2,4-D JMPR 1975 Explanation The Joint Meeting in 1970 considered the use of 2,4-D as a selective herbicide on a range of cereal crops and data on the nature and fate of residues therein (FAO/WHO 1971). Recommendations were not made for maximum residue limits until an acceptable daily intake was established in 1971. (FAO/WHO 1972). In 1974 the use of 2,4-D as a pre- and post-harvest treatment for citrus fruit and as a growth regulator for potatoes was also evaluated and recommendations were made (FAO/WHO 1975). In view of the world-wide use of 2,4-D herbicides it was considered that the residue data, originating mainly in Europe, examined in 1970 possibly did not reflect the practices in countries with more extensive agriculture. Requests were therefore made for further data on the nature and level of 2,4-D residues in cereal crops. The Codex Committee on Pesticide Residues at its 8th Session in 1975 expressed the view that the maximum residue limits proposed were too low (ALINORM 76/24 para 85). This monograph addendum confirms the necessity for a higher limit for 2,4-D residues in raw grain. The additional data which became available are summarized in this monograph addendum. EVALUATION FOR ACCEPTABLE DAILY INTAKE BIOCHEMICAL ASPECTS Absorption, distribution and excretion Following a single administration by gastric intubation to albino rats of sodium and diethylamine salts of 2,4-D at the doses of 555 and 405 mg/kg respectively (the doses corresponding to the LD50 for these compounds) the highest blood concentrations were reached after 3 hours. The half-retention periods were of 1 hour for the sodium salt and 72 hours for the diethylamine salt. Three hours after treatment the organs with the greatest distribution of the diethylamine salt were the liver and kidneys; the highest levels of this salt in tissues (heart, liver, kidney, muscles and brain) were observed 24 hours after administration and there was a substantial decrease after 10 days after the treatment. In the same study, albino rats were given by gastric intubation, daily doses corresponding to 1/20 and 1/5 respectively of the LD50 of 2,4-D (23 and 91 mg/kg), sodium salt of 2,4-D (28 and 111 mg/kg), diethylamine salt of 2,4-D (20 and 80 mg/kg) and 2-methyl-4-chlorophenoxypropionic acid (49 and 1975 mg/kg) for a period of 50 days. The tissue distribution (heart, liver, kidneys, muscles and brain) at the end of the testing period was found to be dose dependent (Buslovish et al., 1973) TOXICOLOGICAL STUDIES Special studies in teratogenicity Groups of 3-month old NMRI female mice randomly bred were injected subcutaneously with levels of 0, 50, 100 mg/kg bw of commercial mixture of 2,4-D and 2,4,5-T in dimethyl sulfoxide solution from day 6 through day 14 of gestation. The content of dioxins of the mixture was less than 1 ppm and the most common dioxin was 2,3,7,8-tetrachlorodibenzo-p-dioxin. On day 18 of gestation, the animals were sacrificed, living foetuses removed, weighed and examined for gross malformation; microscopic examination for internal malformation was also carried out. At high dose foetal mortality was significantly increased, the frequency of cleft palate was increased, foetal weight considerably reduced, skeletal malformations were double with respect to the other group and controls, subcutaneous bleeding was three times as common, renal malformation such as dilated renal pelves, smaller and opaque medullae were slightly increased (Bage et al. 1973). OBSERVATIONS IN MAN Seventeen farm workers concerned with the transport of derivatives of chlorophenoxy acetic acid were examined by electroencephalography before and after massive exposure. EEG tracings before exposure showed slight abnormalities in 7 cases. After 4 to 28 days of exposure disturbances of the cerebral bioelectrical activities were observed in 11 cases. In 5 of these cases overt pathological changes were observed in EEG tracings as revealed by the slowing down of the basal frequency and the presence of slow, high amplitude theta waves (Kontek et al., 1973). A man lost consciousness 2-3 hours after inhalation of vapours originating from a spraying pump containing a herbicide formulation (44% 2,4-D). Early manifestations included urinary incontinence and vomiting followed by myalgia, muscular hypertonia, slight fever, headache and constipation as well as intermittent nodal tachycardia as revealed by EEG. The cardiac arrhythmia and muscular hypertonia gradually subsided within 5 days of administration of quinidine hydrochloride (450 mg/day, 7 days). No abnormalities in the thyroid functions were observed. The patient was released from hospital in good health after 23 days (Paggiaro et al., 1974). Comments An ADI for man of 0 - 0.3 bw was allocated for this compound at the 1971 Joint Meeting. Since then further studies have become available on tissue distribution after gastric intubation to rats of sodium and diethylamine salts of 2,4-D. These studies supplement earlier studies in rodents. A teratology study in mice administered 2 4-D by subcutaneous injection showed no embryotoxic or teratogenic effect at 50 mg/kg body weight. Effects were found at 100 mg/kg. The results confirmed the no-effect level in earlier oral studies in rodents. Reports on apparent effects from occupational exposure to phenoxy herbicides were noted. The previously estimated ADI was reaffirmed. TOXICOLOGICAL EVALUATION Level causing no toxicological effect Rat: 625 ppm in the diet equivalent to 31 mg/kg bw Estimate of acceptable daily intake for man 0 - 0.3 mg/kg bw RESIDUES IN FOOD AND THEIR EVALUATION USE PATTERN No information on new use patterns has become available and, in view of the fact that 2,4-D herbicides have been in world-wide use for more than 25 years it is assumed that there have been no now developments. Depending on the type of cereal crop, the weed spectrum, cultural practices and climatic factors, 2,4-D herbicides may be applied as salts, esters, amines or free acid formulations at rates ranging from 250 g to 2 kg/ha (rarely up to 4 kg/ha). Application is usually made when weeds and cereal crop plants are small but in the case of maize (corn) and sorghum, treatment may be necessary when the crop is well advanced. With some varieties of wheat early treatment is essential to avoid phytotoxic damage which may occur once the seed-head has begun to develop. Usually wheat and oats are treated when the crop is 10-15 cm tall and maize (corn) when 30-35 cm tall. However, when tall weeds growing up in the crop make harvesting difficult, if not impossible, 2,40 herbicides nay be applied 14-21 days prior to harvest to destroy, defoliate or regulate the growth of the weeds so as to prevent interference with harvesting. During 1966 the US production of 2,4-D exceeded 31 000 000 kg (USA 1967). World consumption is estimated to exceed 50 000 000 kg. RESIDUES RESULTING FROM SUPERVISED TRIALS Cereal grains Data derived from supervised residue trials carried out in various regions of the USA have been provided by the US Department of Agriculture. These data were generated during the years 1960, 1961 and 1965 and represent typical use patterns involving amine salt, butyl, iso-octyl, isopropyl and polypropylene glycol butyl ether ester formulations of 2,4-D. The residue analysis was carried out by the US FDA. Early post-emergence application Grain samples collected from plots sprayed 3-4 weeks after emergence with various formulations of 2,4-D were found to contain no residues of 2,4-D (limit of determination of 0.01-0.04 mg/kg) except in the case of oats, and then only when 4 kg/ha was applied. Wheat grain from crops receiving the same heavy application was free from residues. Pre-harvest application Trials carried out in Kansas during 1960 involved the application of butyl, isopropyl and iso-octyl esters of 2,4-D at 1 and 10 kg 2,4-D/ha at intervals ranging from 5 to 23 days before harvest. The residue levels found are set out in Table 1. The data in Table 1 indicate that there is a noticeable accumulation of 2,4-D residues in the grain during the two weeks following application when treatment is made within 3 weeks of harvest. This is not unexpected in view of the systematic properties of the herbicide. However the amount of 2,4-D found in grain is not particularly great following normal rates of application, reaching levels above 0.5 mg/kg only at excessive rates of the order of 10 kg/ha. TABLE 1. Residues of 2,4-D in wheat following application of 2,4-D ester Pre-harvest interval Ester Rate. kg/ha days Residue, mg/kg butyl 1 15 0.07 1 10 0.05 1 5 0.06 10 15 2.45 10 10 1.50 10 5 0.60 isopropyl 1 17 0.05 1 11 0.04 1 5 0.02 10 17 0.22 10 11 1.18 10 5 0.44 Iso-octyl 1 23 0.09 1 18 0.40 1 13 0.27 1 8 0.05 10 23 0.73 10 18 1.06 10 13 0.84 10 8 0.51 The tendency to accumulate in grain during the post-application period was confirmed by trials in Nebraska in 1960, in which the residues resulting from treatment 20 days before sampling were compared with those in the grain at application. The data presented in Table 2 show that the residue level is higher after 20 days and increases as the rate of application is increased. From the limited data it would appear that slightly more residues accumulate from the use of the water-soluble amine formulation than from the oil soluble ester form. Volatility of the latter could play a part. TABLE 2. Residues of 2,4-D in grain on day of application and after 20 days Pre-harvest interval Formulation Rate, kg/ha (days) Residues, mg/kg ester 0.5 0 0.04 1 0 0.11 2 0 0.11 amine 1 0 0.05 ester 0.5 20 0.09 1 20 0.14 2 20 0.34 amine 1 20 0.27 Trials carried out in Kansas compared the residues of 2,4-D resulting from the use of the water-soluble dimethylamine salt with those from the volatile isopropyl ester and the less volatile iso-octyl ester. The results, which are presented in Table 3, generally support the observation that lower residues result from the use of the volatile ester than from the amine salt and the less-volatile ester. The difference is, however, not great. TABLE 3. 2,4-D Residues on Bison Wheat harvested at Hays, Kansas, at various intervals after treatment Residue, mg/kg after pre-harvest interval, days 7 14 21 Dimethylamine salt 0.0 lb/acre 0.05 0.01 0.02 0.5 0.16, 0.08, 0.10 0.19, 0.18 0.06, 0.06 1.0 0.29, 0.06 0.31, 0.15 0.09, 0.12 2.0 0.39 0.50 0.29, 0.22 4.0 1.24 1.46 0.32 Isopropyl ester 0.0 0.07 0.02 0.01 0.5 0.05, 0.16, 0.11 0.03, 0.06, 0.03 0.04, 0.04, 0.05 1.0 0.14, 0.22 0.15, 0.09 0.06, 0.04, 0.06 2.0 0.21, 0.49 0.31, 0.31 0.13, 0.17 4.0 0.78 1.80 0.38 Iso-octyl ester 0.0 0.02, 0.02 0.0, 0.01 0.0, 0.03 0.5 0.12, 0.12 0.10 0.15, 0.11 0.04, 0.06, 0.07 1.0 0.18, 0.26, 0.36 0.35, 0.23, 0.23 0.09, 0.05, 0.16 2.0 0.35, 0.45 0.63 0.15, 0.22 4.0 1.31 1.16 0.53 Cochrane and Russell (1975), using the extraction procedure of Yip (1962) found that when mixed n-butyl/isobutyl ester was applied at the rate of 430 g/ha to young wheat plants (three-leaf), the ester was immediately converted into free 2,4-D acid. Immediately after application 8.35 mg/kg of 2,4-D was found in the wheat plants and this level declined to 1.87 mg/kg on the third day after treatment. Thereafter decline continued at a rapid rate to less than 0.01 mg/kg after 44 days. No trace of 2,4-D could be found in grain or straw at harvest 80 days after treatment. Studies made at the University of California (Harvey, 1970) of the residues resulting from the application of 2,4-D amine to barley, oats and wheat at various growth stages have revealed that the residues in grain at harvest vary according to the growth stage at time of treatment. These data indicate that even though the residue in the whole plant exceeded 10 mg/kg 7 days after application, there was a steady decline in the residue level, so that less than 3 mg/kg remains in the straw and less than 0.3 mg/kg in the grain at harvest. The results of these studies are summarized in Table 4. Klingman et al (1966) found 58 mg/kg 2,4-D acid one half-hour after applying 2.25 kg butyl ester/ha and this decreased to 5 mg/kg on the fifth day. Lokke (1975) developed improved analytical techniques for the determination of 2,4-D and amino acid conjugates in cereal grains and with these found that the application of 4 kg (4 times the normal rate) of 2,4-D per ha to barley at the three-leaf stage resulted in residues of only 0.04-0.06 mg/kg in the grain at harvest. By conventional methods of extraction the same grain was estimated to have less than 0.02 mg/kg of 2,4-D. Treatment made at the same excessive rate after the spikes formed on barley left residues of 0.35-0.45 mg/kg when measured by the method of Lokke (1975) or Yip (1971). By direct extraction methods, only 0.04 mg of 2,4-D could be recovered per kg of barley. Lokke reported that treatment at the same rate after the green grains were fully formed resulted in residues of 4.0-4.3 mg/kg. This is 8-10 times higher than the residue found in the same sample by conventional extraction procedures. In Sweden and other Scandinavian countries where the harvesting of berries and mushrooms regularly takes place in forests, the use of 2,4-D and 2,4,5-T herbicides has become a regular feature of forest management to regulate the growth of underbrush. Erne and Hartman (1973) made an extensive study of the residues of 2,4,5-T in mushrooms and both 2,4-D and 2,4,5-T in berries harvested in forests following the aerial and ground application of brush control herbicides. The results of their findings with respect to 2,4-D are summarized in Table 5. TABLE 4. 2,4-D residues in whole plant, grain and straw following treatment at different stages of growth Residues found at different growth stages, mg/kg (Intervals from treatment/days) Application Stage of Late Mature Mature Mature Crop rate kg/ha treatment Tillering Tillering Boot Harvest Dried (plant) (grain) (straw) Oats 0.75 Tillering 4.4 2.7 1.1 0.57 - - 0.05 1.8 1.5 " 12.3 5.2 2.8 0.77 - - 0.07 2.6 (7) (14) (28) (56) (110) (110) Barley 0.75 Late - 0.84 - 0.37 0.18 - 0.03 0.48 1.5 tillering - 9.5 - 1.2 0.28 - 0.02 0.85 (7) (15) (28) (63) (63) Barley 0.75 Late boot - - - 6.5 2.8 2.6 0.14 2.3 1.5 " - - - 13.8 7.7 6.5 0.3 5.5 (7) (14) (28) (49) (49) Wheat 0.75 Tillering - 5.5 2.3 - 0.31 - 0.02 0.11 1.5 " - 17.5 8.2 - 0.45 - 0.02 0.11 (7) (14) (28) (65) (65) Wheat 0.75 Boot stage - - - - 4.8 0.6 0.02 0.54 1.5 " - - - - 13.5 1.5 0.02 1.10 (7) (28) (50) (50) Barley 0.75 Tillering 3.3 - 1.0 - 0.02 - 0.02 0.02 1.5 " 11.8 - 2.4 - 0.35 - 0.02 0.05 (7) (14) (28) (58) (58) Barley 0.75 Boot stage - - - 4.5 3.1 - 0.02 0.03 1.5 " - - - 14 7.7 - 0.03 0.02 (7) (14) (43) (43) TABLE 5. Residues of 2,4-D in berries resulting from the aerial spraying of forests Residue, mg/kg, at interval, days, after spraying. (No. of samples in parenthesis) Rate of Application Commodity kg/ha 2-5 10-14 24-32 Raspberries 1.375 0.4-0.9 0.3-0.6 <0.03-0.3 (3) (3) (3) Lingonberries 0.980 2.6-7.7 0.8-7.0 1.2-3.6 " (3) (8) (9) " 1.290 0.8-3.5 0.4-1.0 1.2-2.5 (3) (3) (3) " 1.075 - - 0.7-2.7 (3) " 0.980 - 0.3 0.6-0.8 (1) (2) " nil <0.03 <0.03 <0.03 " 1.075 1.5-4.0 1.2-2.0 0.7-2.0 (3) (3) (3) " 1.015 2.0 0.9-1.5 - (3) (3) Bilberries 1.290 2.0-2.4 0.5-1.3 0.9-1.8 (3) (3) (3) " 1.075 1.4-2.9 1.3-2.5 - (4) (3) " nil <0.03 <0.03-0.2 (1) (2) FATE OF RESIDUES In plants An enormous amount of research has been carried out over more than 25 years on the mode of action of 2,4-D, the reason for its selective action and the mechanisms of degradation in plants. Loos (1969) has published a 50 page review including references to 166 papers on the degradation of phenoxyalkanoic acids of which 2,4-D is by far the most important. Only a few of the basic principles can be touched upon in this monograph. In the experiments referred to in the previous section (p. 179), Klingman et al (1966) found that virtually all the butyl and 75% of the 2-ethylhexyl esters of 2,4-D had been hydrolized to the acid within 30 minutes after application to forage. When 2.25 kg butyl ester per ha was applied, initial residues of 58 mg/kg decreased to 5 mg/kg in five days. This work confirmed studies with radio-labelled 2,4-D (Crafts, 1960) and others in which residues were determined by bioassay (Morré and Rogers, 1960) or gas chromatography (Hagin and Linscott, 1965). Similar trials by Cochrane and Russell (1975), in which the butyl ester was applied to wheat, were described in the previous section (p.179). No trace of butyl ester was found after the application of 430 g/ha, but residues of 8.35 mg/kg of the free acid were found immediately after application and decreased rapidly. There appear to be three principal mechanisms for the metabolism of 2,4-D by plants, viz. degradation of the acetic acid side chain, hydroxylation of the aromatic ring and conjugation with plant constituents. Degradation of the side chain has been observed in many plants but in only a few species or varieties does it appear to play a major role in the breakdown of herbicidal activity. Loss of the side chain from a phenoxyacetic acid without further metabolic changes to the molecule would yield the corresponding phenol. Luckwill and Lloyd-Jones (1960) and Chkanikov et al. (1965) have demonstrated the production of 2,4-dichlorophenol in strawberries, beans, sunflowers, corn and barley. Simultaneously the side-chain carbon atoms are released as CO2 in some plants. Fawcett et al. (1959) showed that wheat and pea tissue hydroxylated 2,4-D in the 4-position. Similar reactions were observed in oats, barley and maize (corn), but not in various legumes, by Wilcox et al. (1963). The identity of the principal 2,4-D metabolite in bean, which was believed by Holley (1952) and Crosby (1964) to be a hydroxyphenoxyacetic acid, was studied by Thomas et al. (1964) who confirmed the major phenolic acid as 2,5-dichloro-4-hydroxyphenoxyacetic acid and the minor phenolic acid as 2,3-dichloro-4-hydroxyphenoxyacetic acid. The 4-hydroxylation of 2,4-D in bean was thus made possible by a chlorine shift from the 4 to the 5 or 3 position. These two metabolites accumulate in bean as the glucosides. The esterification of glucose with phenoxyacetic acids has been observed. Klambt (1961) reported the formation of the glucose ester of 2,4-D in wheat, and Thomas et al. (1964) reported that oats converted 2,4-D to its beta-D-glucose ester. Aspartic acid combines with 2,4-D to form 2,4-dichlorphenoxyacetyl-aspartic acid in wheat (Klambt, 1961) and probably in other plants. Feung et al. (1971, 1972, 1973a, b) demonstrated that 2,4-D is rapidly conjugated by means of an amide bond with a number of amino acids. Seven amino acid conjugates have been isolated and identified (glutamic and aspartic acids, alanine, valine leucine, phenylalanine, tryptophane) and these have been shown to have 2,4-D-like herbicidal activity (Feung et al., 1974). Such conjugation cannot be considered as a detoxification mechanism but perhaps as an activation step. Feung et al., 1974, have postulated that the conjugated form of 2,4-D could be exclusively the physiologically active form. Feung et al. (1975) demonstrated that the two ring-hydroxylated metabolites (4-OH-2, 5-dichloro and 4-OH-2, 3-dichloro) which together represent 97% of the soluble metabolites do not possess any growth-stimulating activity and exist as aglycones. In later studies, corn, the only monocotyledon tested, was shown to produce also 3-hydroxy-2, 4-dichlorophenoxyacetic acid (3-OH-2, 4-D) and 4-hydroxy-2-chlorophenoxyacetic acid which were not found in other plants tested. The authors were prompted to suggest that corn possess a significant alternative pathway of metabolism that may account for its resistance to herbicidal quantities of 2,4-D. On the other hand Hagin et al. (1970) have shown that three grasses metabolize 2,4-D to 2,4-dichlorophenoxypropionic acid, which is biologically inactive and this is assumed to be a major detoxification mechanism of these grasses. In animals Jensen and Miller (1975) report studies in which chickens were fed rations containing 10 or 100 mg/kg 2,4-D for 30 days. Tissue samples and eggs from these birds were analysed for residues of 2,4-D and 2,4-dichlorophenol using a method which had a validated sensitivity of 0.05 mg/kg for either compound. No dichlorophenol was detected in any sample. The average 2,4-D residues found are given in Table 6. TABLE 6. 2,4-D residues in chickens fed 2,4-D in the diet 2,4-D residues (mg/kg) 2,4-D in diet (mg/kg) muscle/skin fat liver eggs 10 <0.025 <0.025 <0.05 <0.025 100 <0.2 <0.05 0.5 0.1 There is no reasonable expectation of residues in poultry tissues and eggs from ingestion of feeds containing up to 10 mg 2,4-D/kg. This level is far above the amount of 2,4-D (<0.2 mg/kg) that might be expected from treatment of crops used for chicken feed. EVIDENCE OF RESIDUES IN FOOD IN COMMERCE OR AT CONSUMPTION The only new information on the incidence and level of 2,4-D residues in food in commerce came from Hungary. In 1974 56 samples of barley, oats, rye and wheat from lots which were known to have been treated with 2,4-D were analysed by food inspection laboratories. None of the samples contained residues above the limit of determination (0.005 mg/kg). Whether these laboratories used methods capable of measuring conjugated residues is not known. METHODS OF RESIDUE ANALYSIS Several studies, reviewed by Loos (1969) and Feung et al. (1973a,b) have confirmed the conjugation of chlorophenoxy acids, including 2,4-D, with plant constituents. The conjugates are suggested to consist mainly of combinations of chlorophenoxy acids and amino acids. In spite of this these conjugates are not hydrolysed during most of the published analytical methods for chlorophenoxy acids. Chow et al. (1971) studied the original procedure of Yip and Nay (1966) which involves extraction (without hydrolysis) with 50% diethyl ether/hexane in the presence of sulphuric acid. By heating wheat plant tissue under alkaline conditions they found that less than 25% of the residue could be accounted for by analysing only the organic phase as in the Yip and Nay (1966) method. Lokke (1975) following the lead of Chow et al. (1971) developed a procedure involving hydrolysis of the starch under acidic conditions followed by treatment with diastase and further hydrolysis of amino acid conjugates through the action of proteolytic enzymes. These steps resulted in a considerable increase in the yield of 2,4-D residues from barley treated at various stages of growth with 2,4-D. The proteolytic enzyme (papain or ficin) was shown to be responsible for releasing about 50% of the 2,4-D found. In parallel experiments Lokke found that a straightforward extraction with 65% acetonitrile (Yip, 1971) gave comparable recovery. In the light of the efficient liberation of residues through hydrolysis by proteolytic enzymes, it is remarkable that the simple extraction with acetonitrile is of similar efficiency. Lokke went on to show, however, that neither the extraction procedure nor the enzymic hydrolysis can be considered completely exhaustive. It is not yet clear what amounts of 2,4-D conjugates remain after either of these procedures have been applied to grain. Glas (1975) has used aqueous sodium hydroxide to extract 2,4-D from grain and straw before purification on an alumina microcolumn for GLC quantitation using an electron capture detector. NATIONAL TOLERANCES REPORTED TO THE MEETING Particular attention was drawn to the following tolerances which have been established in national legislation (Table 7). TABLE 7. National tolerances reported to the meeting Country Commodity Tolerance mg/kg USA forage of barley, oats, rye and wheat 20 grain of barley, oats, rye and wheat 0.5 flour of barley, oats, rye and wheat 0.5 other milled fractions of barley, oats, rye and wheat 2 potable water 0.1 APPRAISAL In response to the requirements of the 1970 Meeting, data from supervised trials on grain crops were received, together with a number of papers published on the degradation of 2,4-D in plants and soils and on the nature and measurement of conjugates in plants. Some information was also received on 2,4-D residues in food sampled in commerce. Most of the supervised trials were conducted in the 1960/65 period and there is now evidence that the extraction methods then in use only recovered a portion of the free 2,4-D and none of the residue conjugated with amino acids. More recent experimental evidence indicates that there may be more significant residues present in grain at harvest following approved use of 2,4-D herbicides than was revealed in most of the data generated previously. On the basis of this evidence a higher maximum residue limit is recommended. Following the application of 2,4-D herbicides for brush control in forests in Sweden an extensive published study indicates that significant amounts of 2,4-D residue will be found in raspberries, lingonberries and bilberries harvested from the treated forests. The Meeting felt justified in extending limits based on this study to other vaccinium berries and blackberries. Maximum residue limits for 2,4-D in these berries are therefore recommended. Since 2,4,5-T is usually combined with 2,4-D in brush-killing herbicides used in forests and in view of the evidence that residues of 2,4,5-T can occur in berries and mushrooms, it would appear to be necessary to recommend maximum residue limits for 2,4,5-T in these commodities also. RECOMMENDATIONS Previous recommendations for maximum residue limits are amended (raw grain) and new recommendations are made (berries) as follows. MAXIMUM RESIDUE LIMITS Commodity Limit, mg/kg Milk and milk products 0.05* Meat and eggs 0.05* Raw grain 0.2 Vaccinium berries e.g. lingonberries, bilberries 5 Blackberries, raspberries 5 * At or about the limit of determination REFERENCES Bage, G., Cekanova, E. and Larson, K. D. (1973) Teratogenic and embryotoxic effects of the herbicide Di- and Trichlorophenoxyacetic acids (2,4-D and 2,4,5-T). Acta pharmacol. et toxicol., 32:408-416. Buslovich, S. Yu., Voinova, I. V. and Milchina, G. (1973) Distribution of herbicides (phenoxy acid chloroderivatives) in the blood of albino rats. Gig. Tr. Prof. Zabol., 17(3):35-37 Chkanikov, D. I., Pavlova, N. M. and Gertsuskii, D. F., Khim, V. (1965) Sel'skom Khoz., 3:56 (in Russian); through CA, 63, 8250c Chow, C., Montgomery, M. L. and Yu, T. C. (1971) Bull. Env. Cont. & Toxicol., 6:576-580 Cochrane, V. P. and Russell, J. B. (1975) Residues in wheat and soil treated with the mixed butyl esters of 2,4-D. Canad. J. Plant Sci., 55:323-325 Crafts, A. S. (1960) Evidence of hydrolysis of esters of 2,4-D during absorption by plants. Weeds, 8:19 Crosby, D. G. (1964) J. Agric. Food Chem., 12:3 Erne, K. and Heartman, U. von. (1973) Fenoxisyrarester i skogsbar och svamp (Phenoxy acid esters in berries and mushrooms) Var Foda, 25 (8-9): 146-153 Fawcett, C. H., Pascal, R. M., Pybus, M. B., Taylor, H. F., Wain, R. L., and Wightman, F. (1959) Proc. Roy. Soc. (London) B150, 95 Feung, C. S., Hamilton, R. H., Witham, F. H. (1971) J. Agr. 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See Also: Toxicological Abbreviations D, 2,4- (AGP:1970/M/12/1) D, 2,4- (WHO Pesticide Residues Series 1) D, 2,4- (WHO Pesticide Residues Series 4) D, 2,4- (Pesticide residues in food: 1980 evaluations)