United States
                 Environmental Protection
                 Agency           .
                       Prevention, Pesticides
                       And Toxic Substances
                       (7508W)
EPA-738-F-96-003
September 1995
                 R.E.D.   FACTS
     Pesticide
Reregistration
   Use Profile
 Starlicide


 (3-ch loro-p-tol u id i ne


 hydrochloride)
     All pesticides sold or distributed in the United States must be
 registered by EPA, based on scientific studies showing that they can be used
 without posing unreasonable risks to people or the environment. Because of
 advances in scientific knowledge, the law requires that pesticides which
 were first registered years ago be reregistered to ensure that they meet
 today's more stringent standards.
     In evaluating pesticides for reregistration, EPA obtains and reviews a
 complete set of studies from pesticide producers,  describing the human
 health and environmental effects of each pesticide. The Agency imposes
 any regulatory controls that are needed to effectively manage each
 pesticide's risks.  EPA then reregisters pesticides  that can be used without
 posing unreasonable risks to human health or the  environment.
     When a pesticide is eligible for reregistration, EPA explains the basis
 for its decision in a Reregistration Eligibility Decision (RED)' document.
 This fact sheet summarizes,the information in the RED document for
 reregistration case 2610, 3-chloro-p-toluidine hydrochloride or starlicide.

     Starlicide is an avicide used to control ravens, starlings, crows,
 pigeons, cowbirds, grackles, magpies, and certain gull species. Use sites
 vary by species but include livestock and poultry feedlots, building and
 fenced noncrop areas, Federal and State  wildlife refuges and protected
 areas, gull colonies in coastal areas, and bird staging areas and roosting
 sites,  .
     Starlicide is formulated as a 98% powder to be applied to various
baits, and as a 0.1% ready-to-use product. It is applied in solution to
various baits (meat, grain, egg, french fries), allowed to dry, and placed in
bait boxes or trays or broadcast by various means in target areas.
    Use practice limitations include the classification of all products
containing starlicide as restricted use, to  be applied only by certified
applicators or persons under their supervision. Starlicide treated baits cannot

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    ReQUlatorV
Human Health
  Assessment
be applied within 50 feet of standing water and cannot be applied directly to
food or feed crops.  There is a prohibition against grazing or planting crops
in treated areas within a year of application.  Prebaiting must be done before
application to ensure that nonrtarget or endangered species will not eat
treated baits.

      Starlicide was first registered as a pesticide in the U.S. in 1967..   s
Currently, 15 starlicide products are registered, including 7 Federal and 8
state registrations

Toxicity
      In studies using laboratory animals, starlicide has been shown to be of
moderate to high acute toxicity. Starlicide is  moderately toxic by the oral
route and slightly toxic by the dermal route,  placing it in Toxicity
Categories II and HI, respectively for these effects. Although a study was
not provided, based on its other acute toxicity properties, starlicide is
presumed to be highly acutely toxic (Toxicity Category I) by the inhalation
route. It  is corrosive to skin and eyes (also Toxicity Category I for these
effects) and is a mild to moderate skin sensitizer. Starlicide was not
mutagenic in three mutagenicity  assays provided to the Agency, and is not a
carcinogen.
Dietary Exposure
      Since starlicide is not used on food or  feed crops or commodities, no
human dietary exposure is expected.
Occupational and  Residential Exposure
      Based on current use patterns,  handlers (mixers, loaders, and
applicators) may be exposed to starlicide during the mixing of concentrate
with the  various baits. Because of its high vapor pressure and presumed
high acute inhalation  toxicity, the Agency has concern about the potential
for exposure to handlers mixing  starlicide concentrate in one pound
quantities.  However, the potential for post application exposure for persons
entering  a treated site after application is minimal, and the  Agency has no
post-application concerns.
 Human Risk Assessment
      Starlicide generally is of high.acute toxicity, but is not a mutagen or a
carcinogen. There are no food or feed uses registered for starlicide, and no
human dietary exposure is expected.
      Since there is some concern for handlers (mixers/loaders/applicators)
using one pound or more quantities of starlicide concentrate, the Agency has
concluded that the use of a respirator in these instances would minimize
exposure.

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  Environmental
    Assessment
Environmental Fate
      Starlicide does not hydrdlyze, but does photodegrade in water, which,
based on available data, appears to be its primary route of dissipation in the
environment. Starlicide binds to organic matter in soils, but a complete
environmental fate assessment cannot be performed because the submitted
data was not adequate. The Agency is not requiring new studies, however,
because of the limited uses  of Starlicide and the extremely low volume of
active ingredient applied annually.
Ecological Effects Risk Assessment
      Starlieide is very highly toxic to birds and freshwater invertebrates
and moderately toxic to freshwater fish.  Starlicide is moderately toxic to
mammals.  Data on toxicity to insects (honeybees) and non-target plants
were not required for Starlicide.
      Based on the data, non-target birds and mammals may be at risk from
eating Starlicide treated bait (primary exposure), or, as scavengers and
predators, from consuming  animals who have eaten treated baits (secondary
exposure). The risk to primary non-target bird populations is considered
high for all uses  of s'farlicide, as is the risk to endangered,small mammals in
areas treated with the highest application rates.  Acute risk is also posed to
aquatic invertebrates.
 Risk Mitigation
Additional Data
  Requirements
     . To lessen the risks to non-target animals posed by Starlicide, EPA is
requiring the following risk mitigation measures.
• Prebaiting, which will lessen the risk of ingestion of treated baits by non-
target species, will be required on all labels.
• Lower application rates - Because risk to endangered mammals and aquatic
invertebrates is highest at the maximum application rates, the highest rate
allowed for broadcast applications of Starlicide treated baits will be 0.1 Ibs./
acre.
• Buffer zones To lessen the potential for runoff which may pose acute risk to
aquatic invertebrates, treated baits must be placed at least 50 feet from bodies
of water.                           ,                       .
     Also, because of concern for inhalation exposure of mixers and loaders
to Starlicide concentrate, the following is required:
 • In addition to the personal protective equipment already on Starlicide labels
(goggles and gloves), a respirator approved for pesticides must be worn by
persons mixing quantities of one pound or more of Starlicide.

     The generic database supporting Starlicide is substantially complete.
The Agency is still requiring product-specific data including product
chemistry and acute toxicity studies, revised Confidential Statements of
Formula (CSFs),  and revised  labeling for reregistration.

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  Product Labeling
Changes Required
        Regulatory
         Conclusion
            For More
         Information
      All starlicide end-use products must comply with EPA's current
' pesticide product labeling requirements.  For the complete text of list of
 labeling requirements, please see pp.  33-36 of the starlicide RED
 document.                                                   .

      The use of currently registered products containing starlicide in
 accordance with approved labeling will not pose unreasonable risks or
 adverse effects to humans or the environment.  Therefore, all uses of these
 products are eligible for reregistration.
      Starlicide products will be reregistered once the required product-
 specific data, revised Confidential Statements of Formula, and revised
 labeling are received and accepted by EPA.

      EPA is requesting public comments on the Reregistration Eligibility
 Decision (RED) document for starlicide during a 60-day time period, as
 announced in a Notice of,Availability published in the Federal Register. To
 obtain a copy of the RED document or to submit written comments, please
 contact the Pesticide .Docket, Public Response and Program Resources
 Branch, Field Operations Division (7506C), Office of Pesticide Programs
 (OPP), US EPA, Washington,  DC 20460, telephone 703-305-5805.
      Electronic copies of the RED and this fact sheet can be -downloaded
 from the Pesticide Special Review and Reregistration Information System at
 703-308-7224.  They also are available on the Internet on EPA's gopher
 server, GOPHER.EPA.GOV, or using ftp on FTP.EPA.GOV, or using
 WWW (World Wide Web) on WWW.EPA.GOV.   .
      Printed copies of the RED and fact sheet can be obtained from EPA's
 National Center for Environmental Publications and Information
 (EPA/NCEPI), PO Box 42419, Cincinnati, OH 45242-0419, telephone
 513-489-8190, fax 513-489-8695.
      Following the comment period, the starlicide RED document also will
 be available from the National Technical Information Service (NTIS),  5285
 Port Royal Road, Springfield, VA'22161, telephone 703-487-4650.
      For more information about EPA's pesticide reregistration program,
 the starlicide RED, or reregistration of individual products containing
 starlicide, please contact the Special Review and Reregistration Division
 (7508W), OPP, US EPA, Washington, DC 20460, telephone 703-308-8000.
      For information about the health effects  of pesticides, or for assistance
 in recognizing and managing pesticide poisoning symptoms, please contact
 the National Pesticides Telecommunications Network (NPTN).  Call toll-
 free 1-800-858-7378, between 9:30 am and 7:30 pm Eastern Standard
 Time,  Monday through Friday.

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