v>EPA
       United States
       Environmental Protection
       Agency
        Prevention, Pesticides
        And Toxic Substances
        (7508C)
EPA738-R-00-012
October 2000
Report on FQPA Tolerance
Reassessment Progress
and Interim Risk
Management Decision
          for
       Fenitrothion

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               United States
               Environmental Protection
               Agency
Prevention, Pesticides
and Toxic Substances
(7508C)
EPA738-F-00-010
October 2000
                Fenitrothion   Facts
        EPA has assessed the risks of fenitrothion and completed a "Report on FQPA Tolerance
 Reassessment Progress and Interim Risk Management Decision for Fenitrothion" for this
 organophosphate (OP) pesticide. Without risk mitigation, fenitrothion fits into its own "risk cup"- its
 individual, aggregate risks are within acceptable levels.  Fenitrothion also is eligible for reregistration,
 pending a full reassessment of the cumulative risk from all OPs.
        In July 1995 a RED was issued for
 fenitrothion. Most uses were canceled during the
 RED process or subsequent to the issuance of the
 RED. Currently used in Australia on stored wheat
 and in the U.S. in containerized ant and roach baits in
 child resistant packaging, fenitrothion residues in
 food do not pose risk concerns and exposure
 resulting from use of the containerized ant and roach
 baits is expected to be insignificant.  Without
 -mitigation fenitrothion fits into its own "risk cup."

        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 fenitrothion 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 hi 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 fenitrothion 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
  fenitrothion.
 Uses
        An insecticide/acaricide, fenitrothion is used in Australia on stored wheat and there is a U.S.
        tolerance for imported wheat gluten. The only registered use in the U.S. is for containerized
        ant and roach baits in child resistant packaging.

        Annual domestic use is low.  Annual U.S. consumption of wheat gluten by the food industry
        is about 250 million pounds; currently approximately 26% (65 million pounds) is imported
        from Australia. No data are available on percent crop treated in Australia.
 Health Effects
        Fenitrothion 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 consuming wheat gluten treated with fenitrothion are below the level
        of concern for the entire U.S. population, including infants and children. Drinking water is not
        a source of exposure.

        Risks are not of concern for the use of fenitrothion in containerized ant and roach baits in child
        resistant packaging. Exposure is expected to be insignificant because the material is not
        available through the dermal and oral routes; and, due to the small amount of material which
        would be available through volatilization, inhalation exposure is expected to be minimal.


Risk Mitigation

•      No risk mitigation is necessary at this time.
Next Steps
       Numerous opportunities for public comment were offered as this decision was being
       developed.  The fenitrothion IRED therefore is issued as final (see
       www.epa.gov/pesticides/op), without a formal public comment period. The docket remains

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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 fenitrothion and may require further risk
mitigation measures. The Agency will amend the only tolerance for fenitrothion now  The
tolerance for wheat gluten imported from Australia will be lowered to 3 ppm and the tolerance
expression will be modified to include only the parent compound. For all OPs, raising and/or
establishing tolerances will be considered once a cumulative assessment is completed

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^•^•7  «
UK,
                    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                      WASHINGTON, D.C.  20460
                                                                           OFFICE OF
                                                                       PREVENTION, PESTICIDES
                                                                       AND TOXIC SUBSTANCES
 CERTIFIED MATT.
 Dear Registrant:
                                                                  NOV  0 7
       This is to inform you that the Environmental Protection Agency (hereafter referred to as
 EPA or the Agency) has completed its review of the available data and public comments received
 concerning the revised risk assessment for the organophosphate pesticide fenitrothion. The
 public comment period on the revised risk assessment phase of the tolerance reassessment
 process is closed. The attached document summarizes the Agency's assessment of dietary risk
 from fenitrothion as part of the tolerance reassessment process for this chemical, presents a
 summary of the revised food tolerances for fenitrothion, and provides the Agency's current risk
 management position, based on the risk assessment. Fenitrothion is not registered for use on
 food or feed crops in the U.S. It has only one import tolerance, for wheat gluten imported from
 Australia, and the dietary risk analysis indicates that the risk is below the Agency's level of
 concern. Therefore, no mitigation is necessary at this time.

       A Notice of Availability for this "Report on FQPA Tolerance Reassessment Progress
 and Interim Risk Management Decision for Fenitrothion" will be published in the Federal
 Register. This document and supporting technical documents are available for viewing in the
 Office of Pesticide Programs' Public Docket and can also be found on the Agency's web page
 "www.epa.gov/opp/op."                                                             '

       This document presents an update of the Reregistration Eligibility Decision (RED),
 which was issued in July 1995, taking into account the provisions of the Food Quality Protection
 Act (FQPA) of 1996. The docket includes background  information on the risk assessments.  No
 comments affecting the risk assessments were received during the Phase 3 or Phase 5 public
 comment periods. Therefore, the risk assessments were  not revised.

      This document and the process used to develop it are the results of a pilot process to
 facilitate greater public involvement and participation in the reregistration and/or FQPA
tolerance reassessment decisions on pesticides. As part of the Agency's effort to involve the
public in the implementation of the FQPA, the Agency is undertaking a special effort to maintain
open public dockets on the organophosphate pesticides and to engage the public in the
reregistration and tolerance reassessment processes for these chemicals. The idea of using such
an open process was developed by the Tolerance Reassessment Advisory Committee (TRAC), a
large multi-stakeholder advisory body which advised the Agency on implementing the new

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 provisions of the FQPA. The reregistration and tolerance reassessment reviews for the
 organophosphate pesticides are following this new process.

       Please note that the fenitrothion risk assessment concerns only this particular
 organophosphate. Because the FQPA directs the Agency to consider available information on
 cumulative risk from substances sharing a common mechanism of toxicity, such as the toxicity
 expressed by the organophosphates through a common biochemical interaction with
 cholinesterase, the Agency will evaluate the cumulative risk posed by the entire organophosphate
 class of chemicals, after completing risk assessments for the individual organophosphates. The
 Agency is working to complete a methodology to assess cumulative risk, and individual
 assessments of each organophosphate are likely to be  necessary elements'of any cumulative
 assessment The Agency has decided to move forward with individual assessments and to
 identify mitigation measures, where necessary. The Agency will issue the final tolerance
 reassessment decision for fenitrothion once the cumulative assessment for all of the
 organophosphates is complete.

       If you have questions on this document, please contact the Special Review and
 Reregistration Division representative for fenitrothion, Stephanie Nguyen at (703) 605-0702.
                                         ois A. Rossi, Director
                                        Special Review and
                                         Reregistration Division
Attachment

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Report on FQPA Tolerance Reassessment Progress
     and Interim Risk Management Decision
                     for
                 Fenitrothion

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                              TABLE OF CONTENTS

 Fenitrothion Team	          y
   * •
 Glossary of Terms and Abbreviations	iii

 Executive Summary	         j

 I.     Introduction	          j

 II.    Chemical Overview	         3
       A.    Regulatory History	3
       B.    Chemical Identification	              4
       C.    Use Profile	.^................ 4
       D.    Estimated Usage of Pesticide	5

 III.   Summary of Fenitrothion Risk Assessment 	5
       A.    Human Health Risk Assessment	6
             1.     Dietary Risk from Food	6
                   a.     Toxicity			6
                   b.     FQPA Safety Factor	.".*."."]."."! 6
                   c.     Population Adjusted Dose (PAD)	6
                   d.     Exposure Assumptions	7
                   e.     Acute Food Risk	g
                   f.     Chronic Food Risk	8
             2.     Residential Risk	9
             3.     Aggregate Risk	9

 IV.    FQPA Tolerance Reassessment Progress & Interim Risk Management Decision .. 9
       A.     Tolerance Reassessment Progress & Interim Risk Management Decision .. 9
       B.     Summary of Phase 5 Comments	10
       C.     Regulatory Position	10
             1.    FQPA Assessment	IQ
                  a.     "Risk Cup" Determination	10
                  b.     Tolerance Summary	H
             2.    Endocrine Disrupter Effects	12
       D.     Regulatory Rationale	12

V.     What Manufacturers Must Do	   12
      A.    Additional Data Requirements	12
      B.    Risk Mitigation Requirements	13
VI.
Related Documents and How to Access Them 	13

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 Fenitrothion Team

 Office of Pesticide Programs:

 Health Effects Risk Assessment

 Christine L. Olinger
 Christina Swartz

 Use and Usage Analysis

 Frank Hernandez

 Registration Support

 Marilyn Mautz

 Risk Management

Margaret Rice
Stephanie Nguyen
                                        11

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 Glossary of Terms and Abbreviations
 AE
 a.i.
 AGDCI
 ai
 aPAD
 AR
 ARC
 BCF
 CAS
 CI
 CNS
 cPAD
 CSF
 CFR
 CSFII
 DCI
 DEEM
 DFR
 DRES
 DWEL
DWLOC
EC
EEC

EP
EPA
FAO
FDA
FIFRA
FFDCA
FQPA
FOB
G
GENEEC
GLC
GLN
GM
GRAS
 Acid Equivalent
 Active Ingredient
 Agricultural Data Call-In
 Active Ingredient
 Acute Population Adjusted Dose
 Anticipated Residue
 Anticipated Residue Contribution
 Bioconcentration Factor
 Chemical Abstracts Service
 Cation
 Central Nervous System
 Chronic Population Adjusted Dose
 Confidential Statement of Formula
-Code of Federal Regulations
 USDA Continuing Surveys for Food Intake by Individuals
 Data Call-In
 Dietary Exposure Evaluation Model
 Dislodgeable Foliar Residue
 Dietary Risk Evaluation System
 Drinking Water Equivalent Level (DWEL) The DWEL represents a medium
 specific (i.e., drinking water) lifetime exposure at which adverse, noncarcinogenic
 health effects are not anticipated to occur.
 Drinking Water Level of Comparison.
 Emulsifiable Concentrate Formulation
 Estimated Environmental Concentration. The estimated pesticide concentration in
 an environment, such as a terrestrial ecosystem.
 End-Use Product
 U.S. Environmental Protection Agency
 Food and Agriculture Organization
 Food and Drug Administration
Federal Insecticide, Fungicide, and Rodenticide Act
Federal Food, Drug, and Cosmetic Act
Food Quality Protection Act
Functional Observation Battery
Granular Formulation
Tier I Surface Water Computer Model
Gas Liquid Chromatography
Guideline Number
Geometric Mean
Generally Recognized as Safe as Designated by FDA
                                        in

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  HA
 HAFT
 HOT
 IR
 LC50
 LD
    'so
 LEL
 LOG
 LOD
 LOAEL
 MATC
 MCLG

 mg/kg/day
 mg/L
 MOE
 MP
 MPI
 MRID

 N/A
 NAWQA
 NOEC
 NOEL
 NOAEL
 NPDES
 NR
 OP
 OPP
 OPPTS
 Pa

PAD
PADI
PAG
PAM
  Health Advisory (HA). The HA values are used as informal guidance to
  municipalities and other organizations when emergency spills or contamination
  situations occur.
  Highest Average Field Trial
  Highest Dose Tested
  Index Reservoir
  Median Lethal Concentration. A statistically derived concentration of a substance
  that can be expected to cause death in 50% of test animals. It is usually expressed
  as the weight of substance per weight or volume of water, air or feed, e.g., mg/1,
  mg/kg or ppm.
  Median Lethal Dose. A statistically derived single dose that can be expected to
  cause death in 50% of the test animals when administered by the route indicated
  (oral, dermal, inhalation).  It is expressed as a weight of substance per unit weight
  of animal, e.g., mg/kg.
  Lowest Effect Level
"Level of Concern
 Limit of Detection
 Lowest Observed Adverse Effect Level
 Maximum Acceptable Toxicant Concentration
 Maximum Contaminant Level Goal (MCLG) The MCLG is used by the Agency
 to regulate contaminants in drinking water under the Safe Drinking Water Act.
 Milligram Per Kilogram Per Day
 Milligrams Per Liter
 Margin of Exposure
 Manufacturing-Use Product
 Maximum Permissible Intake
 Master Record Identification (number). EPA's system of recording and tracking
 studies submitted.
Not Applicable
USGS National Water Quality Assessment
No Observable Effect Concentration
No Observed Effect Level
No Observed Adverse Effect Level
National Pollutant Discharge Elimination System
Not Required
Organophosphate
EPA Office of Pesticide Programs
EPA Office of Prevention,  Pesticides and Toxic Substances
pascal, the pressure exerted by a force of one newton acting on an area of one
square meter.
Population Adjusted Dose
Provisional Acceptable Daily Intake
Pesticide Assessment Guideline
Pesticide Analytical Method
                                         IV

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 PCA         Percent Crop Area
 PDF         USDA Pesticide Data Program
 PHED        Pesticide Handler's Exposure Data
 PHI          Preharyest Interval
 ppb          Parts Per Billion
 PPE          Personal Protective Equipment
 ppm          Parts Per Million
 PRN         Pesticide Registration Notice
 PRZM/EXAMS      Tier II Surface Water Computer Model
 Qi *          The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer Risk
              Model
 RAC         Raw Agriculture Commodity
 RBC         Red Blood Cell
 RED         Reregistration Eligibility Decision
 REI          Restricted Entry Interval
 RfD         "Reference Dose
 RQ           Risk Quotient
 RS           Registration Standard
 RUP          Restricted Use Pesticide
 SAP          Science Advisory Panel
 SCI-GROW   Tier I Ground Water Computer Model
 SF           Safety Factor
 SLC          Single Layer Clothing
 SLN          Special Local Need (Registrations Under Section 24© of FIFRA)
 TC           Toxic Concentration. The concentration  at which a substance produces a toxic
              effect.
 TD           Toxic Dose. The dose at which a substance produces a toxic effect.
 TEP          Typical End-Use Product
 TGAI         Technical Grade Active Ingredient
 TLC          Thin Layer Chromatography
 TMRC        Theoretical Maximum Residue Contribution
 torr           A unit of pressure needed to support a column of mercury 1 mm high under
              standard conditions.
 TRR          Total Radioactive Residue
 UF          Uncertainty Factor
             Micrograms Per Gram
             Micrograms Per Liter
USDA       United States Department of Agriculture
USGS        United States Geological Survey
UV          Ultraviolet
WHO        World Health Organization
WP          Wettable Powder
WPS         Worker Protection Standard

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  Executive Summary

        The U.S. Environmental Protection Agency (hereafter referred to as EPA or the Agency)
  has completed its review of public comments on the risk assessment for fenitrothion, and is, in
  this document, issuing its interim decision on the risk mitigation for this chemical. This risk
  assessment is based on review of the required target data base supporting the single fenitrothion
  import tolerance and information received during the public comment periods in the open
  process developed through the Tolerance Reassessment Advisory Committee (TRAC).
  Fenitrothion is registered in the U.S. for use in ant and roach baits. There are no food uses
  registered in the U.S.  The product is manufactured by Sumitomo Chemical Corporation.

        EPA's revised risk assessment for fenitrothion indicates that the dietary risk does not
  exceed the Agency's level of concern; therefore, no risk mitigation is necessary at this time. This
  assessment does not address residential, ecological, drinking water, or worker risks, because little
  or no exposure to residents, workers, or the environment is likely from the current limited
  domestic use of fenitrothion in ant and roach baits.

        The tolerance reassessment decision for fenitrothion will be issued once the cumulative
 assessment for all of the organophosphates is completed. The Agency may need to issue risk
 management measures for fenitrothion at the time the organophosphate cumulative assessment is
 finalized.
 I.
Introduction
       This report on the progress toward tolerance reassessment of fenitrothion is the result of
 the pilot process developed through the TRAC to facilitate greater public involvement in the
 ongoing Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) reregistration and FQPA
 tolerance reassessment initiatives on pesticides. A Reregistration Eligibility Document (RED)
 was issued in July 1995. This assessment presents an update of the RED, taking into account the
 provisions of the Food Quality Protection Act of 1996. Fenitrothion is not used on food or feed
 crops in the U.S.  It has only one tolerance, for wheat gluten imported from Australia. This
 assessment does not address residential, ecological, drinking water, or worker risks, because little
 or no exposure to residents, workers, or the environment is likely from the current limited
 domestic use of fenitrothion in ant and roach baits. Thus, this assessment relates only to the
 requirements of FQPA. However, some history and background of FIFRA is included here for
 informational purposes and to provide a discussion of the existing laws requiring action on
 pesticides.

       The FIFRA was amended in 1988 to accelerate the reregistration of products with active
 ingredients registered prior to November 1,1984. The amended act calls for the development
 and submission of data to support the reregistration of an active ingredient, as well  as a review of
all submitted data by the Agency. Reregistration involves a thorough review of the scientific
database underlying a pesticide's registration. The purpose of the Agency's review is to reassess
all potential hazards arising from the currently registered uses of the pesticide; determine the

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 need for additional data on health and environmental effects; and determine whether the pesticide
 meets the "no unreasonable adverse effects" criteria of FIFRA.

        On August 3,1996, the FQPA was signed into law. This Act amends FIFRA to require
 tolerance reassessment during reregistration. It also requires that, by August 2006, EPA review
 all tolerances in effect on the day before the date of the enactment of the FQPA. FQPA amends
 both FIFRA and the Federal Food, Drug, and Cosmetic Act (FFDCA), but does not amend any of
 the existing reregistration deadlines. Therefore, the Agency is continuing its reregistration
 program while it resolves remaining issues associated with the implementation of FQPA.  The
 Agency is also continuing its progress toward tolerance reassessment as required by FQPA for all
 of the organophosphate chemicals, whether or not they are subject to the reregistration process.
 While the methodology for completion of the cumulative assessment for all of the
 organophosphates is being developed, individual risk assessments and risk mitigation measures,
 where appropriate, are being conducted. The Fenitrothion RED, reflecting decisions of the
 reregistration process, was issued in July 1995. The revised individual dietary assessment for
 fenitrothion has been completed, and will be used in the cumulative assessment of all of the
 organophosphate chemicals, in order to satisfy the requirements of FQPA.

       The import tolerance for fenitrothion is subject to the requirements of FQPA; therefore, a
 dietary risk assessment was completed. This document presents the Agency's dietary risk
 assessment for fenitrothion, as part of the tolerance reassessment process. Note that there is no
 comment period for this document.  As part of the process developed by the TRAC, which
 sought to open up the process to interested parties, the Agency's risk assessment for fenitrothion
 has already been subject to numerous public comment periods, and a further comment period
 was deemed unnecessary. A Notice of Availability for this document is published in the Federal
 Register.  Phase 6 of the pilot process does not include a public comment period. However, for
 some chemicals, the Agency may provide another comment period, depending on the content of
 the risk management decision.

       Implementation of FQPA has required the Agency to revisit some of its existing policies
 relating to the determination and regulation of dietary risk, and has also raised a number of new
 issues for which policies need to be created. These issues were refined and developed through
 collaboration between the Agency and the Tolerance Reassessment Advisory Committee
 (TRAC), which was composed of representatives from industry, environmental groups, and other
 interested parties. TRAC identified the following science policy issues it believed were key to
 the implementation of FQPA and tolerance reassessment:

      Applying the FQPA 10-Fold Safety Factor
      Whether and How to Use "Monte Carlo" Analyses in Dietary Exposure Assessments
 •     How to Interpret "No Detectable Residues" in Dietary Exposure Assessments
•     Refining Dietary (Food) Exposure Estimates
•     Refining Dietary (Drinking Water) Exposure Estimates
•     Assessing Residential Exposure
      Aggregating Exposure from all Non-Occupational Sources

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 •      How to Conduct a Cumulative Risk Assessment for Organophosphate or Other Pesticides
        with a Common Mechanism of Toxicity
        Selection of Appropriate Toxicity Endpoints for Risk Assessments of Organophosphates
 •      Whether and How to Use Data Derived from Human Studies

        The process developed by TRAC calls for EPA to provide one or more documents for
 public comment on each of the policy issues described above. Each of these issues is evolving
 and in a different stage of refinement. Some issue papers have already been published for
 comment in the Federal Register and others will be published shortly.

        This document consists of six sections.  Section I contains the regulatory framework for
 reregistration/tolerance reassessment as well as a description of the process developed by TRAC
 for public comment on science policy issues for the Organophosphate pesticides. Section II
 provides a profile of the usage of this chemical. Section III gives an overview of the dietary risk
 assessment for fenitrothion, including a discussion of any revisions made to the preliminary
 assessment. Section IV presents the Agency's progress towards tolerance reassessment, its
 interim decision, and the regulatory position on this chemical. Section V discusses what the
 manufacturer's obligations are with respect to further actions required, and finally, Section VI
 provides information on how to access related documents.  The entire revised risk assessment is
 not included in this document, but is available on the Agency's web page-(www.epa.gov/opp/op),
 and in the Public Docket.

 II.    Chemical Overview

       A.     Regulatory History

       Fenitrothion, an Organophosphate, is a cholinesterase inhibiting insecticide/acaricide
 registered for use in the U.S.  in ant and roach baits. In the July 1995 RED a tolerance of 15 ppm
 was recommended  for residues of fenitrothion in wheat gluten resulting from post-harvest
 application to stored wheat in Australia. The Agency has reassessed the tolerance for residues of
 fenitrothion  in wheat gluten and is lowering it to 3 ppm, and will revise the tolerance expression
 to include only the  parent compound.

       In the July 1995 RED, greenhouse, outdoor ornamental, and containerized ant and roach
 baits in child resistant packaging were the only registered domestic uses assessed. The RED
required an extensive amount of risk mitigation for the greenhouse and outdoor ornamental uses
as well as a considerable amount of additional data. Subsequent to the issuance of the RED,
these uses were voluntarily canceled, leaving ant and roach baits as the only registered domestic
use.

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       B.     Chemical Identification

              FENITROTHION:
                    Common Name:

                    Chemical Name:


                    Chemical Family:

                    CAS Registry Number:

                    OPP Chemical Code:

                    Empirical Formula:

                    Molecular Weight:

                    Trade and Other Names:


                    Basic Manufacturers:
       Fenitrothion

       O,O-dimethyl O-(4-nitro-m-tolyl)
       phosphorothioate

       Organophosphate

       122-14-5
       105901
            NO5 PS
       277.2

       Tat Ant Trap X, Tat Roach Bait V,
       Sumithion

       Sumitomo Chemical Co.TDT., Osaka,
       Japan (Fenitrothion is not manufactured in
       the U.S.)
      C.     Use Profile

      The following information is based on the current uses of fenitrothion both within and
outside of  the United States, and includes an overview of use sites and application methods.
      Type of Pesticide:
Insecticide/Acaricide

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       Summary of Use Sites:

       Food:
       Residential:



       Target Pests:

       Formulation Types:
There are no registered food uses in the U.S.
Fenitrothion is used in Australia on stored wheat
and there is a U.S. tolerance for imported wheat
gluten.

The only registered use in the U.S. is for
containerized ant and roach baits in child resistant
packaging.

Ants, roaches, palmetto bugs, waterbugs

Emulsifiable concentrate (not registered in the
U.S.), and as pellets and granular baits
       Method and Rates of Application:
                    Method and Rate -
Baits contain either 0.01563% or 1.0% active
ingredient (a.L).  For stored wheat, fenitrothion
emulsifiable concentrate is applied at 12 mg a.i./kg
grain, prior to bin storage (not registered in the
U.S.)
       D.     Estimated Usage of Pesticide

       This section summarizes the best estimates available for the pesticide uses of fenitrothion.
These estimates are derived from a variety of published and proprietary sources available to the
Agency. The data, reported on an aggregate and site (crop) basis, reflect annual fluctuations hi
use patterns as well as the variability in using data from various sources.

       Annual U.S. consumption of wheat gluten by the food industry is about 250 million
pounds; currently approximately 26% (65 million pounds) is imported from Australia. Because
no data are available on percent crop treated, for the purpose of this reassessment, EPA has
assumed that all of the wheat gluten imported from Australia could be treated with fenitrothion.
(Note: Wheat gluten is the natural protein derived from wheat. It is essentially wheat flour with
the starch removed. It is used by the baking industry to improve consistency in bread products,
and has other industrial uses.)

III.   Summary of Fenitrothion Risk Assessment

       Following is a summary of EPA's revised human health risk findings and conclusions for
the organophosphate pesticide fenitrothion, as fully presented in the revised risk assessment

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document, "Fenitrothion HED RED Chapter; Revised Risk Assessment (PC Code 105901),"
dated May 19,1999. The risk assessment presented here forms the basis of the Agency's interim
risk management decision for fenitrothion only; the Agency must complete a cumulative
assessment of the risks of all organophosphate pesticides before it can complete its reassessment
of the fenitrothion tolerance.

       The revised risk assessment for fenitrothion presents the individual dietary assessment for
fenitrothion resulting from its use on wheat gluten imported from Australia. This assessment
does not address residential, ecological, drinking water, or worker risks, because little or no
exposure to residents, workers, or the environment is likely from the current limited domestic use
of fenitrothion in ant and roach baits.

       A.    Human Health Risk Assessment

       No comments affecting the risk assessment were received during the Phase 3 or Phase 5
public comment periods; therefore, the risk assessments were not revised.

             1.     Dietary Risk from Food

                    a.     Toxicity

       The Agency has reviewed all toxicity studies submitted and has determined that the
toxicity database supports a dietary risk assessment for fenitrothion as well as a future FQPA
tolerance reassessment for the import tolerance on wheat gluten.  Further details on the toxicity
of fenitrothion can be found in the  May 19,1999 HED Red Chapter; Revised Risk Assessment.
A brief overview of the studies used for the dietary risk assessment is outlined in Table 1 of this
document.

                    b.     FQPA Safety Factor

       The FQPA Safety Factor was removed based on a complete toxicity data base and
adequate exposure information, which allowed reasonable understanding in predicting possible
effects on infants and children, and the lack of increased susceptibility in the fetuses and/or pups
in the developmental and reproduction studies. The Agency has granted a waiver for the
developmental neurotoxicity (DNT) study for fenitrothion.  The Agency has determined that
exposure to any population group of concern under the FQPA is very low for the currently
registered and labeled uses of fenitrothion, given the amount used, how it is used, and
information available to the Agency regarding levels to which people are exposed.

                    c.     Population Adjusted Dose (PAD)

       The PAD is a relatively new term that characterizes the dietary risk of a chemical, and
reflects the Reference Dose, either acute or chronic, that has been adjusted to account for the
FQPA safety factor (i.e., RfD/FQPA safety factor). For the acute dietary assessment, risk is

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calculated considering what is eaten in one day (consumption) and maximum, high-end residue
values in food. For chronic exposures, dietary risk is calculated by using the average
consumption value for food and average residue value.  In the case of fenitrothion, the FQPA
Safety Factor Committee recommended removal of the 10X safety factor; therefore, the acute or
chronic RfD is equal to the acute or chronic PAD. A risk estimate that is less than 100% of the
acute or chronic PAD does not exceed the Agency's risk concern.

                    d.     Exposure Assumptions

       A tolerance level of 15 ppm was previously recommended to cover residues of
fenitrothion in wheat gluten imported from Australia. However, the Agency has re-evaluated the
magnitude of residue database for fenitrothion and concluded that the tolerance value for
fenitrothion in wheat gluten can be lowered to 3 ppm.  In four trials from four different states in
Australia, residues ranged from 0.95 to 2.5 ppm in/on wheat gluten; the average residue was 1.84
ppm. Monitoring data from a commercial wheat gluten processing facility in Australia showed
residues ranging from 0.09 to 0.9 ppm, with an average of 0.38 ppm. FDA has monitored just a
few wheat gluten samples from Australia over the last several years.  Most samples showed non-
detectable residues of fenitrothion, although trace residues (residues less than the level which can
be reliably quantified) were found in two samples.

       The Agency estimates that approximately 65 million pounds of wheat gluten are imported
from Australia each year, according to quotas that were created in 1998. Based on that figure,
together with an annual U.S. consumption estimate for the U.S. food industry of 250 million
pounds of wheat gluten, the maximum amount of all U.S. wheat gluten which could be treated
with fenitrothion is 26%.  This assumes that 100% of wheat gluten imported from Australia has
been treated.

       Dietary risk analyses for fenitrothion were conducted with the Dietary Exposure
Evaluation Model (DEEM™). DEEM incorporates  consumption data generated in USDA's
Continuing Surveys of Food Intake by Individuals (CSFII), 1989-1992. This model does not
contain consumption values for wheat gluten.  EPA used wheat flour consumption data and an
adjustment factor (0.0062) to estimate the amount of wheat gluten consumed. [The adjustment
factor represents the estimated amount of wheat gluten consumed annually as a proportion of the
total wheat flour consumed annually]. Use of this factor assumes that the relative consumption of
wheat gluten to wheat flour is the same for all population subgroups. Residues were estimated
using the proposed revised tolerance level (3 ppm) and average per capita exposure.

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   Table 1. Summary of Toxicological Endpoints and Other Factors Used in the Human
                       Dietary Risk Assessment of Fenitrothion
Assessment


Acute Dietary





Chronic
Dietary





Study


Acute
Neurotoxicity-
Rat



1 -year Feeding
Study-Dog





Dose


NOAEL=
12.5
mg/kg/day
LOAEL=
50
mg/kg/day
NOAEL=
0.125
mg/kg/day

LOAEL=
0.25
mg/kg/day
Endpoint


Tremors and
impaired motor
coordination



Plasma ChE
inhibition and
histopathology
changes of the
lymph nodes


TJF


100





100




-

FQPA
Safety
Factor
IX





IX






PAD


0.13
rag/kg/
day



0.0013
mg/kg/
day




                    e.
                          Acute Food Risk
       The acute dietary (food) risk of fenitrothion is 0.02% of the aPAD for the general
population, well below the Agency's level of concern.  An acute dietary risk assessment was not
performed in the July 1995 RED because data to estimate single-day consumption of wheat
gluten were not available. However, using the average U.S. population exposure estimate with
the acute dietary NOAEL results in the above acute dietary risk estimate.  Therefore, while there
are uncertainties in the estimated risk due to uncertainties in the consumption estimate, this
extremely low percent of the aPAD indicates that risks from this use will be insignificant. This
analysis satisfies the FQPA requirement for the special consideration of pesticide risk to children.

                   f.     Chronic Food Risk

       Use of the average residues from field trials and limited FDA monitoring, together with
percent of commodity treated data discussed above (26%) results in chronic dietary risk
estimates of <1% of the cPAD for the general U.S. population and all population subgroups.
The most highly exposed sub-population is children 1-6 at 0.7% of the cP AD. Note that this
estimate is considered to be somewhat conservative, since  100% crop treatment is assumed for
wheat gluten produced hi Australia.

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       In summary, the potential acute and chronic dietary exposures on imported wheat gluten
are well below the level of concern for all population sub-groups, including infants and children.
Data on the actual percentage of stored Australian wheat treated with fenitrothion and the percent
of imported Australian wheat gluten diverted for non-food purposes (e.g., the manufacture of
bio-degradable plastic) would allow EPA to further refine the dietary risk estimates.
             2.
Residential Risk
       Exposure resulting from use of the containerized ant and roach baits in child resistant
packaging is expected to be insignificant. The Agency did not quantitatively estimate risks for
this type of use because of the expected low potential for exposure. Exposure is expected to be
insignificant because the material is not available through the dermal and oral routes; and, due to
the small amount of material which would be available through volatilization, inhalation
exposure is expected to be minimal.

              3.     Aggregate Risk

       Because exposure from residential uses is expected to be insignificant, the aggregate
exposure assessment for fenitrothion would include consideration of exposures only from food.
Therefore, an aggregate assessment was not required.
IV.    FQPA Tolerance Reassessment Progress & Interim Risk Management Decision

       A.    Tolerance Reassessment Progress & Interim Risk Management Decision

       The Agency has completed its assessment of the dietary risk of fenitrothion but has not
considered the cumulative effects of organophosphates as a class.  Based on review of the
generic and other data, EPA has sufficient information on the human health effects of
fenitrothion to make an interim decision as part of the tolerance reassessment process under
FQPA. Although the Agency has not yet completed its cumulative risk assessment for the
organophosphates, the Agency has completed its assessment of risk from dietary exposure to
fenitrothion alone in order to determine whether any risk reduction measures are necessary to
allow the continued importation of wheat gluten containing fenitrothion, pending completion of
the cumulative assessment.

       As a result of its assessment, EPA has determined that dietary risk from exposure to
fenitrothion does not exceed the Agency's level of concern. Therefore, no mitigation is
necessary and no further actions are warranted at this time.  The Agency may determine that
further action is necessary after assessing the cumulative risk of the organophosphate class. At
that time, the Agency will also address any other outstanding risk concerns that may arise. Such
an incremental approach to the tolerance reassessment process is consistent with the Agency's
goal of improving the transparency of the implementation of FQPA. By evaluating each

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 organophosphate in turn and identifying appropriate risk reduction measures, the Agency is
 addressing the risks from organophosphates in as timely a manner as possible.

       Because the Agency has not yet completed the cumulative risk assessment for the
 organophosphates, this interim decision does not specifically address the reassessment of the
 existing fenitrothion food residue import tolerance as called for by the FQPA. When the Agency
 has completed the cumulative assessment, the fenitrothion tolerance will be reassessed in that
 light. At that time, the Agency will reassess fenitrothion along with the other organophosphate
 pesticides to complete the FQPA requirements. Nothing in this report will preclude the Agency
 from making further FQPA determinations and tolerance-related ralemakmg that may be
 required on this pesticide or any other in the future.

       If the Agency determines, before finalization of the FQPA assessment for fenitrothion,
 that any of the determinations described in this document are no longer appropriate, the Agency
 will pursue appropriate action, including but not limited to, reconsideration of any portion of this
 document.

       B.     Summary of Phase 5 Comments

       EPA released its revised risk assessment for fenitrothion to the public in September,
 1999, and provided a 60 day comment period for interested parties to submit information,
 including risk mitigation suggestions or proposals. No comments were received. Sumitomo
 Chemical Company, the registrant, submitted a dietary toxicity study using human volunteers, on
 April 25,2000. This study has not been reviewed.

       C.     Regulatory Position

              1.     FQPA Assessment

                    a.     "Risk Cup" Determination

       As part of the FQPA tolerance reassessment process, EPA assessed the risks associated
with this individual organophosphate.  FQPA also requires the Agency to consider available
information on cumulative risk from substances sharing a common mechanism of toxicity, such
as the toxicity expressed by the organophosphates through a common biochemical interaction
with cholinesterase enzyme. The Agency will evaluate the cumulative risk posed by the entire
class of organophosphates once the methodology is developed and the policy concerning
cumulative assessments is resolved.

      EPA has determined that risk from exposure to fenitrothion is within its own "risk cup."
In other words, if fenitrothion did not share a common mechanism of toxicity with other
chemicals, EPA would be able to conclude today that the import tolerance for fenitrothion on
wheat gluten meets the  FQPA safety standards. In reaching this determination, EPA considered
available information on the special sensitivity of infants and children, as well as chronic and

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acute food exposure.  An aggregate assessment was not conducted for fenitrothion, because little
or no exposure is likely from the current limited domestic use of fenitrothion in containerized
ant and roach baits in child resistant packaging.  Exposure is expected to be insignificant because
the material is not available through the dermal and oral routes; and, due to the small amount of
material which would be available through volatilization, inhalation exposure is expected to be
minimal.  Results of the acute and chronic food assessments indicate that exposures are within
acceptable levels; that is, risk from exposure to fenitrothion "fits" within the individual risk cup.
Therefore, the import tolerance remains in effect until a full reassessment of the cumulative risk
from all organophosphates is completed.

                     b.     Tolerance Summary

       A tolerance level of 30 ppm, of which no more than 15 ppm is O,O-dimethyl O-(4-nitro-
m-tolyl) phosphorothioate or O,O-dimethyl O-(4-nitro-m-tolyl) phosphate, is established for
combined residues of the insecticide O,O-dimethyl O-(4-nitro-m-tolyl) phosphorothioate and its
metabolites O,O-dimethyl O-(4-nitro-m-tolyl) phosphate and 3-methyl-4-nitrophenol in wheat
gluten resulting from  postharvest application of the insecticide to stored wheat in Australia.
However, the Agency has re-evaluated the magnitude of residue database for fenitrothion and
concluded the tolerance can be lowered to 3 ppm, as shown in Table 2. Residues in four field
trials from four different states in Australia resulted hi residues ranging from 0.95 to 2.5 ppm
in/on wheat gluten; the average residue was 1.84 ppm. The tolerance expression should be
modified  to include only the parent compound. Although 3-rnethyl-4-nitrophenol is of potential
lexicological concern based on data relative to similar compounds,  the risk assessment
conducted for the cholinesterase-inhibiting metabolite(s) is expected to be more sensitive.
Therefore, only cholinesterase-inhibiting metabolites need to be regulated and 3-methyl-4-
nitrophenol should be deleted from the current tolerance expression. Although O,O-dimethyl O-
(4-nitro-m-tolyl) phosphate is expected to be of greater toxicological concern than the parent,
finite residues of O,O-dimethyl O-(4-nitro-m-tolyl) phosphate are not  expected in/on wheat grain
or in wheat gluten resulting from the postharvest use of fenitrothion on stored wheat in Australia;
therefore, O,O-dimethyl O-(4-nitro-m-tolyl) phosphate should be deleted from the current
tolerance  expression.  All other metabolites were determined not to  be potential cholinesterase
inhibitors and/or were present at such low levels compared to the parent that they were deemed
insignificant and  do not need to be regulated.

                       Table 2.  Tolerance Summary for Fenitrothion
Commodity
Wheat Gluten
Tolerance Currently Listed
Under 40 CFR§ 185.2200
30 ppm
Reassessed
Tolerance"
3 ppm
Comment
Wheat Gluten, imported
The tolerance should be expressed as
parent only and the tolerance will be
listed in 180.540
 * The term "reassessed" is not meant to imply that the tolerance has been reassessed as required by FQPA, since
 this tolerance may be reassessed only upon completion of the cumulative risk assessment of all organophosphates,
                                            11

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as required by this law. Rather, it provides a tolerance level for this single chemical, if no cumulative assessment
were required, that is supported by all of the submitted residue data.
              2.     Endocrine Disrupter Effects

       EPA is required under the FFDCA, as amended by FQPA, to develop a screening
program to determine whether certain substances (including all pesticide active and other
ingredients) "may have an effect in humans that is similar to an effect produced by a naturally
occurring estrogen, or other such endocrine effects as the Administrator may designate."
Following the recommendations of its Endocrine Disrupter Screening and Testing Advisory
Committee (EDSTAC), EPA determined that there was scientific bases for including, as part of
the program, the androgen and thyroid hormone systems, in addition to the estrogen hormone
system. EPA also adopted EDSTAC's recommendation that the Program include evaluations of
potential effects hi wildlife. For pesticide  chemicals, EPA will use FIFRA and, to the extent that
effects hi wildlife may help determine whether a substance may have an effect in humans,
FFDCA authority to require the wildlife evaluations. As the science develops and resources
allow, screening of additional hormone systems may be added to the Endocrine Disrupter
Screening Program (EDSP).

       When the appropriate screening and/or testing protocols being considered under the
Agency's EDSP have been developed, fenitrothion may be subjected to additional screening
an/or testing to better characterize effects related to endocrine disruption.

       D.     Regulatory Rationale

       Fenitrothion has only one import tolerance for wheat gluten, and little or no exposure is
likely from the current limited domestic use of fenitrothion in containerized ant and roach baits
in child resistant packaging.  Exposure is expected to be insignificant because the material is not
available through the dermal and oral routes; and, due to the small amount of material which
would be available through volatilization, inhalation exposure is expected to be minimal.
Therefore, only a dietary risk assessment for food was conducted.  Based on analyses of both
acute and chronic dietary risk, the Agency has determined that the risk estimates are below the
Agency's level of concern, therefore, no mitigation measures are necessary at this tune.
V.     What Manufacturers Must Do

       A.    Additional Data Requirements

       EPA is requiring acute, subchronic, and developmental neurotoxicity studies for all
organophosphates, including those with no domestic registrations (i.e., tolerances are established
only to allow treated commodities to be imported into the U.S.).  However, there are no
additional data required for fenitrothion. The Agency has granted a waiver for the developmental
                                           12

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neurotoxicity (DNT) study for fenitrothion. The Agency has concluded that exposure to any
population group of concern under the FQPA is very low for the currently registered and labeled
uses of fenitrothion, given the amount used, how it is used, and information available to the
Agency regarding levels to which people are exposed, as described in EPA's fenitrothion human
health risk assessments.

      B.    Risk Mitigation Requirements

      As discussed in this document, the acute and chronic food risk from the use of
fenitrothion on imported wheat gluten is not of concern to the Agency, therefore, no mitigation
is necessary at this time. The Agency may need to pursue risk management measures for
fenitrothion once the cumulative assessment is finalized.

VI.   Related Documents and How to Access Them

       This report is supported by documents that are presently maintained in the OPP docket
(#34197). The OPP docket is located in Room 119, Crystal Mall #2,1921 Jefferson Davis
Highway, Arlington, VA. It is open Monday through Friday, excluding legal holidays, from 8:30
am to 4 pm. All documents, in hard copy form, may be viewed in the OPP docket room or
downloaded or viewed via the Internet at the following site: "http://www.epa.gov/opp/op."
                                           13

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             Bibliography for Fenitrothion Docket
 1.     Christine L. Olinger (USEPA/OPPTS/OPP/HED) Fenitrothion HED RED
       Chapter; Revised Risk Assessment, (PC 105901). 5/19/99.

 2.     John C. Redden (USEPA/OPPTS/OPP/HED) HED RED Chapter for Fenitrothion
       (PC 105901). 5/7/94.

 3.     Jess Rowland (USEPA/OPPTS/OPP/HED) Fenitrothion-Correction to the Report
       of HIARC Review Committee. 2/23/99.

 4.     Jess Rowland (USEPA/OPPTS/OPP/HED) Fenitrothion - FQPA Requirement-
       Report of the Hazard Identification Assessment review Committee. 10/8/97.

 5.     Christine Swartz (USEPA/OPPTS/OPP/HED) Chronic Dietary Exposure
       Analyses for the Revised HED Reregistration Eligibility Decision Document
       (RED). 5/28/99.

 6.     Christine L. Olinger (USEPA/OPPTS/OPP/HED) Anticipated Residue and
       Tolerance Reassessment Recommendations. 5/19/99.

 7.     Michael S. Metzger (USEPA/OPPTS/OPP/HED) Update to Consider FQPA
       Requirements. 2/24/98.

 8.     Frank Hernandez (USEPA/OPPTS/OPP/BEAD) Fenitrothion on Wheat Gluten.
       6/29/99.

9.    Robin G. Todd, Ph. D (Sumitomo Chemical Company, Limited) Letter to EPA,
      Fenitrothion Human Health Risk Assessment. 7/22/99.
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