INTERNATIONAL COURT OF JUSTICE
____________________________________________
CASE CONCERNING
AERIAL HERBICIDE SPRAYING
(ECUADOR v. COLOMBIA)
REJOINDER OF THE
REPUBLIC OF COLOMBIA
VOLUME V
ANNEXES 56 - 59
1 FEBRUARY 2012 LIST OF ANNEXES
VOLUME V
Annex 56 United States Environmental Protection Agency (EPA),
Memorandum of 13 May 2003, Technical Review of the six acute
toxicity studies on the spray mixture for Eradication of Illicit Crops in
Colombia. .................................................... 1
Annex 56-A: Six Acute Toxicity Studies with Spray-Charlie, SLI Study
N° 3596.16, 20 Feb. 2003. ................................... 21
Annex 56-B: Six Acute Toxicity Studies with Spray-Alpha, SLI Study
N° 3596.3, 3 Sep. 2002. .................................... 221
Annex 56-C: Six Acute Toxicity Studies with Spray-Bravo, SLI Study
N° 3596.10, 4 Sep. 2002. ................................... 445
Annex 57 Letter by Ms Rebecca L. Puskas to the United States Environmental
ProtectionAgency, 11 Nov. 2008. ................................ 673
Annex 58 Embassy of the United States ofAmerica, List ofAerial Eradication
Verification Missions since 1997
Appendix: Implementation of the verification protocol January –
July 1998, carried out October 18-23, 1998. ........................ 679
Annex 59 United States Department of State, Bureau for International
Narcotics Matters, Herbicide Selection for Coca Eradication,
May 1984. .................................................. 711
iiiiv Annex 56
UnitedStateSenvironmentalProtectionagency (ePa),
m emorandUm of13 may 2003, echnicalreview of
the Six acUte toxicity StUdieS on the SPray mixtUre for
e radication illicic roPS icolombia
(United States Embassy in Bogotá, 2011)
12 Annex 56
3Annex 56
4 Annex 56
5Annex 56
6 Annex 56
7Annex 56
8 Annex 56
9Annex 56
10 Annex 56
11Annex 56
12 Annex 56
13Annex 56
14 Annex 56
15Annex 56
16 Annex 56
17Annex 56
18 Annex 56
1920 Annex 56-A
SixA cutet oxicitS tudieS witS prA-c hArli, Sli StudyN° 3596.16,
20 febrUary 2003
(United States Embassy in Bogotá, 2011)
2122 Annex 56-A
23Annex 56-A
24 Annex 56-A
25Annex 56-A
26 Annex 56-A
27Annex 56-A
28 Annex 56-A
29Annex 56-A
30 Annex 56-A
31Annex 56-A
32 Annex 56-A
33Annex 56-A
34 Annex 56-A
35Annex 56-A
36 Annex 56-A
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---- ---- ----
STUDYL/NO.:U359E616ALESNT-O--MA-LE#------O-BAH6F6TIO-CEUS4NEDTA-AEDURSSI--HOFENLAL--USINT-REO--SK-M-
13SIAL-A---6N--PYE--A-------
-E-P---P1---=----------------
37Annex 56-A
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---- ---- ----
STUDLY/NO.:S35E9616MALES--FEM-ALE#------6OB2671A--ED6LEDUE-SASOFTSAA-OEUSEDOO--LHANAS----------1--Y-
F
S
4--Y------7--PP---------------
38 Annex 56-A
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---- ---- ----
STUDNYLNO.:US359MALE-S--ANIMAL#-5-----4M3846Y1---53TUDY--59-375--04-143A-45-EATH-75DAY)---5--------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
39Annex 56-A
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---- ---- ----
STUDY/N,O.:S359FEMALESANIM-AL#-----213171N-.NOF-S-----8---1---8---1----1-DE19---4DA29)-----------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
40 Annex 56-A
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1 ---- ---- ----
STUINL/A, US DE1MALES-----OAL0-A6/K-DOA23---30-YY-C-02646-SE-30-DEC----OESLUE--3--TNEN---N--ENILII-L
-TOPSRM---
L.XTTS-
---CM--
-----ON----A---
41Annex 56-A
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2 ---- ---- ----
STINL/A, US DEFEMALES--IMA00-A6/KA-OFT----E--D-0-1--4-3----14T-1TISI-I-AT--OHIN--I-TH--TLII--IL-L
-RMAL----MITS------
42 Annex 56-A
43Annex 56-A
44 Annex 56-A
AN ACUTE DERMAL TOXICITY STUDY
IN RATS WITH SPRAY--CHARLIE
FINAL REPORT
OPPTS Guideline
870.1200
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
February 20, 2003
Performing Laboratory
Springborn Laboratories (SLI),
a division of Charles River Company, Inc.
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.17
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 29
45Annex 56-A
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SLI Study No. 3596.17
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date
Title Signature
46 Annex 56-A
47Annex 56-A
48 Annex 56-A
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SLI Study No. 3596.17
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS......................... 2
2. COMPLIANCE STATEMENT....................................................................... 3
3. QUALITY ASSURANCE STATEMENT ....................................................... 4
4. TABLE OF CONTENTS............................................................................... 5
5. LIST OF TABLES AND APPENDICES........................................................ 6
6. SUMMARY................................................................................................... 7
7. INTRODUCTION.......................................................................................... 8
8. MATERIALS AND METHODS..................................................................... 8
9. EXPERIMENTAL PROCEDURES ............................................................. 11
10. DATA ACQUISITION AND ELECTRONIC RECORDS ........................... 12
11. ANALYSIS OF DATA........................................................................
....... 12
12. MAINTENANCE OF RAW DATA AND RECORDS................................. 13
13. RESULTS................................................................................................. 13
14. CONCLUSION ........................................................................
................. 14
15. REPORT REVIEW ........................................................................
........... 14
16. REFERENCES........................................................................
................. 15
49Annex 56-A
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SLI Study No. 3596.17
5. LIST OF TABLES AND APPENDICES
Tables
1. Individual Clinical Observations ..........................................................16
2. Individual Body Weights......................................................................19
3. Individual Gross Necropsy Observations ............................................21
Appendices
A. Macroscopic Dermal Grading System................................................23
B. SLI Personnel Responsibilities...........................................................28
50 Annex 56-A
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SLI Study No. 3596.17
6. SUMMARY
The single-dose dermal toxicity of Spray--Charlie was evaluated in Sprague
Dawley rats. A limit test was performed in which one group of five male and five
female rats received a single dermal administration of the test article at a dose of
5000 mg/kg body weight. Following dosing, the limit test rats were observed daily
and weighed weekly. A gross necropsy examination was performed on all
animals at the time of scheduled euthanasia (day 14).
No mortality occurred during the limit test. Clinical abnormalities observed during
the study included transient incidences of dark material around the facial area
and decreased defecation. Dermal irritation was noted at the site of test article
application. Body weight loss was noted in one male and two females during the
study day 7 to 14 body weight interval. Body weight gain was noted for all other
animals during the test period. No significant gross internal findings were
observed at necropsy on study day 14.
Under the conditions of this test, the acute dermal LD50 of Spray--Charlie was
estimated to be greater than 5000 mg/kg in the rat.
51Annex 56-A
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SLI Study No. 3596.17
7. INTRODUCTION
This study was performed to assess the short-term toxicity of Spray--Charlie in
Sprague Dawley rats when administered by a single dermal dose. This study
was intended to provide information on the potential health hazards of the test
article with respect to dermal exposure. Data from this study may serve as a
basis for classification and/or labeling of the test article. This study was
performed in accordance with the US EPA, Health Effects Test Guidelines,
OPPTS 870.1200, Acute Dermal Toxicity, August 1998. This study was
performed at Springborn Laboratories (SLI), 553 North Broadway, Spencerville,
Ohio. The protocol was signed by the Study Director on October 9, 2002 (GLP
initiation date). The in-life phase of the study was initiated with test article
administration on December 19, 2002 (day 0), and concluded with necropsy on
January 2, 2003.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows:
Assigned Physical Receipt Expiration
Sponsor’s ID SLI ID Description Date Date
Spray—Charlie a S02.003.3596 Amber 12/09/02 None
liquid provided
b
Ingredients:
Herbicide: GLY-41 None
Lot No.: Manufactured 10/20/02 provided
Surfactant: Cosmo Flux-411F None
Lot No.: Manufactured 11/20/02 provided
aSample pooled at SLI from five different mixes of Spray--Charlie (top/middle/bottom).
b
Ingredients used in the five Spray--Charlie mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength, purity, composition,
stability and method of synthesis of the test material according to
40 CFR 160.105 and 40 CFR 792.105. Springborn Laboratories, Inc. analyzed
the test article for the glyphosate (a.e.) which is presented in
SLI Study No. 3596.15.
52 Annex 56-A
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SLI Study No. 3596.17
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture sample
(top/middle/bottom, maintained separately for a total of fifteen 1 mL samples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The test article was returned to the Sponsor following completion of all studies
with the test article.
8.4. Method of Test Article Preparation
The test articles were pooled and administered as received from the Sponsor
and dispensed fresh on the day of dosing. The test articles were stirred
continuously during dosing. The density of the test article was determined to be
1.08 g/mL.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Adult, Hsd: Sprague Dawley® SD® rats were received from Harlan Sprague
Dawley, Inc., Indianapolis, IN. Upon receipt, metal ear tags displaying unique
identification numbers were used to individually identify the animals. Cage cards
displaying at least the study number, animal number and sex were affixed to
each cage. The animals were housed individually in suspended stainless steel
cages. All housing and care were based on the standards recommended by the
Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 71-74°F
(22-23°C) and 40-53%, respectively. Environmental control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10-15 air changes/hour. The animal
room temperature and relative humidity were recorded a minimum of once daily.
8.5.3. Food
PMI Certified Rodent Chow #5002 (Purina Mills, Inc.) was provided ad libitum to
the animals throughout the study. The lot number and expiration date of each
53Annex 56-A
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SLI Study No. 3596.17
batch of diet used during the study were recorded. The feed was analyzed and
certified by the supplier for nutritional components and environmental
contaminants. Dietary limitations for various environmental contaminants,
including heavy metals, pesticides, polychlorinated biphenyls and total aflatoxin
are set by the manufacturer. Within these limits, contaminants which may have
been present were not expected to compromise the purpose of this study.
Results of the dietary analyses (Certificates of Analysis) were provided by the
manufacturer for each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study. The purified water was supplied by an automatic watering
system. Monitoring of the drinking water for contaminants is conducted by SLI
and the records are available for inspection. Within generally accepted limits,
contaminants which may have been present were not expected to compromise
the purpose of this study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with metal ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The animals
were observed daily for overt physical or behavioral abnormalities, general
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were randomly selected from healthy stock
animals using a computerized random numbers table to avoid potential bias. All
animals received a detailed pretest observation prior to dosing. Only healthy
animals were chosen for study use. Females were nulliparous and nonpregnant.
The male animals were approximately 9 weeks of age and weighed 265-290 g
prior to dosing. The female animals were approximately 9 weeks of age and
weighed 189-207 g prior to dosing.
54 Annex 56-A
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SLI Study No. 3596.17
9. EXPERIMENTAL PROCEDURES
9.1. Preliminary Procedures
On day -1, the fur was removed from the dorsal trunk area of the animals chosen
for the limit test using an animal clipper. The clipped area was approximately
10% of the animal’s body surface area (BSA). The region included the scapula
(shoulder) to the wing of the ilium (hipbone) and half way down the flank on each
side of the animal. Care was taken to avoid abrading the skin during the clipping
procedure.
9.2. Dosing
On the following day (day 0), the test article was administered dermally to
approximately 10% of the body surface area. The four corners of this area were
delineated in the clipped area with an indelible marker. The test article was then
spread evenly over the delineated test area and held in contact with the skin with
an appropriately sized 4-ply porous gauze dressing backed with a plastic wrap
which was placed over the gauze dressing (occlusive binding). Removal and
ingestion of the test article was prevented by placing an elastic wrap over the
trunk and test area. The elastic wrap was further secured with a tape harness on
the cranial end of the trunk and then secured with adhesive tape around the trunk
at the caudal end.
The test article was administered at the following level:
Dose Level Dose Volume Concentration No. of Animals
Male Female
(mg/kg) (mL/ka) (%)b
a 5000 4.63 100 5 5
Adjusted based on a density of 1.08 g/mL.
Pooled test article.
Individual doses were calculated based on the animal’s day 0 body weight. After
an approximate 24-hour exposure period, the binding materials were removed
and the corners of the test site were re-delineated using a marker. Residual test
article was removed using gauze moistened with deionized water followed by dry
gauze.
9.3. Dermal Observations
The test animals were examined for erythema and edema following patch
removal and the responses scored on study day 1 and daily thereafter
55Annex 56-A
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SLI Study No. 3596.17
(days 2-14) according to the Macroscopic Dermal Grading System provided in
Appendix A which is based on Draize [2]. The dermal test sites were reclipped
as necessary to allow clear visualization of the skin.
9.4. Clinical Observations
The animals were observed for clinical abnormalities two times on study day 0
(postdose) and daily thereafter (days 1-14). A mortality check was performed
twice daily, in the morning and afternoon.
9.5. Body Weights
Individual body weights were obtained for the animals prior to dosing on day 0
and on days 7 and 14.
9.6. Gross Necropsy
All animals were euthanized by carbon dioxide inhalation at study termination
(day 14) and necropsied. Body cavities (cranial, thoracic, abdominal and pelvic)
were opened and examined. No tissues were retained.
9.7. Protocol Deviations
On study day 1, edema was inadvertently not recorded for Animal No. A6709.
This occurrence was considered to have had no adverse effect on the outcome
of this study.
10. DATA ACQUISITION AND ELECTRONIC RECORDS
Electronic data were recorded on a Compaq Alpha Server DS10 utilizing the
Toxicology Analysis System Customized, Acute Toxicology Module, Version
1.0.0 or higher. The SLI study number assigned to this study is 3596.17. The
computer study number used to collect data for the study phases was 359617.
The tables within the report will display the applicable computer number.
11. ANALYSIS OF DATA
Data from the study were analyzed and an LD50 value estimated as follows:
< 50% Mortality: LD50 was estimated as greater than the administered dose.
= 50% Mortality: LD50 was estimated as equal to the administered dose.
> 50% Mortality: LD50 was estimated as less than the administered dose.
56 Annex 56-A
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SLI Study No. 3596.17
Body weight means and standard deviations were calculated separately for
males and females.
12. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and electronic records were transferred to
the SLI archives for a period of 10 years. The Sponsor will be contacted prior to
final disposition of these items.
13. RESULTS
13.1. Mortality
Individual Data: Table 1
No mortality occurred during the limit test.
13.2. Clinical/Dermal Observations
Individual Data: Table 1
Clinical abnormalities observed during the study included transient incidences of
dark material around the facial area and decreased defecation. Dermal irritation
was noted at the site of test article application.
13.3. Body Weight Data
Individual Data: Table 2
Body weight loss was noted in one male and two females during the study day 7
to 14 body weight interval. Body weight gain was noted for all other animals
during the test period.
13.4. Gross Necropsy
Individual Data: Table 3
No significant gross internal findings were observed at necropsy on study day 14.
57Annex 56-A
58 Annex 56-A
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SLI Study No. 3596.17
16. REFERENCES
1. Guide for the Care and Use of Laboratory Animals, DHHS Publication No.
(NIH) 96-03, 1996.
2.Draize, J.H., Appraisal of the Safety of Chemicals in Foods, Drugs and
Cosmetics, The Association of Food and Drug Officials of the United States,
49-51, 1959.
59Annex 56-A
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---- ---- ----
STUDYL/NO.:U3596D17ALESMENT--MAL-E#------OB-SHEFTERYAS-ETHEG0AIAI-REDRAAATE--UAIHKRKUOH-NDDLAL)-U--RRIRER---PS
DND
-
-8-PTM-----------
60 Annex 56-A
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---- ---- ----
STUDLY/NO.:.3.59617LESME-N---MALE#----0--OBSER-DUATRKR--TH0AIAI--AROUNDN--YE(S)-----------------D----
F
ST-P-YP
-P--7---P----1----P------P-14--R----------------
61Annex 56-A
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---- ---- ----
STUDY/N,O.:.359617MRALESN-FEMALE#-------OBSERVATI-RADATETMA---THEUMDNHEW-SRYARAETSA--ADAL)0-EUADEG-REODU-A5-A
P
PI---OU--P2P---------
62 Annex 56-A
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STUDLY/NO.:.S35MALES-TA-NIMAL#--86---9M9703Y0O--39-UDY--01-144A-95-EATH-05DAY)---5----------------------------------------
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63Annex 56-A
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STIUDY/NO.:.S35FEMALE-ANI-MAL#------151620Y0--040TU1Y---27--911-D2-----0DAY6--------------------------------------------
-------------------------------------
--------------------------------------I--N--L--/--A--,----U--.--S--.--M
64 Annex 56-A
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1 ---- ---- ----
STINL/A, U.S.MDAL-ES----5000------4A6696-ST---036--0-N-B--NJA----N---RESL-U-SS---TORR-N-N----TSIVI--M---
-L--
------------
-
----------------
65Annex 56-A
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2 ---- ---- ----
STINL/A, U.S.FDE-MALES--500-------96710--S5--1037-0-N-O--AJAN---ON---UESL-E-SU--SNOS-N-N----NTSN-T-MI---
LI-
ITS
----
66 Annex 56-A
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SLI Study No. 3596.17
APPENDIX A
Macroscopic Dermal Grading System
67Annex 56-A
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SLI Study No. 3596.17
MACROSCOPIC DERMAL GRADING SYSTEM
ERYTHEMA AND EDEMA OBSERVATIONS
OBSERVATION DEFINITION CODE
Erythema – Grade 0 No erythema 0
Erythema – Grade 1 Very slight erythema (barely perceptible) 1
Erythema – Grade 2 Well-defined erythema 2
Erythema – Grade 3 Moderate to severe erythema 3
Erythema – Grade 4 Severe erythema (beet redness) 4
Maximized Grade 4 Notable dermal lesions (see below) M – 4
(see below)
Edema – Grade 0 No edema 0
Edema – Grade 1 Very slight edema (barely perceptible) 1
Slight edema (edges of area well defined by definite
Edema – Grade 2 raising) 2
Edema – Grade 3 Moderate edema (raised approximately 1 millimeter) 3
Edema – Grade 4 Severe edema (raised more than 1 millimeter and 4
extends beyond the area of exposure)
NOTE: Each animal was assigned an erythema and edema score. The most severely affected
area within the test site was graded. If eschar, blanching, ulceration and/or necrosis greater
than grade 1 was observed, then the “Maximized Grade 4" was assigned to the test site in
place of the erythema score and the type of notable dermal lesion(s) (e.g., eschar - grade 2,
blanching - grade 3, ulceration - grade 4, etc.) was noted. The presence of any other dermal
changes (e.g., desquamation, fissuring, eschar exfoliation, etc.) was also recorded.
68 Annex 56-A
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SLI Study No. 3596.17
MACROSCOPIC DERMAL GRADING SYSTEM
NOTABLE DERMAL LESIONS
OBSERVATION CODE DEFINITION
Eschar – Grade 1 ES-1 Focal and/or pinpoint areas up to 10% of test site.
Eschar – Grade 2 ES-2 > 10% < 25% of test site.
Eschar – Grade 3 ES-3 > 25% < 50% of test site.
Eschar – Grade 4 ES-4 > 50% of test site.
Blanching – Grade 1 BLA-1 Focal and/or pinpoint areas up to 10% of test site.
Blanching – Grade 2 BLA-2 > 10% < 25% of test site.
Blanching – Grade 3 BLA-3 > 25% < 50% of test site.
Blanching – Grade 4 BLA-4 > 50% of test site.
Ulceration – Grade 1 U-1 Focal and/or pinpoint areas up to 10% of test site.
Ulceration – Grade 2 U-2 > 10% < 25% of test site.
Ulceration – Grade 3 U-3 > 25% < 50% of test site.
Ulceration – Grade 4 U-4 > 50% of test site.
Necrosis – Grade 1 NEC-1 Focal and/or pinpoint areas up to 10% of test site
(color) (Note color of necrosis).
Necrosis – Grade 2 NEC-2 > 10% < 25% of test site (Note color of necrosis).
(color)
NEC-3
Necrosis – Grade 3 > 25% < 50% of test site (Note color of necrosis).
(color)
NEC-4
Necrosis – Grade 4 > 50% of test site (Note color of necrosis).
(color)
69Annex 56-A
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SLI Study No. 3596.17
MACROSCOPIC DERMAL GRADING SYSTEM
ADDITIONAL DERMAL FINDINGS
OBSERVATION DEFINITION CODE
Characterized by scaling or flaking of
Desquamation dermal tissue with or without denuded DES
areas.
Characterized by cracking of the skin with
or without moist exudate. Fissuring should
Fissuring be checked prior to removing the animal FIS
from the cage and manipulating the test
site.
The process by which areas of eschar
Eschar Exfoliation EXF
flake off the test site.
Skin located at test site appears to be
TSS
Test Site Staining discolored, possibly due to test article (color)
(note color of staining).
The erythema extends beyond the test
Erythema Extends Beyond site. Note: A study director should be
the Test Site contacted for erythema extending beyond ERB
the test site.
Characterized by pale area(s) (almost a --
burn-like appearance) in the test site.
However, erythema may still be observed
through the pale area. Note: This
observation may affect the overall
erythema score of the test site. This
observation may progress to other
Superficial Lightening
observations resulting in notable dermal
lesions, but SL itself will not be considered
a notable dermal lesion that will result in a
dermal score to be maximized since it
does not result in any in-depth injury. To
be coded using an area designation (see
below).
Superficial Lightening - Focal and/or pinpoint areas up to 10% of
Grade 1 the test site SL-1
Superficial Lightening - > 10% < 25% of test site SL-2
Grade 2
Superficial Lightening - > 25% < 50% of test site SL-3
Grade 3
Superficial Lightening - > 50% of test site
SL-4
Grade 4
70 Annex 56-A
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SLI Study No. 3596.17
MACROSCOPIC DERMAL GRADING SYSTEM
ADDITIONAL FINDINGS
OBSERVATION DEFINITION CODE
Noticeable irritation outside of test site
Dermal Irritation - Outside oprobably due to the binding tape material. IT
the Test Site This notation will only be made for
reactions greater than what are normally
observed from tape removal which do not
interfere with the scoring of the test site.
71Annex 56-A
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SLI Study No. 3596.17
APPENDIX B
SLI Personnel Responsibilities
72 Annex 56-A
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SLI Study No. 3596.17
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Toxicologist
Malcolm Blair, Ph.D. Managing Director Emeritus
Joseph C. Siglin, Ph.D., DABT General Manager
Rusty E. Rush, M.S., LAT, DABT Director, Neurotoxicity and Transgenics
Jason W. Smedley, B.S. Assistant Toxicologist
Pamela S. Smith, ALAT Study Supervisor, Acute Toxicology
Christina L. Zehender, B.S. Primary Technician/Acute Technician I
Delores P. Knippen Supervisor, Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor, Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Cheryl Bellamy Senior Supervisor, Report Writing
Deanna M. Talerico, RQAP-GLP Senior Supervisor, Quality Assurance
J. Dale Thurman, D.V.M., M.S., Senior Director, Pathology
DACVP
Kathy M. Gasser Archivist
73Annex 56-A
AN ACUTE NOSE-ONLY INHALATION TOXICITY
STUDY IN RATS WITH SPRAY--CHARLIE
FINAL REPORT
OPPTS Guidelines
870.1300
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
March 14, 2003
Performing Laboratory
Springborn Laboratories (SLI),
a division of Charles River Laboratories, Inc.
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.18
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 52
74 Annex 56-A
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SLI Study No. 3596.18
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: ____________________ Date
Title Signature
75Annex 56-A
76 Annex 56-A
77Annex 56-A
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SLI Study No. 3596.18
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS......................... 2
2. COMPLIANCE STATEMENT....................................................................... 3
3. QUALITY ASSURANCE STATEMENT ....................................................... 4
4. TABLE OF CONTENTS........................................................................
....... 5
5. LIST OF TABLES AND APPENDICES........................................................ 6
6. SUMMARY........................................................................
........................... 7
7. INTRODUCTION........................................................................
.................. 8
8. MATERIALS AND METHODS..................................................................... 8
9. EXPERIMENTAL PROCEDURES ............................................................. 11
10. ANALYSIS OF DATA........................................................................
....... 14
11. MAINTENANCE OF RAW DATA AND RECORDS................................. 14
12. RESULTS........................................................................
......................... 14
13. CONCLUSION ........................................................................
................. 16
14. REPORT REVIEW ........................................................................
........... 16
15. REFERENCE ........................................................................
................... 17
78 Annex 56-A
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SLI Study No. 3596.18
5. LIST OF TABLES AND APPENDICES
Tables
1. Summary of Aerosol Generation and Chamber Environmental Data......18
2. Individual Clinical Observations ..............................................................19
3. Individual Body Weights..........................................................................23
4. Individual Gross Necropsy Observations................................................25
Figure
1. Multi-Stage 10L Nose-Only Inhalation Chamber......................................27
Appendices
A. Preliminary Aerosol Generation Trials......................................................28
B. Analytical Chemistry Report.....................................................................36
C. Individual Aerosol Generation and Chamber Environmental Data...........43
D. SLI Personnel Responsibilities.................................................................51
79Annex 56-A
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SLI Study No. 3596.18
6. SUMMARY
The four-hour nose-only inhalation toxicity of Spray--Charlie was evaluated in
Sprague Dawley rats. A limit test was performed in which a group of five male
and five female rats received a four-hour nose-only inhalation exposure to a time-
weighted average aerosol concentration (analytically determined) of 2.60 mg/L.
The mass median aerodynamic diameter and geometric standard deviation of the
sampled particles were 2.9 µ + 2.17. The percentage of particles < 4.0 µ was
determined to be 66%. Following the exposure, the limit test rats were observed
daily and weighed weekly. A gross necropsy examination was performed on all
limit test animals at the time of scheduled euthanasia (day 14).
No mortality occurred during the study. The most notable clinical abnormalities
observed during the study included breathing abnormalities, no/decreased
defecation, urine staining, rough haircoat, dark material around the facial area
and decreased food consumption. Body weight loss was noted in two males and
one female during the day 0 to 7 body weight interval. Body weight gain was
noted for all other animals during the test period. At study termination, the
animals had exceeded/maintained their initial body weight. No gross internal
findings were observed at necropsy on study day 14.
Under the conditions of this test, the acute inhalation LC50 of Spray--Charlie was
estimated to be greater than 2.60 mg/L in the rat (which was well above the EPA-
required 2.00 mg/L).
80 Annex 56-A
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SLI Study No. 3596.18
7. INTRODUCTION
This study was performed to assess the short-term toxicity of Spray--Charlie in
Sprague Dawley rats when administered by a four-hour nose-only inhalation
exposure. This study was intended to provide information on the potential health
hazards of the test article with respect to inhalation exposure. Data from this
study may serve as a basis for classification and/or labeling of the test article.
This study was conducted in accordance with the US EPA, Health Effects Test
Guidelines, OPPTS 870.1300, Acute Inhalation Toxicity, August, 1998. This
study was performed at Springborn Laboratories (SLI), 553 North Broadway,
Spencerville, Ohio. The protocol was signed by the Study Director on
October 9, 2002 (GLP initiation date). The in-life phase of the study was initiated
with test article administration on January 14, 2003 (day 0) and concluded with
terminal euthanasia on January 28, 2003.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows:
Assigned Physical Receipt Expiration
Spansor’s ID SLI ID Description Date Date
Spray--Charlie S02.003.3596 Amber 12/09/02 None
liquid provided
b
Ingredients:
Herbicide: GLY-41 None
Lot No.: Manufactured 10/20/02 provided
Surfactant: Cosmo Flux-411F None
a Lot No.: Manufactured 11/29/02 provided
bSample pooled at SLI from five different mixes of Spray--Charlie (top/middle/bottom).
Ingredients used in the five Spray--Charlie mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength, purity, composition,
stability and method of synthesis of the test material according to
40 CFR 160.105 and 40 CFR 792.105. Springborn Laboratories analyzed the
test article for the glyphosate (a.e.) which is presented in
SLI Study No. 3596.15.
81Annex 56-A
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SLI Study No. 3596.18
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture sample
(top/middle/bottom, maintained separately for a total of fifteen 1 mL samples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The test article was returned to the Sponsor following completion of all studies
with the test article.
8.4. Method of Test Article Preparation
The test articles were pooled and administered as received from the Sponsor
and dispensed fresh on the day of dosing. The pooled test article was stirred
approximately 10 minutes prior to dispensation and stirred continuously during
dosing.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Young adult, Hsd: Sprague Dawley® SD® rats were received from Harlan
Sprague Dawley, Inc., Indianapolis, IN. Upon receipt, metal ear tags displaying
unique identification numbers were used to individually identify the animals.
Cage cards displaying at least the study number, animal number and sex were
affixed to each cage. The animals were housed individually in suspended
stainless steel cages. All housing and care were based on the standards
recommended by the Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 64-68°F
(18-20°C) and 37-55%, respectively. Environmental control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10-15 air changes/hour. The animal
room temperature and relative humidity were recorded a minimum of once daily.
8.5.3. Food
PMI Certified Rodent Chow #5002 (Purina Mills, Inc.) was provided ad libitum to
the animals throughout the study (except during the time that the animals were
82 Annex 56-A
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SLI Study No. 3596.18
acclimated to the exposure tubes and maintained in the inhalation room for the
exposure procedure). The lot number and expiration date of each batch of diet
used during the study were recorded. The feed was analyzed and certified by the
supplier for nutritional components and environmental contaminants. Dietary
limitations for various environmental contaminants, including heavy metals,
pesticides, polychlorinated biphenyls and total aflatoxin are set by the
manufacturer. Within these limits, contaminants which may have been present
were not expected to compromise the purpose of this study. Results of the
dietary analyses (Certificates of Analysis) are provided by the manufacturer for
each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study (except during the time that the animals were acclimated to
the exposure tubes and maintained in the inhalation room for the exposure
procedure). The purified water was supplied by an automatic watering system.
Monitoring of the drinking water for contaminants is conducted by SLI and the
records are available for inspection. Within generally accepted limits,
contaminants which may have been present were not expected to compromise
the purpose of this study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with metal ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The animals
were observed daily for overt physical or behavioral abnormalities, general
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were randomly selected from healthy stock
animals using a computerized random numbers table to avoid potential bias. All
animals received a detailed pretest observation prior to dosing. Only healthy
animals were chosen for study use. Females were nulliparous and nonpregnant.
The male animals were approximately 9 weeks of age and weighed 248-275 g on
the day of exposure. The female animals were approximately 9 weeks of age
and weighed 201-212 g on the day of exposure.
83Annex 56-A
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SLI Study No. 3596.18
9. EXPERIMENTAL PROCEDURES
9.1. Preliminary Procedures
9.1.1. Test Article Volatility Determination
The volatility of the test article relative to a distilled water standard was
determined prior to experimental initiation. This procedure was performed in
order to determine if the test article had sufficiently low volatility to allow for an
accurate gravimetric determination of the aerosol concentration. A known
quantity of the test article was placed on a preweighed filter disk and was allowed
to evaporate for a total of ten minutes. The test article weight was determined
each minute and the amount of evaporation of the test article was then
determined. The results of this volatility trial indicated that the test article
evaporation rate (0.82 mg/minute) was only slightly higher than the SLI
determined distilled water evaporation rate (0.55 mg/minute); therefore was
considered to not be volatile.
9.1.2. Preliminary Aerosol Generation Trials
Prior to experimental initiation, preliminary aerosol generation trials were
conducted. These trials were performed in order to determine the most efficient
means of generating an aerosol of the appropriate concentration while utilizing
equipment that would reduce the aerodynamic particle size. Data obtained
during the preliminary aerosol generation trials are presented in Appendix A.
9.2. Limit Test
9.2.1. Aerosol Generation Equipment
The test aerosol was generated with a Pistol Spraying System and a Master Flex
Pump and Pump Heads 77200-60 and 7523-30. Conditioned high pressure
external air was used in generating the test atmosphere. The aerosol was blown
through a 5L Elutriator, the Multi-Stage 10L nose-only inhalation chamber and
then vented from the chamber to an air treatment system which consisted of a
prefilter, a HEPA filter, a charcoal bed and a water scrubbing tower (see
Figure 1).
9.2.2. Dosing
On day 0, the animals chosen for the limit test were weighed, placed in a nose-
only exposure tube and allowed to acclimate to the exposure tube for at least
1 hour. Animals that appeared to have been acclimated to the exposure tube
(i.e., minimal struggling and no inversion) were considered to be acceptable,
84 Annex 56-A
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SLI Study No. 3596.18
removed from the exposure tube and returned to their cages until initiation of the
aerosol exposure. Animals that did not appear to acclimate to the exposure tube
were not acceptable, removed from the exposure tube and returned to their
cages.
The acceptable animals were then placed in exposure tubes, the tubes inserted
into the Multi-Stage 10L nose-only inhalation chamber and the test article
aerosolized at the following level:
Exposure Level No. of Animals
(mg/L) Male Female
2.60 5 5
The aerosol exposure consisted of a 3-minute T99 equilibration period, a
240-minute exposure period and a 3-minute de-equilibration period equal to the
T99 equilibration period. After each aerosol exposure, animals were removed
from the exposure tubes and residual test article was removed from the animal's
exterior surfaces (where practical) by wiping the haircoat with a towel. The
animals were then returned to ad libitum feed and water. The following
parameters were measured during the exposure.
9.2.2.1. Chamber Air Flow
Air flow readings were recorded at the initiation of the T99 equilibration period, at
approximate 30-minute intervals during the aerosol exposure and at the
conclusion of the de-equilibration period.
9.2.2.2. Aerosol Concentration
The aerosol concentration was measured at the beginning of the aerosol
exposure (after equilibration), at approximate 30-minute intervals during the
aerosol exposure and at the conclusion of the aerosol exposure (before de-
equilibration). The concentration of the test article aerosol was collected in the
inhalation chamber by gravimetric technique. A 5 L sample of the aerosol was
drawn from the breathing zone of the chamber through a preweighed glass fiber
filter. The change in weight of the filter (mg) was then determined and this value
was divided by the volume of chamber atmosphere sampled (L) to yield the
gravimetric concentration (mg/L). The average time-weighted gravimetric
concentration of the test atmosphere was then calculated for the exposure. For
the analytical concentration, the gravimetrically obtained samples were analyzed
by Springborn Laboratories for the glyphosate component, a non-volatile
component of the test article. These analyses were performed in order to
determine the analytical (actual) concentrations of the aerosol in the chamber for
each sampling period. The average time weighted analytical concentration of the
85Annex 56-A
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SLI Study No. 3596.18
test atmosphere was then calculated for the exposure. Chemistry methods and
results are detailed in the Analytical Chemistry Report (Appendix B).
9.2.2.3. Chamber Temperature and Humidity
The chamber temperature and humidity were measured electronically and
recorded at approximate 30-minute intervals during the aerosol exposure using a
Vaisala HMI 41 Thermometer.
9.2.2.4. Aerosol Aerodynamic Particle-Size Distribution
The aerosol aerodynamic particle-size distribution was determined three times
during the aerosol exposure using the ITP 7 Stage Cascade Impactor. Each
stage of the impactor was fitted with a preweighed glass fiber filter. Five liters
per minute of the chamber air were drawn through the impactor and the change
in weight of each filter was then determined and recorded. The mean particle-
size distribution was subsequently determined using an Excel computer
adaptation of the manual method. The Mass Median Aerodynamic Diameter,
Geometric Standard Deviation and percentage of particles < 4.0 µ were then
determined. At least one hour passed between each aerosol particle-size
analysis.
9.2.2.5. Chamber Oxygen
Chamber oxygen content was measured and recorded at approximate 30-minute
intervals during the aerosol exposure using a GC-501 Oxygen Sensor.
9.2.3. Clinical Observations
The limit test animals were observed for clinical abnormalities during each
aerosol exposure, two times on study day 0 (post-exposure) and daily thereafter
(days 1-14). A general health/mortality check was performed twice daily (in the
morning and in the afternoon).
9.2.4. Body Weights
Individual body weights were obtained for the limit test animals prior to dosing on
day 0 and on days 7 and 14.
9.2.5. Gross Necropsy
All limit test animals were euthanized by carbon dioxide inhalation at study
termination (day 14) and necropsied. Body cavities (cranial, thoracic, abdominal
and pelvic) were opened and examined. No tissues were retained.
86 Annex 56-A
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SLI Study No. 3596.18
9.3. Protocol Deviations
The temperature of the animal room [64-68°F (18-20°C)] exceeded the preferred
range [66-77°F (19-25°C)] during this study. This occurrence was considered to
have had no adverse effect on the outcome of this study.
10. ANALYSIS OF DATA
Data from the limit tests were analyzed and an LC50 value estimated as follows:
< 50% Mortality: LC50 was estimated as greater than the administered dose.
= 50% Mortality: LC50 was estimated as equal to the administered dose.
> 50% Mortality: LC50 was estimated as less than the administered dose.
Body weight means and standard deviations were calculated separately for
males and females. The aerodynamic particle-size distribution of the test article
aerosol was plotted using an Excel computer adaptation of the three cycle
logarithmic probability paper as per the ITP Cascade Impactor instruction
manual. The Mass Median Aerodynamic Diameter, Geometric Standard
Deviation and particles < 4.0 µ were determined based on the plotted distribution.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and electronic encoded records were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
12. RESULTS
12.1. Aerosol Generation and Chamber Environmental Data
12.1.1. Aerosol Generation Data
Individual Data: Table 1
The average time-weighted analytical concentration for the aerosol exposure was
determined to be 2.60 mg/L. The mass median aerodynamic diameter and
geometric standard deviation of the sampled particles were 2.9µ ± 2.17. The
percentage of particles < 4.0 µ was determined to be 66%.
87Annex 56-A
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SLI Study No. 3596.18
12.1.2. Chamber Environmental Data
Individual Data: Table 1
Chamber temperature and relative humidity for the aerosol exposure ranged from
68.3-70.7°F and 68.3-69.3%, respectively. Oxygen content was maintained at
20.9% throughout the exposure.
12.2. Limit Test Data
12.2.1. Mortality
Individual Data: Table 2
No mortality occurred during the study.
12.2.2. Clinical Observations
Individual Data: Table 2
No positive findings were noted at the time of observation during the 4-hour
exposure period. The most notable clinical abnormalities observed during the
study included breathing abnormalities, no/decreased defecation, urine staining,
rough haircoat, dark material around the facial area and decreased food
consumption.
12.2.3. Body Weight Data
Individual Data: Table 3
Body weight loss was noted in two males and one female during the day 0 to 7
body weight interval. Body weight gain was noted for all other animals during the
test period. At study termination, the animals had exceeded/maintained their
initial body weight.
12.2.4. Gross Necropsy
Individual Data: Table 4
No gross internal findings were observed at necropsy on study day 14.
88 Annex 56-A
89Annex 56-A
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SLI Study No. 3596.18
15. REFERENCE
1. Guide for the Care and Use of Laboratory Animals, DHHS Publication No.
(NIH) 96-03, 1996.
90 Annex 56-A
(18)
PAGE 1
10 5 24 3 3 66
2.60 95.24240 70.3060 2.9±2.17 20.9
68.37.03.-769.3
EXPOSURE LEVEL (MG/L)
TABLE 1
CHAMBER ENVIRONMENTAL DATA
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
4.0 µ (%):
≤
STINL/A, U.S. DEPARTMENT OF STATEOTREIQLWLUQSUMMARY OF AEROSOL GENERATION ANDCDLGYSNSNGNE(%N:(%N):(MG/L):
91Annex 56-A
(19)
---- ---- ----
STUDYSNO.:PA3MALES--O----MALE#-------OBSERVATI--U0RCES68RD-LETCHEDUDSSASGREHANTCERI-LO----1--RNOSTDTAA-
FLSTUDUOC--EPE(S)-11R-----------P
92 Annex 56-A
(20)
---- ---- ----
STUDY.NDO.:A3-9LES---2--MAL--#------O-HSNRVAGIO-EBNBRES-E-GHKRKC---RIALALO-GHNDNNSUM-OTHON------
-
PAY--5F
S
P
Y--P-PP--P---LP--P----1R--------------------
93Annex 56-A
(21)
---- ---- ----
STUUDY.NO.:A3TFEMALES--FEMALE-#------OBS--ULSSUFOINUG-AHIHOT-U-G--EETNEREA1---ERERD---D0--CMAMU
--A
-AROUOCOU-2--S)PPNP---11-------------P
94 Annex 56-A
(22)
---- ---- ----
STUDY.NDO.:AFEM--8ES-F-EMALE#------SOBSERVATI--EBNBRESCES6-MTTETATSEDU-SSNRNIN-RIA-IDANAD--E2--LALAFOO-H--YEOSOPT--RNP-P-------V3-P--
-P--REP-----------
95Annex 56-A
(23)
---- ---- ----
STUDYSNOD.:P359MMALES--ANI-MAL#----30386EA-3Y0OF---9--48---9--535-D---T7-(D-AY)-------------------------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
96 Annex 56-A
(24)
---- ---- ----
STUDSY.NO.:AR35FEMAL-EA-NIMAL#--4858-5ME-60Y0OF--12U2Y---35-47AT-52-7T2-4-DAY)-------------------------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
97Annex 56-A
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1 ---- ---- ----
STU.S. DEPARTMMALES----TMA0-MA6L-A-OFT----A--J-8-3--4-2----14T-1TISI-I-AT--LHIN--I-TH--TLII--IL-L
-IMAL----MITS------
98 Annex 56-A
(26)
2 ---- ---- ----
STU.S. DEPARTMFEM-ALEA-2.60-M--D---6850---TUD--3860---03S--AAL0-A------ILWG---ES---TMAP-M-OR---NVNT---S---SMIT--
-------
-
-------------------
99Annex 56-A
(27)
100 Annex 56-A
(28)
SLI Study No. 3596.18
APPENDIX A
Preliminary Aerosol Generation Trials
101Annex 56-A
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SLI Study No. 3596.18
1. PRELIMINARY AEROSOL GENERATION TRIALS
Prior to experimental initiation, preliminary aerosol generation trials were
conducted. These trials were performed to determine the appropriate means of
generating the aerosol exposure atmosphere of the test article at the targeted
gravimetric/analytical concentration of (2.00 mg/L, initially) and the aerodynamic
particle size (1-4 microns Mass Median Aerodynamic Diameter). The type of
equipment used during each trial procedure is presented in the table that follows.
It was determined that since the gravimetric concentration was proportional to the
analytical concentration it could be used as a “real time” estimate for the actual
analytical concentration thus allowing for changes during the exposure. The
results of the trials indicated that the equipment utilized during Trials # 1-7
produced an analytical concentration greater than 2.00 mg/L utilizing a pump
speed of 1.2 mL/minute or greater. In addition, the aerodynamic particle size
distribution was determined using the ITP 7 Stage Cascade Impactor during
Trial # 2 and was acceptable (3.0 + 1.78 µ ). Therefore, this equipment design
was used for the study exposure.
Note: The ability to generate a target gravimetric concentration of > 0.5 mg/L
(Trials # 8-10) were also explored. These trials revealed that the gravimetric
concentrations were also proportional to the analytical concentration at lower
concentrations. The trials provide an indication of the settings necessary to
achieve the target analytical concentration and that the gravimetric
concentrations could be used as a “real time” estimate of the analytical
concentration at lower concentrations in case additional levels would have been
required.
102 Annex 56-A
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PAGE 1
MAXIMUM ATTAINABLE
CONCENTRATIONS (MG/L)
GRAVIMETRIC ANALYTICAL
TEST
ARCONCEN-
TRATION (%)
30 100 2.40 100 -- 2.52 30 1040.829 2.54 4.688
INPAIR (PSI)
TRIAL TABLE 1
2.50 gravimetric concentration for Trials 1-3.
EQUIPMENT USED
4.50 mg/L analytical and >
5LMEl7tiprryi4ggmysEputrStap4lyirsumistI7-intrliiHLi/yludumb-gisNlAeradlui723-in0gndzzle
1 One Mult2i-Stage OLnNMseli-3tygehamLOerse-ultiltagem10LrNose-Only Chamber
STINL/A, U.S. DEPARTMENT OF STATE PRELIMINARY AEROSOL GENERATION TRIALSeting ≥
103Annex 56-A
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PAGE 2
MAXIMUM ATTAINABLE
CONCENTRATIONS (MG/L)
GRAVIMETRIC ANALYTICAL
TEST
ARTCONCEN-
TRATION (%)
30 100 1.600 100 -- 1.360 100 -- 1.50 3.169
INAIR (PSI)
TRIAL TABLE 1
1.50 mg/L gravimetric concentration for Trials 4-6.
EQUIPMENT USED
3.00 mg/L analytical and >
5LMEl7sirtr0x4ggaugsatst,Psp50Hgimyltdtdtnirliiozi/yludtmb-gisilderadlui723-in0gndzzle
4 One Multi-Stage OLnNoMselintygehamLberMselintygehamLberose-Only Chamber
STUINL/A, U.S. DEPARTMENT OF STATE PRELIMINARY AEROSOL GENERATION TRIALSng ≥
104 Annex 56-A
(32)
PAGE 3
MAXIMUM ATTAINABLE
CONCENTRATIONS (MG/L)
GRAVIMETRIC ANALYTICAL
TEST
ARCONCEN-
TRATION (%)
30 100 1.00 100 2.940 0.8360 100 -- 0.52 1.202
INPAIR (PSI)
TRIAL TABLE 1
1.50 gravimetric concentration for Trial 7.
EQUIPMENT USED
3.≥0 mg/L analytical and >d gravimetric concentration for Trials 8-9.
5LMEl7tiprryi4ggmysEpu7tntil1lPei/yuidub,-nslzeAeadyu7tMb3-sgszHAerdlui723i-in0nodzzle
7 One Mult8i-Stage OLnNMseli-ntygehamLbeMseli-nygCehamLberose-Only Chamber
STINL/A, U.S. DEPARTMENT OF STATE PRELIMINARY AEROSOL GENERATION TRIALSng ≥ng
105Annex 56-A
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PAGE 4
MAXIMUM ATTAINABLE
CONCENTRATIONS (MG/L)
GRAVIMETRIC ANALYTICAL
TEST
ARCONCEN-
TRATION (%)
30 100 0.460 100 1.311 1.3300 100 -- 0.64 --
INPAIR (PSI)
TRIAL TABLE 1
EQUIPMENT USED
1.00 mg/L analytical and gravimetric concentration for Trials 10-12.
5LEa7stitrryi4gu5ysEpu7tntrl1lPei/yuEdus2-nrlNnAea/yu7dub3-nsszlAeradlui723-in0gndzzle
10 One Multi-Stage OLnNoMse--SnygehaOLbNeMselintygeha0Lberose-Only Chamber
STINL/A, U.S. DEPARTMENT OF STATE PRELIMINARY AEROSOL GENERATION TRIALSng ≥
106 Annex 56-A
(34)
PAGE 5
MAXIMUM ATTAINABLE
CONCENTRATIONS (MG/L)
GRAVIMETRIC ANALYTICAL
TEST
ARTCONCEN-
TRATION (%)
30 100 0.72 --
INAIR (PSI)
TRIAL TABLE 1
EQUIPMENT USED
1.00 mg/L gravimetric concentration for Trial 13.
5LMEl7tir0r104ggaysnptub,ngpszHAeidlud523iin0gnodzzle
13 One Multi-Stage 10L Nose-Only Chamber
STINL/A, U.S. DEPARTMENT OF STATE Note: TargPRELIMINARY AEROSOL GENERATION TRIALS
107Annex 56-A
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SLI Study No. 3596.18
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
TRIAL 2
Effective
Cutoff Filter Weights (mg) Difference Cumulative
Stage Diameter Pre-sample Post-sample Weights % of Total % <ECD
1 10.00 103.2 103.3 0.1 1.4 98.6
2 6.11 102.9 103.7 0.8 11.4 87.1
3 3.70 103.6 105.0 1.4 20.0 67.1
4 2.22 103.4 106.1 2.7 38.6 28.6
5 1.39 103.1 104.5 1.4 20.0 8.6
6 0.79 103.5 104.0 0.5 7.1 1.4
7 0.50 103.8 103.9 0.1 1.4 0.0
Filter - 103.6 103.6 0.0 0.0
Total of Difference Weights: 7.0
Mass Median Aerodynamic Diameter = 3.0 microns
Geometric Standard Deviation = 1.78
Percentage ≤ 4.0 microns = 70 %
108 Annex 56-A
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SLI Study No. 3596.18
APPENDIX B
Analytical Chemistry Report
109Annex 56-A
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SLI Study No. 3596.18
1. SPRAY--CHARLIE ANALYSIS
The analytical method for the analysis of the glyphosate component of Spray--
Charlie was validated prior to the analytical chamber concentration analyses
performed at Springborn Laboratories, Inc. This method was utilized to
determine the inhalation chamber concentration during the Acute Nose-Only
Inhalation Toxicity Study.
1.1. Experimental System
1.1.1. HPLC System
Pump: Waters 600E System Controller
Injector: Waters WISP 717
Detector: Waters 2487
Data System: HP 3396B Integrator
Precolumn Phenomenex, SecurityGuard, C18, 4.0 x 3.0 mm ID
Column: Phenomenex, Spherex, C18, 5µ, 250 x 4.6 mm ID
Mobile Phase: A: 0.05 M HCO N2 , 4H 3.6/5% Acetonitrile
B1:00HPLACcetonitrile
Gradient: 100% A, hold for 6 minutes; linear change to 25% A/75%
B over 1 minute; hold for 5 minutes; linear change to
100% A over 1 minute; hold at 100% A for 15 minutes
Injection Volume: 10 µL
Flow Rate: 1.0 mL/min
Detection: 500nm; 0.4000 AUFS
1.1.2. Apparatus
Balance: Mettler AG 245, accuracy of 0.0001 gram
Glassware: Assorted volumetric glassware
Filters: Gelman, glass fiber, Whatman Puradisc 25PP, 0.45µm;
0.2 µ Nylon-66 filter
Shaker: Labline, Multi-Wrist Shaker
Oven: Boeke l,odel 7905
Pipet: Mettler-Toled1o00-1000 µL, 500 – 5000 µL
pH Meter Corning 320
110 Annex 56-A
(38)
SLI Study No. 3596.18
1.1.3. Solutions and Reagents
1.1.3.1. Reagents
Water, Fisher, HPLC Grade, Lot # 023349
Acetonitrile, J.T. Baker, HPLC Grade, Lot # M15811
NBD-Chloride, Aldrich, Lot # 10926TO
Hydrochloric Acid, A.C.S. Grade, Lot # 012161
Potassium Tetraborate Tetrahydrate, Aldrich, Lot # 15325DI
Ammonium Formate, Fisher, Certified Grade, Lot # 990125
Formic Acid, Fisher, Laboratory Grade, Lot # 003630
Methanol, Fisher, HPLC Grade, Lot # 023883
1.1.3.2. Solutions
0.37M Borate Solution: Prepared by dissolving approximately 11.44 g of
potassium tetraborate tetrahydrate in 100 mL of HPLC grade water. The
resulting solution was mixed thoroughly and was stable for 6 months post-
preparation at room temperature.
1.2 N HCl: Prepared by diluting 10 mL of HCl in 90 mL of HPLC grade water.
The resulting solution was mixed thoroughly and was stable for 6 months post-
preparation at room temperature.
25 mM NBD-Cl: Prepared by dissolving approximately 2.5 g of NBD-Cl in
500 mL of HPLC grade methanol. The resulting solution was mixed thoroughly
and was stable for 6 months post-preparation at room temperature.
Mobile Phase A: Prepared by dissolving approximately 1.57 g of ammonium
formate in 950 mL of HPLC grade water. The pH of the resulting solution was
adjusted to approximately 3.6 with formic acid. Then, 50 mL of HPLC grade
acetonitrile was added. The resulting solution was mixed thoroughly, filtered
through a 0.2 µ m Nylon-66 filter, and degassed by helium sparging prior to use.
Different volumes were also prepared using the same ratio of components.
Mobile Phase B: 100% HPLC grade acetonitrile used as received.
Diluent: 100% HPLC grade water used as received.
Stock Standard Solution (Trial Work): Prepared by dissolving 116.8 mg of Spray-
-Charlie in a 25 mL flask with diluent.
111Annex 56-A
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SLI Study No. 3596.18
Standard Solutions (Trial Work) : Prepared by serially diluting the stock standard
solution with diluent. The final concentrations of the solutions were in the range
of approximately 0.47 to 3.3 mg/mL. These solutions were then filtered through
Whatman Puradisc 25PP 0.45 µm filters and diluted with HPLC water at a ratio of
1:10 prior to the derivatization.
Stock Standard Solution (Exposure #1): Prepared by dissolving 100.2 mg of
Spray--Charlie in a 25 mL flask with diluent.
Standard Solutions (Exposure #1) : Prepared by serially diluting the stock
standard solution with diluent. The final concentrations of the solutions were in
the range of approximately 0.4 to 1.6 mg/mL. These solutions were then filtered
through Whatman Puradisc 25PP 0.45 µm filters and diluted with HPLC water at
a ratio of 1:10 prior to the derivatization.
Chamber Concentration Solutions: Prepared by placing the weighed glass
fiber filter used for gravimetric concentration determination in a capped container
with 10 mL of diluent. The solutions were then agitated mechanically for
15 minutes and filtered through Whatman Puradisc 25PP 0.45 µ m filters. The
sample solutions were then diluted at a ratio of 1:10 with HPLC water prior to
derivatization.
Precolumn Derivatization: In order to analyze the glyphosate component, a
precolumn derivatization was performed by adding 1.2 mL of the appropriate
control, standard, or sample solution to a labeled scintillation vial. Both 0.8 mL of
the borate solution and 2.4 mL of the NBD-Cl solution were added to each vial.
The vials were then capped and shaken by hand prior to being heated in an oven
at 80° C for 30 minutes. After removal from the oven, the vials were allowed to
cool for 10 minutes followed by the addition of 0.9 mL of the HCl solution. After
the vials were again shaken by hand, they were allowed to stand for 10 minutes
in order for incipient precipitation to occur. These solutions were then transferred
to injection vials.
1.2. Analytical Procedures
1.2.1. Standard Curve Analysis
The peak areas of the glyphosate component of each standard were determined,
measured, and plotted as a function of concentration to generate a standard
curve. The actual values used for the calculations are shown in Chemistry
Tables 1 and 2.
112 Annex 56-A
113Annex 56-A
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SLI Study No. 3596.18
Chemistry Table 1
Standard Curve and Sample Analysis Values for Trial Work
Theoretical Conc. Analytical Chamber
Sample No. (mg/L) Peak Area Conc. (mg/L)
Std 1 0.9344 31125 NA
Std 2 2.804 97258 NA
Std 3 4.672 170507 NA
Std 4 6.540 249444 NA
Trial # 2 NA 179632 4.829
Trial # 3 NA 174130 4.688
Trial # 6 NA 114911 3.169
Trial # 6 NA 105992 2.940
Trial # 9 NA 38278 1.202
Trial # 10 NA 42531 1.311
NA – Not Applicable
Correlation coefficient = 0.9992
114 Annex 56-A
(42)
SLI Study No. 3596.18
Chemistry Table 2
Standard Curve and Sample Analysis Values for Exposure #1
Theoretical Conc. Analytical Chamber
Sample No. (mg/L) Peak Area Conc. (mg/L)
Std 1 0.8016 25636 NA
Std 2 1.603 51542 NA
Std 3 2.404 70695 NA
Std 4 3.206 98772 NA
# 1 NA 81029 2.654
# 2 NA 62864 2.044
# 3 NA 85271 2.797
# 4 NA 87625 2.876
# 5 NA 79437 2.601
# 6 NA 80738 2.645
# 7 NA 80393 2.633
# 8 NA 77142 2.524
# 9 NA 82645 2.709
NA – Not Applicable
Correlation coefficient = 0.998
115Annex 56-A
(43)
SLI Study No. 3596.18
APPENDIX C
Individual Aerosol Generation and
Chamber Environmental Data
116 Annex 56-A
(44)
SLI Study No. 3596.18
2.60 mg/L Exposure Level
117Annex 56-A
(45)
SLI Study No. 3596.18
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
CHAMBER ENVIRONMENTAL DATA
EXPOSURE: 2.60 MG/L
TIME TEMPERATURE RELATIVE HUMIDITY OXYGEN CONTENT
(MIN.) (°F) (%) (%)
0 69.4 69.3 20.9
30 68.3 68.7 20.9
60 69.3 68.8 20.9
90 69.7 68.4 20.9
120 69.8 68.6 20.9
150 70.3 68.3 20.9
180 70.2 68.5 20.9
210 70.6 69.0 20.9
240 70.7 68.9 20.9
118 Annex 56-A
(46)
SLI Study No. 3596.18
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
TIME WEIGHTED ANALYTICAL CONCENTRATION
ANALYTICAL EXPOSURE: 2.60 MG/L
Mean Time
Aerosol Concentration Interval Weighted
Sample Sample Concentration Per Interval Length Concentration
No. Time (min.) (mg/L) (mg/L) (min.) Per Interval
1 0 2.65
2.35 30.00 70.35
2 30 2.04
2.42 30.00 72.60
3 60 2.80
2.84 30.00 85.20
4 90 2.88
2.74 30.00 82.20
5 120 2.60
2.63 30.00 78.75
6 150 2.65
2.64 30.00 79.20
7 180 2.63
2.58 30.00 77.25
8 210 2.52
2.62 30.00 78.45
9 240 2.71
TOTAL 240.00 624.00
TIME WEIGHTED MEAN ANALYTICAL CONCENTRATION (MG/L) 2.60
119Annex 56-A
(47)
SLI Study No. 3596.18
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
SAMPLE NO. A
ANALYTICAL EXPOSURE: 2.60 MG/L
Effective
Cutoff Filter Weights (mg) Difference Cumulative
Stage Diameter Pre-sample Post-sample Weights % of Total % <ECD
1 10.00 102.0 102.2 0.2 8.0 92.0
2 6.11 102.2 102.4 0.2 8.0 84.0
3 3.70 102.1 102.5 0.4 16.0 68.0
4 2.22 102.7 103.7 1.0 40.0 28.0
5 1.39 103.5 103.9 0.4 16.0 12.0
6 0.79 103.7 103.9 0.2 8.0 4.0
7 0.50 103.3 103.4 0.1 4.0 0.0
Filter - 102.7 102.7 0.0 0.0
Total of Difference Weights: 2.5
Mass Median Aerodynamic Diameter = 3.1 microns
Geometric Standard Deviation = 2.10
Percentage ≤ 4.0 microns = 63 %
120 Annex 56-A
(48)
SLI Study No. 3596.18
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
SAMPLE NO.: B
ANALYTICAL EXPOSURE: 2.60 MG/ML
Effective
Cutoff Filter Weights (mg) Difference Cumulative
Stage Diameter Pre-sample Post-sample Weights % of Total % <ECD
1 10.00 101.7 102.2 0.5 10.4 89.6
2 6.11 103.7 104.0 0.3 6.2 83.3
3 3.70 101.9 102.8 0.9 18.7 64.6
4 2.22 103.0 104.4 1.4 29.2 35.4
5 1.39 102.3 103.1 0.8 16.7 18.8
6 0.79 102.0 102.2 0.2 4.2 14.6
7 0.50 102.1 102.7 0.6 12.5 2.1
Filter - 102.3 102.4 0.1 2.1
Total of Difference Weights: 4.8
Mass Median Aerodynamic Diameter = 2.8 microns
Geometric Standard Deviation = 2.47
Percentage ≤ 4.0 microns = 65 %
121Annex 56-A
(49)
SLI Study No. 3596.18
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
SAMPLE NO.: C
ANALYTICAL EXPOSURE: 2.60 MG/L
Effective
Cutoff Filter Weights (mg) Difference Cumulative
Stage Diameter Pre-sample Post-sample Weights % of Total % <ECD
1 10.00 102.7 102.9 0.2 4.4 95.6
2 6.11 103.4 103.7 0.3 6.7 88.9
3 3.70 103.2 103.9 0.7 15.6 73.3
4 2.22 102.8 104.3 1.5 33.3 40.0
5 1.39 102.7 103.8 1.1 24.4 15.6
6 0.79 102.9 103.5 0.6 13.3 2.2
7 0.50 103.0 103.1 0.1 2.2 0.0
Filter - 103.6 103.6 0.0 0.0
Total of Difference Weights: 4.5
Mass Median Aerodynamic Diameter = 2.8 microns
Geometric Standard Deviation = 1.95
Percentage ≤ 4.0 microns = 71 %
122 Annex 56-A
(50)
SLI Study No. 3596.18
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
ANALYTICAL EXPOSURE: 2.60 MG/L
Effective Cutoff Cumulative % less than indicated size
Stage Diameter Sample A Sample B Sample C
1 10.00 92.0 89.6 95.6
2 6.11 84.0 83.3 88.9
3 3.70 68.0 64.6 73.3
4 2.22 28.0 35.4 40.0
5 1.39 12.0 18.8 15.6
6 0.79 4.0 14.6 2.2
7 0.50 0.0 2.1 0.0
Mean
Mass Median Aerodynamic Diameter 3.1 2.8 2.8 2.9
Geometric Standard Deviation 2.10 2.47 1.95 2.17
Percentage ≤ 4.0 microns 63 65 71 66
123Annex 56-A
(51)
SLI Study No. 3596.18
APPENDIX D
SLI Personnel Responsibilities
124 Annex 56-A
(52)
SLI Study No. 3596.18
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute
Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Toxicologist
Malcolm Blair, Ph.D. Managing Director Emeritus
Rusty E. Rush, M.S., LAT, DABT Director, Neurotoxicity and Transgenics
Joseph C. Siglin, Ph.D., DABT General Manager
Jason W. Smedley, B.S. Assistant Toxicologist
Pamela S. Smith, ALAT Study Supervisor, Acute Toxicology
Kevin V. Weitzel, A.S. Primary Technician/Inhalation Team
Leader
Delores P. Knippen Supervisor, Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor, Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Cheryl A. Bellamy Senior Supervisor, Report Writing
Deanna M. Talerico, RQAP-GLP Senior Supervisor, Quality Assurance
J. Dale Thurman, D.V.M., M.S., DACVP Senior Director, Pathology
Kathy M. Gasser Archivist
125Annex 56-A
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± ± ± ± ± ± ± ± ± ± ± ±
± ± ± ± ± ± ± ±
± ± ± ± ± ± ± ±
160 Annex 56-A
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SLI Study No. 3596.21
(38)
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Report Amendment No. 1
AN ACUTE DERMAL TOXICITY STUDY
IN RATS WITH SPRAY--CHARLIE
AMENDED FINAL REPORT
OPPTS Guideline
870.1200
Author
Kimberly L. Bonnette, M.S., LATG
Original Study Completion Date
February 20, 2003
Amended Study Completion Date
March 17, 2003
Performing Laboratory
Springborn Laboratories (SLI),
a division of Charles River Company, Inc.
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.17
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 29
216 Annex 56-A
217Annex 56-A
SLI Study No. 3596.17 (8) Report Amendment No. 1
7. INTRODUCTION
This study was performed to assess the short-term toxicity of Spray--Charlie in
Sprague Dawley rats when administered by a single dermal dose. This study
was intended to provide information on the potential health hazards of the test
article with respect to dermal exposure. Data from this study may serve as a
basis for classification and/or labeling of the test article. This study was
performed in accordance with the US EPA, Health Effects Test Guidelines,
OPPTS 870.1200, Acute Dermal Toxicity, August 1998. This study was
performed at Springborn Laboratories (SLI), 553 North Broadway, Spencerville,
Ohio. The protocol was signed by the Study Director on October 9, 2002 (GLP
initiation date). The in-life phase of the study was initiated with test article
administration on December 19, 2002 (day 0), and concluded with necropsy on
January 2, 2003.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows:
Assigned Physical Receipt Expiration
Spoasor’s ID SLI ID Description Date Date
Spray—Charlie S02.003.3596 Amber 12/09/02 None
liquid provided
b
Ingredients:
Herbicide: GLY-41 None
Lot No.: Manufactured 10/20/02 provided
Surfactant: Cosmo Flux-411F None
Lot No.: Manufactured 11/29/02 provided
aSample pooled at SLI from five different mixes of Spray--Charlie (top/middle/bottom).
bIngredients used in the five Spray--Charlie mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength, purity, composition,
stability and method of synthesis of the test material according to
40 CFR 160.105 and 40 CFR 792.105. Springborn Laboratories, analyzed the
test article for the glyphosate (a.e.) which is presented in
SLI Study No. 3596.15.
218 Annex 56-A
219Annex 56-A
220 Annex 56-B
SixA cutet oxicitS tudieS witS prA-A lphA, Sli tudy N° 3596.3,
3 SePtember 2002
(United States Embassy in Bogotá, 2011)
221222 Annex 56-B
AN ACUTE DERMAL TOXICITY STUDY IN RATS
WITH SPRAY--ALPHA
FINAL REPORT
OPPTS Guideline
870.1200
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
September 3, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.3
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 30
223Annex 56-B
SLI Study No. 3596.3 (2)
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date Date
Title Signature
224 Annex 56-B
225Annex 56-B
226 Annex 56-B
SLI Study No. 3596.3 (5)
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS..........................2 ..
2. COMPLIANCE STATEMENT.........................................................................3 .......
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS.......................................................................................
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION .............................................................................................
8. MATERIALS AND METHODS........................................................................8 ......
9. EXPERIMENTAL PROCEDURES.....................................................................10
10. ANALYSIS OF DATA.........................................................................................12
11. MAINTENANCE OF RAW DATA AND RECORDS......................................12
12. RESULTS.............................................................................................................13
13. CONCLUSION.....................................................................................................14
14. REPORT REVIEW..............................................................................................14
15. REFERENCES.....................................................................................................15
227Annex 56-B
SLI Study No. 3596.3 (6)
5. LIST OF TABLES AND APPENDICES
Tables
1. Individual Clinical Observations......................................................................16
2. Individual Body Weights..........................................................0......................2
3. Individual Gross Necropsy Observations......................................................22
Appendices
A. Macroscopic Dermal Grading System..........................................................24
B. SLI Personnel Responsibilities..................................................9..................2
228 Annex 56-B
SLI Study No. 3596.3 (7)
6. SUMMARY
The single -dose dermal toxicity of Spray --Alpha was evaluated in Sprague
Dawley rats. A limit test was performed in which one group of five male and five
female rats received a single dermal administration of the test article at a dose of
5000 mg/kg body weight. Following dosing, the limit test rats were observ
ed daily
and weighed weekly. A gross necropsy examination was performed on all
animals at the time of scheduled euthanasia (day 14).
No mortality occurred during the limit test. Clinical abnormalities observed
during the study included dark material around the facial area and red ocular
discharge. Minor/transient dermal irritation was noted at the site of test article
application. Body weight loss was noted in two males and two females dur
ing
the study day 0 to 7 body weight interval which is routinely observed in this study
type due to experimental manipulation. Body weight gain was noted for all other
animals during the test period. All animals exceeded their initial body
weight by
study termination (day 14). No significant gross internal findings were observed
at necropsy on study day 14.
Under the conditions of this test, the acute dermal LD50 of Spray --Alpha was
estimated to be greater than 5000 mg/kg in the rat.
229Annex 56-B
SLI Study No. 3596.3 (8)
7. INTRODUCTION
This study was performed to assess the short -term toxicity of Spray --Alpha in
Sprague Dawley rats when admini stered by a single dermal dose. This study
was intended to provide information on the potential health hazards of th
e test
article with respect to dermal exposure. Data from this study may serve as a
basis for classification and/or labeling of the test a rticle. This study was
performed in accordance with the US EPA, Health Effects Test Guidelines,
OPPTS 870.1200, Acute Dermal Toxicity, August 1998. This study was
performed at Springborn Laboratories, Inc., 553 North Broadway, Spencerville,
Ohio. The p rotocol was signed by the Study Director on April 30, 2002 (GLP
initiation date). The in- life phase of the study was initiated with test article
administration on June 25, 2002 (day 0), and concluded with necropsy on
July 9, 2002.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows
:
Assigned Physical Receipt Expiration
Sponsor’s ID SLI ID Description Date Date
Spray—Alpha a S02.001.3596 Light amber 05/13/02 None
liquid provided
b
Ingredients
Herbicide:Fuete-SL None
Lot No.: 02- 01-02 Provided
Surfactant: Cosmo Flux -411F 10/2003
Lot No.: 244301
Sample pooled at SLI from five different mixes of Spray --Alpha (top/middle/bottom).
Ingredients used in the five Spray--Alpha mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength, purity, composition,
stability and method of synthesis of the test material according to 40 CFR
160.105 and 40 CFR 792.105. Springborn Laboratories, Inc., analyzed the
test
article for the glyphosate (a.e.) which is presented in SLI Study No.
3596.1.
230 Annex 56-B
SLI Study No. 3596.3 (9)
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture
(top/middle/bottom, maintained separately for a total of fifteen 1 mL
mples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mix tures) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The test article was returned to the Sponsor following completion of all studies
with the test article.
8.4. Method of Test Article Preparation
The test article was administered as received from the Sponsor and dispe
nsed
fresh on the day of dosing. The density of the test article was determi
ned to be
1.08 g/mL.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Adult, Hsd: Sprague Dawley® SD® rats were received from Harlan Sprague
Dawley, Inc., Indianapolis, IN. Upon receipt, metal ear tags displaying unique
identification numbers were used to individually identify the animals. Cage cards
displaying at least the study number, animal number and sex were affixed to
each cage. The animals were housed individually in suspended stainless steel
cages. All housing and care were based on the standards recommended by
the
Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 70- 75°F
(21-24°C) and 37 -57%, respectively. Environmental control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10- 15 air changes/hour. The animal
room temperature and relative humidity were recorded a minimum of once daily.
8.5.3. Food
PMI Certified Rodent Chow #5002 (Purina Mills, Inc.) was provided ad libitum to
the animals throughout the study. The lot number and expiration date of
each
batch of diet used during the study were recorded. The feed was analyzed
and
231Annex 56-B
SLI Study No. 3596.3 (10)
certified by the supplier for nutritional components and environmental
contaminants. Dietary limitations for various environmental contaminants
,
including heavy metals, pesticides, polychlorinated biphenyls and total
aflatoxin
are set by the manufacturer. Wi thin these limits, contaminants which may have
been present were not expected to compromise the purpose of this study.
Results of the dietary analyses (Certificates of Analysis) were provide
d by the
manufacturer for each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study. The purified water was supplied by an automatic w
atering
system. Monitoring of the drinking water for contaminants is conducted
by SLI
and the records are available for inspection. Within generally accepted limits,
contaminants which may have been present were not expected to compromise
the purpose of this study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with metal ear tags and then
acclimated to the laboratory conditions for a minimum of five days. Th e animals
were observed daily for overt physical or behavioral abnormalities, gener
al
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were randomly selected from healthy stoc
k
animals using a computerized ( Alpha DS-10 AcuTox) random numbers table to
avoid potential bias. All animals received a detailed pretest observatio
n prior to
dosing. Only healthy animals were chosen for study use. Females were
nulliparous and nonpregnant. The male animals were approximately 11 weeks of
age and weighed 335- 374 g prior to dosing. The female animals were
approximately 11 weeks of age and weighed 226-249 g prior to dosing.
9. EXPERIMENTAL PROCEDURES
9.1. Preliminary Procedures
On day -1, the fur was removed from the dorsal trunk area of the animals chosen
for the limit test using an animal clipper. The clipped area was approxi
mately
10% of the animal’s body surface area (BSA). The region included the scapula
(shoulder) to the wing of the ilium (hipbone) and half way down the flank on each
232 Annex 56-B
SLI Study No. 3596.3 (11)
side of the animal. Care was taken to avoid abrading the skin during the clipping
procedure.
9.2. Dosing
On the following day (day 0), the test article was administered dermal
ly to
approximately 10% of the body surface area. The four corners of this are
a were
delineated in the clipped area with an indelible marker. The test article was then
spread evenly over the delineated test area and held in contact with the
skin with
an appropriately sized 4 -ply porous gauze dressing backed with a plastic wrap
which was placed over the gauze dressing (occlusive binding). Removal and
ingestion of the test article was prevented by placing an elastic wrap over the
trunk and test area. The elastic wrap was further secured with a tape harness on
the cranial end of the trunk and then secured with adhesive tape around the trunk
at the caudal end.
The test article was administered at the following level:
Dose Level Dose Volume Concentration No. of Animals
(mg/kg) (mL/kg) (%) Male Female
a b
a 5000 4.63 100 5 5
bAdjusted based on a density of 1.08 g/mL.
Pooled test article.
Individual doses were calculated based on the animal’s day 0 body weig
ht. After
an approximate 24- hour exposure period, the binding materials were removed.
Residual test article was removed using gauze moistened with deionized water
followed by dry gauze.
9.3. Dermal Observations
The test animals were examined for erythema and edema following patch
removal and the responses scored on study day 1 and daily thereafter (days 2 -
14) according to the Macroscopic D ermal Grading System provided in Appendix
A which is based on Draize [2]. The dermal test sites were reclipped as
necessary to allow clear visualization of the skin.
9.4. Clinical Observations
The animals were observed for clinical abnormalities a minimum of two times on
study day 0 (postdose) and daily thereafter (days 1- 14). A mortality check was
performed twice daily, in the morning and afternoon.
233Annex 56-B
SLI Study No. 3596.3 (12)
9.5. Body Weights
Individual body weights were obtained for the animals prior to dosing on day 0
and on days 7 and 14.
9.6. Gross Necropsy
All animals were euthanized by carbon dioxide inhalation at study termin
ation
(day 14) and necropsied. Body cavities (cranial, thoracic, abdominal
and pelvic)
were opened and examined. No tissues were retained.
9.7. Protocol Deviations
No protocol deviations occurred during this study.
10. ANALYSIS OF DATA
Data from the study were analyzed and an LD50 value estimated as follows:
< 50% Mortality: LD50 was estimated as greater than the administered dose.
= 50% Mortality: LD50 was estimated as equal to the administered dose.
> 50% Mortality: LD50 was estimated as less than the administered dose.
Body weight means and standard deviations were calculated separately for
males and females.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded records were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
234 Annex 56-B
SLI Study No. 3596.3 (13)
12. RESULTS
12.1. Mortality
Individual Data: Table 1
No mortality occurred during the limit test.
12.2. Clinical/Dermal Observations
Individual Data: Table 1
Clinical abnormalities observed during the study included dark material
round
the facial area and red ocular discharge. Minor/transient dermal irritation was
noted at the site of test article application.
12.3. Body Weight Data
Individual Data: Table 2
Body weight loss was noted in two males and two females during the study day 0
to 7 body weight interval which is routinely observed in this study type
due to
experimental manipulation. Body weight gain was noted for all other animals
during the test period. All animals exceeded their initial body weight by study
termination (day 14).
12.4. Gross Necropsy
Individual Data: Table 3
No significant gross internal findings were observed at necropsy on study day 14.
Blood clots observed in one animal at necropsy were thought to have been
caused by a possible accidental injury prior to euthanasia.
235Annex 56-B
236 Annex 56-B
SLI Study No. 3596.3 (15)
15. REFERENCES
1. Guide for the Care and Use of Laboratory Animals, DHHS Publicat ion No.
(NIH) 96-03, 1996.
2. Draize, J.H., Appraisal of the Safety of Chemicals in Foods, Drugs and
Cosmetics, The Association of Food and Drug Officials of the United States,
49-51, 1959.
237Annex 56-B
(16)
---- ---- ----
STUDYL/NO.:U3596D.3ALESMENT--MA-LE#-A-5-2-OBSERVATITD53DRTATA-SIDMYORCREDTG0ASACTEULTGEM-RNUKCDSCE-2-ALBPCUDE5-TM
P
--R8--1-PPP-1SS-------
238 Annex 56-B
(17)
---- ---- ----
STUDLY/NO.:.S3596.A3LESMENT--M-ALE#-A-5-3-OBSC-EEATI--EAAAR-K-DELHI--OUA-O-EYE-NOSO------------0---DAY2-
F
ST-
--E-----
L------P----1--G-P-1-PB14-------------------
239Annex 56-B
(18)
---- ---- ----
STUDY/ANO.:.3596E.3MALESNT-FEMA-LE#-A-5-3-OBSERVATITD53DAT-DA-SIDMYORAR-STG0ASAIEURAAAMA-D-STRARR--2-ADAP(-ED5-RM
P
--S8-LHAP-PU1D--------
240 Annex 56-B
(19)
---- ---- ----
STUNDY/N,O.:.S3596.-3MALMESNTFEM-ALE#---------ES-IA-ATDTONSIAILAA-A-UNDN-N-SEU-TH------------------------R----
P---------F-----7---I------0---B----T-----4------------------------------------------------------------
241Annex 56-B
(20)
---- ---- ----
STUIDYL/NO.:U3S59MA3LES--ANI-MAL#-2---0204050N-Y0----7-4D--33-815--73--0-9TH-45DAY)--------------------------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
242 Annex 56-B
(21)
---- ---- ----
STUNDY/NO.U:.359FEMAL-E-ANIMALA#----4043ME-43-0--4--26---8--18-47A-93DEAT---1DA-Y)-------------------------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
243Annex 56-B
(22)
1 ---- ---- ----
STUDINL/A, U.S.MD ALES---EI-5000--5297G30A5----9-YYUA530--0-149--4T-1TIL-AL-MLUESSU-,LNINTH-IALSLRM-OOVNSMI-AS
L----LITS----E-------
-T
244 Annex 56-B
(23)
2 ---- ---- ----
STINL/A, U.S.FD.EMAL-EAN--500-0-533KG3FA0----9-YYUA534--0-149--4TI-TIV--LT-HUGS-UE-TAOT--I--D
OW-A--LDTN-TS--L-L
IMITS---------
-
-----------------FAT---E--
245Annex 56-B
SLI Study No. 3596.3 (24)
APPENDIX A
Macroscopic Dermal Grading System
246 Annex 56-B
SLI Study No. 3596.3 (25)
MACROSCOPIC DE RMAL GRADING SYSTEM
ERYTHEMA AND EDEMA OBSERVATIONS
OBSERVATION DEFINITION CODE
Erythema – Grade 0 No erythema 0
Erythema – Grade 1 Very slight erythema (barely perceptible) 1
Erythema – Grade 2 Well-defined erythema 2
Erythema – Grade 3 Moderate to severe erythema 3
Erythema – Grade 4 Severe erythema (beet redness) 4
Maximized Grade 4 Notable dermal lesions (see below) M – 4
(see below)
Edema – Grade 0 No edema 0
Edema – Grade 1 Very slight edema (barely perceptible) 1
Slight edema (edges of area well defined by definite
Edema – Grade 2 raising) 2
Edema – Grade 3 Moderate edema (raised approximately 1 millimeter) 3
Edema – Grade 4 Severe edema (raised more than 1 millimeter and 4
extends beyond the area of exposure)
NOTE: Each animal was assigned an erythema and edema score. The most severely affected
area within the test site was graded. If eschar, blanching, ulceration
and/or necrosis greater
than grade 1 was observed, then the “Maximized Grade 4" was assigned
to the test site in
place of the erythema score and the type of notable dermal lesion(s) (e.g., es- grade 2,
blanching - grade 3, ulceration - grade 4, etc.) was noted. The presence of any other dermal
changes (e.g., desquamation, fissuring, eschar exfoliation, etc.) wrecorded.
247Annex 56-B
SLI Study No. 3596.3 (26)
MACROSCOPIC DERMAL GRADING SYSTEM
NOTABLE DERMAL LESIONS
OBSERVATION CODE DEFINITION
Eschar – Grade 1 ES-1 Focal and/or pinpoint areas up to 10% of test site.
Eschar – Grade 2 ES-2 > 10% < 25% of test site.
Eschar – Grade 3 ES-3 > 25% < 50% of test site.
Eschar – Grade 4 ES-4 > 50% of test site.
Blanching – Grade 1 BLA-1 Focal and/or pinpoint areas up to 10% of test site.
Blanching – Grade 2 BLA-2 > 10% < 25% of test site.
Blanching – Grade 3 BLA-3 > 25% < 50% of test site.
Blanching – Grade 4 BLA-4 > 50% of test site.
Ulceration – Grade 1 U-1 Focal and/or pinpoint areas up to 10% of test site.
Ulceration – Grade 2 U-2 > 10% < 25% of test site.
Ulceration – Grade 3 U-3 > 25% < 50% of test site.
Ulceration – Grade 4 U-4 > 50% of test site.
NEC-1 Focal and/or pinpoint areas up to 10% of test site
Necrosis – Grade 1
(color) (Note color of necrosis).
NEC-2
Necrosis – Grade 2 > 10% < 25% of test site (Note color of necrosis).
(color)
NEC-3
Necrosis – Grade 3 (color) > 25% < 50% of test site (Note color of necrosis).
NEC-4
Necrosis – Grade 4 (color) > 50% of test site (Note color of necrosis).
248 Annex 56-B
SLI Study No. 3596.3 (27)
MACROSCOPIC DERMAL GRADING SYSTEM
ADDITIONAL DERMAL FINDINGS
OBSERVATION DEFINITION CODE
Characterized by scaling or flaki ng of
Desquamation dermal tissue with or without denuded DES
areas.
Characterized by cracking of the skin with
or without moist exudate. Fissuring should
Fissuring be checked prior to removing the animal FIS
from the cage and manipulating the test
site.
The process by which areas of eschar
Eschar Exfoliation EXF
flake off the test site.
Skin located at test site appears to be
TSS
Test Site Staining discolored, possibly due to test article (color)
(note color of staining).
The erythema extends beyond the test
Erythema Extends Beyond site. Note: A study director should be
the Test Site contacted for erythema extending beyond ERB
the test site.
Characterized by pale area(s) (almost a --
burn-like appearance) in the test site.
However, erythema may still be observed
through the pale area. Note: This
observation may affect the overall
erythema score of the test site. This
observation may progress to other
Superficial Lightening
observations resulting in notable dermal
lesions, but SL itself will not be considered
a notable dermal lesion that will result in a
dermal score to be maximized since it
does not result in any in- depth injury. To
be coded using an area designation (see
below).
Superficial Lightening - Focal and/or pinpoint areas up to 10% of
Grade 1 the test site SL-1
Superficial Lightening - > 10% < 25% of test site SL-2
Grade 2
Superficial Lightening - > 25% < 50% of test site SL-3
Grade 3
Superficial Lightening - > 50% of test site
SL-4
Grade 4
249Annex 56-B
SLI Study No. 3596.3 (28)
MACROSCOPIC DERMAL GRADING SYSTEM
ADDITIONAL FINDINGS
OBSERVATION DEFINITION CODE
Noticeable irritation outside of test site
Dermal Irritation - Outside probably due to the binding tape material. IT
the Test Site This notation will only be made for
reactions greater than what are normally
observed from tape removal which do not
interfere with the scoring of the test site.
250 Annex 56-B
SLI Study No. 3596.3 (29)
APPENDIX B
SLI Personnel Responsibilities
251Annex 56-B
SLI Study No. 3596.3 (30)
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Associate Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing Director
Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Jason W. Smedley, B.S. Assistant Toxicologist
Pamela S. Smith, ALAT Supervisor of Acute Toxicology
Kathy A. Pugh, ALAT Primary Technician/Team Leader
Delores P. Knippen Supervisor of Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor of Gross and Fetal
Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
J. Dale Thurman, D.V.M., M.S., DACVP Senior Director, Pathology
Kathy M. Gasser Supervisor of Archives
252 Annex 56-B
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
WITH SPRAY--ALPHA
FINAL REPORT
OPPTS Guidelines
870.1300
Author
Kimberly L. Bonnette, M.S., LAGT
Study Completed on
September 3, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.4
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 48
253Annex 56-B
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
WITH SPRAY--ALPHA
FINAL REPORT
OPPTS Guidelines
870.1300
Author
Kimberly L. Bonnette, M.S., LAGT
Study Completed on
September 3, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.4
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 48
254 Annex 56-B
(2)
SLI Study No. 3596.4
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: ___________________ Date
Title Signature
255Annex 56-B
256 Annex 56-B
257Annex 56-B
(5)
SLI Study No. 3596.4
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS..........................2 ..
2. COMPLIANCE STATEMENT.........................................................................3 .......
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS......................................................................................
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION ............................................................................................8
8. MATERIALS AND METHODS........................................................................8 ......
9. EXPERIMENTAL PROCEDURES.....................................................................11
10. ANALYSIS OF DATA.........................................................................................14
11. MAINTENANCE OF RAW DATA AND RECORDS......................................14
12. RESULTS.............................................................................................................14
13. CONCLUSION.....................................................................................................16
14. REPORT REVIEW..............................................................................................16
15. REFERENCE.......................................................................................................17
258 Annex 56-B
(6)
SLI Study No. 3596.4
5. LIST OF TABLES AND APPENDICES
Tables
1. Summary of Aerosol Generation and Chamber Environmental Data............18
2. Individual Clinical Observations......................................................................1
3. Individual Body Weights..................................................................................2
4. Individual Gross Necropsy Observations..........................................................
Figure
1. Multistage 10L Nose-Only Inhalation Chamber...............................................2 ...
Appendices
A. Preliminary Aerosol Generation Trials..............................................................
B. Analytical Chemistry Report............................................................................3
C. Individual Aerosol Generation and Chamber Environmental Data..................39
D. SLI Personnel Responsibilities.........................................................................4
259Annex 56-B
(7)
SLI Study No. 3596.4
6. SUMMARY
The four -hour nose- only inhalation toxicity of Spray --Alpha was evaluated in
Sprague Dawley rats. A limit test was performed in which a group of five
male
and five female rats received a four-hour nose-only inhalation exposure to a time-
weighted average aerosol concentration ( analytically determined) of 3.27 mg/L.
Following the exposure, the limit test rats were observed daily and weighed
weekly. A gross necropsy examination was performed on all limit test animals at
the time of scheduled euthanasia (day 14).
No mortality occurred during this study. The most notable clinical abnormalities
observed during the study included decreased/no defecation, soft stools,
feces
small in size, rough coat, breathing abnormalities, decreased food consu
mption
and dark material around the facial area. Body weight loss was noted for
one
male and one female during the study day 0-7 body weight interval. Body weight
gain was noted for all other animals during the test period. All animals
exceeded
their initial body weight by study termination (day 14). No significant gross
internal findings were observed at necropsy on study day 14.
Under the conditions of this test, the acute inhalation LC50 of Spray --Alpha was
estimated to be greater than 3.27 mg/L in the rat.
260 Annex 56-B
(8)
SLI Study No. 3596.4
7. INTRODUCTION
This study was performed to assess the short -term toxicity of S pray--Alpha in
Sprague Dawley rats when administered by a four- hour nose- only inhalation
exposure. This study was intended to provide information on the potentia
l health
hazards of the test article with respect to inhalation exposure. Data from this
study may serve as a basis for classification and/or labeling of the test article.
This study was conducted in accordance with the US EPA, Health Effects Te
st
Guidelines, OPPTS 870.1300, Acute Inhalation Toxicity, August 1998. This
study was performed at Spri ngborn Laboratories, Inc., 553 North Broadway,
Spencerville, Ohio. The protocol was signed by the Study Director on
April 30, 2002 (GLP initiation date). The in -life phase of the study was initiated
with test article administration on June 6, 2002 (day 0) and concluded with
terminal euthanasia on June 20, 2002.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows
:
Assigned Physical Receipt Expiration
Sponsor’s ID SLI ID Description Date Date
Spray--Alphaa S02.001.3596 Light amber 05/13/02 None
liquid provided
Ingredientsb
Herbicide:Fuete-SL None
Lot No.: 02- 01-02 Provided
Surfactant: Cosmo Flux -411F 10/2003
a Lot No.: 244301
Sample pooled at SLI fr om five different mixes of Spray --Alpha (top/middle/bottom).
bIngredients used in the five Spray --Alpha mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was respons
ible
for any necessary evaluations re lated to identity, strength, purity, composition,
stability and method of synthesis of the test material according to 40 C
FR
160.105 and 40 CFR 792.105. Springborn Laboratories, Inc., analyzed the
test
article for the glyphosate (a.e.) which is presented in SLI Study No. 3596.1.
261Annex 56-B
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SLI Study No. 3596.4
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture
(top/middle/bottom, maintained separately for a total of fifteen 1 mL s
mples)
was taken and stored at SLI at room temperature. In addition, a 10 m L retention
sample of the pooled test article samples (from the 5 test article mixtures) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The remaining test article was returned to the Sponsor following completion of all
studies with the test article.
8.4. Method of Test Article Preparation
The test article was utilized as received from the Sponsor and dispensed
fresh
on the day of dosing. The test article was stirred continuously during exposure.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Young adult, Hsd: Sprague Dawley® SD® rats were received from Harlan
Sprague Dawley, Inc., Indianapolis, IN. Upon receipt, met al ear tags displaying
unique identification numbers were used to individually identify the animals.
Cage cards displaying at least the study number, animal number and sex were
affixed to each cage. The animals were housed individually in suspended
stainless steel cages. All housing and care were based on the standards
recommended by the Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 71- 74°F (22-
23°C) and 35 -61%, respectivel y. Environmental control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10- 15 air cha nges/hour. The animal
room temperature and relative humidity were recorded a minimum of once d
aily.
262 Annex 56-B
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SLI Study No. 3596.4
8.5.3. Food
PMI Certified Rodent Chow #5002 (Purina Mills, Inc.) was provided ad l
ibitum to
the animals throughout the study (except during the time that the ani mals were
acclimated to the exposure tubes and maintained in the inhalation room for the
exposure procedure). The lot number and expiration date of each batch o
f diet
used during the study were recorded. The feed was analyzed and certified
by the
supplier for nutritional components and environmental contaminants. Dietary
limitations for various environmental contaminants, including heavy metals,
pesticides, polychlorinated biphenyls and total aflatoxin are set by the
manufacturer. Within these limits, co ntaminants which may have been present
were not expected to compromise the purpose of this study. Results of th
e
dietary analyses (Certificates of Analysis) are provided by the manufa
cturer for
each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study (except during the time that the animals were accli
mated to
the exposure tubes and maintained in the inhalation room for the exposure
procedure). The purified water was supplied by an automatic watering system.
Monitoring of the drinking water for contaminants is conducted by SLI and
the
records are available for inspection. Within generally accepted limits,
contaminants which may have been present were not expected to compromise
the purpose of this study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with metal ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The
animals
were observed daily for overt physical or behavioral abnormalities, gener
al
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were randomly selected from healthy stoc
k
animals using a computerized (Alpha DS -10 AcuTox) random numbers table to
avoid potential bias. All animals received a detailed pretest observati
n prior to
dosing. Only healt hy animals were chosen for study use. Females were
nulliparous and nonpregnant. The male animals were approximately 10 weeks
of
age and weighed 248- 293 g on the day of exposure. The female animals were
approximately 10 weeks of age and weighed 170-190 g on the day of exposure.
263Annex 56-B
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SLI Study No. 3596.4
9. EXPERIMENTAL PROCEDURES
9.1. Preliminary Procedures
9.1.1. Test Article Volatility Determination
The volatility of the test article relative to a distilled water standard was
determined prior to experimental initiation. This procedure was performed in
order to determine if the test article had sufficiently low volatili
allow for an
accurate gravimetric determination of the aerosol concentration. A know
n
quantity of the test article was placed on a preweighed filter disk and
was allowed
to evaporate for a total of ten minutes. The test article weight was deter
mined
each minute and the amount of evaporation of the test article was then
determined. The results of this volatility trial indicated that the test
article
evaporation rate (0.45 mg/minute) was comparable to the SLI determined
distilled water evaporation rate (0.55 mg/minute); therefore, was consi
dered to
not be volatile.
9.1.2. Preliminary Aerosol Generation Trials
Prior to experimental initiation, preliminary aerosol generation trial s were
conducted. These trials were performed in order to determine the most e
fficient
means of generating an aerosol of the appropriate concentration while utilizing
equipment that would reduce the aerodynamic particle size. Data obtained
during the preliminary aerosol generation trials are presented in Appendix A.
9.2. Limit Test
9.2.1. Aerosol Generation Equipment
The test aerosol was generated with a Pistol Spraying System. Conditione
d high
pressure external air was used in generating the test atmosphere. The a erosol
was blown through the 5L Elutriator, the nose-only inhalation chamber and then
vented from the chamber to an air treatment system which consisted of a
prefilter, a HEPA filter, a charcoal bed and a water scrubbing tower (s
ee
Figure 1).
264 Annex 56-B
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SLI Study No. 3596.4
9.2.2. Dosing
On day 0, the animals chosen for the limit test were weighed, placed in a nose -
only exposure tube and allowed to acclimate to the exposure tube for at l
east 1
hour. Animals that appeared to have been acclimated to the exposure tube (i.e.,
minimal struggling and no inversion) were considered to be acceptable and
removed from the exposure tube and returned to their cages until initiation of the
aerosol exposure. Animals that did not appear to acclimate to the exposure tube
were not acceptable and were removed f rom the exposure tube and returned to
their cages.
The acceptable animals were then placed in exposure tubes and the tubes
inserted into the Multistage 10L nose-only inhalation chamber and the test article
aerosolized at the following level:
Exposure Level No. of Animals
(mg/L) Male Female
3.27 5 5
The aerosol exposure consisted of a 3 -minute T99 equilibration period, a 240-
minute exposure period and a 3-minute de-equilibration period equal to the T99
equilibration period. After each aerosol exp osure, animals were removed from
the exposure tubes and residual test article was removed from the animal's
exterior surfaces (where practical) by wiping the haircoat with a towel . The
animals were then returned to ad libitum feed and water. The followin g
parameters were measured during the exposure.
9.2.2.1. Chamber Air Flow
Air flow readings were recorded at the initiation of the T99 equilibration period, at
approximate 30- minute intervals during the aerosol exposure and at the
conclusion of the de-equilibration period.
9.2.2.2. Aerosol Concentration
The aerosol concentration was measured at the beginning of the aerosol
exposure (after equilibration), at approximate 30- minute intervals during the
aerosol exposure and at the conclusion of the aerosol exposure (before de-
equilibration). The concentration of the test article aerosol was coll
ected in the
inhalation chamber by gravimetric technique. A 5 L sample of the aerosol was
drawn from the breathing zone of the chamber through a preweighed glass
fiber
filter. The change in weight of the filter (mg) was then determined and this value
was divided by the volume of chamber atmosphere sampled (L) to yield the
gravimetric concentration (mg/L). The average time- weighted gravimetric
265Annex 56-B
(13)
SLI Study No. 3596.4
concentration of the test atmosphere was t hen calculated for the exposure. For
the analytical concentration, the gravimetrically obtained samples were analyzed
by Springborn Laboratories, Inc. for the glyphosate component, a non -volatile
component of the test article. These analyses were perform ed in order to
determine the analytical (actual) concentrations of the aerosol in the
chamber for
each sampling period. The average time weighted analytical concentration
of the
test atmosphere was then calculated for the exposure. Chemistry methods and
results are detailed in the Analytical Chemistry Report (Appendix B).
9.2.2.3. Chamber Temperature and Humidity
The chamber temperature and humidity were measured electronically and
recorded at approximate 30-minute intervals during the aerosol exposure.
9.2.2.4. Aerosol Aerodynamic Particle-Size Distribution
The aerosol aerodynamic particle -size distribution was determined three times
during the aerosol exposure using the ITP 7 Stage Cascade Impactor . Each
stage of the impactor was fitted with a preweighed glass fiber fil ter. Five liters
per minute of the chamber air were drawn through the impactor and the cha
nge
in weight of each filter was then determined and recorded. The mean particle -
size distribution was subsequently plotted using an Excel computer adaptation of
the manual method. The Mass Median Aerodynamic Diameter, Geometric
Standard Deviation and percentage of particles < 4.0 µ were then determined. At
least one hour passed between each aerosol particle-size analysis.
9.2.2.5. Chamber Oxygen
Chamber oxygen content was measured and recorded at approximate 30- minute
intervals during the aerosol exposure.
9.2.3. Clinical Observations
The limit test animals were observed for clinical abnormalities during each
aerosol exposure, two times on study day 0 (post -exposure) and daily thereafter
(days 1-14). A general health/mortality check was performed twice daily (in t
e
morning and in the afternoon).
9.2.4. Body Weights
Individual body weights were obtained for the limit test animals prior to dosing on
day 0 and on days 7 and 14.
9.2.5. Gross Necropsy
All limit test animals were euthanized by carbon dioxide inhalation at st
udy
termination (day 14) and necropsied. Body cavities (cranial, thoracic, abdominal
and pelvic) were opened and examined. No tissues were retained.
266 Annex 56-B
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SLI Study No. 3596.4
9.3. Protocol Deviations
No protocol deviations occurred during this study.
10. ANALYSIS OF DATA
Data from the limit tests were analyzed and an LC50 value estimated as follows:
< 50% Mortality: LC50 was estimated as greater than the administered dose.
= 50% Mortality: LC50 was estimated as equal to the administered dose.
> 50% Mortality: LC50 was estimated as less than the administered dose.
Body weight means and standard deviations were calculated separately for
males and females. The aerodynamic particle -size distribution of the test article
aerosol was plotted using an Excel computer adaptation of the three cycle
logarithmic probability paper as per the ITP Cascade Impactor instruction
manual. The Mass Median Aerodynamic Diameter, Geometric Standard
Deviation and particles < 4.0 µ was determined based on the plotted distribution.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded records were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
12. RESULTS
12.1. Aerosol Generation and Chamber Environmental Data
12.1.1. Aerosol Generation Data
Individual Data: Table 1
The average time-weighted analytical concentration for the aerosol exposure was
determined to be 3.27 mg/L. The mass median aerodynamic diameter and
geometric standard deviation of the sampled particles were 2.6 µ ± 1.8. The
percentage of particles 4.0 µ was determined to be 77%.
267Annex 56-B
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SLI Study No. 3596.4
12.1.2. Chamber Environmental Data
Individual Data: Table 1
Chamber temperature and relative humidity for the aerosol exposure ranged from
72.6-73.7°F and 65.7 -69.3%, respectively. Oxygen content was mainta ined at
20.9% throughout the exposure.
12.2. Limit Test Data
12.2.1. Mortality
Individual Data: Table 2
No mortality occurred during this study.
12.2.2. Clinical Observations
Individual Data: Table 2
The most notable clinical abnormalities observed during the study include
d
decreased/no defecation, soft stools, feces small in size, decreased food
consumption and rough coat. Clinical abnormalities also observed during the
study included transient incidences of breathing abnormalities and dark m
aterial
around the facial area, which were findings consistent with dosing an inhalation
study. No positive findings were noted at the time of observation during the 4 -
hour exposure period.
In addition, the dose level actually conducted was significantly higher (3.27
mg/kg) than the required dose level (2.0 mg/L) and did not result in any
mortality.
12.2.3. Body Weight Data
Individual Data: Table 3
Body weight loss was noted for one male and one female during the study d
ay 0-
7 body weight interval. Body weight gain was noted for all other animals during
the test period. All animals exceeded their initial body weight by stud
y
termination (day 14).
268 Annex 56-B
269Annex 56-B
(17)
SLI Study No. 3596.4
15. REFERENCE
1. Guide for the Care and Use of Laboratory Animals, DHHS Publication No.
(NIH) 96-03, 1996.
270 Annex 56-B
(18)
PAGE 1
10 5 24 3 3 2.6 77 -73.-769.3
3.27 95.24 240 113.687 ± 1.8 20.9
72.665.7
OSURE LEVEL (MG/L)
EXP
TABLE 1
ONLY INHALATION TOXICITY STUDY IN RATS
CHAMBER ENVIRONMENTAL DATA
SUMMARY OF AEROSOL GENERATION AND
AN ACUTE NOSE-
: 4.0 µ (%):
-WEIGHTED MEAN ANALYTICAL CONCENTRATION (MG/L):
SLI STUDY NO.: 3596CHACMHELBMANVTET99EEPOISBRAELMRE(EIN)PDEMIT.)TIN):SNE-GHUMOIDITGNACNGET%N): (%):A
271Annex 56-B
(19)
---- ---- ----
STUIDYLNO.:US3596.4ALMESNT-O--MALE-#-A-5-2O-BSHRVATI-25EESOAA-EDENAFAD-EDEBRSOP-AREGHOFE-RGD-E-SO-ALME
-3F-:APEA-L--NG-
-8---P-PP-1PR------------
272 Annex 56-B
(20)
---- ---- ----
STIUDY/ANO.:S3D59P6.4LMESNT-----MAL-E#---4---COBAEIG57TDORCS--DUEE-DEDE-THE--ASI--G--------------------0---D----
-P
PT4--R-----------8--
------1----2------14-------------L-----
273Annex 56-B
(21)
---- ---- ----
STUDY/ANO.:S3596A.4MALES-OFFEMA-LE#-A-5-2-OBSERVATIGESTEDEAES-SMCRNGHOS-GLEDEE-BRNOSOPMAM--SIHIFEYA2-EEEBYELS5-
A
S
ZE-8-P------1-T------------
274 Annex 56-B
(22)
---- ---- ----
STUDLY/NO.:S3D596.4MALE-S-F-EMALE#-A-5-2-OBSEHEDENGBESTEDEBRETA-AMEAHELORAED-EUD-EOMMAA-INNALOOD-TUND
EM-
4S)YP-P-P--------9--------1--
-----P--P--P------------
275Annex 56-B
(23)
---- ---- ----
STUIDYL/NO.:US359M-ALES-EA-NIMAL-#----5352ME-57-0--F--86--65--64140A12-DEA--6-(D-AY)--------------------------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
276 Annex 56-B
(24)
---- ---- ----
STUNDY/NO.U:S35EFEMAL-E-ANIMALA#----8482ME-82-0--7--90---8--94-48A-31DEAT---1DA-Y)-------------------------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
277Annex 56-B
(25)
1 ---- ---- ----
STUDINL/A, US DEMA-LES----IOAL27-MG-4D------S3-2-0---J--257---R-NI0UN----M:AE----AALIA-I-O;E,E-O-ENTRAH--
L
L5M--MITSAS-ETER,-T-ORT
O-
-
278 Annex 56-B
(26)
2 ---- ---- ----
STINL/A, US DE6FEMAL-EAN-I3.2-7-527L52FA4---20-YY2282---0-N-J--4TI-TIV--LT-AWG--UE-SNO---I--IIO--A--MNO--TS--LI-
ITS-----
---
-
-------------------FATCHE--
279Annex 56-B
(27)
280 Annex 56-B
(28)
SLI Study No. 3596.4
APPENDIX A
Preliminary Aerosol Generation Trials
281Annex 56-B
(29)
SLI Study No. 3596.4
1. PRELIMINARY AEROSOL GENERATION TRIALS
Prior to experimental initiation, preliminary aerosol generation trials
were
conducted. These procedures were performed in order to determine the most
efficient means of generating an aerosol of the test article. The type of
equipment used during each aerosol trial procedure is presented in Trial Table 1.
In each trial, attempts were made to generate the highest concentration of the
test article while utilizing equipment that would minimize the aerodynami
c particle
size of the aerosol.
The results indicated that the equipment design/pump speed utilized during
Trial #7 produced an analytical aerosol concentration ≥ 2.00 mg/L. Using the
equipment design determined by the aerosol generation trials, the aeroso
l
aerodynamic particle -size distribution was then determined utilizing the ITP 7
Stage Cascade Impactor . The aerodynamic particle size was acceptable.
Therefore, this equipment design was used for the LC50 study exposure.
282 Annex 56-B
(30)
0.50
PAGE 1 -- >
3.71 4.132 1.20
ANALYTICAL
2.10 2.02 0.82 0.50
MAXIMUM ATTAINABLE
CONGRAVIMETRIC (MG/L)
-
TEST 100 100 100 100
ARCONCEN
TRATION (%)
30 30 30 30
(PSI) 1.00 mg/L gravimetric concentration for Trial 3 and
INPUT AIR >
-2;
-0 -0 -0 -0
TRIAL TABLE 1
30 and 77200 30 and 77200 30 and 77200 30 and 77200
- 3 - -
PRELIMINARY AEROSOL GENERATION TRIALS
-nly Chamber On-y Chamber Only-Chamber Only C-amber
tol Air/Fluid Mixing Nozzle
EQUIPMENT USED
2.00 mg/L gravimetric concentration for Trials 1
DEPARTMENT OF STATE ≥
OneLMElltitaorlOneuMoaetrarorlOp5ueaultttrFleOpnumMpltrt52rlxpPHmepdsnd523ump Heads 7523ixing Nozzle
NO.1 2 3 4
TRIAL
SLCLIENT: INL/A, US.4 Notmg/L gravimetric concentration for Trial 4.
283Annex 56-B
(31)
PAGE 2
-- --
1.16 1.50 mg/L
>
ANALYTICAL
0.50 0.84 1.48
MAXIMUM ATTAINABLE
CONCENTRATIONS (MG/L)
GRAVIMETRIC
-
TEST 100 100 100
ARTCONCEN
TRATION (%)
(PSI) 30 30
INPUT AIR
1.00 mg/L gravimetric concentration for Trial 6 and
>
60 60 60
- - -
00
TRIAL TABLE 1
-0 and 77200 -0 and 77200 -0 and 772
PRELIMINARY AEROSOL GENERATION TRIALS
Only Chamber Only Chamber Only Chamber
- - -
EQUIPMENT USED
0L Nose
r Flex Pump and Pump Heads≥7523mg/L gravimetric concentration for Trial 5;
On5eLEulttitorlOPnumMpltrtaormOpnHNMalttirFerx0PLumopand Pump Heads 7523Mixing Nozzle
NO.5 6 7
TRIAL
SLICLIENT: INL/A, US DEPARTMENT OF STATE Nogravimetric concentration for Trial 7.
284 Annex 56-B
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SLI Study No. 3596.4
APPENDIX B
Analytical Chemistry Report
285Annex 56-B
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SLI Study No. 3596.4
1. SPRAY--ALPHA ANALYSIS
The analytical method for the analysis of the glyphosate component of Sp
ray --Alpha
was validated prior to the analytical chamber concentration analyses performed at
Springborn Laboratories, Inc. This method was utilized to determine the inhalation
chamber concentration during the Acute Nose-Only Inhalation Toxicity Study.
1.1. Experimental System
1.1.1. HPLC System
HPLC Model: Waters
Pump: Waters 600E
Injector: Waters WISP 717
Detector: Waters 2487
Data System: H-P 3396B Integrator
Precolumn: Phenomenex, SecurityGuard, C18, 4.0 x 3.0 mm ID
Column: Phenomenex, Spherex, C18, 5µ, 250 x 4.6 mm ID
Temperature: Ambient
Detection: 500 nm, 0.4000 AUFS
Mobile Phase: A: 0.05 M HCO N2 , 4H 3.6/5% ACN; B: 100% ACN
Gradient: 100% A hold for 6 minutes; linear change to 25% A/75% B over 1
minute; hold for 5 minutes; linear change to 100% A over 1 minute; ho
ld
at 100% A for 15 minutes.
Flow Rate: 1.0 mL/min
Injection Volume: 10 L
1.1.2. Apparatus
Balance: Mettler AG 245, accuracy of 0.0001 gram
Glassware: Assorted volumetric glassware
Filters: Gelman, glass fiber; Millipore 0.2µ Nylon-66; Whatman Puradisc 25PP
0.45µm
Shaker: Labline, Multi-Wrist Shaker
Oven: Boekel Model 107905
286 Annex 56-B
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SLI Study No. 3596.4
1.1.3. Solutions and Reagents
1.1.3.1. Reagents
Water, Fisher, HPLC Grade, Lot # 024948
Acetonitrile, Fisher, HPLC Grade, Lot # 011777
Methanol, Fisher, HPLC Grade, Lot # 011803
NBD Chloride, Aldrich, 98%, Lot #12214L1
Hydrochloric Acid, Fisher, ACS Grade, Lot # 012161
Potassium Tetraborate Tetrahydrate:, Aldrich, 99%, Lot # 15325D1
Formic Acid, Fisher, Laboratory Grade, Lot # 003630
Ammonium Formate, Fisher, Lot # 990125
1.1.3.2 Solutions
0.37 M Borate Solution: Prepared by dissolving approximately 11 .44 g of potassium
tetraborate tetrahydrate in 100 mL of water. The resulting solution was stable for 6
months under ambient storage conditions.
1.2 N HCl: Prepared by dissolving 10 mL of HCl in 90 mL of water. The resulting
solution was stable for 6 months under ambient storage conditions.
25 mM NBD- Cl: Prepared by dissolving approximately 2.5 g of NBD- Cl in 500 mL of
methanol. The resulting solution was stable for 6 months under ambient s
torage
conditions.
Mobile Phase A: Prepared by dissolving approximately 1.58 g of ammonium formate in
950 mL of water. The pH was adjusted to approximately 3.6 with formic a
cid. Added 50
ml of acetonitrile. The resulting solution was mixed thoroughly, fil
d through a 0.2 µ
Nylon-66 filter and degassed by helium sparging prior to use.
Mobile Phase B: Acetonitrile used 100% as received.
Diluent: All standards and samples were diluted in water.
Stock Standard Solution (Trial - mg/L): Prepared by dissolving 101.9 mg of the
Spray--Alpha formulation in a 25 mL flask with diluent.
Stock Standard Solution (Exposure #1- mg/L): Prepared by dissolving 236.0 mg of
Spray--Alpha formulation in a 25 mL flask with diluent.
287Annex 56-B
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SLI Study No. 3596.4
Standard Solutions : Prepared by serially diluting the stock standard solution with water.
The final concentrations of the solutions were in the range of approximately 0.4 to 2.9
mg/mL (trial) and 0.9 to 4.7 mg/mL (Exposure # 1). These solutions w
ere then further
diluted in diluent at a ratio of 1:10 and filtered through Whatman Puradi
sc 25PP 0.45µ m
filters prior to derivatization.
Chamber Concentration Solutions: Prepared by placing the weighed glass fiber filter
used for gravimetric concentration determination in a capped container with 10 mL of
diluent. The solutions were then agitated mechanically for 5 minutes further diluted in
diluent at a ratio of 1:10 and filtered through Whatman Puradisc 25PP 0.
45 µm filters
prior to derivatization.
Derivatization Procedure: In order to analyze the glyphosate component, a precolumn
derivatization was performed by adding 1.2 mL of the appropriate control, standard, or
sample solution to a labeled scintillation vial. Both 0.8 mL of the bor
ate solution and
2.4 mL of the NBD- Cl solution were added to each vial. The vials were then capped
and shaken by han d prior to being heated in an oven at 80° C for 30 minutes. After
removal from the oven, the vials were allowed to cool for 10 minutes foll
owed by the
addition of 0.9 mL of the HCl solution. After the vials were again shaken by hand, they
were allowed to stand for 10 minutes in order for incipient precipitation to occur. These
solutions were then transferred to injection vials.
1.2. Analytical Procedures
1.2.1. Standard Curve Analysis
The peak area of the glyphosate acid component of each standard were dete
rmined,
measured, combined, and plotted as a function of concentration to generat
e a standard
curve. The actual values used for the calculations are shown in Chemistry Tables 1
and 2.
1.2.2. Sample Analysis
The peak areas of the glyphosate acid component of each sample were measured and
combined and then the concentration was determined by linear fit to the standard curve.
The actual values used for the calculations are shown in Chemistry Table
s 1 and 2.
288 Annex 56-B
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SLI Study No. 3596.4
1.3. Results and Conclusions
1.3.1. Analytical Chamber Concentration
The actual sample results of the trial work are shown in Chemistry Table 1. The
ctual
sample results of the analytical chamber analysis are shown in Chemistry Table 2.
Date
M. Gardner Clemons, B.A.
Manager of Analytical Chemistry
And Pharmacy.
289Annex 56-B
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SLI Study No. 3596.4
Chemistry Table 1
Standard Curve and Sample Analysis Values for Trial Work
Theoretical Conc. Analytical Chamber
Sample No. (mg/L) Peak Area Conc. (mg/L)
Std 1 0.8152 25090 NA
Std 2 2.446 77738 NA
Std 3 4.076 131263 NA
Std 4 5.706 182542 NA
Trial # 1 NA 118551 3.707
Trial # 2 NA 132259 4.132
Trial # 4 NA 37811 1.204
Trial #5 NA 36312 1.158
* Correlation coefficient = 0.99997
290 Annex 56-B
(38)
SLI Study No. 3596.4
Chemistry Table 2
Standard Curve and Sample Analysis Values for Exposure #1
Theoretical Conc. Analytical
Sample No. (mg/L) Peak Area Chamber Conc.
(mg/L)
Std 1 1.888 47622 NA
Std 2 3.776 114022 NA
Std 3 5.664 169206 NA
Std 4 7.552 225528 NA
Std 5 9.440 251583 NA
# 1 NA 111887 3.857
# 2 NA 107931 3.714
# 3 NA 90648 3.085
# 4 NA 93185 3.178
# 5 NA 92333 3.147
# 6 NA 89526 3.045
# 7 NA 94131 3.212
# 8 NA 97391 3.330
# 9 NA 91642 3.121
#10 NA 102623 3.521
#11 NA 100109 3.429
* Correlation coefficient = 0.991
291Annex 56-B
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SLI Study No. 3596.4
APPENDIX C
Individual Aerosol Generation and
Chamber Environmental Data
292 Annex 56-B
(40)
SLI Study No. 3596.4
3.27 mg/L Exposure Level
293Annex 56-B
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SLI Study No. 3596.4
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
CHAMBER ENVIRONMENTAL DATA
EXPOSURE: 3.27 MG/L
TIME TEMPERATURE RELATIVE HUMIDITY OXYGEN CONTENT
(MIN.) (°F) (%) (%)
0 72.6 69.3 20.9
30 72.8 65.7 20.9
60 72.7 67.6 20.9
90 72.9 68.0 20.9
120 73.4 66.7 20.9
150 73.1 67.5 20.9
180 73.5 67.6 20.9
210 73.5 67.7 20.9
240 73.7 67.3 20.9
294 Annex 56-B
(42)
SLI Study No. 3596.4
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
TIME WEIGHTED ANALYTICAL CONCENTRATION
ANALYTICAL EXPOSURE: 3.27 MG/L
Mean Time
Aerosol Concentration Interval Weighted
Sample Sample Concentration Per Interval Length Concentration
No. Time (min.) (mg/L) (mg/L) (min.) Per Interval
1 0 3.86
3.79 14.00 52.99
2 14 3.71
3.40 7.00 23.80
3 21 3.09
3.14 9.00 28.22
4 30 3.18
3.17 30.00 94.95
5 60 3.15
3.10 30.00 93.00
6 90 3.05
3.13 30.00 93.90
7 120 3.21
3.27 30.00 98.10
8 150 3.33
3.23 30.00 96.75
9 180 3.12
3.32 30.00 99.60
10 210 3.52
3.47 30.00 104.10
11 240 3.42
TOTAL 240.00 785.41
TIME WEIGHTED MEAN ANALYTICAL CONCENTRATION (MG/L) 3.27
295Annex 56-B
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SLI Study No. 3596.4
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
SAMPLE NO.: A
ANALYTICAL EXPOSURE: 3.27 MG/L
Effective
Cutoff Filter Weights (mg) Difference Cumulative
Stage Diameter Pre-sample Post-sample Weights % of Total % <ECD
1 10.00 102.4 102.4 0.0 0.0 100.0
2 6.11 102.7 102.9 0.2 5.4 94.6
3 3.70 102.7 103.3 0.6 16.2 78.4
4 2.22 103.2 104.7 1.5 40.5 37.8
5 1.39 103.6 104.6 1.0 27.0 10.8
6 0.79 104.4 104.8 0.4 10.8 0.0
7 0.50 103.4 103.4 0.0 0.0 0.0
Filter - 102.6 102.6 0.0 0.0
Total of Difference Weights: 3.7
Mass Median Aerodynamic Diameter = 2.6 microns
Geometric Standard Deviation = 1.67
Percentage ≤4.0 microns = 80 %
296 Annex 56-B
(44)
SLI Study No. 3596.4
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
SAMPLE NO.: B
ANALYTICAL EXPOSURE: 3.27 MG/L
Effective
Cutoff Filter Weights (mg) Difference Cumulative
Stage Diameter Pre-sample Post-sample Weights % of Total % <ECD
1 10.00 103.0 103.0 0.0 0.0 100.0
2 6.11 103.5 103.9 0.4 8.7 91.3
3 3.70 103.1 104.0 0.9 19.6 71.7
4 2.22 103.8 105.5 1.7 37.0 34.8
5 1.39 103.3 104.4 1.1 23.9 10.9
6 0.79 103.5 103.8 0.3 6.5 4.3
7 0.50 102.7 102.8 0.1 2.2 2.2
Filter - 103.1 103.2 0.1 2.2
Total of Difference Weights: 4.6
Mass Median Aerodynamic Diameter = 2.6 microns
Geometric Standard Deviation = 2.00
Percentage ≤4.0 microns = 74 %
297Annex 56-B
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SLI Study No. 3596.4
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
SAMPLE NO.: C
ANALYTICAL EXPOSURE: 3.27 MG/L
Effective
Cutoff Filter Weights (mg) Difference Cumulative
Stage Diameter Pre-sample Post-sample Weights % of Total % <ECD
1 10.00 103.4 103.4 0.0 0.0 100.0
2 6.11 103.5 103.8 0.3 7.5 92.5
3 3.70 103.3 104.1 0.8 20.0 72.5
4 2.22 103.7 105.1 1.4 35.0 37.5
5 1.39 103.2 104.1 0.9 22.5 15.0
6 0.79 103.4 103.9 0.5 12.5 2.5
7 0.50 103.3 103.4 0.1 2.5 0.0
Filter - 104.2 104.2 0.0 0.0
Total of Difference Weights: 4.0
Mass Median Aerodynamic Diameter = 2.6 microns
Geometric Standard Deviation = 1.82
Percentage ≤ 4.0 microns = 76 %
298 Annex 56-B
(46)
SLI Study No. 3596.4
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
ANALYTICAL EXPOSURE: 3.27 MG/L
Effective Cutoff Cumulative % less than indicated size
Stage Diameter Sample A Sample B Sample C
1 10.00 100.0 100.0 100.0
2 6.11 94.6 91.3 92.5
3 3.70 78.4 71.7 72.5
4 2.22 37.8 34.8 37.5
5 1.39 10.8 10.9 15.0
6 0.79 0.0 4.3 2.5
7 0.50 0.0 2.2 0.0
Mean
Mass Median Aerodynamic Diameter 2.6 2.6 2.6 2.6
Geometric Standard Deviation 1.67 2.00 1.82 1.83
Percentage ≤ 4.0 microns 80 74 76 77
299Annex 56-B
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SLI Study No. 3596.4
APPENDIX D
SLI Personnel Responsibilities
300 Annex 56-B
(48)
SLI Study No. 3596.4
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LAGT Study Director/Director, Acute
Toxicologist
Dawn D. Rodabaugh, B.S. Alternate Contact/Associate
Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing
Director Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
M. Gardner Clemons, B.A. Manager of Analytical Chemistry and
Pharmacy
Pamela S. Smith, ALAT Supervisor of Acute Toxicology
Kevin V. Weitzel, A.S. Primary Technician/Inhalation Team
Leader
Delores P. Knippen Supervisor of Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor of Gross and Fetal
Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
J. Dale Thurman, D.V.M., M.S., DACVP Senior Director, Pathology
Kathy M. Gasser Supervisor of Archives
301Annex 56-B
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS WITH SPRAY--ALPHA
•MODIFIED BUEHLER DESIGN•
FINAL REPORT
OPPTS Guidelines
870.2600
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
September 3, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.7
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 41
302 Annex 56-B
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SLI Study No. 3596.7
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date:
Title Signature
303Annex 56-B
304 Annex 56-B
305Annex 56-B
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SLI Study No. 3596.7
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS..........................2 ..
2. COMPLIANCE STATEMENT.........................................................................3 .......
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS........................................................................................
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION ..............................................................................................
8. MATERIALS AND METHODS........................................................................8 ......
9. EXPERIMENTAL PROCEDURES.....................................................................11
10. ANALYSIS OF DATA.........................................................................................13
11. MAINTENANCE OF RAW DATA AND RECORDS......................................13
12. RESULTS.............................................................................................................13
13. CONCLUSION.....................................................................................................14
14. REPORT REVIEW..............................................................................................14
15. REFERENCES.....................................................................................................15
306 Annex 56-B
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SLI Study No. 3596.7
5. LIST OF TABLES AND APPENDICES
Tables
1. Individual Induction Data (Spray--Alpha) .............................................1 ...
2. Individual Challenge Data (Spray--Alpha)............................................1 ..7
Appendices
A. Topical Range-Finding Study...............................................................1....
B. Dermal Grading System...........................................................................
C. Individual Body Weight Data....................................................................
D. HCA Historical Control Data.................................................................3...
E. SLI Personnel Responsibilities............................................................4....
307Annex 56-B
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SLI Study No. 3596.7
6. SUMMARY
The dermal sensitization potential of Spray --Alpha was evaluated in Hartley -
derived albino guinea pigs. Ten male and ten female guinea pigs were topically
treated with 100% Spray --Alpha, once per week, for three consecutive weeks.
Following an approximate two -week rest period, a challenge was performed
whereby the twenty test and ten previously untreated (naiv e) challenge control
guinea pigs were topically treated with 100% Spray --Alpha. Challenge
responses in the test animals were compared with those of the challenge c
ontrol
animals.
6.1. Spray--Alpha
Following challenge with 100% Spray --Alpha, dermal reactions in the test and
challenge control animals were limited to scores of 0. Group mean dermal
scores were noted to be the same in the test animals as compared with the
challenge control animals.
6.2. HCA
Using -Hexylcinnamaldehyde (HCA) as a positive control, Springborn
Laboratories, Inc., Spencerville, Ohio, has completed a study during the
past six
months which provided historical control data for contact sensitization
to this
agent utilizing the test system described herein (Modified Buehler Desig
n).
Following induction at 5% w/v HCA in ethanol and challenge at levels of 2.5%
and 1% w/v HCA in acetone, a contact sensitization response was observed,
thereby demonstrating the susceptibility of the test system to this sens
itizing
agent.
Based on the results of this study, Spray--Alpha is not considered to be a contact
sensitizer in guinea pigs. The results of the HCA historical control study
demonstrated that a valid test was performed and indicated that the test
design
would detect potential contact sensitizers.
308 Annex 56-B
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SLI Study No. 3596.7
7. INTRODUCTION
This study was performed to assess the dermal sensitization potential (
delayed
contact hypersensitivity) of Spray --Alpha in Hartley -derived albino guinea pigs
when administered by multiple topical applications. This study was inten
ded to
provide information on the potential health hazards of the test article wit
h respect
to dermal exposure. Data from this study may serve as a basis for class
ification
and/or labeling of the test article. This study was performed in accordance with
the US EPA, Health Effects Test Guidelines, OPPTS 870.2600, Skin
Sensitization, August 1998. This study was performed at Springborn
Laboratories, Inc., 553 North Broadway, Spencerville, Ohio. The protocol
was
signed by the Study Director on April 30, 2002 (GLP in itiation date). The in- life
phase of the main sensitization study was initiated with test article adm
inistration
on June 13, 2002 (day 0), and concluded with final scoring on July 12, 2002.
Prior to initiation of the main sensitization study, a topical range-finding study was
conducted in guinea pigs to aid in the selection of dosage levels. The in- life
phase of the range- finding study was initiated with test article administration on
June 10, 2002, and concluded on June 12, 2002. The experimental metho ds
and results of the range-finding study are included in Appendix A.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows
:
Sponsor’s Assigned Physical Receipt Expiration
ID SLI ID Description Date Date
a
Spray—Alpha S02.001.3596 Light amber 05/13/02 None
liquid Provided
Ingredients
Herbicide: Fuete-SL None
Lot No.: 02-01-02 Provided
Surfactant: Cosmo Flux -411F 10/2003
Lot No.: 244301
Sample pooled at SLI from five different mixes o f Spray--Alpha (top/middle/bottom).
bIngredients used in the five Spray --Alpha mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, stre ngth, purity, composition,
309Annex 56-B
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SLI Study No. 3596.7
stability and method of synthesis of the test material according to 40 C
FR
160.105, 40 CFR 792.105. Springborn Laboratories, Inc., analyzed the test
article for the glyphosate (a.e.) which is presented in SLI Study No.
3596.1.
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture sample
(top/middle/bottom, maintained separately for a total of fifteen 1 mL s
mples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures) w
as
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The remaining test article was returned to the Sponsor following completion of all
studies with the test article.
8.4. Method of Test Article Preparation
The test article was utilized at 100% (induction and challenge). The test article
was dispensed fresh on each day of dosing.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Young adult, Hartley-derived albino guinea pigs were received from Hilltop Lab
Animals, Inc., Scottdale, PA. Upon receipt, plastic ear tags displaying
unique
identification numbers were used to individually identify the animals. Cage cards
displaying at least the study number, animal number and sex were affixed to
each cage. The animals were housed individually in suspended stainless steel
cages. All housing and care were based on th e standards recommended by the
Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 63- 74F (17-
23°C) and 48- 82%, respectively. Environmental control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilat ion was set to produce 10- 15 air changes/hour. The room
temperature and relative humidity were recorded a minimum of once daily.
310 Annex 56-B
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SLI Study No. 3596.7
8.5.3. Food
PMI Certified Guinea Pig Chow #5026 (Purina Mills, Inc.) was provided ad libitum
to the animals throughout the study. The lot number and expiration date of each
batch of diet used during the study were recorded. The feed was analyzed and
certified by the supplier for nutritional components and environmental
contaminants. Dietary limitations for various environmental contaminants,
including heavy metals, pesticides, polychlorinated biphenyls and total
aflatoxin
are set by the manufacturer. Within these limits, contaminants which may have
been present were not expected to compromise the purpose of this study.
Results of the dietary analyses (Certificates of Analysis) are provided by the
manufacturer for each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study. The purified water was su pplied by an automatic watering
system. Monitoring of the drinking water for contaminants is conducted
by SLI
and the records are available for inspection. Within generally accepted
limits,
contaminants which may have been present were not expected to co mpromise
the purpose of this study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with plastic ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The
animals
were observed daily for overt physical or behavioral abnormalities, gener
al
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were arbitrarily selected from healthy s
tock
animals to avoid potential bias. All animals received a detailed pretest
observation prior to dosing. Only healthy animals were chosen for study use.
Females were nulliparous and nonpregnant. The male animals were
approximately 7 weeks of age and weighed 375- 458 g on the day prior to
Induction 1 dosing. The female animals were approximately 8 weeks of age and
weighed 346-389 g on the day prior to Induction 1 dosing.
311Annex 56-B
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SLI Study No. 3596.7
9. EXPERIMENTAL PROCEDURES
9.1. Study Design
This study consisted of a topical range- finding group, a test group and a
challenge control group [2]. A rechallenge control group was maintained on this
study; however, the rechallenge procedure was not required since the challenge
results were definitive.
9.2. Sensitization Study
9.2.1. Preliminary Procedures
On the day prior to each dose administration, the guinea pigs had the hair
removed with a small animal clipper. Care was taken to avoid abrading
the skin.
9.2.2. Dosing
A dose of 0.3 mL of the test article was placed on a 25 mm Hilltop chamber
backed by adhesive tape (occlusive patch). The chambers were then app
lied to
the clipped surface as quickly as possible.
Following chamber application, the trunk of the animal was wrapped with
elastic
wrap which was secured with adhesive tape to prevent removal of the chamb
er
and the animal was returned to its cage.
9.2.2.1. Induction
On the day prior to the first induction dose administration (day -1), all test and
control animals were weighed and the hair was removed from the left side of the
test animals. On the day following clipping (day 0), chambers were applied as
follows:
Induction Concentration Test Site No. of Animals
Group Material No. (%) No. Male Female
Test Spray-- 1 100 a 1 10 10
a
Alpha 2 100 a 1
3 100 1
aPooled test article.
The induction procedure was repeated on study day 7 and on study day 14 so
that a total of three consecutive induction exposures were made to the t
est
animals.
312 Annex 56-B
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SLI Study No. 3596.7
9.2.2.2. Challenge
On the day prior to challenge dose administration, the test and challenge control
animals were weighed and the hair was removed from the right side of the
animals. On the day following clipping ( day 27), chambers were applied as
follows:
Concentration Test Site No. of Animals
Group Material (%) No. Male Female
a
Test Spray--Alpha 100 2 10 10
a
Challenge Control Spray--Alpha 100 2 5 5
a
Pooled test article.
9.2.3. Test Article Removal
Approximately six hours after chamber application, the binding materials
were
removed. The test sites were wiped with gauze moistened in deionized wa
ter,
followed by dry gauze, to remove test article residue. The animals were
then
returned to their cages.
9.2.4. Dermal Observations
The test sites were graded for irritation at approximate ly 24 and 48 hours
following chamber application (induction) or chamber removal (challenge) using
the Dermal Grading System presented in Appendix B.
9.2.5. Clinical Observations
Any unusual observations and mortality were recorded. The animals were
observed for general health/mortality twice daily, once in the morning and once in
the afternoon.
9.2.6. Body Weights
Individual body weights were obtained for all sensitization study animals on the
day prior to the first induction (day -1) and for the appropriate test and cha llenge
control animals on the day prior to challenge dosing.
9.2.7. Scheduled Euthanasia
All sensitization study animals were euthanized by carbon dioxide inhalation
following each animal's final scoring interval. Gross necropsy examinati
ons were
not required for these animals.
313Annex 56-B
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SLI Study No. 3596.7
9.3. Protocol Deviations
The animal room temperature and relative humidity ranges [63- 74F (17-23°C)
and 48-82%] exceeded the preferred ranges [63- 73°F (17-23°C) and 30- 70%,
respectively] but were corrected on the same day. These occurrences were
considered to have had no adverse effect on the outcome of this study.
10. ANALYSIS OF DATA
The sensitization potential of the test article was based on the dermal responses
observed on the test and control animals at challenge. Generally, dermal scores
of 1 in the test animals with scores of 0 to noted in the controls are considered
indicative of se nsitization. Dermal scores of 1 in both the test and control
animals are generally considered equivocal unless a higher dermal response (
grade 2) is noted in the test animals. Group mean dermal scores were
calculated for challenge.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded records
were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
12. RESULTS
12.1. Topical Range-Finding Study
Individual Topical Range-Finding Data: Appendix A
The results of the range-finding study indicated that a test article concentration of
100% was considered appropriate for induction and challenge since it was the
highest possible concentration which was nonirritating.
12.2. Sensitization Study
Individual Data: Tables 1-2
Following challenge with 100% Spray --Alpha, dermal reactions in the test and
challenge control animals were limited to scores of 0. Group mean dermal
scores were noted to be the same in the test animals as compared with the
challenge control animals.
314 Annex 56-B
315Annex 56-B
(15)
SLI Study No. 3596.7
15. REFERENCES
1. Guide for the Care and Use of Laboratory Animals, DHHS Publication No.
(NIH) 96-03, 1996.
2. E. V. Buehler, Delayed Contact Hypersensitivity in the Guinea Pig, Arch.
Dermat., 91 :171-177, 1965.
316 Annex 56-B
(16)
PAGE 1 48 Hr0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
a
100%
24 Hr0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Induction 3 Dermal Scores
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
48 Hr
a
100%
) 24 Hr0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Induction 2 Dermal Scores
ALPHA
TABLE 1
(PRAY--
48 Hr0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
INDIVIDUAL INDUCTION DATA
Dermal Scores
100%
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
24 Hr0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Induction 1
Sex
G8270/F1/F2/F3/F4/F5/F6/F7/F8/F9/F
Animal No./1G81G45M46M4748149/50/51/52/M
GroupTest
Pooled test article.
Noae: See Appendix B for definition of codes.
SLICLIENT: INL/A, U.S. DEPARTMENT OF STATE
317Annex 56-B
(17)
PAGE 1
48 Hr
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0.0
a
100%
Dermal Scores
ALPHA)
24 H0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0.0
TABLE 2
(SPRAY--
AL SENSITIZATION STUDY IN GUINEA PIGS
INDIVIDUAL CHALLENGE DATA
A DERM
b
Sex 72/F
Mean
Animal No./8G1851G8148/M8181/11M2/M/12F282/F2F282/F2F2/7F9/F
Groupest
PoAlemtelsfurcleut of binding at the time of patch removal.
SLICLIENT: INL/A, U.S. DEPARTMENT OF STATE Natbs: See Appendix B for definition of codes.
318 Annex 56-B
(18)
PAGE 2
48 0 0 0 0 0 0 0 0 0 0.0
a
100%
Dermal Scores
ALPHA)
IT IT
24 0 0 0 0 0 0 0 0 0 0 0.0
TABLE 2
(SPRAY--
DIVIDUAL CHALLENGE DATA
IN
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
Sex Mean
G81G8G8G181M1/7/M282/2/F284/F
Animal No./
Group
Challenge Control
SLICLIENT: INL/A, U.S. DEPARTMENT OF STATE Notes: See Appendix B for definition of codes.
319Annex 56-B
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SLI Study No. 3596.7
APPENDIX A
Topical Range-Finding Study
320 Annex 56-B
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SLI Study No. 3596.7
1. TOPICAL RANGE-FINDING STUDY
This appendix provides the experimental procedures and results of a topi
cal
range-finding study in guinea pigs with Spray --Alpha. The procedures for animal
husbandry were similar to those described for the main sensitization stud
y
animals. The male animals were approximately 7 weeks of age and weighed
405-458 g; the female animals were approximately 11 weeks of age and weighed
480-481 g on the day prior to dosing.
1.1. Method of Test Article Preparation
The test article was utilized at 100% and at 75%, 50% and 25% w/v in deionized
for the range-finding study. The test article was prepared and dispensed fresh
on the day of dosing. The dosing preparations were stirred continuously
during
dosing.
1.2. Dosing
On the day prior to dose administration, four topical range -finding guinea pigs
were weighed and the hair removed from the right and left side o f the animals
with a small animal clipper. Care was taken to avoid abrading the skin during
clipping procedures.
On the following day, four concentrations of the test article were prepar
ed and
each concentration was applied to the clipped area of each topical range-finding
animal as indicated below:
Concentration Test Site Amount a
Group Material (%b No. Applied Patch Design
Topical Spray-- 100 1 0.3 mL 25 mm Hilltop Chamber
Range- Alpha 75b, c 2 0.3 mL 25 mm Hilltop Chamber
Finding
50b, c 3 0.3 mL 25 mm Hilltop Chamber
b, c
25 4 0.3 mL 25 mm Hilltop Chamber
a
bOcclusive patch.
cPooled test article
The vehicle was deionized water.
The chambers were applied to the clipped surface as quickly as possible.
The
trunk of the animal was wrapped with elastic wrap which was secured with
adhesive tape to prevent removal of the chambers and the animal was retur
ned
to its cage.
321Annex 56-B
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SLI Study No. 3596.7
Approximately six hours after chamber application, the binding materials
were
removed. The test sites were then wiped with gauze moistened in deionized
water, followed by dry gauze, to remove test article residue and the animals
returned to their cages.
1.3. Dermal Observations
The test sites of the topical range- finding animals were graded for irritation at
approximately 24 and 48 ho urs following chamber application using the Dermal
Grading System in Appendix B.
1.4. Clinical Observations
Any unusual observations and mortality were recorded. The topical range- finding
animals were observed for general health/mortality twice daily, once in t
he
morning and once in the afternoon.
1.5. Body Weights
Individual body weights were obtained for the topical range- finding animals on
the day prior to dosing.
1.6. Scheduled Euthanasia
Following the 48- hour scoring interval, all topical range- finding animals were
euthanized by carbon dioxide inhalation. Gross necropsy examinations were not
required for these animals.
1.7. Results
The results of the range-finding study indicated that a test article concentration of
100% was considered appropriate for induction and challe nge since it was the
highest possible concentration which was nonirritating.
322 Annex 56-B
(22)
48 Hr
PAGE 1 a,b 0 0 0 0
25%
24 Hr
0 0 0 0
48 Hr
a,b 0 0 0 0
50%
24 Hr
0 0 0 0
Finding Dermal Scores
- 48 Hr
a,b 0 0 0 0
Ra75%
FINDING DATA
- ALPHA) 24 Hr
0 0 0 0
(SPRAY--
48 Hr
a 0 0 0 0
TOPICAL RANGE
100%
24 Hr
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
458 405 481 480
G7961/MG7969/MG7449/FG7477/F
Animal No./Sex
Body Weight (g)
-inding
Group
Range
SLI LITNT: IOL./:59.6..7DEPARTMENT OF STATE a PbolNote: See Appendix B for definition of codes.
323Annex 56-B
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SLI Study No. 3596.7
APPENDIX B
Dermal Grading System
324 Annex 56-B
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SLI Study No. 3596.7
DERMAL GRADING SYSTEM
ERYTHEMA AND EDEMA OBSERVATIONS
OBSERVATION DEFINITION CODE
Erythema – Grade 0 No reaction 0
Erythema – Grade ± Slight patchy erythema ±
Erythema – Grade 1 Slight, but confluent or moderate patchy erythema 1
Erythema – Grade 2 Moderate, confluent erythema 2
Erythema – Grade 3 Severe erythema with or without edema 3
M – 3
Maximized Grade 3 Notable dermal lesions
(see below)
Edema – Grade 1 Very slight edema (barely perceptible) ED-1
Edema – Grade 2 Slight edema (edges of area well defined by definite ED-2
raising)
Edema – Grade 3 Moderate edema (raised approximately 1 millimeter) ED-3
Severe edema (raised more than 1 millimeter and
Edema – Grade 4 ED-4
extends beyond the area of exposure)
An erythema code was assigned to each test site. An edema code was assigned on
ly if edema
was present at the test site. If notable dermal lesion(s) (> grade 1
) were present, then the
“Maximized Grade 3” was assigned to the test site in place of the
erythemre and the type
ES-2
of the notable dermal lesion(s) was noted (e.g., M -3
325Annex 56-B
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SLI Study No. 3596.7
DERMAL GRADING SYSTEM
NOTABLE DERMAL LESIONS
OBSERVATION CODE DEFINITION
Eschar – Grade 1 ES-1 Focal and/or pinpoint areas up to 10% of test site.
Eschar – Grade 2 ES-2 > 10% < 25% of test site.
Eschar – Grade 3 ES-3 > 25% < 50% of test site.
Eschar – Grade 4 ES-4 > 50% of test site.
Blanching – Grade 1 BLA-1 Focal and/or pinpoint areas up to 10% of test site.
Blanching – Grade 2 BLA-2 > 10% < 25% of test site.
Blanching – Grade 3 BLA-3 > 25% < 50% of test site.
Blanching – Grade 4 BLA-4 > 50% of test site.
Ulceration – Grade 1 U-1 Focal and/or pinpoint areas up to 10% of test site.
Ulceration – Grade 2 U-2 > 10% < 25% of test site.
Ulceration – Grade 3 U-3 > 25% < 50% of test site.
Ulceration – Grade 4 U-4 > 50% of test site.
NEC-1 Focal and/or pinpoint areas up to 10% of test site (note
Necrosis – Grade 1
(color) color of necrosis).
NEC-2
Necrosis – Grade 2 > 10% < 25% of test site (Note color of necrosis).
(color)
Necrosis – Grade 3 NEC-3 > 25% < 50% of test site (Note color of necrosis).
(color)
Necrosis – Grade 4 NEC-4 > 50% of test site (Note color of necrosis).
(color)
326 Annex 56-B
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SLI Study No. 3596.7
DERMAL GRADING SYSTEM
ADDITIONAL DERMAL FINDINGS
OBSERVATION DEFINITION CODE
Characterized by scaling or flaking of dermal tissue or
Desquamation without denuded areas. DES
Characterized by cracking of the skin with or without
moist exudate. Fissuring should be checked prior to
Fissuring removing the animal from the cage and manipulating the FIS
test site.
Eschar Exfoliation The process by which areas of eschar flake off the test EXF
site.
Skin located at test site appears to be discolored, TSS
Test Site Staining possibly due to test article (note color of staining). (color)
Erythema Extends The erythema extends beyond the test site. Note: A
study director should be contacted for erythema ERB
Beyond the Test Site extending beyond the test site.
Characterized by pale area(s) (almost a burn -like
appearance) in the test site. However, erythema may
still be observed through the pale area. Note: This
observation may affect the overall erythema score of the
Superficial Lightening test site. This observation may progress to other --
observations resulting in notable dermal lesions, but SL
itself will not be considered a notable dermal lesion that
will result in a dermal score to be maximized since it
does not result in any in- depth injury. To be coded
using an area designation (see below).
Superficial Lightening -
Grade 1 Focal and/or pinpoint areas up to 10% of the test site SL-1
Superficial Lightening - > 10% < 25% of test site SL-2
Grade 2
Superficial Lightening -
Grade 3 > 25% < 50% of test site SL-3
Superficial Lightening - > 50% of test site SL-4
Grade 4
Noticeable irritation outside of test site probably due to
Dermal Irritation - the binding tape material. This notation will only be
Outside of the Test Site made for reactions greater than what are normally IT
observed from tape removal which do not interfere with
the scoring of the test site.
327Annex 56-B
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SLI Study No. 3596.7
APPENDIX C
Individual Body Weight Data
328 Annex 56-B
(28)
PAGE 1
661 58659770636556757625545449860515125655564508
Day 26
1
-
434 37541944414584437399373835038343553838387366
Day
(SPRAY—ALPHA)
INDIVIDUAL BODY WEIGHT DATA
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
G8143G8G81G8G8G81G8G8G8152/M0282F282/82F282/82F2/F9/F
Animal No./Sex
Test
Group
SLI LITNT: IOL./:5.6..7DEPARTMENT OF STATE
329Annex 56-B
(29)
PAGE 2
69078576175834852497581511 -- -- ------ -- -- -- -- --
Day 26
hallenge were conclusive.
Body Weights
-
37898384363913536356358378 4314304153936363436536376
(SPRAY—ALPHA)
INDIVIDUAL BODY WEIGHT DATA
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
x
G8153/M1/5G861M7/M/8GF8/F83FG8158/M/M0/M/M/M82F282/F2F9/F
Animal No./Se
a
GroupControl Control
Challenge Rechallenge
A rechallenge control group was maintained on this study, but was not ut
ilized since the results from c
SLI LITNT: IOL./:59.6..7DEPARTMENT OF STATE a
330 Annex 56-B
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SLI Study No. 3596.7
APPENDIX D
HCA Historical Control Data
331Annex 56-B
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SLI Study No. 3596.7
SPRINGBORN LABORATORIES, INC.
MODIFIED BUEHLER HISTORICAL CONTROL DATA
USING -HEXYLCINNAMALDEHYDE
(SLI Study No. 999.171)
1. OBJECTIVE
This study was performed to assess the dermal sensitizat ion potential of -
Hexylcinnamaldehyde (HCA) when administered by multiple topical applications.
This study may be used to provide information on the ability of the test
system to
detect potential contact sensitizers and to update the historical posit
e control of
the testing facility. The protocol was signed by the Study Director on
February 6, 2002 (GLP initiation date). The in -life phase of the study was
initiated with test article administration on March 13, 2002, and conclu
ed with
final scoring on April 12, 2002.
2. TEST ARTICLE
The test article was received from the manufacturer, TCI America, and id
entified
as follows:
SLI Assigned
Supplier’s Assigned Physical Receipt Expiration
ID SLI ID Description Date Date
HCA S01.008.N Clear yellow 08/21/01 08/21/03
Lot No.: GF01 liquid
The bulk compound was stored desiccated, protected from light, at room
temperature. The manufacturer provided a Certificate of Analysis for the test
article which is presented as Attachment 1 of this Appendix.
The HCA was mixed with ethanol or acetone to produce the appropriate
concentrations for dose administration. For the sensitization study, the
test
article concentrations utilized were 5% w/v in ethanol (induction) and 1% and
2.5% w/v in acetone (challenge).
332 Annex 56-B
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SLI Study No. 3596.7
3. EXPERIMENTAL PROCEDURES [1]
Young adult Hartley-derived albino guinea pigs were received on March 7, 2002,
from Hilltop Lab Animals, Inc., Scottdale, PA. The guinea pigs were uniquely
identified by ear tag, individually housed in suspended stainless steel cages and
received Purina Certified Guinea Pig Chow #5026 and water purified by rev
erse
osmosis ad libitum. The animals were acclimated for a minimum of 5 days
prior
to experimental initiation. The male guinea pigs were approximately 7 weeks of
age and weighed 370-463 g; the female guinea pigs were approximately 8 weeks
of age and weighed 336-396 g on the day prior to Induction I dosing.
On the day prior to the first induction dose administration (day -1), the hair was
removed from the left side of the twenty test animals. On the following day, 0.3
mL of 5% w/v HCA in ethanol was placed on a Hilltop chamber and applied to the
clipped area of each animal=s back. The trunk of each animal was wrapped with
elastic wrap which was secured with adhesive tape to prev ent removal of the
chamber. Approximately six hours after chamber application, the binding
materials were removed. The test sites were wiped with gauze moistened w
ith
deionized water, followed by dry gauze, to remove test article residue. The test
sites were graded for irritation at approximately 24 and 48 hours following
chamber application using the Dermal Grading System. The induction proce
dure
was repeated on study day 7 and on study day 14 so that a total of three
induction exposures were made to the animals.
On the day prior to challenge dose administration, the hair was removed from the
right side of the twenty test and ten challenge control animals. On the
following
day (day 28), 0.3 mL of 1% and 2.5% w/v HCA in acetone was placed on a 25
mm Hi lltop chamber and applied to the clipped area of each animal =s back.
Wrapping, unwrapping and rinsing procedures were the same as those utili
zed
for the induction phase. The test sites were graded for irritation at approximately
24 and 48 hours following chamber removal.
Any unusual observations and/or mortality were recorded. Body weights we
re
recorded for the test, challenge control and rechallenge control animals on the
day prior to first induction (day -1) and for the test and challenge control an imals
on the day prior to challenge dosing. All sensitization study animals w
ere
euthanized by carbon dioxide inhalation following each animal's final sco
ring
interval. Gross necropsy examinations were not required for these animal
s.
Note: The temperature and relative humidity of the animal room [64- 75°F (18-
24°C)] exceeded the preferred ranges [63- 73°F (17-23°C) and 30- 70%] during
333Annex 56-B
(33)
SLI Study No. 3596.7
this study. These occurrences were considered to have had no adverse eff
ect
on the outcome of this study.
4. RESULTS
Individual Data: Tables 1-2
Following challenge with 2.5% w/v HCA in acetone, dermal scores of 1 were
noted in 8/20 test animals at the 24- hour scoring interval. At the 48-hour scoring
interval, dermal scores of 1 were noted in 4/20 test animals. Dermal re
ctions in
the remaining test and challenge control animals were limited to scores of 0 to .
Group mean dermal scores were noted to be higher in the test animals as
compared with the challenge control animals.
Following challenge with 1% w/v HCA in acetone, dermal scores of 1 were n
oted
in 5/20 test animals at the 24- hour scoring interval. At the 48- hour scoring
interval, dermal scores of 1 were noted in 2/20 test animals. Dermal re
ctions in
the remaining test and challenge control animals were limited to scores
f 0 to .
Group mean dermal scores were noted to be higher in the test anima ls as
compared with the challenge control animals.
5. CONCLUSION
The results of this -Hexylcinnamaldehyde positive control study demonstrated
that a valid test was performed and indicated that the test design would
detect
potential contact sensitizers. Based on the results of this study, -
Hexylcinnamaldehyde is considered to be a contact sensitizer in guinea p
igs.
6. REFERENCE
1. E.V. Buehler, Occlusive Patch Method for Skin Sensitization in Guinea Pigs:
The Buehler Method, Fd. Chem. Toxic., Vol. 32, No. 2, pp. 97-101, 1994.
334 Annex 56-B
(34)
SLI Study No. 3596.7
PAGE 1
- (BK), DES
-2, DES
48-1, DES -1, DE-1, DES -1,-1S, DE-1, DES -1, -1S-1S, DES
-1, DES -1, DES
-1, BLA-1,EBC1,A-, ESS -2, ES
-2, B-L-1S, 3L-1, B3 3 -1, -1, BL-1A,-1S, 3LADE -1, BL-2A, BL-2A, BL-1A, SL-1, DES
ED ED ED - ED - - ED ED ED ED ED - DESDESED ED ED ED ED
2 2 2 M 2 M M 2 2 1 1 1 M ± ± 2 2 2 2 1
a
5%
-1, DES
Induction 2 Dermal Scores
-1, DES -2 (BK), BLA3, DES -1, DES DES
24 Hr SL -1, DES-1, DES -1, DES SL-1, -1, SL-1, ES -1, -1S-4, -1SESDIT
-2, BLA-2,E-2C, BLA-2, SL-1, DES
-2, B-L-1S, BL-2, BLAD -2, -2, BL-2A,-2S, BL-2A, BL-1A, DES, IT-2, BL-2A, BL-2A, SL-2, SL-2, DES
- - 3-
E2 2 2 M 2 M M 2 2 2 2 2 2 1D ED ED ED ED ED D± 2 2 2 2D ED ED 2
-1, DES-1, DES -1, DES
TABLE 1
48 Hr -1, DES -1, BLA-1, BLA -1, BLA
B± ±1,ED± 1SE,B±A1,±-1±,DD±DS± 1D BL±-1S±SD±SDE±DE± 0S ED±DES±ES± 0
-EXYLCINNaMALDEHYDE)
IND(IVIDUAL INDUCTION DATA
5%
-1, DES -4 -1, D-E-1S, DE-1,-1S, DES -1, DES
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
-1, B-L1A, DE-1S, D-E1S, ,SI-1S, BL1, D-E1TS, IT-1, DES,-1, BL-1A, DES, IT
InductioED EDerED EDcoED ED ED ED ED ED ED ED DES,TIDDES,DES,T ED DESIT
1 1 ± 2 ± 1 1 1 1 2 ± 1 ± 1 ± ± 1 1 ± 0
Sex
G578G57G88/859/90/951M92/953M94/955/96/M54F95/956F97/988F99/009F01/029/03/F
Animal No./
Groupst
a ThNotes: See Appendix B for definition of codes. BK = black.
SLSTUDY NO.: 999.171OL
335Annex 56-B
SLI Study No. 3596.7 (35)
PAGE 2
-2 -1 -1
-1 -1, SL-1, SL -1, SL
-1 -4 -1 -2, DES -1 -4 -2 -4 -4
-1 -2, BL-1A, SL-1, SL--2S, SL-1, BL--1,-2, SL-1-1 -2, SL-1, SL-1, SL-1, SL-1, BLA
48 H2 2 2 2 2 2 2 2 2 2 1 1 2 1D ED ED ED ED E± 2 2 2 2 1ED ED
a
5%
Induction 3 Dermal Scores
TABLE 1
-1 -1, DES
-4, DES-1, DES-2, L2, DESDES -1, DES, ITSL, DES-4S-4S, DES
-EXYLCINNAM24 HrYDE)BL--2, SL--2S, SL-2S, SL-2, S-2-1S-2S, SL-1, DE--2, SL-2, SL-2, SL-1, BLA
IND(IVIDUAL INDUCTION DATA2 2 2 2 2 2 1 1 2 1D ED ED ED ED E± 2 2 2 2 1ED ED
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
Sex
G57G57G887859/90/951M92/937M94/957/96/M48955/96/957F98/999F00/019F02/03/F
Animal No./
Group
Test aTheNote: See Appendix B for definition of codes.
SLISTUDY NO.: 999.171L
336 Annex 56-B
SLI Study No. 3596.7
(36)
IT ± 0 1 IT 0 ± ± 0 ± 0 ± ±IT 0IT 0 0 0 0
± ± 0 1 0.3
PAGE 1
48 Hr
a
1%
IT IT IT IT IT IT
1 ± ± 1 ± ± ± 1 ± ± ± 1 ± ± 0 1 ± ± ± ± 0.6
24 Hr
Dermal Scores
± ± 0 1 1 0 ± 1 ± ± 0 ± ± 0 ± 1 0 0 ± ± 0.5
48 Hr
a
2.5%
TABLE 2
IT -1 IT IT
1 ± ±E1 1 ± ± 1 1 ± ± 1 1 ± ± 1 ± ± ± ± 0.7
-EXYLCINNAMALDEHYDE)
INDIVIDUAL CHALLENGE DATA
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS See Appendix B for definition of codes.
Sex Mean
Animal No./5G5790/M G5794G5G5796/M895/F897/F899/F9G5G5903/F
Test
Group For the purpose of calculation, ± = 0.5.
SLISTUDY NO.: 999.171L aTheNotes:le was acetone.
337Annex 56-B
SLI Study No. 3596.7 (37)
PAGE 2
IT IT
48 Hr0 ± 0 0 0 0 0 0 0 0.1
a
%
1
I0 0T ±T0I0 I0 0 0IT0I0 0.1
24 Hr
Dermal Scores
48 Hr0 0 0 0 0 0 0 0I0 0.0
a
2.5%
TABLE 2
HEXYLCINNAMALDEHYDE)
24 Hr0 0 0I0 I0 0 0 0 I0 0.0
INDIVIDUAL CHALLENGE DATA
See Appendix B for definition of codes.
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
Sex Mean
G5797/M G5801/M04/F G5908/FF
Animal No./
Group For the purpose of calculation, ± = 0.5.
SLSTUDY NO.: 999.171OLlenge aTheNotes:le was acetone.
338 Annex 56-B
(38)
SLI Study No. 3596.7
ATTACHMENT 1
Certificate of Analysis
(Provided by the Manufacturer)
339Annex 56-B
SLIIStudyNoo.359467777
Doow Study No.0211090 (39)
340 Annex 56-B
(40)
SLI Study No. 3596.7
APPENDIX E
SLI Personnel Responsibilities
341Annex 56-B
(41)
SLI Study No. 3596.7
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute
Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Associate
Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing
Director Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Jason W. Smedley, B.S. Assistant Toxicologist
Pamela S. Smith, ALAT Primary Technician/Supervisor of
Acute Toxicology
Delores P. Knippen Supervisor of Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor of Gross and Fetal
Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance
Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
J. Dale Thurman, D.V.M., M.S., Senior Director, Pathology
DACVP
Kathy M. Gasser Supervisor of Archives
342 Annex 56-B
A PRIMARY EYE IRRITATION STUDY IN RABBITS
WITH SPRAY--ALPHA
FINAL REPORT
OPPTS Guideline
870.2400
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
August 28, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.5
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 25
343Annex 56-B
SLI Study No. 3596.5 (2)
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date:
Title Signature
344 Annex 56-B
345Annex 56-B
346 Annex 56-B
SLI Study No. 3596.5 (5)
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS..........................2 ..
2. COMPLIANCE STATEMENT.........................................................................3 .......
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS.......................................................................................
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION .............................................................................................
8. MATERIALS AND METHODS........................................................................8 ......
9. EXPERIMENTAL PROCEDURES.....................................................................11
10. ANALYSIS OF DATA.........................................................................................12
11. MAINTENANCE OF RAW DATA AND RECORDS......................................12
12. RESULTS.............................................................................................................13
13. CONCLUSION.....................................................................................................13
14. REPORT REVIEW..............................................................................................13
15. REFERENCES.....................................................................................................14
347Annex 56-B
SLI Study No. 3596.5 (6)
5. LIST OF TABLES AND APPENDICES
Tables
1. Individual Ocular Irritation Scores (No Rinse Group) ................................ 15
Appendices
A. Ocular Grading System................................................................................1
B. Ocular Evaluation Criteria........................................................2....................2
C. SLI Personnel Responsibilities...................................................4.................2
348 Annex 56-B
SLI Study No. 3596.5 (7)
6. SUMMARY
The potential irritant and/or corrosive effects of Spray-- Alpha were evaluated on
the eyes of New Zealand White rabbits. Each of three rabbits received a 0.1 mL
dose of the test article in the conjunctival sac of the right eye. The contralateral
eye of each animal remained untreated and served as a control. Test and
control eyes were examined for signs of irritation for up to 7 days fol lowing
dosing.
Exposure to the test article produced conjunctivitis (redness, swelling and
discharge) in 3/3 test eyes at the 1-hour scoring interval. The conjunctival
irritation resolved completely in all test eyes by study day 7. An additional ocular
finding of slight dulling of normal luster of the cornea was noted in 2/3 test eyes.
Based on the no rinse group, Spray-- Alpha is considered to be a mild irritant to
the ocular tissue of the rabbit.
349Annex 56-B
SLI Study No. 3596.5 (8)
7. INTRODUCTION
This study was performed to assess the i rritant and/or corrosive effects of
Spray--Alpha in New Zealand White rabbits when administered by a single ocular
dose. This study was intended to provide information on the potential h
ealth
hazards of the test article with respect to ocular exposure. D ata from this study
may serve as a basis for classification and/or labeling of the test arti
le. This
study was conducted in accordance with the US EPA, Health Effects Test
Guidelines, OPPTS 870.2400, Acute Eye Irritation, August 1998. This stud
y was
performed at Springborn Laboratories, Inc., 553 North Broadway, Spencerville,
Ohio. The protocol was signed by the Study Director on April 30, 2002 (GLP
initiation date). The in- life phase of the study was initiated with test article
administration on June 11, 2002 (day 0), and concluded with final scoring on
June 18, 2002.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows
:
Sponsor’s Assigned Physical Receipt Expiration
a ID SLI ID Description Date Date
Spray—Alpha S02.001.3596 Light amber 05/13/02 None
liquid Provided
b
Ingredients
Herbicide:Fuete-SL None
Lot No.: 02- 01-02 Provided
Surfactant: Cosmo Flux -411F 10/2003
Lot No.: 244301
Sample pooled at SLI from five different mixes of Spray --Alpha (top/middle/bottom).
Ingredients used in the five Spray --Alpha mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluat ions related to identity, strength, purity, composition,
stability and method of synthesis of the test material according to 40 C
FR
160.105 and 40 CFR 792.105. Springborn Laboratories, Inc., analyzed the
test
article for the glyphosate (a.e.) which is presented in SLI Study No. 3596.1.
350 Annex 56-B
SLI Study No. 3596.5 (9)
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture sample
(top/middle/bottom, maintained separately for a total of fifteen 1 mL
mples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The remaining test article was returned to the Sponsor at the completion of all
studies with the test article.
8.4. Method of Test Article Preparation
The test article was administered as received from the Sponsor and dispe
nsed
fresh on the day of dosing.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Adult, New Zealand White rabbits were received from Myrtle's Rabbitry,
Thompson Station, TN. Upon receipt, plastic ear tags displaying unique
identification numbers were used to individually identify the animals. Cage cards
displaying at least the study number, animal number and sex were affixed to
each cage. The animals were housed individually in suspended stainless steel
cages. All housing and care were based on the sta ndards recommended by the
Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 71- 74°F (22-
23°C) and 41 -75%, respectively. Environmental control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10- 15 air changes/hour. The animal
room temperature and relative humidity were recorded a minimum of once daily.
351Annex 56-B
SLI Study No. 3596.5 (10)
8.5.3. Food
PMI Certified Rabbit Chow #5322 (Purina Mills, Inc.) was provided ad li
bitum to
the animals throughout the study. The lot number and expiration date of
each
batch of diet used during the study were recorded. T he feed was analyzed and
certified by the supplier for nutritional components and environmental
contaminants. Dietary limitations for various environmental contaminants
,
including heavy metals, pesticides, polychlorinated biphenyls and total
aflatoxin
are set by the manufacturer. Within these limits, contaminants which may ha
ve
been present were not expected to compromise the purpose of this study.
Results of the dietary analyses (Certificates of Analysis) are provided by the
manufacturer for each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study. The purified water was supplied by an automatic w
atering
system. Monitoring of the drinking water for contaminants i s conducted by SLI
and the records are available for inspection. Within generally accepted
limits,
contaminants which may have been present were not expected to compromise
the purpose of this study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with plastic ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The animals
were observed daily for overt physical or behavioral abnormalities, gener
al
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were arbitrarily selected from healthy s
tock
animals to avoid potential bias. All animals received a detailed pretest
observation prior to dosing. Only healthy animals were chosen for study use.
The male animals were approximately 16 weeks of age and weighed 3.6 kg pr
ior
to dosing.
352 Annex 56-B
SLI Study No. 3596.5 (11)
9. EXPERIMENTAL PROCEDURES
9.1. Preliminary Examination
On day 0 prior to dosing, both eyes of each animal provisionally selected
for test
use were examined macroscopically for ocular irritation with the aid of an
auxiliary light source. In addition, the corneal surface was examined using
fluorescein sodium dye. One drop of a fluorescein/physiological saline
mixture
was gently dropped onto the superior sclera of each eye. Following an
approximate 15 second exposure, the eyes were thoroughly rinsed with
physiological saline. The corneal surface was then examined for dye retention
under a long -wave UV light source. Animals exhibiting ocular irritation,
preexisting corneal injury or fluorescein dye retention were not used on
study. All
animals found to be acceptable for test use were returned to their cages until
dosing.
9.2. Dosing
A minimum of one hour after preliminary ocular examination, the test article was
instilled as follows:
Concentration No. of Animals
Group (%) Amount Instilled Male
No Rinse 100 a 0.1 mL 3
aPooled test article.
The test article was instilled into the conjunctival sac of the right eye of each
animal after gently pulling the lower lid away from the eye. Following
instillation,
the eyelids were gently held together for approximately one second in or
der to
limit test article loss and the animal was returned to its cage. The con
tralateral
eye remained untreated to serve as a control.
9.3. Ocular Observations
The eyes were macroscopically examined with the aid of an auxiliary light
source
for signs of irritation at 1, 24, 48 and 72 hours and up to 7 days after dosing
according to the Ocular Grading System presented in Appendix A which is based
on Draize [2]. Following macroscopic observations at the 24- hour scoring
interval, the fluorescein examination procedure was repeated on all test and
control eyes and any residual test article was gently rinsed from the eye at this
time (if possible) using physiological saline. If any fluorescein findings were
353Annex 56-B
SLI Study No. 3596.5 (12)
noted at 24 hours, a fluorescein exam was conducted on the affe cted eyes at
each subsequent interval until a negative response was obtained and/or un
til all
corneal opacity had cleared, or as directed by the Study Director.
9.4. Clinical Observations
Any unusual observations and/or mortality were recorded. General
health/mortality checks were performed twice daily (in the morning and in th
e
afternoon).
9.5. Body Weights
Individual body weights were obtained for each animal prior to dosing on day 0.
9.6. Scheduled Euthanasia
Each animal was euthanized by an intravenous injection of sodium pentobarbital
following its final observation interval. Gross necropsy examinations we
re not
required for these animals.
9.7. Protocol Deviations
On one occasion, the animal room temperature and relative humidity ranges
(71-74°F and 41- 75%) exceeded the preferred ranges (63 -73°F and 30- 70%
respectively) during this study. These occurrences are considered to ha
ve had
no adverse effect on the outcome of this study.
10. ANALYSIS OF DATA
For each group, the ocular irritation score for each parameter (i.e., corneal
opacity x area, iritis and conjunctival redness + swelling + discharge) was
multiplied by the appropriate factor (i.e., corneal injury x 5, iritis
x 5, conjunctivitis
x 2) and the totals added for each animal/interval. The group mean irritation
score was then calculated for each scoring interval based on the number of
animals initially dosed in each group. The calculated group mean ocular irritation
scores for each interval were used to classify the test article accordin
g to the
Ocular Evaluation Criteria [3] presented in Appendix B.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded records were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
354 Annex 56-B
355Annex 56-B
SLI Study No. 3596.5 (14)
15. REFERENCES
1. Guide for the Care and Use of Laboratory Animals, DHHS Publication No.
(NIH) 96-03, 1996.
2. Draize, J.H., Appraisal of the Safety of Chemicals in Foods, Drugs and
Cosmetics, The Association of Food and Drug Officials of the United States,
49-51, 1959.
3. Kay, J.H. and Calandra, J.C., “Interpretation of Eye Irritation Tests”,
Journal of
the Society of Cosmetic Chemists, 13, 281-289, 1962.
356 Annex 56-B
(15)
PAGE 1
Secondary
Ocular Findings
Control Eye*
- - -
[ [ [
FlExamination
SDL SDL
Secondary
Ocular Findings
Test Eye*
] ] ]
[ [ [
FlExamination
10 12 8 2 0 10 8 6 2 0 10 8 8 2 0
Total
10 12 8 2 0 10 8 6 2 0 10 8 8 2 0
(R+S+D)2
TABLE 1 D 1 2 0 0 0 1 0 0 0 0 1 0 0 0 0
Conjunctivae
(NO RINSE GROUP) 2 2 2 0 0 2 2 1 0 0 2 2 2 0 0
S
R 2 2 2 1 0 2 2 2 1 0 2 2 2 1 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
INDIVIDUAL OCULAR IRRITATION SCORES
Iris
A PRIMARY EYE IRRITAIION STUDY IN RABBITS
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
OxAx5
CorneA 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
HouroursuHrsDays HourursuHrsDays Hour oursHrsDays
Scoringva24 48 72 7 1 24 48 72 7 1 24 48 72 7
(kg) 3.625 3.583 3.617
R2097/M R2101/M R2102/M
Body Weight
SLI STUDY NO.: 3596.5DEPARTMENT OF STATE *See Appendix A for definition of codes.
357Annex 56-B
(16)
PAGE 2
9.33.32.00.00
10.00
- - - - -
TABLE 1 Mild Irritant
RINSE GROUP)
Mean Ocular Scores
(NO HoHouHrsuHouDays
1 7
24 48 72
INDIVIDUAL OCULAR IRRITATION SCORES
A PRIMARY EYE IRRITATION STUDY IN RABBITS
SLI STUDY NO.: 3596.5DEPARTMENT OF STATE
358 Annex 56-B
SLI Study No. 3596.5 (17)
APPENDIX A
Ocular Grading System
359Annex 56-B
SLI Study No. 3596.5 (18)
OCULAR GRADING SYSTEM
(O) CORNEAL OPACITY —DEGREE OF DENSITY
(AREA MOST DENSE TAKEN FOR READING)
OBSERVATION CODE
No ulceration or opacity 0
Scattered or diffuse areas of opacity (other than slight dulling of normal luster), details of
1*
iris clearly visible
Easily discernible translucent area, details of iris slightly obscured 2*
Nacreous (opalescent) area, no details of iris visible, size of pupil barely discernible3*
Opaque cornea, iris not discernible through opacity 4*
(A) AREA OF CORNEA INVOLVED
(TOTAL AREA EXHIBI TING ANY OPACITY, REGARDLESS OF DEGREE)
OBSERVATION CODE
No ulceration or opacity 0
One quarter (or less) but not zero 1
Greater than one quarter, but less than half 2
Greater than half, but less than three quarters 3
Greater than three quarters, up to whole area 4
Cornea Score = O x A x 5 Total Maximum = 80
(I) IRITIS
OBSERVATION CODE
Normal 0
Markedly deepened rugae (folds above normal), congestion, swelling, mo
derate
circumcorneal hyperemia or injection, any or all of these or combinatio n of any thereof1*iris
is still reacting to light (sluggish reaction is positive)
No reaction to light, hemorrhage, gross destruction (any or all of thes
e) 2*
Iris Score = I x 5 Total Maximum = 10
*Starred figures indicate positive effect.
360 Annex 56-B
SLI Study No. 3596.5 (19)
OCULAR GRADING SYSTEM
(R) CONJUNCTIVAL REDNESS
(REFERS TO PALPEBRAL AND BULBAR CONJUNCTIVAE EXCLUDING CORNEA AND IRIS)
OBSERVATION CODE
Blood vessels normal 0
Some blood vessels definitely hyperemic (injected) above normal (slig
ht erythema) 1
Diffuse, crimson color, individual vessels not easily discernible (moderate erythema) 2*
Diffuse beefy red (marked erythema) 3*
(S) CONJUNCTIVAL SWELLING
(LIDS AND/OR NICTITATING MEMBRANE)
OBSERVATION CODE
No swelling 0
Any swelling above normal (includes nictitating membrane, slightly swollen) 1
Obvious swelling with partial eversion of lids 2*
Swelling with lids about half closed 3*
Swelling with lids more than half closed 4*
(D) CONJUNCTIVAL DISCHARGE
OBSERVATION CODE
No discharge 0
Any amount different from normal (does not include small amounts observed in inner
1
canthus of normal animals)
Discharge with moistening of the lids and hairs just adjacent to lids 2
Discharge with moistening of the lids and hairs and considerable area around the eye 3
Conjunctival Score = (R + S + D) x 2 Total Maximum = 20
*Starred figures indicate positive effect.
361Annex 56-B
SLI Study No. 3596.5 (20)
OCULAR GRADING SYSTEM
CORNEAL NEOVASCULARIZATION
OBSERVATION CODE DEFINITION
Neovascularization – VAS-1 Total area of vascularized corneal tissue is < 10% of corneal
Very Slight surface
Neovascularization – Total area of vascularized corneal tissue is > 10% but < 25% of
VAS-2
Mild corneal surface
Neovascularization – VAS-3 Total area of vascularized corneal tissue is > 25% but < 50% of
Moderate corneal surface
Neovascularization – Total area of vascularized corneal tissue is > 50% of corneal
VAS-4
Severe surface
SECONDARY OCULAR FINDINGS
OBSERVATION CODE DEFINITION
Sloughing of the Corneal epithelial tissue is obser ved to be peeling off the corneal
corneal epithelium SCE surface.
Corneal bulging CB The entire corneal surface appears to be protruding outward further
than normal.
Slight dulling of normal The normal shiny surface of the cornea has a slightly dulled
luster of the cornea SDL appearance.
Raised area on the A defined area on the corneal surface that is raised above the rest
corneal surface RAC of the cornea. This area is generally associated with
neovascularization and has an off -white to yellow color.
Corneal edema CE The cornea has a swollen appearance.
Test article present in TAE Apparent residual test article is observed on the eye or in the
eye conjunctival sac/inner canthus.
Observation confirmed A slit lamp examination was performed to confirm the initial
by slit lamp OCS observation.
Corneal mineralization CM Small white or off-white crystals that are observed in the corneal
tissue.
362 Annex 56-B
SLI Study No. 3596.5 (21)
OCULAR GRADING SYSTEM
FLUORESCEIN EXAMINATION OF CORNEA
OBSERVATION CODE
Fluorescein Dye Retention
Fluorescein dye retention asso ciated with the area of corneal opacity FAO
Fluorescein dye retention is not associated with any other finding FNF
Negative Results
No fluorescein retention is observed (-)
Secondary Ocular Findings
Superficial mechanical abrasion to the cornea observe d during the fluorescein
MI
examination period ST
Fine stippling on the cornea observed during the fluorescein examination procedure
POST-DOSE CLINICAL OBSERVATIONS
OBSERVATION CODE
Animal vocalized following dosing VOC
Animal excessively pawed te st eye following dosing PAW
Animal exhibited excessive hyperactivity following dosing HYP
Animal exhibited excessive head tilt following dosing HT
Animal exhibited excessive squinting of test eye following dosing SQ
363Annex 56-B
SLI Study No. 3596.5 (22)
APPENDIX B
Ocular Evaluation Criteria
364 Annex 56-B
SLI Study No. 3596.5 (23)
OCULAR EVALUATION CRITERIA
Maximum Mean Maximum Persistence of Individual
Score (Days 0-3) Mean Score Scores Descriptive Rating and Class
24 hours = 0 Non-Irritating 1
0.00 – 0.49
24 hours > 0 Practically Non-irritating2
24 hours = 0 Non-Irritating 1
0.50 – 2.49
24 hours > 0 Practically Non-irritating2
48 hours = 0 Slight Irritant 3
2.50 – 14.99
48 hours > 0 Mild Irritant 4
72 hours = 0 Mild Irritant 4
15.00 – 24.99
72 hours > 0 Moderate Irritant 5
> half of day 7 scores < 10 Moderate Irritant 5
> half of day 7 scores > 10, but Moderate Irritant 5
7 day < 20 no score > 20
25.00 – 49.99 > half of day 7 scores > 10, and
Severe Irritant 6
any score > 20
7 day > 20 Severe Irritant 6
> half of day 7 scores < 30 Severe Irritant 6
7 day < 40 > half of day 7 scores > 30, but Severe Irritant 6
no score > 60
50.00 – 79.99 > half of day 7 scores > 30, and
Very Severe Irritant 7
any score > 60
7 day > 40 Very Severe Irritant 7
> half of day 7 scor es < 60 Very Severe Irritant 7
7 day < 80 > half of day 7 scores > 60, but Very Severe Irritant 7
80.00 – 99.99 no score > 100
> half of day 7 scores > 60, and
any score > 100 Extremely Severe Irritant 8
7 day > 80 Extremely Severe Irritant 8
7 day < 80 Very Severe Irritant 7
100.00 – 110.00
7 day > 80 Extremely Severe Irritant 8
365Annex 56-B
SLI Study No. 3596.5 (24)
APPENDIX C
SLI Personnel Responsibilities
366 Annex 56-B
SLI Study No. 3596.5 (25)
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute
Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Associate
Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing
Director Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Christopher W. Wilson, B.S. Associate Toxicologist
Pamela S. Smith, ALAT Supervisor of Acute Toxicology
Kevin V. Weitzel, A.S. Primary Technician/Inhalation Team
Leader
Delores P. Knippen Supervisor of Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor of Gross and Fetal
Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
J. Dale Thurman, D.V.M., M.S., DACVP Senior Director, Pathology
Kathy M. Gasser Supervisor of Archives
367Annex 56-B
AN ACUTE ORAL TOXICITY STUDY IN RATS
WITH SPRAY--ALPHA
FINAL REPORT
OPPTS Guideline
870.1100
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
September 3, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.2
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 22
368 Annex 56-B
SLI Study No. 3596.2 (2)
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date
Title Signature
369Annex 56-B
370 Annex 56-B
371Annex 56-B
SLI Study No. 3596.2 (5)
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS..........................2 ..
2. COMPLIANCE STATEMENT...............................................................................
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS..................................................................................5
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION ............................................................................................8
8. MATERIALS AND METHODS.............................................................................
9. EXPERIMENTAL PROCEDURES.....................................................................11
10. ANALYSIS OF DATA.........................................................................................12
11. MAINTENANCE OF RAW DATA AND RECORDS......................................12
12. RESULTS.............................................................................................................12
13. CONCLUSION.....................................................................................................13
14. REPORT REVIEW..............................................................................................13
15. REFERENCE.......................................................................................................14
372 Annex 56-B
SLI Study No. 3596.2 (6)
5. LIST OF TABLES AND APPENDICES
Tables
1. Individual Clinical Observations..................................................5.................1
2. Individual Body Weights.............................................................7.................1
3. Individual Gross Necropsy Observations.....................................................19
Appendix
A. SLI Personnel Responsibilities.....................................................1...............2
373Annex 56-B
SLI Study No. 3596.2 (7)
6. SUMMARY
The single-dose oral toxicity of Spray --Alpha was evaluated in Sprague Dawley
rats. A limit test was performed in which one group of five male and five femal e
rats received a single oral administration of the test article at a dose of
5000 mg/kg body weight. Following dosing, the limit test rats were observed
daily and weighed weekly. A gross necropsy examination was performed on
all
limit test animals at the time of scheduled euthanasia (day 14).
No mortality occurred during the limit test. No significant c linical abnormalities
were observed during the study. Body weight gain was noted for all animals
during the test period. No significant gross interna l findings were observed at
necropsy on study day 14.
Under the conditions of this test, the acute oral LD50 of Spray--Alpha was
estimated to be greater than 5000 mg/kg in the rat.
374 Annex 56-B
SLI Study No. 3596.2 (8)
7. INTRODUCTION
This study was performed to assess the short -term toxicity of Spray --Alpha in
Sprague Dawley rats when administered by gavage as a single oral dose. T
his
study was intended to provide information on the potential health hazards
of the
test article with respect to oral exposure. Data from this study may ser
ve as a
basis for classification and/or labeling of the test article. This study
was
performed in accordance with the US EPA, Health Effects Test Guidelines,
OPPTS 870.1100, Acute Oral Toxicity, August 1998. This study was perform
ed
at Springborn Laboratori es, Inc., 553 North Broadway, Spencerville, Ohio. The
protocol was signed by the Study Director on April 30, 2002 (GLP initiat
ion date).
The in-life phase of the study was initiated with test article administration on
June 4, 2002 (day 0) and concluded with necropsy on June 18, 2002.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows
:
Sponsor’s Assigned Physical Receipt Expiration
aID SLI ID Description Date Date
Spray—Alpha S02.001.3596 Light amber 05/13/02 None
liquid provided
b
Ingredients
Herbicide:Fuete-SL None
Lot No.: 02- 01-02 Provided
Surfactant: Cosmo Flux -411F 10/2003
Lot No.: 244301
a
bSample pooled at SLI from five different mixes of Spray --Alpha (top/middle/bottom).
Ingredients used in the five Spray --Alpha mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength, p urity, composition,
stability and method of synthesis of the test material according to 40 C
FR
160.105 and 40 CFR 792.105. Springborn Laboratories, Inc., analyzed the
test
article for the glyphosate (a.e.) which is presented in SLI Study No.
3596.1.
375Annex 56-B
SLI Study No. 3596.2 (9)
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture sample
(top/middle/bottom, maintained separately for a total of fifteen 1 mL sa
mples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The remaining test article was returned to the Sponsor following completion of all
studies with the test article.
8.4. Method of Test Article Preparation
The test article was administered as received from the Sponsor and dispe
nsed
fresh on the day of dosing. The density of the t est article was determined to be
1.08 g/mL.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Young adult, Hsd: Sprague Dawley® SD® rats were received from Harlan
Sprague Dawley, Inc., Indianapolis, IN. Upon receipt, metal ear tags displaying
unique identification numbers were used to individually identify the animals.
Cage cards displaying at least the study number, animal number and sex were
affixed to each cage. The animals were housed individually in suspended
stainless steel cages. All housing and care were based on the standards
recommended by the Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 61- 74°F (16-
23°C) and 35 -61%, respectively. Environmenta l control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10- 15 air changes/hour. The animal
room temperature and relative humidity were recorded a minimum of once d
aily.
376 Annex 56-B
SLI Study No. 3596.2 (10)
8.5.3. Food
PMI Certified Rodent Chow #5002 (Purina Mills, Inc.) was provided ad l
ibitum to
the animals throughout the study (except during fasting). The lot number and
expiration date of each batch of diet used during the study were recorded. The
feed was analyzed and certified by the supplier for nutritional components and
environmental contaminants. Dietary limitations for various environmental
contaminants, including heavy m etals, pesticides, polychlorinated biphenyls and
total aflatoxin are set by the manufacturer. Within these limits, contaminants
which may have been present were not expected to compromise the purpose of
this study. Results of the dietary analyses (Certif icates of Analysis) are provided
by the manufacturer for each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study. The purified water was supplied by an automatic wa
tering
system. Monitoring of the drinking water for contaminants is conducted
by SLI
and the records are available for inspection. Within generally accepted
limits,
contaminants which may have been present were not expected to compromise
the purpose of t his study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with metal ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The
animals
were observed daily for overt physical or behavioral abnormalities, gener
al
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were randomly selected from healthy stock
animals using a computerized (Alpha DS- 10) random numbers table to avoid
potential bias. All animals received a detailed pretest observation prior to dosing.
Only healthy animals were chosen for study u se. Females were nulliparous and
nonpregnant. The male animals were approximately 10 weeks of age and
weighed 249-259 g prior to fasting. The female animals were approximately 12
weeks of age and weighed 218-242 g prior to fasting.
377Annex 56-B
SLI Study No. 3596.2 (11)
9. EXPERIMENTAL PROCEDURES
9.1. Dosing
On day -1, the animals chosen for the limit test were weighed and fasted
overnight. On day 0, the test article was administered orally as a single dose
using a ball tipped stainless steel gavage needle attached to a syringe at the
following level:
Dose Level Dose Volume Concentration No. of Animals
Male Female
(mg/kg) (mL/kg) (mg/má)
a 5000 4.63 1000 5 5
Pooled test article.
Individual doses were calculated based on the animal’s fasted (day 0
) body
weight. Animals were returned to ad libitum feeding after dosing.
9.2. Clinical Observations
The animals were observed for clinical abnormalities two times on study
day 0
(post-dose) and daily thereafter (days 1 -14). A general health/mortality check
was performed twice daily (in the morning and in the afternoon).
9.3. Body Weights
Individual body weights were obtained for the animals prior to fasting (
ay -1),
prior to dosing on day 0 and on days 7 and 14.
9.4. Gross Necropsy
All animals were euthanized by carbon dioxide inhalation at study termin
ation
(day 14) and necropsied. Body cavities (cranial, thoracic, abdominal and pel
vic)
were opened and examined. No tissues were retained.
9.5. Protocol Deviations
On one occasion, the animal room temperature range (61- 74°F) exceeded the
preferred range (66 -77°F) during t his study. This occurrence is considered to
have had no adverse effect on the outcome of this study.
378 Annex 56-B
SLI Study No. 3596.2 (12)
10. ANALYSIS OF DATA
Data from the study were analyzed and an LD50 value estimated as follows:
< 50% Mortality: LD50 was estimated as greater than the administered dose.
= 50% Mortality: LD50 was estimated as equal to the administered dose.
> 50% Mortality: LD50 was estimated as less than the administered dose.
Body weight means and standard deviations were calculated separately for
males and females.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded records
were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
12. RESULTS
12.1. Mortality
Individual Data: Table 1
No mortality occurred during the limit test.
12.2. Clinical Observations
Individual Data: Table 1
No significant clinical abnormalities were observed during the study.
12.3. Body Weight Data
Individual Data: Table 2
Body weight gain was noted for all animals during the test period.
379Annex 56-B
380 Annex 56-B
SLI Study No. 3596.2 (14)
15. REFERENCE
1. Guide for the Care and Use of Laboratory Anim als, DHHS Publication No.
(NIH) 96-03, 1996.
381Annex 56-B
(15)
---- ---- ----
STUIDYL.NO.:DE3596T.2ALE-S------MA-LE#-A-5-2-4OBA52E56TIS-5EE-U-ENT-E-AUEAN-EE-S--ANTASIAG-------R------1----E-----------P6--
-NP--P-L-P---T1-----
382 Annex 56-B
(16)
---- ---- ----
STUNDY/N.O.D:EP3A5.-2MALE-S--FEMA-LE#-A-5-0-9OBA5R123TI-D-LE-TH-E--S-NTULE-A--U----NA-SIA-------A----------E-----S
---=--
----
---
----
1-----
--R-1---14------P------R-----
383Annex 56-B
(17)
---- ---- ----
STUIDYL.NO.:DE359M-ALES--A-NIMAL-#----4852ME-60Y1--F--59--49--36274-83--14--69-D4-2TH-40DAY9)-----------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
384 Annex 56-B
(18)
---- ---- ----
STUNDY/N.O.D:EP3FEMA-LESANIMA-L#---91132M1107Y-N----19-0---60-2762----2--02T-55EAT---0DA-Y)-----------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
385Annex 56-B
(19)
1 ---- ---- ----
STUDINL/A. DEPARMTALES---FI-5000-A5246G24A5---1--Y12260---0-8-J--4T-1TI--AL-AL--SSU-S-N-NTH-ISL-LRM-ONV-SMI-AL
---MITS----------
-
-----
386 Annex 56-B
(20)
2 ---- ---- ----
STINL./A. DEPARFEMA-LEA--I5-AT0-50/ADEA13---T-D-02--JU---1-4ERV-LL-AN--SUE-S-I--HI-T-W--MA-R-N--IT-M-L
-RM------MI-TS
--------
-
-------------------FATCHE--
387Annex 56-B
(21)
SLI Study No. 3596.2
APPENDIX A
SLI Personnel Responsibilities
388 Annex 56-B
(22)
SLI Study No. 3596.2
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute
Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Associate
Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing
Director Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Christopher W. Wilson, B.S. Associate Toxicologist
Pamela S. Smith, ALAT Supervisor of Acute Toxicology
Kevin V. Weitzel, A.S. Primary Technician/Inhalation Team
Leader
Delores P. Knippen Supervisor of Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor of Gross and Fetal
Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
J. Dale Thurman, D.V.M., M.S., DACVP Senior Director, Pathology
Kathy M. Gasser Supervisor of Archives
389Annex 56-B
390 Annex 56-B
391Annex 56-B
392 Annex 56-B
393Annex 56-B
394 Annex 56-B
395Annex 56-B
396 Annex 56-B
397Annex 56-B
398 Annex 56-B
399Annex 56-B
400 Annex 56-B
° °
401Annex 56-B
402 Annex 56-B
403Annex 56-B
404 Annex 56-B
405Annex 56-B
406 Annex 56-B
407Annex 56-B
408 Annex 56-B
409Annex 56-B
410 Annex 56-B
411Annex 56-B
412 Annex 56-B
PURITY ANALYSIS FOR GLYPHOSATE OF SPRAY--ALPHA
(ACTIVE INGREDIENT)
FINAL REPORT
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
October 3, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.1
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 31
413Annex 56-B
(2)
SLI Study No. 3596.1
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any infor mation contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date
Title Signature
414 Annex 56-B
415Annex 56-B
416 Annex 56-B
(5)
SLI Study No. 3596.1
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS..........................2 ..
2. COMPLIANCE STATEMENT.........................................................................3 .......
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS........................................................................................
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION .............................................................................................
8. MATERIALS AND METHODS........................................................................8 ......
9. EXPERIMENTAL PROCEDURE....................................................................9 ......
10. ANALYTICAL CHEMISTRY..............................................................................10
11. SPRAY--ALPHA ANALYSIS ............................................................................10
12. STATISTICAL ANALYSIS.................................................................................13
13. PROTOCOL DEVIATIONS................................................................................13
14. MAINTENANCE OF RAW DATA AND RECORDS......................................13
15. RESULTS.............................................................................................................13
16. CONCLUSION.....................................................................................................14
17. REPORT REVIEW..............................................................................................15
417Annex 56-B
(6)
SLI Study No. 3596.1
5. LIST OF TABLES AND APPENDICES
Tables
1. Standard Curve and Sample Analysis Values for the
Before Use Purity Analyses............................................................1
2. Standard Curve and Sample Analysis Values for the
Before Use Purity Analyses ...........................................................1
3. Sample Analysis Values and % Error (Before-Use Purity)..............18
4. Standard Curve and Sample Analysis Vales for the
After- Use Purity Analyses for Stability......................................9.....1
5. Sample Analysis Values and % Error (After-Use
Purity for Stability) ..........................................................................2
Appendices
A. Statistical Analysis ...............................................................................2
B. SLI Personnel Responsibilities............................................................3
418 Annex 56-B
(7)
SLI Study No. 3596.1
6. SUMMARY
The objective of this study was to assess the concentration(s) of glyphosate
(active ingredient) in the Spray--Alpha formulation.
Five test article mixtures were prepared in the field by the Sponsor. T
hree 500
mL samples of each mixture were collected at the top/middle/bottom (or
beginning/middle/end) of Hoppers PNC 3065 (Test Article Mixtures 1 and
4),
PNC 2070 (Test Article Mixtures 2 and 5), and PNC 3077 (Test Article
Mixture 3).
Test Article mixtures were prepared as follows:
Ingredient Amount Added (gallons)
Herbicide:
Fuente-SL (MON 2139) 87.9
Surfactant:
Cosmo Flux-411F 2.0
Well water 110.1
Mixing time: 10 minutes in flight.
Test article mixtures were prepared on two separate day s (May 2, 2002, for Test
Article Mixtures 1 and 2, and May 3, 2002 for Test Article Mixtures 3, 4
, and 5).
The overall concentration of the Spray--Alpha was 16.3 [in terms of % glyphosate
(a.e.)] before use at SLI and 15.5 [in terms of % glyphosate (a.e. )] after use at
SLI, indicating that the test material was stable during use at SLI.
The overall result (~16.3% glyphosate a.e.) was slightly higher than the
anticipated 14.80% glyphosate (a.e.), but well within acceptable error
of mixing
conditions in the field. Therefore, since the results of the analysis were
appropriate (and would provide conservative results for toxicity, irrit
ation and
sensitization since they were slightly higher than expected), approximat
ely
400 mL of each sample were pooled into a single container for use in the
remaining studies.
419Annex 56-B
(8)
SLI Study No. 3596.1
7. INTRODUCTION
This study was performed to assess the concentrations of glyphosate (active
ingredient) in Spray --Alpha. This study was performed to support studies
conducted under the US EPA, Health Effects Test Guidelines. This study was
performed at Springborn Laboratories, Inc., 553 North Broadway, Spencerville,
Ohio. The protocol was signed by the Study Director on April 17, 2002 (GLP
initiation date). The test article mixtures were analyzed fo r glyphosate (a.e.)
initially on May 22, 2002, prior to all other studies and again on August 12, 2002,
after all studies were complete for purposes of stability.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows:
Assigned Physical Receipt Expiration
Sponsor’s ID SLI ID Description Date Date
a
Spray—Alpha S02.001.3596 Light amber 05/13/02 None
liquid Provided
Ingredients
Herbicide: Fuete-SL None
Lot No.: 02- 01-02 Provided
Surfactant: Cosmo Flux-411F 10/2003
Lot No.: 244301
a
bample pooled at SLI from five different mixes of Spray --Alpha (top/middle/bottom).
Ingredients used in the five Spray --Alpha mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength, purity, composition,
stability and method of synthesis of the test material according to 40 C
FR
160.105 and 40 CFR 792.105.
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture sample
(top/middle/bottom, maintained separately for a total of fifteen 1 mL
mples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures) was
420 Annex 56-B
(9)
SLI Study No. 3596.1
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The test ar ticle was returned to the Sponsor following completion of all studies
with the test article.
8.4. Method of Test Article Preparation
The test article containers were hand shaken and dispensed fresh on the day of
analysis. The samples were stirred continuously until diluted for analysis.
9. EXPERIMENTAL PROCEDURE
9.1. Sample Collection
Samples were collected from the prepared test article mix using pre- labeled
containers provided by SLI as follows:
Test Article Mix 1 500 mL Beginning
500 mL Middle
500 mL End
Test Article Mix 2 500 mL Beginning
500 mL Middle
500 mL End
Test Article Mix 3 500 mL Beginning
500 mL Middle
500 mL End
Test Article Mix 4 500 mL Beginning
500 mL Middle
500 mL End
Test Article Mix 5 500 mL Beginning
500 mL Middle
500 mL End
Five test article mixtures were prepared in the field by the Sponsor. Three 500
mL samples of each mixture were collected from the top/middle/bottom (o
r
beginning/middle/end) of Hoppers PNC 3065 (Test Article Mixtures 1 and
4),
PNC 2070 (Test Article Mixtures 2 and 5), and PNC 3077 (Test Article Mixture 3).
The Test Article mixtures were prepared as follows:
421Annex 56-B
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SLI Study No. 3596.1
Ingredient Amount Added (gallons)
Herbicide:
Fuente-SL (MON 2139) 87.9
Surfactant:
Cosmo Flux-411F 2.0
Well water 110.1
Mixing time: 10 minutes in flight.
Test article mixtures were prepared on two separate days (May 2, 2002, f
or Test
Article Mixtures 1 and 2, and May 3, 2002 for Test Article Mixtures 3, 4
, and 5).
A total of fifteen 500 mL samples were collected. The individual (Robert
Derosier, (Fixed Wing Standards Pilot, American Embassy, Bogota, Unit 5127,
APO AA 34038) collecting samples completed the SLI provided form upon
collection including signature and date when collected at San Jose del Guaviare,
Columbia. Samples were maintained under ambient conditions.
10. ANALYTICAL CHEMISTRY
The samples were analyzed in terms of the active ingredient for concentra
tion
determination prior to any dosing (Before Use- Purity) and again after completion
of all studies for stability determination (After- Use Purity). All analytical dilutions
were performed in duplicate (either the same day or over two days).
The analytical method was a previously validated method for the analysis
of
glyphosate in solution. Purity analysis of the test article was perform
ed in
duplicate by comparison of the test article with supplied reference stan
dards of
known concentrations.
11. SPRAY--ALPHA ANALYSIS
The analytical method for the analysis of the glyphosate component of Spray --
Alpha was validated prior to the purity analyses perf ormed at Springborn
Laboratories, Inc. This method was utilized to determine both the purity and the
stability of the Spray--Alpha test material before and after use at SLI.
11.1. Experimental System
11.1.1. High Performance Liquid Chromatography (HPLC) System
HPLC Model: Waters
Pump: Waters 600E
Injector: Waters WISP 717
422 Annex 56-B
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SLI Study No. 3596.1
Detector: Waters 2487
Data System: H-P 3396B Integrator
Precolumn: Phenomenex, SecurityGuard, C18, 4.0 x 3.0 mm ID
Column: Phenomenex, Spherex, C18, 5µ, 250 x 4.6 mm ID
Temperature: Ambient
Detection: 500 nm, 0.4000 AUFS
Mobile Phase: A: 0.05 M HCO NH , pH 3.6/5% ACN; B: 100% ACN
2 4
Gradient: 100% A hold for 6 minutes; linear change to 25% A/75% B over 1
minute; hold for 5 minutes; linear change to 100% A over 1
minute; hold at 100% A for 15 minutes.
Flow Rate: 1.0 mL/min
Injection Volume: 10 L
11.1.2. Apparatus
Balance: Mettler AG 245, accuracy of 0.0001 gram
Glassware: Assorted volumetric glassware
Filters: Gelman, glass fiber; Millipore 0.2µ Nylon-66; Whatman Puradisc
25PP 0.45µm
Shaker: Labline, Multi-Wrist Shaker
Oven: Boekel Model 107905
11.1.3. Solutions and Reagents
11.1.3.1. Reagents
Water, Fisher, HPLC Grade, Lot # 024471, 025012
Acetonitrile, Fisher, HPLC Grade, Lot # 011777
Acetonitrile, J.T. Baker, HPLC Grade, Lot # M13828
Methanol, Fisher, HPLC Grade, Lot # 011803
NBD Chloride, Aldrich, 98%, Lot #12214L1
Hydrochloric Acid, Fisher, ACS Grade, Lot # 012161
Potassium Tetraborate Tetrahydrate:, Aldrich, 99%, Lot # 15325D1
Formic Acid, Fisher, Laboratory Grade, Lot # 003630
Ammonium Formate, Fisher, Lot # 990125
Glyphosate, Sigma, Lot # 71K36491
11.1.3.2. Solutions
0.37 M Borate Solution: Prepared by dissolving approximately 11.44 g of
potassium tetraborate tetrahydrate in 100 mL of water. The resulting solution
was stable for 6 months under ambient storage conditions.
423Annex 56-B
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SLI Study No. 3596.1
1.2 N HCl: Prepared by dissolving 10 mL of HCl in 90 mL of water. The resulting
solution was stable for 6 months under ambient storage conditions.
25 mM NBD- Cl: Prepared by dissolving approximately 2.5 g of NBD- Cl in 500
mL of methanol. The r esulting solution was stable for 6 months under ambient
storage conditions.
Mobile Phase A: Prepared by dissolving approximately 2.36 g of ammonium
formate in 1425 mL of water. The pH was adjusted to approximately 3.6 with
formic acid prior to the addit ion of 75 ml of acetonitrile. The resulting solution
was mixed thoroughly, filtered through a 0.2 µ Nylon -66 filter and degassed by
helium sparging prior to use. Larger volumes were also prepared using t
he same
ratio of components.
Mobile Phase B: Acetonitrile used 100% as received.
Diluent: All standards and samples were diluted in water.
Stock Standard Solution: Prepared by dissolving approximately 30 mg of
glyphosate standard in a 100 mL flask with diluent.
Standard Solutions : Prepared by serially diluting the stock standard solution with
water. The final concentrations of the solutions were in the range of
approximately 0.02 to 0.14 mg/mL. These solutions were sonicated and then
further diluted in diluent at a ratio of 3:10 and filtered throug h Whatman Puradisc
25PP 0.45µm filters prior to derivatization.
Purity Solutions: Prepared by diluting 1.2 mL aliquots of each sample to a final
volume of 100 mL with diluent. The solutions were further diluted in diluent first
at a ratio of 4:100 and th en at a ratio of 4:10. The resulting solutions were then
filtered through Whatman Puradisc 25PP 0.45 µm filters prior to derivatization.
These preparations were performed in duplicate for each sample.
Derivatization Procedure: In order to analyze the glyphosate component, a
precolumn derivatization was performed by adding 1.2 mL of the appropriat
e
control, standard, or sample solution to a labeled scintillation vial. Both 0.8 mL of
the borate solution and 2.4 mL of the NBD- Cl solution were added to each vial.
The vials were then capped and shaken by hand prior to being heated in an oven
at 80° C for 30 minutes. After removal from the oven, the vials were allowed to
cool for 10 minutes followed by the addition of 0.9 mL of the HCl soluti
on. After
the vials were again shaken by hand, they were allowed to stand for 10 minutes
in order for incipient precipitation to occur. These solutions were then transferred
to injection vials.
424 Annex 56-B
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SLI Study No. 3596.1
11.2. Analytical Procedures
11.2.1. Standard Curve Analysis
The peak area of the glyphosate acid component of each standard were
determined, measured, combined, and plotted as a function of concentrati
on to
generate a standard curve. The actual values used for the calculations
are
shown in Chemistry Tables 1 and 2.
11.2.2. Sample Analysis
The peak areas of the glyphosate acid component of each sample were
measured and combined and then the concentration was determined by linear
fit
to the standard curve. The actual values used for the calculations are
hown in
Chemistry Tables 1 and 2.
12. STATISTICAL ANALYSIS
A statistical analysis was conducted on the average results of the % gl
hosate
(a.e.) for each test article mixture as compared to the theoretical val
ue [14.80%
glyphosate (a.e.) as calculated by the Sponsor] and for the combined r
sults of
all test article mixture samples as compared to the theoretical value using one
way analysis of variance (ANOVA).
13. PROTOCOL DEVIATIONS
No protocol deviations occurred during this study.
14. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded records were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
15. RESULTS
15.1. Analytical Chemistry Results
Individual Data: Tables 1-5
The actual sample results of the initial purity analyses are shown in Chemistry
Tables 1, 2 and 3. These samples were analyzed over two separate days
(Before-Use Purity). The actual sample results of the final purity analyses (After-
425Annex 56-B
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SLI Study No. 3596.1
Use Purity for stability purposes) are shown in Chemistry Tables 4 and 5. These
samples were all analyzed on the same day. All concentration values are
reported in terms of the acid equivalent (a.e.) of the glyphosate. The overall
concentration of Spray--Alpha was 16.3 [in terms of % glyphosat e (a.e.)] before
use at SLI and 15.5 [in terms of % glyphosate (a.e.)] after use at SLI, indicating
that the test material was stable during use at SLI. The average % error for
Before-Use (and After- Use) indicate that the Test Article Mix 3 was significantly
higher in concentration then the other 4 mixes.
15.2. Statistical Analysis
Individual Data: Appendix A
Results of the Before-Use statistical analysis indicate that Test Article Mixture 4
(18.4% glyphosate a.e.) and test article mixture 2 (16.2% glyphosate a
.e.) were
significantly higher than the theoretical value (14.8% glyphosate a.e.).
However,
since these values were within the possible error rate of field mixing and since
these samples were to be part of a pooled sample for dosing the remainin
g
studies, these samples were included. Overall, the results of all mixtures for
the
pooled sample (16.3% glyphosate a.e.) were significantly higher than the
theoretical value (14.8% glyphosate a.e.). This was considered within possible
field mixing error and woul d provide a conservative estimate of toxicity, irritation
and sensitization for the remaining studies. Therefore, the pooled samp
le was
considered to be acceptable for use.
16. CONCLUSION
The overall result (~16.3% glyphosate a.e.) was slightly higher than th
e
anticipated 14.80% glyphosate (a.e.), but well within acceptable error
of mixing
conditions in the field. Therefore, since the results of the analysis were
appropriate (and would provide conservative results for toxicity, irrit
ation and
sensitization si nce they were slightly higher than expected), approximately
400 mL of each sample were pooled into a single container for use in the
remaining studies.
Date
Kimberly L. Bonnette, M.S., LATG
Study Director
426 Annex 56-B
427Annex 56-B
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SLI Study No. 3596.1
Chemistry Table 1
Standard Curve and Sample Analysis Values for the Before Use Purity Analyses
(5/22/2002)
Theoretical Actual Conc.
Sample Type. Conc. Peak Area [% Glyphosate
(mg/mL) (a.e.)]
Std 1 0.008580 36729 NA
Std 2 0.01716 74954 NA
Std 3 0.02574 110393 NA
Std 4 0.03432 152099 NA
Std 5 0.04290 191914 NA
Test Mix # 1, B NA 134276 15.84
Test Mix # 1, M NA 139682 16.46
Test Mix # 1, E NA 133783 15.77
Test Mix # 2, B NA 122717 14.50
Test Mix # 2, M NA 177523 13.90
Test Mix # 2, E NA 115833 13.71
Test Mix # 3, B NA 146078 17.20
Test Mix # 3, M NA 149827 17.63
Test Mix # 3, E NA 142745 16.81
Test Mix # 3, B*NA 140800 18.26
Test Mix # 3, M*NA 145972 18.92
Test Mix # 3, E*NA 151078 19.56
Test Mix # 4, B*NA 114166 14.91
Test Mix # 4, M NA 112720 13.35
Test Mix # 4, E NA 116564 13.79
Test Mix # 5, B NA 118306 13.99
Test Mix # 5, M NA 122335 14.46
Test Mix # 5, E NA 116804 13.82
Correlation coefficient = 0.9996
Note: B = Beginning; M = Middle; E = End; NA = Not Applicable
* These samples were re-analyzed on 5/23/2002 to verify the original results.
** The original value generated for this sample on 5/22/2002 w as not reported due to it’s
deviation from the mean.
428 Annex 56-B
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SLI Study No. 3596.1
Chemistry Table 2
Standard Curve and Sample Analysis Values for the Before Use Purity Analyses
(5/23/2002)
(Duplicate Samples)
Theoretical Actual Conc.
Sample Type. Conc. Peak Area [% Glyphosate
(mg/mL) (a.e.)]
Std 1 0.008550 32585 NA
Std 2 0.01710 65919 NA
Std 3 0.02565 99885 NA
Std 4 0.03420 136969 NA
Std 5 0.04275 173829 NA
Test Mix # 1, B’ NA 140334 18.21
Test Mix # 1, M’ NA 138656 17.99
Test Mix # 1, E’ NA 132930 17.27
Test Mix # 2, B’ NA 122491 15.96
Test Mix # 2, M’ NA 118147 15.41
Test Mix # 2, E’ NA 123855 16.13
Test Mix # 3, B’ NA 151318 19.59
Test Mix # 3, M’ NA 147145 19.07
Test Mix # 3, E’ NA 145996 18.92
Test Mix # 4, B’ NA 113519 14.83
Test Mix # 4, M’ NA 117864 15.38
Test Mix # 4, E’ NA 118768 15.49
Test Mix # 5, B’ NA 122705 15.99
Test Mix # 5, M’ NA 118657 15.48
Test Mix # 5, E’ NA 136909 17.77
Correlation coefficient = 0.9997
' = Duplicate
Note: B = Beginning; M = Middle; E = End; NA = Not Applicable
429Annex 56-B
(18)
-urity)
(18(18)
Chemistry Table 3
Sample Analysis Value and % Error Based on Theoretical Value (Before Use
run of initial sample to verify results
-
SLI Study No. 3596.1 ' *eplicateerror determined based on result compared to theoretical value (14.80%).
430 Annex 56-B
(19)
SLI Study No. 3596.1
Chemistry Table 4
Standard Curve and Sample Analysis Values for the After-Use Purity (for Stability)
Analyses
(8/12/2002)
Theoretical Actual Conc.
Sample Type. Conc. Peak Area [% Glyphosate (a.e.)]
(mg/mL)
Std 1 0.008778 35758 NA
Std 2 0.01756 52370 NA
Std 3 0.02633 105625 NA
Std 4 0.03511 149415 NA
Std 5 0.04389 198319 NA
Test Mix # 1, B NA 128284 15.54
Test Mix # 1, B’ NA 136144 16.43
Test Mix # 1, M NA 135922 16.40
Test Mix # 1, M’ NA 131126 15.86
Test Mix # 1, E NA 135464 16.35
Test Mix # 1, E’ NA 139284 16.79
Test Mix # 2, B NA 123800 15.03
Test Mix # 2, B’ NA 118776 14.46
Test Mix # 2, M NA 123293 14.97
Test Mix # 2, M’ NA 120982 14.71
Test Mix # 2, E NA 125297 15.20
Test Mix # 2, E’ NA 122015 14.83
Test Mix # 3, B NA 148552 17.84
Test Mix # 3, B’ NA 149797 17.98
Test Mix # 3, M NA 149962 18.00
Test Mix # 3, M’ NA 146301 17.58
Test Mix # 3, E NA 150692 18.08
Test Mix # 3, E’ NA 152330 18.27
Test Mix # 4, B NA 114245 13.95
Test Mix # 4, B’ NA 118361 14.41
Test Mix # 4, M NA 116396 14.19
Test Mix # 4, M’ NA 112566 13.75
Test Mix # 4, E NA 115074 14.04
Test Mix # 4, E’ NA 114163 13.94
Test Mix # 5, B NA 120549 14.66
Test Mix # 5, B’ NA 116356 14.19
Test Mix # 5, M NA 121537 14.77
Test Mix # 5, M’ NA 115371 14.07
Test Mix # 5, E NA 119116 14.50
Test Mix # 5, E’ NA 119244 14.51
Correlation coefficient = 0.996
Note: B = Beginning; M = Middle; E = End; NA = Not Applicable
' = Duplicate Sample
431Annex 56-B
(20)
-urity for Stability)
able 5
Chemistry T
(20))
Sample Analysis Value and % Error Based on Theoretical Value (After Use
-un of initial sample to verify results
SLI Study No. 3596.1 ' *Re*Not used in calculation of average. Refer to statement dated 5/28/200
2.(14.8%).
432 Annex 56-B
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SLI Study No. 3596.1
APPENDIX A
Statistical Analysis
433Annex 56-B
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434 Annex 56-B
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435Annex 56-B
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436 Annex 56-B
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437Annex 56-B
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438 Annex 56-B
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439Annex 56-B
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440 Annex 56-B
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441Annex 56-B
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SLI Study No. 3596.1
APPENDIX B
SLI Personnel Responsibilities
442 Annex 56-B
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SLI Study No. 3596.1
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing Director
Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Jason W. Smedley, B.S. Assistant Toxicologist
M. Gardner Clemons, B.S. Senior Supervisor of Analytical Chemistry
and Pharmacy
Delores P. Knippen Supervisor of Pharmacy
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
Kathy M. Gasser Supervisor of Archives
443444 Annex 56-C
SixA cutet oxicitS tudieS witS prA-B rAvo, Sli tudy N° 3596.10,
4 SePtember 2002
(United States Embassy in Bogotá, 2011)
445 AN ACUTE DERMAL TOXICITY STUDY IN RATS
WITH SPRAY--BRAVO
FINAL REPORT
OPPTS Guideline
Kimberly L. Bonnette, M.S., LATG
Study Completed on
September 4, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
Submitted to
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 28
446 Annex 56-C
AN ACUTE DERMAL TOXICITY STUDY IN RATS
WITH SPRAY--BRAVO
FINAL REPORT
OPPTS Guideline
870.1200
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
September 4, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.10
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 28
447Annex 56-C
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SLI Study No. 3596.10
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date Date
Title Signature
448 Annex 56-C
449Annex 56-C
450 Annex 56-C
(5)
SLI Study No. 3596.10
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS..........................2 ..
2. COMPLIANCE STATEMENT.........................................................................3 .......
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS.......................................................................................
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION .............................................................................................
8. MATERIALS AND METHODS........................................................................8 ......
9. EXPERIMENTAL PROCEDURES.....................................................................10
10. ANALYSIS OF DATA.........................................................................................12
11. MAINTENANCE OF RAW DATA AND RECORDS......................................12
12. RESULTS.............................................................................................................12
13. CONCLUSION.....................................................................................................13
14. REPORT REVIEW..............................................................................................13
15. REFERENCES.....................................................................................................14
451Annex 56-C
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SLI Study No. 3596.10
5. LIST OF TABLES AND APPENDICES
Tables
1. Individual Clinical Observations......................................................................15
2. Individual Body Weights.........................................................8.......................1
3. Individual Gross Necropsy Observations......................................................20
Appendices
A. Macroscopic Dermal Grading System..........................................................22
B. SLI Personnel Responsibilities.................................................7...................2
452 Annex 56-C
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SLI Study No. 3596.10
6. SUMMARY
The single -dose dermal toxicity of Spray --Bravo was evaluated in Sprague
Dawley rats. A limit test was performed in which one group of five male and five
female rats received a single dermal administration of the test article at a dose of
5000 mg/kg body weight. Following dosing, the limit test rats were observ
ed daily
and weighed weekly. A gross necropsy examination was performed on all
animals at the time of scheduled euthanasia (day 14).
No mortality occurred during the limit test. Clinical abnormalities observed during
the study included dark material around the facial area and urine stain.
Minor/transient dermal irritation was noted at the site of test article application.
Body weight loss was noted in two male and two females during the study
day 0
to 7 body weight interval which is routinely observed in this study type
due to
experimental manipulation. Body weight gain was noted for all other animals
during the test period. All animals exceeded their initial body weight by study
termination (day 14). No significant gross internal findings were observed at
necropsy on study day 14.
Under the c onditions of this test, the acute dermal LD50 of Spray-- Bravo was
estimated to be greater than 5000 mg/kg in the rat.
453Annex 56-C
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SLI Study No. 3596.10
7. INTRODUCTION
This study was performed to assess the short -term toxicity of Spray --Bravo in
Sprague Dawley rats when administered by a sin gle dermal dose. This study
was intended to provide information on the potential health hazards of th
e test
article with respect to dermal exposure. Data from this study may serve as a
basis for classification and/or labeling of the test article. This study was
performed in accordance with the US EPA, Health Effects Test Guidelines,
OPPTS 870.1200, Acute Dermal Toxicity, August 1998. This study was
performed at Springborn Laboratories, Inc., 553 North Broadway, Spencerville,
Ohio. The protocol was signed by the Study Director on April 26, 2002 (GLP
initiation date). The in- life phase of the study was initiated with test article
administration on July 1, 2002 (day 0), and concluded with necropsy on
July 15, 2002.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows:
Sponsor’s ID Assigned Physical Receipt Expiration
a SLI ID Description Date Date
Spray--Bravo S02.002.3596 Cloudy pale 05/31/02 None
amber liquid provided
b
Ingredients:
Herbicide: Roundup SL None
Lot No.: 4010/4212 provided
4397/4272
4333/4340
4379/4076
4397/4333
Surfactant: Cosmo Flux -411F None
Lot No.: Unknown provided
aSample pooled at SLI from fiv e different mixes of Spray --Bravo (top/middle/bottom).
b
Ingredients used in the five Spray --Bravo mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength, purity, composition,
stability and method of synthesis of the test material according to 40 C
FR
160.105 and 40 CFR 792.105. Springborn Laboratories, Inc., analyzed the
test
article for the glyphosate (a.e.) which is presented in SLI Study No. 3596.8.
454 Annex 56-C
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SLI Study No. 3596.10
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture
(top/middle/bottom, maintained separately for a total of fifteen 1 mL
mples)
was taken and stored at SLI at room temperature. In addition, a 10 mL re
t ention
sample of the pooled test article samples (from the 5 test article mixtures) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The test article was returned to the Sponsor following completion of all studies
with the test article.
8.4. Method of Test Article Preparation
The test article was administered as received from the Sponsor and dispe
nsed
fresh on the day of dosing. The density of the test article was determined to be
1.08 g/mL.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Adult, Hsd: Sprague Dawley® SD® rats were received from Harlan Sprague
Dawley, Inc., Indianapolis, IN. Upon receipt, metal ear tags displaying unique
identification numbers were used to individually identify the animals.
age cards
displaying at least the study number, animal number and sex were affixed to
each cage. The animals were housed individually in suspended stainless steel
cages. All housing and care were based on the standards recommended by the
Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 69- 75°F
(21-24°C) and 37 -58%, respectively. Environme ntal control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10- 15 air changes/hour. T he animal
room temperature and relative humidity were recorded a minimum of once d
aily.
8.5.3. Food
PMI Certified Rodent Chow #5002 (Purina Mills, Inc.) was provided ad libitum to
the animals throughout the study. The lot number and expiration date of
each
batch of diet used during the study were recorded. The feed was analyzed and
certified by the supplier for nutritional components and environmental
455Annex 56-C
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SLI Study No. 3596.10
contaminants. Dietary limitations for various environmental contaminants
,
including heavy metals, pesticides, p olychlorinated biphenyls and total aflatoxin
are set by the manufacturer. Within these limits, contaminants which may have
been present were not expected to compromise the purpose of this study.
Results of the dietary analyses (Certificates of Analysis) were provided by the
manufacturer for each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study. The purified water was supplied by an automatic w
atering
system. Monitoring of the drinking water for contaminants is conducted by SLI
and the records are available for inspection. Within generally accepted
limits,
contaminants which may have been present were not expected to compromise
the purpose of this study. The wat er meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with metal ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The
animals
were observed daily for overt physical or behavioral abnormalities, gener
al
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were rand omly selected from healthy stock
animals using a computerized ( Alpha DS-10 AcuTox) random numbers table to
avoid potential bias. All animals received a detailed pretest observatio
n prior to
dosing. Only healthy animals were chosen for study use. Females were
nulliparous and nonpregnant. The male animals were approximately 11 weeks of
age and weighed 360- 391 g prior to dosing. The female animals were
approximately 11 weeks of age and weighed 212-235 g prior to dosing.
9. EXPERIMENTAL PROCEDURES
9.1. Preliminary Procedures
On day -1, the fur was removed from the dorsal trunk area of the animals chosen
for the limit test using an animal clipper. The clipped area was approxi
mately
10% of the animal’s body surface area (BSA). The region included the scapula
(shoulder) to the wing of the ilium (hipbone) and half way down the flank on each
side of the animal. Care was taken to avoid abrading the skin during the clipping
procedure.
456 Annex 56-C
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SLI Study No. 3596.10
9.2. Dosing
On the following day (day 0), the test article was administered dermal
ly to
approximately 10% of the body surface area. The four corners of this area were
delineated in the clipped area with an indelible marker. The test article was then
spread evenly over the delineated test area and held in contact with the
skin with
an appropriately sized 4 -ply porous gauze dressing backed with a plastic wrap
which was placed over the gauze dressing (occlusive binding). Removal
and
ingestion of the test article was prevented by placing an elastic wrap over the
trunk and test area. The elastic wrap was further secured with a tape harness on
the cranial end of the trunk and then secured with adhesive tape around
the trunk
at the caudal end.
The test article was administered at the following level:
No. of Animals
Dose Level Dose Volume Concentration Male Female
(mg/kg) (mL/ka) (%)b
a 5000 4.63 100 5 5
Adjusted based on a density of 1.08 g/mL.
bPooled test article.
Individual doses were calculated based on the animal’s day 0 body weig
ht. After
an approximate 24- hour exposure period, the b inding materials were removed
and the corners of the test site were re- delineated using a marker. Residual test
article was removed using gauze moistened with deionized water followed by dry
gauze.
9.3. Dermal Observations
The test animals were examined for er ythema and edema following patch
removal and the responses scored on study day 1 and daily thereafter (days 2 -
14) according to the Macroscopic Dermal Grading System provided in Appendix
A which is based on Draize [2]. The dermal test sites were reclipped as
necessary to allow clear visualization of the skin.
9.4. Clinical Observations
The animals were observed for clinical abnormalities a minimum of two times on
study day 0 (postdose) and daily thereafter (days 1- 14). A mortality check was
performed twice daily, in the morning and afternoon.
457Annex 56-C
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SLI Study No. 3596.10
9.5. Body Weights
Individual body weights were obtained for the animals prior to dosing on day 0
and on days 7 and 14.
9.6. Gross Necropsy
All animals were euthanized by carbon dioxide inhalation at study termin
ation
(day 14) and necropsied. Body cavities (cranial, thoracic, abdominal and pelvic)
were opened and examined. No tissues were retained.
9.7. Protocol Deviations
No protocol deviations occurred during this study.
10. ANALYSIS OF DATA
Data from the study were analyzed and an LD50 value estimated as follows:
< 50% Mortality: LD50 was estimated as greater than the administered dose.
= 50% Mortality: LD50 was estimated as equal to the administered dose.
> 50% Mortality: LD50 was estimated as less than the administered dose.
Body weig ht means and standard deviations were calculated separately for
males and females.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report andmagnetically encoded records were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
12. RESULTS
12.1. Mortality
Individual Data: Table 1
No mortality occurred during the limit test.
458 Annex 56-C
459Annex 56-C
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SLI Study No. 3596.10
15. REFERENCES
1. Guide for the Care and Use of Laboratory Animals, DHHS Publi cation No.
(NIH) 96-03, 1996.
2. Draize, J.H., Appraisal of the Safety of Chemicals in Foods, Drugs and
Cosmetics, The Association of Food and Drug Officials of the United States,
49-51, 1959.
460 Annex 56-C
(15)
1 ---- ---- ----
STUINL/A, U.S. DEMAALESMENT-500SE#M------OSSERVATIO-AEUTAD-0AIA31-IRDER-AEGS5D-LSATE-NT-UL--RNM-MR
D
H
AKRKU-U-NA----RAR--------1-PPP--
4
-P
461Annex 56-C
(16)
---- ---- ----
STIUDY/NO.:.3.596.10ALESNTFEMALE-#------OBSE--DULEMPHMAK-KRKSCHCOREADATAUTH8AD(SAITDGREDMAG-YAHMDUHFA-
-UOHANAO-P---P1-P--P-E-------
462 Annex 56-C
(17)
---- ---- ----
STUDY/ANO.:.359D6.10ALEESNFE-MALE#----4--OBSER---LTHMAKR--A:DR0AI--AROUNDN-E-E(S)---------------DAY---F-=TUD-5-
-P-
------PP-P--1---PP-P3-------P--------------
463Annex 56-C
(18)
1 ---- ---- ----
STUINL/A, U.S.MD-ALES-----TAL-0-5A/--1M07-----F---7--60----1--6--DEA-------BL-----------
--H------R-----
--------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------------
464 Annex 56-C
(19)
2 ---- ---- ----
STINL/A, U.S.FD.EMALES--IM5000-M----3831---0---51-22-----9--413-D-1--N--TAY--------------------N--A----
--------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------------
465Annex 56-C
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E 1 ---- ---- ----
STUDINL/A, U.S.MDALES----NMAL00-5G/K-OFT----U--J-5-1--4-15---14T--TISI-I-ATL--OIN--I-TH---DIMB-I--L
-RMAL----MITS---------
---
466 Annex 56-C
(21)
E 2 ---- ---- ----
STINL/A, U.S.FDE-MALES---500-0----8G330--ST---1234-2--0B--AUA----N----RSL--S-UE---TRMO-R-NO---SNVA---TS--TIMI--S
-------
-
------------------
467Annex 56-C
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SLI Study No. 3596.10
APPENDIX A
Macroscopic Dermal Grading System
468 Annex 56-C
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SLI Study No. 3596.10
MACROSCOPIC DERMAL GRADING SYSTEM
ERYTHEMA AND EDEMA OBSERVATIONS
OBSERVATION DEFINITION CODE
Erythema – Grade 0 No erythema 0
Erythema – Grade 1 Very slight erythema (barely perceptible) 1
Erythema – Grade 2 Well-defined erythema 2
Erythema – Grade 3 Moderate to severe erythema 3
Erythema – Grade 4 Severe erythema (beet redness) 4
Maximized Grade 4 Notable dermal lesions (see below) M – 4
(see below)
Edema – Grade 0 No edema 0
Edema – Grade 1 Very slight edema (barely perceptible) 1
Slight edema (edges of area well defined by definite
Edema – Grade 2 raising) 2
Edema – Grade 3 Moderate edema (raised approximately 1 millimeter) 3
Edema – Grade 4 Severe edema (raised more than 1 millimeter and 4
extends beyond the area of exposure)
NOTE: Each animal was assigned an erythema and edema score. The most severely affected
area within the test site was graded. If eschar, blanching, ulceration
and/or necrosis greater
than grade 1 was observed, then the “Maximized Grade 4" was assigned
to the test site in
place of the erythema score and the type of notable dermal lesion(s) (e.g
., e- grade 2,
blanching - grade 3, ulceration - grade 4, etc.) was noted. The presence of any other dermal
changes (e.g., desquamation, fissuring, eschar exfoliation, etc.) was also recorded.
469Annex 56-C
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SLI Study No. 3596.10
MACROSCOPIC DERMAL GRADING SYSTEM
NOTABLE DERMAL LESIONS
OBSERVATION CODE DEFINITION
Eschar – Grade 1 ES-1 Focal and/or pinpoint areas up to 10% of test site.
Eschar – Grade 2 ES-2 > 10% < 25% of test site.
Eschar – Grade 3 ES-3 > 25% < 50% of test site.
Eschar – Grade 4 ES-4 > 50% of test site.
Blanching – Grade 1 BLA-1 Focal and/or pinpoint areas up to 10% of test site.
Blanching – Grade 2 BLA-2 > 10% < 25% of test site.
Blanching – Grade 3 BLA-3 > 25% < 50% of test site.
Blanching – Grade 4 BLA-4 > 50% of test site.
Ulceration – Grade 1 U-1 Focal and/or pinpoint areas up to 10% of test site.
Ulceration – Grade 2 U-2 > 10% < 25% of test site.
Ulceration – Grade 3 U-3 > 25% < 50% of test site.
Ulceration – Grade 4 U-4 > 50% of test site.
NEC-1 Focal and/or pinpoint areas up to 10% of test site
Necrosis – Grade 1
(color) (Note color of necrosis).
NEC-2
Necrosis – Grade 2 > 10% < 25% of test site (Note color of necrosis).
(color)
NEC-3
Necrosis – Grade 3 (color) > 25% < 50% of test site (Note color of necrosis).
NEC-4
Necrosis – Grade 4 (color) > 50% of test site (Note color of necrosis).
470 Annex 56-C
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SLI Study No. 3596.10
MACROSCOPIC DERMAL GRADING SYSTEM
ADDITIONAL DERMAL FINDINGS
OBSERVATION DEFINITION CODE
Characterized by scaling or fl aking of
Desquamation dermal tissue with or without denuded DES
areas.
Characterized by cracking of the skin with
or without moist exudate. Fissuring should
Fissuring be checked prior to removing the animal FIS
from the cage and manipulating the test
site.
The process by which areas of eschar
Eschar Exfoliation EXF
flake off the test site.
Skin located at test site appears to be
TSS
Test Site Staining discolored, possibly due to test article (color)
(note color of staining).
The erythema extends beyond the test
Erythema Extends Beyond site. Note: A study director should be
the Test Site contacted for erythema extending beyond ERB
the test site.
Characterized by pale area(s) (almost a --
burn-like appearance) in the test site.
However, erythema may still be observed
through the pale area. Note: This
observation may affect the overall
erythema score of the test site. This
observation may progress to other
Superficial Lightening
observations resulting in notable dermal
lesions, but SL itself will not be considere d
a notable dermal lesion that will result in a
dermal score to be maximized since it
does not result in any in- depth injury. To
be coded using an area designation (see
below).
Superficial Lightening - Focal and/or pinpoint areas up to 10% of
Grade 1 the test site SL-1
Superficial Lightening - > 10% < 25% of test site SL-2
Grade 2
Superficial Lightening - > 25% < 50% of test site SL-3
Grade 3
Superficial Lightening - > 50% of test site
SL-4
Grade 4
471Annex 56-C
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SLI Study No. 3596.10
MACROSCOPIC DERMAL GRADING SYSTEM
ADDITIONAL FINDINGS
OBSERVATION DEFINITION CODE
Noticeable irritation outside of test site
Dermal Irritation - Outside probably due to the binding tape material. IT
the Test Site This notation will only be made for
reactions greater than what are normally
observed from tape removal which do not
interfere with the scoring of the test site.
472 Annex 56-C
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SLI Study No. 3596.10
APPENDIX B
SLI Personnel Responsibilities
473Annex 56-C
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SLI Study No. 3596.10
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Associate Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing Director
Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Jason W. Smedley, B.S. Assistant Toxicologist
Pamela S. Smith, ALAT Supervisor of Acute Toxicology
Kevin V. Weitzel, A.S. Primary Technician/Inhalation Team
Leader
Delores P. Knippen Supervisor of Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor of Gross and Fetal
Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
J. Dale Thurman, D.V.M., M.S., Senior Director, Pathology
DACVP
Kathy M. Gasser Supervisor of Archives
474 Annex 56-C
AN ACUTE NOSE-ONLY INHALATION TOXICITY
STUDY IN RATS WITH SPRAY--BRAVO
FINAL REPORT
OPPTS Guideline
870.1300
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
January 7, 2003
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.11
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 50
475Annex 56-C
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SLI Study No. 3596.11
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company: ______________________________________________________
Company Agent: ________________________ Date_____________________
________________________ ___________________________________
Title Signature
476 Annex 56-C
477Annex 56-C
478 Annex 56-C
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SLI Study No. 3596.11
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS..........................2 ..
2. COMPLIANCE STATEMENT.........................................................................3 .......
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS.......................................................................................
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION .............................................................................................
8. MATERIALS AND METHODS........................................................................8 ......
9. EXPERIMENTAL PROCEDURES .....................................................................11
10. ANALYSIS OF DATA.........................................................................................14
11. MAINTENANCE OF RAW DATA AND RECORDS......................................14
12. RESULTS.............................................................................................................15
13. CONCLUSION.....................................................................................................16
14. REPORT REVIEW..............................................................................................16
15. REFERENCE.......................................................................................................17
479Annex 56-C
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SLI Study No. 3596.11
5. LIST OF TABLES AND APPENDICES
Tables
1. Summary of Aerosol Generation and Chamber Environmental Data.......18
2. Individual Clinical Observations.................................................................1..9
3. Individual Body Weight Data.....................................................................2
4. Individual Gross Necropsy Observations..................................................2
Figure
1. Multistage 10L Nose-Only Inhalation Chamber..........................................7
Appendices
A. Preliminary Aerosol Generation Trials.......................................................2
B. Analytical Chemistry Report.......................................................................3
C. Individual Aerosol Generation and Chamber Environmental Data.............41
D. SLI Personnel Responsibilities...................................................................4
480 Annex 56-C
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SLI Study No. 3596.11
6. SUMMARY
The four -hour nose- only inhalation toxicity of Spray --Bravo was evaluated in
Sprague Dawley rats. A limit test was performed in which a group of five male
and five female rats received a four-hour nose-only inhalation exposure to a time-
weighted average aerosol concentration ( analytically determined) of 2.40 mg/L.
Following the exposure, the limit test rats were observed daily and weighed
weekly. A gross necropsy examination was performed on all limit test animals at
the time of death or scheduled euthanasia (day 14).
Mortality occurred during the limit test as follows:
Dose Level No. Dead/No. Dosed
(mg/L) Males Female Combined
2.40 2/5 0/5 2/10
All mortality occurred by study day 1. Although mortality was observed i
n 2/5
males the LD50 is still estimated to be greater than 2.40 mg/L, which is
well
above the EPA required 2.00 mg/L. The most notable clinical abnormalities
observed during the study included decreased activity, breathing abnorma
lities,
decreased defecation, rough haircoat, nasal discharge and dark material
around
the facial area. A slight body weight loss was noted for two males durin
g the day
0 to 7 body weight interval. Body weight gain/maintenance was noted for
all
other surviving animals during the test period. The most notable gross i
nternal
findings were observed in the animals that died and included dark red lobes of
the lung and abnormal content in the small intestine. No significant gross internal
findings were observed at necropsy on study day 14.
Under the conditions of this test, the acute inhalation LC50 of Spray --Bravo was
estimated to be greater than 2.40 mg/L in the ra t (which was well above the EPA
required 2.00 mg/L).
481Annex 56-C
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SLI Study No. 3596.11
7. INTRODUCTION
This study was performed to assess the short -term toxicity of Spray --Bravo in
Sprague Dawley rats when administered by a four- hour nose- only inhalation
exposure. This study was intended to provide information on the potential health
hazards of the test article with respect to inhalation exposure. Data from this
study may serve as a basis for classification and/or labeling of the test article.
This study was conducted in accordance with the US EPA, Health Effects Test
Guidelines OPPTS 870.1300, Acute Inhalation Toxicity, August 1998. This study
was performed at Springborn Laboratories, Inc., 553 North Broadway,
Spencerville, Ohio. The protocol was signed by the Study Director on
April 26, 2002, (GLP initiation date). The in -life phase of the study was initiated
with test article administration on August 1, 2002 (day 0), and conclu
ded with
terminal euthanasia on August 15, 2002.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows:
Sponsor’s ID Assigned Physical Receipt Expiration
SLI ID Description Date Date
Spray--Bravo S02.002.3596 Cloudy pale 05/31/02 None
amber liquid provided
b
Ingredients:
Herbicide: Roundup SL None
Lot No.: 4010/4212 provided
4397/4272
4333/4340
4379/4076
4397/4333
Surfactant: Cosmo Flux -411F None
Lot No.: Unknown provided
a
bample pooled at SLI from five different mixes of Spray--Bravo (top/middle/bottom).
Ingredients used in the five Spray --Bravo mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength , purity, composition,
stability and method of synthesis of the test material according to 40 C
FR
160.105 and 40 CFR 792.105. Springborn Laboratories, Inc., analyzed the
test
article for the glyphosate (a.e.) which is presented in SLI Study No.
3596.8.
482 Annex 56-C
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SLI Study No. 3596.11
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixtu re
(top/middle/bottom, maintained separately for a total of fifteen 1 mL
mples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The remaining test article was returned to the Sponsor following completion of all
studies with the test article.
8.4. Method of Test Article Preparation
The test article was utilized as received from the Sponsor and dispensed
fresh
on the day of dosing. The test article was stirred prior to and continuously during
exposure.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Young adult, Hsd: Sprague Dawley® SD® rats were received from Harlan
Sprague Dawley, Inc., Indianapolis, IN. Upon receipt, metal ear tags dis
playing
unique identification numbers were used to individually identify the animals.
Cage cards displaying at least the study number, animal number and sex were
affixed to each cage. The animals were housed individually in suspended
stainless steel cages. All housing and care were based on the standards
recommended by the Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 69- 78°F
(21-26°C) and 34 -60%, respectively. Environmental control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10- 15 air changes/hour. The animal
room temperature and relative humidity were recorded a minimum of once daily.
8.5.3. Food
PMI Certified Rodent Chow #5002 (Purina Mills, Inc.) was provided ad l
ibitum to
the animals throughout the study (except during the time that the animals were
acclimated to the exposure tubes and maintained in the inhalation room for the
483Annex 56-C
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SLI Study No. 3596.11
exposure procedure). The lot number and expiration date of each batch of d
iet
used during the study were recorded. The feed was analyzed and certified
by the
supplier for nutritional components and environmental contaminants. Die
tary
limitations for various environmental contaminants, including heavy metals,
pesticides, polychlorinated biphenyls and total aflatoxin are set by the
manufacturer. Within these limits, contaminants which may have been pres
ent
were not expected to compromise the purpose of this study. Results of the
dietary analyses (Certificates of Analysis) are provided by the manufa
cturer for
each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study (except during the time that the animals were acclimated to
the exposure tubes and maintained in the inhalation room for the exposure
procedure). The purified water was supplied by an automatic watering system.
Monitoring of the drinking water for contaminants is conducted by SLI and the
records are available for inspection. Within generally accepted limits,
contaminants which may have been present were not expected to compromise
the purpose of this study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with metal ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The animals
were observed daily for overt physical or behavioral abnormalities, gener
al
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were randomly selected from healthy stoc
k
animals using a computerized (Alpha DS- 10 AcuTox) random numbers table to
avoid potential bias. All animals received a detailed pretest observatio
n prior to
dosing. Only healthy animals were chosen for study use. Females were
nulliparous and nonpregnant. The male animals were approximately 10 weeks of
age and weighed 305- 324 g on the day of exposure. The female animals were
approximately 9 weeks of age and weighed 191-200 g on the day of exposure.
484 Annex 56-C
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SLI Study No. 3596.11
9. EXPERIMENTAL PROCEDURES
9.1. Preliminary Procedures
9.1.1. Test Article Volatility Determination
The volatility of the test article relative to a distilled water standard was
determined prior to experimental initiation. This procedure was performed in
order to determine if the test article had sufficiently low volatility to allow foan
accurate gravimetric determination of the aerosol concentration. A know
n
quantity of the test article was placed on a preweighed filter disk and
was allowed
to evaporate for a total of ten minutes. The test article weight was det
ermined
each minute an d the amount of evaporation of the test article was then
determined. The results of this volatility trial indicated that the test
article
evaporation rate (0.52 mg/minute) was comparable to the SLI determined
distilled water evaporation rate (0.55 mg/minute); therefore was considered to not
be volatile.
9.1.2. Preliminary Aerosol Generation Trials
Prior to experimental initiation, preliminary aerosol generation trials
were
conducted. These trials were performed in order to determine the most e
fficient
means of generating an aerosol of the appropriate concentration while utilizing
equipment that would reduce the aerodynamic particle size. Data obtained
during the preliminary aerosol generation trials are presented in Appendix A.
9.2. Limit Test
9.2.1. Aerosol Generation Equipment
The test aerosol was generated with a Pistol Spraying System and a Master Flex
Pump and Pump Heads 77200- 60 and 7523- 30. Conditioned high pressure
external air was used in generating the test atmosphere. The aerosol was
blown
through a 5L Elutriator, the nose-only inhalation chamber and then vented from
the chamber to an air treatment system which consisted of a prefilter, a
HEPA
filter, a charcoal bed and a water scrubbing tower (see Figure 1).
9.2.2. Dosing
On day 0, the animals chosen for the limit te st were weighed, placed in a nose -
only exposure tube and allowed to acclimate to the exposure tube for at least one
hour. Animals that appeared to have been acclimated to the exposure tube (i.e.,
minimal struggling and no inversion) were considered to be acceptable and
removed from the exposure tube and returned to their cages until initiation of the
485Annex 56-C
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SLI Study No. 3596.11
aerosol exposure. Animals that did not appear to acclimate to the exposure tube
were not acceptable and were removed from the exposure tube and returned
to
their cages.
The acceptable animals were then placed in exposure tubes and the tubes
inserted into the Multistage 10L nose-only inhalation chamber and the test article
aerosolized at the following level:
Exposure Level No. of Animals
(mg/L) Male Female
2.40 5 5
The aerosol exposure consisted of a 4 -minute T99 equilibration period, a 240-
minute exposure period and a 4-minute de-equilibration period equal to the T99
equilibration period. After each aerosol exposure, animals were removed
from
the exposure tubes and residual test article was removed from the animal's
exterior surfaces (where practical) by wiping the haircoat with a towel . The
animals were then returned to ad libitum feed and water. The following
parameters were measured during the exposure.
9.2.2.1. Chamber Air Flow
Air flow readings were recorded at the initiation of the T99 equilibration period, at
approximate 30- minute intervals during the aerosol exposure and at the
conclusion of the de-equilibration period.
9.2.2.2. Aerosol Concentration
For the analytical concentration, the test article aerosol concentration was
collected in the inhalation chamber utilizing impinger glassware containing
20 mL of methanol per tube. Three impingers were placed in tandem and the
aerosol atmosphere was drawn through the three sample tubes to collect the test
article. Three impingers were utilized in order to ensure that all test
article was
collected in the initial tube and none had escaped into the second or third (last)
tube. A 2 L sample of the aerosol was drawn from the breathing zone of the
chamber for two minutes (4 L of atmosphere). The aerosol concentration
was
measured at the beginning of the aerosol exposure (after equilibration),
then
hourly during the exposure and at the conclusion of the aerosol e xposure (before
de-equilibration) for a total of five samples. However, the initial sampling
collection procedure did not produce a viable sample (confirmed by anal
ytical
chemistry to not contain any test article) due to a probable loose connection tube.
Therefore, the second sample collected was considered the aerosol
concentration during the entire first hour. The samples were analyzed by
Springborn Laboratories, Inc., for glyphosate, a non -volatile component of the
486 Annex 56-C
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SLI Study No. 3596.11
test article. These analyses were performed in order to determine the analytical
(actual) concentrations of the aerosol in the chamber for each sampling period.
The average time weighted analytical concentration of the test atmosphere was
then calculated for the exposure. Chemistry methods and results are detailed in
the Analytical Chemistry Report (Appendix B).
Note: There were no changes in air flow nor test article flow over this t
ime period
to the second sampling.
9.2.2.3. Chamber Temperature and Humidity
The chamber temperature and humidity w ere measured electronically and
recorded at approximate 30-minute intervals during the aerosol exposure.
9.2.2.4. Aerosol Aerodynamic Particle-Size Distribution
The aerosol aerodynamic particle -size distribution was determined three times
during the aerosol exposur e using the ITP 7 Stage Cascade Impactor . Each
stage of the impactor was fitted with a preweighed glass fiber filter. Five liters
per minute of the chamber air were drawn through the impactor and the cha
nge
in weight of each filter was then determined and recorded. The mean particle -
size distribution was subsequently plotted using an Excel computer adaptation of
the manual method. The Mass Median Aerodynamic Diameter, Geometric
Standard Deviation and percentage of particles < 4.0 µ were then determined. At
least one hour passed between each aerosol particle-size analysis.
9.2.2.5. Chamber Oxygen
Chamber oxygen content was measured and recorded at approximate 30- minute
intervals during the aerosol exposure.
9.2.3. Clinical Observations
The limit test animals were observed for clinical abnormalities during the aerosol
exposure, a minimum of two times on study day 0 (post- exposure) and daily
thereafter (days 1 -14). A general health/mortality check was performed twice
daily (in the morning and in the afternoon).
487Annex 56-C
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SLI Study No. 3596.11
9.2.4. Body Weights
Individual body weights were obtained for the limit test animals prior to dosing on
day 0 and for all surviving animals on days 7 and 14. Animals found dead after
day 0 were also weighed.
9.2.5. Gross Necropsy
All limit test animals that died spontaneously during the study or were euthanized
by carbon dioxide inhalation at study termination (day 14) were necrops
ied.
Body cavities (cranial, thoracic, abdominal and pelvic) were opened and
examined. No tissues were retained.
9.3. Protocol Deviations
The temperature of the animal room [69-78°F (21-26°C)] exceeded the preferred
range [66-77°F (19-25°C)] during this study. This occurrence was considered to
have had no adverse effect on the outcome of this study.
10. ANALYSIS OF DATA
Data from the limit tests were analyzed and an LC50 value estimated as follows:
< 50% Mortality: LC50 was estimated as greater than the administered dose.
= 50% Mortality: LC50 was estimated as equal to the administered dose.
> 50% Mortality: LC50 was estimated as less than the administered dose.
Body weight means and standard deviations were calculated separately for
males and females. The aerodynamic particle -size distribution of the test article
aerosol was plotted using an Excel computer adaptation of the three cycle
logarithmic probability paper as per the ITP Cascade Impactor instruction
manual. The Mass Median Aerodynamic Diameter, Geometric Standard
Deviation and particles < 4.0 µ was determined based on the plotted distribution.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded records were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
488 Annex 56-C
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SLI Study No. 3596.11
12. RESULTS
12.1. Aerosol Generation and Chamber Environmental Data
12.1.1. Aerosol Generation Data
Individual Data: Table 1
The average time-weighted analytical concentration for the aerosol exposure was
determined to be 2.40 mg/L. The mass median aerodynamic diameter and
geometric standard deviation of the sampled particles were 3 .2 µ ± 1.96. The
percentage of particles 4.0 µ was determined to be 63%.
12.1.2. Chamber Environmental Data
Individual Data: Table 1
Chamber temperature and relative humidity for the aerosol exposure ranged from
74.9-77.0°F and 57.1 -60.6%, respectively. Oxyge n content was maintained at
21% throughout the exposure.
12.2. Limit Test Data
12.2.1. Mortality
Individual Data: Table 2
All mortality occurred by study day 1.
12.2.2. Clinical Observations
Individual Data: Table 2
The most notable clinical abnormalities observed during the study included
transient incidences of decreased activity, breathing abnormalities, decreased
defecation, rough haircoat, nasal discharge and dark material around the facial
area. No positive findings were noted at the time of observation during the 4 -
hour exposure period.
489Annex 56-C
490 Annex 56-C
(17)
SLI Study No. 3596.11
15. REFERENCE
1. Guide for the Care and Use of Laboratory Animals, DHHS Publication No.
(NIH) 96-03, 1996.
491Annex 56-C
(18)
PAGE 1
10 5 22 4 4 63 -77.0021
2.40 88.24 240 2.40 3.2±1.96
297.69 74.97.1
EXPOSURE LEVEL (MG/L)
TABLE 1
ONLY INHALATION TOXICITY STUDY IN RATS
-
CHAMBER ENVIRONMENTAL DATA
SUMMARY OF AEROSOL GENERATION AND
AN ACUTE NOSE
: 4.0 µ (%):
EXPOSURE DATA
-WEIGHTED MEAN ANALYTICAL CONCENTRATION (MG/L):
SLI STUDY NO.: 3596CHACHBELUMTRAETT99EEPOI-BREELOMEAMENI:DEMNTR.(TIN):SLE-GZEDFEPVIRONIEES≤NA:L DATA
492 Annex 56-C
(19)
---- ---- ----
STUDYL/NO.:U3596.E11LESMENT--MALE#-A-----OBSE-NDGEORESARBSCCOHIARGLEEUBRDYTDD5BECEAIDMNGD-LEWONCAOAACP(S)OCO-EPBRGPE:SL-G9--
---=M--P--P----------------------
493Annex 56-C
(20)
---- ---- ----
STUDY/ANO.:.359D6.11ESMEN---M-ALE#-----(-OBSERV--DECTLKRK-ECTORGLA-CLEARDND-OSEUTH----------0---DAY-----RTPDY-P--------8-------R-----------
494 Annex 56-C
(21)
---- ---- ----
STUDY/ANO.:.3596.P11ALESNTFEMALE#--A----OBSER-EDUEORESPW--ANCCS------50ABRCESTE-AETEDAFEUN-ESIBGYE-AR-HEDTY---(-------P---
---
-----1--P13--PP---------------
495Annex 56-C
(22)
---- ---- ----
STUDLY/NO.:.3.596.11ALMESNF-EMALE#--5-----AS-HENEW-:NEEUB--LI-SIAG--2--------T-------S-----------DAY-
-N-PTUPY--------
--------------------
496 Annex 56-C
(23)
---- ---- ----
STUDLY/NO.:.S35MALE1S--ANIMAL#-6-----222024Y0--03STU7------144.-T-DEA-2--(DAY-1--6-----(----1--)-----------------------------
-------------------------------------
---------------------------------------------------------------------------------------------
497Annex 56-C
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---- ---- ----
STIUDY/NO.U:.35FE.MALESANIMA-L#------75057AN-0OF-ST-----9--1---A2-D----H-(D-AY)9-------------------------
-----------------------------------
498 Annex 56-C
(25)
1 ---- ---- ----
STINL/A, U.S.MDALES---EIMA.40-5G/L--FTH--------------O-----------AUG--IARKRAU-AAU-C-EOBR
ERI
EPAT-IANSAOS--MDLN-WTRESERI-K;TH-CCLTENSL-TAWE
499Annex 56-C
(26)
2 ---- ---- ----
STINL/A, U.S.FD.EMALES----AL#0-574L57-A5--AUG---G-AU--A15-----TIO-OSS4---TIS--IN-T-N-HIN--IMIH-M-L
-
-IL
L--MITS---------
-
---
500 Annex 56-C
(27)
501Annex 56-C
(28)
SLI Study No. 3596.11
APPENDIX A
Preliminary Aerosol Generation Trials
502 Annex 56-C
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SLI Study No. 3596.11
1. PRELIMINARY AEROSOL GENERATION TRIALS
Prior to experimental initiation, preliminary aerosol generation trials were conducted.
These procedures were performed in order to determine the most efficient
means of
generating an aerosol of the test article. The type of equipment used during each
aerosol trial procedure is presented in Trial Table 1. In each trial, attempts were
made to generate the highest concentration of the test article while utilizing
equipment that would minimize the aerodynamic particle size of the aeros
ol.
The analytical chemistry was initially attempt ed by extracting the active (glyphosate)
from the glass fiber filters. However, for this material, the results w
ere inaccurate and
the collection procedure changed to collect the atmosphere test article s
ample
directly into a liquid (using 20 mL methanol in an impinger). Four impingers were
utilized in tandem to insure that all of the test article was trapped
ased on these
results of less than 10% test article in the second, third and fourth impingers, no more
than two impingers were needed for the main study. However, three impingers were
utilized as a precaution. In addition, the sample collection procedure was the same
as utilized for Trial #2 (2 L of atmosphere drawn through the impingers
for 2 minutes
for a total of 4 L of atmosphere). In order to ensure a > 2.00 target dose, the test
article flow rate was increased to 5.0 mL/minute.
Using the equipment design determined by the aerosol generation trials, p
reliminary
results from previous trial work indicated the aerosol aerodynamic partic
le -size
distribution would be acceptable.
503Annex 56-C
(30)
d ND ND ND ND
PAGE 1
c 0.06 0.06 0.02 0.02
b
IMPIN0.06 0.06 0.02 0.05
MAXIMUM ATTAINABLE
CONCEaTRATIONS (MG/L)
1.07 1.63 1.31 1.51
a
-
TEST 100 100 100 100
ARCONCEN
TRATION (%)
30 30 30 30
INPUT(PSI)
60 60 60 60
TRIAL TABLE 1 - - - -
30 and 77200 30 and 77200 30 and 77200 30 and 77200
PRELIMINARY AEROSOL GENERATION TRIALS - - -
Only Chamber Only Chamber Only Chamber Only Chamber
EQUIPMENT USED - - -
2.00 mg/L analytical concentration for Trials 1-4. ND = None Detected.
One Multistage 10LONnoseultistage 1ONnosMeultistage 1Oneoseultistage 10L Nose5n2d3Pump Heads 7523ph1erzxfloe
1 2 3 4
SLICLIENT: INL/A, U.S. DEPARTMENT OF STATE aPooNote: Targeting ≥
504 Annex 56-C
(31)
g
ND ND
PAGE 5
f ND ND
e
ND ND
d ND ND
(MG/L)
IMPcNGERS
ND ND
ATTAINABLE CONCENTRATIONS
b
0.13 0.20
a
MAXIMUM 1.65 1.31
a
-
tected.
100 100
TEST
ARCONCEN
TRATION (%)
30 30
(PSI)
TRIAL TABLE 1NPUT AIR
-0 and -0 and
PRELIMINARY AEROSOL GENERATION TRIALS
-nly Chamber -nly Chamber
EQUIPMENT USED
bing size
2.00 mg/L analytical concentration for Trials 5-6. ND = None De
-0 -0
One Mu7llst00r.14ggau1pltes,littS0:irL4LfaysxitCh,lip)ze:i/LluteatiisphNeezfer 1 minute
5 6
SLCLIENT: INL/A, U.S. DEPARTMENT OF STATE aPoNote: Targeting ≥.
505Annex 56-C
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SLI Study No. 3596.11
APPENDIX B
Analytical Chemistry Report
506 Annex 56-C
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SLI Study No. 3596.11
1. SPRAY--BRAVO ANALYSIS
The analytical method for the analysis of the glyphosate component of Sp
ray --Bravo
was validated prior to the analytical chamber concentration analyses performed at
Springborn Labora tories, Inc. This method was utilized to determine the inhalation
chamber concentration during the Acute Nose-Only Inhalation Toxicity Study.
1.1. Experimental System
1.1.1. HPLC System
HPLC Model: Waters
Pump: Waters 600E
Injector: Waters WISP 717
Detector: Waters 2487
Data System: H-P 3396B Integrator
Precolumn: Phenomenex, SecurityGuard, C18, 4.0 x 3.0 mm ID
Column: Phenomenex, Spherex, C18, 5µ, 250 x 4.6 mm ID
Temperature: Ambient
Detection: 500 nm, 0.4000 AUFS
Mobile Phase: A: 0.05 M HCO N2 , 4H 3.6/5% Acetonitrile (ACN);
B: 100% ACN
Gradient: 100% A hold for 6 minutes; linear change to 25% A/75% B
over 1 minute; hold for 5 minutes; linear change to 100%
A over 1 minute; hold at 100% A for 15 minutes.
Flow Rate: 1.0 mL/min
Injection Volume: 10 L
1.1.2. Apparatus
Balance: Mettler AG 245, accuracy of 0.0001 gram
Glassware: Assorted volumetric glassware
Filters: Gelman, glass fiber; Millipore 0.2 µ Nylon- 66; Whatman
Puradisc 25PP 0.45µm
Shaker: Labline, Multi-Wrist Shaker
Oven: Boekel Model 107905
Pipet: Mettler, VoluMate, 200-1000 µL
507Annex 56-C
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SLI Study No. 3596.11
1.1.3. Solutions and Reagents
1.1.3.1. Reagents
Water, Fisher, HPLC Grade, Lot # 024948, 025012
Acetonitrile, Baker, HPLC Grade, Lot # M15811
Methanol, Fisher, HPLC Grade, Lot # 011803, 023006
NBD Chloride, Aldrich, 98%, Lot #12214L1
Hydrochloric Acid, Fisher, ACS Grade, Lot # 012161
Potassium Tetraborate Tetrahydrate: Aldrich, 99%, Lot # 15325D1
Formic Acid, Fisher, Laboratory Grade, Lot # 003630
Ammonium Formate, Fisher, Certified, Lot # 990125
1.1.3.2. Solutions
0.37 M Borate Solution: Prepared by dissolving approximately 11.44 g of
potassium tetraborate tetrahydrate in 100 mL of water. The resulting so
lution
was stable for 6 months under ambient storage conditions.
1.2 N HCl : Prepared by dissolving 10 mL of HCl in 90 mL of water. The
resulting solution was stable for 6 months under ambient storage conditi
ons.
25 mM NBD-Cl: Prepared by dissolving approximately 2.5 g of NBD-Cl in 500
mL of methanol. The resulting solution was stable for 6 months under
ambient storage conditions.
Mobile Phase A: Prepared by dissolving approximately 3.153 g of ammonium
formate in 1900 mL of water. The pH was adjusted to approximately 3.6 w
ith
formic acid. Then added 100 mL of acetonitrile. The resulting solution was
mixed thoroughly, filtered through a 0.2µ Nylon-66 filter and degassed by
helium sparging prior to use. Different volumes were used using the sam
e
ratio of components.
Mobile Phase B: Acetonitrile used 100% as received.
Diluent: All standards and samples were diluted in methanol.
Stock Standard Solution (Impinger Trial, mg/L): For the 2 × 5L trial, prepared
by dissolving 65.8 mg of the Spray Bravo formulation in a 25 mL flask wit
h
diluent. For the 2 × 2L trial, prepared by dissolving 13.4 mg of the Spray
508 Annex 56-C
(35)
SLI Study No. 3596.11
Bravo formulation in a 25 mL flask with diluent. For the 1 × 5L trial, prepared
by dissolving 22.5 mg of the Spray Bravo formulation in a 25 mL flask wit
h
diluent. For the 1 × 1L trial, prepared by dissolving 7.8 mg of the Spray
Bravo formulation in a 200 mL flask with diluent.
Stock Standard Solution (Exposure #1): Prepared by dissolving 13.2 mg of
Spray Bravo formulation in a 25 mL flask with diluent.
Standard Solutions (Impinger Trial): Prepared by serially diluting the stock
standard solution with methanol. The final concentrations of the solutions
were in the range of approximately 0.10 to 0.52 mg/mL (2 min × 5 L); 0.053
to 0.26 mg/mL (2 min × 2 L); 0.09 to 0.45 mg/mL (1 min × 5 L); and 0.0039 to
0.019 mg/mL (1 min × 1 L). The 2 min × 5 L solutions were then further
diluted in diluent at a ratio of 4:10 prior to derivatization, due to the higher
concentration.
Standard Solutions (Exposure #1): Prepared by serially diluting the stock
standard solution with methanol. The final conce ntrations of the solutions
were in the range of approximately 0.26 to 1.3 mg/mL.
Chamber Concentration Solutions (Exposure # 1) : Prepared by passing the
analytical chamber sample through three impingers, each filled with 20 mL
of diluent. The diluent fro m each impinger was collected and derivatized
separately.
Derivatization Procedure: In order to analyze the glyphosate component, a
precolumn derivatization was performed by adding 1.2 mL of the
appropriate control, standard, or sample solution to a label ed scintillation
vial. Both 0.8 mL of the borate solution and 2.4 mL of the NBD- Cl solution
were added to each vial. The vials were then capped and shaken by hand
prior to being heated in an oven at 80° C for 30 minutes. After removal from
the oven, the vials were allowed to cool for 10 minutes followed by the
addition of 0.9 mL of the HCl solution. After the vials were again shaken by
hand, they were allowed to stand for 10 minutes in order for incipient
precipitation to occur. These solutions were th en transferred to injection
vials.
509Annex 56-C
510 Annex 56-C
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SLI Study No. 3596.11
Chemistry Table 1
Standard Curve and Sample Analysis Values for Impinger Trial Work f
5 L×
Theoretical Conc. Analytical Chamber
Sample No. (mg/L) Peak Area Conc. (mg/L)
Std 1A 0.2632 45363 NA
Std 2A 0.5264 108136 NA
Std 3A 0.7896 144205 NA
Std 4A 1.053 198178 NA
Std 5A 1.316 259386 NA
Trial # 1a NA 304141 1.567
Trial # 1b NA 8136 0.06353
Trial # 1c NA 6969 0.05760
Trial # 1d NA ND ND
Correlation coefficient = 0.997; NA = Not applicable; ND = Not Detected.
511Annex 56-C
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SLI Study No. 3596.11
Chemistry Table 2
Standard Curve and Sample Analysis Values for Impinger Trial Work for 2 × 2 L
Theoretical Conc. Analytical Chamber
Sample No. (mg/L) Peak Area Conc. (mg/L)
Std 1B 0.1340 26211 NA
Std 2B 0.2680 54882 NA
Std 3B 0.4020 85616 NA
Std 4B 0.5360 115986 NA
Std 5B 0.6700 131941 NA
Trial # 2a NA 331783 1.625
Trial # 2b NA 13774 0.06202
Trial # 2c NA 12332 0.05493
Trial # 2d NA ND ND
Correlation coefficient = 0.997; NA = Not applicable; ND = Not Detected.
512 Annex 56-C
(39)
SLI Study No. 3596.11
Chemistry Table 3
Standard Curve and Sample Analysis Values for Impinger Trial Work 1 × 5 L
Analytical
Theoretical Conc. Chamber Conc.
Sample No. (mg/L) Peak Area (mg/L)
Std 1C 0.1800 40947 NA
Std 2C 0.3600 86151 NA
Std 3C 0.5400 133858 NA
Std 4C 0.7200 182217 NA
Std 5C 0.9000 250029 NA
Trial # 3a NA 358270 1.309
Trial # 3b NA 19872 0.1243
Trial # 3c NA 21161 0.1288
Trial # 3d NA ND ND
Trial # 4a NA 415221 1.508
Trial # 4b NA 26568 0.1477
Trial # 4c NA 17339 0.1154
Trial # 4d NA ND ND
Correlation coefficient = 0.997; NA = Not Applicable; ND = Not Detected
513Annex 56-C
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SLI Study No. 3596.11
Chemistry Table 4
Standard Curve and Sample Analysis Values for Impinger Trial Work 1 × 1 L
Analytical
Theoretical Conc. Chamber Conc.
Sample No. (mg/L) Peak Area (mg/L)
Std 1D 0.03900 ND NA
Std 2D 0.07800 3520 NA
Std 3D 0.1170 5630 NA
Std 4D 0.1560 6869 NA
Std 5D 0.1950 8931 NA
Trial # 5a NA 74105 1.651
Trial # 5b NA 6043 0.1322
Trial # 5c NA ND ND
Trial # 5d NA ND ND
Trial # 5e NA ND ND
Trial # 5f NA ND ND
Trial # 5g NA ND ND
Trial # 6a NA 58780 1.309
Trial # 6b NA 9271 0.2042
Trial # 6c NA ND ND
Trial # 6d NA ND ND
Trial # 6e NA ND ND
Trial # 6f NA ND ND
Trial # 6g NA ND ND
* Correlation coefficient = 0.995; NA = Not Applicable; ND = Not Detected
514 Annex 56-C
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SLI Study No. 3596.11
APPENDIX C
Individual Aerosol Generation and
Chamber Environmental Data
515Annex 56-C
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SLI Study No. 3596.11
2.40 mg/L Exposure Level
516 Annex 56-C
(43)
SLI Study No. 3596.11
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
CHAMBER ENVIRONMENTAL DATA
EXPOSURE: 2.40 MG/L
TIME TEMPERATURE RELATIVE HUMIDITY OXYGEN CONTENT
(MIN.) (°F) (%) (%)
0 77.0 57.1 21
30 74.9 60.2 21
60 75.1 60.6 21
90 76.0 58.2 21
120 75.6 59.8 21
150 75.6 59.6 21
180 75.6 59.8 21
210 75.9 59.5 21
240 75.6 59.8 21
517Annex 56-C
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SLI Study No. 3596.11
Standard Curve and Sample Analysis Values for Impinger Exposure #1
Analytical
Theoretical Conc. Chamber Conc.
Sample No. (mg/L) Peak Area (mg/L)
Std 1 0.1320 22300 NA
Std 2 0.2640 41117 NA
Std 3 0.3960 74124 NA
Std 4 0.5280 87613 NA
Std 5 0.6600 110814 NA
1A NA ND ND
1B NA ND ND
1C NA ND ND
2A NA 344241 2.032
2B NA 8366 0.04860a
a
2C NA 8105 0.04706
3A NA 324116 1.913
3B NA 11740 0.06852a
a
3C NA 8177 0.04748
4A NA 510006 3.011
4B NA 20840 0.1223a
a
4C NA 7258 0.04206
5A NA 566238 3.343
a
5B NA 8150 0.04732a
5C NA 9333 0.05431
* Correlation coefficient = 0.995; NA = Not Applicable; ND =
ctedte
a
Less than 10%; therefore, not utilized in determining chamber concentration.
518 Annex 56-C
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SLI Study No. 3596.11
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
SAMPLE NO.: A
EXPOSURE: 2.40 MG/L
Effective
Cutoff Filter Weights (mg) Difference Cumulative
Stage Diameter Pre-sample Post-sample Weights % of Total % <ECD
1 10.00 103.3 103.5 0.2 2.6 97.4
2 6.11 102.8 103.6 0.8 10.5 86.8
3 3.70 102.6 104.6 2.0 26.3 60.5
4 2.22 103.2 106.1 2.9 38.2 22.4
5 1.39 102.7 104.0 1.3 17.1 5.3
6 0.79 103.5 103.8 0.3 3.9 1.3
7 0.50 102.9 102.9 0.0 0.0 1.3
Filter - 103.4 103.5 0.1 1.3
Total of Difference Weights: 7.6
Mass Median Aerodynamic Diameter = 3.1 microns
Geometric Standard Deviation = 1.90
Percentage ≤ 4.0 microns =
66 %
519Annex 56-C
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SLI Study No. 3596.11
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
SAMPLE NO.: B
EXPOSURE: 2.40 MG/L
Effective
Cutoff Filter Weights (mg) Difference Cumulative
Stage Diameter Pre-sample Post-sample Weights % of Total % <ECD
1 10.00 103.1 103.2 0.1 1.2 98.8
2 6.11 102.7 103.9 1.2 14.5 84.3
3 3.70 102.4 104.4 2.0 24.1 60.2
4 2.22 102.9 105.8 2.9 34.9 25.3
5 1.39 102.5 103.9 1.4 16.9 8.4
6 0.79 102.8 103.3 0.5 6.0 2.4
7 0.50 103.3 103.3 0.0 0.0 2.4
Filter - 102.9 103.1 0.2 2.4
Total of Difference Weights: 8.3
Mass Median Aerodynamic Diameter = 2.8 microns
Geometric Standard Deviation = 1.93
Percentage ≤4.0 microns = 70 %
520 Annex 56-C
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SLI Study No. 3596.11
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
SAMPLE NO.: C
EXPOSURE: 2.40 MG/L
Effective
Cutoff Filter Weights (mg) Difference Cumulative
Stage Diameter Pre-sample Post-sample Weights % of Total % <ECD
1 10.00 103.4 104.1 0.7 8.3 91.7
2 6.11 102.2 103.5 1.3 15.5 76.2
3 3.70 103.0 105.0 2.0 23.8 52.4
4 2.22 102.5 105.2 2.7 32.1 20.2
5 1.39 101.7 103.1 1.4 16.7 3.6
6 0.79 102.0 102.2 0.2 2.4 1.2
7 0.50 102.0 102.0 0.0 0.0 1.2
Filter - 102.5 102.6 0.1 1.2
Total of Difference Weights: 8.4
Mass Median Aerodynamic Diameter = 3.7 microns
Geometric Standard Deviation = 2.06
Percentage ≤4.0 microns = 54 %
521Annex 56-C
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SLI Study No. 3596.11
AN ACUTE NOSE-ONLY INHALATION TOXICITY STUDY IN RATS
AERODYNAMIC PARTICLE SIZE DATA
EXPOSURE: 2.40 MG/L
Effective Cutoff Cumulative % less than indicated size
Stage Diameter Sample A Sample B Sample C
1 10.00 97.4 98.8 91.7
2 6.11 86.8 84.3 76.2
3 3.70 60.5 60.2 52.4
4 2.22 22.4 25.3 20.2
5 1.39 5.3 8.4 3.6
6 0.79 1.3 2.4 1.2
7 0.50 1.3 2.4 1.2
Mean
Mass Median Aerodynamic Diameter 3.1 2.8 3.7 3.2
Geometric Standard Deviation 1.90 1.93 2.06 1.96
Percentage ≤ 4.0 microns 66 70 54 63
522 Annex 56-C
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SLI Study No. 3596.11
APPENDIX D
SLI Personnel Responsibilities
523Annex 56-C
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SLI Study No. 3596.11
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute
Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing
Director Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Rusty E. Rush, M.S., LAT, DABT Director, Neurotoxicity and Transgenics
Jason W. Smedley, B.S. Assistant Toxicologist
Pamela S. Smith, ALAT Supervisor of Acute Toxicology
Kevin V. Weitzel, A.S. Primary Technician/Inhalation Team
Leader
Delores P. Knippen Supervisor of Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor of Gross and Fetal
Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
J. Dale Thurman, D.V.M., M.S., DACVP Senior Director, Pathology
Kathy M. Gasser Supervisor of Archives
524 Annex 56-C
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS WITH SPRAY--BRAVO
•MODIFIED BUEHLER DESIGN•
FINAL REPORT
OPPTS Guidelines
870.2600
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
October 4, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.14
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 43
525Annex 56-C
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SLI Study No. 3596.14
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date:
Title Signature
526 Annex 56-C
527Annex 56-C
528 Annex 56-C
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SLI Study No. 3596.14
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS..........................2 ..
2. COMPLIANCE STATEMENT.........................................................................3 .......
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS.......................................................................................
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION .............................................................................................
8. MATERIALS AND METHODS........................................................................8 ......
9. EXPERIMENTAL PROCEDURES.....................................................................11
10. ANALYSIS OF DATA.........................................................................................13
11. MAINTENANCE OF RAW DATA AND RECORDS......................................13
12. RESULTS.............................................................................................................13
13. CONCLUSION.....................................................................................................14
14. REPORT REVIEW..............................................................................................14
15. REFERENCES.....................................................................................................15
529Annex 56-C
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SLI Study No. 3596.14
5. LIST OF TABLES AND APPENDICES
Tables
1. Individual Induction Data (Spray--Bravo)..........................................6..1
2. Individual Challenge Data (Spray--Bravo) ...........................................1
Appendices
A. Topical Range-Finding Study...............................................................1
B. Dermal Grading System.......................................................................2
C. Individual Clinical Observations...........................................................2
D. Individual Body Weight Data................................................................2
E. HCA Historical Control Data.................................................................3..2
F. SLI Personnel Responsibilities............................................................4
530 Annex 56-C
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SLI Study No. 3596.14
6. SUMMARY
The dermal sensitization potential of Spray --Bravo was evaluated in Ha rtley-
derived albino guinea pigs. Ten male and ten female guinea pigs were topically
treated with 100% Spray --Bravo, once per week, for three consecutive weeks.
Following a two -week rest period, a challenge was performed whereby the
twenty test and ten p reviously untreated (naive) challenge control guinea pigs
were topically treated with 100% Spray --Bravo. Challenge responses in the test
animals were compared with those of the challenge control animals.
6.1. Spray--Bravo
Following challenge with 100% Spray --Bravo, dermal reactions in the test and
challenge control animals were limited to scores of 0. Group mean dermal
scores were noted to be the same in the test animals as compared with the
challenge control animals.
6.2. HCA
Using -Hexylcinnamaldehyde (HCA) as a positive control, Springborn
Laboratories, Inc., Spencerville, Ohio, has completed a study during the
past six
months which provided historical control data for contact sensitization
to this
agent utilizing the test system described herein (Modified Bu ehler Design).
Following induction at 5% w/v HCA in ethanol and challenge at levels of 2.5%
and 1% w/v HCA in acetone, a contact sensitization response was observed,
thereby demonstrating the susceptibility of the test system to this sens
itizing
agent.
6.3. Conclusion
Based on the results of this study, Spray--Bravo is not considered to be a contact
sensitizer in guinea pigs. The results of the HCA historical control study
demonstrated that a valid test was performed and indicated that the test
design
would detect potential contact sensitizers.
531Annex 56-C
(8)
SLI Study No. 3596.14
7. INTRODUCTION
This study was performed to assess the dermal sensitization potential (
delayed
contact hypersensitivity) of Spray-- Bravo in Hartley -derived albino guinea pigs
when administered by multiple topical applicati ons. This study was intended to
provide information on the potential health hazards of the test article w
ith respect
to dermal exposure. Data from this study may serve as a basis for class
ification
and/or labeling of the test article. This study was performed in accordance with
the US EPA, Health Effects Test Guidelines, OPPTS 870.2600, Skin
Sensitization, August 1998. This study was performed at Springborn
Laboratories, Inc., 553 North Broadway, Spencerville, Ohio. The protocol
was
signed by the Study Director on April 26, 2002 (GLP initiation date). The in- life
phase of the main sensitization study was initiated with test article adm
inistration
on July 8, 2002 (day 0) and concluded with final scoring on August 7, 2002.
Prior to initiation of the main sensitization study, a topical range-finding study was
conducted in guinea pigs to aid in the selection of dosage levels. The in- life
phase of the range- finding study was initiated with test article administration on
July 1, 2002, and concluded on July 3, 2002. The experimental methods and
results of the range-finding study are included in Appendix A.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows
:
Sponsor’s Assigned Physical Receipt Expiration
ID SLI ID Description Date Date
a
Spray—Bravo S02.002.3596 Cloudy pale 05/31/02 None
amber liquid Provided
Ingredients
Herbicide: Roundup SL None
Lot Nos.: 4010/4212 Provided
4397/4272
4333/4340
4379/4076
4397/4333
Surfactant: Cosmo Flux -411F None
Lot No.: Unknown provided
aSample pooled at SLI from five different mixes of Spray --Bravo (top/middle/bottom).
bIngredients used in the five Spray --Bravo mixes that were prepared by the Sponsor.
532 Annex 56-C
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SLI Study No. 3596.14
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength, purity, composition,
stability and method of synthesis of the test material according to 40 CFR
160.105, 40 CFR 792.105. Springborn Laboratories, Inc., analyzed the test
article for the glyphosate (a.e.) which is presented in SLI Study No.
3596.8.
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture sample
(top/middle/bottom, maintained separately for a total of fifteen 1 mL samples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The remaining test article was returned to the Sponsor following completion of all
studies with the test article.
8.4. Method of Test Article Preparation
The test article was utilized at 100% (induction and challenge). The test article
was dispensed fresh on each day of dosing.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Young adult, Hartley-derived albino guinea pigs were received from Hilltop Lab
Animals, Inc., Scottdale, PA. Upon receipt, plastic ear tags displaying
unique
identification numbers were used to individually identify the animals.
age cards
displaying at least the study number, an imal number and sex were affixed to
each cage. The animals were housed individually in suspended stainless steel
cages. All housing and care were based on the standards recommended by
the
Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 64- 74F (18-
23°C) and 34- 72%, respectively. Environmental control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10- 15 air changes/hour. The room
temperature and relative humidity were recorded a minimum of once daily.
533Annex 56-C
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SLI Study No. 3596.14
8.5.3. Food
PMI Certified Guinea Pig Chow #5026 (Purina Mills, Inc.) was provided ad libitum
to the animals throughout the study. The lot number and expiration date
of each
batch of diet used during the study were recorded. The feed was analyzed and
certified by the supplier for nutritional components and environmental
contaminants. Dietary limitations for various environmental contaminants
,
including heavy metals, pesticides, polychlorinated biphenyls and total
aflatoxin
are set by the manufacturer. Within these limits, contaminants which may have
been present were no t expected to compromise the purpose of this study.
Results of the dietary analyses (Certificates of Analysis) are provided by the
manufacturer for each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was av ailable ad libitum
throughout the study. The purified water was supplied by an automatic w
atering
system. Monitoring of the drinking water for contaminants is conducted
by SLI
and the records are available for inspection. Within generally accepted limit s,
contaminants which may have been present were not expected to compromise
the purpose of this study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with plastic ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The
animals
were observed daily for overt physical or behavioral abn ormalities, general
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were arbitrarily selected from healthy s
tock
animals to avoid potential bias. All animals received a detailed pretest
observation prior to dosing. Onl y healthy animals were chosen for study use.
Females were nulliparous and nonpregnant. The male animals were
approximately 7 weeks of age and weighed 410- 483 g on the day prior to
Induction I dosing. The female animals were approximately 9 weeks of age and
weighed 364-453 g on the day prior to Induction 1 dosing.
534 Annex 56-C
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SLI Study No. 3596.14
9. EXPERIMENTAL PROCEDURES
9.1. Study Design
This study consisted of a topical range- finding group, a test group and a
challenge control group [2]. A rechallenge control group was maintained on this
study; however, the rechallenge procedure was not required since the chall
enge
results were definitive.
9.2. Sensitization Study
9.2.1. Preliminary Procedures
On the day prior to each dose administration, the guinea pigs had the hair
removed with a small animal clipper. Care was taken to avoid abrading the skin.
9.2.2. Dosing
A dose of 0.3 mL of the test article was placed on a 25 mm Hilltop chamber
backed by adhesive tape (occlusive patch). The chambers were then app
lied to
the clipped surface as quickly as possible.
Following chamber application, the trunk of the animal was wrapped with elastic
wrap which was secured with adhesive tape to prevent removal of the chamb
er
and the animal was returned to its cage.
9.2.2.1. Induction
On the day prior to the first induction dose administration (day -1), all test and
control animals were weighed and the hair was removed from the left side
of the
test animals. On the day following clipping (day 0), chambers were applied as
follows:
Induction Concentration Test Site No. of Animals
Group Material No. (%) No. Male Female
Test Spray-- 1 100a 1 10 10
Bravo 2 100a 1
3 100a 1
a
Pooled test article.
The induction procedure was repeated on study day 7 and on study day 14 so
that a total of three consecutive induction exposures were made to the test
animals.
535Annex 56-C
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SLI Study No. 3596.14
9.2.2.2. Challenge
On the day prior to challenge dose administration, the test and challeng
e control
animals were weighed and the hair was removed from the right side of the
animals. On the day following clipping ( day 28 ), chambers were applied as
follows:
Concentration Test Site No. of Animals
Group Material (%) No. Male Female
a
Test Spray--Bravo 100 2 10 10
a
Challenge Control Spray--Bravo 100 2 5 5
a
Pooled test article.
9.2.3. Test Article Removal
Approximately six hours after chamber application, the binding materials were
removed. The test sites were wiped with gauze moistened in deionized wa
ter,
followed by dry gauze, to remove test article residue. The animals were
then
returned to their cages.
9.2.4. Dermal Observations
The test sites were graded for irritation at approximately 24 and 48 hour
s
following chamber application (induction) or chamber removal (challenge) using
the Dermal Grading System presented in Appendix B.
9.2.5. Clinical Observations
Any unusual observations and mortality were recorded. The animals were
observed for general health/mortality twice daily, once in the morning and once in
the afternoon.
9.2.6. Body Weights
Individual body weights were obtained for all sensitization study animals on the
day prior to the first induction (day -1) and for the appropriate test and challenge
control animals on the day prior to challenge dosing.
9.2.7. Scheduled Euthanasia
All sensitization study animals were euthanized by carbon dioxide inhalation
following each animal's final scoring interval. Gross necropsy examinations were
not required for these animals.
536 Annex 56-C
(13)
SLI Study No. 3596.14
9.3. Protocol Deviations
On one occasion each, the animal room temperature and relative humidity
ranges [64-74F (17-23°C) and 34-72%] exceeded the preferred ranges [63-73°F
(17-23°C) and 30-70%, respectively] during this study. These occurrences were
considered to have had no adverse effect on the outcome of this study.
10. ANALYSIS OF DATA
The sensitization potential of the test article was based on the dermal responses
observed on the test and control animals at challenge. Generally, dermal scores
of 1 in the test animals with scores of 0 to noted in the controls are considered
indicative of sensitization. Dermal scores of 1 in both the test and control
animals are generally considered equivocal unless a higher dermal response (
grade 2) is noted in the test animals. Group mean dermal scores were
calculated for challenge.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded record
ere
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
12. RESULTS
12.1. Topical Range-Finding Study
Individual Topical Range-Finding Data: Appendix A
The results of the range-finding study indicated that a test article concentration of
100% was considered appropriate for induction and challenge since it was the
highest possible concentration which was nonirritating.
12.2. Sensitization Study
Individual Data: Tables 1-2
Following challenge with 100% Spray --Bravo, dermal reactions in the test and
challenge control animals were limited to scores of 0. Group mean dermal
scores were noted to be the same in the test anima ls as compared with the
challenge control animals.
537Annex 56-C
538 Annex 56-C
(15)
SLI Study No. 3596.14
15. REFERENCES
1. Guide for the Care and Use of Laboratory Animals, DHHS Publication No.
(NIH) 96-03, 1996.
2. E. V. Buehler, Delayed Contact Hypersensitivity in the Guinea Pig, Arch.
Dermat., 91 :171-177, 1965.
539Annex 56-C
(16)
PAGE 1 48 Hr 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
a
100%
24 Hr 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Induction 3 Dermal Scores
48 Hr 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
a
100%
IT
) 24 Hr0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Induction 2 Dermal Scores
BRAVO
TABLE 1
(PRAY--
48 Hr 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
a
INDIVIDUAL INDUCTION DATA
100%
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
Induction 1 Dermal Scores 0 0 0 0 0 0 0 0 0 0 0 0 0 0
./
Sex
Animal NoG87G8748749/59/53/M5/46/47/50/M/F7/F8/F9/F0/F1/F2/F3/F4/F5/F
Groupest
Nate: See Appendix B for definition of codes.
SLI STUDY NO.: 3596.14DEPARTMENT OF STATE
540 Annex 56-C
(17)
PAGE 1
48 Hr
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0.0
a
100%
Dermal Scores
BRAVO)
24 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0.0
TABLE 2
(SPRAY--
INDIVIDUAL CHALLENGE DATA
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
Sex
Mean
Animal No./87M7M78787/57G7M7M0/M88888G8F8F8F88888/4F5/F
Test
Group
SLI STUDY NO.: 3596.14DEPARTMENT OF STATE Nates: See Appendix B for definition of codes.
541Annex 56-C
(18)
PAGE 2
48 Hr
0 0 0 0 0 0 0 0 0 0.0
a
100%
Dermal Scores
BRAVO)
24 0 0 0 0 0 0 0 0 0 0 0.0
TABLE 2
(SPRAY--
INDIVIDUAL CHALLENGE DATA
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
TATE /
Sex Mean
G87G8787/57M7/7/M/G8F8F8/F7/F
Animal No.
Appendix B for definition of codes.
Group
Challenge Control
SLI STUDY NO.: 3596.14DEPARTMENT OF S Nates: Seeest article.
542 Annex 56-C
(19)
SLI Study No. 3596.14
APPENDIX A
Topical Range-Finding Study
543Annex 56-C
(20)
SLI Study No. 3596.14
1. TOPICAL RANGE-FINDING STUDY
This appendix provides the experimental procedures and results of a topi
cal
range-finding study in guinea pigs with Spray--Bravo. The procedures for animal
husbandry were similar to those described for the main sensitization stud
y
animals. The male animals were approximately 8 weeks of age and weighed
407-497 g; the female animals were approximately 10 weeks of age and weighed
479-498 g on the day prior to dosing.
1.1. Method of Test Article Preparation
The test article was utilized at 100% and at 75%, 50% and 25% w/v in deionized
for the range-finding study. The test article was prepared and dispensed fresh
on the day of dosing. Th e dosing preparations were stirred continuously during
dosing.
1.2. Dosing
On the day prior to dose administration, four topical range -finding guinea pigs
were weighed and the hair removed from the right and left side of the ani
mals
with a small animal clipper. Care was taken to avoid abrading the skin during
clipping procedures.
On the following day, four concentrations of the test article were prepar
ed and
each concentration was applied to the clipped area of each topical range
- finding
animal as indicated below:
Concentration Test Site Amount
Group Material (%) No. Applied Patch Design
Topical Spray-- 100 1 0.3 mL 25 mm Hilltop Chamber
Range- Bravo
Finding 75c 2 0.3 mL 25 mm Hilltop Chamber
c
50 3 0.3 mL 25 mm Hilltop Chamber
25c 4 0.3 mL 25 mm Hilltop Chamber
Occlusive patch.
Pooled test article.
The vehicle was deionized water.
The chambers were applied to the clipped surface as quickly as possible.
The
trunk of the animal was wrapped with elastic wrap which was secured with
adhesive tape to prevent removal of the chambers and the animal was returned
to its cage.
544 Annex 56-C
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SLI Study No. 3596.14
Approximately six hours after chamber application, the binding materials
were
removed. The test sites were then wiped with gauze moistened in deioniz
ed
water, followed by dry g auze, to remove test article residue and the animals
returned to their cages.
1.3. Dermal Observations
The test sites of the topical range- finding animals were graded for irritation at
approximately 24 and 48 hours following chamber application using the Der
mal
Grading System in Appendix B.
1.4. Clinical Observations
Any unusual observations and mortality were recorded. The topical range- finding
animals were observed for general health/mortality twice daily, once in t
he
morning and once in the afternoon.
1.5. Body Weights
Individual body weights were obtained for the topical range- finding animals on
the day prior to dosing.
1.6. Scheduled Euthanasia
Following the 48- hour scoring interval, all topical range- finding animals were
euthanized by carbon dioxide inhalation. Gross necropsy examinations were not
required for these animals.
1.7. Results
The results of the range-finding study indicated that a test article concentration of
100% was considered appropriate for induction and challenge since it was the
highest possible concentration which was nonirritating.
545Annex 56-C
(22)
48 Hr
PAGE 1
a,b 0 0 0 0
25%
24 Hr
0 0 0 0
48 Hr
a,b 0 0 0 0
50%
24 Hr
0 0 0 0
-indi48 Hrrmal Scores
a,b 0 0 0 0
Ra75%
-INBRAVO)ATA
24 Hr
0 0 0 0
(SPRAY--
a 48 Hr
0 0 0 0
TOPICAL RANGE
100%
24 Hr
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
407 497 479 498
G8349/MG8353/MG8506/FG8507/F
AnBody Weight (g)
Finding
-
Group
Range
SLCLIENT: INL/A, U.S. DEPARTMENT OF STATE aPbTolNote: See Appendix B for definition of codes.
546 Annex 56-C
(23)
SLI Study No. 3596.14
APPENDIX B
Dermal Grading System
547Annex 56-C
(24)
SLI Study No. 3596.14
DERMAL GRADING SYSTEM
ERYTHEMA AND EDEMA OBSERVATIONS
OBSERVATION DEFINITION CODE
Erythema – Grade 0 No reaction 0
Erythema – Grade ± Slight patchy erythema ±
Erythema – Grade 1 Slight, but confluent or moderate patchy erythema 1
Erythema – Grade 2 Moderate, confluent erythema 2
Erythema – Grade 3 Severe erythema with or without edema 3
M – 3
Maximized Grade 3 Notable dermal lesions
(see below)
Edema – Grade 1 Very slight edema (barely perceptible) ED-1
Edema – Grade 2 Slight edema (edges of area well defined by defi nite ED-2
raising)
Edema – Grade 3 Moderate edema (raised approximately 1 millimeter) ED-3
Severe edema (raised more than 1 millimeter and
Edema – Grade 4 ED-4
extends beyond the area of exposure)
An erythema code was assigned to each test site. An edema code was assigned only if edema
was present at the test site. If notable dermal lesion(s) (> grade 1
) were present, then the
“Maximized Grade 3” was assigned to the test site in place of the
erythema score and the type
ES-2
of the notable dermal lesion(s) w as noted (e.g., M -3
548 Annex 56-C
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SLI Study No. 3596.14
DERMAL GRADING SYSTEM
NOTABLE DERMAL LESIONS
OBSERVATION CODE DEFINITION
Eschar – Grade 1 ES-1 Focal and/or pinpoint areas up to 10% of test site.
Eschar – Grade 2 ES-2 > 10% < 25% of test site.
Eschar – Grade 3 ES-3 > 25% < 50% of test site.
Eschar – Grade 4 ES-4 > 50% of test site.
Blanching – Grade 1 BLA-1 Focal and/or pinpoint areas up to 10% of test site.
Blanching – Grade 2 BLA-2 > 10% < 25% of test site.
Blanching – Grade 3 BLA-3 > 25% < 50% of test site.
Blanching – Grade 4 BLA-4 > 50% of test site.
Ulceration – Grade 1 U-1 Focal and/or pinpoint areas up to 10% of test site.
Ulceration – Grade 2 U-2 > 10% < 25% of test site.
Ulceration – Grade 3 U-3 > 25% < 50% of test site.
Ulceration – Grade 4 U-4 > 50% of test site.
Necrosis – Grade 1 NEC-1 Focal and/or pinpoint areas up to 10% of test site (note
(color) color of necrosis).
Necrosis – Grade 2 NEC-2 > 10% < 25% of test site (Note color of necrosis).
(color)
Necrosis – Grade 3 NEC-3 > 25% < 50% of test site (Note color of necrosis).
(color)
Necrosis – Grade 4 NEC-4 > 50% of test site (Note color of necrosis).
(color)
549Annex 56-C
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SLI Study No. 3596.14
DERMAL GRADING SYSTEM
ADDITIONAL DERMAL FINDINGS
OBSERVATION DEFINITION CODE
Desquamation Characterized by scaling or flaki ng of dermal tissue or DES
without denuded areas.
Characterized by cracking of the skin with or without
Fissuring moist exudate. Fissuring should be checked prior to FIS
removing the animal from the cage and manipulating the
test site.
The process by which areas of eschar flake off the test
Eschar Exfoliation EXF
site.
Test Site Staining Skin located at test site appears to be discolored, TSS
possibly due to test article (note color of staining). (color)
The erythema extends beyond the test site. Note: A
Erythema Extends
Beyond the Test Site study director should be contacted for erythema ERB
extending beyond the test site.
Characterized by pale area(s) (almost a burn -like
appearance) in the test site. However, erythema may
still be observed through the pale area. Note: This
observation may affect the overall erythema score of the
test site. This observation may progress to other
Superficial Lightening observations resulting in notable dermal lesions, but SL --
itself will not be considered a notable dermal lesion that
will result in a dermal score to be maximized since it
does not result in any in-depth injury. To be coded
using an area designation (see below).
Superficial Lightening - Focal and/or pinpoint areas up to 10% of the test site SL-1
Grade 1
Superficial Lightening -
Grade 2 > 10% < 25% of test site SL-2
Superficial Lightening - > 25% < 50% of test site SL-3
Grade 3
Superficial Lightening -
Grade 4 > 50% of test site SL-4
Noticeable irritation outside of test site probably due to
Dermal Irritation - the binding tape material. This notation will only be
made for reactions greater than what are normally IT
Outside of the Test Site observed from tape removal which do not interfere with
the scoring of the test site.
550 Annex 56-C
(27)
SLI Study No. 3596.14
APPENDIX C
Individual Clinical Observations
551Annex 56-C
(28)
PAGE 1
DINGS) - -
(POSITIVE FIN
INDIVIDUAL CLINICAL OBSERVATIONS
CliThinThin Appearance: Days 6
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
G8837F
G8836/F
Animal No./Sex
GroTest
SLI STUDY NO.: 3596.14DEPARTMENT OF STATE
552 Annex 56-C
(29)
SLI Study No. 3596.14
APPENDIX D
Individual Body Weight Data
553Annex 56-C
(30)
PAGE 1
536716567691676865716575152515059452625157632
Day 27
1
-
410484545479454645483414140383841636423639453
Day
INDIVIDUAL BODY WEIGHT DATA
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
G874G8G8G87G8G8G8G87G8750/M/78G8F8F88888/G8F8/4F5/F
Animal No./Sex
Groupst
SLI STUDY NO.: 3596.14DEPARTMENT OF STATE
554 Annex 56-C
(31)
PAGE 2
------ ------ --
62968606656925453252512507 -- ----
Day 27
Body Weights
1
-
42745833454573840737384370 446 4574446321383736469370
Day
INDIVIDUAL BODY WEIGHT DATA
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
/F
G8751/M2/M7/87M7/MG88/FGF86FG8760/M1/M/M3/M/M/F9/F/F/F3
Animal No./Sex
a
Group
Challengel Control
Rechallenge
SLI STUDY NO.: 3596.14DEPARTMENT OF STATE
555Annex 56-C
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SLI Study No. 3596.14
APPENDIX E
HCA Historical Control Data
556 Annex 56-C
(33)
SLI Study No. 3596.14
SPRINGBORN LABORATORIES, INC.
MODIFIED BUEHLER HISTORICAL CONTROL DATA
USING -HEXYLCINNAMALDEHYDE
(SLI Study No. 999.171)
1. OBJECTIVE
This study was performed to assess the dermal sensitization potential of -
Hexylcinnamaldehyde (HCA) when administered by multiple topical applications.
This study may be used to provide information on the ability of the test
system to
detect potential contact sensitizers and to update the historical posit
e control of
the testing facility. The protocol was signed by the Study Director on
February 6, 2002 (GLP initiation date). The in -life phase of the study was
initiated with test article administration on March 13, 2002, and conclud
ed with
final scoring on April 12, 2002.
2. TEST ARTICLE
The test article was received from the manufacturer, TCI America, and id
entified
as follows:
SLI Assigned
Supplier’s Assigned Physical Receipt Expiration
ID SLI ID Description Date Date
HCA S01.008.N Clear yellow 08/21/01 08/21/03
Lot No.: GF01 liquid
The bulk compound was stored desiccated, protected from light, at room
temperature. The manufacturer provided a Certificate of Analysis for the test
article which is presented as Attachment 1 of this Appendix.
The HCA was mixed with etha nol or acetone to produce the appropriate
concentrations for dose administration. For the sensitization study, the
test
article concentrations utilized were 5% w/v in ethanol (induction) and 1% and
2.5% w/v in acetone (challenge).
557Annex 56-C
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SLI Study No. 3596.14
3. EXPERIMENTAL PROCEDURES [1]
Young adult Hartley-derived albino guinea pigs were received on March 7, 2002,
from Hilltop Lab Animals, Inc., Scottdale, PA. The guinea pigs were uniquely
identified by ear tag, individually housed in suspended stainless steel
cages and
received Purina Certified Guinea Pig Chow #5026 and water purified by reverse
osmosis ad libitum. The animals were acclimated for a minimum of 5 days
prior
to experimental initiation. The male guinea pigs were approximately 7 weeks of
age and weighed 370-463 g; the female guinea pigs were approximately 8 weeks
of age and weighed 336-396 g on the day prior to Induction I dosing.
On the day prior to the first induction dose administration (day -1), the hair was
removed from the left side of the twenty test animals. On the following day, 0.3
mL of 5% w/v HCA in ethanol was placed on a Hilltop chamber and applied to the
clipped area of each animal=s back. The trunk of each animal was wrapped with
elastic wrap which was secured with adhesive tape to prevent removal of the
chamber. Approximately six hours after chamber application, the binding
materials were removed. The test sites were wiped with gauze moistened w
ith
deionized water, followed by dry gauze, to remove test article residue. The test
sites were graded f or irritation at approximately 24 and 48 hours following
chamber application using the Dermal Grading System. The induction proce
dure
was repeated on study day 7 and on study day 14 so that a total of three
induction exposures were made to the animals.
On the day prior to challenge dose administration, the hair was removed fr
om the
right side of the twenty test and ten challenge control animals. On the
following
day (day 28), 0.3 mL of 1% and 2.5% w/v HCA in acetone was placed on a 25
mm Hilltop chamber and applied to the clipped area of each animal =s back.
Wrapping, unwrapping and rinsing procedures were the same as those utili
zed
for the induction phase. The test sites were graded for irritation at approximately
24 and 48 hours following chamber removal.
Any unusual observations and/or mortality were recorded. Body weights we
re
recorded for the test, challenge control and rechallenge control animals on the
day prior to first induction (day -1) and for the test and challenge control animals
on the d ay prior to challenge dosing. All sensitization study animals were
euthanized by carbon dioxide inhalation following each animal's final sco
ring
interval. Gross necropsy examinations were not required for these animal
s.
Note: The temperature and rel ative humidity of the animal room [64- 75°F (18-
24°C)] exceeded the preferred ranges [63- 73°F (17-23°C) and 30- 70%] during
558 Annex 56-C
(35)
SLI Study No. 3596.14
this study. These occurrences were considered to have had no adverse eff
ect
on the outcome of this study.
4. RESULTS
Individual Data: Tables 1-2
Following challenge with 2.5% w/v HCA in acetone, dermal scores of 1 were
noted in 8/20 test animals at the 24- hour scoring interval. At the 48-hour scoring
interval, dermal scores of 1 were noted in 4/20 test animals. Dermal re
ctions in
the remaining test and challenge control animals were limited to scores of 0 to .
Group mean dermal scores were noted to be higher in the test animals as
compared with the challenge control animals.
Following challenge with 1% w/v HCA in acetone, dermal scores of 1 were n
oted
in 5/20 test animals at the 24- hour scoring interval. At the 48- hour scoring
interval, dermal scores of 1 were noted in 2/20 test animals. Dermal re
ctions in
the remaining test and challenge control animals were limited to scores
f 0 to .
Group mean dermal scores were noted to be higher in the test anima ls as
compared with the challenge control animals.
5. CONCLUSION
The results of this -Hexylcinnamaldehyde positive control study demonstrated
that a valid test was performed and indicated that the test design would
detect
potential contact sensitizers. Based on the results of this study, -
Hexylcinnamaldehyde is considered to be a contact sensitizer in guinea p
igs.
6. REFERENCE
1. E.V. Buehler, Occlusive Patch Method for Skin Sensitization in Guinea Pigs:
The Buehler Method, Fd. Chem. Toxic., Vol. 32, No. 2, pp. 97-101, 1994.
559Annex 56-C
(36)
SLI Study No. 3596.14
PAGE 1
- (BK), DES
-2, DES
48-1, DES -1, D-1, DES -1,-1S, DE-1, DES -1,-1S,-1S, DES
-1, DES -1, DES
-1, BLA1,EBC1,A-2, ESS -2, ES
-2, B-L-1S, B-1, BLAED -1,-1, BL-1A,-1S, BLADE -1, BL-2A, BL-2A, BL-1A, SL-1, DES
ED ED ED - ED - - ED ED ED ED ED - DESDESED ED ED ED ED
2 2 2 M 2 M M 2 2 1 1 1 M ± ± 2 2 2 2 1
a
5%
-1, DES
GS
Induction-1, DESal Scores -3, DES -1, DES DES
-2 (BK), BLA
-1, SL -1, DE-1, DES -1, SL-1, -1, SL-1, ES -1,-1S, DES
24 Hr -1, DES -4,-1SESDIT
-2, BLA2,E-2C, BLA-2, SL-1, DES
-2, B-L-1S, B-2, BLAED -2,-2, BL-2A,-2S, BL-2A, BL-1A, DES, IT-2, BL-2A, BL-2A, SL-2, SL-2, DES
ED ED ED - ED - - ED ED ED ED ED ED ED DES,T ED ED ED ED
2 2 2 M 2 M M 2 2 2 2 2 2 1 ± 2 2 2 2 2
-1, DES-1, DES -1, DES
TABLE 1
48 Hr -1, DES -1, BLA-1, BLA -1, BLA
BLA-1,SEDSE,SEBLA1,A1S,DDEDSESED BLA-1SESDESDESDESDES ED DESDES
± ± ± 1 ± ± ± ± ± 1 ± ± ± ± ± 0 ± ± ± 0
-EXYLCINNaMALDEHYDE)
IN(IVIDUAL I5%UCTION DATA
-1, DES -1, D--1S, DE-1,-1S, DES -1, DES
A DERMAL SENSITIZATION STUDY IN GUINEA PI
Induction 1 Dermal Scores-1A, BL-1A-1S, BL-1, D-ETS, IT-1, DES-1, BL-1A, DES, IT
ED ED ED ED ED ED ED ED ED ED ED ED DES,TIDDES,ES,T ED DESIT
1 1 ± 2 ± 1 1 1 1 2 ± 1 ± 1 ± ± 1 1 ± 0
Sex
G57G57MG88/89/950M91/927M93/94/955/96/M48F95/96/957F98/999F00/01/052/03/F
Animal No./
Test
Group
The vehicle was ethanol.
a Notes: See Appendix B for definition of codes. BK = black.
SLI HISTORICAL CONTROL
560 Annex 56-C
SLI Study No. 3596.14 (37)
PAGE 2
-2 -1 -1
-1 -1, SL-1, SL -1, SL
-1 -4 -1 -2, DES -1 -4 -2 -4 -4
-1 -2, BL-1A, SL-1, SL--2S, SL-1, BL-1A,-2, SL-1 -2, SL-1, SL-1, SL-1, SL-1, BLA
48ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED
2 2 2 2 2 2 2 2 2 2 1 1 2 1 ± 2 2 2 2 1
a
5%
Induction 3 Dermal Scores
TABLE 1
-1 -1, DES
-4, DE-1, DES-2,L2, DES DES -1, DES, I-4, DES4S,-4S, DES
SL
-EXYLCINNAM24 HrYDE)L-2-2, SL-2S, SL-2S, SL-2, S--1S,-2S, SL-1, DE-2, SL-2, SL-2, SL-1, BLA
ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED ED
IND(IVIDUAL INDUCTION DATA 2 2 2 2 2 2 2 1 1 2 1 ± 2 2 2 2 1
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS
Sex
G58G948955/96/978958F99/009051F02/03/F
Animal No./7G887M89/90/917M92/93/947M95/96/M
Group
Test aTheNote: See Appendix B for definition of codes.
SLI HISTORICAL CONTROL
561Annex 56-C
SLI Study No. 3596.14 (38)
IT IT IT IT
± ± 0 1 ± 0 ± ± 0 ± 0 ± ± 0 0 1 0 0 0 0 0.3
PAGE 1
48 Hr
a
1%
IT IT IT IT IT IT
1 ± ± 1 ± ± ± 1 ± ± ± 1 ± ± 0 1 ± ± ± ± 0.6
24 Hr
Dermal S±o±es0 1 1 0 ± 1 ± ± 0 ± ± 0 ± 1 0 0 ± ±
0.5
48 Hr
a
2.5%
TABLE 2
-1
I1 ± ±ED 1 ± ± 1 1I± ± 1 1 ± ± 1 I± ± ± ± 0.7
1
-EXYLCINNAMALDEHYDE)
24 Hr
INDIVIDUAL CHALLENGE DATA
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS See Appendix B for definition of codes.
Sex
Mean
Animal No./5G5790/M G5794G5G5796/M895/F897/F899/F9G5G5903/F
Groupst
For the purpose of calculation, ± = 0.5.
The vehicle was acetone.
SLI HISTORICAL CONTROL a Notes:
562 Annex 56-C
SLI Study No. 3596.14 (39)
0.1
PAGE 2
IT IT
48 Hr0 ± 0 0 0 0 0 0 0
a
1
0.1
IT0I0IT± 0I0 I0 0 0T 0I0
24 Hr
Dermal Scores 0.0
48 Hr0 0 0 0 0 0 0 0I0
GE DATA
a
2.5%
TABLE 2
0.0
HEXYLCINNAMALDEHYDE)
24 Hr0 0 0I0 I0 0 0 0 I0
INDIVIDUAL CHALLEN
A DERMAL SENSITIZATION STUDY IN GUINEA PIGS See Appendix B for definition of codes.
Sex Mean
G5797/M G5801/M04/F G5908/F/F
Animal No./
Group
For the purpose of calculation, ± = 0.5.
The vehicle was acetone.
SLI HISTORICAL CONTROLllenge a Notes:
563Annex 56-C
(40)
SLI Study No. 3596.14
ATTACHMENT 1
Certificate of Analysis
(Provided by the Manufacturer)
564 Annex 56-C
SLI StudyNoo.3596.147
Doow StudyNoo.0210090 (41)
565Annex 56-C
(42)
SLI Study No. 3596.14
APPENDIX F
SLI Personnel Responsibilities
566 Annex 56-C
(43)
SLI Study No. 3596.14
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute
Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Associate
Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing
Director Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Jason W. Smedley, B.S. Assistant Toxicologist
Pamela S. Smith, ALAT Primary Technician/Supervisor of
Acute Toxicology
Delores P. Knippen Supervisor of Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor of Gross and Fetal
Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance
Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
J. Dale Thurman, D.V.M., M.S., Senior Director, Pathology
DACVP
Kathy M. Gasser Supervisor of Archives
567Annex 56-C
A PRIMARY EYE IRRITATION STUDY IN RABBITS
WITH SPRAY--BRAVO
FINAL REPORT
OPPTS Guideline
870.2400
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
September 18, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.12
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 27
568 Annex 56-C
SLI Study No. 3596.12 (2)
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date:
Title Signature
569Annex 56-C
570 Annex 56-C
571Annex 56-C
SLI Study No. 3596.12 (5)
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS......................... 2
2. COMPLIANCE STATEMENT....................................................................... 3
3. QUALITY ASSURANCE STATEMENT ....................................................... 4
4. TABLE OF CONTENTS............................................................................... 5
5. LIST OF TABLES AND APPENDICES........................................................ 6
6. SUMMARY........................................................................
........................... 7
7. INTRODUCTION.......................................................................................... 8
8. MATERIALS AND METHODS..................................................................... 8
9. EXPERIMENTAL PROCEDURES ............................................................. 11
10. ANALYSIS OF DATA........................................................................
....... 12
11. MAINTENANCE OF RAW DATA AND RECORDS................................. 12
12. RESULTS........................................................................
......................... 13
13. CONCLUSION ........................................................................
................. 13
14. REPORT REVIEW ........................................................................
........... 13
15. REFERENCES........................................................................
................. 14
572 Annex 56-C
SLI Study No. 3596.12 (6)
5. LIST OF TABLES AND APPENDICES
Tables
1. Individual Ocular Irritation Scores (No Rinse Group) ...................15.......
Appendices
A. Ocular Grading System....................................................17..................
..
B. Ocular Evaluation Criteria (Kay and Calandra)............................22........
C. Individual Clinical Observations.........................................24..................
D. SLI Personnel Responsibilities ..........................................26..................
573Annex 56-C
SLI Study No. 3596.12 (7)
6. SUMMARY
The potential irritant and/or corrosive effects of Spray--Bravo were evaluated on
the eyes of New Zealand White rabbits. Each of three rabbits received a 0.1 mL
dose of the test article in the conjunctival sac of the right eye. The contralateral
eye of each animal remained untreated and served as a control. Test and
control eyes were examined for signs of irritation for up to 7 days following
dosing.
Exposure to the test article produced iritis in 2/3 test eyes at the 1-hour scoring
interval which resolved completely in all test eyes by the 24-hour scoring interval.
Conjunctivitis (redness, swelling and discharge) was noted in 3/3 test eyes at the
1-hour scoring interval. The conjunctival irritation resolved completely in all test
eyes by study day 7.
Based on the Kay and Calandra Evaluation, Spray--Bravo is considered to be a
mild irritant to the ocular tissue of the rabbit.
574 Annex 56-C
SLI Study No. 3596.12 (8)
7. INTRODUCTION
This study was performed to assess the irritant and/or corrosive effects of
Spray--Bravo in New Zealand White rabbits when administered by a single ocular
dose. This study was intended to provide information on the potential health
hazards of the test article with respect to ocular exposure. Data from this study
may serve as a basis for classification and/or labeling of the test article. This
study was conducted in accordance with the US EPA, Health Effects Test
Guidelines, OPPTS 870.2400, Acute Eye Irritation, August 1998. This study was
performed at Springborn Laboratories, Inc., 553 North Broadway, Spencerville,
Ohio. The protocol was signed by the Study Director on April 26, 2002 (GLP
initiation date). The in-life phase of the study was initiated with test article
administration on June 28, 2002 (day 0), and concluded with final scoring on
July 5, 2002.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows:
Assigned Physical Receipt Expiration
Sponaor’s ID SLI ID Description Date Date
Spray—Bravo S02.002.3596 Cloudy pale 05/31/02 None
amber liquid Provided
b
Ingredients
Herbicide: Roundup-SL None
Lot No.: 4010/4212 Provided
Surfactant: Cosmo Flux-411F None
a Lot No.: Unknown Provided
bSample pooled at SLI from five different mixes of Spray--Bravo (top/middle/bottom).
Ingredients used in the five Spray--Bravo mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength, purity, composition,
stability and method of synthesis of the test material according to 40 CFR
160.105 and 40 CFR 792.105. Springborn Laboratories, Inc., analyzed the test
article for the glyphosate (a.e.) which is presented in SLI Study No. 3596.8.
575Annex 56-C
SLI Study No. 3596.12 (9)
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture sample
(top/middle/bottom, maintained separately for a total of fifteen 1 mL samples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The remaining test article was returned to the Sponsor at the completion of all
studies with the test article.
8.4. Method of Test Article Preparation
The test article was administered as received from the Sponsor and dispensed
fresh on the day of dosing.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Adult, New Zealand White rabbits were received from Myrtle's Rabbitry,
Thompson Station, TN. Upon receipt, plastic ear tags displaying unique
identification numbers were used to individually identify the animals. Cage cards
displaying at least the study number, animal number and sex were affixed to
each cage. The animals were housed individually in suspended stainless steel
cages. All housing and care were based on the standards recommended by the
Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 69-72°F (21-
22°C) and 46-61%, respectively. Environmental control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10-15 air changes/hour. The animal
room temperature and relative humidity were recorded a minimum of once daily.
576 Annex 56-C
SLI Study No. 3596.12 (10)
8.5.3. Food
PMI Certified Rabbit Chow #5322 (Purina Mills, Inc.) was provided ad libitum to
the animals throughout the study. The lot number and expiration date of each
batch of diet used during the study were recorded. The feed was analyzed and
certified by the supplier for nutritional components and environmental
contaminants. Dietary limitations for various environmental contaminants,
including heavy metals, pesticides, polychlorinated biphenyls and total aflatoxin
are set by the manufacturer. Within these limits, contaminants which may have
been present were not expected to compromise the purpose of this study.
Results of the dietary analyses (Certificates of Analysis) are provided by the
manufacturer for each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study. The purified water was supplied by an automatic watering
system. Monitoring of the drinking water for contaminants is conducted by SLI
and the records are available for inspection. Within generally accepted limits,
contaminants which may have been present were not expected to compromise
the purpose of this study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were removed randomly from the shipping cartons,
examined by qualified personnel, identified with plastic ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The animals
were observed daily for overt physical or behavioral abnormalities, general
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were arbitrarily selected from healthy stock
animals to avoid potential bias. All animals received a detailed pretest
observation prior to dosing. Only healthy animals were chosen for study use.
The female was nulliparous and nonpregnant. The male animals were
approximately 16 weeks of age and weighed 3.4-3.5 kg prior to dosing. The
female animal was approximately 14 weeks of age and weighed 3.3 kg prior to
dosing.
577Annex 56-C
SLI Study No. 3596.12 (11)
9. EXPERIMENTAL PROCEDURES
9.1. Preliminary Examination
On day 0 prior to dosing, both eyes of each animal provisionally selected for test
use were examined macroscopically for ocular irritation with the aid of an
auxiliary light source. In addition, the corneal surface was examined using
fluorescein sodium dye. One drop of a fluorescein/physiological saline mixture
was gently dropped onto the superior sclera of each eye. Following an
approximate 15 second exposure, the eyes were thoroughly rinsed with
physiological saline. The corneal surface was then examined for dye retention
under a long-wave UV light source. Animals exhibiting ocular irritation,
preexisting corneal injury or fluorescein dye retention were not used on study. All
animals found to be acceptable for test use were returned to their cages until
dosing.
9.2. Dosing
A minimum of one hour after preliminary ocular examination, the test article was
instilled as follows:
No. of Animals
Concentration
Group (%)a Amount Instilled Male Female
No Rinse 100 0.1 mL 2 1
aPooled test article.
The test article was instilled into the conjunctival sac of the right eye of each
animal after gently pulling the lower lid away from the eye. Following instillation,
the eyelids were gently held together for approximately one second in order to
limit test article loss and the animal was returned to its cage. The contralateral
eye remained untreated to serve as a control.
9.3. Ocular Observations
The eyes were macroscopically examined with the aid of an auxiliary light source
for signs of irritation at 1, 24, 48 and 72 hours and up to 7 days after dosing
according to the Ocular Grading System presented in Appendix A which is based
on Draize [2]. Following macroscopic observations at the 24-hour scoring
interval, the fluorescein examination procedure was repeated on all test and
control eyes and any residual test article was gently rinsed from the eye at this
time (if possible) using physiological saline. If any fluorescein findings were
578 Annex 56-C
SLI Study No. 3596.12 (12)
noted at 24 hours, a fluorescein exam was conducted on the affected eyes at
each subsequent interval until a negative response was obtained and/or until all
corneal opacity had cleared, or as directed by the Study Director.
9.4. Clinical Observations
Any unusual observations and/or mortality were recorded. General
health/mortality checks were performed twice daily (in the morning and in the
afternoon).
9.5. Body Weights
Individual body weights were obtained for each animal prior to dosing on day 0.
9.6. Scheduled Euthanasia
Each animal was euthanized by an intravenous injection of sodium pentobarbital
following its final observation interval. Gross necropsy examinations were not
required for these animals.
9.7. Protocol Deviations
No protocol deviations occurred during this study.
10. ANALYSIS OF DATA
For each group, the ocular irritation score for each parameter (i.e., corneal
opacity x area, iritis and conjunctival redness + swelling + discharge) was
multiplied by the appropriate factor (i.e., corneal injury x 5, iritis x 5, conjunctivitis
x 2) and the totals added for each animal/interval. The group mean irritation
score was then calculated for each scoring interval based on the number of
animals initially dosed in each group. The calculated group mean ocular irritation
scores for each interval were used to classify the test article according to the
Ocular Evaluation Criteria [3] presented in Appendix B.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded records were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
579Annex 56-C
580 Annex 56-C
SLI Study No. 3596.12 (14)
15. REFERENCES
1. Guide for the Care and Use of Laboratory Animals, DHHS Publication No.
(NIH) 96-03, 1996.
2. Draize, J.H., Appraisal of the Safety of Chemicals in Foods, Drugs and
Cosmetics, The Association of Food and Drug Officials of the United States,
49-51, 1959.
3. Kay, J.H. and Calandra, J.C., “Interpretation of Eye Irritation Tests”, Journal of
the Society of Cosmetic Chemists, 13, 281-289, 1962.
581Annex 56-C
(15)
PAGE 1
Secondary
Ocular Findings
Control Eye*
FlExamination
[-]
Secondary
Ocular Findings
Test Eye*
FlExamination
TABLE 1
Conjunctivae
(NO RINSE GROUP)
A PRIMARY EYE IRRITATION STUDY IN RABBITS
Corneagval O A OxAx5 I Ix5 R S D (R+S+D)2Total
H4o8rso0a0s00000 001H4oH7o2a0s 0000 00 H4oH7o2a0s 0000 00 00101000 0 4 0 4 0
(kg) 3.327 H2o4urs00 03.4360 2H2o4urs0000 3.451 2H2o4urs0010 0 0 2 2 2-] MI12 12 [-] [-]
R2257/F Ho1ur 00 R2167/M Ho1ur 00 1R2163/M Ho1ur 00 8 0 1 5 2 2 2 12 17
SLICLIENT: I(N SLP/R,AYS—DBERPAVROT)MENT OF STATE INDIVIDUAL OCULAR IRRITAT*See Appendix A for definition of codes.
582 Annex 56-C
(16)
PAGE 2
TABLE 1 Mild Irritant
Mean Ocular Scores
(NO RINSE GROUP)
124 H8oHrsHsuD-ys-3.-10.7.62.67.00
A PRIMARY EYE IRRITATION STUDY IN RABBITS
SLI STUDY NO.: 3596.12ERAVRO)MENT OF STATE INDIVIDUAL OCULAR IRRITATION SCORES
583Annex 56-C
SLI Study No. 3596.12 (17)
APPENDIX A
Ocular Grading System
584 Annex 56-C
SLI Study No. 3596.12 (18)
OCULAR GRADING SYSTEM
(O) CORNEAL OPACITY—DEGREE OF DENSITY
(AREA MOST DENSE TAKEN FOR READING)
OBSERVATION CODE
No ulceration or opacity 0
Scattered or diffuse areas of opacity (other than slight dulling of normal luster), details of
1*
iris clearly visible
Easily discernible translucent area, details of iris slightly obscured 2*
Nacreous (opalescent) area, no details of iris visible, size of pupil barely discernibl3*
Opaque cornea, iris not discernible through opacity 4*
(A) AREA OF CORNEA INVOLVED
(TOTAL AREA EXHIBITING ANY OPACITY, REGARDLESS OF DEGREE)
OBSERVATION CODE
No ulceration or opacity 0
One quarter (or less) but not zero 1
Greater than one quarter, but less than half 2
Greater than half, but less than three quarters 3
Greater than three quarters, up to whole area 4
Cornea Score = O x A x 5 Total Maximum = 80
(I) IRITIS
OBSERVATION CODE
Normal 0
Markedly deepened rugae (folds above normal), congestion, swelling, moderate
circumcorneal hyperemia or injection, any or all of these or combination of any thereof1*iris
is still reacting to light (sluggish reaction is positive)
No reaction to light, hemorrhage, gross destruction (any or all of these) 2*
Iris Score = I x 5 Total Maximum = 10
*Starred figures indicate positive effect.
585Annex 56-C
SLI Study No. 3596.12 (19)
OCULAR GRADING SYSTEM
(R) CONJUNCTIVAL REDNESS
(REFERS TO PALPEBRAL AND BULBAR CONJUNCTIVAE EXCLUDING CORNEA AND IRIS)
OBSERVATION CODE
Blood vessels normal 0
Some blood vessels definitely hyperemic (injected) above normal (slight erythema) 1
Diffuse, crimson color, individual vessels not easily discernible (moderate erythema) 2*
Diffuse beefy red (marked erythema) 3*
(S) CONJUNCTIVAL SWELLING
(LIDS AND/OR NICTITATING MEMBRANE)
OBSERVATION CODE
No swelling 0
Any swelling above normal (includes nictitating membrane, slightly swollen) 1
Obvious swelling with partial eversion of lids 2*
Swelling with lids about half closed 3*
Swelling with lids more than half closed 4*
(D) CONJUNCTIVAL DISCHARGE
OBSERVATION CODE
No discharge 0
Any amount different from normal (does not include small amounts observed in inner
1
canthus of normal animals)
Discharge with moistening of the lids and hairs just adjacent to lids 2
Discharge with moistening of the lids and hairs and considerable area around the eye 3
Conjunctival Score = (R + S + D) x 2 Total Maximum = 20
*Starred figures indicate positive effect.
586 Annex 56-C
SLI Study No. 3596.12 (20)
OCULAR GRADING SYSTEM
CORNEAL NEOVASCULARIZATION
OBSERVATION CODE DEFINITION
Neovascularization – Total area of vascularized corneal tissue is < 10% of corneal
Very Slight VAS-1 surface
Neovascularization – Total area of vascularized corneal tissue is > 10% but < 25% of
VAS-2
Mild corneal surface
Neovascularization – Total area of vascularized corneal tissue is > 25% but < 50% of
Moderate VAS-3 corneal surface
Neovascularization – Total area of vascularized corneal tissue is > 50% of corneal
VAS-4
Severe surface
SECONDARY OCULAR FINDINGS
OBSERVATION CODE DEFINITION
Sloughing of the Corneal epithelial tissue is observed to be peeling off the corneal
corneal epithelium SCE surface.
Corneal bulging CB The entire corneal surface appears to be protruding outward further
than normal.
Slight dulling of normal The normal shiny surface of the cornea has a slightly dulled
luster of the cornea SDL appearance.
Raised area on the A defined area on the corneal surface that is raised above the rest
corneal surface RAC of the cornea. This area is generally associated with
neovascularization and has an off-white to yellow color.
Corneal edema CE The cornea has a swollen appearance.
Test article present in TAE Apparent residual test article is observed on the eye or in the
eye conjunctival sac/inner canthus.
Observation confirmed A slit lamp examination was performed to confirm the initial
by slit lamp OCS observation.
Corneal mineralization CM Small white or off-white crystals that are observed in the corneal
tissue.
587Annex 56-C
SLI Study No. 3596.12 (21)
OCULAR GRADING SYSTEM
FLUORESCEIN EXAMINATION OF CORNEA
OBSERVATION CODE
Fluorescein Dye Retention
Fluorescein dye retention associated with the area of corneal opacity FAO
Fluorescein dye retention is not associated with any other finding FNF
Negative Results
No fluorescein retention is observed (-)
Secondary Ocular Findings
Superficial mechanical abrasion to the cornea observed during the fluorescein MI
examination period ST
Fine stippling on the cornea observed during the fluorescein examination procedure
POST-DOSE CLINICAL OBSERVATIONS
OBSERVATION CODE
Animal vocalized following dosing VOC
Animal excessively pawed test eye following dosing PAW
Animal exhibited excessive hyperactivity following dosing HYP
Animal exhibited excessive head tilt following dosing HT
Animal exhibited excessive squinting of test eye following dosing SQ
588 Annex 56-C
SLI Study No. 3596.12 (22)
APPENDIX B
Ocular Evaluation Criteria
(Kay and Calandra)
589Annex 56-C
SLI Study No. 3596.12 (23)
OCULAR EVALUATION CRITERIA
Maximum Mean Maximum Persistence of Individual
Score (Days 0-3) Mean Score Scores Descriptive Rating and Class
24 hours = 0 Non-Irritating 1
0.00 – 0.49
24 hours > 0 Practically Non-irritating2
24 hours = 0 Non-Irritating 1
0.50 – 2.49
24 hours > 0 Practically Non-irritating2
48 hours = 0 Slight Irritant 3
2.50 – 14.99
48 hours > 0 Mild Irritant 4
72 hours = 0 Mild Irritant 4
15.00 – 24.99
72 hours > 0 Moderate Irritant 5
> half of day 7 scores < 10 Moderate Irritant 5
> half of day 7 scores > 10, but
7 day < 20 Moderate Irritant 5
25.00 – 49.99 no score > 20
> half of day 7 scores > 10, and Severe Irritant 6
any score > 20
7 day > 20 Severe Irritant 6
> half of day 7 scores < 30 Severe Irritant 6
> half of day 7 scores > 30, but
7 day < 40 no score > 60 Severe Irritant 6
50.00 – 79.99
> half of day 7 scores > 30, and Very Severe Irritant 7
any score > 60
7 day > 40 Very Severe Irritant 7
> half of day 7 scores < 60 Very Severe Irritant 7
> half of day 7 scores > 60, but
7 day < 80 no score > 100 Very Severe Irritant 7
80.00 – 99.99 > half of day 7 scores > 60, and
Extremely Severe Irritant 8
any score > 100
7 day > 80 Extremely Severe Irritant 8
7 day < 80 Very Severe Irritant 7
100.00 – 110.00
7 day > 80 Extremely Severe Irritant 8
590 Annex 56-C
SLI Study No. 3596.12 (24)
APPENDIX C
Individual Clinical Observations
591Annex 56-C
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PAGE 1
(POSITIVE FINDINGS)
INDIVIDUAL CLINICAL OBSERVATIONS
A PRIMARY EYE IRRITATION STUDY IN RABBITS
R2257/F Soft stools: Day 1
Animal No./Sex Clinical Observations
SLILIENTY:IOL./:A9612EPARTMENT OF STATE
592 Annex 56-C
SLI Study No. 3596.12 (26)
APPENDIX D
SLI Personnel Responsibilities
593Annex 56-C
SLI Study No. 3596.12 (27)
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute
Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Associate
Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing
Director Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Christopher W. Wilson, B.S. Associate Toxicologist
Pamela S. Smith, ALAT Supervisor of Acute Toxicology
Kathy A. Pugh, ALAT Primary Technician/Team Leader
Delores P. Knippen Supervisor of Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor of Gross and Fetal
Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
J. Dale Thurman, D.V.M., M.S., DACVP Senior Director, Pathology
Kathy M. Gasser Supervisor of Archives
594 Annex 56-C
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1 ---- ---- ----
STUINL/A, U.S DEPMALTESENT-5000TMGE-----O--CHENG-CHEFT---EWAHIHENATERANO--:AO1ICIT--AT--------R---N------Y---6---P--P-----0---
--L=-
-14-
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(16)
2 ---- ---- ----
STINL/A, U.S DEP9FEMALEST-FEMALTMGAK----OB-CHEN-TISCS-STHE-IAEU-CLED--ESAL=-L(I--SIY-2--F--------I-P--ST--RE-
-------
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(17)
1 ---- ---- ----
STUINL/A, U.S D.MALES---NIM5000-M----5556----O---57-96--------0---14-E-3---BLH-X5-O------U--
------T--)-
--------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------------
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2 ---- ---- ----
STINL/A, U.S D6FEMALES---MAL--45A5K-7ME--------S----1----173--751822-T---L--A--DAY3-------------------
--------------------------------------------------------
------------------------------------------------------------
612 Annex 56-C
(19)
E 1 ---- ---- ----
STUINL/A, U.S D.-ALES----50-F#---452545-54---L-0----UL--U2-J---TIO--ESUU-S-IS--IN-NE---IN--IMIH-M-L
-R-AL
---MITS---------
-
---------------
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E 2 ---- ---- ----
STINL/A, U.S DFE-MALES---50--0----1G472--S4--7024-0-L-O---JUL---ON---UESL-E-SU--SNOS-N-N----NTSN-T-MI---
LI-
ITS
----
614 Annex 56-C
615Annex 56-C
616 Annex 56-C
A PRIMARY SKIN IRRITATION STUDY IN RABBITS
WITH SPRAY--BRAVO
FINAL REPORT
OPPTS Guideline
870.2500
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
September 3, 2002
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.13
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 25
617Annex 56-C
SLI Study No. 3596.13 (2)
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date
Title Signature
618 Annex 56-C
619Annex 56-C
620 Annex 56-C
SLI Study No. 3596.13 (5)
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS..........................2 ..
2. COMPLIANCE STATEMENT.........................................................................3 .......
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS.......................................................................................
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION .............................................................................................
8. MATERIALS AND METHODS........................................................................8 ......
9. EXPERIMENTAL PROCEDURES.....................................................................10
10. ANALYSIS OF DATA.........................................................................................12
11. MAINTENANCE OF RAW DATA AND RECORDS......................................12
12. RESULTS.............................................................................................................12
13. CONCLUSION.....................................................................................................13
14. REPORT REVIEW..............................................................................................13
15. REFERENCES.....................................................................................................14
621Annex 56-C
SLI Study No. 3596.13 (6)
5. LIST OF TABLES AND APPENDICES
Tables
1. Individual Dermal Irritation Scores...........................................5...................1
Appendices
A. Macroscopic Dermal Grading System ..........................................................16
B. Dermal Evaluation Criteria.......................................................0....................2
C. Individual Clinical Observations................................................2...................2
D. SLI Personnel Responsibilities..................................................4..................2
622 Annex 56-C
SLI Study No. 3596.13 (7)
6. SUMMARY
The potential irritant and/or corrosive effects of Spray --Bravo were evaluated on
the skin of New Zealand White rabbits. Each of three rabbits received a 0.5 mL
dose of the test article as a single dermal application. The dose was held in
contact with the skin under a semi-occlusive binder for an exposure period of four
hours. Following the exposure period, the binder was remov ed and the
remaining test article was wiped from the skin using gauze moistened with
deionized water followed by dry gauze. Test sites were subsequently examined
and scored for dermal irritation for up to 7 days following patch application.
Exposure to the test article produced very slight erythema on 3/3 test sites at the
1-hour scoring interval. The dermal irritation resolved completely on all test sites
by study day 7.
Under the conditions of the test, Spray --Bravo is considered to be a slight irri tant
to the skin of the rabbit. The calculated Primary Irritation Index for t
he test article
was 0.83.
623Annex 56-C
SLI Study No. 3596.13 (8)
7. INTRODUCTION
This study was performed to assess the potential irritant and/or corrosi
ve effects
of Spray--Bravo in New Zealand White rabbits when admi nistered by a single
dermal dose. This study was intended to provide information on the potential
health hazards of the test article with respect to dermal exposure. Data from this
study may serve as a basis for classification and/or labeling of the test article.
This study was conducted in accordance with the US EPA, Health Effects Te
st
Guidelines, OPPTS 870.2500, Acute Dermal Irritation, August 1998. This study
was performed at Springborn Laboratories, Inc., 553 North Broadway,
Spencerville, Ohio. Th e protocol was signed by the Study Director on
April 26, 2002 (GLP initiation date). The in -life phase of the study was initiated
with test article administration on June 24, 2002 (day 0) and concluded with final
scoring on July 1, 2002.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows
:
Assigned Physical Receipt Expiration
Sponsor’s ID SLI ID Description Date Date
Spray--Bravo S02.002.3596 Cloudy pale 05/31/02 None
amber liquid provided
b
Ingredients:
Herbicide: Roundup SL None
Lot No.: 4010/4212 provided
4397/4272
4333/4340
4379/4076
4397/4333
Surfactant: Cosmo Flux -411F None
Lot No.: Unknown provided
a
bample pooled at SLI from five different mixes of Spray --Bravo (top/middle/bottom).
Ingredients used in the five Spray --Bravo mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was respons
ible
for any necessary evaluat ions related to identity, strength, purity, composition,
stability and method of synthesis of the test material according to 40 C
FR
160.105 and 40 CFR 792.105. Springborn Laboratories, Inc. analyzed the
test
article for the glyphosate (a.e.) which is presented in SLI Study No. 3596.8.
624 Annex 56-C
SLI Study No. 3596.13 (9)
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture sample
(top/middle/bottom, maintained separately for a total of fifteen 1 mL
mples)
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures ) was
collected and stored at SLI at room temperature. These samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The remaining test article was returned to the Sponsor following completion of all
studies with the test article.
8.4. Method of Test Article Preparation
The test article was administered as received from the Sponsor and dispe
nsed
fresh on the day of dosing.
8.5. Animals and Animal Husbandry
8.5.1. Description, Identification and Housing
Adult, New Zealan d White rabbits were received from Myrtle’s Rabbitry,
Thompson Station, TN. Upon receipt, plastic ear tags displaying unique
identification numbers were used to individually identify the animals.
age cards
displaying at least the study number, animal number and sex were affixed to
each cage. The animals were housed individually in suspended stainless steel
cages. All housing and care were based on the standards recommended by
the
Guide for the Care and Use of Laboratory Animals [1].
8.5.2. Environment
The animal room temperature and relative humidity ranges were 71- 76°F (22-
24°C) and 43 -61%, respectively. Environmental control equipment was
monitored and adjusted as necessary to minimize fluctuations in the animal room
environment. Light timers were set to maintain a 12-hour light/12-hour dark cycle
and room ventilation was set to produce 10- 15 air changes/hour. The animal
room temperature and relative humidity were recorded a minimum of once d
aily.
8.5.3. Food
PMI Certified Rabbit Chow #5322 (Purina Mills, Inc.) w as provided ad libitum to
the animals throughout the study. The lot number and expiration date of
each
batch of diet used during the study were recorded. The feed was analyzed
and
certified by the supplier for nutritional components and environmental
625Annex 56-C
SLI Study No. 3596.13 (10)
contaminants. Dietary limitations for various environmental contaminants,
including heavy metals, pesticides, polychlorinated biphenyls and total
aflatoxin
are set by the manufacturer. Within these limits, contaminants which may have
been present were not e xpected to compromise the purpose of this study.
Results of the dietary analyses (Certificates of Analysis) were provid
d by the
manufacturer for each lot of diet. These are maintained by SLI.
8.5.4. Water
Municipal tap water treated by reverse osmosis was available ad libitum
throughout the study. The purified water was supplied by an automatic w
atering
system. Monitoring of the drinking water for contaminants is conducted
by SLI
and the records are available for inspection. Within generally accepted limits,
contaminants which may have been present were not expected to compromise
the purpose of this study. The water meets the standards specified under the
EPA National Drinking Water Regulations (40 CFR Part 141).
8.5.5. Acclimation
Upon receipt, the animals were re moved randomly from the shipping cartons,
examined by qualified personnel, identified with plastic ear tags and then
acclimated to the laboratory conditions for a minimum of five days. The
animals
were observed daily for overt physical or behavioral abnor malities, general
health/moribundity and mortality.
8.5.6. Animal Selection
The animals chosen for study use were arbitrarily selected from healthy stock
animals to avoid potential bias. All animals received a detailed pretest
observation prior to dosing. Only healthy animals were chosen for study use.
The male animals were approximately 17- 18 weeks of age and weighed 3.4 -3.7
kg prior to dosing.
9. EXPERIMENTAL PROCEDURES
9.1. Preliminary Procedures
On day -1, the animals chosen for use on the primary skin irritation study had the
fur removed from the dorsal area of the trunk using an animal clipper. C
are was
taken to avoid abrading the skin during the clipping procedure.
9.2. Dosing
On the following day (day 0), the test article was applied to a small
rea of intact
skin on each test animal (approximately 1 inch x 1 inch) as indicated below:
626 Annex 56-C
SLI Study No. 3596.13 (11)
Concentration Amount No. of Animals
(%) Applied Patch Design Male
100a 0.5 mL ~1” x 1” square 4-ply gauze patch 3
a
Pooled test article
The test article was administered under the gauze patch. The gauze patch was
held in contact with the skin at the cut edges with a nonirritating tape
. Removal
and ingestion of the test article was prevented by placing an elastic wr
ap over the
trunk and test area (semi -occlusive binding). The elastic wrap was then further
secured with adhesive tape around the trunk at the cranial and caudal end
s.
After dosing, collars were placed on each animal and remained in place until
removal on day 3. After a four -hour exposure period, the binding materials were
removed from each animal and the corners of the test site delineated using a
marker. Residual test article was removed using gauze moistened with
deionized water, followed by dry gauze.
9.3. Dermal Observations
Animals were examined for signs of eryt hema and edema and the responses
scored at 1 hour after patch removal and 24, 48 and 72 hours and up to 7 days
after patch application according to the Macroscopic Dermal Grading System
presented in Appendix A which is based on Draize [2].
9.4. Clinical Observations
Any unusual observations and/or mortality were recorded. General
health/mortality checks were performed twice daily (in the morning and
in the
afternoon).
9.5. Body Weights
Individual body weights were obtained for each animal prior to dosing on day 0.
9.6. Scheduled Euthanasia
Each animal was euthanized by an intravenous injection of sodium pentoba
rbital
following its final scoring interval. Gross necropsy examinations were n
ot
required for these animals.
627Annex 56-C
SLI Study No. 3596.13 (12)
9.7. Protocol Deviations
On two occasions, the animal room temperature range [71- 76°F (22- 24°C)]
exceeded the preferred range [63- 73°F (17- 23°C)] during this study. This
occurrence was considered to have had no adverse effect on the outcome of this
study.
10. ANALYSIS OF DATA
The 1-, 24-, 48- and 72- hour erythema and edema scores for all animals were
added and the total divided by the number of test sites x 4. The calcu
ted
Primary Irritation Index (P.I.I.) was classified according to the Dermal Evaluation
Criteria [3] presented in Appendix B.
11. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded records
were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
12. RESULTS
12.1. Dermal/Clinical Observations
Individual Data: Table 1
Individual Clinical Observations: Appendix C
Exposure to the test article produced very slight erythema on 3/3 test si
tes at the
1-hour scoring interval. The dermal irritation resolved completely on all test sites
by study day 7.
Transient clinical observations of few feces, decreased food consumption and
feces small in size were observed in one animal during the study and were not
considered to be test article-related.
628 Annex 56-C
629Annex 56-C
SLI Study No. 3596.13 (14)
15. REFERENCES
1. Guide for the Care and Use of Laboratory Animals, DHHS Publication No.
(NIH) 96-03, 1996.
2. Draize, J.H., Appraisal of the Safety of Chemicals in Foods, Drugs and
Cosmetics, The Association of Food and Drug Officials of the United States,
49-51, 1959.
3. Pesticide Assessment Guidelines, Subdivision F, Hazard Evaluation: Human
and Domestic Animals-Addendum 3 on Data Reporting, US EPA, 1988 .
630 Annex 56-C
(15)
PAGE 1
BRAVO) Comments IT IT
TABLE 1(SPRAY--
0.83 = Slight irritant
Primary Irritation Index
INDIVIDUAL DERMAL IRRITATION SCORES 0 0 0 0 0 0
A PRIMARY SKIN IRRITATION STUDY IN RABBITS
Erythema1 0 1 1 1 1 0 1 1 1 0
TMENT OF SAal
HouHoursursursHouroursursrs Houroursrsurs
ScIonnrg2448 72 1 24 48 72 7 Days 24 4872
Appendix A for definition of codes.
3.567 3.364 3.650
R2111/M R2122/M R2126/M
SLICLIENT: INL/A, US DEPAR(kg) Note: See
631Annex 56-C
SLI Study No. 3596.13 (16)
APPENDIX A
Macroscopic Dermal Grading System
632 Annex 56-C
SLI Study No. 3596.13 (17)
MACROSCOPIC DERMAL GRADING SYSTEM
ERYTHEMA AND EDEMA OBSERVATIONS
OBSERVATION DEFINITION CODE
Erythema – Grade 0 No erythema 0
Erythema – Grade 1 Very slight erythema (barely perceptible) 1
Erythema – Grade 2 Well-defined erythema 2
Erythema – Grade 3 Moderate to severe erythema 3
Erythema – Grade 4 Severe erythema (beet redness) 4
Maximized Grade 4 Notable dermal lesions (see below) M – 4
(see below)
Edema – Grade 0 No edema 0
Edema – Grade 1 Very slight edema (barely perceptible) 1
Slight edema (edges of area well defined by definite
Edema – Grade 2 raising) 2
Edema – Grade 3 Moderate edema (raised approximately 1 millimeter) 3
Severe edema (raised more than 1 millimeter and
Edema – Grade 4 extends beyond the area of exposure) 4
NOTE: Each animal was assigned an erythema and edema score. The most severely
aff ected
area within the test site was graded. If eschar, blanching, ulceration
and/or necrosis greater
than grade 1 was observed, then the “Maximized Grade 4" was assigned
to the test site in
place of the erythema score and the type of notable dermal les(s) (e.g., eschar - grade 2,
blanching - grade 3, ulceration - grade 4, etc.) was noted. The presence of any other dermal
changes (e.g., desquamation, fissuring, eschar exfoliation, etc.) was
also recorded.
633Annex 56-C
SLI Study No. 3596.13 (18)
MACROSCOPIC DERMAL GRADING SYSTEM
NOTABLE DERMAL LESIONS
OBSERVATION CODE DEFINITION
Eschar – Grade 1 ES-1 Focal and/or pinpoint areas up to 10% of test site.
Eschar – Grade 2 ES-2 > 10% < 25% of test site.
Eschar – Grade 3 ES-3 > 25% < 50% of test site.
Eschar – Grade 4 ES-4 > 50% of test site.
Blanching – Grade 1 BLA-1 Focal and/or pinpoint areas up to 10% of test site.
Blanching – Grade 2 BLA-2 > 10% < 25% of test site.
Blanching – Grade 3 BLA-3 > 25% < 50% of test site.
Blanching – Grade 4 BLA-4 > 50% of test site.
Ulceration – Grade 1 U-1 Focal and/or pinpoint areas up to 10% of test site.
Ulceration – Grade 2 U-2 > 10% < 25% of test site.
Ulceration – Grade 3 U-3 > 25% < 50% of test site.
Ulceration – Grade 4 U-4 > 50% of test site.
Necrosis – Grade 1 NEC-1 Focal and/or pinpoint areas up to 10% of test site (note
(color) color of necrosis).
Necrosis – Grade 2 NEC-2 > 10% < 25% of test site (note color of necrosis).
(color)
Necrosis – Grade 3 NEC-3 > 25% < 50% of test site (note color of necrosis).
(color)
Necrosis – Grade 4 NEC-4 > 50% of test site (note color of necrosis).
(color)
634 Annex 56-C
SLI Study No. 3596.13 (19)
MACROSCOPIC DERMAL GRADING SYSTEM
ADDITIONAL DERMAL FINDINGS
OBSERVATION DEFINITION CODE
Desquamation Characterized by scaling or flaking of dermal tissue or DES
without denuded areas.
Characterized by cracking of the skin with or without
Fissuring moist exudate. Fissuring should be checked prior to FIS
removing the animal from the cage and manipulating the
test site.
The process by which areas of eschar flake off the test
Eschar Exfoliation EXF
site.
Test Site Staining Skin located at test site appears to be discolored, TSS
possibly due to test article (note color of staining). (color)
The erythema extends beyond the test site. Note: A
Erythema Extends
Beyond the Test Site study director should be contacted for erythema ERB
extending beyond the test site.
Characterized by pale area(s) (almost a burn -like
appearance) in the test site. However, erythema may
still be observed through the pale area. Note: This
observation may affect the overall erythema score of the
test site. This observation may progress to other
Superficial Lightening observations resulting in notable dermal lesions, but SL --
itself will not be considered a notable dermal lesion that
will result in a dermal score to be maximized since it
does not result in any in- depth injury. To be coded
using an area designation (see below).
Superficial Lightening - Focal and/or pinpoint areas up to 10% of the test site SL-1
Grade 1
Superficial Lightening -
Grade 2 > 10% < 25% of test site SL-2
Superficial Lightening - > 25% < 50% of test site SL-3
Grade 3
Superficial Lightening -
Grade 4 > 50% of test site SL-4
Noticeable irritation outside of test site probably due to
Dermal Irritation - the binding tape ma terial. This notation will only be
made for reactions greater than what are normally IT
Outside of the Test Site observed from tape removal which does not interfere
with the scoring of the test site.
635Annex 56-C
SLI Study No. 3596.13 (20)
APPENDIX B
Dermal Evaluation Criteria
636 Annex 56-C
SLI Study No. 3596.13 (21)
DERMAL EVALUATION CRITERIA
Primary Irritation Index
(P.I.I.) Irritation Rating
0.00 Nonirritant
0.01 - 1.99 Slight Irritant
2.00 - 5.00 Moderate Irritant
5.01 - 8.00 Severe Irritant
637Annex 56-C
SLI Study No. 3596.13 (22)
APPENDIX C
Individual Clinical Observations
638 Annex 56-C
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PAGE 1
(POSITIVE FINDINGS)
INDIVIDUAL CLINICAL OBSERVATIONS
A PRIMARY SKIN IRRITATION STUDY IN RABBITS
Clinical Observationsozeu:Datyio4n: Days 3, 5
R2122/M
Animal No./Sex
SLCLIENT: INL/A, US DEPARTMENT OF STATE
639Annex 56-C
SLI Study No. 3596.13 (24)
APPENDIX D
SLI Personnel Responsibilities
640 Annex 56-C
SLI Study No. 3596.13 (25)
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute
Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Associate Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing
Director Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Rusty E. Rush, M.S., LAT, DABT Director, Neurotoxicity and Transgenics
Jason W. Smedley, B.S. Assistant Toxicologist
Pamela S. Smith, ALAT Supervisor of Acute Toxicology
Lyndsay K. Simindinger, A.S. Primary Technician/Acute Technician I
Delores P. Knippen Supervisor of Pharmacy
Steven H. Magness, B.S., LATG Senior Supervisor of Gross and Fetal
Pathology
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
J. Dale Thurman, D.V.M., M.S., Senior Director, Pathology
DACVP
Kathy M. Gasser Supervisor of Archives
641Annex 56-C
PURITY ANALYSIS FOR GLYPHOSATE OF SPRAY--BRAVO
(ACTIVE INGREDIENT)
FINAL REPORT
Author
Kimberly L. Bonnette, M.S., LATG
Study Completed on
January 9, 2003
Performing Laboratory
Springborn Laboratories, Inc. (SLI)
Ohio Research Center
640 North Elizabeth Street
Spencerville, Ohio 45887
SLI Study No.
3596.8
Submitted to
INL/A
U.S. Department of State
2201 C St. NW SA-4
Washington, DC 20520
Page 1 of 30
642 Annex 56-C
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SLI Study No. 3596.8
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA §10(d)(1)(A), (B), or (C).
Company:
Company Agent: Date
Title Signature
643Annex 56-C
644 Annex 56-C
645Annex 56-C
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SLI Study No. 3596.8
4. TABLE OF CONTENTS
1. STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS ..........................2 ..
2. COMPLIANCE STATEMENT.........................................................................3 .......
3. QUALITY ASSURANCE STATEMENT..........................................................4 .....
4. TABLE OF CONTENTS.....................................................................................
5. LIST OF TABLES AND APPENDICES..........................................................6 .....
6. SUMMARY ......................................................................................................7.........
7. INTRODUCTION ............................................................................................8
8. MATERIALS AND METHODS........................................................................8 ......
9. EXPERIMENTAL PROCEDURE....................................................................9 ......
10. ANALYTICAL CHEMISTRY..............................................................................10
11. SPRAY--BRAVO ANALYSIS............................................................................10
12. STATISTICAL ANALYSIS.................................................................................13
13. PROTOCOL DEVIATIONS................................................................................13
14. MAINTENANCE OF RAW DATA AND RECORDS......................................13
15. RESULTS.............................................................................................................14
16. CONCLUSION.....................................................................................................15
17. REPORT REVIEW..............................................................................................15
646 Annex 56-C
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SLI Study No. 3596.8
5. LIST OF TABLES AND APPENDICES
Tables
1. Standard Curve and Sample Analysis Values for the
Before Use-Purity Analysis.................................................................1
2. Sample Analysis Values and % Error Based on Theoretical Value
(Before Use-Purity)..............................................................................1
3. Standard Curve and Sample Analysis Values for the
After Use-Purity Analysis for (Stability) ...............................................1
4. Sample Analysis Values and % Error Based on Theoretical Value
(After Use- Purity for Stability).............................................................1
Appendices
A. Statistical Analysis...............................................................................2
B. SLI Personnel Responsibilities............................................................2
647Annex 56-C
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SLI Study No. 3596.8
6. SUMMARY
The objective of this study was to assess the concentration(s) of glyphosate
(active ingredient) in the Spray--Bravo formulation.
Five test article mixtures were prepared in the field by the Sponsor. Three 500
mL samples of each mixture were collected from the top/middle/bottom (o
r
beginning/middle/end) of Aircraft 3077 (Test Article Mixtures 1 and 5), Aircraft
3064 (Test Article Mixtures 2 and 4) and Aircraft - unknown (Test Article Mixture
3 – aircraft not documented). Test Article mixtures were prepared as foll
ows:
Ingredient Amount Added (gallons)
Herbicide: 88
Roundup SL
Surfactant: 2
Cosmo Flux-411F
Well water 110
Mixing time: 10-15 minutes in flight.
Test article mixtures were prepared on two separate days (May 26, 2002, for
Test Article Mixtures 1, 2 and 3; and May 28, 2002 for Test Article Mixtu
res 4
and 5).
The overall concentration of the Spray --Bravo was 16.33 [in terms of %
glyphosate (a.e.)] before use at SLI and 17.04 [in terms of % glyphosate (a.e.)]
after use at SLI, indicating that the test material was stable during us
e at SLI.
The overall result (~16.33% glyphosate a.e.) was slightly higher than t
he
anticipated 14.80% glyphosate (a.e.), but well within acceptable error o
f mixing
conditions in the field. Therefore, since the results of the analysis were
appropriate (and would provide conservative results for toxicity, irrit
ation and
sensitization since they were slightly higher than expected), approximately
400 mL of each sample were pooled into a single container for use in the
remaining studies.
648 Annex 56-C
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SLI Study No. 3596.8
7. INTRODUCTION
This study was performed to assess the concentrations of glyphosate (active
ingredient) in S pray--Bravo. This study was performed to support studies
conducted under the US EPA, Health Effects Test Guidelines. This study was
performed at Springborn Laboratories, Inc., 553 North Broadway, Spencerville,
Ohio. The protocol was signed by the Study Director on April 25, 2002 (GLP
initiation date). The test article mixtures were analyzed for glyphosat
e (a.e.)
initially on June 11, 2002, prior to all other studies and again on Augus
t 21, 2002,
after all studies were complete for purposes of stability.
8. MATERIALS AND METHODS
8.1. Test Article
The test article was received from the Sponsor and identified as follows
:
Assigned Physical Receipt Expiration
Sponaor’s ID SLI ID Description Date Date
Spray—Bravo S02.002.3596 Cloudy pale 05/31/02 None provided
amber liquid
Ingredients:
Herbicide: Roundup SL None provided
Lot Nos.: 4010/4212
4397/4272
4333/4340
4379/4076
4397/4333
Surfactant: Cosmo Flux -411F None provided
aLot No.: Unknown
bSample pooled at SLI from five different mixes of Spray --Bravo (top/middle/bottom).
Ingredients used in the five Spray --Bravo mixes that were prepared by the Sponsor.
The test article was stored at room temperature. The Sponsor was responsible
for any necessary evaluations related to identity, strength , purity, composition,
stability and method of synthesis of the test material according to 40 C
FR
160.105 and 40 CFR 792.105.
8.2. Retention Sample
An approximate 1 mL retention sample of each test article mixture sample
(top/middle/bottom, maintained separat ely for a total of fifteen 1 mL samples)
649Annex 56-C
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SLI Study No. 3596.8
was taken and stored at SLI at room temperature. In addition, a 10 mL retention
sample of the pooled test article samples (from the 5 test article mixtures) was
collected and stored at SLI at room temperature. The se samples serve as the
retention samples for all studies conducted with this material.
8.3. Test Article Disposition
The test article was returned to the Sponsor following completion of all studies
with the test article.
8.4. Method of Test Article Preparation
The test article containers were hand shaken and dispensed fresh on the day of
analysis. The samples were stirred continuously until diluted for analy
sis.
9. EXPERIMENTAL PROCEDURE
9.1. Sample Collection
Samples were collected from the prepared test article mix using pre- labeled
containers provided by SLI as follows:
Test Article Mix 1 500 mL Beginning
500 mL Middle
500 mL End
Test Article Mix 2 500 mL Beginning
500 mL Middle
500 mL End
Test Article Mix 3 500 mL Beginning
500 mL Middle
500 mL End
Test Article Mix 4 500 mL Beginning
500 mL Middle
500 mL End
Test Article Mix 5 500 mL Beginning
500 mL Middle
500 mL End
Five test article mixtures were prepared in the field by the Sponsor
ree 500
mL samples of each mixture were collected from the top/middle/botto m (or
beginning/middle/end) Aircraft 3077 (Test Article Mixtures 1 and 5), Aircraft 3064
650 Annex 56-C
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SLI Study No. 3596.8
(Test Article Mixtures 2 and 4) and Aircraft - unknown (Test Article Mixture 3 –
aircraft not documented). The Test Article mixtures were prepared as fo
llows:
Ingredient Amount Added (gallons)
Herbicide: 88
Roundup SL
Surfactant: 2
Cosmo Flux-411F
Well water 110
Mixing time: 10 (Test mixture 4) -15 (Test mixtures 1, 2, 3 and 5) minutes in flight.
Test article mixtures were prepared on two separate days ( May 26, 2002, for
Test Article Mixtures 1, 2 and 3; and May 28, 2002 for Test Article Mixtures 4 and
5).
A total of fifteen 500 mL samples were collected. The individual (Brad Carter,
Assistant Operations Manager, Embajada Americana, Carrera 45, No. 22D- 45,
Bogota, Columbia, South America) collecting samples completed the SLI
provided form upon collection including signature and date when collected at San
Jose del Guaviare, Columbia. Samples were maintained under ambient
conditions.
10. ANALYTICAL CHEMISTRY
The samples were analyzed in terms of the active ingredient for concentra
tion
determination prior to any dosing (Before Use- Purity) and again after completion
of all studies for stability determination (After Use- Purity). All analytical dilutions
were performed in duplicate (all dilutions were performed on the same day).
The analytical method was a previously validated method for the analysis
of
glyphosate in solution. Purity analysis of the test article was perform
ed in
duplicate by comparison of the t est article with supplied reference standards of
known concentrations.
11. SPRAY--BRAVO ANALYSIS
The analytical method for the analysis of the glyphosate component of Spray --
Bravo was validated prior to the purity analyses performed at Springborn
Laboratories, Inc. This method was utilized to determine both the purity and the
stability of the Spray--Bravo test material before and after use at SLI.
651Annex 56-C
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SLI Study No. 3596.8
11.1. Experimental System
11.1.1. HPLC System
HPLC Model: Waters
Pump: Waters 600E
Injector: Waters WISP 717
Detector: Waters 2487
Data System: H-P 3396B Integrator
Precolumn: Phenomenex, SecurityGuard, C18, 4.0 x 3.0 mm ID
Column: Phenomenex, Spherex, C18, 5µ, 250 x 4.6 mm ID
Temperature: Ambient
Detection: 500 nm, 0.4000 AUFS
Mobile Phase: A: 0.05 M HCO NH2, p4 3.6/5% ACN (Acetonitrile);
B: 100% ACN
Gradient: 100% A hold for 6 minutes; linear change to 25% A/75% B over 1
minute; hold for 5 minutes; linear change to 100% A over 1
minute; hold at 100% A for 15 minutes.
Flow Rate: 1.0 mL/min
Injection Volume: 10 L
11.1.2. Apparatus
Balance: Mettler AG 245, accuracy of 0.0001 gram
Glassware: Assorted volumetric glassware
Filters: Millipore 0.2µ Nylon-66; Whatman Puradisc 25PP 0.45µm
Oven: Boekel Model 107905
Pipet:: Mettler VoluMate, 200-1000 µL
11.1.3. Solutions and Reagents
11.1.3.1. Reagents
Water, Fisher, HPLC Grade, Lot # 024948, 025012
Acetonitrile, Baker, HPLC Grade, Lot # M15811
NBD Chloride, Aldrich, 98%, Lot #12214L1
Hydrochloric Acid, Fisher, ACS Grade, Lot # 012161
Potassium Tetraborate Tetrahydrate, Aldrich, 99%, Lot # 15325D1
Formic Acid, Fisher, Laboratory Grade, 90%, Lot # 003630
Ammonium Formate, Fisher, Certified, Lot # 990125
Glyphosate, Sigma, 95%, Lot # 71K36491
652 Annex 56-C
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SLI Study No. 3596.8
1.1.3.2 Solutions
0.37 M Borate Solution: Prepared by dissolving approximately 11.44 g of
potassium tetraborate tetrahydrate in 100 mL of water. The resulting solution
was stable for 6 months under ambient storage conditions.
1.2 N HCl: Prepared by dissolving 10 mL of HCl in 90 mL of water. The resulting
solution was stable for 6 months under ambient storage conditions.
25 mM NBD-Cl: Prepared by dissolving approximately 2.5 g of NBD-Cl in 500
mL of methanol. The resulting solution was stable for 6 months under am
bient
storage conditions.
Mobile Phase A: Prepared by dissolving approximately 3.153 g of ammonium
formate in 1900 mL of water. The pH was adjusted to approximately 3.6 w
ith
formic acid prior to the addition of 100 mL of acetonitrile. The result
ing solution
was mixed thoroughly, filtered through a 0.2µ Nylon-66 filter and degassed by
helium sparging prior to use.
Mobile Phase B: Acetonitrile used 100% as received.
Diluent: All standards and samples were diluted in water.
Stock Standard Solution: Prepared by dissolving approximately 30 mg of
glyphosate standard in a 100 mL flask with diluent.
Standard Solutions: Prepared by serially diluting the stock standard solution with
water. The final concentrations of the solutions were in the range of
approximately 0.02 to 0.14 mg/mL. These solutions were then further diluted in
diluent at a r atio of 3:10 and filtered through Whatman Puradisc 25PP 0.45µ m
filters prior to derivatization.
Purity Solutions: Prepared by diluting 1.0 mL aliquots of each sample to a final
volume of 100 mL with diluent. The solutions were then further diluted in diluent
first at a ratio of 2:50 and then at a ratio of 4:10. The resulting sol
utions were
then filtered through Whatman Puradisc 25PP 0.45 µm filters prior to
derivatization. These preparations were performed in duplicate for each sample.
Derivatization Procedure: In order to analyze the glyphosate component, a
precolumn derivatization was performed by adding 1.2 mL of the appropriat
e
control, standard, or sample solution to a labeled scintillation vial. Both 0.8 mL of
the borate solution and 2.4 mL of the NBD- Cl solution were added to each vial.
The vials were then capped and shaken by hand prior to being heated in an oven
653Annex 56-C
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SLI Study No. 3596.8
at 80° C for 30 minutes. After removal from the oven, the vials were allowed to
cool for 10 minutes followed by the addition of 0.9 mL of the HCl solution. After
the vials were again shaken by hand, they were allowed to stand for 10 minutes
in order for incipient precipitation to occur. These solutions were then transferred
to injection vials.
11.2. Analytical Procedures
11.2.1. Standard Curve Analysis
The peak areas of the glyphosate acid component of each standard were
determined, measured, combined, and plotted as a function of concentrati
on to
generate a standard curve. The actual values used for the calculations
are
shown in Chemistry Tables 1 and 3.
11.2.2. Sample Analysis
The peak areas of the glyphosate acid component of each sample were
measured and combined and then the concentration was determined by linear
fit
to the standard curve. The actual values used for the calculations are s
hown in
Chemistry Tables 1 and 3.
12. STATISTICAL ANALYSIS
A statistical analysis was conducted on the average results of the % glyp
hosate
(a.e.) for each test article mixture as compared to the theoretical val
ue [14.80%
glyphosate (a.e.) as calculated by the Sponsor] and for the combined results of
all test article mixture samples as compared to the theoretical value using one
way analysis of variance (ANOVA).
13. PROTOCOL DEVIATIONS
No protocol deviations occurred during this study.
14. MAINTENANCE OF RAW DATA AND RECORDS
All original raw data, the final report and magnetically encoded records were
transferred to the SLI archives for a period of 10 years. The Sponsor will be
contacted prior to final disposition of these items.
654 Annex 56-C
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SLI Study No. 3596.8
15. RESULTS
15.1. Analytical Chemistry Results
Individual Data: Tables 1-4
The actual sample results of the before use purity analyses are shown in
Chemistry Table 1. The % errors of the results of the before use purity analyses
are shown in Chemistry Table 2. The actual sample results of the after
use purity
(stability) analyses are shown in Chemistry Table 3. The % errors of the
results
of the after use purity (stability) analyses are shown in Chemistry Ta
le 4. All
concentration values are reported in terms of the acid equivalent (a.e.
) of the
glyphosate. The overall concentration of the Spray Bravo was 16.33 [in terms of
% glyphosate (a.e.)] before use at SLI and 17.04 [in terms of % glyphosate (a.e.)]
after use at SLI, indicating that the test material was stable during u
at SLI.
The average % error (based upon a comparison between the analyzed value and
the theoretical value) for the before use purity analysis was between 4.8 and
20.1%. The average % error (based upon a comparison between the analyzed
value and the theoretical value) for the after use purity (stability) analysis was
between 7.1 and 30.7%.
15.2. Statistical Analysis
Individual Data: Appendix A
Results of the Before-Use statistical analysis indicate that Test Article Mixtures 2,
3 and 5 (17.07, 17.78 and 17.35% glyphosate a.e.) were significantly higher than
the theoretical value (14.8% glyphosate a.e.). However, since these va
lues were
within the possible error rate of field mixing and since these samples w
ere to be
part of a pooled sample for dosing the remaining studies, these samples were
included. Overall, the results of all mixtures for the pooled sample (
16.33%
glyphosate a.e.) were significantly higher than the theoretical value (
4.8%
glyphosate a.e.). Again, this result was considered within possible fi
eld mixing
error and would provide a conservative estimate of toxicity, irritation and
sensitization for the remaining studies. Therefore, the pooled sample wa
s
considered to be acceptable for use.
655Annex 56-C
656 Annex 56-C
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SLI Study No. 3596.8
Chemistry Table 1
Standard Curve and Sample Analysis Values for the Before Us-ePurity Analysis
(6/11/2002)
Theoretical Conc. Actual Conc. [%
Sample Type (mg/L) Peak Area Glyphosate (a.e.)]
Std 1 0.008637 35543 NA
Std 2 0.01727 73477 NA
Std 3 0.02591 110900 NA
Std 4 0.03456 154704 NA
Std 5 0.04320 193670 NA
Test Mix # 1, B NA 112077 15.98
Test Mix # 1, B’ NA 112767 16.08
Test Mix # 1, M NA 114677 16.34
Test Mix # 1, M’ NA 118352 16.84
Test Mix # 1, E NA 126172 17.90
Test Mix # 1, E’ NA 136131 19.25
Test Mix # 2, B NA 128331 18.19
Test Mix # 2, B’ NA 129222 18.31
Test Mix # 2, M NA 133033 18.83
Test Mix # 2, M’ NA 129348 18.33
Test Mix # 2, E NA 117614 16.74
Test Mix # 2, E’ NA 114082 16.26
Test Mix # 3, B NA 106042 15.16
Test Mix # 3, B’ NA 109377 15.61
Test Mix # 3, M NA 108735 15.53
Test Mix # 3, M’ NA 108624 15.51
Test Mix # 3, E NA 110508 15.77
Test Mix # 3, E’ NA 108454 15.49
Test Mix # 4, B NA 119612 17.01
Test Mix # 4, B’ NA 120670 17.15
Test Mix # 4, M NA 125863 17.86
Test Mix # 4, M’ NA 122465 17.39
Test Mix # 4, E NA 119981 17.06
Test Mix # 4, E’ NA 124304 17.64
Test Mix # 5, B NA 98279 14.11
Test Mix # 5, B’ NA 99554 14.28
Test Mix # 5, M NA 96188 13.83
Test Mix # 5, M’ NA 93828 13.50
Test Mix # 5, E NA 98206 14.10
Test Mix # 5, E’ NA 96311 13.84
Correlation coefficient = 0.9996; NA = Not Applicable
Note: B = Beginning; M = Middle; E = End; ‘ = Replicate sample
657Annex 56-C
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Purity)
Chemistry Table 2
Sample Analysis Values and % Error Based on Theoretical Value
SLI Study No. 3596.8
658 Annex 56-C
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SLI Study No. 3596.8
Chemistry Table 3
Standard Curve and Sample Analysis Values for the
After Use-Purity Analysis for (Stability) (8/21/2002)
Theoretical
Conc. Actual Conc.
Sample Type (mg/L) Peak Area (mg/mL)
Std 1 0.008580 29599 NA
Std 2 0.01716 64382 NA
Std 3 0.02574 94096 NA
Std 4 0.03432 124119 NA
Std 5 0.04290 147270 NA
Test Mix # 1, B NA 95077 16.67
Test Mix # 1, B’ NA 94928 16.64
Test Mix # 1, M NA 94778 16.61
Test Mix # 1, M’ NA 85965 15.01
Test Mix # 1, E NA 92202 16.14
Test Mix # 1, E’ NA 106892 18.81
Test Mix # 2, B NA 110867 19.54
Test Mix # 2, B’ NA 110275 19.43
Test Mix # 2, M NA 107060 18.84
Test Mix # 2, M’ NA 107748 18.97
Test Mix # 2, E NA 101906 17.91
Test Mix # 2, E’ NA 98293 17.25
Test Mix # 3, B NA 97602 17.13
Test Mix# 3, B’ NA 97729 17.15
Test Mix # 3, M NA 90909 15.91
Test Mix # 3, M’ NA 89923 15.73
Test Mix # 3, E NA 93383 16.36
Test Mix # 3, E’ NA 90589 15.85
Test Mix # 4, B NA 111212 19.60
Test Mix # 4, B’ NA 113409 20.00
Test Mix # 4, M NA 113974 20.10
Test Mix # 4, M’ Na 107497 18.93
Test Mix # 4, E NA 112424 19.82
Test Mix # 4, E’ NA 100144 17.59
Test Mix # 5, B NA 90451 15.83
Test Mix # 5, B’ NA 86161 15.04
Test Mix # 5, M NA 84031 14.66
Test Mix # 5, M’ NA 71194 12.33
Test Mix # 5, E NA 83091 14.49
Test Mix # 5, E’ NA 73311 12.71
Correlation coefficient = 0.998; NA = Not Applicable
Note: B = Beginning; M = Middle; E = End; ‘ = Replicate sample
'
659Annex 56-C
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Purity for Stability)
Chemistry Table 4
(After Use-
Sample Analysis Values and % Error Based on Theoretical Value
SLI Study No. 3596.8 '
660 Annex 56-C
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SLI Study No. 3596.8
APPENDIX A
Statistical Analysis
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SLI Study No. 3596.8
APPENDIX B
SLI Personnel Responsibilities
670 Annex 56-C
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SLI Study No. 3596.8
SLI PERSONNEL RESPONSIBILITIES
Kimberly L. Bonnette, M.S., LATG Study Director/Director, Acute Toxicology
Dawn D. Rodabaugh, B.S. Alternate Contact/Toxicologist
Robert C. Springborn, Ph.D. Chairman, President and CEO
Malcolm Blair, Ph.D. Senior Vice President, Managing Director
Emeritus
Joseph C. Siglin, Ph.D., DABT Vice President, Managing Director
Jason W. Smedley, B.S. Assistant Toxicologist
M. Gardner Clemons, B.A. Manager of Analytical Chemistry and
Pharmacy
Delores P. Knippen Supervisor of Pharmacy
Anita M. Bosau, RQAP-GLP Senior Director, Compliance Assurance
Deanna M. Talerico, RQAP-GLP Senior Supervisor of Quality Assurance
Kathy M. Gasser Supervisor of Archives
671672 Annex 57
letter bym Srebeccal. PUSkaS to thUnitedStateSenvironmental
Protectionagency, 11 ovember2008
(United States Embassy in Bogotá, 2011)
673674 Annex 57
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embaSSy of thU nitedStateS oa merica, iSt oa erialeradication
v erificatiom iSSion Sin1997
aPPendix: mplementatIon of the verIfIcatIon pJanuary– uly1998,
carried oUtoctober 18-23, 1998
(United States Embassy in Bogotá, 2011)
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UnitedS tateSdePartment ofState, UreaU forinternationalnarcoticS
m atterS, erbicideSelection foc oca eradicatio, may 1984
(United States Department of State, Bureau for International Narcotics Matters,
May 1984)
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