:  Technical MCPP at 51-52 ppm did not hydrolyze during 31
  days of incubation in sterile buffered solutions (pH 5, 7, and 9) at
  25 degrees C plus or minus 2 degrees C.
- Bioaccumulation:  Available data indicate a low potential of MCPP to
  bioaccumulate in fish.
- Ground water:  Available data indicate that MCPP is mobile in many
  soils and may potentially leach to ground water.
Ecological Characteristics
- Avian acute toxicity:  MCPP acid has been shown to have an acute oral
  LD50 Of 700 mg/kg to the bobwhite quail and is considered to be of low
  toxicity.
- Avian dietary toxicity:  Studies on MCPP acid indicate LC50 values of
  >5620 ppm and 5000 ppm for the mallard and the bobwhite quail,
  respectively.  These values are considered practically nontoxic to
  avian species on subacute basis.
- Freshwater fish acute toxicity:  MCPP acid has very low toxicity to
  the rainbow trout (LC50 = 124 ppm).
- Freshwater invertebrates toxicity:  There were no acceptable
  freshwater invertebrate studies submitted.
- Fish early lifestage and aquatic invertebrate life cycle toxicity:
  There were no fish early lifestage nor aquatic invertebrate life cycle
  studies submitted.
- Nontarget plant toxicity:  There were no acceptable nontarget plant
  studies submitted.
- Nontarget insects:  There were no data on effects of MCPP to honeybees
  and nontarget insects submitted.
Pesticide Incidents
- There were no reports of MCPP pesticide incidents.
                    4. SUMMARY OF REGULATORY POSITION
1.  Special review:  The Agency is deferring a decision on initiating a 
Special Review of MCPP based on teratogenicity until data needed to 
refine worker exposure estimates have been submitted and evaluated.
2.  Restricted Use:  The Agency will not restrict the use of MCPP 
products at this time.
3.  Special Data Requirements:  The Agency is requiring a submission of 
special studies to refine exposure estimates to workers.  These data 
will be used to assess the teratogenic risk posed by MCPP to workers or 
other persons exposed to MCPP.
4.  Basic Data Requirements:  The Agency is requiring data specific to 
the amines and the ester formulations as well as the acid.  Acceptable 
data received on the MCPP acid will be generally acceptable for the 
potassium salt.
5.  Groundwater concerns:  MCPP has the potential to contaminate 
groundwater because it is mobile in many mineral soils.  Studies to 
evaluate the potential of MCPP and its metabolites to contaminate 
groundwater are required.  A groundwater statement is required (see 
labeling section below).
6.  Reentry requirement:  Reentry data are required because of the 
potential teratogenic risk and because some use patterns involve post-
treatment tasks that could result in dermal exposures of workers to MCPP 
residues.  Workers are not permitted to reenter treated areas until 
sprays have dried and dusts have settled (see labeling section below).
7.  Protective clothing requirement:  The Agency is requiring mixers/ 
loaders and applicators to use protective clothing and equipment.  See 
the protective clothing statement in the labeling section below.
8.  Endangered species regulatory position:  There has been no 
determination that MCPP acid or any MCPP formulation would affect 
endangered animal or plant species.
9.  Dibenzo-p-dioxins/Dibenzofurans:  The Agency is requiring submission 
of manufacturing process data on MCPP to assess the possibility of 
contamination by dibenzo-p-dioxins or dibenzofurans.
10.  Nitrosamines:  The Agency is requiring chemical analysis of 
products containing MCPP amine salts for possible nitrosamine 
contamination.
11. Data for Immediate Review:  The Agency has identified data which 
will be reviewed as soon as they are received:  product chemistry: 
environmental fate: dermal absorption, applicator exposure and reentry; 
toxicity on the amine salts and ester; and Tier II phytoxicity.
                        5. LABELING REQUIREMENTS
- Statements for Manufacturing-Use Products
  - "Do not discharge effluent containing this product into lakes,
     streams, ponds, estuaries, oceans or public waters unless this
     product is specifically identified and addressed in an NPDES
     permit.  Do not discharge effluent containing this product to sewer
     systems without previously notifying the sewage treatment plant
     authority.  For guidance, contact your State Water Board or
     Regional Office of the EPA."
- Statements for End-Use Products
  - Ground Water Contamination:  "Although highly mobile, in general
    phenoxy herbicides such as MCPP are not sufficiently persistent to
    reach ground water from use as specified on product labels.  Most
    cases of ground water  contamination involving phenoxy herbicides
    have been associated with mixing/loading and disposal sites.
    Caution should be exercised when handling MCPP at such sites to
    prevent contamination of water supplies."
  - Protective Clothing:  "Mixer/loader and applicators must wear long
    pants, long sleeve shirts, and gloves.  Persons applying liquid MCPP
    products such as sprays are required to use goggles to cover their
    eyes."
- Worker Reentry:
- "Do not reenter or permit workers to reenter treated areas until
   sprays have dried or dusts have settled."
- Nontarget Plant Species:
- Aquatic uses:
  "Drift or run-off may adversely affect nontarget plants.  Do not apply
   directly to water except as specified on this label.  Do not
   contaminate water when disposing of equipment washwaters."
- Nonaquatic uses:
  "Drift or run-off may adversely affect nontarget plants.
   Do not apply directly to water or wetlands (swamps, bogs,
   marshes and potholes).  Do not contaminate water when
   disposing of equipment washwaters."
                        6. SUMMARY OF DATA GAPS
     The following data are required as specified.  Uses of MCPP 
potassium salt may be supported with data on either the salt or MCPP 
acid.  Codes for the different formulations are MCPP Acid (1), Potassium 
Salt (2), Diethanolamine (3), Dimethylamine (4), and Isooctyl Ester (5).
                          MCPP             Due Date - From
Study                     Formulation      Date of Standard
_____                     ___________      ________________
Product Chemistry:           All               9-12 months
Toxicology:
  Acute Oral, Dermal,        3, 4, 5           9 months
    Inhalation, Eye
 
  Irritation, Dermal Irritation
    and Sensitization
  Subchronic
    21-Day Dermal            All               12 months
  Chronic
    Teratogenicity           3, 4, 5           15 months
    Mutagenicity             3, 4, 5           9 months
    Chromosomal Aberration   All               12 months
    Other (sister
     chromatid exchange)     3, 4, 5           12 months
  Special Testing
    Dermal Absorption        All               9 months
    Applicator Exposure      All            (protocols due in 6 months)
Reentry Protection:
  Foliar Dissipation         All               27 months
  Soil Dissipation           All               27 months
  Dermal Exposure            All               27 months
Environmental Fate:
  Hydrolysis                 All               9 months
  Photodegradation
    Water and Soil           All               9 months
  Metabolism
    Aerobic Soil             All               27 months
    Anaerobic Aquatic        2, 4, 5           27 months
    Aerobic Aquatic          2, 4, 5           27 months
  Mobility
    Leaching and Ad-
    sorption/Desorption      All               12 months
  Dissipation
    Soil                     All               27 months
    Aquatic (sediment)       2, 4, 5           27 months
    Forestry                 4                 27 months
  Accumulation
    Irrigated Crops          2, 4, 5           39 months
    Fish                     All               12 months
    Aquatic Nontarget
      Organisms              2, 4, 5           12 months
Wildlife & Aquatic organisms:
  Avian & Mammalian:
    Acute Avian Oral         3, 4, 5           9 months
    Avian Subacute
      Upland Game Bird       3, 4, 5           9 months
      Waterfowl              3, 5              9 months
  Aquatic Organism:
    Freshwater Fish
      Coldwater Fish TGAI     3, 4, 5          9 months
      Coldwater Fish TEP      1, 3, 4, 5       9 months
      Warmwater Fish TGAI     All              9 months
      Warmwater Fish TGAI     2, 4, 5          9 months
    Freshwater
      Invertebrates TGAI      All              9 months
      Invertebrates TEP       2, 4, 5          9 months
  Plant Protection:
    Nontarget Phytotoxicity - Tier II:
      Seed Germination/
        Emergence TGAI        All              9 months
      Vegetative Vigor TGAI   All              9 months
      Aquatic Plant
        Growth TGAI           All              9 months
  Nontarget Insect:
    Honey Bee Contact TGAI    2, 3, 4, 5       9 months
                      7. CONTACT PERSON AT EPA
Mr. Richard Mountfort
Product manager (Team 23)
Fungicide-Herbicide Branch
Registration Division (TS-767C)
Office of Pesticide Programs
Environmental Protection Agency
401 M St., SW
Washington, D.C. 20460
Physical Location
Crystal Mall #2
1921 Jefferson Davis Highway
Arlington, VA
Telephone number:  (703) 557-1830
 
DISCLAIMER:  The information in this Pesticide Fact Sheet is a summary 
only and may not be used to satisfy data requirements for pesticide 
registration and reregistration. The complete Registration Standard for 
the pesticide may be obtained from the National Technical Information 
Service.  Contact the Product Manager listed above for further 
information.