United States
                      Environmental Protection
Prevention, Pesticides
and Toxic Substances
EPA 738-F-02-007
January 2002
&EPA   Naled  Facts
               EPA has assessed the risks of naled and reached an Interim Reregistration Eligibility Decision
        ,(IRED) for this organophosphate (OP) pesticide. Provided that risk mitigation measures are adopted
        naled fits into its own "risk cup"- its individual, aggregate risks are within acceptable levels. Naled
        also is eligible for reregistration, pending a full reassessment of the cumulative risk from all OPs.
               Used mainly to control mosquitos and to
        control insects on a variety of agricultural crops,
        naled residues in food and drinking water do not
        pose risk concerns. Naled may no longer be used in
        and around the home by residents or professional
        applicators. However, residents can be exposed as
        by-standers from wide-area mosquito control
        applications. Sergeant's, the sole end-use registrant
        for pet collars, is voluntarily cancelling all of its
        naled products.  With mitigation limiting
        homeowners' and children's exposure naled fits into
        its own "risk cup." With other mitigation measures,
        naled's worker and ecological risks will also 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 naled cannot be considered final until
        mis cumulative assessment is complete. Further risk
        mitigation may be warranted 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.
               The naled 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
       An insecticide, naled is used primarily to control adult mosquitos. It is also registered to
       control blackfiies, and leaf eating insects on a variety of fruits, vegetables, and nuts.

       Annual domestic use is approximately 1,000,000 pounds of active ingredient, with
       approximately 70% used in mosquito control and approximately 30% in agriculture.
Health Effects
       Naled 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.
      Dietary exposures from eating food crops treated with naled 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.

      The only remaining residential risks have been addressed by the voluntary cancellation of
       naled pet collar products.

      EPA also has risk concerns for workers who mix, load, and/or apply naled to agricultural
       sites, and for black fly control.

      Acute'and chronic risks are of concern for fish and other freshwater organisms.

Risk Mitigation

       In order to support a reregistration eligibility decision for naled, the following risk mitigation
measures are necessary:

To mitigate risks to agricultural workers:

      Require closed mixing/loading systems for all agricultural uses (except greenhouses and
       hand-held application)  and public health uses involving control of mosquitos and black flies.
      Require enclosed cabs for ground application or enclosed cockpits for aerial application, for
       all agricultural uses and public health uses involving control of mosquitos and black flies.
      Prohibit manual activation of hotplates.

       Prohibit manual activation of ventilation equipment in greenhouses.
       Delete backpack sprayers and hand-held foggers.                                  .
       Delete the greenhouse heal/steam pipe painting use.
       Delete use in apartments, motels, hotels and drive-in theaters.
       Reduce the maximum application rate for use on almonds and peaches to 1.875 Ibs ai/A and
       prohibit aerial use on almonds and peaches.
       Prohibit ready to use formulation.
       Delete wet and dry bait uses.
       Delete spot treatment for cockroach control.
       Prohibit human flaggers.
       Establish 48 hour reentry intervals after application to field crops.
       Establish 24 hour reentry intervals after application in greenhouses.

To mitigate risk to residents and children, the following measures are needed:

       The sole manufacturer of pet collars (Sergeant's) has requested voluntary cancellation of
       these uses.
       Prohibit all residential uses either by resident or professional applicator.  Use in residential
       areas by mosquito control districts would still be allowed.

To mitigate risk to non-target species:

       Reduce application rates for control of black fly from 0.25 to 0.1 Ibs/ai/A, and reduce rates on
       peaches and almonds from 2.8 to 1.875 Ibs/ai/A.
      Require buffer zones around permanent bodies of water to reduce runoff.
      Establish spray setbacks to reduce spray drift for  agricultural uses.

Next Steps

*      Numerous opportunities forpublic comment were offered as this decision was being
       developed. The Naled 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.

       When the cumulative risk assessment for all organophosphate pesticides is completed, EPA
       will issue its final tolerance reassessment decision for naled and may request further risk
       mitigation measures. However some tolerance actions for naled will be undertaken prior to
       completion of the final tolerance reassessment, including lowering of tolerances, changing of
       commodity definitions, and other administrative actions. For all OPs, raising and/or
       establishing tolerances will be considered once cumulative risk is considered.