United States
              Environmental Protection
              Agency	
Prevention, Pesticides
and Toxic Substances
(7508C)	
EPA738-F-00-001
June 2000
              Bensulide  Facts
       EPA has assessed the risks of bensulide and reached an Interim Reregistration Eligibility
Decision (IRED) for this organophosphate (OP) pesticide. With the risk mitigation measures required,
bensulide fits into its own "risk cup"-- its individual, aggregate risks are within acceptable levels.
Bensulide also is eligible for reregistration, pending a full reassessment of the cumulative risk from all
OPs.
       Bensulide residues in food and drinking
water do not pose risk concerns. With
mitigation limiting homeowners' and children's
exposure via home lawns and other turf,
bensulide fits into its own "risk cup." With
other mitigation measures, bensulide's worker
and ecological risks also will be below levels of
concern for reregistration.

       EPA's next step under the Food Quality
Protection Act (FQPA) is to complete a
cumulative risk assessment and risk
management decision encompassing all the OP
pesticides, which share a common mechanism
of toxicity.  The interim decision on bensulide
cannot be considered final until this cumulative
assessment is complete. Further risk mitigation
may be required at that time.

       EPA is reviewing the OP pesticides to
determine whether they meet current health and
safety standards. Older OPs need decisions
about their eligibility for reregistration under
FIFRA.  OPs with residues in food, drinking water, and other non-occupational exposures also must be
reassessed to make sure they meet the new FQPA safety standard.
      The OP Pilot Public Participation Process

           The organophosphates are a group of
    related pesticides that affect the functioning of the
    nervous system. They are among EPA's highest
    priority for review under the Food Quality Protection
    Act.
           EPA is encouraging the public to
    participate in the review of the OP pesticides.
    Through a six-phased pilot public participation
    process, the Agency is releasing for review and
    comment its preliminary and revised scientific risk
    assessments for individual OPs.  (Please contact
    the OP Docket, telephone 703-305-5805, or see
    EPA's web site, www.epa.gov/pesticides/op .)
           EPA is exchanging information with
    stakeholders and the public about the OPs, their
    uses, and risks through Technical Briefings,
    stakeholder meetings, and other fora. USDA is
    coordinating input from growers and other OP
    pesticide users.
           Based on current information from
    interested stakeholders and the public, EPA is
    making interim risk management decisions for
    individual OP pesticides,  and will make final
    decisions through a cumulative OP assessment.

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       The bensulide interim decision was made through the OP pilot public participation process,
which increases transparency and maximizes stakeholder involvement in EPA's development of risk
assessments and risk management decisions.  EPA worked extensively with affected parties to reach
the decisions presented in this interim decision document, which concludes the OP pilot process for
bensulide.

Uses

       An herbicide, bensulide is used to control a variety of grasses and weeds in food crops (60 to
       65 % of all use)  including carrots, fruiting vegetables, leafy vegetables (mostly head lettuce),
       dry bulb vegetables (onions), cucurbits (mostly melons), and cole crops (cauliflower, cabbage,
       broccolini and broccoflower).  Bensulide products may be used outdoors by homeowners on
       lawns and ornamentals, and by professional lawn care operators. Bensulide may be used on
       turf (primarily golf course greens and tees), on ornamentals, and for greenhouse and outdoor
       uses in commercial nurseries.

       Annual domestic use is low- approximately 550,000 pounds of active ingredient per year.

Health Effects

       Bensulide can cause cholinesterase inhibition in humans; that is, it can overstimulate the nervous
       system causing nausea, dizziness, confusion, and at very high exposures (e.g., accidents or
       major spills), respiratory paralysis and death.
Risks
       Dietary exposures from eating food crops treated with bensulide are below the level of concern
       for the entire U.S. population, including infants and children. Drinking water is not a significant
       source of exposure.

       Risks are of concern for homeowners who apply bensulide, and for children entering turf areas
       treated with bensulide if label directions are not followed properly.

       EPA also has risk concerns for workers who mix, load, and/or apply bensulide to agricultural
       sites, golf courses, and home lawns.

       Chronic risks are of concern for birds and mammals;  risks are posed to some aquatic species.

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Risk Mitigation
       To mitigate risks to agricultural workers:
             for groundboom application, add respirators for mixers and/or loaders; add personal
              protective equipment or use of closed systems for commercial applicators;
              for chemigation, require respirators for mixing and/or loading; and restrict this
              application to California and Arizona where acreage treated is low.

       To mitigate worker risks from turf use:
              prohibit all handheld application methods except one (retained for spot treatment only);
             prohibit treatment of large turf areas like parks and recreation areas, except golf
              courses (see restrictions below for golf courses) (this measure will also reduce risks to
              children and the environment);
              require respirators and gloves for all remaining mixer/loader turf uses;
             require respirators for all "for hire" applications;
             require coveralls, gloves,  and a respirator for application of granulars with a push
              spreader.

       To mitigate residential risks:
             add label language prohibiting use of any handheld application method;
              add label language directing homeowners to water in the herbicide immediately after
              application, for safety reasons; and
             prohibit treatment of large turf areas, as mentioned above.

       To mitigate ecological risks:
              prohibit use on large non-golf course turf sites (as mentioned above);
             restrict golf course fairway use to a single grass type (bentgrass) in certain states;
             restrict the number of fairway applications to one; and
             limit the fairway application to the fall (minimizing exposure to birds during breeding
              season).
Next Steps
       Numerous opportunities for public comment were offered as this decision was being
       developed. The Bensulide IRED therefore is issued in final (see www.epa.gov/REDs/ or
       www.epa.gov/pesticides/op ), without a formal public comment period. The docket remains
       open, however, and any comments submitted in the future will be placed in this public docket.

       To effect risk mitigation as quickly as possible, time frames for making the changes required by
       the Bensulide IRED are shorter than those in a usual RED.  The Agency is requiring that all

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labels must be amended to include the above mitigation and submitted to the Agency within 90
days after issuance of this IRED.

When the cumulative risk assessment for all organophosphate pesticides is completed, EPA will
issue its final tolerance reassessment decision for bensulide and may require further risk
mitigation measures. The Agency will revoke the cottonseed tolerance because there are no
registered uses, amend a carrot tolerance, and make administrative changes to commodity
definitions now.  For all OPs, raising and/or establishing tolerances will be considered once a
cumulative assessment is completed.

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