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f TRICLOPYR; ([( 3, 5, 6,- tric 2- pyridinyl)oxy]acetic acid Ref: pp. 129 Table 3 -48 Couuuercial Triclopyr Formulations Formulation Active ingredient Inert ingredients GARLON 3A Triethylamine salt water ethanol emulsifiers surfacants GARLON 4 Butoxyethyl ester kerosene Ref: pp. 129 Triclopyr has NOT been used in the DEA Cannabis eradication para 1 program. Point to If this product is to be used are drift control ponder additives such as Nalco -Trol or Arborchem -38 in- corporated to reduce spray drift. Ref: pp. 130 d. Fate in water para 5 Half of the triclopyr is removed in 4 days. The major breakdown product is oxamic acid (Woodburn et al., 1993). Oxamic Acid: NH COCOOH a high melting cyrstalline acid intermediate between oxalic acid and oxamide. Oxalic Acid: (COOH) or H C 0 is a poisonous strong dicarbaxylic Point to ponder Do we want the breakdown by- product of triclopyr oxalic acid in our water or run off from rain that is a strong poisonous acid. Ref: pp. 136 (a) Surface Water In the DEA program, surface water CAN be contaminated with herbicide if rainfall runs off the treated area carrying herbicides with it. Operating procedures and mitigation measures prohibit direct spray of water resources or when surface runoff (rain) is likely within 48 hours of application. Ref: pp. 138 (b) Groundwater para 1 The majority of the amine (CARLON 3A) will be transported out of the treatment area through movement of groundwater. For the ester ( GARLON 4), an equal amount of the triclopyr will be transported in runoff through movement to groundwater. Ref: pp 143 (2) Aquatic Species para 1 The ester formulation is more toxic to most aquatic organisms than the amine formulation, and the expected enviromrntal concentrations of ester are higher than those of the amine.