United States       Prevention, Pesticides    EPA 738-R-95-041
         Environmental Protection   And Toxic Substances    September 1995
         Agency	(7508W)	
&EPA  Reregi strati on
         Eligibility  Decision (RED)

         Tetrachlorvinphos

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           \        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 "\, Oon1^                            WASHINGTON, D.C. 20460
                                                                            OFFICE OF
                                                                       PREVENTION, PESTICIDES
                                                                       AND TOXIC SUBSTANCES
CERTIFIED MAIL
Dear Registrant:

       I am pleased to announce that the Environmental Protection Agency has completed its
reregistration eligibility review and decisions on the pesticide chemical case
Tetrachlorvinphos. The enclosed Reregistration Eligibility Decision (RED) contains the
Agency's evaluation of the data base of this chemical, its conclusions of the potential human
health and environmental risks of the current product uses, and its decisions and conditions
under which these uses and products will be eligible for reregistration.  The RED includes the
data and labeling requirements for products for reregistration.  It may also include
requirements  for additional data (generic) on  the active ingredient to confirm the risk
assessments.

       To assist you with a proper response,  read the enclosed document entitled "Summary
of Instructions for Responding to the RED."  This summary also refers to other enclosed
documents which include further instructions. You must follow all instructions and submit
complete and timely responses.  The first set of required responses are  due 90 days from
the date of this letter.  The second set of required responses are due 8 months from the
date of this letter. Complete and timely responses will avoid the Agency taking the
enforcement action of suspension against your products.

       If you have questions on the product specific data requirements or wish to meet with
the Agency, please contact the Special Review and Reregistration Division representative Jeff
Billingslea at (703) 308-8004.  Address any questions on required generic data to the Special
Review and Reregistration Division representative Bill  Wooge at (703) 308-8794.

                                                      Sincerely yours,
                                                      Lois A. Rossi, Director
                                                      Special Review
                                                       and Reregistration Division
Enclosures

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              SUMMARY OF INSTRUCTIONS FOR RESPONDING TO
             THE REREGISTRATION ELIGIBILITY DECISION (RED)

1  DATA CALL-IN (PCI) OR "90-DAY RESPONSE"  If generic data are required for
reregistration, a DCI letter will be enclosed describing such data. If product specific data are
required, another DCI letter will be enclosed listing such requirements.  If both generic and
product specific data are required, a combined Generic and Product Specific letter will be
enclosed describing such data.  Complete the two response forms provided with each DCI
letter (or four forms for the combined) by following the instructions provided. You must
submit the response forms for each product and for each DCI within 90 days of the date
of this letter (RED issuance date); otherwise, your product may be suspended.

2. TIME EXTENSIONS AND DATA WAIVER REQUESTS No time extension requests
will be granted for the 90-day response. Time extension requests may be submitted only with
respect to actual data submissions. Requests for data waivers must be submitted as part of the
90-day response. Requests for time extensions should be submitted in the 90-day response,
but certainly no later than the 8-month response date.  All  data waiver and time  extension
requests must be accompanied by a full justification. All waivers and time extensions must be
granted by EPA in order to go into effect.

3. APPLICATION FOR REREGISTRATION OR "8-MONTH RESPONSE"-You must
submit the following items for each product within eight months of the date of this letter
(RED issuance date).

      a. Application for Reregistration (EPA Form 8570-1).  Use only an original
application form. Mark it "Application for Reregistration."  Send your Application for
Reregistration (along with the other forms listed in b-e below) to the address listed in item 5.

      b. Five copies of draft labeling which complies with the RED and current regulations
and requirements.  Only make labeling changes which are  required by the RED  and current
regulations (40 CFR 156.10) and policies. Submit any other amendments (such as formulation
changes, or labeling changes not related to reregistration) separately. You may  delete uses
which the RED says are ineligible for reregistration. For further labeling guidance, refer to
the labeling section of the EPA publication "General Information on Applying for Registration
in the U.S., Second Edition, August 1992" (available from the National Technical Information
Service, publication #PB92-221811; telephone number 703-487-4650).

      c. Generic or Product Specific Data.  Submit all data in a format which complies
with PR Notice 86-5,  and/or submit citations of data already submitted and give the EPA
identifier (MRID) numbers. Before citing these studies, you must make sure that they meet
the Agency's acceptance criteria (attached to the DCI).

      d. Two copies of the Confidential Statement of Formula (CSF) for each basic and
each alternate formulation.  The labeling and CSF which you submit for each product must
comply with P.R. Notice 91-2 by declaring the active ingredient as the nominal

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concentration. You have two options for submitting a CSF:  (1) accept the standard certified
limits (see 40 CFR §158.175) or (2) provide certified limits that are supported by the analysis
of five batches. If you choose the second option, you must submit or cite the data for the five
batches along with a certification statement as described in 40 CFR §158.175(e).  A copy of
the CSF is enclosed; follow the instructions on its back.

      e. Certification With Respect to Data Compensation Requirements. Complete and
sign EPA form 8570-31 for each product.

4. COMMENTS IN RESPONSE TO FEDERAL REGISTER NOTICE-Comments
pertaining to the content of the RED may be submitted to the address shown in the Federal
Register Notice which announces the availability of this RED.

5  WHERE TO SEND PRODUCT SPECIFIC PCI RESPONSES (90-DAY) AND
APPLICATIONS FOR REREGISTRATION (8-MONTH RESPONSES)

By U.S. Mail:

      Document Processing Desk (RED-SRRD-PRB)
      Office of Pesticide Programs (7504C)
      EPA, 401 M St. S.W.
      Washington, D.C. 20460-0001

By express:

      Document Processing Desk (RED-SRRD-PRB)
      Office of Pesticide Programs (7504C)
      Room 266A, Crystal Mall 2
      1921 Jefferson Davis Hwy.
      Arlington, VA 22202

6. EPA'S REVIEWS-EPA will screen all submissions for completeness; those which are not
complete will be returned with a request for corrections. EPA will try to respond to data
waiver and time extension requests within 60 days.  EPA will also try to respond to all 8-
month submissions with a final reregistration determination within 14 months after the RED
has been issued.

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REREGISTRATION ELIGIBILITY DECISION

              Tetrachlorvinphos

                  LIST A

                 CASE 0321
           ENVIRONMENTAL PROTECTION AGENCY
             OFFICE OF PESTICIDE PROGRAMS
        SPECIAL REVIEW AND REREGISTRATION DIVISION

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                          TABLE OF CONTENTS

TETRACHLORVINPHOS REREGISTRATION ELIGIBILITY DECISION TEAM .  . i

EXECUTIVE SUMMARY	v

I.     INTRODUCTION                                                       1

II.    CASE OVERVIEW                                                      2
      A.    Chemical Overview 	2
      B.    Use Profile	2
      C.    Usage Data	4
      D.    Use Profile	5
      E.    Regulatory History 	5

III.   SCIENCE ASSESSMENT                                                5
      A.    Physical Chemistry Assessment	5
            1.     Description of Chemical	5
            2.     Identification of Active Ingredient  	6
            3.     Manufacturing-Use Products	6
      B.    Human Health Assessment  	7
            1.     Toxicology Assessment 	7
                  a.    Acute Toxicity	7
                  b.    Subchronic Toxicity  	8
                  c.    Chronic toxicity	9
                  d.    Carcinogenicity 	10
                  e.    Developmental Toxicity	10
                  f.     Reproductive Toxicity	11
                  g.    Mutagenicity	11
                  h.    Metabolism	12
                  i.     Dermal Absorption	12
                  j.     Reference Dose and Cancer Potency Factor  	13
                  k.    Domestic Animal Safety	13
            2.     Exposure Assessment	14
                  a.    Dietary Exposure	14
                  b.    Occupational and Residential Exposure	21
            3.     Risk Assessment  	26
                  a.    Dietary Risk  	26
                  b.    Occupational and Residential Risk 	29
                  c.    Domestic Animal Safety	32
      C.    Environmental Assessment	32
            1.     Ecological Toxicity	32
                  a.    Toxicity to Terrestrial Animals	32
                  b.    Toxicity to Aquatic Animals	35
                  c.    Toxicity to Plants	37

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            2.    Environmental Fate	37
                  a.    Environmental Fate Assessment	37
                  b.    Environmental Chemistry, Fate and Transport	38
            3.    Ecological Exposure and Risk Characterization 	42
                  a.    Exposure and Risk to Nontarget Terrestrial Animals  .... 42
                  b.    Exposure and Risk to Nontarget Aquatic Animals	45
                  c.    Exposure and Risk to Nontarget Terrestrial, Semi-Aquatic, and
                        Aquatic Plants	46
                  d.    Endangered Species 	46

IV.   RISK MANAGEMENT AND REREGISTRATION DECISION	47
      A.    Determination of Eligibility	47
            1.    Eligibility Decision	48
            2.    Eligible Uses   	48
      B.    Regulatory Position	49
            1.    Tolerance Reassessment  	49
            2.    Human Health Risks and Eligibility 	52
                  a.    Dietary Risk 	52
                  b.    Worker Risk	53
                  c.    Homeowner Risk  	54
            3.    Domestic Animal Safety  	54
            4.    Labeling Rationale/Risk Mitigation  	54
            5.    Endangered Species Statement	56

V.    ACTIONS REQUIRED BY REGISTRANTS  	56
      A.    Manufacturing-Use Products	56
            1.    Additional Generic Data Requirements	56
      B.    End-Use Products 	57
            1.    Additional Product-Specific Data Requirements	57
            2.    General Labeling Requirements for Products	57
                  a.    All Products  	57
                  b.    Products Intended Primarily for Occupational Use  	58
                  c.    Occupational Products Used in Recreational Areas  	59
                  d.    Products with Feed-Through Uses	59
      C.    Existing Stocks	59

VI.   APPENDICES                                                          61
      APPENDIX A.     Table of Use Patterns Subject to Reregistration	63
      APPENDIX B.     Table of the Generic Data Requirements and Studies Used to
                        Make the Reregistration Decision	87
      APPENDIX C.     Citations Considered to be Part of the Data Base Supporting the
                        Reregistration of Tetrachlorvinphos  	93
      APPENDIX D.     Product Specific Data Call-in	  103
            Attachment 1.      Chemical Status Sheets   	  115

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            Attachment 2.      Product Specific Data Call-In Response Forms Plus
                               Instructions	  117
            Attachment 3.      Product Specific Requirement Status and Registrant's
                               Response Forms and Instructions  	  119
            Attachment 4.      EPA Batching of End-Use Products for Meeting Data
                               Requirements for Reregistration	  129
            Attachment 5.      List of All Registrants Sent This Data Call-In Notice
                                 	  135
            Attachment 6.      Cost Share, Data Compensation Forms,  Confidential
                               Statement of Formula Form and Instructions ...  137
      APPENDIX E.      List of Available Related Documents	  145

                                    TABLES

Table 1 - Estimates of Tetrachlorvinphos Use on Livestock	4
Table 2 - Registered Tetrachlorvinphos Manufacturing-Use Products	6
Table 3 - Acute Toxicity Data	7
Table 4 - Anticipated Residues of Tetrachlorvinphos and Metabolites in Animal
         Commodities  	20
Table 5 - Exposure Estimates for Tetrachlorvinphos (Mixer/Loader/Applicator)  ....  23
Table 6 - Exposure Scenario Descriptions for Tetrachlorvinphos	25
Table 7 - Analysis I: All Commodities with Established and Extended1 Tolerances ...  27
Table 8 - Analysis II: Only Uses  Supported for Reregistration	28
Table 9 - Risk Estimates for Occupational/Residential Uses of Tetrachlorvinphos ....  30
Table 10 - Avian Acute  Oral Toxicity Findings	32
Table 11 - Avian Subacute  Dietary Toxicity Findings	33
Table 12 - Mammalian Acute Oral Toxicity Findings	33
Table 13 - Nontarget Insect Acute Contact Toxicity Findings	34
Table 14 - Nontarget Insect Foliar Residue Toxicity Findings  	34
Table 15 - Freshwater Fish Acute Toxicity Findings	35
Table 16 - Freshwater Invertebrate Toxicity Findings   	36
Table 17 - Estuarine/Marine Acute Toxicity Findings	37
Table 18 - Summary of Environmental Chemistry  , Fate and Transport Data	38
Table 19 - Leaching/Adsorption/Desorption Data for Tetrachlorvinphos in 4 Soils ...  41
Table 20 - Residues on Avian and Mammalian Dietary Food Items in PPM	43
Table 21 - Tolerance Reassessment Summary	51

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TETRACHLORVINPHOS REREGISTRATION ELIGIBILITY DECISION TEAM
Office of Pesticide Programs:

Biological and Economic Analysis Division

Douglas W. Sutherland
Ghulam Ali
Steve Jarboe

Environmental Fate and Effects Division

Sharlene R. Matten
Allen Vaughn
William R. Effland

Health Effects Division

David J. Miller
Patricia  McLaughlin
Byron Backus
Kathryn Boyle
Laura E. Morris
Jennifer Wintersteen

Registration Division

John Hebert
George LaRocca
Mark Perry

Special Review and Reregistration Division

Kathy Davis
Bill Wooge

Office of General Counsel:

Jon Fleuchaus

Office of Enforcement and Compliance:

Rick Colbert
Biological Analysis Branch
Economic Analysis Branch
LUIS
Science Analysis and Coordination Staff
Ecological Effects Branch
Environmental Fate and Groundwater Branch
Reregistration Support Chemistry Branch
Toxicology Branch II
Toxicology Branch II
Risk Characterization and Analysis Branch
Occupational and Residential Exposure Branch
Science Analysis Branch
Insecticide-Rodenticide Branch
Insecticide-Rodenticide Branch
Registration Support Branch
Accelerated Reregistration Branch
Accelerated Reregistration Branch

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11

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GLOSSARY OF  TERMS AND ABBREVIATIONS
ADI
AE
a.i.
ARC
CAS
CI
CNS
CSF
DFR
DRES
DWEL
EEC

EP
EPA
FDA
FIFRA
FFDCA
FOB
GLC
GM
GRAS
HA

HOT
LC
LD
LD10
LEL
LOG
LOD
LOEL
MATC
MCLG
mg/L
MOE
MP
MPI
MRID
N/A
NOEC
    Acceptable Daily Intake. A now defunct term for reference dose (RfD) .
    Acid Equivalent
    Active Ingredient
    Anticipated Residue Contribution
    Chemical Abstracts Service
    Cation
    Central Nervous System
    Confidential Statement of Formula
    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, non carcinogenic health effects are not anticipated to
    occur.
    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 Drug Administration
    Federal Insecticide, Fungicide, and Rodenticide Act
    Federal Food, Drug,  and Cosmetic Act
    Functional  Observation Battery
    Gas Liquid Chromatography
    Geometric  Mean
    Generally Recognized as Safe  as Designated by FDA
    Health Advisory (HA) The HA values are used as informal guidance to municipalities and other
    organizations when emergency spills or contamination situations occur.
    Highest Dose Tested
    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.
    Lethal Dose-low. Lowest Dose at which lethality occurs
    Lowest Effect Level
    Level of Concern
    Limit of Detection
    Lowest Observed 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.
    Micrograms Per Gram
    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
    No effect concentration
                                     111

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           GLOSSARY OF TERMS AND ABBREVIATIONS

NPDES        National Pollutant Discharge Elimination System
NOEL         No Observed Effect Level
NOAEL        No Observed Adverse Effect Level
OP            Organophosphate
OPP           Office of Pesticide Programs
PADI          Provisional Acceptable Daily Intake
PAG           Pesticide Assessment Guideline
PAM           Pesticide Analytical Method
PHED         Pesticide Handler's Exposure Data
ppb            Parts Per Billion
PPE           Personal Protective Equipment
ppm           Parts Per Million
PRN           Pesticide Registration Notice
Q*!            The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer Risk Model
RBC           Red Blood Cell
RED           Reregistration Eligibility Decision
REI            Restricted Entry Interval
RfD            Reference Dose
RS            Registration Standard
SLN           Special Local Need (Registrations Under Section 24 (c) 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.
FAO/WHO     Food and Agriculture Organization/World Health Organization
WP            Wettable Powder
WPS           Worker Protection Standard
                                                IV

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EXECUTIVE SUMMARY

       As required under the Federal Insecticide, Fungicide, and Rodenticide Act, as amended in
1988, the U. S. Environmental Protection Agency has considered the reregistration eligibility  for
the pesticide active  ingredient  tetrachlorvinphos.    This eligibility  consideration  includes  a
comprehensive reassessment of the required target data base and use patterns of currently registered
products.  The Agency compared its risk assessment to current science and regulatory policies.
Where appropriate, it has imposed changes to the terms for continued registration in order to reduce
risks to human health and the environment.

       The Agency has determined that the dermal application to livestock, non-food animal, general
outdoor treatment, and pet uses  of tetrachlorvinphos, specified in this document, will not cause
unreasonable risk to humans  or  the environment and these uses are eligible  for reregistration.
However, the Agency cannot make a determination regarding the reregistration eligibility of the feed-
through (oral) livestock use at this time.

       The Agency has determined that all uses of tetrachlorvinphos, with the exception of oral feed-
through larvicide treatment to livestock intended for food use, will not cause unreasonable risk to
humans or the environment and these uses are eligible for reregistration.  The Agency has reviewed
environmental and toxicological data to reach this decision.

       Use Patterns

       Tetrachlorvinphos is an organophosphate insecticide.  It is currently applied dermally to
livestock to control flies and mites.  Tetrachlorvinphos is used as a feed-through (oral) larvicide in
cattle, hogs, goats and horses; in cattle ear tags to control flies; in cattle feedlots; in poultry dust
boxes to control poultry mites; and in poultry houses.  Tetrachlorvinphos also is used in pet sleeping
areas  and pet flea collars.  It is used to control nuisance and public health pests (flies) in and around
refuse sites, recreational areas, and for general outdoor treatment.

       Human Health Assessment

       Tetrachlorvinphos has been classified  as a group C (possible human) carcinogen by the
Carcinogenicity Peer  Review Committee  of  the Agency's  Office  of Pesticide Programs.   It
determined the cancer potency factor (Qx*) of 1.83 x 10~3 (mg/kg/day)"1. Also,  a RfD of 0.04 mg/kg
body  weight/day was established based on a  NOEL of  4.23  mg/kg  bwt/day from  a  chronic rat
feeding study. There were liver histological changes and adrenal changes at 43.2 mg/kg/day (LOEL)
in male rats. An uncertainty factor of 100 was used in setting the RfD.

       Because the livestock uses  result in human dietary  exposure, a tolerance reassessment using
Anticipated Residues (ARs) is included in this document.  Confirmatory data describing the residues
in tissues resulting from the dermal livestock treatments are required for the continued registration
of tetrachlorvinphos.  These data have been required from the registrant.  For feed-through (oral)
larvicide use in livestock, a feed  additive tolerance has been established. However,  this tolerance
is barred by the  Delaney clause  of the Federal Food, Drug and Cosmetic Act (FFDCA) which

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provides that a food/feed additive regulation for a livestock feed additive may not be established for
a pesticide which induces  cancer in man or animals. This is discussed below and in Section IV of
this document.  Data would also be required for the feed-though (oral) larvicide uses;  however, this
requirement has been deferred because the feed additive tolerance currently established has been
proposed for revocation under the Delaney clause of the FFDCA.  The proposed revocation of the
existing FFDCA section 409 tolerance for tetrachlorvinphos was issued September 21, 1995 in the
60 FR 49141.

       Some of the occupational  and residential  exposures  to  tetrachlorvinphos are of concern
because of potential cancer risks. Risks to tetrachlorvinphos handlers wearing full protective clothing
range from 5.7 x 10"8 to 1.3 x 10"5.  Baseline Personal Protective Equipment (PPE) for occupational
handlers of tetrachlorvinphos end-use products are chemical resistant gloves, long-sleeved shirts and
long pants, socks,  and shoes.  PPE for homeowner uses (flea collars, aerosol cans for pet sleeping
areas,  and dust shakers for pet treatments) are not established in this RED because they are not
warranted due to low exposure and risk.  Occupational-use products containing tetrachlorvinphos
which are used on recreational areas are required to carry labeling to restrict re-entry until sprays
have dried, to limit exposure to the wet formulations.

       Environmental Assessment

       In  the environment, tetrachlorvinphos is not persistent but its mobility increases as soil texture
becomes  coarse and the  organic matter content decreases.  The primary route of dissipation is
through biotic degradation.  Under alkaline conditions,  abiotic processes (e.g., hydrolysis) are
somewhat effective.  Parent tetrachlorvinphos is not available from the manure of treated animals and
is therefore not available to the environment from the feed-through (oral) larvicide uses.  Based on
current product labeling,  it is unlikely that serious detrimental impacts to ground or surface water
will occur from the use of tetrachlorvinphos.  Confirmatory  data for describing the hydrolysis of
tetrachlorvinphos have been submitted and are in review.  The results of this  review are not likely
to change the environmental assessment for this pesticide.

       Under the use patterns described in this RED document, tetrachlorvinphos poses little acute
or chronic risk to wildlife.   Exposure to the environment is expected to be  minimal, especially
exposures to aquatic species because of the use patterns.  Although the acute levels of concern are
exceeded  for fresh water  invertebrates and endangered fish and invertebrates,  significant risk is
unlikely due to low exposure.  Chronic exposures and risks are unlikely because of the use patterns.

       Product Reregistration

       Before reregistering the tetrachlorvinphos products with eligible uses, the Agency is requiring
that product specific data, revised Confidential Statements of Formula (CSF) and revised labeling
be submitted within eight months of the issuance of this  document.  These  data include product
chemistry for each registration and acute toxicity testing. After reviewing these data and any revised
labels  and finding them acceptable in accordance with Section 3(c)(5) of FIFRA, the Agency will
reregister a product. Those products which contain other active ingredients will be eligible for
reregistration only  when the other active ingredients are determined to be eligible for reregistration.

                                             vi

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I.      INTRODUCTION

       In 1988, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended
to accelerate the reregistration of products with active ingredients registered prior to November
1,  1984. The amended Act provides a schedule for the reregistration process to be completed in
nine years.  There are  five phases to  the reregistration process.  The first four phases of the
process focus  on identification of data requirements to support the reregistration of an active
ingredient and the generation and submission of data to fulfill the requirements. The fifth phase
is a review by the U.S. Environmental Protection Agency (referred to as "the Agency") of all data
submitted to support reregistration.

       FIFRA  Section  4(g)(2)(A)  states  that in Phase 5 "the Administrator shall  determine
whether pesticides containing such active ingredient are eligible for reregistration" before calling
in  data on products and either reregistering products or taking "other appropriate regulatory
action."  Thus, reregistration involves a thorough  review of the scientific data base underlying a
pesticide's registration.  The purpose of the Agency's review is to reassess the potential hazards
arising from the currently registered uses of the pesticide; to determine the need for additional
data on health and environmental effects; and to determine whether the pesticide meets the  "no
unreasonable adverse effects" criterion of FIFRA.

       This document presents the Agency's decision regarding the reregistration eligibility of
the registered uses of tetrachlorvinphos.  The document consists of six sections. Section I is the
introduction.  Section II describes tetrachlorvinphos, its uses, data requirements and regulatory
history.  Section III discusses the human health and environmental assessment based on the data
available to the Agency.  Section IV presents the reregistration decision for tetrachlorvinphos.
Section V discusses the reregistration requirements for tetrachlorvinphos.  Finally, Section VI is
the Appendices which  support this Reregistration Eligibility Decision.  Additional details
concerning the Agency's review of applicable data are available on request.

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II.    CASE OVERVIEW

      A.     Chemical Overview

             The following active ingredient is  covered by this Reregistration Eligibility
      Decision:

             •     Common Name:     Tetrachlorvinphos

             •     Chemical Name:     (Z)-2-chloro-l(2,4,5-trichlorophenyl) vinyl
                                       dimethyl phosphate

             •     Chemical Family:   Organophosphate

             •     CAS Registry Number:    22248-79-9 [(Z) - isomer]
                                             22350-76-1 [(E) - isomer]
                                             961-11-5 [mixed isomers]

             •     OPP Chemical Code:      083701

             •     Empirical Formula:       C10H9C14O4P

             •     Trade and Other Names:   Rabon*, Gardona^

             •     Basic Manufacturers:      Fermenta Animal Health Company
                                             Hartz Mountain Corporation

      B.     Use Profile

             The following is information on the currently registered uses with an overview of
      use sites and application methods.  A detailed table of these uses of tetrachlorvinphos is
      in Appendix A.

             For Tetrachlorvinphos:

             Type of Pesticide:   Organophosphate insecticide

             Use Sites:

             TERRESTRIAL FEED: Cattle feedlots

             INDOOR FOOD: Agricultural/Farm  Structures/Buildings and Equipment, Cattle
             Feedlots, Beef/Range/Feeder Cattle, Dairy Cattle (Lactating or Unspecified), Dairy
             Goats (Lactating or Unspecified), Hog/Pig/Swine  (Meat), Livestock, Poultry
             (Egg/Meat), Poultry (Meat).

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INDOOR RESIDENTIAL: Cats (Adults/Kittens), Dogs/Canines (Adults/Puppies),
Household/Domestic Dwellings Indoor Premises.

INDOOR NONFOOD:  Horses (Show/Race/Special/Ponies), Mink (Fur Animal),
Specialized Animals (such as racing and hunting dogs, show dogs and cats)

TERRESTRIAL NON-FOOD:  Recreational  Areas,  Refuse/Solid Waste  Sites
(Outdoor), Wide Area/General Outdoor Treatment (Public Health Use).

Pests: Fleas, ticks, lice, flies (adults and larvae), chiggers,  mites, spiders, wasps,
cattle grubs

Formulation Types Registered:

       Technical:                 98.7% a.i.
       Manufacturing use:         97.3% a.i.
       Wettable powder:           50% a.i.
       Dust:                      !%,3%a.i.
       Granular:                  0.18% to 7.76% a.i.
                                 one product 97.3% a.i.
       Pelleted/Tableted           0.3% to 1.25%  a.i. primarily mineral blocks
                                 for cattle/livestock.
       Impregnated material:       3%, 13.7%  a.i. pet collars, cattle ear tags.
       Liquid, ready-to-use:        1% to 2%  a.i. spray on/wipe  on/backrub
                                 materials for pets, horses, cattle.
       Pressurized liquid:          1% a.i. flea and tick  spray for cats.
       Emulsifiable concentrate:    23 %, 24 % a.i.

Methods and Rates of Application:

Application methods include: hand application, hand and power sprayers and
dusters, free-choice  mineral blocks,  livestock feed supplements, poultry dust
boxes,  pressurized aerosol cans, pet collars, and cattle ear tags.

Current application  rates are  largely indeterminate,  with directions to  spray
thoroughly, to cover animal completely, or to  permit free access  to backrubs or
mineral blocks.

Use Practice Limitations: None currently.

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       C.    Usage Data
              This  section summarizes the best estimates available for the pesticidal uses of
       tetrachlorvinphos in the U.S. These estimates are derived from a variety of published and
       proprietary sources available to the Agency.  These data reflect variability in using data
       from  various  information  sources.   Table  1,  below,  summarizes  the  amounts of
       tetrachlorvinphos used by site.

Table 1 - Estimates of Tetrachlorvinphos Use on Livestock
Site
Cattle - Feed Through
Cattle - Dermal
Hogs
Horses
Poultry -Dermal
Other8
Totalh
Pounds a.i.
Per Animal3
0.1725
—
0.0661
0.1808
—
na

Active
Ingredient
Used per
Yearb
(Million Ibs)
2.1
—
0.24
0.12
—
0.44
3.05
Number of
Animals
Treated
c(Million)
12
—
4
1
—
na
12
Total
Number of
Animalsd
(Million)
96
—
111.3
2.1
—
na
211.5
Percentage
of Animals
Treated6
12.7
5-20f
3.18
31
—
na
na
na     not available/applicable
a      Pounds  tetrachlorvinphos  (a.i.) per animal  was calculated using application  rates to
       determine the amount of tetrachlorvinphos applied to the animal.
b      The total  use  of tetrachlorvinphos per type of livestock was obtained from an EPA
       proprietary database that contains information about tetrachlorvinphos distribution in the
       U.S.
c      Number animals treated = Ibs active ingredient used/lbs used per animal.
d      U.S. Dept. of Commerce, 1992 Census of Agriculture, Volume 1, part 51, October 1994
e      Percent livestock treated = number animals treated/total number animals.
f      Information  was  provided by  Extension Entomologists from Texas  A&M  and  the
       University of Wisconsin, and faculty from Oklahoma State University.
g      Information  about the use of tetrachlorvinphos in livestock premises is not  readily
       available.  Similarly, information about treated dogs and cats is not available.
h      Texas and Oklahoma are assumed to be the major states of tetrachlorvinphos livestock use.

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       D.     Use Profile

              Data required in the October 1988  Registration Standard for tetrachlorvinphos
       (Guidance for the Reregistration  of Pesticide Products Containing Tetrachlorvinphos)
       included studies on product chemistry, ecological effects, environmental fate, and residue
       chemistry. These data were required to support the uses listed in the Registration Standard
       and registered at that time.  Appendix B of this RED document includes all data
       requirements identified by the Agency  for a reregistration eligibility decision for the
       currently registered uses.

       E.     Regulatory History

              Tetrachlorvinphos (commonly referred to by the trade names Rabon and Gardona)
       was initially registered for use in  the United States in 1966 by the U.S. Department of
       Agriculture.  The original registrant of technical tetrachlorvinphos  was  Shell Chemical.
       The registration was  subsequently transferred  to E. I. duPont de Nemours.

              In September, 1992, duPont transferred ownership of technical tetrachlorvinphos
       data to Hartz Mountain Corporation and  Fermenta Animal Health Company. Hartz and
       Fermenta each received their own technical grade product registrations in 1992. DuPont
       voluntarily canceled its registration in December 1993. A third technical tetrachlorvinphos
       product was registered to VMX Pet  Products Corporation in 1993.  Hartz is responsible
       for supplying generic data supporting domestic pet uses and Fermenta is responsible for
       supplying generic data supporting  livestock  uses.

              Tetrachlorvinphos was registered for use on various food crops, livestock, pet
       animals, and in or around buildings. However, the crop uses were voluntarily canceled
       from product registrations in  1987.  Currently, the primary uses of tetrachlorvinphos are
       the control of manure flies  in livestock applied as a feed through in the form of feed
       additives; flies and mites in  livestock building premises applied as dusts; and ticks and
       fleas on domestic pets applied as dusts, sprays, and collars.

              In October, 1988, the Agency issued  a Registration Standard.  In the Standard the
       Agency summarized its assessment of the supporting scientific data available at that time
       and identified and required  the submission of additional data, as mentioned  above, to
       support continued registration of tetrachlorvinphos products.

III.    SCIENCE  ASSESSMENT

       A.     Physical Chemistry Assessment

              1.      Description  of Chemical

                     Tetrachlorvinphos [(Z)-2-chloro-l-(2,4,5-trichlorophenyl)vinyl dimethyl

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             phosphate] is a non-systemic organophosphate insecticide. Its molecular structure
             and empirical formula are:
                              Tetrachlorvinphos (beta isomer)

                           Empirical Formula:   C10H9C14O4P
                           Molecular Weight:   366.0
                           CAS Registry No.:   22248-79-9

             2.     Identification of Active Ingredient
                    Technical tetrachlorvinphos  is a tan to brown crystalline solid  with  a
             melting point of 93-98°C and a bulk density of 50-55 Ib/cu. ft.  The solubility of
             tetrachlorvinphos in water at 24°C  is 15 ppm.  Tetrachlorvinphos has  limited
             solubility in most  aromatic hydrocarbons (i.e., 40  ppm  in chloroform and
             dichloromethane, 20 ppm in acetone, and 8 ppm in xylene at 0°C).

             3.     Manufacturing-Use Products

                    There  are five tetrachlorvinphos manufacturing-use  products  (MPs)
             currently registered. They are listed below in Table 2.

Table 2 - Registered Tetrachlorvinphos Manufacturing-Use Products
Formulation
98.8% T
98.7% T
98.7% T
97.3% FI
75% FI
EPA Reg. No.
62725-1
2596-131
56493-88
56493-38
56493-19
Registrant
VMX Pet Products Corp.
Hartz Mountain Corp.
Fermenta Animal
Health Company
Date Registered
11/93
9/92
10/92
8/86
8/86

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       B.    Human Health Assessment
              1.     Toxicology Assessment

                    The toxicological data base  for tetrachlorvinphos is  adequate and will
              support reregistration eligibility.

                    a.     Acute Toxicity

                           Acute  toxicity  values and categories  for  tetrachlorvinphos  are
                    summarized in Table 3.
Table 3 - Acute Toxicity Data
TEST
Oral LD50-rat
Dermal LD50— rabbit
Inhalation LC50-rat
Eye irritation— rabbit1
Dermal irritation— rabbit1
Dermal sensitization— guinea pig1
RESULTS
1480 mg/kg cf;
465-965 mg/kg ?
>2g/kg
>3.61 mg/L
moderate
slight
sensitizer
CATEGORY
III
III
IV
III
IV
—
       Data pertaining to primary eye irritation, dermal irritation, and dermal sensitization are
       not required to support the reregistration of the TGAI.  These data are presented here for
       informational purposes.

                           From an acute oral toxicity study with rats, the LD50 was estimated
                    to be 1480 mg/kg for males and between 465 and 965 mg/kg for females
                    (GDLN 81-1; MRID # 41222504).  An acute dermal toxicity study with
                    rabbits estimated the LD50 to be greater than 2 g/kg (GDLN 81-2;  MRID
                    # 41222505).  An acute inhalation toxicity study with rats estimated the
                    LC50 to be greater than 3.61 mg/L (GDLN 81-3; MRID # 138933).

                           A primary eye irritation study with rabbits resulted in some iritis
                    and redness, clearing by the third day, placing tetrachlorvinphos in Toxicity
                    Category  III (GDLN 81-4; MRID # 41222506). In a dermal irritation
                    study, rabbits exhibited slight irritation,  placing tetrachlorvinphos  in

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toxicity category IV, or low toxicity, for this parameter (GDLN 81-5;
MRID #41222507).

       Two dermal sensitization studies with Hartley albino guinea pigs
indicate that tetrachlorvinphos is a moderate sensitizing agent (GDLN 81-6;
MRID # 41377902, 42981001).

       Tetrachlorvinphos did not cause delayed neurotoxicity in hens in
two studies. In the first study hens were dosed at 300 mg/kg for 5 days or
1.5 g/kg  for  1  day.   Results  were  negative.  In  the  second study,
tetrachlorvinphos was orally administered  to hens in 2 oral doses of 2500
mg/kg, given 21 days apart (cumulative total of 5000 mg/kg).  This did not
result in delayed neurotoxicity as evidenced by in-life observations and
microscopic examinations (GDLN 81-7; MRID #s 115348, 41905901).

       In  an acute neurotoxicity  study, Sprague Dawley rats were orally
dosed at 0, 65, 325, or 650 mg/kg.   Transient neurotoxic effects were
observed in both sexes on day 0 at the two highest doses; these effects were
consistent  with cholinesterase inhibition.  The LOEL was 325 mg/kg and
the NOEL was 65 mg/kg.  Only minor effects remained by day 7, and  all
rats were  normal by day 14.  There was no indication of any permanent
behavioral changes or of any adverse neuropathological effects (GDLN 81-
8; MRID #42912501).

b.     Subchronic Toxicity

       In a 21-day dermal toxicity study, Crl:CD BR rats were given doses
of 0, 10, 100,  or 1000 mg/kg/day tetrachlorvinphos which was applied 6
hours/day, 5 days/week for a total of 15 treatments over the 21 day period.
The NOEL was determined to be 100 mg/kg/day for females and 1000
mg/kg/day for  males. The LOEL was  1000 mg/kg/day for females based
on decreased plasma cholinesterase activity. No other systemic effects and
no dermal effects were observed (GDLN 82-3; MRID # 41342001).

       Tetrachlorvinphos was given to Sprague Dawley rats in the diet at
doses of 0, 100,  2000,  or 5000 ppm (0, 4.23, 43.2, 88.5 mg/kg/day for
males; 0,  5.93, 62.7,  125.3 mg/kg/day for females) for 13 weeks.  The
Agency concluded the NOEL to be 100 ppm for both sexes. The LOEL
was  2000 ppm  based on  reduced plasma and red blood cell (RBC)
cholinesterase  activity in both sexes.   At  the highest dose, these effects
were seen  along with reduced brain cholinesterase activity in females.  Rats
treated at  the two highest  doses  had reduced body  weights and  reduced
weight gains, as well as bilateral basophilic tubules of the kidneys in males,
increased  fat deposition in the adrenal cortex of females, centrilobular

                       8

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hepatocellular hypertrophy in females and mid-dose males, and higher
adjusted adrenal weights in females. In both sexes at the two highest doses
there were thyroid follicular cell hypertrophy and higher adjusted liver
weights (GDLN 82-1; MRID # 43371201).

c.     Chronic toxicity

       In a one-year oral study, tetrachlorvinphos was given to beagle dogs
by capsule at doses of 0, 6.25, 500, or 1000 mg/kg/day.  The systemic
NOEL was determined to be 6.25 mg/kg/day.  The systemic LOEL was
500 mg/kg/day based on decreased RBC counts, hemoglobin, hematocrit,
and urine  specific gravity. There were also increased mean corpuscular
volume, alkaline phosphatase, kidney weights and liver weights.  At 1000
mg/kg/day, females showed increased white blood cell (WBC) count and
males exhibited increased prostate weight as well as decreased cholesterol.
The  plasma  cholinesterase inhibition NOEL in both sexes was  6.25
mg/kg/day and the LOEL was 500 mg/kg/day (GDLN  83-1; MRID #
42679401).

       In  a two-year oral toxicity study, beagle dogs were given dietary
doses of 0, 5, 25,  125, or 2000 ppm (0, 0.13, 0.63, 3.13, 50 mg/kg/day,
respectively).  The Agency concluded the NOEL was 3.13 mg/kg/day.
The LOEL was 50 mg/kg/day, based on decreased plasma cholinesterase
activity and increased relative liver and  kidney  weights  (GDLN 83-1;
MRID  #77819).

       Tetrachlorvinphos was given to Porton rats at dietary levels of 0, 5,
25,  125,  or 2000 ppm (0,  0.25, 1.25, 6.25, and  100  mg/kg/day,
respectively)  for two years.   The NOEL was determined to be 1.25
mg/kg/day.   The  LOEL was 6.25 mg/kg/day  based on  increased liver
weights in females.  At the highest dose, effects included  lower body
weight, lower food intake, decreased plasma cholinesterase activity in
males,  decreased RBC counts and plasma cholinesterase activity in females,
decreased  serum total protein, decreased serum urea, decreased  male
kidney  weights, increased male thyroid weights, and increased female liver
weight (GDLN 83-1; MRID # 112525).

       A two-year study with Sprague Dawley rats used doses of 0, 100,
1000, or 2000 ppm tetrachlorvinphos (0, 4.23, 43.2, and 88.5 mg/kg/day
for males; 0, 5.93,  62.7, and 125.3 mg/kg/day for females) in the feed.
The  Agency concluded the NOEL  for  systemic toxicity  to  be  4.23
mg/kg/day. The LOEL was 43.2 mg/kg/day, based on histological changes
in liver and adrenal glands in both sexes, reduced female weight gains, and
depression of plasma cholinesterase in females. High dose females also had

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elevated cholesterol levels.  At termination there were more thyroid C-cell
adenomas for male rats in the high dose than in the controls, but this was
not statistically significant (GDLN 83-1, 83-2; MRID # 42980901).

d.     Carcinogenicity

       The National Cancer Institute sponsored a carcinogenicity study in
Osborne-Mendel rats using tetrachlorvinphos.  The doses were 0, 4250, or
8500  ppm  given in the diet for 80 weeks which  was followed by
observation for  31 weeks.   Increased incidences of adrenal cortical
adenomas and thyroid C-cell adenomas were found in dosed female rats.
High  incidences of thyroid C-cell  hyperplasia  in both  sexes  further
indicated an effect on the thyroid (MRID # 117443).

       In a carcinogenicity study  with B6C3F1 mice, animals were fed
diets  containing  0,  17.5,  64,  320,  1600,  8000,  or  16000  ppm
tetrachlorvinphos for two years.   For systemic toxicity, the  NOEL was
1600  ppm (240  mg/kg/day)  and the LOEL was 8000 ppm (1200
mg/kg/day), based on decreased weight gain.  In female mice, there  were
statistically  significant increased incidences of hepatocellular carcinoma at
8000  and 16000 ppm, of combined adenomas/carcinomas at  the  three
highest doses, and of adenomas at the highest dose. In male mice,  there
were   statistically  significant  increases  in combined  incidences  of
hepatocellular adenomas and carcinomas at the highest dose,  and in
adenomas, carcinomas, and combined adenomas/carcinomas of the kidney
at the highest dose (GDLN 83-2; MRID # 126039).

       The National Cancer Institute reported another carcinogenicity  study
in B6C3F1  mice.  Tetrachlorvinphos was given in the feed at doses  of 0,
8000, or 16000 ppm for 80 weeks followed by  12 weeks observation.
Increased incidences of hepatocellular carcinomas and  granulomatous
lesions of the liver were found in the dosed mice (GDLN 83-2; MRID #
117443).

e.     Developmental Toxicity

       A developmental toxicity study was conducted with Sprague Dawley
rats.  Doses  of 0,  75, 150,  or 300  mg/kg/day were given to pregnant
females by gavage on days 6-15 of gestation.  The Agency determined the
maternal toxicity NOEL to be 75  mg/kg/day.   The LOEL  was 150
mg/kg/day  based on  reduced weight gain  at both the  150  and 300
mg/kg/day  levels.   The NOEL  for  developmental  toxicity  was 300
mg/kg/day, the highest dose tested (MRID # 42520101).
                      10

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      Another developmental toxicity study with Sprague Dawley rats
tested doses of 0, 75, 150, or 300 mg/kg/day given by gavage on gestation
days 6-15. The maternal toxicity NOEL was 75 mg/kg/day.  The maternal
LOEL was 150 mg/kg/day, based on reductions in weight gain and food
consumption.  There were also tremors and chromodacryorrhea at this
dose.  No indications of developmental toxicity were seen  at the 300
mg/kg/day dose level (MRID # 40152701).  These two studies together
fulfill GDLN 83-3.

      New Zealand white rabbits were used in  a developmental  toxicity
study. Doses of 0, 150, 375, or 750 mg/kg/day were given by gavage on
gestation days 6-19.  The maternal  toxicity NOEL was 375 mg/kg/day.
The maternal LOEL was 750 mg/kg/day based on abortions, red vaginal
fluid, and reduced weight gain.   The developmental NOEL was 150
mg/kg/day.   The developmental LOEL was 375 mg/kg/day, based on
reduced numbers of viable fetuses and reduced  implantations. Animals
treated at the highest dose tested (750 mg/kg/day)  also showed an increased
incidence of early resorptions (GDLN 83-3; MRID # 127831).

f.     Reproductive Toxicity

      In a two-generation reproductive toxicity study, Sprague  Dawley
rats were given 0, 100, 500, or 2000 ppm (0, 5, 25, and 100 mg/kg/day,
respectively)  tetrachlorvinphos in their diets.   The NOEL for systemic
toxicity was 500 ppm. The LOEL was 2000 ppm, based on reduced weight
gains in the Fx generation, increased adrenal gland weights in F0 females,
and reduced weight gains in F0 males. The NOEL for reproductive effects
was 2000 ppm, the highest dose tested (GDLN 83-4; MRID # 42054301).

      A three-generation reproductive toxicity study was conducted in rats
with dietary doses of 0,  100, 330,  or  1000 ppm (0, 5, 16.5,  and 50
mg/kg/day, respectively).  The NOEL for the study was 330 ppm.  The
LOEL was 1000 ppm based on an increase in liver size in the F3 generation
weanlings.  However, no effects were noted microscopically in the livers
or any of the other organs examined.  No effect on fertility (number or size
of litters) was noted (GDLN 83-4; MRID # 00077802).

g.    Mutagenicity

      An Ames test in Salmonella  typhimurium exhibited no mutagenic
effect in strains TA98, TA100, TA1535,  TA1537, and TA1538,  at dose
levels of 66.7, 100, 333, 667,  1000, or 3300 ug/plate with activation, or
at dose  levels of 10, 33.3,  66.7,  100,  333,  or 667 ug/plate  without
activation (MRID # 41222508).

                      11

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       A test for  chromosomal aberration was conducted in Chinese
hamster ovary cells.  The Agency concluded that tetrachlorvinphos was
positive for inducing chromosomal aberrations at 59.9, 79.8, and 99.8
ug/mL, but not at 29.9  or 44.9 ug/mL,  in  the absence  of metabolic
activation.    However,  tetrachlorvinphos  was negative  for inducing
chromosomal aberrations at 12.5, 25, 37.6, or 75.1 ug/mL in the presence
of rat S9/metabolic activation (MRID # 41312901).

       In another study, cultures of rat hepatocytes were dosed with 5, 7.5,
10, 15, 20,  23, 25,  27,  30,  35, or 40  ug/mL of tetrachlorvinphos.
Concentrations of 35 and 40 ug/mL were lethal.  Only the cultures exposed
to doses from 10 to 30 ug/mL were analyzed for evidence of unscheduled
DNA synthesis (UDS).  The results were negative.  (MRID # 42156401).
(These studies fulfill GDLNs 84.)

h.     Metabolism

       Radiolabelled tetrachlorvinphos was given orally to  CD rats as a
single low  dose  (5 mg/kg), as  a single high dose (250 mg/kg), and in a
series of doses (5 mg/kg).   It was almost completely metabolized and most
of the label was excreted in urine (46-60%)  and feces (38-56%) within 48
hours of dosing.  Only minor amounts were found in the tissues.  Very
little  unmetabolized parent compound  was recovered.   The  metabolic
processes produced a number of different metabolites which were not all
identified.      The   major   metabolite   observed   in   feces   was
trichlorophenylethanol with females eliminating  more of this metabolite (18
- 34% total administered  14C) than males (13  - 23%)  at all three dosing
levels. Trichlorophenylethandiol was also found in feces ranging from 4 -
7  % in males and 3 - 6  % in females.  A major metabolite in urine,
trichloromanderic acid, was excreted in males  at 19 - 26% but only 10 -
12% in females. At the high dose, females excreted more (25%) desmethyl
tetrachlorvinphos than males (11%).  However, there  was  essentially no
difference for the  low dose group with males (8%)  and  females  (7%)
(GDLN 85-1; MRID # 41988401).

i.      Dermal Absorption

       A study was conducted with male CD rats using doses of 0.01, 0.1,
1, or 5 mg/cm2  radiolabeled tetrachlorvinphos, with some  of each dose
group sacrificed at 0.5, 1, 2, 4,  or 10 hours.  Additionally, there was a
group of animals, sacrificed at 72 hours, in  which the skin was washed at
10 hours.  The  area of the dermal application was washed  to  recover
unabsorbed tetrachlorvinphos.  Then, the skin, urine, feces, and carcass
were analyzed for percent of total tetrachlorvinphos applied.  For the group

                      12

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sacrificed  at  10  hours,   84%  of  the  total  applied  (0.1  mg/cm2)
tetrachlorvinphos was recovered in the wash, and 9.57% remained in the
skin, urine, feces, and carcass.  This absorption value, 9.57%, is used for
assessing human risk following dermal exposure.  The percent absorption
increased with the  duration of exposure and generally decreased with
increasing  dose.   The actual  quantity of  tetrachlorvinphos absorbed
increased with increasing dose (GDLN 85-2;  MRID # 42111501).

j.      Reference Dose and Cancer Potency Factor

       The Reference Dose (RfD)  Committee of the Agency's Office of
Pesticide Programs,  Health Effects Division (HED) selected a RfD of 0.04
mg/kg body weight/day, based on the NOEL of 4.23 mg/kg bwt/day in the
chronic rat feeding  study (MRID # 42980901), discussed above.   There
were  liver histological changes  and  adrenal  changes observed  at 43.2
mg/kg/day (LOEL) in male rats.  The Committee applied an uncertainty
factor of 100 to account for inter-species extrapolation and intra-species
variability.

       The  Cancer  Peer  Review   Committee  of  HED  classified
tetrachlorvinphos as a Group C, possible human carcinogen, based on
statistically    significant   increases   in   combined   hepatocellular
ademonas/carcinomas (predominantly carcinomas) in the female B6C3F1
mouse,  suggestive  evidence  of thyroid c-cell ademonas and  adrenal
pheochromocytomas in the rat  (MRID  # 126039),  and mutagenicity
concerns. The Agency calculated a cancer potency factor (Qx*) of 1.83 x
10"3 (mg/kg/day)"1 using the Weibull 83 time-to-tumor model.  A 3/4's
scaling factor was used to convert from mouse to  human equivalents.

k.     Domestic Animal Safety

       Domestic animal safety tests for pets are generally conducted when
cats, dogs, or other  domestic animals will be exposed to a given pesticide
through  direct application  for pest control or to support specific label
claims for products used  on pets. One cat  and two dog studies were
performed using formulated tetrachlorvinphos products to check for
cholinesterase  inhibition.

       A 1987 dog  study was performed using female beagles that wore
collars impregnated with 14.5% technical tetrachlorvinphos.  The dogs
were  divided into three groups: control (placebo collar),  1 collar  group
(recommended usage), and 2 collar  group  (2x recommended  usage).
Collars were kept on during pregnancy, parturition, and nursing.  Collars
identical to the mothers' were placed on the puppies at 4 weeks old. The

                      13

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       greatest mean measured  plasma cholinesterase (ChE) inhibition (about
       20-30%, which was statistically significant) occurred 12  days after these
       collars were applied. There was no evidence of any significant plasma ChE
       inhibition in the mothers or of any red blood cell (RBC) ChE inhibition in
       either the mothers or puppies.  There were no significant dose-related
       differences in  weight gains between  the  three  groups  of puppies,
       particularly when sex ratio differences between the groups were taken into
       consideration. (This study was undertaken to satisfy labeling requirements;
       MRID # 40436601)

             The second  dog  study was performed using  a  formulated dip
       product (3.1% technical tetrachlorvinphos) applied with a sponge. Each
       group was composed of 6 dogs ranging in age from 2 to 12 years.  Group
       I was sponged with water (control).  Group II was sponged with a mixture
       of 2 oz.  product/1 gallon water (Ix label specified use dilution).  Group III
       was sponged  with a mixture of 8 oz. product/1 gallon water (4x group).
       Blood was taken from each animal on days  -5, 0 (before treatment), 2, 7,
       and 14.  There was no evidence of any statistically significant reduction in
       RBC and/or plasma ChE activity  in  any group.  (GDLN  86-1; MRID  #
       41810102).

             The cat study was organized in a manner identical to the second dog
       study. Groups I, II,  and III were the same, with each group composed of
       6  cats ranging in age from 3 to 8 years. Blood was taken from each animal
       on the  same  days.   The results were consistent in that there was no
       evidence of any statistically  significant reduction in  RBC and/or  plasma
       ChE activity in any group. (GDLN 86-1; MRID # 41810101)

2.     Exposure Assessment

       a.    Dietary Exposure

             Plant Metabolism

                    While there are established tolerances for tetrachlorvinphos
             on certain crops, no currently registered  tetrachlorvinphos end-use
             product is labeled for use  on any plant commodity.  Therefore,
             plant metabolism data were not required.  The Agency has proposed
             revocation of the associated tolerances as discussed in Section IV.

             Animal Metabolism

                    The qualitative nature of the residue in ruminants following
             oral dosing is adequately understood. In a goat metabolism study

                             14

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the   major   metabolites    identified   were   free   1-(2,4,5-
trichlorophenyl)ethanol,      conjugated      l-(2,4,5-
trichlorophenyl)ethanol,  and 2,4,5-trichloroacetophenone.   The
proposed   metabolic  pathway   in   ruminants  following  oral
administration  involves  conversion  of   tetrachlorvinphos  to
trichlorophenylethanol, which  is  conjugated to glucuronide  or
further metabolized to  trichloroacetophenone.

       Also, the qualitative nature  of the  residue in ruminants
following dermal application is adequately understood.  The major
residues identified were the parent tetrachlorvinphos, free l-(2,4,5-
trichlorophenyl)-ethanol,      conjugated      l-(2,4,5-
trichlorophenyl)ethanol, and 2,4,5-trichloroacetophenone.

       Tetrachlorvinphos was poorly absorbed through the skin,
and  most  residues  adjacent to the  application site were  not
metabolized.  Residues that entered the general  circulation were
extensively metabolized in tissues distal to the application site.  In
the proposed metabolic pathway in ruminants following dermal
application, tetrachlorvinphos was metabolized to either l-(2,4,5-
trichlorophenyl)ethanol, which is conjugated  to glucuronic acid, or
to 2,4,5-trichloroacetophenone,  which is  converted to  2,4,5-
trichlorobenzoic acid.

       The  qualitative nature of the residue in poultry following
dermal application is adequately understood.  The major residues
identified   were  the  parent  tetrachlorvinphos,  des-O-methyl
tetrachlorvinphos,  free l-(2,4,5-trichlorophenyl)-ethanol,  and 1-
(2,4,5-trichlorophenyl)-ethanediol.      The   metabolite   2,4,5-
trichloroacetophenone  was a minor metabolite.

       Tetrachlorvinphos was poorly absorbed through the  skin of
poultry, and most residues  adjacent  to the  application site were
either  not  metabolized or  were  demethylated to  des-O-methyl
tetrachlorvinphos.   Residues that  entered the general circulation
were extensively metabolized in tissues distal to the application site.

       The  proposed  metabolic pathway  in  poultry following
dermal  application is  similar to  that  of ruminants  except that
l-(2,4,5-trichlorophenyl)ethanol is not conjugated, but may  be
metabolized to the mandelic acid and benzoic acid derivatives via
trichlorophenylethanediol and 2,4,5-trichloroacetophenone.
                15

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                                   The  metabolism  of tetrachlorvinphos  in  ruminants and
                            poultry differs.  The  metabolites des-O-methyl tetrachlorvinphos
                            and l-(2,4,5-trichlorophenyl)ethanediol are found only in hens, and
                            the  metabolite  l-(2,4,5-trichlorophenyl)ethanol is found only in
                            goats  (following both  oral  and dermal administration).   The
                            difference in metabolic profiles between goats and  swine,  both
                            mammals,  would  be expected  to  be  less  significant  than the
                            difference between goats and hens.

                                   From analysis of the above animal  metabolism  data, the
                            HED Metabolism Committee has determined that the residues of
                            concern are tetrachlorvinphos, des-O-methyl tetrachlorvinphos, 1-
                            (2,4,5-trichlorophenyl)ethanol (free and conjugated forms), 2,4,5-
                            trichloroacetophenone,  and  l-(2,4,5-trichlorophenyl)ethanediol.
                            See Figure A.

Figure A.  The Chemical Structures of Tetrachlorvinphos and the Metabolites of Concern.
  Des-O-methyl tetrachlorvinphos
l-(2,4,5- Trichlorophenyl)-ethanol
                                   Tetrachlorvinphos (beta
                                           isomer)
 l-(2,4,5-Trichlorophenyl)-ethanediol
  2,4,5-Trichloroacetophenone
                                            16

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Residue Analytical Methods-Plants and Animals

       A  gas  liquid chromatography  (GLC) method  for  the
determination of tetrachlorvinphos per se in animal commodities is
described in the Pesticide Analytical Method (PAM), Vol. II, as
Method I.  Methodology to detect and quantitate the above four
tetrachlorvinphos metabolites of concern does not exist. Therefore,
new  or revised  methods  must  be  developed  for tolerance
enforcement and data collection purposes. The enforcement method
may  determine residues  of  the  parent  and  four  metabolites
individually, or may convert all residues, including the parent, to
a common moiety,  as  long  as  the  parent is also  determined
individually.    The  purpose  of the requirement for  individual
determination of residues of tetrachlorvinphos is to allow  separate
risk assessments  for cholinesterase  inhibition (involving parent
only) and carcinogenicity (involving parent and four metabolites).
The Agency has required these data from the registrants  and has
required them to be submitted  by April 30,  1996.  These methods
are to be used to recalculate the anticipated residues and the risks
as discussed below.

       No  tetrachlorvinphos  end-use  products  are currently
registered for use on any plant commodity.  Provided  existing
tolerances  on  crops are  revoked,  methods for  analysis  of
tetrachlorvinphos residues in plants are not required.

       No data pertaining to the behavior of tetrachlorvinphos using
FDA's multiresidue protocols have been submitted.  Samples from
the  animal  metabolism  studies must be  analyzed by  FDA
multiresidue protocols A, B, D, and E to ascertain if the methods
are capable of accurately quantifying all residues  of concern,
including the metabolites. The FDA PESTDATA database dated
of  August 1993  (PAM  Vol. I,  Appendix II) indicates  that
tetrachlorvinphos (parent) is completely recovered (>80%) using
FDA multiresidue method protocol D (Section 232.4) but is not
recovered using protocol E (Sections 211.1/231.1 and 212.1/232.1,
fatty and nonfatty matrices). The Agency has required these data
from the registrants and has required them to be submitted by April
30, 1996.

Storage Stability

       All data requirements pertaining to storage stability have
been evaluated and deemed adequate, except that additional storage

                17

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stability  data are required for tetrachlorvinphos  and its  four
metabolites of concern in animal tissues and milk to support the
required  magnitude of the residue in animal studies. The Agency
has required these data from the registrants and has required them
to be submitted by April 30, 1996.  Storage stability studies have
been conducted using fortified samples of milk and animal tissues.
Residues  of the tetrachlorvinphos per se are stable for 25 days at 0°
C in milk, for 31 days at 0° C in  milk fat,  for  3  days at room
temperature in muscle, for 4 days at room temperature in kidney,
for 5 days at room temperature in liver, and for 11 days at room
temperature in fat.

Magnitude of the Residue in Plants
Magnitude of the Residue in Processed Food/Feed
Confined/Field Rotational Crops

       As stated under Plant Metabolism, no tetrachlorvinphos end-
use  products are currently registered  for  use  on any plant
commodity.  Therefore, no field residue data, processing data, or
confined/field rotational crop studies were required. The existing
tolerances on crops have been proposed for revocation.

Magnitude of the Residue in Meat, Milk, Poultry, and Eggs

       Ruminant, swine,  and  poultry  magnitude of the residue
studies have  been reevaluated  for  reregistration.  The Agency
concludes that these studies are inadequate. They failed to reflect
dosing rates  representing  the  maximum  expected  combined
exposures and do not contain data for all residues of concern.
Therefore, new magnitude of the residue studies reflecting dermal
applications to cattle and poultry are required as confirmatory data.
The Agency has required these data from the registrants and they
are due by April 30, 1996.

       Because the Agency cannot make an eligibility determination
for livestock oral feed-through use (refer to  Section IV  of this
document for more detail), the Agency has deferred the requirement
for new magnitude of the residue studies reflecting oral application
to cattle and swine.

       No residue data are required for horses provided that all
applicable labels prohibit treatment of horses destined for slaughter.
The label for the 7.76% G oral larvacide formulation (EPA. Reg.
No. 56493-35) must be amended to prohibit treatment of horses

                18

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destined for slaughter, or registrants must include the horse in their
magnitude of residue studies.

Anticipated Residues (ARs)

       Due to the inadequate studies for magnitude of the residue
in meat/milk/poultry/eggs, available residue data are insufficient to
assess the established tolerances for residues of tetrachlorvinphos in
the fat of cattle, goats, hogs, horses, sheep, and poultry; in eggs;
and in milk fat (including negligible residues in whole milk).  New
magnitude of the residue studies have been required and are due by
April 30,  1996.

       The Agency used anticipated residues (ARs)  to estimate
human exposures for both chronic  and upper bound carcinogenic
dietary risk. The estimates (see Table 4) were developed based on
data from metabolism studies, which at the present time are the best
available  residue  data.   Some  of the  AR estimates  exceed the
current tolerance levels.  This results from 1) the use of data from
the nature of the residue studies (metabolism) instead of the use of
data from the magnitude of the  residue  studies (due to  their
inadequacies), and 2) use of a revised  tolerance expression which
includes tetrachlorvinphos and the four metabolites of concern.

       The Agency's anticipated residue estimates  were further
refined using percent uses of livestock treated in the United States.
Two methods were used to estimate the  percentages. For dermally-
treated cattle and  poultry, percent estimates were obtained  from
various  sources.  These  percentages and  sources  are specified in
Table 1.   Five to twenty  percent of cattle are treated dermally and
about eleven percent of poultry are treated.  For all other livestock,
the percents were calculated using application rates from labels.
These ranged from 3.18 percent for hogs, 12.7 percent for orally-
treated cattle, and 31 percent  for  horses.  Until the  oral  (feed-
through) tolerance is revoked,  it must still be considered in this
evaluation.  It should be noted that these estimates are derived on
the basis  of  certain  assumptions and  therefore  may  have  a
significant degree of uncertainty. It should be further emphasized
that these estimates were made for the purpose of data refinement
only, since magnitude of the residue data were not available.  Once
the required studies have been submitted and evaluated, ARs for
tetrachlorvinphos and its metabolites will be recalculated and the
risk will be re-examined in light of this new information.
                19

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Table 4 - Anticipated Residues of Tetrachlorvinphos and Metabolites in Animal Commodities
Commodity

Cattle, meat
[loin muscle, round muscle]
Cattle, fat
Cattle, mbyp
Eggs
Goats, meat
Goats, fat
Goats, mbyp
Hogs, meat
Hogs, fat
Hogs, mbyp
Horses, meat
Horses, fat
Horses, mbyp
Milk
Poultry, meat
[breast muscle, thigh muscle]
Poultry, fat
Poultry, mbyp
Sheep, meat
Sheep, fat
Sheep, mbyp
Tetrachlorvinphos
Plus Regulated
Metabolites From
Oral Nature of the
Residue Studies3
(ppm)
[<0.01, <0.01]b
0.06
0.50
n/a
<0.01
0.06
0.50
<0.01
0.06
0.50
<0.01
0.06
0.50
0.005
nac
nac
nac
<0.01
0.06
0.50
Tetrachlorvinphos
Plus Regulated
Metabolites From
Dermal Nature of
the Residue
Studies3 (ppm)
[1.87, 0.01]
0.10
0.13
0.28
1.87
0.10
0.13
1.87
0.10
0.13
1.87
0.10
0.13
0.02
[0.059, 2.90]
6.94
1.27
1.87
0.10
0.13
Refined
Residues
Using
Percent
Livestock
Treated Data
0.077
0.028
0.090
0.0308
0.387
0.160
0.630
0.012
0.005
0.020
0.000
0.000
0.000
0.005
0.192
0.763
0.140
0.000
0.000
0.000
b
c
These concentrations represent parent plus four metabolites and are to be used for chronic
and carcinogenic dietary risk evaluation.
Apparent analytical limit of quantification (LOQ) 0.01 ppm; l/i LOQ 0.005 ppm.
Not applicable. Not fed to poultry.
                                          20

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              Currently, tolerances for tetrachlorvinphos per se exist for
       alfalfa; apples; cherries; corn, grain (sweet and pop); cranberries;
       peaches; pears; tomatoes; and horse meat, fat and byproducts. The
       use of tetrachlorvinphos on these fruit and vegetable commodities
       has been voluntarily canceled.  The  use  of tetrachlorvinphos on
       horses used for food is prohibited by labeling.  Dietary risk was
       calculated both with and  without these tolerances,  based on the
       assumption  that until  these  tolerances are revoked, the  use  of
       tetrachlorvinphos could still occur on imported commodities.

b.     Occupational and Residential Exposure

       An occupational and/or residential exposure assessment is required
for an active ingredient if (1) certain toxicological criteria are met and (2)
there is potential exposure to handlers (mixers, loaders, applicators) during
use or to persons entering treated sites after application is complete.  These
criteria for tetrachlorvinphos and its uses are met. Therefore, the Agency
conducted  a  limited   exposure/risk  assessment  for   handlers   of
tetrachlorvinphos using  chemical-specific data and  other  generic data
obtained from the Pesticide Handlers Exposure Database (PHED).

       Handler (Mixer/Loader/Applicators) Exposures

              In an occupational setting,  tetrachlorvinphos  is applied by
       hand application (e.g.,  treating  cattle with dust formulation), hand
       and  power  sprayers  and  dusters,  free-choice  mineral  blocks,
       granular feed supplements, dust boxes (for poultry), cattle ear tags,
       pressurized aerosol cans, and pet collars.

              Product label directions permit "free access" (e.g., free-
       choice mineral blocks), and  include  specific  maximum rates for
       cattle/swine and other farm animal treatments.  Products  containing
       tetrachlorvinphos intended primarily  for homeowner use  are for
       controlling  fleas on   cats,  dogs,  and  in pet  sleeping   areas.
       Application  rates for these  spot treatments, when given, are to
       "spray thoroughly."

              The Agency has determined that there is potential exposure
       to mixers, loaders, applicators, or other handlers for use patterns
       associated with tetrachlorvinphos. Specifically, the Agency focused
       on potential exposures arising from  mixing and loading  liquids,
       wettable powders, and granulars, and from applications of aerosols,
       dusters, pellets, power sprayers,  low pressure handwands, and
       impregnated material (backrubbers).

                       21

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       The Agency required two mixer/loader/applicator (M/L/A)
exposure    studies   per   the   Registration   Standard    for
Tetrachlorvinphos (October 1988).  Studies at one indoor site and
one outdoor site were required.

       Chemical-specific M/L/A data using the product Rabon® 50
WP were generated by registrants  using power sprayers  for  the
interior of poultry houses (MRID # 42622301). The acceptability
of this study is pending  the Agency's verification of the  storage
duration of the field samples versus the storage duration of the field
recovery samples.  This verification is necessary to validate  the
storage stability of tetrachlorvinphos.

       Based on the use patterns and potential exposures described
above,  EPA  identified  the  major  exposure  scenarios   for
tetrachlorvinphos. These exposure scenarios are presented in Table
5. Table 6 summarizes the personal protective clothing, equipment,
and other assumptions used for each exposure  scenario.  Protection
factors were applied, when needed, to the exposure data reported in
Table 6 to simulate personal protective equipment  such as long-
sleeved shirt and long pants, and the use or absence of gloves. The
Agency relied on the results of the dermal absorption study  (MRID
# 42111501, summarized previously) conducted on male CD rats,
which found a 9.57% dermal absorption rate.
                22

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Table 5 - Exposure Estimates for Tetrachlorvinphos (Mixer/Loader/Applicator)
Exposure Scenario
(Scenario. #)
Dermal Exposure"
(mg/lb ai)
Inhalation Exposure1"
(mg/lb ai)
Maximum Label
Application Rate0
Daily Maxd
Treated
Daily Dermal
Dosee
(mg/kg/day)
Daily Inhalation
Dosef
(mg/kg/day)
LADD8
(mg/kg/day)
Mixer/Loader Exposure
Liquids (I)
Granules (II)
Wettable Powder (Ilia)
[gloves]
Wettable Powder (Illb)
[no gloves]
0.3
0.03
0.3
1.2
0.0004
0.0024
0.024
0.005
0.027 Ib ai/cow
0.14 Ib ai/cow
40 Ib ai/poultry
house
40 Ib ai/poultry
house
400 cattle
400 cattle
1 poultry house
1 poultry house
0.0044
0.0023
0.016
0.067
.00006
.0019
.014
.0028
1.1 x 104
1 x 10 4
5.3 x 10 4
1.2x 10 3
Applicator Exposure Only
Aerosol Can (IV)h
Dusters (V)h
Pellets (VI)
Power Sprayers (VII)
Impregnating Material (VIII)
109
No Data
No Data
0.6 (gloves)
No Data
3.5
No Data
No Data
0.006
No Data
0.00433 Ib ai/can
No Data
No Data
40 Ib ai/poultry
house
1% solution, 1
gallon per 20
linear feet
1 can
No Data
No Data
1 poultry house
No Data
0.00064
No Data
No Data
0.033
No Data
.00022
No Data
No Data
.0034
No Data
3.1 x 105
No Data
No Data
6.4 x 104
No Data
Mixer/Loader/Applicator
Low Pressure Handwand (IX)
Backpack/Knapsack (X)
103
2.6
0.039
0.03
1.41bai/A
1 .4 Ib ai/A
1 acre
1 acre
0.20
0.0048
.00078
.0006
7.1 x 10 3
1.9 x 10"
        Dermal unit exposures are reported as the best fit mean to simulate workers wearing long pants, long-sleeved shirts, and no gloves.  The best fit mean is the composite
        total dermal exposure based on using the geometric mean for log normal distributed data, arithmetic mean for normal distributed data, and the median for all other
        distribution types.  The tetrachlorvinphos generated mixer/loader and applicator data are reported as the geometric mean. Protection factors were used to calculate dermal
        exposure values because insufficient data are available for PPE in these scenarios.  Fifty percent of the total dermal exposure is assumed to be attributed to hand exposure.
        Fifty percent protection factor is applied to the dermal (non-hand) exposure for simulating long pants and long-sleeved shirts.  NOTE:  Worker wore chemical-resistant
        gloves in MRID # 42622301.
                                                                              23

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b       Inhalation exposure values are reported as geometric means (log normal distribution).  No adjustment has been made to simulate workers wearing dust/mist respirators.
        Tetrachlorvinphos labels  (56493-29, 56493-34, 56493-13).
d       Values represent the maximum area which is assumed to be used in a single day to complete treatments for each exposure scenario of concern.
e       The Daily Dermal Dose has been adjusted for dermal absorption based on the data presently available. The Agency assumed ten hours exposure (a typical 8 hour work
        day plus time before washing any material from the skin). The value used (9.57%) is a combination of tetrachlorvinphos bound to the skin, that could not be washed off
        and is therefore available for absorption, and absorbed tetrachlorvinphos. (MRID 42111501)
        Daily Dermal Dose (mg/kg/day) = Exposure (mg/lb ai) X  Max. Appl. Rate (Ib ail cycle)  X  Max. Treated  X  0.0957 absorbed
                                                                        70kg
f       Inhalation Daily Dose (mg/kg/day) =  Exposure (mg/lb ai)   X  Max. Appl. Rate (Ib ai/cycle)  X  Max. Treated
                                                                70kg"
        (Assumed 100 %  absorption via the inhalation pathway.)
8       LADD (mg/kg/day) = [Daily Dermal Dose + Daily Inhalation Dose(mg/kg/day)]  X  (Work Days Per Yr/365 Days Per Year)  X  (35 Yrs/70 Yrs)
h       May be homeowner and/or occupational use

Exposure Scenarios
I.       Liquids                 - Preparation of livestock, pet, and premise sprays, wipe-ons, and back-rubbers
II.      Granular                - Preparation of pesticide to livestock feeds
III.     Wettable Powder         - Preparation of dust for poultry dust boxes
IV.     Aerosol Can             - Application of pesticide by aerosols to dogs, cats for controlling fleas, ticks
V.      Dusters                 - Application of dusts to livestock - manually and with dust bags, dust boxes for poultry
VI.     Pellets                  - Application of mineral blocks or the additive to animal feeds
VII.    Power Sprayers          - Application of liquid to poultry houses  using pressure sprayers
VIII.    Impregnating Materials   - Application of soluble liquid to burlap or rope backrubber
XI.     Low Pressure Handwand - Application of liquid to cattle feed lots  and general outdoor areas (picnic areas,  recreational areas)
X.      Backpack/Knapsack      - Application of liquid to cattle feed lots  and general outdoor areas (picnic areas,  recreational areas)
                                                                               24

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Table 6 - Exposure Scenario Descriptions for Tetrachlorvinphos
Exposure Scenario
(Scenario #)
Data
Source
Clothing
Scenario"
Equipment
Standard Assumptions'1
Comments"
Mixer/Loader Exposure
Liquids(I)
Granules (II)
Wettable Powders
(Ilia)
Wettable Powders
(IHb)
PHED
PHED
MRID#
42622301
PHED
Long Pants,
Long-Sleeved
Shirt, No
Gloves
Total
Deposition,
No Gloves
Single Layer
Coveralls,
Gloves
Long Pants,
Long-Sleeved
Shirt, No
Gloves
Open Mixing
Open Mixing
Open Mixing
Open Mixing
Treat cattle every 10 days for 6
months (18 treatments)
Feed to cattle every 10 days for
6 months (18 treatments)
4 Ib ai/100 gal; 1 gal/ 100 birds;
100,000 birds/facility;
treat once every 14 days for 6
months (13 treatments)
4 Ib ai/100 gal; 1 gal/ 100 birds;
100,000 birds/facility;
treat once every 14 days for 6
months (13 treatments)
Acceptable grades;
Dermal =14+ replicates;
Inhalation = 40 replicates;
High confidence in data
All grades;
Dermal = 3 to 14 replicates;
Inhalation =14 replicates;
Low confidence in data
Acceptable grades (pending verification
of storage stability);
Dermal and inhalation = 16 replicates;
High confidence in data (based on
preliminary findings)
All grades;
Dermal = 4 to 33 replicates;
Inhalation = 35 replicates;
Medium to low confidence in data
Applicator Exposure Only
Aerosol Can (IV)
Dusters (V)
Pellets (VI)
Power Sprayers (VII)
Impregnating
Material (VIII)
PHED
No Data
No Data
MRID#
42622301
No Data
Total
Deposition,
Gloves
No Data
No Data
Single Layer
Coveralls,
Gloves
No Data
Aerosol Can
No Data
No Data
Wandtype Sprayers,
Coarse Spray, Single
Nozzle, 100 ft. long
hose
Burlap or Rope
Backrubber
1 can - 1 animal treated once per
week for 6 months (26
treatments)
No Data
No Data
4 Ib ai/100 gal; 1 gal/ 100 birds;
100,000 birds/facility;
treat once every 14 days for 6
months (13 treatments)
No Data
All C grades;
Dermal and Inhalation = 15 replicates;
Medium confidence in data
No Data
No Data
Acceptable grades (pending verification
of storage stability) ;
Dermal and inhalation = 16 replicates;
High confidence in data (based on
preliminary findings)
No Data
Mixer/Loader/Applicator
Low Pressure
Handwand (IX)
Backpack/Knapsack
(X)
PHED
PHED
Long Pants,
Long-Sleeved
Shirt, No
Gloves
Long Pants,
Long-Sleeved
Shirt, Gloves
2 to 3 gallon low
pressure single wand
2 gallon Knapsack
1 acre treated once per week for
6 months (26 treatments)
1 acre treated once per week for
6 months (26 treatments)
All grades;
Inhalation = 95 replicates;
Dermal = 25 to 95 replicates;
Medium confidence in data
Acceptable grades (except for hand
exposure) ;
Inhalation = 9 replicates;
Dermal = 9 replicates;
Medium confidence in data
        Clothing scenario represents actual monitored exposure data.  The dermal exposure values in Table 5 have been adjusted using
        protection factors to simulate long pants, long-sleeved shirt and gloves/no gloves, as noted.
        Standard Assumptions based on an 8-hour work day as estimated by OREB. BEAD data were not available.
        These grades are based on Quality Assurance/Quality Control data provided as part of the exposure studies. "Acceptable grades"
        for dermal and inhalation studies are A and B as defined in Subdivision U Guidelines. All grades that do not meet the guidelines
        are listed separately.  A replicate refers to data acquired during one complete work cycle.  High confidence in data indicates that
        there were at  least 15  replicates of Grades A  and B data.  Medium  confidence in data indicates that there were at least 15
        replicates,  but that some of the data did not meet the criteria for Grades A and B data.  Low confidence in data indicates that there
        were less than 15 replicates of data.
                                                             25

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              Post-Application Exposure

                    The Agency believes  that there is  potential  exposure to
              persons entering treated sites after application is complete.

                    As   discussed   above,  tetrachlorvinphos   meets   the
              toxicological criteria (classification as Group C-possible human
              carcinogen)  for  consideration of a risk  assessment.   However,
              because the uses are primarily to animals and in animal areas, the
              potential  for post-application exposure should be minimal.  For
              example,  for indoor premise-residential use (i.e., aerosol can) the
              label states that application to pets and bedding is a spot treatment.
              Therefore, post-application  exposure data have not been required.

3.     Risk Assessment

       a.      Dietary Risk

              An  acute dietary  risk  assessment was  not  required  since  an
       appropriate toxicological endpoint was not identified.

              (1)    Chronic Dietary Risk

                    EPA performed a chronic dietary risk assessment based on
              the RfD for tetrachlorvinphos. As discussed previously,  the RfD
              is 0.04 mg/kg body wt/day based on  a chronic rat feeding study
              (MRID 42980901).

                    For this assessment, the Agency performed four analyses
              based on  different assumptions of residues available in the human
              diet.  Each assessment calculated the  chronic dietary risk for the
              overall U.S. population and  22 population subgroups.  In Analysis
              I (see Table 7), exposure was calculated for all commodities with
              established tolerances and commodities where tolerances are to be
              established.  Assessment la was performed using tolerance level
              residues.  Tolerances for meat and meat by-product commodities do
              not  currently exist for cattle, hogs,  goats, sheep,  and  poultry.
              These commodities were included in this assessment by extending
              the existing fat tolerances to meat and meat-by-products (i.e., the
              established tolerance of 0.75 part per million for poultry fat was
              used  for chicken  and  turkey).     This  could  result  in  an
              overestimation  or underestimation  of risk,  but due  to  data
              limitations, it was the only  method available to the Agency at this
              time.  A second assessment (Ib) was performed using anticipated

                              26

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                            residues for meat, milk, poultry, and eggs (See Table 8).  Use of
                            anticipated residues is considered to be a more accurate estimate of
                            dietary exposure and therefore a more realistic scenario.  However,
                            for this scenario, anticipated residues were not available for fruit
                            and vegetable  commodities;  therefore, it was necessary  to use
                            tolerance level residues for fruits and vegetables in the anticipated
                            residue calculation.  This could result in a possible overestimation
                            of risk.

                                   In Analysis II,  only those commodities supported by the
                            registrants  for reregistration (orally and dermally treated livestock)
                            were included in  the  exposure  assessments.    Alfalfa, apples,
                            cherries, corn (grain, sweet and pop), cranberries, peaches, pears,
                            tomatoes, and horse (meat, fat, and byproducts) have been proposed
                            for revocation, and are not included in this Analysis.  Analysis Ha
                            used tolerance values for residues and Analysis lib used anticipated
                            residue values from Table 4.

                                   In these four analyses the Agency  compared  the estimated
                            dietary exposures to the reference dose (0.04 mg/kg bwt/day) for
                            a measure  of dietary risk. The % RfD is  a measure  of how much
                            of the RfD has been taken up by the estimated exposure.

Table 7 - Analysis I: All Commodities with Established and Extended1 Tolerances
Assumed
Residues
Using
Tolerance
Level
Residues (la)
Using
Anticipated
Residues (Ib)
Subgroup
U.S. Population
Non-nursing Infants ( < 1 year)
Nursing Infants ( < 1 year)
Children (1-6 years)
Children (7-12 years)
Exposure
(mg/kg/day)
0.031951
0.153108
0.088606
0.082572
0.049890
%Reference
Dose
80
380
220
210
120
All other subgroups were less than 100% of the RfD
U.S. Population
Non-nursing Infants ( < 1 year)
Nursing Infants ( < 1 year)
Children (1-6 years)
0.023441
0.117466
0.079950
0.061191
59
290
200
150
All other subgroups were less than 100% of the RfD
1 Tolerances for meat and meat by-product commodities do not currently exist for cattle, hogs, goats, sheep, and
poultry.  These commodities were included in this assessment by extending the existing fat tolerances to meat and
meat-by-products.
                                            27

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Table 8 - Analysis II: Only Uses Supported for Reregistration
Assumed
Residues
Using
Tolerance
Level
Residues
(Ha)
Using
Anticipated
Residues
(lib)
Subgroup
U.S. Population
Non-nursing Infants ( < 1 year)
Exposure
(mg/kg/day)
0.009036
0.036636
%Reference
Dose
23
92
All other subgroups were less than 57% of the RfD
U.S. Population
Non-nursing Infants ( < 1 year)
Children (1 -6 years)
0.000525
0.000994
0.001100
1
2
3
All other subgroups were less than 3% of the RfD
                                  Overall, chronic dietary risk appears to be minimal when
                           only uses supported for reregistration are included in the calculation
                           (Analyses Ha and lib).

                           (2)     Carcinogenic Dietary Risk

                                  The Agency also calculated the upper bound carcinogenic
                           risk from consumption of food commodities, using anticipated
                           residues of tetrachlorvinphos in animal products and tolerance levels
                           in vegetables and fruits, in the following equation:

                           Upper Bound Cancer Risk = Anticipated Dietary Exposure x Qj*

                                  For the U.S. population,  based on a  Qx* of  1.83 x  1"6
                           (mg/kg/day)"1, the upper bound cancer risk was calculated to be 4.3
                           x 10"5, contributed through  all the published tolerances (supported
                           and unsupported  uses) for  tetrachlorvinphos.  This assumes  that
                           100% of the fruit and vegetable commodities consumed by the U.S.
                           population are imported and contain tetrachlorvinphos  at tolerance
                           levels.

                                  However, when only commodities of supported food uses
                           (meat, milk, poultry, and eggs) are considered, the dietary cancer
                           risk is 1 x 10"6.
                                           28

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b.     Occupational and Residential Risk

       A short term or intermediate term occupational or residential risk
assessment was not required since an appropriate toxicological endpoint
was not identified.

       The Agency's cancer risk estimates for occupational and home uses
of tetrachlorvinphos are presented in Table 9. The Agency lacks data to
evaluate the risks in three worker exposure scenarios: dusters, pellets, and
impregnating material. The Agency believes that the uses of low-pressure
handwands and power sprayers represent worst-case exposure scenarios
(due to the  nature  of a spraying operation) for the current uses of
tetrachlorvinphos.  Since risks to workers under these worst-case scenarios
do not exceed the Agency's level of concern, it is not likely that exposures
resulting from applications of dusts, pellets,  or impregnating materials will
exceed the Agency's level of concern.  The upper bound estimates of
carcinogenic  risk range  from  1.3  x  10~5  (low-pressure handwand/
applicator) to 5.7 x 10~8 (aerosol can/applicator).
                       29

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Table 9 - Risk Estimates for Occupational/Residential Uses of Tetrachlorvinphos
Exposure Scenario
(Scenario #)
Dermal Exposure"
(mg/lb ai)
Inhalation
Exposureb
(mg/lb ai)
Maximum Label
Application
Ratec
Daily Maxd
Treated
Daily
Dermal
Dose6
(mg/kg/day)
Daily
Inhalation
Dose'
(mg/kg/day)
Mixer/Loader/Applicator
LADD8
(mg/kg/day)
RISK11
Mixer/Loader Exposure
Liquids (I)
Granules (II)
Wettable Powder (Ilia)
[gloves]
Wettable Powder (Illb)
[gloves]
0.3
0.03
0.3
1.2
0.0004
0.0024
0.024
0.005
0.027 Ib ai/cow
0.141bai/cow
40 Ib ai/poultry
house
40 Ib ai/poultry
house
400 cattle
400 cattle
1 poultry house
1 poultry house
0.0044
0.0023
0.016
0.067
.00006
.0019
.014
.0028
1.1 x 104
1 x 10 4
5.3 x 10 4
1.2x 10 3
2.0 x 10 7
1.8 x 10 7
9.7 x 107
2.2 x 10 '
Applicator Exposure Only
Aerosol Can (IV)1
Dusters (V)1
Pellets (VI)
Power Sprayers (VII)
[gloves]
Impregnating Material (VIII)
109
No Data
No Data
0.6 (gloves)
No Data
3.5
No Data
No Data
0.006
No Data
0.00433 Ib ai/can
No Data
No Data
40 Ib ai/poultry
house
1% solution, 1
gallon per 20
linear feet
1 can
No Data
No Data
1 poultry house
No Data
0.00064
No Data
No Data
0.033
No Data
.00022
No Data
No Data
.0034
No Data
3.1 x 105
No Data
No Data
6.4 x 104
No Data
5.7 x 10 8
No Data
No Data
1.2x 10 6
No Data
Mixer/Loader/Applicator
Low Pressure Handwand (IX)
Backpack/Knapsack (X)
103
2.6
0.039
0.03
1.41bai/A
1 .4 Ib ai/A
1 acre
1 acre
0.20
0.0048
.00078
.0006
7.1 x 10 3
1.9 x 10"
1.3 x 10 5
3.5 x 10 7
        Dermal unit exposures are reported as the best fit mean to simulate workers wearing long pants, long-sleeved shirts, and no gloves.  The best fit mean is the composite
        total dermal exposure based on using the geometric mean for log normal distributed data, arithmetic mean for normal distributed data, and the median for all other
        distribution types.  The tetrachlorvinphos generated mixer/loader and applicator data are reported as the geometric mean.  Protection factors were used to calculate dermal
        exposure values because insufficient data are available for PPE in these scenarios. Fifty percent of the total dermal exposure is assumed to be attributed to hand exposure.
        Fifty percent protection factor is applied to the dermal (non-hand) exposure for simulating long pants and long-sleeved shirts.  NOTE:  Worker wore chemical-resistant
        gloves in MRID # 426220301.
        Inhalation exposure values are reported as geometric means (log normal distribution).  No adjustment has been made to simulate workers wearing dust/mist respirators.
        Tetrachlorvinphos labels (56493-29,  56493-34, 56493-13).
                                                                              30

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d       Values represent the maximum area which is assumed to be used in a single day to complete treatments for each exposure scenario of concern.
e       The Daily Dermal Dose has been adjusted for dermal absorption based on the data presently available, the Agency assumed ten hours exposure (a typical 8 hour work
        day plus time before washing any material from the skin). The value used (9.57%) is a combination of tetrachlorvinphos bound to the skin, that could not be washed off
        and is therefore available for absorption, and absorbed tetrachlorvinphos.
        (MRID# 42111501)
        Daily Dermal Dose (mg/kg/day) = Exposure (mg/lb ai)  X Max. Appl. Rate (Ib ai/cycle)  X  Max. Treated  X  0.0957
                                                               70kg
f       Inhalation Daily Dose (mg/kg/day) = Exposure (mg/lb ai)  X   Max. Appl. Rate (Ib ai/cycle)  X   Max. Treated
                                                               70kg"
        (Assumed 100% absorption via the inhalation pathway)
8       LADD (mg/kg/day) = [Daily Dermal Dose + Daily Inhalation Dose(mg/kg/day)]  X  (Work Days Per Yr/365 Days Per Year) * (35 Yrs/70 Yrs)
h       Risk = LADD (mg/kg/day)  X  (Q*); where Q*  =   1.83  x 10'3 mg/kg/day1.
1       May be homeowner and/or occupational use
                                                                             31

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                    c.     Domestic Animal Safety

                           Tetrachlorvinphos may be applied directly to pets for flea control.
                    Based on the results of studies on cats and dogs, risks to domestic animals
                    from tetrachlorvinphos products are expected to be minimal.

       C.    Environmental Assessment

             1.     Ecological Toxicity

                    The ecotoxicological data base is adequate to characterize the toxicity of
             tetrachlorvinphos to nontarget terrestrial and aquatic organisms when used on the
             registered sites.

                    a.     Toxicity to Terrestrial Animals

                           (1)    Birds, Acute and Subacute

                                  In order to establish  the toxicity  of tetrachlorvinphos to
                           birds,  the following tests are required  using the technical grade
                           material:  one avian single-dose oral (LD50) study on one species
                           (preferably mallard or bobwhite quail); two subacute dietary studies
                           (LC50) on one species of waterfowl (preferably the mallard duck)
                           and one species of upland game bird (preferably bobwhite quail or
                           ring-necked pheasant).

                                  (a)    Avian Acute Toxicity

                                        The Agency relied  on studies  (MRID  #  160000)
                                  using three avian test species.   From its review  of these
                                  data,  the  Agency  concludes  that  tetrachlorvinphos is
                                  practically non-toxic to birds.
Table 10 - Avian Acute Oral Toxicity Findings
Species
Mallard duck
Ring-necked pheasant
Chukar1
% Test Material
(TGAI)
Tech.
Tech.
Tech.
LDSO
> 2000 mg/kg
> 2000 mg/kg
> 2000 mg/kg
Conclusions
practically non-toxic
practically non-toxic
practically non-toxic
1  Study is supplemental because chukar is not a recommended species for this test.
                                           32

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                                         These  results  show  that   tetrachlorvinphos   is
                                  practically non-toxic to birds.   The guideline requirement
                                  for the avian acute oral LD50 study is  fulfilled. (MRID #
                                  160000)

                                  (b)    Avian Subacute Dietary Toxicity

Table 11 - Avian Subacute Dietary Toxicity Findings
Species
Bobwhite Quail
Mallard Duck
% Test Material
96
96
LCSO
>5000 ppm
>5000 ppm
Conclusions
practically nontoxic
practically nontoxic
                                         On  a  subacute  dietary basis,  tetrachlorvinphos  is
                                  practically  nontoxic to birds.  Two  studies,  one on the
                                  mallard duck and one on the bobwhite quail produced LC50s
                                  > 5000 ppm (MRID # 22923).

                           (2)     Birds, Chronic

                                  Avian reproduction studies are required when birds may be
                           exposed   repeatedly   or  continuously   through  persistence,
                           bioaccumulation,  or  multiple applications,  or  if  mammalian
                           reproduction tests indicate reproductive toxicity.  These conditions
                           do not apply to the current registered uses of tetrachlorvinphos,
                           therefore, avian reproduction studies are not required at this time.

                           (3)     Mammals

                                  Wild mammal testing is required  on a case-by-case basis,
                           depending on the results of the lower tier studies such as acute and
                           subacute testing, intended use pattern, and pertinent environmental
                           fate characteristics.  Data  to  describe toxicity to  wild mammals
                           were not required for tetrachlorvinphos.
Table 12 - Mammalian Acute Oral Toxicity Findings
Species
Rat
LDso(mg/kg)
1480
Conclusion
slightly toxic
                                           33

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                                  The    available   mammalian    data    indicate   that
                           tetrachlorvinphos is slightly toxic to small mammals on an acute
                           basis.

                                  As stated  in our discussion of the toxicological database
                           above, on a chronic basis, a three-generation reproduction study
                           with rats produced a reproductive NOEL of 330 ppm and an LOEL
                           of 1000 ppm. (MRID # 77802)
                           (4)
Insects
                                  A honey bee acute contact LD50  study is required if the
                           proposed use will result in honey bee exposure.  The minimum data
                           required to establish the acute toxicity to honey bees is an acute
                           contact LD50 study with the technical material. Through the general
                           outdoor treatments,  some  exposure  to honey bees  is expected,
                           therefore, these data were  required for tetrachlorvinphos.
Table 13 - Nontarget Insect Acute Contact Toxicity Findings
Species
Apis mellifera
% Test Material
Technical
LDso
1.37 jig/bee
Conclusion
highly toxic
                                  There   is    sufficient   information   to   characterize
                           tetrachlorvinphos  as highly  toxic  to  bees.    The  guideline
                           requirement is fulfilled (MRID # 36935).

                                  When data from the acute study provide an LD50  <  11
                           /xg/bee, a foliar residue toxicity study is required.
Table 14 - Nontarget Insect Foliar Residue Toxicity Findings
Species
Apis mellifera
% Test Material
21bEC
Conclusion
At 1 Ib a.i./A, 3 hour old residues caused 4% mortality
                                  Results from this study indicate that tetrachlorvinphos foliar
                           residues remained toxic to honey bees for less than 3 hours.  The
                           honey bee foliar residue testing requirement is fulfilled (MRID #
                           5000837).
                                           34

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                    b.     Toxicity to Aquatic Animals

                           (1)    Freshwater Fish Toxicity

                                  In order to establish the toxicity of a pesticide to freshwater
                           fish, the minimum data required on the technical grade of the active
                           ingredient are two freshwater fish toxicity studies.  One study
                           should use a coldwater species (preferably the rainbow trout), and
                           the other should use a warmwater species (preferably the bluegill
                           sunfish).
Table 15 - Freshwater Fish Acute Toxicity Findings
Species
Rainbow trout
Bluegill sunfish
Channel catfish1
% Test Material (TGAI)
75 (formulated product)
94
94
LCSO
0.43 ppm
0.53 ppm
>0.5 ppm
Conclusions
highly toxic
highly toxic
highly toxic
1  Study is supplemental, because an LC50 was not determined.
                                  The results of the two 96-hour acute toxicity studies indicate
                           that tetrachlorvinphos is highly toxic to both cold- and warmwater
                           fish.  The guideline requirement for acute toxicity testing of the
                           technical ingredient on  freshwater  fish (warmwater) is  fulfilled
                           (MRID # 40098001).  However,  the  requirement for testing the
                           technical pesticide on coldwater fish has not been satisfied.  Because
                           of mitigating factors (data are available for other fish species, end
                           use product data are available for rainbow trout, and the likelihood
                           that exposure is minimal), the Agency is not requiring this study.

                                  Formulated product  testing on fish  has been required
                           because the LC50 values  of the technical pesticide is less  than the
                           EEC in the aquatic  environment. The  results of the 96-hour acute
                           toxicity study with rainbow trout as the test species and with a 75 %
                           formulated product  indicate that tetrachlorvinphos is highly toxic to
                           freshwater fish (MRID # 40098001).

                           (2)    Freshwater Invertebrate Toxicity

                                  The minimum  testing required to  assess the hazard of a
                           pesticide is a freshwater aquatic invertebrate toxicity test, preferably
                                           35

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                           using  first  instar Daphnia  magna or early instar  amphipods,
                           stoneflies, mayflies, or midges.
Table 16 - Freshwater Invertebrate Toxicity Findings
Species
Daphnia magna
% Test Material (TGAI)
99
LCSO
1.9ppb
Conclusions
very highly toxic
                                  There    is   sufficient   information    to    characterize
                           tetrachlorvinphos as very highly toxic to aquatic invertebrates. The
                           guideline requirement is fulfilled (MRID #41257101).

                                  An aquatic invertebrate life cycle test is required when a
                           product is applied directly to water or is expected to be transported
                           to aquatic sites  and 1) exposure of  aquatic organisms will  be
                           continual or recurrent; or 2) the lowest EC50 is 1 mg/L or less; or
                           3) the EEC in water is equal to or greater than 0.01 of any EC50; or
                           4) if the EEC is less than any EC50 and the product has reproductive
                           effects on, or cumulative effects in aquatic organisms, or has a half-
                           life in water greater  than 4 days.

                                  For tetrachlorvinphos, the laboratory EC50 value is less than
                           1  mg/L.  No acceptable aquatic invertebrate life cycle data are
                           available for tetrachlorvinphos.  The requirement was previously
                           reserved pending review of the manure dissipation study.  Because
                           no parent compound was found in manure following the feed-
                           through study, data from an aquatic invertebrate life cycle  study are
                           not required.

                           (3)    Estuarine/Marine Animal Toxicity

                                  Acute toxicity testing with marine and estuarine organisms
                           is required  when  an  end-use product is  intended for direct
                           application to the marine and estuarine  environment or is  expected
                           to reach this environment in significant concentrations. The uses of
                           tetrachlorvinphos are unlikely to result in exposure to the marine
                           and estuarine environment.

                                  The requirements under this category include a 96-hour LC50
                           for an  estuarine fish, a  96-hour LC50 for shrimp, and either a 48-
                           hour embryo-larvae study or a 96-hour shell deposition study with
                           oysters.
                                           36

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Table 17 - Estuarine/Marine Acute Toxicity Findings
Species
Eastern oyster embryo larvae
Pink Shrimp
Spot
% Test Material
(TGAI)
94
94
94
LCSO
> 1000 ppb
280 ppb
> 1000 ppb
Conclusions
moderately toxic
very highly toxic
moderately toxic
              2.
              There   is   sufficient   information   to   characterize
       tetrachlorvinphos as highly toxic to marine and estuarine shrimp.
       No studies were  required to fulfill this guideline.  However, the
       submitted studies  were reviewed and are considered supplemental.
       (MRID # 40228401)

c.     Toxicity to Plants

       Terrestrial  and  aquatic  plant  testing   is  not required  for
tetrachlorvinphos. Non-target plant testing is only required for insecticides
if there are reported incidents of adverse effects to non-target plants, which
there are not for tetrachlorvinphos.

Environmental Fate
                     Environmental fate data requirements are fulfilled except for hydrolysis
              (161-1). The submitted hydrolysis study is partially acceptable; information on the
              fate of tetrachlorvinphos is  acceptable  for acidic (pH 5)  and neutral (pH  7)
              conditions. Clarification has been required from the registrant to characterize the
              [14C] residues in the pH 9 solutions at the 21- and 30-day sampling intervals.  The
              clarification  will be  used to  assess  the fate of the  primary degradates  of
              tetrachlorvinphos which form  during alkaline hydrolysis. The Agency believes the
              clarification  regarding  the  alkaline  (pH  9)  hydrolysis   study  will supply
              confirmatory data and the attached environmental fate assessment will not change
              appreciably with  the confirmatory data.  Sufficient  data for a comprehensive
              qualitative environmental fate  assessment of tetrachlorvinphos are available and are
              summarized below.
                     a.
       Environmental Fate Assessment
                            Based on the current information in the environmental fate data base
                     required  for  reregistration of tetrachlorvinphos,  the Agency considers
                     tetrachlorvinphos to be non-persistent and has a mobility that varies from
                                            37

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                    mobile in coarse-textured, low organic matter soils to relatively immobile
                    in fine-textured soils with 2-3% organic matter.  The principal route of
                    dissipation  for  tetrachlorvinphos is through  biotic processes such  as
                    microbially-mediated metabolism (aerobic soil metabolism half-life of 4.4
                    days). Abiotic processes such as hydrolysis are more effective at degrading
                    tetrachlorvinphos under alkaline (t1/2@pH9  = 10 days) conditions; however,
                    hydrolytic degradation  is relatively ineffective at neutral  to  acid  pH
                    conditions (t1/2 @PH 7  = 30  days; ^2 @pH 5    =  57 days).  Based  on the
                    submitted batch equilibrium studies,  the  mobility  of  tetrachlorvinphos
                    varies from mobile (Kds ranged from 0.6-4.0 mL/g) in coarse-textured soils
                    (e.g., sands, sandy loams with < 1 % organic matter) to relatively immobile
                    (Kds ranged from 8.2-13.7 mL/g) in fine-textured soils (e.g., loams, silty
                    clays with 2-3% organic matter).  Under simulated field conditions, parent
                    tetrachlorvinphos  was not detected  in manure  which had been collected
                    from a beef cow treated with tetrachlorvinphos as a feed additive.  Based
                    on the environmental fate assessment for tetrachlorvinphos, the  use of
                    tetrachlorvinphos  will not, according to current product labeling, create
                    serious detrimental impacts to  either ground water or  surface  water
                    environmental media.

                    b.     Environmental Chemistry, Fate and Transport

Table 18 - Summary of Environmental Chemistry , Fate and Transport Data
GUIDELINE #
161-1
162-1
163-1
164-A-SS
DATA REQUIREMENT
Hydrolysis
Aerobic soil metabolism
Mobility
Dissipation of Residue in
Livestock Manure
SUMMARY
Hydrolysis is more rapid under alkaline conditions (partially
acceptable study).
ti/2epH9: 10 days < t1/2@pH7: 30 days < t1/2(8pH5: 57 days
Nonpersistent; t1/2 = 4.4 days (Blackoar loam); acceptable study
1/2 < 8 days (medium loam) ; supplemental study
Varies from mobile (Kds: 0.6-4.0 mL/g) in coarse- textured soils
(e.g., sands, sandy loams with < 1% organic matter) to relatively
immobile (Kds: 8.2-13.7 mL/g) in fine- textured soils (e.g., loams,
silty clays with 2-3 % organic matter)
Tetrachlorvinphos administered to a beef cow as a feed additive
was not detected in manure which had weathered under simulated
field conditions.
                           (1)    Hydrolysis (161-1)

                                  Hydrolysis data at pH 5 and 7 indicate that hydrolysis is
                           more rapid under  alkaline conditions.   Tetrachlorvinphos was
                                           38

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shown to degrade via hydrolysis with the most rapid hydrolytic
degradation  occurring   under   alkaline  conditions  (t1/2   ~
(approximately) 10 days at pH 9; t1/2 ~ 30 days at pH 7; \/2 ~ 57
days atpH 5).

       The  study  by  Blumhorst  (1991) was  found  partially
acceptable for  fulfilling the hydrolysis  data requirement.   The
portions  of this study conducted at pH  5 and 7 are acceptable.
Tetrachlorvinphos degraded with a half-life of 10.3 days in a sterile
pH 9,  0.01 M  aqueous buffer solution that was incubated in the
dark at 25°C; the hydrolytic half-lives were 29.8 and 57.3 days for
pH 7  and 5  solutions, respectively,  that were incubated under
similar conditions.    Two  major degradates,  1-oxo-1-[2,4,5-
trichlorophenyl]-2-hydroxyethane  and   l-(2,4,5-trichlorophenyl)
vinyl dimethyl phosphate (TVDP) (or its  cyclic isomer, CTVDP),
were identified in the treated buffer solutions. The TVDP/CTVDP
isomers  were identified only in  the pH 9 test  solutions with
maximum concentrations of «28% of the applied radioactivity at 21
days which decreased to ~ 15% of the applied at 30 days.  During
the study, material balances ranged from 97.6-101.8% of the
applied. (MRID # 41929101)

       In order for the pH 9 test solution data to contribute towards
the fulfillment of the hydrolysis data requirement,  the registrant
must clarify the discrepancies between the UV and radioactivity
detection  and must  conclusively identify  [14C]  residues present in
the methylene  chloride extracts of the  21-  and 30-day pH  9
solutions.  The clarification will be used to assess the fate of the
primary degradates of tetrachlorvinphos which form during alkaline
hydrolysis.  The Agency believes  that clarification regarding the
alkaline (pH 9) hydrolysis study will simply supply confirmatory
data.  The registrant has  submitted additional  hydrolysis  data
(MRID # 43663501) to upgrade the existing study, and these data
are in review.  The  overall environmental fate assessment will not
change appreciably  with the addition of this confirmatory data.

(2)    Aerobic Soil Metabolism (162-1)

       Tetrachlorvinphos degraded rapidly with a calculated half-
life of 4.4 days, in Blackoar loam soil  (MO; fine-silty, mixed,
mesic Fluvaquentic Haplaquolls) that was incubated in the dark at
22 + 2 °C and 75%  of 0.33 bar moisture capacity.  Five degradates
were identified.  For carbon dioxide, approximately  9% of the
applied remained at 302 days post-application.   For 2-chloro-l-

                39

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(2,4,5-trichlorophenyl)ethanol, a maximum of 14.1% of the applied
remained at 7 days post-treatment, decreasing to approximately
0.40%   by   60   days   post-treatment.      For   l-(2,4,5-
trichlorophenyl)ethanol, a  maximum of 28.3% of  the  applied
remained at 4 days post-treatment, decreasing to approximately 1 %
of  the  applied by  302  days  post-treatment.     For   2,4,5-
trichloroacetophenone, a  maximum of 50.7%  of  the  applied
remained at 60 days post-treatment, decreasing to 19.1%  by 302
days post-treatment.  For 2,4,5-trichlorobenzoic acid and one or
more dichlorobenzoic acid isomers, a maximum of 17.4% of the
applied remained at 99 days post-treatment, and decreased to 14.4%
of the applied at 302 days post-treatment.  In the sterile soil  system,
tetrachlorvinphos monomethyl ester was the  only degradate detected
(concentrations remaining ranged from approximately 0.6% of the
applied  at 3 days post-treatment to a maximum of approximately
4% of the applied at day 31) (MRID #42082401).  This study may
be upgraded to acceptable by providing information on the  aerobic
metabolism of phenyl-labeled tetrachlorvinphos in a Blackoar loam
soil; however, no further information is required. The information
provided in  this study and in the study described below provide
adequate aerobic soil metabolism data.

      A  study  by   Beynon   and  Wright  (1968)  provides
supplemental   data   on  the   aerobic   soil  metabolism  of
tetrachlorvinphos in a "medium" loam  soil.  In this study,  vinyl
carbon-labeled [14C]  tetrachlorvinphos (purity unspecified), at 13.4
ppm, degraded with  a half-life of < 8 days.  Two major degradates,
each accounting for  <28% of the applied in the medium loam soil,
were identified as  l-(2,4,5-trichlorophenyl)-2-chloroethan-l-ol
(maximum of 28%  of the applied at day 16, decreasing to  18% of
the applied  at  30  days)  and l-(2,4,5-trichlorophenyl)ethan-l-ol
(maximum of -25% of the applied  at day 16 and 30). Additional
minor    degradates   detected   were    l-chloroacetyl-2,4,5-
trichlorobenzene  (<5%   at   all  sampling   times),   2,4,5-
trichloroacetophenone (maximum of 9% at day 30), and l-(2,4,5-
trichlorophenyl)ethane-diol  (< 1 %  at all  sampling times).   The
distribution of the unextractable radioactivity ranged from  23 % of
the applied at day 8 to  a maximum of 33 % of the applied at  day 30.
Data on the clay loam, sandy loam, and peat soil textures were not
acceptable  because only  one  sampling   period  (day  30)  was
conducted.   New data for the three soils (clay loam, sandy loam,
peat) are not needed, however,  because the other two soils tested
(Blackoar loam and  "medium" loam) showed tetrachlorvinphos is
not persistent (half-lives of 4-8 days). (MRID # 77821)

                40

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                           (3)    Leaching/Adsorption/Desorption (163-1)

                                  Results   of   the  batch   equilibrium   tests   indicates
                           tetrachlorvinphos is mobile  (Kd <1.0) in sandy loam, slightly
                           mobile (Kd  <5.0) in sand, and relatively immobile (£   >5.0) in
                           loam and silty clay soils.  Reported Freundlich Kads_des values were
                           0.60-0.69 for sandy loam (pH =  8.0; Kom = 1038-1195), 4.04-5.09
                           for sand (pH = 5.6; Kom = 871-1097), 8.18-9.04 for loam (pH =
                           6.1; Kom =  522-577), and 13.7-13.8 for the silty clay soil (pH =
                           5.6;  Kom  =   1074-1081).   Data  collected  during the batch
                           equilibrium  tests suggests  that  sorption  of  tetrachlorvinphos
                           probably results from binding to soil organic matter and/or clay.

Table 19 - Leaching/Adsorption/Desorption Data for Tetrachlorvinphos in 4 Soils
Soil
Texture
sand
sandy loam
loam
silty clay
Clay
(%)
4
7
14
40
Organic
Matter (%)
0.8
0.1
2.7
2.2
CEC
(meq/lOOg)
2.0
8.1
10.1
21.1
Kads
(mL/g)
4.04
0.60
8.18
13.7
Kdes
(mL/g)
5.09
0.69
9.04
13.8
T^
ads,om
(mL/g)
871
1038
522
1074
T^
des,om
(mL/g)
1097
1195
577
1081
                                  This study (Blumhorst, 1990) is acceptable and can be used
                           to fulfill  the  Mobility  by Leaching/Adsorption/Desorption data
                           requirement.   However,  the Kds determined in this  study may
                           overestimate  the   mobility   of tetrachlorvinphos  because   of
                           uncertainty  regarding the soil/testing solution equilibration time.
                           During preliminary testing,  the degradation of tetrachlorvinphos
                           after 24 and 48 hours necessitated establishing a study equilibration
                           time  of 4  hours.    However, it  could  not  be determined if
                           tetrachlorvinphos had established equilibrium between the soil  and
                           water phases at the time of sampling. (MRID # 41681301)

                           (4)    Dissipation of Residues in Livestock Manure (164-A-SS)

                                  The  standard guideline data requirement Terrestrial Field
                           Dissipation  was replaced with the  special study Dissipation of
                           Residues in Livestock Manure because tetrachlorvinphos is used
                           primarily as a feed additive for controlling flies associated with
                           livestock, leaving tetrachlorvinphos residues in the feces.  The
                           manure dissipation study (Krautter, 1993) was required to assess the
                                           41

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             dissipation of tetrachlorvinphos under simulated field conditions.
             The study measured tetrachlorvinphos and its residues present in
             manure from  a treated beef cow. The manure from treated cows
             may be applied to agricultural fields prior to planting food crops.

                    Parent tetrachlorvinphos was not isolated in the compost
             samples   at  any   sampling  interval.     Total  residues   of
             tetrachlorvinphos     [beta    isomer,     (Z)-2-chloro-l-(2,4,5-
             trichlorophenyl)vinyl dimethyl phosphate] did not decline during 6
             months of storage from composted manure collected throughout
             treatment from a cow treated orally at 70.4 mg a.i./100 pounds/day
             for 14  days.   There were several  degradates identified in the
             compost samples. Sixty-nine percent of the radioactivity at day 0
             was found in  l-(2,4,5-trichlorophenyl)-ethanol and approximately
             40%  of the recovered radioactivity at 3 and 6 months sampling
             times.   Seven percent  of the radioactivity was recovered as 1-
             (2,4,5-trichlorophenyl)-2-chloroethanol at day 0, but not detected
             at 3 and 6 months sampling times.  Approximately  10% of the
             recovered radioactivity was detected as 2,4,5-trichlorobenzoic acid
             at the 6  month sampling time.  Eight additional degradates were
             isolated   from the  manure  at  0.3  to  5.3  ppm  (maximum
             concentrations of 10% of the recovered radioactivity) but were not
             identified.  The  unidentified compounds were not characterized
             following attempted extraction with strong acid (6N HC1) or strong
             base (6N NaOH) extractants. Unextracted radioactivity was 9.2%
             and 23 % of the recovered radioactivity at the Day 0 and 6 month
             sampling times, respectively.  (MRID # 42848501)

3.     Ecological Exposure and Risk Characterization

       a.     Exposure and Risk to Nontarget Terrestrial Animals

             Given the use  patterns of tetrachlorvinphos, exposure of nontarget
       terrestrial organisms to tetrachlorvinphos will be  minimal.  The uses most
       likely to result in exposure would be the general outdoor and  agricultural
       premise treatments.  The maximum application rate for such  uses is 1 Ib
       a.i./A.

             The Agency's acute toxicity level of concern  for an avian  or
       mammalian species is a  risk quotient value greater than or equal to 0.5.
       The  risk  quotient (RQ) is calculated  from the  preliminary estimated
       environmental concentration (EEC) divided by the lowest LC50 value for
       birds and mammals.  There is a potential for acute risk if the risk quotient
       is greater than or equal to 0.5.

                             42

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                           The maximum concentration of residues of tetrachlorvinphos which
                    may be expected to occur on selected avian or mammalian dietary food
                    items following a single  foliar  application at two application rates is
                    provided in the table below:

Table 20 - Residues on Avian and Mammalian Dietary Food Items in PPM
Use Sites
Range Grasses (short)
Fruit/Vegetable Leaves
Forage and Insects
Seeds
Fruits
Application rates (Ib a.i./A)
0.75
180
95
44
9
6
1.0
240
125
58
12
7
* Residue data are from the Kenaga nomograph. Most current reference is Fletcher et. al., 1994.

                           (1)    Birds

                                 Avian acute oral or subacute dietary risks are not expected
                           for  tetrachlorvinphos.   Residues found  on dietary  food items
                           following  a  single  application  of  tetrachlorvinphos  may  be
                           compared to LC50 values to predict hazard.

                                 Tetrachlorvinphos  is  practically  nontoxic  to birds,  as
                           indicated by  tests conducted on the  representative test  species,
                           mallard duck, ring-necked pheasant, and chukar.  Acute LD50 and
                           LC50 values are >2000 mg/kg and  >5000 ppm, respectively.

                                 The highest expected environmental concentration is  240
                           ppm on short range grasses for the maximum application of 1.0 Ib
                           of active ingredient per acre (see Table 20).

                                  EEC  = 240 ppm  =  .05
                                  LC50    5000 ppm

                           This suggests that tetrachlorvinphos is unlikely to be of risk to
                           birds, from acute oral or subacute dietary exposure.
                                          43

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       Because exposure to birds is not expected to be repeated or
continuous, chronic effects are not anticipated.

       Nonendangered or endangered omnivorous bird species, and
bird species that eat only seeds, only insects, or only fruit are also
unlikely to be affected (risk quotients less than 0.1).

(2)     Mammals

       Acute toxicological data  show  tetrachlorvinphos  to  be
slightly toxic to mammals  on an acute  basis (rat LD50  = 1480
mg/kg) (MRID # 41222504).  In the absence of mammalian LC50
data, hazard assessment will be based on the LD50 value, as follows.

       Using the relationship (pesticide residue in the diet (ppm) *
food consumption (kg)/body weight (kg) =  mg pesticide/kg/day)
(Lehman, 1959), one can  determine the amount of daily dietary
residue needed to obtain the LD50 of an organism.  For example:

i       The food consumption and body weight for a young rat are
       typically  0.01 kg and 0.1 kg, respectively.  Therefore, a
       young rat consumes food  at a rate  of  10  %  of its body
       weight on a daily basis.

ii      The LD50 for tetrachlorvinphos to rats is 1480 mg/kg.  This
       represents an LC50 of 148 mg/animal (1480 mg/kg * 0.1 kg
       =  148 mg/animal).

iii     To obtain an LD50 of 148 mg/animal a dietary residue of
       14,800 ppm is required:

             ppm * food consumption (kg)/body weight (kg) =
             mg/kg/day

             ppm * 0.01 kg/0.1 kg = 1480 mg/kg/day

             ppm =  14,800

       The high risk LOG for terrestrial  organisms is 0.5.  When
the acute risk quotient (RQ) (RQ = EEC/LC50) reaches, or exceeds,
this value (0.5) high risk is presumed.   For tetrachlorvinphos, a
terrestrial EEC of 7400 ppm is required to obtain 0.5 (RQ = 7400
ppm/14,800  ppm = 0.5).
                44

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              As can  be seen in the residue table above (Table 20),
       residues at this level will not be found,  even following application
       at the highest rate.  Thus, significant acute hazard to mammals is
       not expected.  (Reference: Lehman, A. J.  1959. In: Appraisal of
       the Safety  of Chemicals in  Foods,  Drugs,  and  Cosmetics.
       Association  of Food  and Drug Officials  of the United  States.
       Austin, Texas.)

       (3)     Insects

              Significant risk to non-target insect species is not expected
       from use of tetrachlorvinphos.  For nontarget insects, the honeybee
       is the representative test species; with an acute contact LD50 value
       of 1.37 /xg/bee, tetrachlorvinphos is highly toxic  to  honeybees.
       However, registered uses of this pesticide are unlikely to result in
       significant exposure to bees.   Hence, an insignificant  risk is
       expected  to nontarget  insects  as a result  of  exposure  to
       tetrachlorvinphos.

b.     Exposure and Risk to Nontarget Aquatic Animals

       Given the use information available for tetrachlorvinphos, exposure
of nontarget aquatic organisms to tetrachlorvinphos will be  minimal. The
uses most likely to  result in exposure would be the general outdoor and
agricultural  premise treatments.  Aquatic organisms may  be exposed to
tetrachlorvinphos via runoff from agricultural premises (e.g., feedlots).
The maximum rate  for such uses would be  1 Ib a.i./A.

       Minimal acute  risk to aquatic  animals is expected.  Moreover,
chronic risk to aquatic  animals is not anticipated because of the relatively
low potential for chronic exposure.

       The freshwater EEC following application at 1 Ib a.i./A would be
30.5 ppb.

For unincorporated  ground application

1 Ib X 0.05 (5% runoff) X  10 A (from 10 acre drainage basin) =  0.5 Ib

*EEC of 1 Ib a.i. direct application to 1 A surface water body 6-feet deep
= 61 ppm

Therefore, EEC =  61 ppb X 0.5 Ib total runoff =  30.5 ppb.
                       45

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       To estimate acute risk to aquatic animals, the Agency compared the
risk quotient (EEC of 30.5 ppb/LC50) to the level of concern value (greater
than or equal to 0.5). The ecotoxicity values used in this risk assessment
are:  rainbow trout LC50 = 0.43 ppm and Daphnia magna EC 50 = 1.9 ppb.
The freshwater fish LOG is be exceeded with a risk quotient of 0.07.  The
aquatic invertebrate  LOG  is also exceeded with a risk quotient of 16.05,
indicating a potential for acute risk to freshwater invertebrates.  However,
these risks are considered to be minimal because tetrachlorvinphos is used
primarily in applications which will not result in exposure to the aquatic
environment.  The  only  exposure of concern for tetrachlorvinphos is
possible runoff from the manure of treated farm animals.  However, the
manure dissipation study (see Environmental Fate section)  indicates that no
tetrachlorvinphos was found in weathered manure following feed-through
treatment.  Therefore, no acute risk to aquatic organisms is anticipated.
Chronic risk to aquatic organisms is not expected because chronic exposure
is not expected.

c.      Exposure and Risk to Nontarget Terrestrial, Semi-Aquatic,  and
       Aquatic Plants

       Unless there are known reports of phytotoxicity resulting from the
use of a  specific insecticide, terrestrial and aquatic plant testing are not
required.   There  are no  known incidents of  adverse effects  to  plants
resulting  from tetrachlorvinphos use that have been reported to the Agency.
Therefore, the Agency assumes the potential risk to plants is insignificant.

d.     Endangered  Species

       For endangered avian and mammalian species the level of concern
is  a  risk quotient value greater than or equal  to  0.1.   For endangered
aquatic vertebrate and invertebrate species, the LOG is a risk quotient value
greater than or equal to 0.05.  And for endangered plant species, the LOG
is greater than or equal to  1.0.

       The  Agency believes  significant  acute  and  chronic  risks to
endangered birds and small mammals is not expected.  Chronic exposure
to  birds  and  small mammals is not expected.  For endangered aquatic
organisms, acute  levels  of concern  are  exceeded for  both  fish  and
invertebrate species  with risk quotients of 0.07 and  16.05, respectively.
However, as  noted  earlier in the  discussion on  nonendangered aquatic
species, the likelihood of exposure is so  low that acute toxicity risk to
endangered aquatic organisms is expected to be  insignificant.  Because
chronic exposure is not expected for aquatic organisms, significant chronic
toxicity risk to aquatic organisms is not expected.

                       46

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                           The Endangered Species Protection Program is expected to become
                     final in 1996. Limitations in the use of tetrachlorvinphos may be required
                     to protect endangered and threatened species, but these limitations have not
                     been defined and may be formulation specific. The Agency anticipates that
                     a consultation with the  Fish and Wildlife Service will be conducted in
                     accordance with  the  species-based priority approach described  in  the
                     Program.  After completion of consultation, registrants will be informed if
                     any required label modifications are necessary. Such  modifications would
                     most likely consist of the generic label statement referring pesticide users
                     to use limitations contained in county  Bulletins.

IV.    RISK MANAGEMENT AND REREGISTRATION DECISION

       A.     Determination of Eligibility

              Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission
       of relevant data concerning  an active ingredient, whether products containing  the active
       ingredients are eligible for  reregistration.   The Agency has  previously identified and
       required the submission  of the generic  (i.e. active ingredient specific) data required to
       support reregistration  of products  containing  tetrachlorvinphos.    The  Agency  has
       completed  its review  of these  generic data, and has  determined that,  based on  the
       information currently available, there are data to support reregistration  of all products
       containing  tetrachlorvinphos; however; a reregistration eligibility decision on products
       registered for livestock feed-through (oral) larvicide uses cannot be made  at this time for
       reasons discussed below. Appendix B identifies the generic data requirements that the
       Agency  reviewed  as  part  of  its   determination of reregistration   eligibility   of
       tetrachlorvinphos,  and  lists the submitted studies that the Agency found acceptable.

              The data identified in Appendix B were sufficient to allow the Agency to assess the
       registered uses of tetrachlorvinphos.  The Agency has determined that except for the  use
       as a feed-through larvicide for livestock,  tetrachlorvinphos can be used as described in this
       document  without resulting  in unreasonable  adverse  effects to  humans  and  the
       environment.  The Agency therefore finds that all products containing tetrachlorvinphos
       as the sole active ingredient are eligible for reregistration,  with the exception of those
       products labeled  for the livestock feed-through use.  The reregistration  of  particular
       products is addressed in Section V of this document.

              The Agency made its reregistration eligibility determination based upon the target
       data  base required for reregistration, the current guidelines for conducting acceptable
       studies to generate such data, published  scientific literature,  other available information,
       and the data identified in Appendix B.  Although the Agency has found  that all uses of
       tetrachlorvinphos are eligible for reregistration, with the exception of the livestock feed-
       through use, it should be understood that the Agency may take appropriate regulatory
       action, and/or require  the submission of additional data to support the registration of

                                           47

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products containing tetrachlorvinphos, if new information comes to the Agency's attention
or if the data requirements for registration or the guidelines for generating such data
change.

       1.      Eligibility Decision

              Based  on the reviews  of the  generic data  for  the  active  ingredient
       tetrachlorvinphos, the Agency has sufficient information on the potential health
       effects of tetrachlorvinphos and on  its potential  for causing adverse effects in
       wildlife and the environment.  The Agency has determined that tetrachlorvinphos
       products except those with  feed-through  larvicide  uses,  labeled and  used as
       specified in this RED document will not pose unreasonable risks  to humans or the
       environment.   However,  the Agency cannot make a determination as to the
       eligibility of the use of tetrachlorvinphos as a livestock feed-through larvicide, for
       the reason discussed below.  Therefore,  the Agency considers  that products
       containing tetrachlorvinphos for all uses except the livestock feed-through use are
       eligible for reregistration.

              The  feed  additive  tolerance   regulations  which  cover  residues  of
       tetrachlorvinphos in livestock feeds for the feed-through use have been proposed
       for revocation.  The Delaney clause of Section 409  of the Federal Food, Drug, and
       Cosmetic Act (FFDCA) prohibits the Agency from approving food or feed additive
       tolerances for a chemical that induces cancer in  animals  or humans  within the
       meaning of the Delaney clause.  The Agency cannot make a determination with
       regard to the eligibility of the livestock feed-through use because EPA has not
       made a final determination on the proposed  revocation and EPA is currently
       reevaluating how it will coordinate its actions under the FFDCA and FIFRA.  This
       issue is discussed in greater detail below in the Regulatory Position section of this
       document.

       2.      Eligible Uses

              The domestic animal and agricultural premise treatments,  general outdoor/
       recreational area uses, uses on horses (provided  labels restrict use from horses
       meant for slaughter), dermal applications to livestock, and pet uses are eligible for
       reregistration.

              The Agency cannot make a determination as to the eligibility of the use of
       tetrachlorvinphos as a livestock feed-through larvicide, for the  reason discussed
       below.
                                     48

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B.     Regulatory Position

       The  following is  the  regulatory  position and  rationale for the reregistration
eligibility decision for tetrachlorvinphos.  Where labeling revisions are imposed, specific
language is set forth in Section V of this document.

       1.     Tolerance Reassessment

              As part of its reregistration eligibility decision, the Agency reassessed the
       tolerances of tetrachlorvinphos residues in or on food or feed commodities.  The
       purpose of this  reassessment was to determine whether the uses of currently
       registered tetrachlorvinphos products are adequately and appropriately supported
       by residue tolerances as required under the FFDCA.  Where deficiencies are noted,
       the Agency presents a course of appropriate action to resolve the deficiencies.  A
       summary  analysis  of the current  tolerances  is presented in Table 21  after the
       following  discussion.

              A feed additive regulation has been established for tetrachlorvinphos for use
       as an additive in the feed of beef cattle, dairy  cattle, horses, and swine at the rate
       of 0.00015 Ib per 100 Ib body weight per day  for beef and dairy cattle and horses,
       and 0.00011 Ib per 100 Ib of body weight per day for swine (40 CFR  §186.950).

              The chemical name of tetrachlorvinphos as specified in 40 CFR §180.252
       and  §186.950,  "2-chloro-l-(2,4,5-trichlorophenyl)vinyl dimethyl phosphate",
       should be  replaced with "(Z)-2-chloro-l-(2,4,5-trichlorophenyl)vinyl  dimethyl
       phosphate."

              Tolerances Listed Under 40 CFR §180.252

                     Currently, the tolerances  specified  for the raw  agricultural
              commodities (RACs) listed in 40 CFR §180.252 are expressed  in terms of
              residues of tetrachlorvinphos per se.  The Agency has concluded that the
              tetrachlorvinphos metabolites  des-O-methyl tetrachlorvinphos,  l-(2,4,5-
              trichlorophenyl)-ethanol    (free   and    conjugated  forms),    2,4,5-
              trichloroacetophenone,  and  l-(2,4,5-trichloro-phenylethanediol are  of
              toxicological concern and should  also  be  regulated.   The tolerance
              definition should therefore be revised to include the residues of these four
              metabolites of tetrachlorvinphos.

                     The  available  data are  insufficient to  assess  the  established
              tolerances for residues of tetrachlorvinphos in the fat of cattle, goats, hogs,
              horses, sheep, and poultry; in eggs; and  in milk fat (including negligible
              residues in whole milk). In  October, 1993, the Agency required registrants
              to  submit new studies reflecting oral and dermal exposure of beef cattle,

                                    49

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dairy cattle, and hogs, and dermal exposure of poultry to tetrachlorvinphos.
The Agency required the registrants to analyze all residues of concern in
cattle, hogs, and poultry using validated analytical methods.  These data are
due by April, 1996.

       Currently, there are not any registered  tetrachlorvinphos products
for use on plants.   All  uses  on  food or feed plant  commodities were
voluntarily canceled in 1987. The established tolerances for alfalfa; apples;
cherries; field corn fodder and forage; fresh corn (kernel plus cob with
husks removed (K+CWHR));  corn grain; pop corn  fodder and forage;
sweet corn  (K + CWHR);  sweet  corn fodder and forage; cranberries;
peaches; pears; and tomatoes should therefore be revoked.  The Agency
published notice of the proposed revocation in the Federal Register.  Refer
to "Tetrachlorvinphos, Terbutrin, and  Etridiazole; removals"; Federal
Register, Volume 59, No. 138, July 20, 1994.

Tolerances Listed Under 40 CFR §186.950

       The  40 CFR  §186.950 lists  no  tolerances,  but  describes  the
prescribed conditions for use of tetrachlorvinphos as an additive in the feed
of beef and dairy cattle, hogs and horses for control of fecal flies in manure
of these animals.

       The available  data are insufficient to assess the established feed
additive  regulation  for  residues  of  tetrachlorvinphos.    New studies
reflecting oral and dermal exposure of beef cattle, dairy cattle, and hogs,
and dermal exposure  of poultry to tetrachlorvinphos have  been required.
Because  of the proposal to revoke feed  additive tolerances  (described
below), the Agency has deferred the requirement for the submission of new
residue studies reflecting oral exposure to tetrachlorvinphos.  However,
residue  data  for  dermal uses  remain required  because the Agency is
concerned about residues from tetrachlorvinphos from dermal uses.  All
residues  of concern should be analyzed in cattle, hogs, and poultry using
validated analytical methods.

       As noted previously, in 60FR 49141 published September 21,  1995,
the Agency has proposed to revoke the feed additive  tolerance set at 40
CFR  §  186.950  due to  the Delaney clause  of FFDCA.  This clause
prohibits the establishment of a regulation for any food/feed additive that
is found to induce cancer in man or animals.  The Ninth Circuit Court of
Appeals ruled in July 1992 that the Agency must interpret this provision
strictly.  Therefore, since EPA has concluded that tetrachlorvinphos is an
animal carcinogen within the meaning of the Delaney clause,  EPA has
proposed to revoke the animal feed additive tolerance.  Further,  under

                      50

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                    current Agency policy if a needed food/feed additive tolerance cannot be
                    continued, EPA will neither register nor leave in effect a registration under
                    FIFRA for the associated use.  EPA is currently reevaluating this policy
                    and a decision is expected by the end of 1995. Once EPA makes a decision
                    on this policy and a  final determination on the proposed revocation,  a
                    determination on the eligibility of the livestock feed-through use will be
                    made.
Table 21 - Tolerance Reassessment Summary
Commodity
Current
Tolerance
(ppm)
Tolerance
Reassessment
(ppm)
Comment
Tolerances listed under 40 CFR §180.252
Alfalfa
Apples
Cattle, fat
Cattle, meat
Cattle, mbyp
Cherries
Corn, field, fodder
Corn, field, forage
Corn, fresh (K+CWHR)
Corn, grain
Corn, pop, fodder
Corn, pop, forage
Corn, sweet, (K+CWHR)
Corn, sweet, fodder
Corn, sweet, forage
Cranberries
Eggs
Goats, fat
Goat, meat
Goat, mbyp
Hogs, fat
Hog, meat
Hog, mbyp
110.0
10.0
1.5
None
None
10.0
110.0
110.0
10.0
10.0
110.0
110.0
10.0
110.0
110.0
10.0
0.1
0.5
None
None
1.5
None
None
Revoke
Revoke
TBDa
TBD
TBD
Revoke
Revoke
Revoke
Revoke
Revoke
Revoke
Revoke
Revoke
Revoke
Revoke
Revoke
TBD
TBD
TBD
TBD
TBD
TBD
TBD
No registered uses exist.
Additional data are required. New magnitude of the residue
studies with cattle are required because submitted studies
do not reflect dosing rates representing the maximum
expected combined exposures and do not contain data for
all residues of concern.
No registered uses exist.
Additional data are required. New magnitude of the
residue studies with cattle, poultry and hogs are required
because submitted studies do not reflect dosing rates
representing the maximum expected combined exposures
and do not contain data for all residues of concern.
                                           51

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Commodity
Horses, fat
Horses, meat
Horses, mbyp
Milk, fat (N) b
Peaches
Pears
Poultry, fat
Poultry, meat
Poultry, mbyp
Sheep, fat
Sheep, meat
Sheep, mbyp
Tomatoes
Current
Tolerance
(ppm)
0.5
None
None
0.5
0.1
10.0
0.75
None
None
0.5
None
None
5.0
Tolerance
Reassessment
(ppm)
Revoke
Revoke
Revoke
TBD
Revoke
Revoke
TBD
TBD
TBD
Revoke
Revoke
Revoke
Revoke
Comment
No additional data required for horses provided all
applicable labels prohibit treatment of horses destined for
slaughter.
See comment above referring to additional data required.
No registered uses exist.
Additional data are required. New magnitude of the residue
studies with poultry are required because submitted studies
do not contain data for all residues of concern.
No registered uses exist.
No registered uses exist.
Tolerances listed under 40 CFR §186.950
Feed items (feed additive
regulation)
--
Revoke
Delaney clause Policy -
carcinogens in animal feeds
TBD = To Be Determined. Reassessment of tolerance(s) cannot be made at this time because additional data are required.
Reflecting negligible residues in whole milk.

              CODEX Harmonization

              There are no Codex  maximum  residue  limits  (MRLs) established or
       proposed for residues of tetrachlorvinphos.  Therefore, there are no issues with
       respect to compatibility of U.S.  tolerances with Codex MRLs.

       2.     Human Health Risks  and Eligibility

              All  uses of  tetrachlorvinphos, with  the exception of the oral livestock
       larvicide use, are eligible for reregistration.  Although there are risks posed by the
       carcinogenic potential of this compound from dietary and  occupational/residential
       exposure, these  risks are considered to be within an acceptable range  for regulatory
       purposes.

              a.     Dietary Risk

                     Both   chronic   systemic,  and carcinogenic  dietary  risks  were
              calculated  (see Section III.B.3.). These risks appear to be minimal when
              only uses supported  for reregistration are included in the assessment.
                                      52

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       For the U.S. population,  the upperbound carcinogenic risk was
calculated using anticipated residues for meat, milk, poultry, and eggs and
refined by percent livestock treated estimates. The carcinogenic risk for all
published and supported uses was 4.3 x 10~5. This assumes that 100% of
the fruit and vegetable commodities consumed are imported and contain
tetrachlorvinphos at tolerance levels.  However, only meat, milk, poultry,
and eggs are supported for reregistration.  When only these commodities
are considered the dietary cancer risk is 1 x  10"6.

       When dietary risk from chronic systemic effects was assessed, the
calculated percent RfD for the U.S. population was 59%. When only the
anticipated residues from supported uses were included, the percent RfD
for the U.S. population is 1 %.

       The Agency is proceeding to revoke the feed additive tolerances as
required by the Delaney clause.  When these tolerances are revoked and the
uses removed from labeling, the risk will change.  It is not possible to
estimate the amount that the risk would  be reduced or increased since it is
possible that some users  of tetrachlorvinphos would switch from a feed-
through application to a dermal application.

b.     Worker Risk

       Table  9,  Risk Estimates for  Occupational/Residential uses of
Tetrachlorvinphos,  presents the  upper bound  carcinogenic risk for
mixers/loaders/applicators from exposure to tetrachlorvinphos products for
ten different use  scenarios.   The highest calculated risk is for the low
pressure handwand  scenario which  is  1.3  x  10"5.   This  is  below the
Agency's 10"4 level of concern for worker exposure.

       The  Agency lacks data to evaluate the risks  in three worker
exposure scenarios: dusters, pellets, and impregnating material.   The
Agency  believes  that the uses of low-pressure handwands  and  power
sprayers represent worst-case exposure scenarios (due to the nature of a
spraying operation) for the current uses of tetrachlorvinphos.  Since risks
to workers under these worst-case scenarios do not exceed the Agency's
level of concern, it is not likely that exposures resulting from applications
of dusts, pellets, or impregnating materials will exceed the Agency's level
of concern.

       To minimize worker exposure and  reduce the risk to handlers,
baseline PPE are set through this document: long-sleeved shirt, long pants,
socks and shoes, and chemical-resistant gloves. The Agency expects that
these  PPEs  will  adequately  protect workers   from  exposures  to

                      53

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       tetrachlorvinphos.  The use of chemical-resistant gloves in the PPE for
       applicators  using low  pressure  handwands  should further  reduce  the
       potential carcinogenic risk.

       c.     Homeowner Risk

             Although there is  the potential for homeowner  exposures  to
       tetrachlorvinphos,  it is unlikely that  homeowners  would  experience
       significant exposure resulting from the uses described below.

             impregnated flea collars for pets

                    Homeowners would experience transient and brief exposures
             from application of these flea collars to pets.

             aerosols and dust shakers

                    Tetrachlorvinphos products formulated as aerosols and dusts
             are  intended  for spot applications and  do  not pose significant
             exposure to homeowners.

             Similarly,  reentry  exposures  to  homeowners  from these uses,
       including the pet dusts  and collars are expected  to be minimal. Reentry
       restrictions for homeowners are not warranted.

3.     Domestic Animal Safety

       Tetrachlorvinphos may be applied directly to dogs and cats to control fleas.
Data submitted to describe  cholinesterase inhibition from formulated products
suggests there is little risk to pets from these applications.

4.     Labeling Rationale/Risk Mitigation

       a.     Personal Protection Equipment (PPE) Requirements

             (1)    PPE    for    Handlers    (Mixer/Loader/Applicators)
                    Occupational Use Products

                    The Agency has  concerns of potential  carcinogenic and
             chronic  risk  to  workers from  exposure  to  tetrachlorvinphos.
             Because of  this and  since  there  are  no  engineering  control
             requirements,  such as closed systems, currently on product labeling
             of tetrachlorvinphos products which would mitigate exposures to
             handlers, the Agency is establishing minimum or  "baseline" handler

                             54

-------
       PPE requirements for  all occupational  end-use products  (not
       intended for homeowner use) containing this active ingredient.

             The minimum (baseline) PPE requirements for handlers of
       all end-use products  primarily intended for occupational use of
       tetrachlorvinphos are: chemical-resistant gloves and long-sleeved
       shirt and long pants, socks and shoes for all handlers.

             These minimum PPE requirements must then be compared
       with the PPE that the Agency will designate on the basis of the
       acute toxicity of each  end-use product.  The more stringent choice
       for each type of PPE (i.e., bodywear,  hand protection, footwear,
       eyewear,  etc.) must  then be placed on the label of the end-use
       product to be reregistered.

       (2)    Handler PPE for Homeowner-Use Products

             There are several products containing tetrachlorvinphos that
       are intended primarily for homeowner use (impregnated pet collar,
       aerosol can, and dust shaker). At this time the Agency will not
       establish  minimum (baseline) PPE for homeowner-use products
       based  on toxicity of  tetrachlorvinphos per se, since the Agency
       believes exposures are likely to be much  less than those from
       occupational uses.

b.     Entry Restrictions

       (1)    Entry Restrictions for Occupational-Use Products

             The Agency is not establishing entry restrictions for uses of
       occupational-use  products  on  livestock,  poultry,  or   other
       commercial animals,  since entry restrictions for these uses are
       impractical or  probably  unnecessary.  However,   for  uses of
       occupational-use products on  recreational  sites, the Agency is
       establishing an entry  restriction for  liquid  application.   This
       restriction requires that sprays  have dried before entering treated
       areas.

       (2)    Entry Restrictions for Homeowner-Use Products

             At this time the Agency will not establish entry restrictions
       for  indoor  homeowner-use products,  since entry restrictions for
       such uses as  formulated for homeowner use (i.e., impregnated
       collar, aerosol can, and dust shaker) are not necessary due to very
       low exposure.

                      55

-------
                    c.     Product Specific Labeling Changes

                           A  label amendment is required to prohibit treatment of horses
                    destined for  slaughter.   Uses on horses for  slaughter and the resulting
                    potential for residues in these tissues have not have not been supported with
                    the submission of data.

                           Label amendments are required in the use directions to clarify that
                    weights of pesticide to be added to feed refer to weights  of active ingredient
                    and not weights of product in order to avoid confusion in dosing.

                           In addition, because tetrachlorvinphos  is classified as  a  skin
                    sensitizer, the Agency is requiring a warning statement be placed on labels.

             5.     Endangered Species  Statement

                    Currently, the Agency is developing a program ("The Endangered Species
             Protection Program") to  identify  all pesticides whose use may cause adverse
             impacts  on endangered  and threatened  species and  to implement mitigation
             measures that will eliminate the adverse impacts.  The program would require use
             modifications or a generic product  label statement, requiring  users to consult
             county-specific bulletins.  These bulletins would provide information about specific
             use  restrictions to protect endangered and  threatened species in  the county.
             Consultations with the Fish and Wildlife Service will be necessary to assess  risks
             to newly listed species or from proposed new uses.

                    The Agency plans to publish a description of the Endangered Species
             Program in the Federal Register  in 1996.  Because the Agency is taking this
             approach for protecting endangered and threatened species, it is not imposing  label
             modifications at this time through the RED. Rather, any requirements for product
             use modifications will occur in the future under the Endangered Species Protection
             Program.

V.     ACTIONS REQUIRED BY REGISTRANTS

       This section specifies the data requirements and responses necessary for the reregistration
of both manufacturing-use and end-use products.

       A.    Manufacturing-Use Products

             1.     Additional Generic Data Requirements

                    The generic data base  supporting the reregistration of tetrachlorvinphos for
             the  above eligible uses has  been  reviewed and determined  to be substantially

                                           56

-------
       complete.  However, the Agency has required the submission of additional data as
       confirmatory information. Analytical methods and data to describe the residues of
       tetrachlorvinphos and its regulated metabolites for cattle, hogs, and poultry are
       required.  These data have been required and their due dates are listed below.

              Guideline No.        Study Name                             Due Date

              171-4(d)             Residue Analytical Methods               4/30/96

              171-40)             Magnitude of the Residue                4/30/96
                                  in Dermally-Treated Cattle and Poultry

              Because of the feed additive tolerance issue with the Delaney clause the
       requirement for the livestock residue data for the feed-through use oral exposure
       is deferred.

              Data are also  required to upgrade the Mixer/Loader/Applicator  study,
       (MRID # 42622301).  These data must supply information to verify the storage
       duration of the field samples versus the field recovery samples.

B.     End-Use Products

       1.      Additional Product-Specific Data Requirements

              Section 4(g)(2)(B) of FIFRA calls for the  Agency to obtain any needed
       product-specific data regarding the pesticide after a determination of eligibility has
       been made. The product specific data requirements  are listed in Appendix  G, the
       Product Specific Data Call-in Notice.

              Registrants must review previous data submissions to ensure that they meet
       current EPA acceptance criteria (Appendix F; Attachment E) and if not, commit
       to conduct new studies. If a registrant believes that previously submitted data meet
       current testing standards, then study MRID numbers should be cited according to
       the instructions in the Requirement Status and Registrants Response Form provided
       for each product.

       2.      General Labeling Requirements for Products

              a.     All Products

                    Because tetrachlorvinphos  is classified as a skin sensitizer, the
              Agency requires that the following statement appear on all tetrachlorvinphos
                                    57

-------
labels in the "Hazards to Humans (and Domestic Animals)" section of the
Precautionary Statements:

       "This product may cause skin  sensitization reactions in
       certain individuals."

b.     Products Intended Primarily for Occupational Use

       The Agency is requiring the following labeling statements to be
located on all  end-use  products containing  tetrachlorvinphos  that are
intended primarily for occupational use:

       (1)    Application Restrictions:

             "Do not  apply  this product in a way that will contact
             workers or other persons, either directly or through drift.
             Only protected  handlers  may be  in the  area  during
             application."

       (2)    User Safety Requirements:

             "Follow      manufacturer's     instructions      for
             cleaning/maintaining  PPE.   If no such instructions for
             washables, use detergent and hot water. Keep and wash
             PPE separately from other laundry."

       (3)    User Safety Recommendations:

             •     "Users should wash hands before eating, drinking,
                    chewing gum, using tobacco, or using the toilet."

             •     "Users  should remove  clothing immediately  if
                    pesticide gets inside.  Then wash thoroughly and put
                    on clean clothing."

             •     "Users  should remove PPE  immediately  after
                    handling this product.  Wash the outside of gloves
                    before removing.    As  soon as possible,  wash
                    thoroughly and change into clean clothing."
                      58

-------
              c.     Occupational Products Used in Recreational Areas

                    The following entry restriction must be added to the labels of all
              products used occupationally in recreational areas:

                    For Liquid Application:

                    "Do not enter or allow others to enter the treated area until sprays
                    have dried."

              d.     Products with Feed-Through Uses

                    All products labeled for use on horses (currently EPA Reg. No.
              56493-35) must have the following restriction:

                    "This product is not to be used on horses destined for slaughter."

                    Labels of all products with directions for use as a feed-through for
              livestock (currently EPA  Reg. Nos. 56493-34 and  56493-35) must be
              clarified so that weights of pesticide to be added to feed refer to weights of
              active ingredient and not weights of product.

C.     Existing Stocks

       Registrants may generally  distribute and sell products bearing old labels/labeling
for 26 months from the date of the issuance of this Reregistration  Eligibility Decision
(RED). Persons other than the registrant may generally distribute or sell such products for
50 months from the date of  the issuance of this  RED.  However,  existing stocks time
frames will be established case-by-case,  depending on the number of products involved,
the number of label changes, and other factors. Refer to "Existing Stocks of Pesticide
Products; Statement of Policy"; Federal Register, Volume 56, No.  123, June 26, 1991.

       The  Agency  has   determined  that  registrants  may  distribute  and  sell
tetrachlorvinphos products  bearing old labels/labeling for 26 months from the date of
issuance  of this RED.  Persons  other than the registrant  may distribute or sell such
products  for 50 months  from the date of the issuance  of this  RED.  Registrants and
persons other than registrants  remain obligated to meet pre-existing Agency imposed label
changes and existing stocks requirements applicable to products they sell or distribute.
                                    59

-------
60

-------
VI. APPENDICES
      61

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62

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Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  —  CASE 0321, [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                          LUIS 2.1  -  Page 1
SITE Application Type, Application
Timing, Application Equipment —
Surface Type (Antimicrobial only) &
cy Influencing Factor (Antimicrobial

USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES
BARNS/BARNYARDS/AUCTION BARNS
Enclosed premise treatment., When
needed., Knapsack sprayer.



Enclosed premise treatment., When
needed., Power sprayer.


BEEF /RANGE/FEEDER CATTLE (MEAT)
Animal treatment (back rubber) . , When
needed., Hand held sprayer.
Animal treatment (dust) ., When needed.
Dust bag.



Animal treatment (dust) ., When needed.
Rotary duster.



Animal treatment (dust) ., When needed.
Shaker can.


Fo rm ( s )
Min . Appl .
Max. Appl. Soil
Rate (AI un- Rate (AI Tex.
Effica-
only)




EC

WP
WP/D
WP/D
EC

WP
WP/D

EC

D

D
D
D
D

D
D
D
D

D
D
less noted
otherwise)




NA

NA
NA
NA
NA

NA
NA

NA

NA

NA
NA
NA
NA

NA
NA
NA
NA

NA
NA
unless noted Max.
otherwise) Dose



Use Group :
3233 Ib IK sq.ft *

3333 Ib IK sq.ft *
3333 Ib IK sq.ft *
3333 Ib IK sq.ft *
3233 Ib IK sq.ft *

3333 Ib IK sq.ft *
3333 Ib IK sq.ft *
Use Group :
UC *

UC *

UC *
UC *
UC *
.00375 Ib animal *

.0075 Ib animal *
.00375 Ib animal *
.00375 Ib animal *
.00375 Ib animal *

.0075 Ib animal *
.00375 Ib animal *
Max. #
© Max .
/crop
cycle



Apps
Rate
/year




Max. Dose [ (AI
unless
noted
otherwise) /A]
/crop
cycle


/year



Min.
Interv
(days)




Restr. Geographic Limitations
Entry Allowed Disallowed
Interv
[day(s) ]



Use
Limitations
Codes




: INDOOR FOOD
NS

NS
NS
NS
NS

NS
NS
NS

NS
NS
NS
NS

NS
NS
NS

NS
NS
NS
NS

NS
NS
NS

NS
NS
NS
NS

NS
NS
NS

NS
NS
NS
NS

NS
NS
NS

NS
NS
NS
NS

NS
NS
CAE

CAE
CAC, CAG
CAE
CAE

CAE
CAE
: INDOOR FOOD
NS

NS

NS
NS
NS
NS

NS
NS
NS
NS

NS
NS
NS

NS

NS
NS
NS
NS

NS
NS
NS
NS

NS
NS
NS

NS

NS
NS
NS
NS

NS
NS
NS
NS

NS
NS
NS

NS

NS
NS
NS
NS

NS
NS
NS
NS

NS
NS
10

1

NS
NS
NS
1

NS
NS
NS
1

NS
NS
NS

NS

NS
NS
NS
NS

NS
NS
NS
NS

NS
NS
CAD

CAC


CAC
CAE
CAC


CAC
CAE
CAC


CAC
                                                                                         63

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Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321, [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                          LUIS  2.1   -  Page 2
SITE Application Type, Application Form(s;
Timing, Application Equipment —
Surface Type (Antimicrobial only) & Effica-
cy Influencing Factor (Antimicrobial only)
USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
BEEF /RANGE/FEEDER CATTLE (MEAT) (con't)

Animal treatment (face rubber) ., When
needed., Hand held sprayer.
Animal treatment (spray) ., Not on label.,
Knapsack sprayer.
Animal treatment (spray) ., Not on label.,
Power sprayer.
Animal treatment (spray) ., When needed.,
Knapsack sprayer.



Animal treatment (spray) ., When needed.,
Power sprayer.



Animal treatment., When needed., Knapsack
sprayer.
Animal treatment., When needed., Power
sprayer.
Back rubber. Use code ATK. , When needed.,
By hand .
Back rubber. Use code ATK., When needed.,
Not applicable.
Ear tag. Use code ATO . , When needed.,
Pliers.
Enclosed premise treatment., When
needed., Knapsack sprayer.
i Min. Appl . Max. Appl. Soil Max. tt Apps Max. Dose [ (AI Min.
Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv
less noted unless noted Max. /crop /year otherwise) /A] (days)
otherwise) otherwise) Dose cycle /crop /year
cycle
Use Group: INDOOR FOOD
D
EC

EC
EC
EC
WP
WP
WP/D
EC
WP
WP
WP/D
EC

EC

RTU

EC

IMPR
EC
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA

NA

NA

NA
NA
.00375


.03988
.03988
.03984
.04167
.04
.04167
.03984
.04167
.04
.04167
.04209

.04209



.003988

.009061
Ib


Ib
Ib
Ib
Ib
Ib
Ib
Ib
Ib
Ib
Ib
Ib

Ib



Ib

Ib
.79764
animal
UC

animal
animal
animal
animal
animal
animal
animal
animal
animal
animal
animal

animal

UC

linear
ft
animal
Ib IK
sq.ft
* NS
* NS

* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS

* NS

* NS

* NS

* NS
* NS
NS
NS

NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS

NS

NS

NS
NS
(con't)
NS
NS

NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS

NS

NS

NS
NS

NS
NS

NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS

NS

NS

NS
NS

NS
10

NS
NS
10
NS
NS
NS
10
NS
NS
NS
NS

NS

NS

NS

AN
NS
Restr. Geographic
Entry Allowed
Interv
[day(s) ]

NS
NS

NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS

NS

NS

NS
NS
Limitations Use
Disallowed Limitations
Codes

CAE
CAD

CAD
CAD
CAD

CAE
CAE
CAD

CAE
CAE
CAE

CAE

CAC

CAD

S09(0)
CAD
                                                                                        64

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Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321, [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                          LUIS 2.1  -  Page 3
SITE Application Type, Application Form(s)
Timing, Application Equipment —
Surface Type (Antimicrobial only) & Effica-
cy Influencing Factor (Antimicrobial only)

USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
BEEF /RANGE/FEEDER CATTLE (MEAT) (con't)
Enclosed premise treatment., When EC
needed., Power sprayer.
Face rubber. Use code ATR, When needed., EC
Not applicable.
Feed through . , When needed . , By hand . G
Feed through . , When needed . , Not on FM?
label.
G




G



G


G

G

G



G

G
P/T


Min. Appl . Max. Appl. Soil Max. tt Apps Max. Dose [ (AI Min. Restr. Geographic Limitations
Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv Entry Allowed Disallowed
less noted unless noted Max. /crop /year otherwise) /A] (days) Interv
otherwise) otherwise) Dose cycle /crop /year [day(s)]
cycle


Use Group: INDOOR FOOD (con't)
NA .79764 Ib IK * NS NS NS NS NS NS
sq.ft
NA .003988 Ib linear * NS NS NS NS NS NS
ft
NA .198 Ib ton * NS NS NS NS NS NS
NA UC * NS NS NS NS 1 NS

NA NA * NS NS NS NS 1 NS
1.595E-04 Ib 100 *
Ib body wt
1.500E-06 Ib Ib *
body wt
NA 1.309E-06 Ib 100 * NS NS NS NS 1 NS
Ib body wt
1.929E-08 Ib Ib *
body wt
NA UC * NS NS NS NS 1 NS
1.543E-08 Ib Ib *
body wt
NA 1.550E-06 Ib Ib * NS NS NS NS 1 NS
body wt
NA 3.387E-07 Ib Ib * NS NS NS NS 1 NS
body wt
NA .004631 Ib 100 Ib * NS NS NS NS 7 NS
body wt
2.120E-08 Ib Ib *
body wt
NA 3.387E-07 Ib Ib * NS NS NS NS NS NS
body wt
NA .198 Ib ton * NS NS NS NS NS NS
NA UC * NS NS NS NS 1 NS
1.543E-08 Ib Ib *
body wt
Use
Limitations
Codes





CAD

CAD

CAC







C93



CAA


CAC

CAE







CAC



                                                                                         65

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Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos] Chemical 083701  [Tetrachlorvinphos]
                                                                                                                                                          LUIS  2.1  -   Page  4
SITE Application Type, Application Form(s) Min. Appl . Max. Appl. Soil
Timing, Application Equipment — Rate (AI un- Rate (AI Tex.
Surface Type (Antimicrobial only) & Effica- less noted unless noted Max.
cy Influencing Factor (Antimicrobial only) otherwise) otherwise) Dose
USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
BEEF /RANGE/FEEDER CATTLE (MEAT) (con't)







Manure treatment. Use site code 40001.,
When needed., Knapsack sprayer.
Manure treatment. Use site code 40001.,
When needed., Power sprayer.
CALVES (MEAT)
Enclosed premise treatment., When
needed., Knapsack sprayer.
Enclosed premise treatment., When
needed., Power sprayer.
DAIRY CATTLE (LACTATING OR UNSPECIFIED)
Animal treatment (back rubber) . , When
needed., Hand held sprayer.
Animal treatment (dust) ., When needed.,
Dust bag.




Animal treatment (dust) ., When needed.,

P/T NA

P/T NA

P/T NA

P/T NA
EC NA

EC NA


EC NA

EC NA


EC NA

D NA

D NA
D NA
D NA
D NA
D NA
Use Group :
1.157E-08 Ib Ib *
body wt
4.630E-09 Ib Ib *
body wt
1.235E-08 Ib Ib *
body wt
UC *
.79764 Ib IK *
sq.ft
.79764 Ib IK *
sq.ft
Use Group :
.3233 Ib IK sq.ft *

.3233 Ib IK sq.ft *

Use Group :
UC *

UC *

UC *
UC *
UC *
UC *
.0075 Ib animal *
Max. tt Apps Max. Dose [ (AI Min. Restr. Geographic
@ Max. Rate unless noted Interv Entry Allowed
/crop /year otherwise) /A] (days) Interv
cycle /crop /year [day(s)]
cycle
Limitations Use
Disallowed Limitations
Codes
: INDOOR FOOD (con't)
NS

NS

NS

NS
NS

NS

NS NS NS 1 NS

NS NS NS 1 NS

NS NS NS 1 NS

NS NS NS NS NS
NS NS NS NS NS

NS NS NS NS NS

C93

CAA

CAC


CAD

CAD

: INDOOR FOOD
NS

NS

NS NS NS NS NS

NS NS NS NS NS

CAE

CAE

: INDOOR FOOD
NS

NS

NS
NS
NS
NS
NS
NS NS NS NS NS

NS NS NS 1 NS

NS NS NS 1 NS
NS NS NS NS NS
NS NS NS NS NS
NS NS NS NS NS
NS NS NS NS NS
CAD

CAC

CAE

CAC
CAE

Hand held duster.

Animal treatment (dust).,  When needed.,
Rotary duster.
    .00375 Ib animal
                                                                                         66

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Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos] Chemical 083701  [Tetrachlorvinphos]
                                                                                                                                                          LUIS 2.1  -  Page 5
SITE Application Type, Application Form(s;
Timing, Application Equipment —
Surface Type (Antimicrobial only) & Effica-
cy Influencing Factor (Antimicrobial only)
USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
i Min. Appl . Max. Appl. Soil Max. tt Apps Max. Dose [ (AI Min.
Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv
less noted unless noted Max. /crop /year otherwise) /A] (days)
otherwise) otherwise) Dose cycle /crop /year
cycle
DAIRY CATTLE (LACTATING OR UNSPECIFIED) (con't)





Animal treatment (dust) ., When needed.,
Shaker can.





Animal treatment (face rubber) ., When
needed., Hand held sprayer.
Animal treatment (spray) ., Not on label.,
Knapsack sprayer.
Animal treatment (spray) ., Not on label.,
Power sprayer.
Animal treatment (spray) ., When needed.,
Power sprayer.
Back rubber. Use code ATK. , When needed.,
By hand .
Back rubber. Use code ATK., When needed.,
Not applicable.
Ear tag. Use code ATO . , When needed.,
Pliers.
Enclosed premise treatment., When
D
D
D
D
D
D

D
D
D
D
D
EC

EC
EC
EC
RTU

EC

IMPR
EC
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA

NA
NA
NA
NA

NA

NA
NA
.00375
.00375
.00375
.00375
.00375
.00375

.00375
.00375
.00375
.00375
.00375


.04985




.003988

.009061
.3191 Ib
Ib
Ib
Ib
Ib
Ib
Ib

Ib
Ib
Ib
Ib
Ib


Ib




Ib

Ib
Use Group: INDOOR FOOD
animal
animal
animal
animal
animal
animal

animal
animal
animal
animal
animal
UC

UC
animal
UC
UC
UC

linear
ft
animal
IK sq.ft
* NS
* NS
* NS
* NS
* NS
* NS

* NS
* NS
* NS
* NS
* NS
* NS

* NS
*
* NS
* NS
* NS

* NS

* NS
* NS
NS
NS
NS
NS
NS
NS

NS
NS
NS
NS
NS
NS

NS
NS
NS
NS

NS

NS
NS
(con't)
NS
NS
NS
NS
NS
NS

NS
NS
NS
NS
NS
NS

NS
NS
NS
NS

NS

NS
NS

NS
NS
NS
NS
NS
NS

NS
NS
NS
NS
NS
NS

NS
NS
NS
NS

NS

NS
NS

1
1
NS
NS
NS
1

1
1
NS
NS
NS
NS

NS
NS
NS
NS

NS

AN
NS
Restr. Geographic
Entry Allowed
Interv
[day(s) ]

NS
NS
NS
NS
NS
NS

NS
NS
NS
NS
NS
NS

NS
NS
NS
NS

NS

NS
NS
Limitations Use
Disallowed Limitations
Codes

CAC
CAE

CAC
CAE


CAC
CAE

CAC
CAE
CAD

CAD
CAD
CAD
CAC

CAD

S09(0)
CAD
needed.,  Knapsack sprayer.
                                                                                         67

-------
Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321, [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                          LUIS  2.1   -  Page 6
SITE Application Type, Application Form(s)
Timing, Application Equipment —
Surface Type (Antimicrobial only) & Effica-
cy Influencing Factor (Antimicrobial only)
USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
DAIRY CATTLE (LACTATING OR UNSPECIFIED)



Enclosed premise treatment., When
needed., Power sprayer.



Face rubber. Use code ATR, When needed.
Not applicable.
Feed through . , When needed . , By hand .
Feed through . , When needed . , Not on
label.
















(con't)
EC
WP
WP/D
EC
EC
WP
WP/D
EC

G
FM?
G



G


G


G

G

Min. Appl. Max. Appl. Soil
Rate (AI un- Rate (AI Tex.
less noted unless noted Max.
otherwise) otherwise) Dose


Use Group :
NA .3233 Ib IK sq.ft *
NA .3333 Ib IK sq.ft *
NA .3333 Ib IK sq.ft *
NA .3191 Ib IK sq.ft *
NA .3233 Ib IK sq.ft *
NA .3333 Ib IK sq.ft *
NA .3333 Ib IK sq.ft *
NA .003988 Ib linear *
ft
NA .198 Ib ton *
NA UC *
NA NA *
.004631 Ib 100 Ib *
body wt
1.500E-06 Ib Ib *
body wt
NA 1.309E-06 Ib 100 *
Ib body wt
1.198E-07 Ib Ib *
body wt
NA UC *
1.543E-08 Ib Ib *
body wt
NA 3.387E-07 Ib Ib *
body wt
.198 Ib ton *
NA 3.387E-07 Ib Ib *
body wt
Max. tt Apps Max. Dose [ (AI
@ Max. Rate unless noted
/crop /year otherwise) /A]
cycle /crop /year
cycle


: INDOOR FOOD (con't)
NS NS NS NS
NS NS NS NS
NS NS NS NS
NS NS NS NS
NS NS NS NS
NS NS NS NS
NS NS NS NS
NS NS NS NS

NS NS NS NS
NS NS NS NS
NS NS NS NS



NS NS NS NS


NS NS NS NS


NS NS NS NS

NS NS NS NS

Min. Restr. Geographic Limitations
Interv Entry Allowed Disallowed
(days) Interv
[day(s) ]



NS NS
NS NS
7 NS
NS NS
NS NS
NS NS
7 NS
NS NS

1 NS
1 NS
1 NS



1 NS


1 NS


1 NS

1 NS

Use
Limitations
Codes



CAE

CAC, CAG
CAD
CAE

CAC, CAG
CAD

CAC





C93


CAA


CAC

CAE

                                                                                        68

-------
Report Run Date: 07/14/95  -  Time 09:57
               APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                            LUIS  2.1   -  Page 7
SITE Application Type, Application
Timing, Application Equipment —
Fo rm ( s )

Surface Type (Antimicrobial only) & Effica-
cy Influencing Factor (Antimicrobial

USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
DAIRY CATTLE (LACTATING OR UNSPECIFIED)
















Manure treatment. Use site code 40001.,
When needed., Knapsack sprayer.

Manure treatment. Use site code 40001.,
only)



(con't)
G

G




P/T


P/T

P/T

P/T

EC

WP/D
WP/D
Min. Appl . Max. Appl. Soil Max. tt Apps Max. Dose [ (AI Min. Restr. Geographic Limitations
Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv Entry Allowed Disallowed
less noted unless noted Max. /crop /year otherwise) /A] (days) Interv
otherwise) otherwise) Dose cycle /crop /year [day(s)]
cycle


Use Group: INDOOR FOOD (con't)
NA 2.120E-08 Ib Ib * NS NS NS NS 7 NS
body wt
NA 1.476E-04 Ib 100 * NS NS NS NS NS NS
Ib body wt
.001595 Ib animal *
3.387E-07 Ib Ib *
body wt
NA UC * NS NS NS NS 1 NS
1.543E-08 Ib Ib *
body wt
NA 1.929E-08 Ib Ib * NS NS NS NS 1 NS
body wt
NA 4.630E-09 Ib Ib * NS NS NS NS 1 NS
body wt
NA 1.235E-08 Ib Ib * NS NS NS NS 1 NS
body wt
NA .79764 Ib IK * NS NS NS NS NS NS
sq.ft
NA .8333 Ib IK sq.ft * NS NS NS NS 7 NS
NA .8333 Ib IK sq.ft * NS NS NS NS 7 NS
Use
Limitations
Codes















C93

CAA

CAC

CAD

CAC, CAG
CAC, CAG
When needed., Power sprayer.

EGG HANDLING ROOMS  (COMMERCIAL)

Enclosed premise treatment., When
needed., Duster.

Enclosed premise treatment., When
needed., Knapsack sprayer.

Enclosed premise treatment., When
needed., Power sprayer.

HOG/PIG/SWINE (MEAT)

Animal bedding/litter treatment., When
needed., Hand held duster.
WP/D


WP/D


WP/D
                               Use Group:  INDOOR  FOOD

                                 UC    *  NS    NS
.08333  Ib IK
       sq.ft

.08333  Ib IK
       sq.ft
                  NS
                                         NS
                        NS
                                               NS
                                                                   NS   NS     NS
                                           NS   NS     NS
                                                                   NS   NS     NS
                               Use Group:  INDOOR  FOOD

                      .2 Ib IK sq.ft    *  NS    NS
CAC,  CAG


CAC,  CAG


CAC,  CAG
                                                                                          69

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Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos] Chemical 083701  [Tetrachlorvinphos]
                                                                                                                                                           LUIS 2.1  -  Page
SITE Application Type, Application Form(s) Min. Appl . Max. Appl. Soil Max. tt Apps Max. Dose [ (AI Min.
Timing, Application Equipment — Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv
Surface Type (Antimicrobial only) & Effica- less noted unless noted Max. /crop /year otherwise) /A] (days)
cy Influencing Factor (Antimicrobial only) otherwise) otherwise) Dose cycle /crop /year
cycle
USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
HOG/PIG/SWINE (MEAT) (con't)

Animal bedding/litter treatment., When
needed., Power duster.


Animal treatment (dust) ., When needed.,
Hand held duster.


Animal treatment (dust) ., When needed.,
Power duster.




Animal treatment (dust) ., When needed.,
Rotary duster.


Animal treatment (dust) ., When needed.,
Shaker can.


Animal treatment (spray) ., Not on label.
Use Group: INDOOR FOOD
D
D

D
D
D

D
D
D

D
D
D
D
D

D
D
D

D
D
. , EC
NA
NA

NA
NA
NA

NA
NA
NA

NA
NA
NA
NA
NA

NA
NA
NA

NA
NA
NA
.0075
.2 Ib

.2 Ib
.0075
.0075

.0075
.0075
.0075

.0075
.0075
.0075

.0075

.0075
.0075
.0075

.0075
.0075
.01992
Ib animal
IK sq.ft

IK sq.ft
Ib animal
Ib animal

Ib animal
Ib animal
Ib animal

Ib animal
Ib animal
Ib animal
UC
Ib animal

Ib animal
Ib animal
Ib animal

Ib animal
Ib animal
Ib animal
* NS
* NS

* NS
* NS
* NS

* NS
* NS
* NS

* NS
* NS
* NS
* NS
* NS

* NS
* NS
* NS

* NS
* NS
* NS
NS
NS

NS
NS
NS

NS
NS
NS

NS
NS
NS
NS
NS

NS
NS
NS

NS
NS
NS
(con't)
NS
NS

NS
NS
NS

NS
NS
NS

NS
NS
NS
NS
NS

NS
NS
NS

NS
NS
NS

NS
NS

NS
NS
NS

NS
NS
NS

NS
NS
NS
NS
NS

NS
NS
NS

NS
NS
NS

14
1

14
14
14

14
14
1

14
14
14
NS
1

14
14
1

14
NS
14
Restr. Geographic
Entry Allowed
Interv
[day(s) ]

NS
NS

NS
NS
NS

NS
NS
NS

NS
NS
NS
NS
NS

NS
NS
NS

NS
NS
NS
Limitations Use
Disallowed Limitations
Codes

CAE
CAC


CAE


CAC
CAE
CAC


CAC
CAE
CAE


CAC
CAE


CAC
CAE
CAD
Knapsack sprayer.

Animal treatment (spray)., Not on label.
Powe r sp raye r.
    .01992 Ib animal
                                                                                         70

-------
Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321, [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                          LUIS  2.1   -  Page
SITE Application Type, Application
Timing, Application Equipment —
Surface Type (Antimicrobial only) &
cy Influencing Factor (Antimicrobial

USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
HOG/PIG/SWINE (MEAT) (con't)
Animal treatment (spray) ., When needed
Knapsack sprayer.


Animal treatment (spray) ., When needed
Power sprayer.


Fo rm ( s )
Min . Appl .
Max. Appl. Soil
Rate (AI un- Rate (AI Tex.
Effica-
only)




WP

WP
WP/D
WP

WP
WP/D
Animal treatment., When needed., Knapsack EC
sprayer.
Animal treatment., When needed., Power
sprayer.
Enclosed premise treatment., When
needed., Knapsack sprayer.


Enclosed premise treatment., When
needed., Power sprayer.


Feed through . , When needed . , By hand .
Feed through . , When needed . , Not on
label.







EC

EC

EC
WP/D
EC

EC
WP/D
G
G


G
G



less noted
otherwise)




NA

NA
NA
NA

NA
NA
NA

NA

NA

NA
NA
NA

NA
NA
NA
NA


NA
NA



unless noted Max.
otherwise) Dose



Use Group :
.02083 Ib animal *

.02 Ib animal *
.02083 Ib animal *
.02083 Ib animal *

.02 Ib animal *
.02083 Ib animal *
.02105 Ib animal *

.02105 Ib animal *

3233 Ib IK sq.ft *

3191 Ib IK sq.ft *
3333 Ib IK sq.ft *
3233 Ib IK sq.ft *

3191 Ib IK sq.ft *
3333 Ib IK sq.ft *
.198 Ib ton *
UC *
4.653E-05 Ib *
animal
UC *
UC *
4.653E-05 Ib *
animal
.198 Ib ton *
Max.
@ Max
/crop
cycle



# Apps
. Rate
/year




: INDOOR FOOD
NS

NS
NS
NS

NS
NS
NS

NS

NS

NS
NS
NS

NS
NS
NS
NS


NS
NS



NS

NS
NS
NS

NS
NS
NS

NS

NS

NS
NS
NS

NS
NS
NS
NS


NS
NS



Max. Dose
[(AI
unless noted
otherwise) /A]
/crop
cycle


(con't)
NS

NS
NS
NS

NS
NS
NS

NS

NS

NS
NS
NS

NS
NS
NS
NS


NS
NS



/year




NS

NS
NS
NS

NS
NS
NS

NS

NS

NS
NS
NS

NS
NS
NS
NS


NS
NS



Min.
Interv
(days)





14

14
NS
14

14
NS
14

14

14

NS
NS
14

NS
NS
1
1


1
1



Restr. Geographic Limitations
Entry Allowed Disallowed
Interv
[day(s) ]




NS

NS
NS
NS

NS
NS
NS

NS

NS

NS
NS
NS

NS
NS
NS
NS


NS
NS



Use

Limitations
Codes







CAE
CAE


CAE
CAE
CAE

CAE

CAE

CAD
CAC,
CAE

CAD
CAC,
CAC



C93
CAC























CAG



CAG









                                                                                        71

-------
Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321, [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                            LUIS 2.1  -  Page 10
SITE Application Type, Application Form(s;
Timing, Application Equipment —
Surface Type (Antimicrobial only) & Effica-
cy Influencing Factor (Antimicrobial only)
USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
HOG/PIG/SWINE (MEAT) (con't)

Litter and bedding treatment. Use code
AAL . , When needed., Hand held duster.
Litter and bedding treatment. Use code
AAL., When needed., Power duster.

Litter and bedding treatment. Use code
AAL., When needed., Rotary duster.

Litter and bedding treatment. Use code
AAL., When needed., Shaker can.

Manure treatment. Use site code 40001.,
When needed., Knapsack sprayer.
Manure treatment. Use site code 40001.,
When needed., Power sprayer.
POULTRY (EGG /MEAT)
Animal equipment treatment., When
needed., Paintbrush.






Animal treatment (dust) ., When needed.,
G
G
D
D
D
D
D
D
D
EC

EC


D
D

D
D
WP
WP/D
D
i Min. Appl . Max. Appl. Soil
Rate (AI un- Rate (AI Tex.
less noted unless noted Max.
otherwise) otherwise) Dose
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA


NA
NA

NA
NA
NA
NA
NA


.2 Ib
.2 Ib
.2 Ib
.2 Ib
.2 Ib
.2 Ib
.2 Ib
Use Group :
UC *
UC *
IK sq.ft *
IK sq.ft *
IK sq.ft *
IK sq.ft *
IK sq.ft *
IK sq.ft *
IK sq.ft *
.79764 Ib IK *

sq.ft
.79764 Ib IK *


2 .4
2 .4
2.4 Ib
.3
2 .4
.1
.1042
.0006
sq.ft
Use Group :
Ib IK ft *
Ib IK ft *
IK sq.ft *
Ib IK ft *
Ib IK ft *
Ib IK ft *
Ib IK ft *
Ib bird *
Max. # Apps Max. Dose [ (AI Min.
@ Max. Rate unless noted Interv
/crop /year otherwise) /A] (days)
cycle /crop /year
cycle
: INDOOR FOOD (con't)
NS NS NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS

NS
NS
NS
NS
NS
NS
NS
NS
NS

NS

NS
NS
NS
NS
NS
NS
NS
NS
NS

NS

NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS

1
NS
14
14
14
14
14
14
14
NS

NS

Restr. Geographic
Entry Allowed
Interv
[day(s) ]
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS

Limitations Use
Disallowed Limitations
Codes
CAE

CAE

CAE
CAC
CAE
CAC
CAE
CAD

CAD

: INDOOR FOOD
NS
NS

NS
NS
NS
NS
NS
NS
NS

NS
NS
NS
NS
NS
NS
NS

NS
NS
NS
NS
NS
NS
NS

NS
NS
NS
NS
NS
14
NS

NS
NS
NS
NS
NS
NS
NS

NS
NS
NS
NS
NS
CAE


CAC
CAE
CAE
CAE

Dust box.
                                                                                        72

-------
Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321, [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                            LUIS 2.1  -  Page 11
SITE Application Type, Application
Timing, Application Equipment —
Surface Type (Antimicrobial only) &
cy Influencing Factor (Antimicrobial

USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
POULTRY (EGG /MEAT) (con't)






Animal treatment (dust) ., When needed.
Rotary duster.









Animal treatment (dust) ., When needed.
Shaker can.









Animal treatment (spray) ., When needed
Knapsack sprayer.

Fo rm ( s )

Effica-
only)




D
D
WP

WP/D

D

D

D


D

D

D

D

D


D

D

EC

WP
Min . Appl .
Rate (AI un
less noted
otherwise)




NA
NA
NA

NA

NA

NA

NA


NA

NA

NA

NA

NA


NA

NA

NA 3.

NA
Max. Appl. Soil
Rate (AI Tex.
unless noted Max.
otherwise) Dose



Use Group :
.0006 Ib bird *
.0006 Ib bird *
.15625 Ib 100 *
birds
.15625 Ib 100 *
birds
.009999 Ib 100 *
birds
.009999 Ib 100 *
birds
.009999 Ib 100 *
birds
.0001 Ib bird *
.009999 Ib 100 *
birds
.009999 Ib 100 *
birds
*

.009999 Ib 100 *
birds
.009999 Ib 100 *
birds
.0001 Ib bird *
.009999 Ib 100 *
birds
.009999 Ib 100 *
birds
988E-04 Ib bird *

.0004 Ib bird *
Max. tt Apps Max. Dose [ (AI
@ Max. Rate unless noted
/crop /year otherwise) /A]
cycle /crop /year
cycle


: INDOOR FOOD (con't)
NS NS NS NS
NS NS NS NS
NS NS NS NS

NS NS NS NS

NS NS NS NS

NS NS NS NS

NS NS NS NS


NS NS NS NS

NS NS NS NS

NS NS NS NS

NS NS NS NS

NS NS NS NS


NS NS NS NS

NS NS NS NS

NS NS NS NS

NS NS NS NS
Min. Restr. Geographic Limitations
Interv Entry Allowed Disallowed
(days) Interv
[day(s) ]




NS NS
NS NS
NS NS

NS NS

1 NS

14 NS

14 NS


NS NS

NS NS

1 NS

14 NS

14 NS


NS NS

NS NS

14 NS

14 NS
Use
Limitations
Codes





CAC
CAE
CAE

CAE

CAC

CAC

CAE




CAE

CAC

CAC

CAE




CAE

CAD

CAE
                                                                                         73

-------
Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321, [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                            LUIS 2.1  -  Page 12
SITE Application Type, Application Form(s;
Timing, Application Equipment —
Surface Type (Antimicrobial only) & Effica-
cy Influencing Factor (Antimicrobial only)
USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
POULTRY (EGG /MEAT) (con't)

Animal treatment (spray) ., When needed.,
Power sprayer.


Brush-on., When needed., Brush.
Brush- on., When needed., Paintbrush.
Dust., When needed., Rotary duster.
Enclosed premise treatment., When
needed., Brush.
Enclosed premise treatment., When
needed., High pressure sprayer.
Enclosed premise treatment., When
needed., Knapsack sprayer.




Enclosed premise treatment., When
needed., Power sprayer.




Equipment treatment., When needed.,
Paintbrush .
i Min. Appl . Max. Appl. Soil Max. tt Apps Max. Dose [ (AI Min.
Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv
less noted unless noted Max. /crop /year otherwise) /A] (days)
otherwise) otherwise) Dose cycle /crop /year
cycle
Use Group: INDOOR FOOD
WP/D
EC
WP
WP/D
WP
D
D
WP/D
EC
EC
EC
WP
WP
WP/D
EC
EC
WP
WP
WP/D
D
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
.005 gal bird
3.988E-04 Ib bird
.0004 Ib bird
.005 gal bird
.1042 Ib IK ft
.3 Ib IK ft
.0006 Ib bird
.1042 Ib IK ft
.79764 Ib IK
sq.ft
.09971 Ib IK
linear ft
.1616 Ib IK sq.ft
.3333 Ib IK sq.ft
.8 Ib IK sq.ft
.3333 Ib IK sq.ft
.09971 Ib IK
linear ft
.1616 Ib IK sq.ft
.8333 Ib IK sq.ft
.8 Ib IK sq.ft
.3333 Ib IK sq.ft
2.4 Ib IK linear
ft
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
(con't)
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

14
14
14
14
NS
14
14
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
1
Restr. Geographic
Entry Allowed
Interv
[day(s) ]

NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Limitations Use
Disallowed Limitations
Codes

CAE
CAD
CAE
CAE

CAE
CAE
CAC, CAG
CAD
CAD
CAE

CAE
CAC, CAG
CAD
CAE

CAE
CAC, CAG
CAC
                                                                                        74

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Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos] Chemical 083701  [Tetrachlorvinphos]
                                                                                                                                                            LUIS 2.1  -  Page 13
SITE Application Type, Application Form(s;
Timing, Application Equipment —
Surface Type (Antimicrobial only) & Effica-
cy Influencing Factor (Antimicrobial only)
USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
POULTRY (EGG /MEAT) (con't)

Equipment treatment., When needed.,
Rotary duster.
Litter and bedding treatment. Use code
AAL . , When needed., Duster.
Litter and bedding treatment. Use code
AAL., When needed., Knapsack sprayer.

Litter and bedding treatment. Use code
AAL., When needed., Power sprayer.

Litter and bedding treatment. Use code
AAL., When needed., Rotary duster.




Litter and bedding treatment. Use code
AAL., When needed., Shaker can.


Manure treatment. Use site code 40001.,
When needed., Knapsack sprayer.


Manure treatment. Use site code 40001.,
When needed., Power sprayer.
i Min. Appl . Max. Appl. Soil Max. tt Apps Max. Dose [ (AI Min.
Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv
less noted unless noted Max. /crop /year otherwise) /A] (days)
otherwise) otherwise) Dose cycle /crop /year
cycle
Use Group: INDOOR FOOD
D
D
WP
WP
WP/D
WP
WP/D
D
D
D
D
D
D
D
D
EC

EC
WP/D
EC

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA

.3 Ib

.156
.08 Ib
1.6 Ib
.08 Ib
1.6 Ib
.3 Ib
.3 Ib
.3 Ib
.3 Ib
.3 Ib
.3 Ib
.1 Ib
.3 Ib
IK sq.ft

25 Ib 100
birds
IK sq.ft
IK sq.ft
IK sq.ft
IK sq.ft
IK sq.ft
IK sq.ft
IK sq.ft
IK sq.ft
IK sq.ft
IK sq.ft
IK sq.ft
IK sq.ft
.79764 Ib IK

.8081 Ib
.8333 Ib
sq.ft
IK sq.ft
IK sq.ft
.79764 Ib IK

sq.ft
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS

* NS
* NS
* NS

NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS
NS
NS

(con't)
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS
NS
NS


NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS
NS
NS


NS
1
NS
NS
NS
NS
NS
1
14
NS
NS
NS
14
NS
NS
NS

NS
NS
NS

Restr. Geographic
Entry Allowed
Interv
[day(s) ]

NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS

NS
NS
NS

Limitations Use
Disallowed Limitations
Codes

CAE
CAC

CAE
CAE
CAE
CAE
CAC
CAE

CAC
CAE
CAE

CAE
CAD

CAE
CAC, CAG
CAD

                                                                                         75

-------
Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos] Chemical 083701  [Tetrachlorvinphos]
                                                                                                                                                            LUIS  2.1  -   Page  14
SITE Application Type, Application
Timing, Application Equipment —
Surface Type (Antimicrobial only) &
cy Influencing Factor (Antimicrobial

USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
POULTRY (EGG /MEAT) (con't)


POULTRY (MEAT)
Animal equipment treatment., When
needed., Paintbrush.

Animal treatment (dust) ., When needed.
Dust box.



Animal treatment (dust) ., When needed.
Rotary duster.


Animal treatment (dust) ., When needed.
Shaker can.


Animal treatment (spray) ., When needed
Knapsack sprayer.

Animal treatment (spray) ., When needed
Power sprayer.

Enclosed premise treatment., When
Fo rm ( s )
Min . Appl .
Max. Appl. Soil
Rate (AI un- Rate (AI Tex.
Effica-
only)




EC
WP/D

D

WP/D
D

D
WP/D

D

D

D

D

EC

WP/D
EC

WP/D
EC
less noted
otherwise)




NA
NA

NA

NA
NA

NA
NA

NA

NA

NA

NA

NA 3

NA 4
NA 3

NA 4
NA
unless noted Max.
otherwise) Dose



Use Group :
8081 Ib IK sq.ft *
8333 Ib IK sq.ft *
Use Group :
2 .4 Ib IK ft *
2.4 Ib IK sq.ft *
.1042 Ib IK ft *
.0006 Ib bird *

.0006 Ib bird *
.15625 Ib 100 *
birds
.009999 Ib 100 *
birds
.009999 Ib 100 *
birds
.009999 Ib 100 *
birds
.009999 Ib 100 *
birds
.988E-04 Ib bird *

.167E-04 Ib bird *
.988E-04 Ib bird *

.167E-04 Ib bird *
.79764 Ib IK *
Max.
@ Max
/crop
cycle



# Apps
. Rate
/year




: INDOOR FOOD
NS
NS
NS
NS
Max. Dose
[(AI
unless noted
otherwise) /A]
/crop
cycle


(con't)
NS
NS
/year




NS
NS
Min.
Interv
(days)





NS
NS
Restr. Geographic Limitations
Entry Allowed Disallowed
Interv
[day(s) ]




NS
NS
Use
Limitations
Codes





CAE
CAC, CAG
: INDOOR FOOD
NS

NS
NS

NS
NS

NS

NS

NS

NS

NS

NS
NS

NS
NS
NS

NS
NS

NS
NS

NS

NS

NS

NS

NS

NS
NS

NS
NS
NS

NS
NS

NS
NS

NS

NS

NS

NS

NS

NS
NS

NS
NS
NS

NS
NS

NS
NS

NS

NS

NS

NS

NS

NS
NS

NS
NS
NS

NS
14

NS
NS

14

14

14

14

14

NS
14

NS
NS
NS

NS
NS

NS
NS

NS

NS

NS

NS

NS

NS
NS

NS
NS


CAE
CAE


CAE



CAE



CAE

CAD

CAE
CAD

CAE
CAD
needed.,  High pressure sprayer.

Enclosed premise treatment., When
needed.,  Knapsack sprayer.
               sq.ft

        .09971 Ib IK   *  NS
           linear ft
                                                                                         76

-------
Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos] Chemical 083701  [Tetrachlorvinphos]
                                                                                                                                                            LUIS 2.1  -  Page 15
SITE Application Type, Application Form(s) Min. Appl . Max. Appl. Soil Max. tt Apps Max. Dose [ (AI Min. Restr. Geographic
Timing, Application Equipment — Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv Entry Allowed
Surface Type (Antimicrobial only) & Effica- less noted unless noted Max. /crop /year otherwise) /A] (days) Interv
cy Influencing Factor (Antimicrobial only) otherwise) otherwise) Dose cycle /crop /year [day(s)]
cycle
USES ELIGIBLE FOR REREGISTRATION
FOOD/FEED USES (con't)
POULTRY (MEAT) (con't)

Enclosed premise treatment., When
needed., Power sprayer.

Equipment treatment., When needed.,
Paintbrush .
Litter and bedding treatment. Use code
AAL . , When needed., Electric duster.
Litter and bedding treatment. Use code
AAL., When needed., Knapsack sprayer.
Litter and bedding treatment. Use code
AAL., When needed., Mechanical duster.
Litter and bedding treatment. Use code
AAL., When needed., Power sprayer.
Litter and bedding treatment. Use code
AAL., When needed., Rotary duster.


Litter and bedding treatment. Use code
AAL., When needed., Shaker can.
Manure treatment. Use site code 40001.,
When needed., Knapsack sprayer.

Manure treatment. Use site code 40001.,
When needed., Power sprayer.
Limitations Use
Disallowed Limitations
Codes
Use Group: INDOOR FOOD (con't)
EC NA
EC NA
EC NA
D NA
WP/D NA
WP/D NA
WP/D NA
WP/D NA
D NA
D NA
WP/D NA
D NA
EC NA

EC NA
EC NA

.1616 Ib IK sq.
.09971 Ib
linear
.1616 Ib IK sq.
.3 Ib IK sq.
.2344 Ib IK sq.
1.6 Ib IK sq.
.2344 Ib IK sq.
1.6 Ib IK sq.
.3 Ib IK sq.
.3 Ib IK sq.
.2344 Ib IK sq.
.1 Ib IK sq.
.79764 Ib
sq.
.8081 Ib IK sq.
.79764 Ib
sq.
ft * NS NS NS NS NS NS
IK * NS NS NS NS NS NS
ft
ft * NS NS NS NS NS NS
ft * NS NS NS NS 14 NS
ft * NS NS NS NS NS NS
ft * NS NS NS NS NS NS
ft * NS NS NS NS NS NS
ft * NS NS NS NS NS NS
ft * NS NS NS NS 14 NS
ft * NS NS NS NS NS NS
ft * NS NS NS NS NS NS
ft * NS NS NS NS NS NS
IK * NS NS NS NS NS NS
ft
ft * NS NS NS NS NS NS
IK * NS NS NS NS NS NS
ft
CAE
CAD
CAE
CAE
CAE
CAE
CAE
CAE
CAE

CAE

CAD

CAE
CAD

                                                            .8081 Ib IK sq.ft
                                                                                         77

-------
Report Run Date: 07/14/95  -  Time 09:57
      APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos] Chemical  083701  [Tetrachlorvinphos]
                                                                                                                                                             LUIS 2.1  -  Page  16
SITE Application Type, Application        Forn
  Timing, Application Equipment  —
  Surface Type  (Antimicrobial only) & Effica-
  cy Influencing Factor  (Antimicrobial only)
USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED
Min.  Appl.       Max.  Appl. Soil Max. # Apps Max. Dose  [(AI   Min.   Restr.      Geographic  Limitations      Use
Rate (AI un-      Rate  (AI Tex. ® Max. Rate unless noted     Interv  Entry    Allowed           Disallowed   Limitations
less noted    unless noted Max. /crop /year otherwise)/A]    (days)  Interv                                  Codes
otherwise)       otherwise) Dose cycle       /crop    /year          [day(s)]
                                            cycle
ANIMAL KENNELS/SLEEPING QUARTERS  (COMMERCIAL)

Animal treatment  (dust)., When needed.,   D
Hand held duster.

Animal treatment  (spray)., When needed.,  WP/D
Knapsack sprayer.

Animal treatment  (spray)., When needed.,  WP/D
Powe r sp raye r.

Premise treatment., When needed.,         EC
Knapsack sprayer.

Premise treatment., When needed., Power   EC
sprayer.
Premise treatment.,  Not on label.,        EC
Knapsack sprayer.

Premise treatment.,  Not on label., Power  EC
sprayer.

CATS (ADULTS/KITTENS)

Animal bedding/litter treatment., When    PRL
needed., Aerosol can.

Animal bedding/litter treatment., When    D
needed., By hand.
Animal bedding/litter treatment., When
needed., Hand held duster.

Animal bedding/litter treatment., When
needed., Mist sprayer.

Animal treatment  (collar)., When needed.,  IMPR
By hand.
                      Use Group: INDOOR NON-FOOD

                        UC   *  NS    NS         NS


           .05 Ib IK sq.ft   *  NS    NS         NS


           .05 Ib IK sq.ft   *  NS    NS         NS


         .3335 Ib IK sq.ft   *  NS    NS         NS


         .3335 Ib IK sq.ft   *  NS    NS         NS


                      Use Group: TERRESTRIAL NON-FOOD

                  .996 Ib A   *  NS    NS         NS
                                                                                                          CROP

                                                                                                             NS
                  .996 Ib A
                                NS    NS
                                                 NS
                      Use Group: INDOOR RESIDENTIAL
D
D
RTU
IMPR
IMPR
IMPR
NA
NA
NA
NA
NA
NA
UC
UC
UC
UC
UC
UC
* NS
* NS
* NS
* NS
* NS
* NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
7
7
120
150
60
NS
NS
NS
NS
NS
NS
                                                                                         78

-------
Report Run Date: 07/14/95  -  Time 09:57
               APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos] Chemical  083701  [Tetrachlorvinphos]
                                                                                                                                                             LUIS 2.1  -  Page 17
SITE Application Type, Application
Timing, Application Equipment —
Surface Type (Antimicrobial only) &
cy Influencing Factor (Antimicrobial
USES ELIGIBLE FOR REREGISTRATION
NON-FOOD/NON-FEED (con't)
CATS ( ADULTS /KITTENS ) ( con ' t )
Animal treatment (dust) ., When needed.
By hand .



Animal treatment (dust) ., When needed.
Fo rm ( s )
Effica-
only)



D

D
D
D
D
Min . Appl .
Rate (AI un-
less noted
otherwise)



NA

NA
NA
NA
NA
Max. Appl.
Rate (AI
unless noted
otherwise)


Use
UC

UC
UC
UC
UC
Soil
Tex.
Max.
Dose


Group :
*

*
*
*
*
Max.
@ Max
/crop
cycle


# Apps
. Rate
/year


Max. Dose [ (AI
unless noted
otherwise) /A]
/crop /year
cycle


: INDOOR RESIDENTIAL
NS

NS
NS
NS
NS
NS

NS
NS
NS
NS
NS

NS
NS
NS
NS


(con't)
NS

NS
NS
NS
NS
Min.
Interv
(days)



7

7
NS
NS
7
Restr. Geographic Limitations
Entry Allowed Disallowed
Interv
[day(s) ]



NS

NS
NS
NS
NS
Use
Limitations
Codes





CAC

CAE

Hand held duster.
Animal treatment  (spray)., When needed.
Aerosol can.
Enclosed premise treatment., When
needed., Aerosol can.

Indoor premise treatment., When needed.
Aerosol can.

Indoor premise treatment., When needed.
Mist sprayer.

Sponge-on., When needed., Sponge.
DOGS/CANINES  (ADULTS/PUPPIES)

Animal bedding/litter treatment., When
needed., Aerosol can.
Animal bedding/litter treatment., When
needed.,  By hand.
D

D

PRL


RTU

PRL


PRL
PRL


RTU

D
NA

NA

NA


NA

NA
                                                   NA

                                                   NA
UC   *  NS    NS

UC   *  NS    NS

UC   *  NS    NS


UC   *  NS    NS

UC   *  NS    NS
NS

NS

NS


NS

NS
                                 UC
                                         NS    NS
                                 UC   *  NS
                                                                            UC    *   NS
                                                              .04409  Ib  animal    *
                                                                                          NS
                                                                                                     NS
                               Use Group: INDOOR RESIDENTIAL

                                 UC   *  NS    NS         NS
                        UC   *  NS    NS

                        UC   *  NS    NS
                         NS

                         NS
NS   NS

NS   NS

NS   NS


NS   7

NS   NS


NS   NS
        NS

        NS
NS

NS

NS


NS

NS
            NS

            NS
                                                                            UC    *   NS
                                                                                          NS
                                                                                         79

-------
Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos]  Chemical  083701  [Tetrachlorvinphos]
                                                                                                                                                             LUIS  2.1  -  Page 18
SITE Application Type, Application        Form(s)  Min.  Appl.       Max.  Appl.  Soil Max.  # Apps Max.  Dose [(AI   Min.   Restr.      Geographic Limitations      Use
  Timing, Application Equipment  —                 Rate  (AI un-       Rate (AI  Tex. ® Max. Rate unless noted    Interv Entry   Allowed           Disallowed   Limitations
  Surface Type  (Antimicrobial only) & Effica-      less  noted     unless  noted  Max. /crop /year otherwise)/A]    (days) Interv                                 Codes
  cy Influencing Factor  (Antimicrobial only)       otherwise)       otherwise)  Dose cycle       /crop    /year         [day(s)]
                                                                                                cycle

USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED  (con't)
DOGS/CANINES  (ADULTS/PUPPIES)  (con't)

Animal bedding/litter treatment., When
needed., Hand held duster.

Animal bedding/litter treatment., When
needed., Mist sprayer.

Animal treatment  (collar)., When needed.
By hand.
Animal treatment  (dust)., When needed.,
By hand.
                Use Group: INDOOR RESIDENTIAL  (con't)
Animal treatment  (dust)., When needed.,
Hand held duster.
Animal treatment  (spray)., When needed.
Aerosol can.

Animal treatment  (spray)., When needed.
Mist sprayer.

Indoor premise treatment., When needed.
Aerosol can.
                  UC   *  NS
                  UC   *  NS
                  UC   *  NS
                                NS
                  UC   *  NS
                                           NS
IMPR
D
D
D
D
D
D
D
PRL
NA
NA
NA
NA
NA
NA
NA
NA
NA
UC
UC
UC
UC
UC
UC
UC
UC
UC
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
* NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
60
7
7
NS
NS
7
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Indoor premise treatment., When needed.
Mist sprayer.

Sponge-on., When needed., Sponge.
HORSES (SHOW/RACE/SPECIAL/PONIES)

Animal treatment  (dust)., When needed.,
Hand held duster.
                                                                            UC   *   NS
                                                              .04409  Ib animal   *
                                                                                          NS
                                                                                                     NS
                Use Group: INDOOR NON-FOOD

                  UC   *  NS    NS         NS
                                                                                          80

-------
Report Run Date: 07/14/95  -  Time 09:57
APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos] Chemical 083701  [Tetrachlorvinphos]
                                                                                                                                                            LUIS  2.1  -  Page  19
SITE Application Type, Application Form(s) Min. Appl . Max. Appl. Soil Max. tt Apps Max. Dose [ (AI Min. Restr. Geographic
Timing, Application Equipment — Rate (AI un- Rate (AI Tex. @ Max. Rate unless noted Interv Entry Allowed
Surface Type (Antimicrobial only) & Effica- less noted unless noted Max. /crop /year otherwise) /A] (days) Interv
cy Influencing Factor (Antimicrobial only) otherwise) otherwise) Dose cycle /crop /year [day(s)]
cycle
USES ELIGIBLE FOR REREGISTRATION
NON-FOOD/NON-FEED (con't)
HORSES (SHOW /RACE/SPECIAL/PONIES) (con't)
Animal treatment (dust) ., When needed., D NA
Rotary duster.
Animal treatment (dust) ., When needed., D NA
Shaker can.
D NA
Animal treatment (spray) ., When needed., RTU NA
Sprayer.
Animal treatment (wound) ., When needed., RTU NA
By hand .
Animal treatment (wound) ., When needed., RTU NA
Cloth.
Enclosed premise treatment (spot) ., When D NA
needed., Shaker can.
Enclosed premise treatment., When D NA
needed., Rotary duster.
Enclosed premise treatment., When D NA
needed., Shaker can.
Feed through . , When needed . , Not on G NA
label.
G NA

G NA

G NA

P/T NA
Use Group: INDOOR NON-FOOD (con't)
.00375 Ib animal * NS NS NS NS NS NS

.00375 Ib animal * NS NS NS NS NS NS

.00375 Ib animal * NS NS NS NS NS NS
.001039 Ib animal * NS NS NS NS AN NS
UC * NS NS NS NS NS NS

UC * NS NS NS NS NS NS

.00375 Ib animal * NS NS NS NS NS NS
UC * NS NS NS NS NS NS
UC * NS NS NS NS NS NS
1.852E-08 Ib Ib * NS NS NS NS 1 NS
body wt
1.543E-08 Ib Ib * NS NS NS NS 1 NS
body wt
2.395E-06 Ib Ib * NS NS NS NS 1 NS
body wt
3.809E-06 Ib 100 * NS NS NS NS NS NS
Ib body wt
UC * NS NS NS NS 1 NS
Limitations Use
Disallowed Limitations
Codes

CAE



CAE






CAE
CAE

C93

CAE




                                          P/T


                                          P/T
     7.624E-09 Ib Ib   *
             body wt

     9.753E-09 Ib Ib   *  NS    NS
             body wt
                                                                                         81

-------
Report Run Date: 07/14/95  -  Time 09:57
                                                          APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos] Chemical 083701  [Tetrachlorvinphos]
                                                                                                                                                              LUIS  2.1  -  Page 20
SITE Application Type, Application
  Timing, Application Equipment  —
                                           Form(s)   Min.  Appl .
                                                    Rate  (AI un-
  Surface Type  (Antimicrobial only) & Effica-
  cy Influencing Factor  (Antimicrobial only)
USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED  (con't)
       Max.  Appl.  Soil Max.  tt Apps Max. Dose  [(AI   Min.  Restr.     Geographic Limitations       Use
         Rate (AI  Tex. @ Max. Rate unless noted    Interv Entry   Allowed           Disallowed    Limitations
                                                    less  noted    unless noted Max.  /crop /year otherwise) /A]    (days) Interv
                                                    otherwise)
                                                                    otherwise)  Dose cycle
                                   /crop
                                   cycle
/year
[day(s)]
                                                                                                                                                               Codes
HORSES (SHOW/RACE/SPECIAL/PONIES)  (con't)

Rub-on.,  When needed., By hand.           RTU

Rub-on.,  When needed., Cloth.             RTU

Wipe-on/wiper treatment., When needed.,   RTU
Cloth.

Wipe-on/wiper treatment., When needed.,   RTU
Glove.

HOUSEHOLD/DOMESTIC DWELLINGS

Spot treatment., When needed., Shaker     D
can.

HOUSEHOLD/DOMESTIC DWELLINGS  INDOOR PREMISES

Indoor premise treatment., When needed.,  PRL
Aerosol can.

HOUSEHOLD/DOMESTIC DWELLINGS  OUTDOOR PREMISES

                                          EC
Outdoor general surface spray., Not on
label., Knapsack sprayer.

Outdoor general surface spray., Not on
label., Power sprayer.
Manure treatment. Use site code 40001.,
When needed., Knapsack sprayer.
Manure treatment. Use site code 40001.,
When needed., Power sprayer.
                                           EC
                                                    NA

                                                    NA

                                                    NA
             Use Group:  INDOOR NON-FOOD (con't)

               UC   *  NS    NS         NS      NS   NS

               UC   *  NS    NS         NS      NS   NS

.001039 Ib animal   *  NS    NS         NS      NS   AN
                                                                            UC
                                                                                    NS
                                                                                          NS
                                                                                                     NS
                                                                          Use Group:  INDOOR RESIDENTIAL

                                                                            UC   *  NS    NS         NS


                                                                          Use Group:  INDOOR RESIDENTIAL

                                                                            UC   *  NS    NS         NS


                                                                          Use Group:  OUTDOOR RESIDENTIAL

                                                                     49.8 Ib A   *  NS    NS         NS
                                                                     49.8 Ib A
                                                                                    NS
                                                                                          NS
                                                                                                     NS
                                                                          Use Group:  OUTDOOR RESIDENTIAL
                                                                                                             NS
                                                                                                                  NS
                NS

                NS

                NS
EC
WP
WP
WP/D
EC
WP
WP
NA
NA
NA
NA
NA
NA
NA
.83375
.8333 Ib
.8 Ib
.8333 Ib
IK
IK
IK
.83375
.8333 Ib
.8 Ib
IK
IK
Ib
sq.
sq.
sq.
sq.
Ib
sq.
sq.
sq.
IK
ft
ft
ft
ft
IK
ft
ft
ft
* NS
* NS
* NS
* NS
* NS
* NS
* NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
7
7
7
NS
7
7
NS
NS
NS
NS
NS
NS
NS
                                                                                                                                                              CAE

                                                                                                                                                              CAE

                                                                                                                                                              CAD
                                                                                          82

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Report Run Date: 07/14/95  -  Time 09:57
               APPENDIX A  -  CASE 0321,  [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                              LUIS  2.1   -  Page 21
SITE Application Type, Application
  Timing, Application Equipment  —
  Surface Type  (Antimicrobial only) & Effica-
  cy Influencing Factor  (Antimicrobial only)
USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED  (con't)
Form(s)  Min. Appl.
         Rate  (AI un-
         less noted
         otherwise)
Max. Appl. Soil Max. tt Apps Max. Dose  [ (AI   Min.  Restr.
       Rate (AI Tex.  ® Max.  Rate unless noted
   unless noted Max.  /crop /year otherwise)/A]
     otherwise)  Dose  cycle       /crop    /year
                                 cycle
                                             Interv  Entry   Allowed
                                             (days)  Interv
                                                    [day(s)]
                                                                   Geographic Limitations
                                                                                                                                                 Disallowed
                                                 Limitations
                                                 Codes
MANURE (con't)
Feed through.,  When needed., Not on
label.

NONAGRICULTURAL UNCULTIVATED AREAS/SOILS

Mound treatment., When needed., Shaker
can.

PET LIVING/SLEEPING QUARTERS

Animal bedding/litter treatment., When
needed., Aerosol can.

Enclosed premise treatment., When
needed., By hand.

Enclosed premise treatment., When
needed., Hand held duster.

Indoor premise treatment., When needed.,
Aerosol can.

RECREATIONAL AREAS

Outdoor general surface spray., Not on
label.,  Knapsack sprayer.

Outdoor general surface spray., Not on
label.,  Power sprayer.

Outdoor general surface spray., When
needed., Knapsack sprayer.
Outdoor general surface spray., When
needed., Power sprayer.

Outdoor premise treatment., When needed.
Knapsack sprayer.
                                          WP/D
WP


WP/D

WP


WP
                                                    NA

                                                    NA
                               Use Group: OUTDOOR RESIDENTIAL  (con't)

                   .8333 Ib IK sq.ft    *  NS    NS          NS       NS

                               Use Group: INDOOR NON-FOOD

                    3.422E-07 Ib Ib    *  NS    NS          NS       NS
                            body wt

                               Use Group: TERRESTRIAL  NON-FOOD  CROP

                                 UC    *  NS    NS          NS       NS


                               Use Group: INDOOR RESIDENTIAL

                                 UC    *  NS    NS          NS       NS
                                 UC
                                         NS    NS
                                                           NS
                                 UC    *  NS
                               Use Group: TERRESTRIAL  NON-FOOD  CROP
      .996  Ib A   *  NS    NS


      .996  Ib A   *  NS    NS


         1  Ib A   *  NS    NS


.05  Ib IK sq.ft   *  NS    NS

         1  Ib A   *  NS    NS


     1.042  Ib A   *  NS    NS
                                 NS

                                 NS
NS

NS
NS

NS
NS

NS
CAE


CAE

CAE
                                                                                          83

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Report Run Date: 07/14/95  -  Time 09:57
                                                       APPENDIX A  -  CASE  0321,  [Tetrachlorvinphos]  Chemical 083701 [Tetrachlorvinphos]
                                                                                                                                                             LUIS 2.1  -  Page  22
SITE Application Type, Application Form(s)
Timing, Application Equipment —
Surface Type (Antimicrobial only) & Effica-
cy Influencing Factor (Antimicrobial only)

Min . Appl .
Rate (AI un-
less noted
otherwise)

Max. Appl. Soil Max. # Apps Max. Dose [ (AI
Rate (AI Tex. ® Max . Rate unless noted
unless noted Max. /crop /year otherwise) /A]
otherwise) Dose cycle /crop /year
cycle
Min . Restr . Geographic Limitations
Interv Entry Allowed Disallowed
(days) Interv
[day(s) ]

Use
Limitations
Codes


USES ELIGIBLE FOR REREGISTRATION

NON-FOOD/NON-FEED (con't)
RECREATIONAL AREAS  (con't)

Outdoor premise treatment., When needed., WP
Power sprayer.

REFUSE/SOLID WASTE SITES  (OUTDOOR)

Disposal treatment., When needed.,        WP
Knapsack sprayer.
                                          WP/D
Disposal treatment., When needed., Power  WP
sprayer.
                                                                        Use  Group:  TERRESTRIAL NON-FOOD CROP (con't)
                                                                  1.042  Ib A    *   NS
                                                                                        NS
                                                                                                   NS
                                                                                                           NS   NS
                                                                        Use  Group:  TERRESTRIAL NON-FOOD CROP

                                                              .8  Ib  IK sq.ft   *   NS     NS          NS      NS
                                                 NA        .8333  Ib  IK sq.ft    *   NS     NS

                                                 NA           .8  Ib  IK sq.ft    *   NS     NS
                                                                                                     NS

                                                                                                     NS
NS

NS
NS

NS
CAE


CAC,  CAG

CAE
  HEADER ABBREVIATIONS
  Min. Appl. Rate  (AI unless  : Minimum dose for a single application  to  a  single  site.   System calculated.   Microbial claims only.
  noted otherwise)
  Max. Appl. Rate  (AI unless  : Maximum dose for a single application  to  a  single  site.   System calculated.
  noted otherwise)
                              : Maximum dose for a single application  to  a  single  site  as related to soil texture (Herbicide claims only).
                              : Maximum number of Applications  at  Maximum Dosage Rate.   Example:  "4 applications per year" is expressed as "4/1 yr"; "4 applications per 3
                               years" is expressed as  "4/3 yr"
                              : Maximum dose applied to a site  over  a  single  crop  cycle or year.   System calculated.
Soil Tex. Max. Dose
Max. tt Apps @ Max. Rate
Max. Dose  [(AI unless
noted otherwise)/A]
Min. Interv (days)
Restr. Entry Interv  (days
                               Minimum Interval between Applications  (days)
                               Restricted Entry Interval  (days)
  SOIL TEXTURE FOR MAX APP. RATE
  *         Non-specific
  C         Coarse
  M         Medium
  F         Fine
  O         Others

  FORMULATION CODES
  D         DUST
  EC        EMULSIFIABLE CONCENTRATE
  FM?       FORM NOT IDENTIFIED
  G         GRANULAR
  IMPR      IMPREGNATED MATERIAL
  P/T       PELLETED/TABLETED
  PRL       PRESSURIZED LIQUID
  RTU       LIQUID-READY TO USE
  WP        WETTABLE POWDER
  WP/D      WETTABLE POWDER/DUST
  ABBREVIATIONS
  AN
  NA
  NS
  UC
          As Needed
          Not Applicable
          Not Specified  (on label)
          Unconverted due to lack of data  (on label), or with  one  of  following units:  bag,  bait,  bait block,  bait pack,  bait station, bait station(s), block, briquet,
          briquets, bursts, cake, can, canister, capsule,  cartridges,  coil,  collar,  container,  dispenser,  drop,  eartag,  grains, lure, pack, packet, packets, pad, part,
          parts, pellets, piece, pieces, pill, pumps, sec,  sec burst,  sheet,  spike,  stake,  stick,  strip,  tab,  tablet,  tablets,  tag, tape, towelette, tray, unit, --
                                                                                         84

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APPLICATION RATE
DCNC
No Calc
W
V
U
cwt
nnE-xx
    Dosage Can Not be Calculated
    No Calculation can be made
    PPM calculated by weight
    PPM Calculated by volume
    Unknown whether PPM is given by weight or by volume
    Hundred Weight
    nn times (10 power -xx); for instance,  "1.234E-04"
                                                              is equivalent to " . 0001234"
USE LIMITATIONS CODES
C93
CAA
CAC
CAD
CAE
CAG
S09
Do not apply directly to water.
Do not apply to any body of water.
Keep out of lakes, streams, and ponds.
Do not apply directly to water or wetlands.
Do not apply directly to water or wetlands  (swamps, bogs, marshes, and potholes).
Do not apply where runoff is likely to occur.
	 day(s) preslaughter interval.
  NUMBER IN PARENTHESES REPRESENTS THE NUMBER OF TIME UNITS  (HOURS, DAYS, ETC.) DESCRIBED IN THE LIMITATION.
                                                                                       85

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86

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                               GUIDE TO APPENDIX B
Appendix B contains listings of data requirements which support the reregistration for active
ingredients within the case Tetrachlorvinphos covered by this Reregistration Eligibility Decision
Document. It contains generic data requirements that apply to Tetrachlorvinphos in all products,
including data requirements for which a "typical formulation" is the test substance.

       The data table is organized in the following format:

       1.  Data Requirement (Column 1).  The data requirements are listed in the order in which
they appear in 40 CFR Part 158. the reference numbers accompanying each test refer to the test
protocols  set in the Pesticide Assessment Guidelines, which are  available  from the National
Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161  (703) 487-4650.

       2.  Use  Pattern (Column 2).   This column indicates the use patterns  for which the data
requirements apply. The following letter designations are used  for the given use patterns:

                           A      Terrestrial food
                           B      Terrestrial feed
                           C      Terrestrial non-food
                           D      Aquatic food
                           E      Aquatic non-food outdoor
                           F      Aquatic non-food industrial
                           G      Aquatic non-food residential
                           H      Greenhouse food
                           I      Greenhouse non-food
                           J      Forestry
                           K      Residential
                           L      Indoor food
                           M     Indoor non-food
                           N      Indoor medical
                           O      Indoor residential

       3.  Bibliographic citation (Column 3).  If the Agency has acceptable data in its files, this
column lists  the  identifying  number of each study.   This normally  is the Master  Record
Identification (MRID)  number, but  may be  a  "GS" number if no MRID number has been
assigned.  Refer to the Bibliography appendix for a complete citation of the study.
                                           87

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88

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                                                     APPENDIX  B
                 Data Supporting Guideline Requirements for the Reregistration of Tetrachlorvinphos
REQUIREMENT
USE PATTERN  CITATION(S)
PRODUCT CHEMISTRY
61-1         Chemical Identity
61-2A       Start. Mat. & Mnfg. Process.
61-2B       Formation of Impurities
62-1         Preliminary Analysis
62-2         Certification of limits
62-3         Analytical Method
63-2         Color
63-3         Physical State
63-4         Odor
63-5         Melting Point
63-6         Boiling Point
63-7         Density
63-8         Solubility
63-9         Vapor Pressure
63-10       Dissociation Constant
63-11       Octanol/Water Partition
63-12       pH
63-13       Stability
63-14       Oxidizing/Reducing Action
63-15       Flammability
63-16       Explodability
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
       All
41222501, 41222502, 43160601
41222501, 42013001
40491301, 41222501, 42013001
40924701, 41222502, 43160601, 43160602
41222502
41222502, 42013002, 42275201, 42679201, 43160601
41222503
41222503
41222503
41222503
Not Applicable
41222503
41222503
41222503
Not Applicable
41222503
41222503
41222503
Not Applicable
Not Applicable
Not Applicable
                                                                  89

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Data Supporting Guideline Requirements for the Reregistration of Tetrachlorvinphos
REQUIREMENT
63-17
63-18
63-19
63-20
Storage stability
Viscosity
Miscibility
Corrosion characteristics
USE PATTERN CITATION(S)
All
All
All
All
41222503, 42013003, 42407801
Not Applicable
Not Applicable
41222503, 42013003
ECOLOGICAL EFFECTS
71-1A
71-2A
71-2B
72-1A
72-1D
72-2A
72-3A
72-3B
72-3C
141-1
141-2
Acute Avian Oral -Quail/Duck
Avian Dietary - Quail
Avian Dietary - Duck
Fish Toxicity Bluegill
Fish Toxicity Rainbow Trout- TEP
Invertebrate Toxicity
Estuarine/Marine Toxicity - Fish
Estuarine/Marine Toxicity - Mollusk
Estuarine/Marine Toxicity - Shrimp
Honey Bee Acute Contact
Honey Bee Residue on Foliage
B, C, K
B, C, K
B, C, K
B, C, K

B, C, K





00160000
00022923
00022923
40098001
40098001
41257101
40228401
40228401
40228401
00036935
05000837
TOXICOLOGY
81-1
81-2
81-3
81-4
81-5
81-6
81-7
Acute Oral Toxicity - Rat
Acute Dermal Toxicity - Rabbit/Rat
Acute Inhalation Toxicity - Rat
Primary Eye Irritation - Rabbit
Primary Dermal Irritation - Rabbit
Dermal Sensitization - Guinea Pig
Acute Delayed Neurotoxicity - Hen
All
All
All
All
All
All

41222504
41222505
00138933
41222506
41222507
41377902, 42981001
00079791, 41905901
                                      90

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                 Data Supporting Guideline Requirements for the Reregistration of Tetrachlorvinphos
REQUIREMENT
USE PATTERN  CITATION(S)
81-8        Acute Neurotoxity - Rat
82-1        90-Day Feeding - Rodent
82-3        90-Day Dermal - Rodent
83-1A      Chronic Feeding Toxicity - Rodent
83-1B      Chronic Feeding Toxicity - Non-Rodent
83-2A      Oncogenicity - Rat
83-2B      Oncogenicity - Mouse
83-3A      Developmental Toxicity - Rat
83-3B      Developmental Toxicity - Rabbit
83-4        2-Generation Reproduction - Rat
84-2A      Gene Mutation (Ames Test)
84-2B      Structural Chromosomal Aberration
84-4        Other Genotoxic Effects
85-1        General Metabolism
85-2        Dermal Penetration
86-1        Domestic Animal Safety
OCCUPATIONAL/RESIDENTIAL EXPOSURE
133-3      Dermal Passive Dosimetry Exposure
133-4      Inhalation Passive Dosimetry Exposure
ENVIRONMENTAL FATE
160-5      Chemical Identity
161-1      Hydrolysis
162-1      Aerobic Soil Metabolism
163-1      Le aching/Ad sorption/De sorption
                  42912501
      B, L        43371201
                  41342001
      B, L        00112525,42980901
      B, L        00077819, 42679401
      B, L        00117443,42980901
      B, L        00117443,00126039
      B, L        40152701, 42520101
      B, L        00127831
      B, L        00077802, 42054301
  B, C, K, L, M     41222508
  B, C, K, L, M     41312901
  B, C, K, L, M     42156401
      B,L        41988401
                  42111501
                  40436601, 41810101, 41810102

                  42622301
                  42622301

       All         41222501, 41222502, 43160601
       All         41929101
     B, C, K       00077821, 42082401
     B, C, K       41681301
                                                                  91

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                 Data Supporting Guideline Requirements for the Reregistration of Tetrachlorvinphos
REQUIREMENT
                                                   USE PATTERN   CITATION(S)
164-A-SS     Dissipation of Residues in Excrement

RESIDUE CHEMISTRY
171-4B
171-4
C&D
171-4E
171-4J
Nature of Residue - Livestock
Residue Analytical Method - Plants/Animals
Storage Stability
Magnitude of Residues - Meat/Milk/Poultry/Egg
B



B


B


B
                                                                     42848501
00116020, 00117354, 00120147, 00120204, 42828801, 42828802,
42828803

00038458, 00077812, 00077814, 00077816, 00115939, 00116020,
00116553, 00117329, 00117340, 00117351, 00117354, 00117389,
00118265, 00120147, 00120200, 00120205, 00120206, 00120229,
00130705, 00133913, 05004211

00117329, 00117354, 00117361, 00117389, 00133913
00038458,
00117354,
00120227,
00084189,
00117389,
05006630
00115939, 00117298, 00117339, 00117340,
00118265, 00120200, 00120206, 00120225,
                                                                  92

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                               GUIDE TO APPENDIX C

1.     CONTENTS OF BIBLIOGRAPHY.  This bibliography contains citations of all studies
       considered relevant by EPA in arriving at the positions and conclusions stated elsewhere
       in  the Reregistration Eligibility  Document.   Primary  sources  for  studies  in  this
       bibliography have been the body of data submitted to EPA and its predecessor agencies
       in  support of past regulatory decisions.  Selections from other sources including the
       published literature,  in those instances where they have been considered, are included.

2.     UNITS OF ENTRY.  The unit of entry in this bibliography is called a "study".  In the
       case  of published materials,  this corresponds closely  to an  article.  In the case of
       unpublished materials submitted to the Agency,  the  Agency has sought to identify
       documents at a level parallel to the published article from  within the typically larger
       volumes in which they were submitted.  The  resulting "studies" generally have a  distinct
       title (or at least a single  subject), can stand alone  for purposes of review and can be
       described with a conventional bibliographic citation. The Agency has also attempted to
       unite basic documents and commentaries upon them, treating them as a single study.

3.     IDENTIFICATION   OF  ENTRIES.   The  entries in this bibliography are  sorted
       numerically by Master Record Identifier, or "MRID number". This number is unique to
       the citation, and should be used whenever a specific reference is required.  It is not related
       to the six-digit "Accession Number" which has been used to identify volumes of submitted
       studies (see paragraph 4(d)(4) below for further explanation).  In a few cases, entries
       added to the bibliography late  in the  review may be preceded by a  nine character
       temporary identifier. These  entries  are listed after all MRID entries.  This temporary
       identifying number is also to be used whenever specific reference is needed.

4.     FORM OF ENTRY.  In addition to the Master Record Identifier (MRID),  each entry
       consists of a  citation containing standard elements followed, in the case of material
       submitted to EPA, by a  description of the  earliest known submission.   Bibliographic
       conventions used reflect the standard of the American National Standards Institute (ANSI),
       expanded to provide for certain special needs.

       a     Author.  Whenever the author could confidently be  identified, the Agency has
             chosen to show a personal author.  When no individual was identified, the Agency
             has shown an identifiable laboratory or testing facility as the author.  When no
             author or laboratory could be identified, the Agency has shown the first submitter
             as the author.

       b.     Document date.  The date of the study is taken directly from the document.  When
             the date is  followed by a question mark, the bibliographer has deduced the date
             from the evidence contained in the document. When the date appears as (19??),
             the Agency was unable to determine or estimate the date of the document.
                                          93

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c.      Title.  In some cases, it has been necessary for the Agency bibliographers to create
       or enhance a document title. Any such editorial insertions are contained between
       square brackets.

d.      Trailing parentheses.  For studies submitted to the Agency in the past, the trailing
       parentheses include (in addition to any self-explanatory text) the following elements
       describing the earliest known submission:

       (1)     Submission date.   The date of the  earliest known submission  appears
              immediately following the word  "received."

       (2)     Administrative number.  The next element immediately following the word
              "under"  is the registration number,  experimental use permit number,
              petition number, or other administrative number associated with the earliest
              known submission.

       (3)     Submitter.  The third  element  is the submitter.  When authorship is
              defaulted to the submitter, this element is omitted.

       (4)     Volume  Identification (Accession Numbers).  The final  element in the
              trailing parentheses identifies the EPA accession number of the volume in
              which the original submission of the study appears. The six-digit accession
              number  follows the symbol "CDL," which stands for "Company Data
              Library."  This accession  number is in turn followed by an alphabetic
              suffix which shows the relative position of the study within the volume.
                                    94

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                                      BIBLIOGRAPHY
MRID
CITATION
00022923       Hill, E.F.; Heath, R.G.; Spann, J.W.; et al. (1975) Lethal Dietary Toxicities of Environmental
               Pollutants to Birds: Special Scientific Report-Wildlife No.  191. (U.S. Dept. of the Interior, Fish
               and Wildlife Service, Patuxent Wildlife Research Center; unpublished report)

00036935       Atkins,  E.L.;  Greywood,  E.A.;  Macdonald, R.L. (1975) Toxicity of Pesticides and Other
               Agricultural Chemicals to Honey Bees: Laboratory Studies. By University of California, Dept. of
               Entomology. ?: UC, Cooperative Extension. (Leaflet 2287; published study.)

00038458       Schultz, D.R.; Rawn, D.T.; DeKay, D.E. (1973) Residues of SD 8447 in Biopsy  Fat Samples
               from Pigs Fed 400 and 800 PPM Stirofos in the Ration: TIR-26-005-73.  (Unpublished study
               received Jun 27, 1980 under OH5269; prepared by Shell Development Co., submitted by Diamond
               Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:242780-G)

00077802       Eisenlord, G.; Loquvam, G.S.; Nemenzo, J.; et al. (1966) Results of Reproduction Study of Rats
               Fed Diets Containing SD 8447 Insecticide over Three Generations: Report No. 28. (Unpublished
               study received May 23,  1967 under 8G0665; prepared by Hine Laboratories, Inc., submitted by
               Shell Chemical Co., Washington, D.C.; CDL:091166-M)

00077812       Shell Development Company (1966) Residue Determination  of SD 8447 and Its Low-melting
               Isomer SD 13462 in Agricultural Crops:  GLC Electron Capture Method.  Analytical method
               MMS-71/66  dated Jan 21,  1966.  (Unpublished study received May 23,  1967 under 8G0665;
               CDL:091166-AE)

00077814       Shell Development Company (1966) Residue Determination  of SD 8447 and Its Low-melting
               Isomer SD 13462 in Agricultural Crops: GLC Phosphorus Detector Method. Analytical method
               MMS-80/66  dated  Dec  1966.  (Unpublished study  received May 23, 1967  under 8G0665;
               CDL:091166-AG)

00077816       Shell Development Company (1967) Residue Determination of Acid Hydrolizable  Conjugate
               Metabolites from SD 8447 Treated Crops: GLC Electron-capture method.  Analytical method
               MMS-85/67 dated  Apr  1967.  (Unpublished study  received May 23, 1967  under 8G0665;
               CDL:091166-AI)

00077819       Doyle, R.L.; Teske, R.H.; Elsea, J.R. (1968) Two-year Dietary Administration of SD 8447 to
               Dogs: P-99A.  (Unpublished study received Aug 17, 1968 under 9F0739; prepared by Hill Top
               Research, Inc., submitted by Shell Chemical Co., Washington, D.C.; CDL:  091273-A)

00077821       Beynon, K.I.; Wright,  A.N. (1968) The Breakdown of the Insecticide Gardona (SD 8447,
               2-Chloro-l-(2',4',5'-trichlorophenyl)vinyl Dimethyl Phosphate) on Plants and in Soils: WP-193-68.
               (Unpublished study received Aug 17,  1968 under  9F0739; submitted by Shell Chemical Co.,
               Washington, D.C.;  CDL:091273-F)
                                                95

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                                      BIBLIOGRAPHY
MRID
                       CITATION
00079791       El-sebae,  A.H.;   Soliman,  S.A.;  Elamayem,  M.A.;  et  al.  (1977)  Neurotoxicity  of
               organophosphorus insecticides leptophos and EPN. Journal of Environmental Science and Health
               B 12(4):269-288. (Also~In~unpublished submission received on unknown date under 352-338;
               submitted by E.I. du Pont de Nemours & Co., Wilmington, Del.; CDL:236741-G)

00084189       Ivey, M.C.; DeVaney, J.A.; Me, G.W. (1981) Residues of Stirofos (Rabon-(R)ae) in Eggs of
               Laying Hens Treated for Northern Fowl Mite Control by Dipping.  (U.S.  Dept. of Agriculture,
               Science and  Education  Administration, Agricultural Research,  Veterinary  Toxicology and
               Entomology Research Laboratory; unpublished study; CDL:245949-A)

00112525       Walker, A.; Hunter, C. (1967) The Oral Toxicity of the Halophenyl Vinyl Phosphate Insecticide
               Gardona (SD 8447):  Two  Year Oral Experiment  in Rats:  Research  Report  R(T)-9-67.
               (Unpublished study  received Aug 17, 1968 under 9F0739; prepared by Shell Research Ltd., Eng.,
               submitted by Shell Chemical Co., Washington, DC; CDL:091274-O)

00115939       Shell Chemical Co.  (1972) Residue Data in Reply to EPA's July 10,  1972 Letter of Special Review
               for Ciovap EC Insecticide. (Compilation; unpublished study received Sep 20, 1972 under 201-244;
               CDL:000948-A)

00116020       Shell Chemical Co. (1970) Residue Data Developed from the Use  of Dairy Cattle: CRabon|.
               (Compilation; unpublished study received Jan 19,  1970 under 1F1090; CDL:090850-B)

00116553       Shell Chemical Co.  (1971) The Results of Tests on the Amount of Residues  Remaining, Including
               a Description of the Analytical Methods Used: CGardona| .  (Compilation; unpublished  study
               received Oct 12, 1972 under 2F1281; CDL:091818-B)

00117298       Miller, R.; Gordon, C. (19??) Effect of feeding  Rabon to dairy  cows over extended periods.
               Journal of Economic Entomology 66(1):  135-138.  (Also In unpublished submission received Oct
               17, 1973 under 201-359; submitted by Shell Chemical Co., Washington, DC; CDL:050006-G)

00117329       Shell Chemical Co. (1969) CGardona:  Residues in Milk and Other Subjects | .  (Compilation;
               unpublished study received on unknown date under 9F0805; CDL:093114-C)

00117339       Shell Chemical Co. (1969) Residue Data Developed from  the Use of Rabon on Livestock.
               (Compilation; unpublished study received Dec 13, 1970 under 1F1121; CDL:093431-C)

00117340       Shell Chemical Co.  (1969) Residue Data for Rabon Metabolites in Chicken Tissues and Eggs from
               California.  (Compilation; unpublished study received Dec 1,  1969 under 9F0835; CDL:093538-A)

00117351       Shell Chemical Co. (1971) Analytical Methods for the Determination of the Pesticide Chemical:
               CGardona | .   (Compilation;  unpublished study received Aug  6,  1971  under 2F1187;
               CDL:093510-C)
00117354
Shell Chemical Co. (1973) Residue Data: CSD-84471
Oct 17, 1973 under 201-359; CDL: 101173-A)
(Compilation; unpublished study received
                                                96

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                                      BIBLIOGRAPHY
MRID
CITATION
00117361       Shell Chemical Co.  (1975)  Rabon Oral Larvicide Self-fed Supplement:  Label Application.
               (Compilation; unpublished study received Jul 22, 1975 under 201-392; CDL:220992-A)

00117389       Shell Chemical Co. (1978) CRabon: Residues in Tissue, Milk, and Fat of Cattle | .  (Compilation;
               unpublished study received Mar 30, 1979 under 201-407; CDL:237924-A)

00117443       U.S. National Institutes of Health (1978) Bioassay of tetrachlorvinphos for possible carcinogenicity.
               By National Cancer Institute, Div. of Cancer Cause and Prevention, Carcinogenesis Program,
               Carcinogen Bioassay and Program Resources Branch.  Bethesda, MD: USNIH.  (NCI-CG-TR-33;
               CAS No. 961-11-5; DHEW publication no. (NIH)78-833; published study; CDL:238926-A)

00118265       Shell Oil Co. (1975) Residue Data in Support of the Use of Rabon Insecticide Cattle Ear Tags.
               (Compilation; unpublished study received Apr 12, 1979 under TN 79/1; CDL:238024-B)

00120147       Shell Chemical  Co.  (1967)  CDetermination of  Gardona  Residues  in  Various Products |.
               (Compilation; unpublished study received Jun 12, 1968 under 9F0739; CDL:091275-A)

00120200       Shell Chemical Co. (1968) The Residue Data Developed from Test Plots Including a Description
               of the Analytical Methods Used:  CGardona Insecticide |. (Compilation; unpublished study received
               Apr 27, 1969 under 9F0804;  CDL:091388-B)

00120205       Shell Chemical Co. (1968) The Results of Tests on the Amount of Residues Remaining, Including
               a Description  of  the Analytical Methods Used: CRabon |.   (Compilation; unpublished study
               received Apr 26, 1969 under  9F0805; CDL:091389-A)

00120206       Shell Chemical Co. (1969) The Results of Tests on the Amount of Residues Remaining, Including
               a Description  of  the Analytical Methods Used: CRabon |.   (Compilation; unpublished study
               received Apr 26, 1969 under  9F0805; CDL:091390-A)

00120224       Sherman,  M. (1964) Acute,  Subacute and Chronic Toxicology Data on Rabon Insecticide to
               Chickens.  (Unpublished study received Oct 4, 1969 under 9F0835; prepared by Univ. of Hawaii,
               submitted by Shell Chemical Co., Washington, DC; CDL:091439-B)

00120225       Yadava, C. (1969) An Investigation of the Toxicology and Residues of Rabon in Poultry. Doctoral
               dissertation, Univ. of Massachusetts.  (Unpublished study received  Oct 4, 1969 under 9F0835;
               submitted by Shell Chemical Co., Washington, DC; CDL:091439-C)

00120227       Shell Chemical Co. (1969) The  Results of the Amount of Residues Remaining,  Including a
               Description of the Analytical  Method:  CRabon | . (Compilation; unpublished study received Oct
               4, 1969 under 9F0835; CDL:091439-G)

00120229       Shell Chemical Co. (1969) Rabon Insecticide on Poultry.  (Unpublished study received Oct 5, 1969
               under 9F0835; CDL:091440-B)
                                                 97

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                                      BIBLIOGRAPHY
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00126039       Hazleton Laboratories America, Inc. (1980) 103-week Chronic Feeding Study in Mice: SD-8447
                and Original SD-8447.  Final rept. (Unpublished study received Jul 31,  1980 under unknown
                admin, no.; submitted by Shell Chemical Co., Washington, DC; CDL: 242976-A; 242977)

00127831       Laveglia, J.; Killeen,  J.; Ignatoski, J. (1982)  A Teratology  Study in Rabbits with DS-36779:
                Document No. 572-5TX-82-0007-003.  (Unpublished study received Apr 13, 1983 under unknown
                admin,  no.;  submitted by  Diamond  Shamrock Agricultural  Chemicals,  Cleveland,  OH;
                CDL:249988-A)

00130705       Ralston Purina Co. (1969) Residue Data Developed from the Use of Dairy Cattle. (Compilation;
                unpublished study received Jun 17, 1983 under 602-301; CDL:251028-A)

00133913       Shell Chemical Co. (1973)  Summary-Residues: CToxicity  of SD 8447 in Cattle  and  Other
                Mammals |.   (Compilation;  unpublished study  received  Dec  20,  1974 under  4H5047;
                CDL:223244-B)

00138933       Coate, W.; Zoetis, T.;  Hardy, R. (1983) Acute Inhalation Toxicity Study in Rats: Ralston Purina
                Residual Livestock Insecticide: Project No. 2200-105.  Final rept. (Unpublished study received
                Jan 31, 1984 under 602-301; prepared by Hazleton Laboratories America, Inc., submitted by
                Ralston Purina Co., St. Louis, MO; CDL:252343-C)

00160000       Hudson, R.; Tucker,  R.; Haegele, M. (1984) Handbook of toxicity of pesticides to wildlife:
                Second edition. US Fish and Wildlife Service:  Resource Publication 153.  91 p.

05000837       Johansen, C.A. (1972) Toxicity of field-weathered insecticide residues to four kinds of bees.
                Environmental Entomology l(3):393-394.

05004211       Bowman, M.C.;  Beroza, M. (1967) Temperature-programmed gas chromatography of 20
                phosphorus-containing  insecticides on 4 different columns and its application to the analysis of milk
                and corn silage. Journal of the Association of Official Analytical Chemists 50(6): 1228-1236.

05006630       Oehler, D.D.; Eschle, J.L.;  Miller, J.A.;  Claborn, H.V.; Ivey,  M.C. (1969) Residues in milk
                resulting from ultra-low-volume sprays of malathion, methoxychlor, coumaphos,  ronnel, or
                Gardona for control of the horn fly. Journal of Economic Entomology 62(6): 1481-1483.

40098001       Mayer, F.; Ellersieck, M. (1986)  Manual of Acute Toxicity: Intepretation and Data Base 410
                Chemicals and 66 Species of Fresh-Water Animals.  US  Fish  & Wildlife  Service; Resource
                Publication (160): 579 p.

40152701       Ford, W.; Killeen, J. (1987) A Teratology Study in Rats with  Technical Rabon: Project ID:
                1019-003;  85-0074.  Unpublished study prepared by Ricerca, Inc.  in cooperation with Argus
                Research Laboratories, Inc. and Test Substance Analysic Laboratory.  298 p.
                                                 98

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                                      BIBLIOGRAPHY
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40228401        Mayer, F.;  Ellersieck, M. (1986) Manual of Acute Toxicity: Intepretation and Data Base 410
                Chemicals and 66 Species of Fresh-Water Animals.  US Fish & Wildlife Service; Resource
                Publication (160): 579 p.

40491301        Sheeran,  P.  (1987) Rabon Product Chemistry:  Du Pont Report #84477  PC-1.  Unpublished
                compilation  prepared by E.I. du Pont de Nemours & Co.  68 p.

40924701        Keeler,   D.   (1988)   Determination   of   2,3,7,8-Tertrachloro-p-dibenzodioxin    and
                2,3,7,8-Tetrachlorodibenzofuran in Technical Tetrachlorvinphos: Laboratory Project ID: Y2033.A.
                Unpublished study prepared by Triangle Laboratories, Inc.  177 p.

41222501        Silveira, E.  (1989) Technical Rabon Insecticide: Product Identity and Composition:  Project ID
                Y2033.C. Unpublished study prepared Du Pont de Nemours and Co.  97 p.

41222502        Silveira, E. (1989) Technical Rabon Insecticide: Analysis and  Certification of Product Ingredients:
                Project ID Y2033.D.  Unpublished study prepared by Du Pont de Nemours and Co.  40 p.

41222503        Silveira, E.  (1989) Technical Rabon Insecticide:  Physical and Chemical Characteristics: Project
                ID Y2033.B.  Unpublished study prepared by Du Pont de Nemours and Co.  65 p.

41222504        Naas, D. (1989) Acute Oral Toxicity (LD50) Study in Albino  Rats with Rabon Technical: Project
                ID WIL-149001.  Unpublished  study prepared by WIL Research Laboratories, Inc. 69 p.

41222505        Naas, D.  (1989) Acute Dermal Toxicity (LD50) Study in Albino Rabbits with Rabon  Technical:
                Project ID WIL-149002. Unpublished study prepared by WIL Research Laboratories,  Inc.  25 p.

41222506        Naas, D. (1989) Primary Eye Irritation Study in Albino Rabbits with Rabon Technical:  Project ID
                WIL-149004. Unpublished study prepared by WIL Research Laboratories, Inc.  24 p.

41222507        Naas, D. (1989) Primary Dermal Irritation Study in Albino Rabbits with Rabon Technical: Project
                ID WIL-149003.  Unpublished  study prepared by WIL Research Laboratories, Inc. 21 p.

41222508        Lawlor, T.;  Valentine, D. (1989) Mutagenicity Test On Tetrachlorvinphos (TCVP); Rabon in the
                Ames  Salmonella?microsome  Reverse  Mutation Assay:  HLA  Study  No.  10913-0-401R.
                Unpublished study prepared by Hazleton Laboratories America, Inc.  35 p.

41257101        Forbis, A.  (1989)  Acute Toxicity  of Rabon to Daphnia  magna: Final  Report No. 38116.
                Unpublished study prepared by Analytical BioChemistry Laboratories, Inc.   176 p.

41312901        Murli, H. (1989) Mutagenicity Test on Tetrachlorvinphos (TCVP) in an in vitro Cytogenetic Assay
                Measuring Chromosomal Aberration Frequencies in Chinese Hamster Ovary (CHO) Cells:  Lab
                Project Number: 10913/0/437.  Unpublished study prepared by  Hazleton Laboratories America,
                Inc.  31 p.
                                                 99

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                                      BIBLIOGRAPHY
MRID
CITATION
41342001       Naas, D. (1989) 21-Day Dermal Study in Rats with Rabon Technical: Final Report: Lab Project
               Number WIL-149007.  Unpublished study prepared by WIL Research Laboratories, Inc. 277 p.

41377902       Naas, D. (1989) Skin Sensitization Study in Albino Guinea Pigs with Rabon Technical: Lab Project
               Number: WIL-149005. Unpublished study prepared by Wil Research Laboratories, Inc. 48 p.

41681301       Blumhorst, M. (1990) Adsorption/Desorption Studies-Batch Equilibrum for Rabon: Lab Project
               Number: 149-001.  Unpublished study prepared by EPL Bio-Analytical Services, Inc.  119 p.

41810101       Sharp, M. (1990) Domestic Animal Safety: Cholinesterase Test-Cats: Lab Project Number: 1077.
               Unpublished study prepared by Sharp Veterinary Research. 20 p.

41810102       Sharp, M. (1990) Domestic Animal Safety: Cholinesterase Test-Dogs: Lab Project Number: 1073.
               Unpublished study prepared by Sharp Veterinary Research. 19 p.

41905901       Naas, D. (1990) Acute Delayed Neurotoxicity Study in Hens with Rabon Technical: Lab Project
               Number: WIL-149006.  Unpublished study prepared by WIL Research Laboratories, Inc. 250 p.

41929101       Blumhorst, M. (1991) Aqueous Hydrolysis of Rabon: Lab Project Number: 149-003.  Unpublished
               study prepared by EPL Bio-Analytical Services, Inc.  88 p.

41988401       Hawkin, D.; Mayo, B.; Pollard, A.; et al. (1991) Rat Metabolism of Orally Administered: Ccarbon
               14|Tetrachlorvinphos:  Lab Project  Number:  207-901645.   Unpublished study  prepared by
               Huntingdon Research Centre Ltd. 76 p.

42013001       Silveira, E. (1991) Technical Rabon Insecticide: Product Identity and Composition: Lab Project
               Number: Y2033.C. Unpublished study prepared by E. I. du Pont de Nemours and  Co.  20 p.

42013002       Silveira, E. (1991) Technical Rabon Insecticide: Analysis and Certification of Product Ingredients:
               Lab Project Number: Y2033.D. Unpublished study prepared by E.I. du Pont de Nemours and Co.
               10 p.

42013003       Silveira,  E. (1991)  Technical Rabon Insecticide: Physical and  Chemical Properties: Lab Project
               Number: Y2033.B.  Unpublished study prepared by E.I. du Pont de Nemours and  Co.  lip.

42054301       Barton, S.  (1991) Tetrachlorvinphos: Two Generation Reproduction Study in Rats: Lab Project
               Number: 438712. Unpublished study prepared by  Inveresk Research International. 229 p.

42082401       Blumhorst, M. (1991) Aerobic Soil Metabolism Study of Rabon: Lab Project Number:  149-002.
               Unpublished study prepared by EPL BioAnalytical Services, Inc.  190 p.

42111501       Hawkins, D.; Mayo,  B.;  Pollard,  A.; et al.  (1991)  The  Dermal  Absorption  of Carbon
               14-Tetrachlorvinphos in the Rat: Lab Project Number: 208/91102. Unpublished study  prepared
               by Huntingdon Research Centre Ltd. 85 p.
                                                100

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                                      BIBLIOGRAPHY
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CITATION
42156401       McKeon,  M. (1992) Mutagenicity Test on Tetrachlorvinphos in the Rat Primary Hepatocyte
               Unscheduled DNA  Synthesis Assay:  Final  Report:  Lab  Project  Number:   10913-1-447.
               Unpublished study prepared by Hazleton Washington, Inc. 28 p.

42275201       Silveira, E. (1992) Technical Rabon Insecticide: Analysis and Certification of Product Ingredients:
               Lab Project Number: Y2033.D. Unpublished study prepared by E.I. du Pont de Nemours and
               Co., Inc.  6 p.

42407801       Silveira,   E.  (1992)  Technical Rabon  Insecticide:  Physical and  Chemical Characteristics:
               CSupplement No. 21 : Lab Project Number: Y2033. B. Unpublished study prepared by E. I. Du
               Pont de Nemours & Co. 9 p.

42520101       Hoberman, A. (1992) A Teratology Study in Rats with T-142-4: An Amendment: Lab Project
               Number: 1019-003.  Unpublished study prepared by Argus Research Laboratories, Inc.  88 p.

42622301       Meikle, S.; Baugher, D. (1992) Monitoring Exposure of Mixer/Loaders and Applicators Treating
               Agricultural Premises with Tetrachlorvinphos (Rabon 50WP Insecticide) in Handheld Wand-type
               Sprayers: Lab Project Number: 31189: 562: 62-RAB/92099. Unpublished study prepared by Orius
               Associates, Inc. and PTRL East, Inc. 207 p.

42679201       Silveira, E. (1993) Technical Rabon Insecticide Analysis and Certification of Product Ingredients:
               Supplement No. 3: Lab Project Number: Y2033.D.  Unpublished study prepared by E.I. du Pont
               de Nemours and Co.  9 p.

42679401       Tompkins,  E.  (1993)  One  Year Oral (Capsule) Toxicity  Study in  Dogs with Rabon
               (Tetrachlorvinphos):  Final Report: Lab  Project Number:  WIL-149009.  Unpublished study
               prepared by WIL Research Labs., Inc.  1079 p.

42828801       Krautter,  G. (1993)  The Metabolism of (carbon  14)Tetrachlorvinphos  in the Lactating Goat
               Following  Oral Administration for 3  Consecutive  Days:  Lab  Project  Number: 542:  1508.
               Unpublished study prepared by PTRL East, Inc. 131 p.

42828802       Krautter, G. (1993) The Metabolism of (carbon 14)Tetrachlorvinphos in Laying Hens Following
               Dermal Application: Lab Project Number:  540: 1532.  Unpublished study prepared by PTRL East,
               Inc. 166 p.

42828803       Krautter,  G. (1993)  The Metabolism of (carbon  14)Tetrachlorvinphos  in the Lactating Goat
               Following Dermal Application: Lab Project Number: 541:  1531.  Unpublished study prepared by
               PTRL  East, Inc. 127 p.

42848501       Krautter, G. (1993) The Dissipation of (carbon 14)Tetrachlorvinphos and Its Metabolites in Manure
               from a Beef Cow Following Oral Administration for 14 Consecutive Days: Lab Project Number:
               710: 1520. Unpublished study prepared by PTRL East, Inc.  101 p.
                                                101

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42912501        Lamb,  I. (1993) An Acute  Neurotoxicity Study of Rabon in Rats:  Lab  Project Number:
                WIL-149018.  Unpublished study prepared by Wil Research Labs., Inc.  1050 p.

42980901        Mulhern, M.; Robb, D.; Perry, C.; et al. (1993) Tetrachlorvinphos: 104 Week Dietary Combined
                Chronic Toxicity/Carcinogenicity Study in Rats: Lab Project Number:  7929.  Unpublished study
                prepared by Inveresk Research International.  1135 p.

42981001        Morris, T. (1993) Delayed Contact Hypersensitivity Study in Guinea Pigs with Technical RABON
                Insecticide (Buehler Technique): Lab Project Number: 93-8055-21 (A):  93-8055-21. Unpublished
                study prepared by Hill Top Biolabs, Inc.  86 p.

43160601        McKeown,  K. (1994) Analysis of Gardona Samples from an Alternate Manufacturing Source:
                Rabon:  Lab  Project Number: 1362/56: TM#0124-02. Unpublished study prepared by The Hartz
                Mountain Corp.   32 p.

43160602        McKeown, K. (1994) Du Pont Analysis of Alternate Source Rabon Samples: Lab Project Number:
                9859: 9878. Unpublished  study prepared by E.I. du Pont de Nemours & Co., Inc., Mobile
                Manufacturing Center.  9 p.

43371201        Perry,  C.;  Mulhern, M.; Henderson, W. et al.  (1990) Tetrachlorvinphos:  13  Week Dietary
                Toxicity Study in Rats: Lab Project Number: 7258: IRI/438141. Unpublished study prepared by
                Inveresk Research International.  194 p.
                                                 102

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         \
         I            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
         ?                            WASHINGTON, D.C. 20460
                                                                           OFFICE OF
                                                                      PREVENTION, PESTICIDES
                                                                      AND TOXIC SUBSTANCES
                              DATA CALL-IN NOTICE
CERTIFIED MAIL
Dear Sir or Madam:

       This Notice requires you and other registrants of pesticide products containing the
active ingredient identified in Attachment 1 of this Notice, the Data Call-In Chemical Status
Sheet, to submit certain product specific data as noted herein to the U.S. Environmental
Protection Agency (EPA, the Agency).  These data are  necessary to maintain the continued
registration of your product(s) containing this active ingredient.  Within 90 days after you
receive this Notice you must respond as set forth in Section III below.  Your response must
state:

       1.     How you will comply with the requirements set forth in this Notice and its
             Attachments 1 through 6; or

       2.     Why you believe you are exempt from the requirements listed in this Notice and
             in Attachment 3,  Requirements Status and Registrant's Response Form, (see
             section III-B); or

       3.     Why you believe EPA should not require your submission  of product specific
             data in the manner specified by this Notice (see section III-D).

       If you do not respond to this Notice,  or if you do not satisfy EPA that you will comply
with its  requirements or should be exempt or excused from doing so, then the registration of
your product(s) subject to this Notice will be subject to  suspension. We have provided a list
of all of your products subject to this Notice in Attachment 2, Data Call-In Response Form, as
well as a list of all registrants who were sent this Notice (Attachment 6).
                                          103

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       The authority for this Notice is section 3(c)(2)(B) of the Federal Insecticide, Fungicide
and Rodenticide Act as amended (FIFRA), 7 U.S.C. section 136a(c)(2)(B).  Collection of this
information is authorized under the Paperwork Reduction Act by OMB Approval No. 2070-
0107 and 2070-0057 (expiration date 03-31-96).

       This Notice is divided into six sections and six Attachments.  The Notice itself contains
information and instructions applicable to all Data Call-in Notices. The Attachments contain
specific chemical information and instructions. The six sections of the Notice are:

       Section I      - Why You Are Receiving This Notice
       Section II     - Data Required By This Notice
       Section III    - Compliance With Requirements Of This Notice
       Section IV    - Consequences Of Failure To Comply With This Notice
       Section V     - Registrants' Obligation To Report Possible Unreasonable
                     Adverse Effects
       Section VI    - Inquiries And Responses To This Notice

The Attachments to this Notice are:

       1  -   Data Call-In Chemical Status Sheet
       2  -   Product-Specific Data  Call-In Response  Form
       3  -   Requirements Status and Registrant's Response Form
       4  -   EPA Batching of End-Use Products for Meeting Acute Toxicology Data
             Requirements for Reregistration
       5  -   List of Registrants Receiving This Notice
       6  -   Cost Share and Data Compensation Forms

SECTION I.  WHY YOU ARE RECEIVING THIS NOTICE

       The Agency has reviewed existing data for this  active ingredient and reevaluated the
data needed to support continued registration of the subject active ingredient.  The  Agency has
concluded that the only additional data necessary are product specific data. No additional
generic data requirements are being imposed.  You have been sent this Notice because you
have product(s) containing the subject active ingredient.

SECTION II.  DATA REQUIRED BY THIS  NOTICE

II-A.   DATA REQUIRED

       The product specific data required by this  Notice are specified in Attachment 3,
Requirements Status and Registrant's Response Form.  Depending on the  results of the studies
required in this Notice, additional testing may be  required.

II-B.   SCHEDULE FOR SUBMISSION OF  DATA

       You are required to submit the data or otherwise satisfy the data requirements specified
in Attachment 3, Requirements Status and Registrant's Response Form, within the time frames
provided.

                                          104

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II-C.   TESTING PROTOCOL

       All studies required under this Notice must be conducted in accordance with test
standards outlined in the Pesticide Assessment Guidelines for those studies for which
guidelines have been established.

       These EPA Guidelines are available from the National Technical Information Service
(NTIS), Attn: Order Desk, 5285 Port Royal Road, Springfield, Va 22161 (tel: 703-487-4650).

       Protocols approved by the Organization for Economic Cooperation and Development
(OECD) are also acceptable if the OECD-recommended test standards conform to those
specified in the Pesticide Data Requirements regulation (40 CFR § 158.70).  When using the
OECD protocols, they should be modified as appropriate so that the data generated by the
study will satisfy the requirements of 40 CFR § 158. Normally,  the Agency will not extend
deadlines for complying with data requirements when the studies were not conducted in
accordance  with acceptable standards.  The OECD protocols are  available from OECD, 2001
L Street, N.W., Washington, D.C. 20036 (Telephone number 202-785-6323; Fax telephone
number 202-785-0350).

       All new studies and proposed protocols submitted in response to this Data Call-in Notice
must be in accordance with Good Laboratory Practices [40 CFR Part 160.3(a)(6)].

II-D.   REGISTRANTS RECEIVING PREVIOUS  SECTION 3(c)(2)(B) NOTICES ISSUED
       BY THE AGENCY

       Unless otherwise noted herein, this Data Call-In does not in any way supersede or
change the requirements of any previous Data Call-In(s), or  any other agreements entered  into
with the Agency pertaining to such prior Notice. Registrants must comply with the requirements
of all Notices to avoid issuance of a Notice of Intent to Suspend their affected products.

SECTION III. COMPLIANCE WITH REQUIREMENTS OF THIS NOTICE

III-A.  SCHEDULE FOR RESPONDING TO THE AGENCY

        The appropriate responses initially required by this Notice for product specific data must
be submitted to the Agency within 90 days after your receipt of this Notice. Failure to
adequately respond to this Notice within 90 days of your receipt will be a basis for issuing a
Notice of Intent to Suspend (NOIS) affecting your products.  This and other bases for issuance of
NOIS due to failure to comply with this Notice are presented in Section IV-A and IV-B.

III-B.  OPTIONS FOR RESPONDING TO THE AGENCY

       The  options for responding to this Notice for product specific data are: (a) voluntary
cancellation, (b) agree to satisfy the product specific data requirements imposed by this notice or
(c) request a data waiver(s).

       A discussion of how to respond if you chose the Voluntary Cancellation option is
presented below.  A discussion of the various options  available for satisfying the product

                                         105

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specific data requirements of this Notice is contained in Section III-C. A discussion of options
relating to requests for data waivers is contained in Section III-D.

       There are two forms that accompany this Notice of which, depending upon your
response, one or both must be used in your response to the Agency.  These forms are the Data-
Call-in Response Form, and the Requirements Status and Registrant's Response Form,
Attachment 2 and Attachment 3. The Data Call-In Response Form must be submitted as part of
every response to this Notice.  In addition, one copy of the Requirements Status and Registrant's
Response Form must be submitted for each product listed on the Data Call-in Response Form
unless the voluntary cancellation option is selected or unless the product is identical to another
(refer to the instructions for completing the Data Call-in Response Form in Attachment 2).
Please note that the company's authorized representative is required to sign the first page of the
Data Call-in Response Form and Requirements Status and Registrant's Response Form (if this
form is  required) and initial any subsequent pages. The forms contain separate detailed
instructions on the response options.  Do not alter the printed material. If you have questions  or
need assistance in preparing your response, call or write the contact person(s) identified in
Attachment 1.

       1. Voluntary Cancellation - You may avoid the requirements of this Notice by requesting
voluntary cancellation of your product(s) containing the active ingredient that is the subject of
this Notice.  If you wish to voluntarily cancel your product, you must submit a completed Data
Call-in Response Form, indicating your election of this option.  Voluntary cancellation is item
number 5 on the Data Call-In Response Form. If you choose this option, this is the only form
that you are required to complete.

       If you chose to voluntarily cancel your product, further sale and distribution of your
product after the effective date of cancellation must be  in accordance with the Existing Stocks
provisions of this Notice which are contained in Section IV-C.

       2. Satisfying the Product Specific Data Requirements of this Notice There are various
options  available to satisfy the product specific data requirements of this Notice.  These options
are discussed in Section III-C of this Notice and comprise  options 1  through 6 on the
Requirements Status and Registrant's Response Form and item numbers 7a and 7b on the Data
Call-in Response Form. Deletion of a use(s) and the low volume/minor use option are not valid
options  for fulfilling product specific data requirements.

       3. Request for Product  Specific Data Waivers.  Waivers for product specific  data are
discussed in Section III-D of this Notice and are covered by option 7 on the Requirements Status
and Registrant's  Response Form.  If you choose one of these options, you must submit both
forms as well as  any  other information/data pertaining  to the option chosen to address the data
requirement.

III-C   SATISFYING THE DATA REQUIREMENTS OF THIS NOTICE

       If you acknowledge on  the Data Call-in Response Form that you agree to satisfy the
product specific data requirements (i.e. you select item number 7a or 7b),  then you must select
one of the six options on the Requirements Status and Registrant's Response Form related to
data production for each data requirement. Your option selection should be entered under item


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number 9, "Registrant Response."  The six options related to data production are the first six
options discussed under item 9 in the instructions for completing the Requirements Status and
Registrant's Response Form.  These six options are listed immediately below with information
in parentheses to guide registrants to additional instructions provided in this Section.  The
options are:

       (1)     I will generate and submit data within the specified time frame (Developing Data)
       (2)     I have entered into an agreement with one or more registrants to develop data
              jointly (Cost Sharing)
       (3)     I have made offers to cost-share (Offers to Cost Share)
       (4)     I am submitting an existing  study that has not been submitted previously to the
              Agency by anyone (Submitting an Existing Study)
       (5)     I am submitting or citing data to upgrade a study classified by EPA as partially
              acceptable and upgradeable (Upgrading a Study)
       (6)     I am citing an existing study that EPA has classified  as acceptable or an existing
              study that has been submitted but not reviewed by the Agency (Citing an Existing
              Study)

       Option 1,  Developing Data — If you choose to develop the required data it must be in
conformance with Agency deadlines and with other Agency requirements as referenced herein
and in the attachments. All data generated and submitted must comply with the Good
Laboratory Practice (GLP) rule (40 CFR Part 160), be conducted according to the Pesticide
Assessment Guidelines (PAG), and be in conformance with the requirements of PR Notice 86-5.

       The time frames in the Requirements Status and Registrant's Response Form  are the time
frames that the Agency is allowing for the  submission of completed study reports.  The noted
deadlines run from the date of the receipt of this Notice by the registrant. If the data are not
submitted by the deadline, each registrant is subject to receipt of a Notice of Intent to Suspend
the affected registration(s).

       If you cannot submit the data/reports to the Agency in the time required by this Notice
and intend to seek additional time to meet the requirements(s), you must  submit a request to the
Agency which includes:  (1) a detailed description of the expected difficulty and (2) a proposed
schedule including alternative dates for meeting such requirements on a step-by-step basis.  You
must explain any technical or laboratory difficulties and provide documentation from the
laboratory performing the testing.  While EPA is considering your request, the original deadline
remains. The Agency will respond to your request in writing. If EPA does not grant your
request, the original deadline remains.  Normally, extensions  can be requested only in cases of
extraordinary testing problems beyond the  expectation or control  of the registrant.  Extensions
will not be given in submitting the 90-day responses. Extensions will not be considered if the
request for extension is not made in a timely fashion; in no event shall an extension request be
considered if it is submitted at or after the  lapse of the subject deadline.

       Option 2,  Agreement to Share in Cost to Develop Data — Registrants may only choose
this option for acute toxicity data and certain efficacy data  and only if EPA has indicated in the
attached data tables that your product and at least one other product are similar for purposes of
depending on the same data.  If this is the case, data may be generated for just one of the
products in the group.  The registration number of the product for which data will be submitted


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must be noted in the agreement to cost share by the registrant selecting this option.  If you
choose to enter into an agreement to share in the cost of producing the required data but will not
be submitting the data yourself, you must provide the name of the registrant who will be
submitting the data. You must also provide EPA with documentary evidence that an agreement
has been formed. Such evidence may be your letter offering to join in an agreement and the
other registrant's acceptance of your offer, or a written statement by the parties that an
agreement exists. The agreement to produce the data need not specify all of the terms of the
final arrangement between the parties or the mechanism to resolve the terms. Section 3(c)(2)(B)
provides that if the parties cannot resolve the terms of the agreement they may resolve their
differences through binding arbitration.

       Option 3, Offer to Share in the Cost of Data Development — This option only applies to
acute toxicity and certain efficacy data as described in option 2 above. If you have  made an
offer to pay in an attempt to enter into an agreement or amend an existing agreement to meet the
requirements of this Notice and have been unsuccessful, you may request EPA (by selecting this
option) to exercise its discretion not to suspend your registration(s), although you do not comply
with the data submission requirements of this Notice. EPA has determined that as a general
policy, absent other relevant considerations, it will not suspend the registration of a  product of a
registrant who has in good faith sought and continues to seek to enter into a joint data
development/cost sharing program, but the other registrant(s) developing the data has refused to
accept your offer.  To qualify for this option, you must submit documentation to the Agency
proving that you have made an offer to another registrant (who has an obligation to  submit data)
to share in the burden of developing that data.  You must also submit to the  Agency a completed
EPA Form 8570-32, Certification of Offer to Cost Share in the Development of Data,
Attachment 7.  In addition, you must demonstrate that the other registrant to whom  the offer was
made has not accepted your offer to enter into a cost sharing agreement by including a copy of
your offer and proof of the other registrant's receipt of that offer  (such as a certified mail
receipt). Your offer must, in addition to anything else, offer to share in the burden  of producing
the data upon terms to be agreed or failing agreement to be bound by  binding arbitration as
provided by FIFRA section 3(c)(2)(B)(iii) and must not qualify this offer.  The other registrant
must also inform EPA of its election of an option to develop and submit the  data required by this
Notice by submitting a Data Call-in Response Form and a Requirements  Status  and  Registrant's
Response Form committing to develop and submit the data required by this Notice.

       In order for you to avoid suspension under this option, you may not withdraw your offer
to share in the burdens of developing the data.  In addition, the other registrant must fulfill its
commitment to develop and submit the data as required by this Notice. If the other  registrant
fails to develop the data or for some other reason is subject to suspension, your registration as
well as that of the other registrant will normally be subject to initiation of suspension
proceedings, unless you commit to submit, and do submit the required data in the specified time
frame.  In such cases, the Agency generally will not grant a time  extension for submitting the
data.

       Option 4, Submitting an Existing Study — If you choose to submit an existing study in
response to this Notice, you must determine that the study satisfies the requirements imposed by
this Notice. You may only submit a study that has not been previously submitted to the Agency
or previously cited by anyone. Existing  studies are studies which predate issuance of this
Notice.  Do not use this option if you are submitting data to upgrade a study. (See Option 5).


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       You should be aware that if the Agency determines that the study is not acceptable, the
Agency will require you to comply with this Notice, normally without an extension of the
required date of submission. The Agency may determine at any time that a study is not valid
and needs to be repeated.

       To meet the requirements of the DCI Notice for submitting an existing study, all of the
following three criteria must be clearly met:

       a.      You must certify at the time  that the existing study is submitted that the raw data
              and specimens from the study are available for audit and review and you must
              identify where they are available.  This must be done  in accordance with the
              requirements of the Good Laboratory Practice (GLP) regulation, 40 CFR Part
              160. As stated in 40 CFR 160.3(j) " 'raw data' means any laboratory worksheets,
              records, memoranda, notes,  or exact copies thereof, that are the result of original
              observations and activities of a study and are necessary for the reconstruction and
              evaluation of the report of that  study.  In the event that exact transcripts of raw
              data have been prepared (e.g.,  tapes which have been transcribed verbatim,
              dated, and verified accurate by signature), the exact copy or exact transcript may
              be substituted for the original source as raw data.  'Raw data' may include
              photographs, microfilm or microfiche copies, computer printouts, magnetic
              media, including dictated observations, and recorded data from automated
              instruments." The term "specimens",  according to 40 CFR 160.3(k), means "any
              material derived from a test system for examination or analysis."

       b.      Health and safety studies completed after May 1984 must also contain all GLP-
              required quality assurance  and  quality control information,  pursuant to the
              requirements of 40 CFR Part 160.  Registrants must also certify at the time of
              submitting the existing study that such GLP information is available for post-May
              1984 studies by including an appropriate statement on or attached to the study
              signed by an authorized official or representative of the registrant.

       c.      You must certify that each study fulfills the acceptance criteria for the Guideline
              relevant to the study provided in the FIFRA Accelerated Reregistration Phase 3
              Technical Guidance and that the study has been conducted according to the
              Pesticide Assessment Guidelines (PAG) or meets the purpose of the PAG (both
              available from NTIS).  A study not conducted according to the PAG may be
              submitted to the Agency for consideration if the registrant believes that the study
              clearly meets the purpose of the PAG.  The registrant is referred to 40 CFR
              158.70 which states the Agency's policy regarding acceptable protocols. If you
              wish to submit the  study, you must, in addition to certifying that the purposes of
              the PAG are met by the study,  clearly  articulate the rationale why you believe the
              study meets the  purpose of the  PAG, including copies of any supporting
              information or data.  It has been the Agency's experience that studies completed
              prior to January 1970 rarely  satisfied the purpose of the PAG and that necessary
              raw data are usually not available for such studies.

       If you submit an existing study, you must certify that the study meets all requirements of
the criteria outlined above.
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       If you know of a study pertaining to any requirement in this Notice which does not meet
the criteria outlined above but does contain factual information regarding unreasonable adverse
effects, you must notify the Agency of such a study. If such  study is in the Agency's files, you
need only cite it along with the notification. If not in the Agency's files, you must submit a
summary and copies as required by PR Notice 86-5.

       Option 5, Upgrading a Study — If a study has been classified as partially acceptable and
upgradeable, you may submit data to upgrade that study.  The Agency will review the data
submitted and determine if the requirement is satisfied. If the Agency decides the requirement is
not satisfied, you may still be required to submit new data normally without any time extension.
Deficient, but upgradeable studies will normally be classified as supplemental.  However, it is
important to note that not all studies classified as  supplemental are upgradeable. If you have
questions regarding the classification of a study or whether a study may be upgraded, call or
write the contact person listed in Attachment 1.  If you submit data to upgrade an existing study
you must satisfy or supply information to correct all deficiencies in the study identified by EPA.
You  must provide a clearly articulated rationale of how the deficiencies have been remedied or
corrected and why the study should be rated as acceptable to EPA. Your submission must also
specify the MRID number(s) of the study which you are attempting to upgrade and must be in
conformance with PR Notice 86-5.

       Do not submit additional data for the purpose of upgrading a study classified as
unacceptable and determined by the Agency as not capable of being upgraded.

       This option should also be used to cite data that has been previously submitted to upgrade
a study, but has not yet been reviewed by the Agency.  You must provide the MRID number of
the data submission as well as the MRID number of the study being upgraded.

       The criteria for submitting an existing study, as specified in Option 4 above,  apply to all
data  submissions intended to upgrade studies. Additionally your submission of data intended to
upgrade studies must be accompanied by a  certification that you comply with each of those
criteria as well as a certification regarding protocol compliance with Agency requirements.

       Option 6, Citing Existing Studies — If you choose to cite a study that has been previously
submitted to EPA, that study must have been previously classified by EPA as acceptable or it
must be a study which has not yet been reviewed by the Agency.  Acceptable toxicology studies
generally will have been classified as "core-guideline" or "core minimum."  For all other
disciplines the classification would be "acceptable."  With respect to any studies for which you
wish to select this option you must provide the MRID number of the study you are citing and, if
the study has been reviewed by the Agency, you must provide the Agency's classification of the
study.

       If you are citing a study of which you are not the original data submitter, you must
submit a completed copy  of EPA Form 8570-31,  Certification with Respect to Data
Compensation Requirements.

       Registrants who select one of the above 6 options must meet all of the requirements
described in the instructions for completing the Data Call-In Response Form and the
Requirements Status and Registrant's Response Form, as appropriate.


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III-D   REQUESTS FOR DATA WAIVERS

       If you request a waiver for product specific data because you believe it is inappropriate,
you must attach a complete justification for the request, including technical reasons, data and
references to relevant EPA regulations, guidelines or policies.  (Note: any supplemental data
must be submitted in the format required by PR Notice 86-5). This will be the only opportunity
to state the reasons or provide information in support of your request. If the Agency approves
your waiver request, you will not be required to supply the data pursuant to section 3(c)(2)(B) of
FIFRA. If the Agency denies your waiver request, you must choose an option for meeting the
data requirements of this Notice within 30 days of the receipt of the Agency's decision. You
must indicate and submit the option chosen  on the Requirements Status and Registrant's
Response Form.  Product specific data requirements for product chemistry, acute toxicity and
efficacy (where appropriate) are required for all products and the Agency would grant a waiver
only under extraordinary circumstances.  You should also be aware that submitting a waiver
request will not automatically extend the due date for the study in question. Waiver requests
submitted without adequate supporting rationale will be denied and the original due date will
remain in force.

SECTION IV. CONSEQUENCES OF FAILURE TO COMPLY WITH THIS NOTICE

IV-A   NOTICE OF INTENT TO SUSPEND

       The Agency may issue a Notice of Intent to Suspend products subject to this Notice due
to failure by a registrant to comply with the requirements of this Data Call-In Notice, pursuant
to FIFRA  section 3(c)(2)(B).  Events which may be the basis for issuance of a Notice of Intent
to Suspend include, but are not limited to, the following:

       1.     Failure to respond as required by this Notice within 90 days of your receipt of
             this Notice.

       2.     Failure to submit on the required schedule an acceptable proposed or final
             protocol when such is required to be submitted to the Agency for review.

       3.     Failure to submit on the required schedule an adequate progress report on a study
             as required by this Notice.

       4.     Failure to submit on the required schedule acceptable data as required by this
             Notice.

       5.     Failure to take a required action or submit adequate information pertaining to any
             option chosen to address the data requirements (e.g., any required action or
             information pertaining to submission or citation of existing studies or offers,
             arrangements, or arbitration  on the sharing of costs or the formation of Task
             Forces, failure to comply with the terms of an agreement or arbitration
             concerning joint data development or failure to comply with any terms of a data
             waiver).
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       6.      Failure to submit supportable certifications as to the conditions of submitted
              studies, as required by Section III-C of this Notice.

       7.      Withdrawal of an offer to share in the cost of developing required data.

       8.      Failure of the registrant to whom you have tendered an offer to share in the cost
              of developing data and provided proof of the registrant's receipt of such offer or
              failure of a registrant on whom you rely for a generic data exemption either to:

              a.     inform EPA of intent to develop and submit the data required by this
                    Notice on a Data Call-in Response Form and a Requirements Status and
                    Registrant's Response Form;

              b.     fulfill the commitment to develop and  submit the data as required by this
                    Notice; or

              c.     otherwise take appropriate steps to meet the requirements stated in this
                    Notice, unless you commit to submit and do  submit the required data in
                    the specified time frame.

       9.      Failure to take any required or appropriate steps, not mentioned above, at any
              time following the issuance of this Notice.

IV-B.  BASIS FOR DETERMINATION THAT SUBMITTED STUDY IS UNACCEPTABLE

       The Agency may determine that a study (even if submitted within the required time) is
unacceptable and constitutes  a basis  for issuance of a Notice  of Intent to  Suspend.  The grounds
for suspension include, but are not limited to, failure to meet any of the following:

       1.  EPA requirements specified in the Data Call-in Notice or other documents
       incorporated by reference (including, as applicable, EPA  Pesticide Assessment
       Guidelines, Data Reporting Guidelines, and GeneTox Health Effects Test Guidelines)
       regarding the design, conduct, and reporting of required studies.   Such requirements
       include, but are not limited to, those relating to test material, test procedures,  selection
       of species, number of animals,  sex and distribution of animals, dose and effect levels to
       be tested or attained,  duration of test, and,  as applicable, Good Laboratory Practices.

       2.  EPA requirements regarding the submission of protocols, including the incorporation
       of any changes required by the Agency following review.

       3.  EPA requirements regarding the reporting of data, including the manner of reporting,
       the completeness of results, and the adequacy of any  required supporting (or raw) data,
       including, but not limited to, requirements referenced or included in this Notice or
       contained in PR 86-5. All studies must be submitted  in the  form of a final report;  a
       preliminary report will not be considered to fulfill the submission requirement.
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IV-C  EXISTING STOCKS OF SUSPENDED OR CANCELED PRODUCTS

       EPA has statutory authority to permit continued sale, distribution and use of existing
stocks of a pesticide product which has been suspended or cancelled if doing so would be
consistent with the purposes of the Act.

       The Agency has determined that such disposition by registrants of existing stocks for a
suspended registration when a section 3(c)(2)(B) data request is outstanding would generally not
be consistent with the Act's purposes. Accordingly, the Agency anticipates granting registrants
permission to sell,  distribute, or use existing stocks of suspended product(s) only in exceptional
circumstances.  If you believe such disposition of existing stocks of your product(s) which may
be suspended for failure to comply with this Notice should be permitted, you have the burden of
clearly demonstrating to EPA that granting such permission would be consistent with the Act.
You must also explain why an "existing stocks" provision is necessary, including a statement of
the quantity  of existing stocks and your estimate of the time required for their sale, distribution,
and use.  Unless you meet this burden the Agency will not consider any request pertaining to the
continued sale, distribution, or use of your existing stocks after suspension.

       If you request a voluntary cancellation of your product(s) as a response to this Notice
and your product is in full compliance with all Agency requirements, you will have, under most
circumstances, one year from the date your 90 day response to this Notice is due, to sell,
distribute, or use existing stocks.  Normally, the Agency will allow persons other than the
registrant such as independent distributors, retailers and end users to sell, distribute or use such
existing stocks until the stocks are exhausted.  Any sale, distribution or use of stocks  of
voluntarily cancelled products containing an active ingredient for which the Agency has
particular risk concerns will be determined on case-by-case basis.

       Requests for voluntary cancellation received after the 90 day response period required by
this Notice will not result in the Agency granting any additional time to  sell, distribute, or use
existing stocks beyond  a year from the date the 90 day response was due unless you demonstrate
to the Agency  that you are in full compliance with all Agency requirements, including the
requirements of this Notice.  For example, if you decide to voluntarily cancel your registration
six months before a 3 year study is scheduled to be submitted, all progress reports and other
information  necessary to establish that you have been conducting the study in an acceptable and
good faith manner  must have been submitted to the Agency, before EPA will consider granting
an existing stocks provision.

SECTION V.  REGISTRANTS' OBLIGATION TO REPORT POSSIBLE UNREASONABLE
              ADVERSE EFFECTS

       Registrants are reminded that FIFRA section 6(a)(2) states that if at any time after a
pesticide is registered a registrant  has additional factual information regarding unreasonable
adverse effects on the environment by the pesticide, the registrant shall submit the information to
the Agency.  Registrants must notify the Agency of any factual information they have, from
whatever source, including but not limited to interim or preliminary results of studies, regarding
unreasonable adverse effects on man or the environment.  This requirement continues as long as
the products are registered by the  Agency.
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SECTION VI. INQUIRIES AND RESPONSES TO THIS NOTICE

       If you have any questions regarding the requirements and procedures established by this
Notice, call the contact person(s) listed in Attachment 1, the Data Call-In Chemical Status Sheet.

       All responses to this Notice (other than voluntary cancellation requests and generic data
exemption claims) must include a completed Data Call-In Response Form and a completed
Requirements Status and Registrant's Response Form (Attachment 2 and Attachment 3 for
product specific data) and any other documents required by this Notice, and should be submitted
to the contact person(s) identified in Attachment 1.  If the voluntary cancellation or generic data
exemption option is chosen, only the Data  Call-In Response Form need be submitted.

       The Office of Compliance Monitoring (OCM) of the Office of Pesticides and Toxic
Substances (OPTS), EPA, will be monitoring the data being generated in response to this
Notice.

                                        Sincerely yours,
                                        Lois Rossi, Division Director
                                        Special Review and
                                          Reregistration Division
Attachments

       1  -   Data Call-In Chemical Status Sheet
       2  -   Product-Specific Data Call-In Response Form
       3  -   Requirements Status and Registrant's Response Form
       4  -   EPA Batching of End-Use Products for Meeting Acute Toxicology Data
             Requirements for Reregistration
       5  -   List of Registrants  Receiving This Notice
       6  -   Cost Share and Data Compensation Forms  and the Confidential Statement of
             Formula Form
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TETRACHLORVINPHOS  DATA CALL-IN CHEMICAL STATUS SHEET

INTRODUCTION

       You have been sent this Product Specific Data Call-In Notice because you have product(s)
containing Tetrachlorvinphos.

       This Product Specific Data Call-In Chemical Status Sheet, contains an overview of data
required by this notice, and point of contact for inquiries pertaining to  the reregistration of
Tetrachlorvinphos. This attachment is to be used in conjunction with (1)  the Product Specific
Data Call-In Notice, (2) the Product Specific Data Call-In Response Form (Attachment 2), (3) the
Requirements Status  and Registrant's Form (Attachment  3), (4) EPA's Grouping of End-Use
Products for Meeting Acute Toxicology Data Requirement (Attachment 4), (5) a list of registrants
receiving this DCI (Attachment 5) and (6) the  Cost Share and Data Compensation Forms in
replying to this Tetrachlorvinphos Product Specific Data Call-In (Attachment (6)). Instructions
and guidance accompany each form.

DATA REQUIRED BY THIS NOTICE

       The additional data requirements needed  to complete the database for Tetrachlorvinphos
are contained in the Requirements Status and Registrant's Response, Attachment 3.  The Agency
has concluded that additional data on Tetrachlorvinphos are needed for specific products. These
data  are required to be submitted to the Agency within the time frame listed.  These data are
needed to fully complete the reregistration of all eligible Tetrachlorvinphos products.

INQUIRIES AND RESPONSES TO THIS NOTICE

       If you have any questions regarding this product specific data requirements and procedures
established by this Notice, please contact Jeffrey Billingslea at (703) 308-8004.

       All responses to this Notice for the Product Specific data requirements should be submitted
       to:
             Jeffrey Billingslea
             Chemical Review Manager Team 81
             Product Reregistration Branch
             Special Review and Reregistration Branch 7508W
             Office of Pesticide Programs
             U.S. Environmental Protection Agency
             Washington,  D.C.  20460

             RE:  Tetrachlorvinphos
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 INSTRUCTIONS FOR COMPLETING THE DATA CALL-IN RESPONSE FORM FOR
                            PRODUCT SPECIFIC DATA

Item 1-4.     Already completed by EPA.

Item 5.       If you wish to voluntarily cancel your product, answer "yes." If you choose this
             option, you will not have to provide the data required by the Data Call-In Notice
             and you will not have to complete any other forms.  Further sale and distribution
             of your product after the effective date of cancellation must be in accordance with
             the Existing Stocks provision of the Data Call-In Notice (Section IV-C).

Item 6.       Not applicable since this form calls in product specific data only. However, if
             your product is identical to another product and you qualify for a data exemption,
             you must respond with "yes" to Item 7a (MUP) or 7B (EUP) on this form, provide
             the EPA registration numbers of your source(s); you would not complete the
             "Requirements  Status and Registrant's  Response" form.  Examples of such
             products include repackaged products and Special Local Needs (Section 24c)
             products which are identical to federally registered products.

Item 7a.      For each manufacturing use product (MUP) for which you wish to maintain
             registration, you must agree to satisfy the data requirements by responding "yes."

Item 7b.      For each end use product (EUP) for which you wish to maintain registration, you
             must agree  to satisfy the data requirements by responding "yes."  If you  are
             requesting a data waiver, answer "yes"  here; in addition, on the "Requirements
             Status and Registrant's Response"  form under Item 9, you must respond with
             Option 7 (Waiver Request) for each study for which you are requesting a waiver.
             See Item 6 with regard to identical products and data exemptions.

Items 8-11.   Self-explanatory.

NOTE:      You may provide additional information that does not fit on this form in a signed
             letter that accompanies this form.  For example, you may wish to report that your
             product has already been transferred to another company or that you have already
             voluntarily canceled this  product.  For these  cases, please supply all relevant
             details so that EPA can ensure that its records are correct.
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DATA CALL-IN RESPONSE Page 1 of 1
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      INSTRUCTIONS FOR COMPLETING THE REQUIREMENTS STATUS AND
        REGISTRANT'S RESPONSE FORM FOR PRODUCT SPECIFIC DATA

Item 1-3      Completed by EPA. Note the unique identifier number assigned by EPA in
             Item 3.  This number must be used in the transmittal document for any data
             submissions in response to this  Data Call-In Notice.

Item 4.       The guideline reference numbers of studies required to support the product's
             continued registration are identified.  These guidelines, in addition to the
             requirements specified in the Notice, govern the conduct of the required studies.
             Note that series 61  and 62 in product chemistry are now listed under 40 CFR
             158.155 through  158.180, Subpart C.

Item 5.       The study title associated with the guideline reference number is identified.

Item 6.       The use pattern(s) of the pesticide associated with the product specific
             requirements is (are) identified.  For most product specific data requirements,
             all use patterns are  covered by the data requirements.  In the case of efficacy
             data, the required studies only pertain  to products which have the use sites
             and/or pests  indicated.

Item 7.       The substance to  be tested is identified by EPA.  For product specific data, the
             product as formulated for sale and distribution is the test substance, except in
             rare cases.

Item 8.       The due date for  submission of each study is identified.  It is normally based on
             8 months after issuance of the Reregistration Eligibility Document unless
             EPA determines that a longer time period is necessary.

Item 9.       Enter only one of the following response codes for each data requirement to
             show how you intend to comply with the data requirements listed in this
             table.  Fuller descriptions of each option are contained in the Data Call-In
             Notice.

       1.     I will generate and  submit data by the  specified due date (Developing Data).
             By indicating that I have chosen this option, I certify that I will comply with all
             the requirements  pertaining to the conditions for submittal of this study as
             outlined in the Data Call-In Notice.  By the specified due date, I will also
             submit:  (1) a completed "Certification With Respect To Data Compensation
             Requirements" form (EPA Form 8570-29) and (2) two completed and signed
             copies of the Confidential Statement  of Formula (EPA Form 8570-4).

       2.     I have entered into  an agreement with  one or more registrants to develop data
             jointly (Cost Sharing). I am submitting a copy of this agreement. I
             understand that this option is available only for acute toxicity or certain efficacy
             data and only if EPA indicates in an attachment to this Notice that my product

                                         119

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       is similar enough to another product to qualify for this option.  I certify that
       another party in the agreement is committing to submit or provide the required
       data; if the required study is not submitted on time, my product may be subject
       to suspension.  By the specified due date,  I will also submit: (1) a completed
       "Certification With Respect  To Data Compensation Requirements" form
       (EPA Form 8570-29) and (2) two completed and signed copies of the
       Confidential Statement of Formula (EPA Form 8570-4).

3.      I have made offers to share in the cost to develop data (Offers to Cost Share).
       I understand that this option is available only for acute toxicity or certain
       efficacy data and only if EPA indicates in an attachment to this Data Call-in
       Notice that my  product is similar enough to another product to  qualify for this
       option. I am submitting evidence that I have  made an offer to another
       registrant (who has an obligation to submit data) to share in the cost of that
       data. I am also submitting a completed "Certification of Offer to Cost Share
       in the Development Data" form. I am including a copy of my offer and proof
       of the other registrant's receipt of that offer. I am identifying the party which is
       committing to submit or provide the required data;  if the required study is not
       submitted on time, my product may be subject to suspension.  I understand that
       other terms under Option 3 in the Data Call-In Notice (Section  III-C.l.) apply
       as well.  By the specified due  date, I will also submit: (1) a completed
       "Certification With Respect  To Data Compensation Requirements" form
       (EPA Form 8570-29) and (2) two completed and signed copies of the
       Confidential Statement of Formula (EPA Form 8570-4).

4.      By the specified due date, I will submit an existing study that has not been
       submitted previously to the Agency by anyone (Submitting an Existing
       Study).  I certify that this study will meet all the requirements for submittal of
       existing data outlined in Option 4 in the Data Call-In  Notice (Section III-C.l.)
       and will meet the attached acceptance criteria (for acute toxicity and product
       chemistry data). I will attach  the needed supporting information along with this
       response. I also certify that I  have determined that this study will fill the data
       requirement for which I have indicated this choice. By the specified due  date, I
       will also submit a completed "Certification With Respect To Data
       Compensation Requirements" form (EPA Form 8570-29) to  show what data
       compensation option I have chosen.  By the specified due date, I will also
       submit: (1) a completed "Certification With Respect To Data Compensation
       Requirements" form (EPA Form 8570-29) and (2) two completed and signed
       copies of the Confidential Statement of Formula (EPA Form 8570-4).

5.      By the specified due date, I will submit or cite data to upgrade a study classified
       by the Agency as partially acceptable and upgradable (Upgrading a Study).  I
       will submit evidence of the Agency's review indicating that the study may be
       upgraded and what information is required to do so.  I will provide  the MRID
       or Accession number of the study at the due date. I understand that the
       conditions for this option outlined Option 5 in the Data Call-In  Notice (Section
                                   120

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             III-C.l.) apply. By the specified due date, I will also submit: (1) a completed
             "Certification With Respect To Data Compensation Requirements" form
             (EPA Form 8570-29) and (2) two completed and signed copies of the
             Confidential Statement of Formula (EPA Form 8570-4).

       6.     By the specified due date, I will cite an existing study that the Agency has
             classified as acceptable or an existing study that has been submitted but not
             reviewed by the Agency (Citing an Existing Study).  If I am citing another
             registrant's study, I understand that this option is available only for acute
             toxicity or certain efficacy data and only if the cited study was conducted on my
             product, an identical product or a product which EPA has "grouped" with one
             or more other products for purposes of depending on the same data.  I may also
             choose this option if I am citing my own data.  In either case, I will provide the
             MRID or Accession number(s) for the cited data on a "Product Specific Data
             Report" form or in a similar format. By the specified due date, I will also
             submit: (1) a completed "Certification With Respect To Data Compensation
             Requirements" form (EPA Form 8570-29) and (2) two completed and signed
             copies of the Confidential Statement of Formula (EPA Form 8570-4).

       7.     I request a waiver for  this study because it is inappropriate for my product
             (Waiver Request).  I  am attaching a complete justification for this request,
             including technical reasons, data and references to relevant EPA regulations,
             guidelines or policies. [Note: any supplemental data must be submitted in the
             format required by P.R.  Notice 86-5].  I understand that this is my only
             opportunity to state  the reasons or provide information in support of my
             request.  If the Agency approves my waiver request, I  will not be required to
             supply the data pursuant to Section 3(c)(2)(B) of FIFRA.  If the Agency denies
             my waiver request,  I must choose a method of meeting the data requirements of
             this Notice by the due date stated by this Notice. In this case, I must, within 30
             days of my receipt of the Agency's written decision, submit a revised
             "Requirements Status  and Registrant's  Response"  Form indicating the option
             chosen.  I also understand that the deadline for submission of data as specified
             by the original data  call-in notice will not change. By  the specified due date, I
             will also submit: (1) a completed "Certification With  Respect To Data
             Compensation Requirements" form (EPA Form 8570-29) and (2) two
             completed and signed  copies of the Confidential Statement of Formula (EPA
             Form 8570-4).

Items 10-13.  Self-explanatory.

NOTE:      You may provide additional information that does not fit on this form in a
             signed letter that accompanies this form. For example, you  may wish to report
             that your product has already been transferred to another company or that you
             have already voluntarily canceled this product.  For these cases, please supply
             all relevant details so that EPA  can ensure that its records are correct.
                                         121

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122

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REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE Page 1 of 2
                          123

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124

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REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE Page 2 of 2
                          125

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126

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FOOTNOTES AND KEY DEFINITIONS FOR GUIDELINE REQUIREMENTS Page 1 of 2
                               127

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FOOTNOTES AND KEY DEFINITIONS FOR GUIDELINE REQUIREMENTS Page 2 of 2
                               128

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    EPA'S BATCHING OF TETRACHLORVINPHOS PRODUCTS FOR MEETING
          REREGISTRATION ACUTE TOXICITY DATA REQUIREMENTS

       In an effort to reduce the time, resources and number of animals needed to fulfill the
acute toxicity data requirements for reregistration of products containing
TETRACHLORVINPHOS as the active ingredient, the Agency has batched products  which
can be considered similar for purposes of acute toxicity. Factors considered in the sorting
process include each product's active and inert ingredients (identity, percent composition and
biological activity), type of formulation (e.g., emulsifiable concentrate, aerosol, wettable
powder,  granular, etc.), and labeling (e.g., signal word, use  classification, precautionary
labeling, etc.).  Note that the Agency is not describing batched products as "substantially
similar"  since some products within a batch may not be considered chemically similar or have
identical use patterns.

       Using available information, batching has been accomplished by the process described
in the preceding paragraph. Notwithstanding the batching process, the Agency reserves the
right to require, at any time, acute  toxicity data for an individual product should the need
arise.

       Registrants of products within a batch may choose to  cooperatively generate, submit or
cite a single battery of six acute toxicological studies to represent all the products within that
batch.  It is the registrant's option to participate in the process with all other registrants, only
some of the other registrants, or only their own products within a batch, or to generate all the
required acute toxicological studies for each of their own products. If a registrant chooses to
generate the data for a batch, he/she must use one  of the products within the batch as the test
material. If a registrant chooses to rely upon previously submitted acute toxicity data, he/she
may do so provided that the data base is complete and valid by today's standards (see
acceptance criteria attached), the formulation tested is considered by EPA to be similar for
acute toxicity, and the formulation  has not been significantly  altered since submission and
acceptance of the  acute toxicity data. Regardless of whether new data is generated or existing
data is referenced, registrants must clearly identify the test material by EPA  Registration
Number. If more  than one confidential statement of formula (CSF) exists for a product, the
registrant must indicate the formulation actually tested by identifying the corresponding CSF.

       In deciding how to meet the product specific data requirements, registrants must follow
the  directions given in the Data Call-In Notice and its attachments appended  to the RED. The
DCI Notice contains two response  forms which are to be completed and submitted to the
Agency within 90 days of receipt.  The first form, "Data Call-In Response," asks whether the
registrant will meet the data requirements for each product.  The second form, "Requirements
Status  and Registrant's Response,"  lists the product specific data required  for each product,
including the  standard six acute toxicity tests. A registrant who wishes to participate in a
batch must decide whether he/she will provide the data or depend on someone else to do so. If
a registrant supplies the data to support a batch of products, he/she must select one of the
following options: Developing Data (Option  1), Submitting an Existing Study (Option 4),
Upgrading an Existing Study (Option 5) or Citing an Existing Study (Option 6). If a registrant
depends  on another's data, he/she must choose among: Cost  Sharing (Option 2), Offers to
Cost Share  (Option 3) or Citing an  Existing Study (Option 6). If a registrant does not want to
participate in  a  batch,  the choices are Options 1,  4,  5 or 6. However, a registrant should


                                          129

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know that choosing not to participate in a batch does not preclude other registrants in the batch
from citing his/her studies and offering to cost share (Option 3) those studies.

       One hundred thirty two products were found which contain  TETRACHLORVINPHOS
as the active ingredient. The products have been placed into twelve batches and a "no batch"
category in accordance with the active and inert ingredients, type of formulation and current
labeling. Table 1 identifies the products in each batch. Table 2 lists the products which has
been placed in the "no batch"  category. The following summarizes acute data requirement by
batch:

Q     Registrants with products in Batch 1 may cite acute data on the technical product.
Q     Registrants with products in Batch 2 may cite acute data on the technical product with
       the exception of the eye irritation study.  Since the products in  this batch may be more
       irritating to the eyes, an eye irritation study performed on a product in this batch is
       needed.
Q     Registrants with products in Batch 3 need to cite/submit all acute data on one of the
       subject products.
Q     Registrants with products in Batch 4 may cite acute data on the technical product.
Q     All products in Batch 5 are already supported by currently acceptable acute data.  The
       registrant of the products in this batch should reference the existing data to support
       reregistration.
Q     Registrants with products in Batch 6 may cite acute data on the technical product.
Q     Registrants with products in Batch 7 may cite acute data on the technical product with
       the exception of the eye irritation study.  Since the products in  this batch may be more
       irritating to the eye, an eye irritation study performed on a product in this batch is
       needed.
Q     Registrants with products in Batch 8 may cite acute data on the technical product with
       the exception of the eye irritation study.  Since the products in  this batch may be more
       irritating to the eye, an eye irritation study performed on a product in this batch is
       needed.
Q     Registrants with products in Batch 9 may cite acute data on the technical product with
       the exception of the eye irritation study.  Since the products in  this batch may be more
       irritating to the eye, an eye irritation study performed on a product in this batch is
       needed.
Q     Registrants with products in Batch 10 may cite acute data on the technical product.
Q     Registrants with products in Batch 11 may cite acute data on the technical product with
       the exception of the eye irritation study.  Since the products in  this batch may be more
       irritating to the eye, an eye irritation study performed on a product in this batch is
       needed.
Q     Registrants with products in Batch 12 need to cite/submit all acute data on one of the
       subject products.

       Since acute data generated with the technical material can be cited in most cases, a
complete set of new  acutes is only needed for products in batch 3, batch 12 and the no batch
group.  If a registrant does not believe that the results  of the technical data apply to a
particular end use product or group of products within a batch, product/batch specific data
may be submitted.
                                           130

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Table 1
Batch
i
2
3
4
5
6
EPA Reg. No.
2596-131
56493-34
56493-38
56493-88
62725-1
70-191
28293-76
34704-432
47000-68
56493-13
56493-45
56493-42
56493-43
2596-49
2596-50
2596-62
2596-63
2596-83
2596-84
56493-50
56493-89
56493-90
2596-122
2596-123
2596-125
2596-126
270-164
1352-62
6482-8
11715-202
11715-203
11715-217
40833-5
65901-1
Percent Tetrachlorvinphos
99.0
97.3
97.3
98.7
98.8
50.0
50.0
50.0
50.0
50.0
50.0
23.0
Dichlorvos 5.3
23.0
Dichlorvos 5.3
13.7
13.7
13.7
13.7
14.55
14.55
13.7
13.7
13.7
0.96
0.96
1.07
1.07
2.46
0.40
0.15
0.47
0.30
2.96
0.30
0.47
Formulation Type
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Spray
Spray
Collar
Collar
Collar
Collar
Collar
Collar
Tag
Collar
Collar
Spray
Spray
Spray
Spray
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
                                         131

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Batch
7
8
EPA Reg. No.
70-192
70-224
299-188
572-295
2393-393
2596-78
2596-79
11715-208
19713-340
28293-13
34704-266
34704-276
34704-307
47000-66
47000-67
56493-28
56493-44
58210-3
67517-40
99-118
534-94
602-267
602-268
602-311
602-359
602-360
1304-64
1304-66
1304-68
1352-26
1352-56
1352-60
1352-61
1352-63
1990-386
1990-387
1990-517
2011-5
2011-6
Percent Tetrachlorvinphos
3.0
1.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
1.0
3.0
3.0
3.0
3.0
3.0
3.0
3.0
0.84
0.40
1.45
1.45
1.23
0.57
0.77
0.98
0.98
0.68
1.72
0.50
0.30
1.2
0.61
1.0
0.46
1.0
1.0
1.0
Formulation Type
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
132

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Batch
8
EPA Reg. No.
2011-7
4089-5
6552-12
6552-13
6552-14
6552-17
7138-12
7455-32
7627-21
7627-22
7627-26
7698-7
7702-5
9078-6
9078-12
9374-8
9374-9
11715-284
12714-3
20552-2
37774-9
38110-4
38110-7
40833-4
40833-6
40833-9
40833-10
40833-11
40833-12
40833-13
41200-2
43757-1
44666-1
46911-1
55392-1
Percent Tetrachlorvinphos
1.0
1.24
1.25
0.75
1.25
0.47
0.35
1.0
0.60
0.30
0.63
1.40
1.0
0.93
0.31
0.30
0.80
0.46
1.79
0.30
4.0
1.0
1.0
0.49
0.60
1.0
1.0
1.0
0.30
1.24
1.23
1.0
1.0
0.70
0.80
Formulation Type
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
133

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Batch
9
10
11
12
EPA Reg. No.
1352-24
3213-36
4987-5
7455-23
38092-3
39258-11
39409-1
48390-1
56493-35
99-121
67517-26
1304-63
2011-10
37774-1
40833-8
56493-29
67517-33
Percent Tetrachlorvinphos
7.76
7.76
7.76
7.76
7.76
7.76
7.76
7.76
7.76
6.60
7.76
7.76
7.76
7.76
7.76
24.0
24.0
Formulation Type
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Liquid
Liquid
       The following table lists products that were either considered not to be similar or the
Agency lacked sufficient information for decision making and were not placed in any batch.
The registrants of these producs are responsible for meeting the acute toxicity data
requirements separately.

Table 2  (No Batch)
EPA Reg. No.
1352-59
2596-89
2596-119
56493-27
28293-28
28293-27
56493-19
% Tetrachlorovinphos
0.18
0.99
2.8
1.0
Dichlorvos 0.23
2.0
Pyrethrins 0.09
Piperonyl butoxide, tech 0.18
N-octyl bicycloheptene 0.30
1.0
Pyrethrins 0.09
Piperonyl butoxide, tech 0.18
N-octyl bicycloheptene 0.30
Di-n-propyl iso-
cinchomeronate 0.50
75.0
Formulation Type
Solid
Spray
Liquid
Liquid
Gel
Spray
Solid
                                           134

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LIST OF ALL REGISTRANTS SENT THIS DATA CALL-IN NOTICE Page 1 of 2
                             135

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LIST OF ALL REGISTRANTS SENT THIS DATA CALL-IN NOTICE Page 1 of 2
                            136

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Instructions for Completing the Confidential Statement of Formula

The Confidential Statement of Formula (CSF) Form 8570-4 must be used. Two legible, signed
copies of the form are required.  Following are basic instructions:

      a.     All the blocks on the form must be filled in and answered completely.

      b.     If any block is not applicable, mark it N/A.

      c.     The CSF must be signed,  dated and the telephone number of the responsible
             party must be provided.

      d.     All applicable information which is  on the product specific data submission
             must also be reported on the CSF.

      e.     All weights reported under item 7 must be in pounds per gallon for liquids and
             pounds per cubic feet for solids.

      f.     Flashpoint must be in degrees Fahrenheit and flame extension in inches.

      g.     For all active ingredients, the EPA Registration Numbers for the currently
             registered source products must be reported under column 12.

      h.     The Chemical Abstracts Service (CAS) Numbers for all actives and inerts and
             all common names for the trade names must be reported.

      i.     For the active ingredients, the percent purity of the source products must be
             reported under column 10 and must be exactly the same as on the source
             product's label.
      j.     All the weights in columns 13.a. and 13.b. must be in pounds, kilograms, or
             grams. In no case will volumes be accepted. Do not mix English and metric
             system units (i.e., pounds and kilograms).

      k.     All the items under column  13.b. must total 100 percent.

      1.     All items under columns 14.a. and 14.b. for the active ingredients must
             represent pure active form.

      m.    The upper and lower certified limits for  ail active and inert ingredients must
             follow the 40 CFR 158.175 instructions. An explanation must be provided if the
             proposed limits are different than standard certified limits.

      n.     When new CSFs are submitted  and  approved,  all previously submitted CSFs
             become obsolete for that specific formulation.
                                         137

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138

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    r/EPA
United States  Environmental  Protection  Agency
            Washington,  DC  20460
   CERTIFICATION OF  OFFER  TO  COST
SHARE  IN THE  DEVELOPMENT OF  DATA
Form Approved

OMB No.  2070-0106
         2070-0057

Approval  Expires 3 31 96
 Public reporting burden for this collection of information is estimated to average 15 minutes per response, including
 time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and
 completing and reviewing the collection of information. Send comments regarding the burden estimate or any other
 aspect of this collection of information, including suggestions for reducing this burden, to Chief, Information Policy
 Branch, PM-223. U.S. Environmental Protection Agency, 401 M St., S.W., Washington, DC 20460; and to the Office
 of Management and Budget, Paperwork Reduction Project (2070-0106), Washington, DC 20503.

 Please fill In  blanks below.
Company Name
Product Name
Company Number
EPA Keg. No.
 I Certify that:

 My company is willing to develop and submit the data required by EPA under the authority of the Federal
 Insecticide, Fungicide and Rodenticide Act (FIFRA), if necessary. However, my company would prefer to
 enter into an agreement with one or more registrants to develop jointly or share in the cost of developing
 data.

 My firm has offered in writing to enter into such an agreement.  That offer was irrevocable and included an
 offer  to be bound  by arbitration decision under  section 3(c)(2)(B)(iii) of FIFRA if final agreement on  all
 terms could not be reached otherwise.  This offer was made to the following firm(s) on the following
 date(s):
  Name of Firm(s)
                                                                            Date of Offer
Certification:
I certify that I am duly authorized to represent the company named above, and that the statements that I have made on
this form and all attachments therein are true, accurate, and complete. I acknowledge that any knowingly false or
misleading statement may be punishable by fine or imprisonment or both under applicable law.
Signature
Name and
of Company's Authorized Representative
Date
Title (Please Type or Print)
 EPA Form 8570 32 (5/91)    Replaces EPA Form 8580, which is obsolete
                                                 141

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142

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United States Environmental Protection Agency
Washington, DC 20460
.^os%
USEfcJ
CERTIFICATION WITH RESPECT TO V, ^
"**/ poO"\'C*
DATA COMPENSATION REQUIREMENTS
Form Approved
OMB No. 2070-0107,
2070-0057
Approval Expires
3-31-96
Public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for
reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the
collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden to, Chief Information Policy Branch, PM-233, U.S. Environmental Protection
Agency, 401 M St., S.W., Washington, DC 20460; and to the Office of Management and Budget, Paperwork Reduction Project
(2070-0106), Washington, DC 20503.
Please fill in blanks below.
Company Name
Product Name
Company Number
EPA Reg. No.
I Certify that:
1. For each study cited in support of registration or reregistratiion under the Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA) that is an exclusive use study, I am the original data submitter, or I have obtained the written permission of the original
data submitter to cite that study.
2. That for each study cited in support of registration or reregistration under FIFRA that is NOT an exclusive use study, I am the
original data submitter, or I have obtained the written permission of the original data submitter, or I have notified in writing the
company(ies) that submitted data I have cited and have offered to: (a) Pay compensation for those data in accordance with sections
3(c)(1)(F) and 3(c)(2)(D) of FIFRA; and (b) Commence negotiation to determine which data are subject to the compensation
requirement of FIFRA and the amount of compensation due, if any. The companies I have notified are. (check one)
[ ] The companies who have submitted the studies listed on the back of this form or attached sheets, or indicated on the attached
"Requirements Status and Registrants' Response Form,"
3. That I have previously complied with section 3(c)(1)(F) of FIFRA for the studies I have cited in support of registration or reregistration
under FIFRA.
Signature
Date
Name and Title (Please Type or Print)
GENERAL OFFER TO PAY: I hereby offer and agree to pay compensation to other persons, with regard to the registration or
reregistration of my products, to the extent required by FIFRA section 3(c)(1)(F) and 3(c)(2)(D).
Signature
Date
Name and Title (Please Type or Print)
EPA Form 8570-31 (4-96)
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    The following is a list of available documents for Tetrachlorvinphos that my further assist
you in responding to this Reregistration Eligibility Decision document. These documents may
be obtained by the following methods:

Electronic
File format:   Portable Document Format (.PDF) Requires Adobe® Acrobat or compatible
             reader.  Electronic copies 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., or contact Jeffrey Billingslea at (703)-308-8004.

    1.       PR Notice 86-5.

    2.       PR Notice 91-2 (pertains to the Label Ingredient Statement).

    3.       A full copy of this RED document.

    4.       A copy of the fact sheet for Tetrachlorvinphos.

    The following documents are part of the Administrative Record for Tetrachlorvinphos and
may included in the EPA's Office of Pesticide Programs Public Docket.  Copies of these
documents are not available electronically, but may be obtained by contacting the person listed
on the Chemical Status Sheet.

    1.       Health and Environmental Effects Science Chapters.

    2.       Detailed Label Usage Information System (LUIS) Report.

    The following Agency reference documents are not available electronically, but may be
obtained by contacting the person listed on the Chemical Status Sheet of this RED document.

    1.       The Label Review Manual.

    2.       EPA Acceptance Criteria
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