United States
Environmental Protection
Agency
Prevention, Pesticides
and Toxic Substances
(7508C)
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
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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
naled.
Uses
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.
Risks
• 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.
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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.
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