EPA 730-N-00-004
                                     WASHINGTON, D.C. 20460

                                   Pesticide Registration (PR) Notice
                                                                                  OFFICE OF
                                                                           PREVENTION. PESTICIDES AND
                                                                               TOXIC SUBSTANCES
       ATTENTION: Persons Responsible for Federal Registrations and Re-registrations of Pesticides.

       SUBJECT:    The Non-Dietary Exposure Task Force


       This PR Notice announces an industry-wide task force to jointly develop residential indoor
       exposure data for pesticides containing one or more of the active ingredients synthetic
       pyrethroids, pyrethrum and synergists. This Notice explains why these data are being developed
       and how registrants may wish to participate in the development of these data by joining the Task
       Force. The Notice identifies an Environmental Protection Agency (EPA) and a Task Force
       contact for persons wanting further information.

       The Federal Food, Drug, and Cosmetic Act (FFDCA) Requirement To Consider Available
       Exposure Information

       The FFDCA requires EPA to consider available information concerning dietary and non-dietary
       routes of exposure when assessing a pesticide's residue risks, especially to children. The Non-
       Dietary Exposure Task Force ("Task Force" or "NDETF") was formed in July, 1997 to jointly
       develop residential indoor exposure data on pesticides containing synthetic pyrethroids,
       pyrethrum and synergists (through the representative synergist piperonyl butoxide) as active
       ingredients ("the active ingredients"). NDETF data, once developed, will be one  form of
       available data that may inform decisions on pesticide residue tolerances as well as registration
       and reregistration activities for pyrethroids as well as other active ingredients to which the data
       may relate. Applicants and registrants seeking to rely on NDETF to satisfy any applicable EPA
       data submission requirements must comply with the applicable provisions of section 3(c)(l)(F)
       and 3(c)(2)(B) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) regarding
       data compensation.

III.    Residential Indoor Exposure Data

       The N DETF,  in consultation with scientists from EPA, the California Environmental Protection
       Agency (Cal-EPA), Canada's Pest Management Regulatory Agency (PMRA) and the Health
       Safety Executive (UK), has designed, through pilot studies, a program to assess the
       transferability of the active ingredients following different types of applications. The studies will
       utilize standardized application methods, validated analytical methods and measure
       transferability and photodegredation on carpet and vinyl flooring surfaces. While the class of
       active ingredients referred to as synthetic pyrethroids includes a spectrum of substances, the
               Recycled/Recyclable . Printed wRh Vegetable OH Based Inks on 100% Recycled Paper (40% Postconsumer)

       NDETF intends to test a range of synthetic pyrethroids that could be representative of the class in
       addition to the Task Force's testing of pyrethrum and piperonyl butoxide.

       EPA will consider relevant, available information regarding dietary and non-dietary routes of
       exposure  as part of a registration application or amendment, a reregistration eligibility
       determination or a pesticide residue tolerance assessment.  EPA has relatively few studies
       assessing indoor exposure to pesticides.  In the absence of studies that can be used to accurately
       assess such exposures, EPA will use appropriate estimates or other modeling to assess potential
       exposures.  The development of indoor exposure studies would likely provide EPA with a more
       accurate tool for assessing these exposures. In some instances, EPA may in the future determine
       that development of indoor exposure data is in fact necessary to support applications, existing
       registrations, or tolerance assessments (and reassessments). Pesticide registrants and applicants
       wishing to develop such data may wish to participate in the NDETF.

       Any pesticide registrants or applicants who believe they may need to satisfy indoor residential
       exposure requirements in the future or believe such data may better inform EPA's assessments
       may wish to presently join the Task Force. Should EPA impose a requirement to submit or cite
       indoor residential exposure data or should an applicant or registrant otherwise rely on NDETF
       data [to support or maintain registration], a registrant or applicant electing to participate in
       NDETF's study, must at the appropriate time,  inform the agency of its election of this option and
       provide evidence of its membership in the Task Force or evidence that it has complied with any
       applicable data compensation requirements. In accordance with FIFRA, in the event that the
       NDETF and a non-member who cites to NDETF's data to satisfy a data submission obligation
       are unable to reach agreement, the terms and amount of compensation shall, upon the request of
       either party, be determined by binding arbitration, as provided in sections 3(c)(l)(F) and
       3(c)(2)(B) of FIFRA.

TV.    Current Members

       Current Members of the Task Force are Aventis Environmental Science (formerly AgrEvo
       Environmental Health), Botanical Resources Australia, Ltd., Endura S.p.a., McLaughlin
       Gormley King Company, Premiss Incorporated, Pyrethrum Board of Kenya, S.C. Johnson &
       Son, Inc., and Takasago International.

V.     Joining the NDETF

       The Agency is not a participant in the NDETF but is available as the Agency deems appropriate
       to provide guidance and assistance relating to the development of the data. As noted, the Agency
       and other regulatory authorities have provided input to the NDETF. The following information
       was supplied to EPA by the NDETF for the benefit of registrants and applicants of the active
       ingredients interested in joining the Task Force: The NDETF is organized under a FIFRA joint
       data development agreement with certain common developmental costs shared equally among all
       registrants and certain costs shared according  to the number active ingredients registered by the
       registrant. Membership is available for a period of six months from the date of issuance of this
       PR Notice upon payment of an appropriate share of prior member assessments, adjusted for
       interest.  Thereafter, membership is available by paying an appropriate share of all assessments,

       interests and certain late fees. Each participating company has the right to appoint one
       representative to the Steering Committee and the Technical Committee of the NDETF Those
       desiring further information on the Task Force niay contact the following:

              Paul Keane, Chairman, Steering Committee, Non-Dietary Exposure Task Force 47 West
              Division Street, Suite 389, Chicago, IL 60610.
                    Phone: (312)664-4781                                  
                    Fax:   (312)664-0728
                    Email:  Pkeane2100@aol.com

              Tom Osimitz, Ph.D., Chairman, Technical Committee, Non-Dietary Exposure Task
              Force, S.C. Johnson & Son, Inc., 1525 Howe Street, M.S. 122 Racine  WI 53403
                    Fax:   (414)260-0186
                    Email:  tgosimit@scj.com

VI.    What the NDETF Will Do

       The work product expected to be developed and submitted by and through the NDETF will
       include but is not limited to the following study reports for the active ingredients that are the
       subject of the program:

             Method Development for Measurement of Transferable Residues from Vinyl Flooring
             and Carpet Using the Indoor Roller.

             Method Development for Measurement of Transferable Residues from Vinyl Flooring
             and Carpet Using the Drag Block/Drag Winch.

             Measurement of Residue Transfer of Active Ingredients From Treated Carpet and Vinvl
             Flooring to Human Hands.

             Fate of Active Ingredients in a Household Spray Formulation Exposed to Various Indoor
             and Outdoor Lighting Conditions.

             Post-Application Deposition Measurements for Active Ingredients Following Use of a
             Total Release Indoor Fogger.
      It is possible that the program will include additional study reports and it is possible that certain
      use patterns, uncommon formulations, or other situations may arise for which EPA might require
      separate indoor residential exposure data from an applicant or a registrant that would not be
      available through the work performed by the Task Force.

      This PR Notice is issued by the Agency for the sole purpose of informing pesticide registrants
      and applicants of the formation of the NDETF. It is not intended to define or restrict the terms of
      or subsequent amendments to the joint data development agreement and its operation

VII.   For Further Information

       For questions or further information regarding the NDETF, please contact Alan Dixon at
       (703) 305-7237.
                               ia E. Mulkey, Director Office of Pesticide Programs