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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