Comment submitted by B. Sachau

i oppose allowing this new toxic chemical to be used. i think its effects are far too onerous and destructive to allow its manufacture, distribution, sale or use. Pesticide Directory : A - E | F | G-P | Q-Z Pesticide Project Homepage Abstracts Adverse Health Effects Federal Register Open Comments Glossary of terms MSDS/Labels Pesticide Groups Pesticide Manafacturers Pesticides in the News PFOA-PFOS Reports etc. Submissions Useful Links Contact Project Pesticides Adverse Effects Flumiclorac-pentyl CAS No. 87546-18-7 Return to Index Page Activity: Herbicide (unclassified) Structure for "Flumiclorac" Adverse Effects: Blood Kidney Liver Phototoxic Environmental ? Very little toxicological data is available for this herbicide. ? As of February 14, 2005, this herbicide is permitted in or on 5 food commodities in the United States - see list at bottom of page. Blood (click on for all fluorinated pesticides) -- Chronic Toxicity (Including Cancer): Studies with Flumiclorac Pentyl Technical indicate that repeated high exposures produced changes in liver, kidney, and red blood cells but did not produce cancer in test animals. -- Potentially Aggravated Condition: Individuals with preexisting diseases of the liver, kidney, or red blood cells may have increased susceptibility to the toxicity of excessive exposures. -- SUBCHRONIC: Compound-related effects noted at very high dose levels of Flumiclorac Pentyl Technical in rodents and/or dogs included: increased liver and kidney weights; histological changes in the kidney and liver; slight changes in blood biochemistry parameters; decreased red blood cell count, hemoglobin, and hematocrit; and slight decreases in body weight. The NOEL in rats and mice was 1000 ppm. -- CHRONIC/CARCINOGENICITY: Effects of long-term high dose exposures to Flumiclorac Pentyl Technical in rodents and/or dogs consisted primarily of increases in kidney and liver weights, slight changes in blood biochemistry, and histological changes in the liver. The lowest NOEL was 300 ppm in the mouse study. Flumiclorac Pentyl Technical was not carcinogenic in either rats or mice. Ref: Material Safety Data Sheet for RESOURCE TM Herbicide. http://www.horizononline.com/MSDS_Sheets/529.txt Kidney (click on for all fluorinated pesticides) In the rat, the kidney is a potential target organ at high dose levels. Effects included urinary incontinence, increased water consumption, increased urine volume, and increased kidney weights in the females, and increased squamous epithelial cells in urinary sediment and increased kidney weights in the males. Nephropathy was evident in male rats in a two-generation reproduction study following administration of high dose levels. Reference: June 28, 2005. US EPA. Health Effects Division Chapter of the Tolerance Reassessment Eligibility Decision Document (TRED). http://www.fluorideaction.org/pesticides/flumiclorac-p.opp-2005-0229-0003.pdf -- Chronic Toxicity (Including Cancer): Studies with Flumiclorac Pentyl Technical indicate that repeated high exposures produced changes in liver, kidney, and red blood cells but did not produce cancer in test animals. -- Potentially Aggravated Condition: Individuals with preexisting diseases of the liver, kidney, or red blood cells may have increased susceptibility to the toxicity of excessive exposures. -- SUBCHRONIC: Compound-related effects noted at very high dose levels of Flumiclorac Pentyl Technical in rodents and/or dogs included: increased liver and kidney weights; histological changes in the kidney and liver; slight changes in blood biochemistry parameters; decreased red blood cell count, hemoglobin, and hematocrit; and slight decreases in body weight. The NOEL in rats and mice was 1000 ppm. -- CHRONIC/CARCINOGENICITY: Effects of long-term high dose exposures to Flumiclorac Pentyl Technical in rodents and/or dogs consisted primarily of increases in kidney and liver weights, slight changes in blood biochemistry, and histological changes in the liver. The lowest NOEL was 300 ppm in the mouse study. Flumiclorac Pentyl Technical was not carcinogenic in either rats or mice. Ref: Material Safety Data Sheet for RESOURCE TM Herbicide. http://www.fluoridealert.org/pesticides/Flumiclorac-pentyl.MSDS.htm Liver (click on for all fluorinated pesticides) -- Chronic Toxicity (Including Cancer): Studies with Flumiclorac Pentyl Technical indicate that repeated high exposures produced changes in liver, kidney, and red blood cells but did not produce cancer in test animals. -- Potentially Aggravated Condition: Individuals with preexisting diseases of the liver, kidney, or red blood cells may have increased susceptibility to the toxicity of excessive exposures. -- SUBCHRONIC: Compound-related effects noted at very high dose levels of Flumiclorac Pentyl Technical in rodents and/or dogs included: increased liver and kidney weights; histological changes in the kidney and liver; slight changes in blood biochemistry parameters; decreased red blood cell count, hemoglobin, and hematocrit; and slight decreases in body weight. The NOEL in rats and mice was 1000 ppm. -- CHRONIC/CARCINOGENICITY: Effects of long-term high dose exposures to Flumiclorac Pentyl Technical in rodents and/or dogs consisted primarily of increases in kidney and liver weights, slight changes in blood biochemistry, and histological changes in the liver. The lowest NOEL was 300 ppm in the mouse study. Flumiclorac Pentyl Technical was not carcinogenic in either rats or mice. Ref: Material Safety Data Sheet for RESOURCE TM Herbicide. http://www.fluoridealert.org/pesticides/Flumiclorac-pentyl.MSDS.htm Environmental (click on for all fluorinated pesticides) Phototoxic Pesticide. Light-dependent peroxidizing herbicides (LDPHs). US EPA identified the following fluorinated herbicides - Acifluorfen, Azafenidin, Carfentrazone-ethyl, Flumiclorac-penty, Flumioxazin, Fluthiacet-methyl, Fomesafen, Lactofen, Oxadiargyl, Oxadiazon, Oxyfluorfen, Sulfentrazone, Thidiazimin as phototoxic pesticides that act by inhibiting protoporphyringen oxidase in the heme and chlorophyll biosynthetic pathway. [10 out of the 13 pesticides that EPA identified are fluorinated pesticides]. SEE http://www.fluoridealert.org/pesticides/PHOTOTOXICITY.PAGE.htm Ref: December 11, 2001 - US EPA. Revised Environmental Fate and Effects Division Preliminary Risk Assessment for the Oxyfluorfen Reregistration Eligibility Decision Document (also at: http://www.epa.gov/oppsrrd1/reregistration/oxyfluorfen/oxyefedchap.pdf An aquatic phototoxicity study is being required for light-dependent peroxidizing herbicides, including flumiclorac pentyl. Note: This is a new data requirement and will be required under a group DCI for Light-Dependent Peroxidizing Herbicides to be sent under separate cover - (page 7). Ref: August 23, 2005: Report of the Food Quality Protection Act (FQPA) Tolerance Assessment Progress and Risk Management Decision (TRED). Federal Regiser Docket No. OPP-2005-0229-0002. http://www.fluorideaction.org/pesticides/flumiclorac-p.opp-2005-0229-0002.pdf Ref: Acute Aquatic Ecotoxicity Summaries for Flumiclorac-pentyl on All Taxa Groups. PAN Pesticides Database - Chemical Toxicity Studies on Aquatic Organisms. http://www.pesticideinfo.org/List_AquireAcuteSum.jsp?Rec_Id=PC35968 Common Name Scientific Name Avg Species LC50 (ug/L) LC50 Std Dev Number of Studies Avg Species Rating Outlier Result for Organism Group? Fish Sheepshead minnow Cyprinodon variegatus 24,000 - 1 Slightly Toxic Rainbow trout,donaldson trout Oncorhynchus mykiss 1,100 - 1 Moderately Toxic Zooplankton Opossum shrimp Americamysis bahia 560.0 - 1 Highly Toxic A February 14, 2005, check at the Code of Federal Regulations for Flumiclorac pentyl: this herbicide is permitted in or on 5 food commodities in the United States. The following list identifies these crops for which EPA has set pesticide tolerances. [Code of Federal Regulations] [Title 40, Volume 22] [Revised as of July 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 40CFR180.477] [Page 470-471] TITLE 40--PROTECTION OF ENVIRONMENT CHAPTER I--ENVIRONMENTAL PROTECTION AGENCY (CONTINUED) PART 180_TOLERANCES AND EXEMPTIONS FROM TOLERANCES FOR PESTICIDE CHEMICALS IN FOOD--Table of Contents Subpart C_Specific Tolerances Sec. 180.477 Flumiclorac pentyl; tolerances for residues. (a) General. Tolerances are established for residues of the herbicide flumiclorac pentyl, pentyl[2-chloro-4-fluoro-5-(1,3,4,5,6,7- hexahydro-1,3-dioxo-2H-isoindol-2-yl)phenoxy]acetate, including all the metabolites of flumiclorac pentyl, in or on the food commodities listed below. The tolerance level for each commodity is expressed in terms of the parent only which serves as an indicator of the use of flumiclorac pentyl on these food commodities. Crop Parts per Million Corn, field, forage 0.01 Corn, field, grain 0.01 Corn, field, stover 0.01 Soybean, hulls 0.02 Soybean, seed 0.01 (b) Section 18 emergency exemptions. [Reserved] (c) Tolerances with regional registrations. [Reserved] (d) Indirect or inadvertent residues. [Reserved] Fluoride Action Network | Pesticide Project | 315-379-9200 | pesticides@fluoridealert.org this data convinces me that i dont want this on the market. b. sachau 15 elm st florham park nj 07932