United States
Environmental Protection
Agency	
Prevention, Pesticides
And Toxic Substances
(7508W)
EPA 738-R-96-009
June 1996
Reregistration
Eligibility Decision (RED)

Furanone

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                  United States
                  Environmental Protection
                  Agency	
                      Prevention, Pesticides
                      And Toxic Substances
                      (7508W)  ____
EPA-738-F-96-009
June 1996
                  R.E.D.   FACTS
                  Furanone
     Pesticide
Reregistration
    Use Profile
     All pesticides sold or distributed in the United States must be
registered by EPA, based on scientific studies showing that they can be
used without posing unreasonable risks to people or the environment.
Because of advances in scientific knowledge, the law requires that
pesticides which were first registered before November 1,1984r be
reregistered to ensure that they meet today's more stringent standards.
     In evaluating pesticides for reregistration, EPA obtains and reviews a
complete set of studies from pesticide producers, describing the human
health and environmental effects of each pesticide. The Agency develops
any mitigation measures or regulatory controls heeded to effectively reduce
each pesticide's risks. EPA then reregisters pesticides that can be used
without posing unreasonable risks to human health or the environment.
     When a pesticide is eligible for reregistration, EPA explains the basis
for its decision in a Reregistration Eligibility Decision (RED) document.
This fact sheet summarizes the information in the RED document for
reregistration case 3138, furanone.

     Dihydro-5-pentyl-2(3H)-furanone and dihydro-5-heptyl-2(3H)-
furanone (also known as gamma-nonalactone and gamma-undeccalactone,
respectively) are also referred to by the common name furanone.  Products
containing furanones are registered for use as insecticides, insect and
mammal repellents, and mosquito larvicides.
     Pesticide products containing furanones may be used used as a dog
and cat repellent; fly, cockroach and ant killer; insect repellent, insect
repellent strip, and insect repellent tablecloth; and mosquito larvicide.
Formulations include liquid ready-to-use solutions, emulsifiable
concentrates, granulars and impregnated material.
     Furanone is applied by the use of impregnated table cloths,
premoistened applicator puffs, aersol sprayers, non-aerosol hand pump
sprayer, knapsack sprayers, and granules which may be applied by hand.
     Use practice limitations include a label statement prohibiting
application directly to treated, finished drinking water reservoirs or drinking
water receptacles. Users also must avoid application to man-made surfaces
sensitive to mineral oils.

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        Regulatory       Furanone was first registered as a pesticide in the U.S. in 1983 for use
            H,StOiy  a, a cat repellent.  Currently, there are seven furanone products, which are
                       registered as mixtures with the active ingredient, limonene (Case 3083)
                       The Agency issued a Reregistered Eligibility Decision (RED) on limonene
                       m September1994 One of me seven products also contains a third
                       ingredient, Aliphatic Petroleum Hydrocarbons.

,  Human Health   Toxicity
     Assessment
        Acute oral, dermal and inhalation toxicity studies indicate low acute

         " H^T* ?• LikeWiS6' 6ye "* demal irritation studies -bo
   classified the formulated product in Category IV. The product is not a skin
   sensitzer. Data from the open literature on each of the two compounds
   considered the furanones to be of low toxicity             °rnpounds
                                             WOuM require a 90-day ^nnal toxicity study for
                                  may result in prolonged human dermal exposure through
                      repeated skin applications. The Agency has decided to waive this
                      requirement for the furanones based on a combination of the following-
                      bw exposure to furanones in the product; comparable concentrations of
                      tools in this product to those already used in cosmetic products (lotions
                      detergents, perfumes); anaturally occurring compound; and absence of
                      toxicity m the toxicology studies (notwithstanding limiied data)
                      Dietary Exposure

                     fn H C^ren!!yre^SteredP^^
                     food uses so dietary exposure is not anticipated. Although it is not a
                     chemical that is Generally Recognized as Safe (GRAS) by the Food and
                     Drug Administration (FDA), furanone is approved by FDA as a food
                     additive, and exposures to low concentrations are considered safe
                     Occupational and Residential Exposure
                         For the following reasons, the Agency has no concerns regarding
                     occupational or residential exposure to the furanones: (1) all acute studies
                     for the furanones indicate that  they have low acute toxiciJy (categorylv)
                     and (2) the furanones are only  in pesticide products that also contain
                                    percentage °f furanones i
                    Human Risk Assessment

                             A8ency does not "ntidpate occupational or residential risks of

                                    °S    t0 thC fUr
          .  .  r        "«, iuicuiunea.  nowever, as the ruranones
only in pesticide products that also contain limonene, the following
concerns from the limonene RED apply to the furanones.
                                                                                are

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Environmental
   Assessment
      Human exposure to furanones/limonene may occur during application
 of animal repellent granules or insect spray, or use of impregnated
 tablecloths. lexicological concerns for humans from exposure to limonene
 include dermal irritation and sensitization.  Systemic toxicity is not
 anticipated to occur at doses below the threshold for dermal irritation.
 Ocular irritation also may occur if products are accidently placed in the eye
 and not washed away.
      The tablecloth insect repellent product containing limonene was
 exempted from tolerance requirements and is not believed to cause
 exposure through food.  Exposure to limonene would be discontinued by
 most users if dermal irritation occurred, and exposure therefore is believed
 to be self-limiting. Product labeling required by the limonene RED is
 intended to prevent risks of potential skin and eye irritation to users.

 Environmental Fate
      Environmental fate data are not required to support the low-volume,
 outdoor, residential uses of the furanones. However, environmental fate
 data generally are required to support aquatic nonfood uses such as the
 mosquito larvicide use.  A quantitative environmental fate assessment
 cannot be made for the furanones at this time because no environmental fate
 data have been submitted for review. The furanones are classified as
 lactones, and some open literature data are available on physiochemical
; properties of lactones and their possible effect on the environment. The,
 reported data indicate lactones may not be stable in alkaline environments.
 Ecological Effects
                        j      • .
      Acute toxicity data indicate that the formulated product is practically
 non-toxic on an acute oral and subacute dietary basis to birds, mammals,
 and freshwater fish. The product is slightly toxic to freshwater
 invertebrates.
 Ecological Effects Risk Assessment
      The furanones, when used as mosquito larvicides, are applied directly
 to water. The public health larvicidal use of furanones applied at
 4.16 Ibs/acre (A) to 6 inches of water results in exceedances of the level of
 concern (LOC) for freshwater invertebrates. The LOG for endangered
 species is exceeded when the product is applied at 1.64 Ibs/A in water 6
 inches deep or less, or when it is  applied at 4.10 Ibs/A in water 1 foot deep
 or less.
      This assessment is based on testing done on a formulated product and
 tells little about the actual toxicity of the furanones as' active ingredients.
 Chronic invertebrate toxicity data and basic environmental fata data would
 improve the Agency's understanding and assessment of the potential risk
 posed by the use of the furanones in mosquito larvicides.

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     Risk Mitigation
                                The volume of products containing furanones that are used annually
                           as mosquito arvicides is low, and the percentage of furanone in me
                           products is also low. The low volume and low percent of furanone support
                           Ae conclusion that widespread adverse impacts are not likely to result from
                           the mojito larvicide use if continued at the amounts currently produced

                                It should be recognized that the risk posed to aquatic invertebrates is

                                     m°S   ^ dI
                                                                                         us
 hor»   *  * '         Pr°dUCtS t0 be harmful to a^uatic invertebrates
 because the target species is itself an aquatic invertebrate.  The mosquho
 larvicide product containing furanones would cause less harm to aquatic
 ecosystems than many other products because its risk is limited to aauatic
 invertebrates, whereas others pose a risk to fish and birds^well

      To lessen the risks to aquatic invertebrates posed by furanones used
as mosquito larvicides EPA is imposing a production limit on fur^one for
use in mosquito larvicides of 150 gallons per year.  Should the volume
produced and used and/or the percent of furanone in the product
significantly increase, the Agency would impose the following additional
data requirements to understand and assess potential risks:

          161-1, Hydrolysis
          161-2, Photodegradation in Water
          162-3, Anaerobic Aquatic Metabolism
          162-4, Aerobic Aquatic Metabolism
          163-1, Leaching/Adsorption-Desorption
          164-2, Aquatic Field Dissipation

                                   72-4(b), Life Cycle Invertebrate


                                 f 8fnCyfaIS° is requirinS Product-specific data including product
                        Fo    ,   ™?  6,tOX1Clty StUdiCS' fevised C^dential Statements of
                        Formula (CSFs), and revised labeling for registration.

Product Labeling        All furanone end-use products must comply with EPA's current
          Changes   Pesticide product labeling requirements and wim the folbwing Tor a
          Required      Pnsive Iist of Deling requirements, please see the fufanone RED

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                      The manufacturing use product (MP) labeling must be revised to
                 comply will all current EPA regulations, PR Notices and applicable
                 policies.  The MP labeling must bear the following statement under
                 Direction For Use:
                      "Only for formulation into an [fill blank with Insecticide, Herbicide
                      or the applicable term which describes the type of pesticide use(s)]
                      for the following use(s)[fill blank only with those uses that are being
                      supported by the MP registrant."
                 An MP registrant may, at his/her discretion, add one of the following
                 statements to an MP label under
 Regulatory
Conclusion
      "Directions for Use" to permit the reformulation of the product for a
      specific use or all additional uses, supported by a formulation or user
      group:

(a)   "This product may be used to formulate products for specific use(s)
      hot listed on the MP label if the formulator., user group, of grower
      has complied with U.S. EPA submission requirements regarding
      support of such use(s)."
(b)   "This product may be used to formulate products for any additional
      use(s) not listed on the MP label if the formulator, user group, or
      grower has complied with U.S. EPA submission requirements
      regarding support of such use(s)."

End-use products without the mosquito larvicide use must bear the
following statement:

          . "Do not apply directly to water,  or to areas where, surface
           water is  present or to interidal areas below the mean high-water
           mark. Do not contaminate water when disposing of equipment
           washwater or rinsate."

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

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                 addition to furanone and limonene will be reregistered when their other
                 active ingredients also are eligible for reregistration.
                      Environmental fate and chronic invertebrate toxicity data are not
                 available and are needed to complete the assessment of risks posed by the
               .  use of the furanones as mosquito larvicides. However, EPA is not requiring
                 additional data as long as the production of furanone for this use does not
                 exceed 150 gallons per year  Should the volume produced and used and/or
                 the percent of active ingredient in the product significantly increase the
                 Agency may impose additional data requirements in order to develop a
                 more complete data base regarding these uses of furanone.

   For More        EPA is requesting public comments on the Reregistration Eligibility
Information   Decision (RED) document for furanone during a 60-day time period as
                 announced in a Notice of Availability published in the Federal RegisW To
                 obtain a copy of the RED document or to submit written comments, please
                 contact the Pesticide Docket, Public Response and Program Resources
                ^™ V?oeld °perations Division (7506C), Office of Pesticide Programs
                (OPP), US EPA, Washington, DC 20460, telephone
                703-305-5805.
                     Electronic copies of the REID and this fact sheet can be downloaded
                  7   4»e?^de5eCiaI ^^ ^ RereSistrati°n 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  WVW.EPA.GOV.          '
                    Printed copies of the RED and fact sheet can be obtained from EPA's
               National Center for Environmental Publications and Information
               CEPA/NCEPI), PO Box 42419, Cincinnati, OH 45242-0419, telephone
               513-489-8190, fax 513-489-8695.
                    Following the comment period, the furanone RED document also will
               be available from the National Technical Information Service (NTIS)  5285
               Port Royal Road, Springfield, VA 22161, telephone 703-487-4650.  '
                    For more information about EPA's pesticide reregistration program
               toe furanone RED, or reregistration of individual products containing   '
               furanone, please contact the Special Review and Reregistration Division
               (7508W), OPP, US EPA, Washington, DC 20460, telephone
               703-308-8000.
                    For information about the health effects of pesticides, or for assistance
               m recognizing and managing pesticide poisoning symptoms, please contact
               the National Pesticides Telecommunications Network (NPTN)  Call toll
               free 1-800-858-7378, between 9:30 am and 7:30 pm Eastern Standard
               lime, Monday through Friday.

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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                     WASHINGTON, D.C.  20460
                                                                           OFFICE OF
                                                                      PREVENTION, PESTICIDES
                                                                      AND TOXIC SUBSTANCES
CERTIFIED MAIL
                                                                          JUL  2 4  |996
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 Furanone which
includes the active ingredients dihydro-5-pentyl-2(3H)-furanone and dihydro-5-heptyl-2(3H)-
furanone. The enclosed Reregistration Eligibility Decision (RED) contains the Agenpy 's
evaluation of the data base of these chemicals, 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 ingredients 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 is due 90 days from the
receipt of this letter.  The second set of required responses is 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,
Emily Mitchell at (703) 308-8583. Address  any questions on required generic data to the
Planning and Reregistration Division representative, Emily Mitchell at (703) 308-8583.
                                                     Sincerely yours
Enclosures
                                                     Lois Rossi, Division Director
                                                     Special Review
                                                     and Reregistration Division

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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, a DCI letter will be enclosed listing such requirements.  If both generic and
 product specific data are required, a combined Generic and Product Specific DCI letter will
 be enclosed describing such data.  However, if you are an end-use product registrant only and
 have been granted a generic data exemption (GDE) by EPA, you are being sent only the
 product specific response forms (2 forms) with,the RED.  Registrants responsible for generic
 data are being sent response forms for both generic and product specific data requirements (4
 forms).  You must submit the appropriate response forms (following the instructions
 provided) within 90 days of the receipt of this RED/DC! letter; 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 time extensions for product specific data
 should be submitted in the 90-day response.  Requests for data waivers must be submitted as
 part of the 90-day response.  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-D. 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, but are not
 required to, 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).

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    ,  ,d-  Two copies of the Confidential Statement of Formula (CSF) for earh h*<^ » A
"' 1- ......... g.
 sign EPA




 ggSlster Notlce which announces the availability of this RED.                 ~    •




 By U.S. MaH;


      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

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REREGISTRATION ELIGIBILITY DECISION

                  Furanone

                   LIST C

                 CASE 3138
           ENVIRONMENTAL PROTECTION AGENCY
            OFFICE OF PESTICIDE PROGRAMS
        SPECIAL REVIEW AND REREGISTRATION DIVISION

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                        TABLE OF CONTENTS
 FURANONE REREGISTRATIONELIGIBILITY DECISION TEAM . . ..	1

 EXECUTIVE SUMMARY		                .  v

 I.    INTRODUCTION	         1

 II.    CASE OVERVIEW	           .......  2
      A.   Chemical Overview  .	                           2
      B.   Use Profile '.	-.'.....	. .......... '.•'. .....'.  3
      C.   Estimated Usage of Pesticide	*'.'  4
      D.   Data Requirements	.6
      E.   Regulatory History	  6

 HI.   SCIENCE ASSESSMENT ...		 .              5
      A.   Physical Chemistry Assessment	  6
      B.   Human Health Assessment.	    9
           1.    Toxicology Assessment .	    9
                 a.    Acute Toxicity	'...... 9
                 b.    Subchronic Toxicity .	 11
                 c.    Chronic toxicity	12
                 d.    Carcinogenicity	12
      v           e.    Other Toxic Endpoints	12
                 f.    Reference Dose	13
           2.    Exposure Assessment	 13
           s      a.    Occupational and Residential  ..... ... . . .	13
           3.    Risk Assessment	 i	 14
                 a.    Occupational and Residential  f	14
      C.   Environmental Assessment	 .  . .	   .14
           1.    Ecological Toxicity Data	14
                 a.    Toxicity to Terrestrial Animals	 15
                 b.    Toxicity to Aquatic Animals	 . :	 . 17
           2.    Environmental Fate Assessment	 19
           3.    Exposure and Risk Characterization	20
                 a.    Ecological Exposure and Risk Characterization 	.20

IV.    RISK MANAGEMENT AND REREGISTRATION DECISION	26
      A.   Determination of Eligibility  ..............;	 . 26
      B.    Determination of Eligibility Decision	' ] ' 26
           1.    Eligibility Decision	26
           2.    Eligible and Ineligible Uses	27
      C.    Regulatory Position	^'. ........ 27

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       2.
                  Endangered Species Statement  . ..............           28
V.
 ACTIONS REQUIRED OF REGISTRANTS  	  !                       28
 A.    Manufacturing-Use Products	      	     28
      1.    Additional Generic Data Requirements	 28
      2.    Labeling Requirements for Manufacturing-Use Products         29
      End-Use Products	                 	3Q
      1.    Additional Product-Specific Data Requirements .... . .         30
      2.    Labeling Requirements for End-Use Products         	30
      Existing Stocks  	              	,1
      B.
      C.
VI.
                                                                          33
APPENDICES  .......................
f^^SSIX  A*    TaWe °f Use Patterns Subject to Reregistration  . .        34
APPENDIX  B.    Table of the Generic Data Requirements and Studies Used to
      Make the Reregistration Decision ..........                      40
                  Citations Considered to be Part of the Data Base Supporting the
                                                                     AQ
                                       ''''''''''''''''
      APPENDIX C.
           Reregistration of Furanone
      APPENDIX D.    Generic Data Call-in	
           Attachment  1.    Chemical Status Sheets	  	74
           Attachment  2.    Generic DCI Response Forms Inserts (TForm A)  plus
                 Instructions	                     7-
           Attachinent  3.    Requirements Status and Registrants'Response Forms
                 Inserts (Form B) plus Instructions                            73
     APPEl^T1*  t A  ^ rf ***«*« ^nt this DCI ansert)  . . . . . \ 83
     APPENDIX E.    Product Specific Data Call-In                          85
           Attachment  1.    Chemical Status Sheet                          99
           Attachment  2.    Product Specific Data Call-in Response Forms (Form A
                 inserts) Plus Instructions	                IOQ
           Attachment  3.     Product Specific Requirement Status and Registrant's
                 Response Forms (Form B inserts) and Instructions              102
           Attachment  4.     EPA Batching of End-Use Products for Meeting Data
                 Requirements for Reregistration	          109
           Attachment  5.     List of Registrants) sent this DCI (Insert)	  111
           Attachment  6.     Cost Share, Data Compensation Forms,  Confidential
                 Statement of Formula Form and Instructions                  112
     APPENDIX  F.     List of Available Related Documents ..'.'.'.'.'.'.'.'. .      n8

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FURANQNE REREGISTRATION ELIGIBILITY DECISION TEAM

Office of Pesticide Programs:

Biological and Economic Analysis Division
Alan Halvorson
William Gross
Thomas C. Harris

Environmental Fate and Effects Division

Mary Powell
Nick Mastrota
James Hetrick

Health Effects Division  .

John Redden
LinneaHansen
Winston Dang

Registration Division

Mark Perry
Sami Malak
Beth Edwards

Special Review and Reregistration Division

Emily Mitchell
Barbara Briscoe
Economic Analysis Branch
Biological Analysis Branch
Biological Analysis Branch
Science Analysis and Coordination Staff
Ecological Effects Branch
Environmental Fate and Gfoundwater Branch
Risk Characterization and Analysis Branch
Toxicology Branch I
Occupational and Residential Exposure Branch
Registration Support Branch
Registration Support Branch
Insecticide-Rodenticide Branch
Planning and Reregistration Branch
Planning and Reregistration Branch
Policy and Special Projects Staff

Jean Frane
Office of Compliance Monitoring:

Phyllis Flaherty
Pesticides Enforcement Policy Branch:

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11

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 ADI
 AE
 a.i.
 ARC
 CAS
 CI
 CNS
 CSF
 DFR
 DRES
 DWEL
 EEC

 EP
 EPA
 FDA
 HERA
 FFDCA
 FOB
 GLC
 GM
 GRAS
 HA

 HOT
 LC™
 LD,
LD10
LEL
LOG
LOD
LOEL
MATC
MCLG

Mg/g
mg/L
MOE
MP
MPI
MRID
N/A  '
NOEC
NPDES
GLOSSARY OF TERMS AND ABBREVIATIONS

   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, nori 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
   National Pollutant Discharge Elimination System
                                                111

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              GLOSSARY OF TERMS AND ABBREVIATIONS
  NOEL
  NOAEL
  OP
  OPP
  PADI
  PAG
  PAM
  PHED
  PHI
1  ppb
  PPE
  ppm
  PRN
  Q*.
 RBC
 RED
 REI
 RfD
 RS
 SLN
 TC
 TD
 TEP
 TGAI
 TLC
 TMRC
 torr
FAO/WHO
WP
WPS
  No Observed Effect Level
  No Observed Adverse Effect Level
  Organophosphate          ,
  Office of Pesticide Programs
  Provisional Acceptable Daily Intake
  Pesticide Assessment Guideline
  Pesticide Analytical Method
  Pesticide Handler's Exposure Data
  Preharvest Interval
  Parts Per Billion
  Personal Protective Equipment
 Parts Per Million
 Pesticide Registration Notice
                      ial °f a C°mpOUnd' Quantified ^ *e EPA's Cancer Risk Model

 Reregistration Eligibility Decision
 Restricted Entry Interval
 Reference Dose
 Registration Standard
 Special Local Need (Registrations Under Section 24 (c) of FIFRA)
 Toxic Concentration. The concentration at which a substance produces a toxic effect
 loxic Dose. The dose at which a substance produces a toxic effect
 Typical End-Use Product
 Technical Grade Active Ingredient
 Thin Layer Chromatography
 Theoretical Maximum Residue Contribution

 £j? °H A"*8"? Me?d t0 SUPP°rt a C°lumn of mercury 1 mm fogh «nder standard conditions
 Food and Agnculture OrganizationAVorld Health Organization                   conoiuons.
 Wettable Powder
Worker Protection Standard
                                              IV

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 EXECUTIVE SUMMARY
        This Reregistration Eligibility Decision Document (RED) addresses the reregistration
.eligibility of two active ingredients: dihydro-5-pentyl-2(3H)-furanone and dihydro-5-heptyl-
 2(3H)-furanone (also known as gamma-nonalactone and gamma-undecalactone, respectively).
 Both of these active ingredients are also referred to by the common name furanone.  Products
 containing  furanones are registered for use as insecticides,  repellents, mammal repellents and
 mosquito larvicides.

        The Agency first registered a product containing furanone in 1983 for use as a cat
 repellent. Later, the Agency registered six additional products as insect toxicants, including use
 as a mosquito larvicide, or repellents. At present, there are seven furanone products, which are
 all registered as mixtures with the active ingredient, limonene (Case 3083). The Agency issued
 a Reregistered Eligibility Decision (RED) on limonene in September 1994.  One of the seven
 products also contains a third active ingredient, Aliphatic Petroleum Hydrocarbons.

        The Agency has determined that all uses of furanone products, labeled and used  as
 specified in the RED, will not pose unreasonable risks to humans or the environment  and,
 therefore, are eligible for reregistratipn.

        Acute toxicity tests to assess both human toxicity and toxicity to non-target organisms
 were conducted on a  formulated product containing : .024% dihydro-5-pentyl-2(3H)-furanone,
 .049% dihydro-5-heptyl-2(3H)-furanone, and 4.015% limonene. No toxicity data are available
 on the technical.                                              .

        Acute  oral, dermal, and inhalation toxicity studies indicate low acute toxicity (Category
IV).   Likewise,  eye and dermal irritation studies also classified  the formulated product  in
Category IV.  The product also is not a skin sensitizes  Data from the open literature on each  of
the two compounds considered, the furanones, indicate low toxicity.

       Acute toxicity data indicate that the formulated product is practically non-toxic to birds
(oral,  subacute dietary),  .mammals, and freshwater  fish.  The product is slightly toxic  to
freshwater invertebrates.

       The furanones, when used jn mosquito larvicides, are applied directly to water (residential
and large scale public health use.)  The public health larvicidal use of furanones applied at 4.10
Ibs/A  to  6  inches  of water results in exceedances of the level of concern for freshwater
invertebrates.  The LOG for endangered species is exceeded when the product is applied at 1.64
Ibs/A in water 6 inches deep or less, or when it is applied at 4.10 Ibs/A in water 1 foot deep or
less.  This assessment is based on testing done on a formulated product and tells little about the
actual toxicity of the furanones as active ingredients. Chronic invertebrate toxicity data (life cycle
test with a freshwater invertebrate) and basic environmental fate data

-------
 would improve the Agency's understanding and assessment of the potential risk posed by the use
 of the furanones m mosquito larvicides.                 .
 i< low           v°lume^Products containing furanones that are used as mosquito larvicides
 £ ™   f ? P61061*3*6 of taone in the products is also low. The low volume used and low
 percent of furanone support the conclusion that widespread adverse impacts are not likely to

 aX~r&^^
 production Hmit on furanone L use in mosqui^Scide 5 'l£££ ™ y
 volume product and used and/or the percent of furanone in the pfoduct s£ficanth  toae
 the. Agency may impose additional data requirements to understand and assfss potentials

       It should be recognized that the risk posed to aquatic invertebrates is common to most

               ^ ****" USe'  ft 1S the natUfe °f mos^to larvicide« to be harmfu?to aquatic
            because the target species is itself an aquatic invertebrate  The mosquito

           ^^               ld CaUSC I6SS ha™ to *^c ecosysTels Z m
                               3qUatiC invertebra^' **ereas others pose a risksh
       Before reregistering the products containing furanone, the Agency is requiring that oroduct
specific data, revised Confidential Statements of Formula (CSF) and 1 revised ?abeHn?lx ^subrnkted
within eight months of the issuance of this document.  These data incluS ^producfche^ for
each lustration and acute toxicity testing. After reviewing these d fa^y ^ M ^SlTa^d
finding them actable in accordance with Section 3(c)(5) of FIFRA, the Agen^ wHl rerelTer
a product   Those  products which contain other  active ingredients^ I™ £ TelSf for

                        *" Other  "^  in              "etermilt £ ^ !  for
                                       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 furanone.   The  document consists  of six sections. Section I is the
introduction. Section II describes furanone, its uses, data requirements and regulatory history
Section IE discusses the human health and environmental assessment based on the data available
to the Agency. Section IV presents the reregistration decision for furanone . Section V discusses
the reregistration requirements for furanone . 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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H.    CASE OVERVIEW




      A.    Chemical Overview




      Decision^ ^U°Wing active ingredient(s) are covered by this Reregistration Eligibility





      +     Common Name:          Furanone




      +     Chemical Name:          Dihydro-5-pentyl-2(3H)-furanone



      +    Alternate Name:          gamma-nonalactone



      +    CAS Registry Number:    104-61-0




     *    OPP Chemical Code:      122301



     *     Empirical Formula:       CgHj^




     *     Trade and Other Names:   Doo-Not




     *     Basic Manufacturer:       Rod Products Company
           Common Name:



           Chemical Name:



           Alternate Name:
Furanone




Dihydro-5-heptyl-2(3H)-furanone



gamma-undecalactone
          CAS Registry Number:    104-67-6




          OPP Chemical Code:      122302




          Empirical Formula:       CnH20O2




          Trade and Other Names:   Doo-Not




          Basic Manufacturer:       Rod Products Company

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B.     Use Profile

       The following is information on the currently registered uses for furanone. A
detailed table of eligible uses as well as the methods, application rates, and use restrictions
is included in Appendix A.

       For: dihydro-5-pentyl-2(3H) furanone
       For: dihydro-5-heptyl-2(3H) furanone

       Type of Pesticide:   Insecticide/repellent, mammal repellent, mosquito larvicide

Currently registered products, containing these chemicals, have the following uses:

             1) dog and cat repellent;
             2) fly, cockroach and ant killer;
             3) insect repellent;
             4) insect repellent strip;
             5) insect repellent tablecloth; and
             6) mosquito larvicide (contains mineral oil).


       Use Sites:    Terrestrial. Non-Food & Outdoor Residential
\ '                         ~              '•             ' '      •

       Target Pests: cats, dogs, house flies, cockroaches, ants, biting flies, mosquito
                    adults and larvae
      Formulation Types Registered:    Granular
                                      .  Liquid Ready-to-use
                                        Impregnated Material
                                        Emulsifiable Concentrate
                               .         Pressurized Liquid

      Percentage of the three AIs in all formulations

             Active Ingredient    Weight Percentage in formulations

             d-Limonene                4.015%
             gamma-Undecalactone      0.049%
             gamma-Nonalactone         0.024%

      There are no formulations that contain the furanones alone.

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         Method and Rates of Application:
               Equipment -
               Method and Rate -
       Use Practice Limitations:
  Hand,  pre-moistened  applicator  puffs,   aerosol
  sprayers,  non-aerosol  hand   pumped  sprayers,
  hydraulic ground sprayers, aircraft, compressed air
  sprayers and knapsack.

  Furanone may be applied by the use of impregnated
  table cloths, premoistened applicator puffs, aersol
  sprayers,  non-aerosol  hand   pumped  sprayer,
  knapsack sprayers, and the granules may be applied
  by hand by .sprinkling from the bag.

  Some product  labels  do not provide  adequate
  information to calculate rates;  however, for those
  that can be calculated they are as follows:
  granules are applied at rates of 0.002 Ib ai/1000
  square feet, and for the emulsifiable concentrate for
  mosquito larvae control, the rates range from 0 0393
  to 0.0984 Ibai/acre.

  Product  labels  do  not  give specific  timing of
  application of this product.  The language  reads-
.  "when needed."

 Do not apply directly to treated, finished drinking
 water  reservoirs or drinking  water  receptacles.
 Avoid application to man-made surfaces sensitive to
 mineral oils.
C.    Estimated Usage of Pesticide

       This section summarizes the best estimates available for the pesticide uses of
furanone.  These estimates  are derived from a variety of published and proprietary
sources available to the Agency.  The data, reported on an aggregate and site (crop' basi7
reflect annual fluctuations m use patterns as well as the variability in using data from
various information sources.

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."..-.. The table below summarizes the pesticides use by site.
Estimated Typical Annual Usage of Furanone (Dihydro-5-pentyl-2(3HMuranone and 5-HeDtvIdihvdrn-2ttHVf,,rannn.>l

Drainage systems
Eating establ incl servg areas
Flooded areas, intermittent
Food marktg/storg/distr facils
Food proc/hndl/stor pits/areas
Garbage dumps/manure
Households, indoor/outdoor
Human body/hair/clothg/footwr
Lakes/ponds/impounded water
Omarri herbaceous plants/lawns
Omam ponds/fountains/aquaria
Paved areas
Recreation areas
Refuse/solid waste containers
Swamps/marshes/bogs/stdg water
Wide area/gen indr/outdr trtmt
TOTAL
Site
Available
(000)
na
na
na
na
na
na
90.000H
250.000P
na
30.000A
na
na
na
na
na
na
na
Site Treated
(000)
na

na •



OOH
<2SOP
na
<30A



na


na
(%)
<1
<1
<1
<1
<1
<1
<1
<1
<1

<1
<1
<1
<1
<1

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 probably considerably less than one percent of available recreation areas, however measured are
 treated with furanone.

        D.    Data Requirements

              Data requested in the Phase IV Data Call-in Notice(s) for furanone (dihydro-5-
        pentyl-2(3H)-furanone and dihydro-5-heptyl-2(3H)-furanone) include studies on product
        chemistry and environmental fate.  These data were required to support the uses listed
        in the Phase IV Data Call-in Notice(s), dated July 27,1992. Appendix B includes all data
        requirements identified by the Agency for currently registered uses needed to support
        reregistration.                                                            v*

       E.     Regulatory History

              The Agency first registered a product containing furanone in 1983 for use as a
       dog and cat repellent. Later,  the Agency registered six additional products as insect
       toxicants, including use as a mosquito larvicide, or repellents.  At present, there are seven
       furanone products, which are all registered as mixtures with the active ingredient
       hmonene (Case 3083). The Agency issued a Reregistration Eligibility Decision (RED)
       on hmonene in September 1994.  One of the seven products also contains a third active
       ingredient, Aliphatic Petroleum Hydrocarbons.

             The compounds dihydro-5-heptyl-2(3H)-furanone  (also known  as gamma-
       undecalactone)  and  dihydro-5-pentyl-2(3H)-furanone  (also  known  as  gamma-
       nonalactone) are compounds that appear on the 'GRAS' ("generally recognized as safe")
       list of the Expert Panel of the Flavoring Extract Manufacturers' Association of the United
       States (FEMA).  These same compounds are not on the FDA 'GRAS' list but are
       approved as food additives by the FDA.                                  '

IH.    SCIENCE ASSESSMENT

       A.     Physical Chemistry Assessment

             The following physical/chemical property information was extracted from MRID
      No. 240229307 (Product Chemistry) and is supplied as background material, and from
      two monographs in Food and Cosmetics Toxicology (FD Cosmet Toxicol Vol 12 889
      and 921 1975).                                                            '

            The data for the active ingredients were extracted from the Food Chemicals Codex
      f ** ^ °n pages 456> 457> 844> 845>553 ™d 554. The first active, dihydro-5-heptyl-
      2(3H)-furanone, is referred  to as  Undecanoic acid, 4-hydroxy, gamma-lactone by the
      registrant. The active ingredient product name is gamma-Undecalactone. The second
      active dihydro-5-pentyl-2(3H)-furanone (on submitted material this active ingredient is

-------
       referred to as: 2(3H)-furanone dihydro-5-pentyl; MW=156.25) is synonymous to gamma-
       Nonalactone (active ingredient product name).

       dihydro-5-heptyl-2(3H)-furanone Properties
       o
       o
       o
       o
       o
       o
       o
       o
       o
       o
       o
       o
M.W. - 184.31
Color - colorless to yellow
Odor - strong fruity odor suggestive of peach
Melting point - liquid, not applicable
Sqlubility -   60% alcohol in water - 20% soluble
             70% alcohol in water - 33% soluble
             Insoluble in water
Stability - stable under all normal conditions
Octanol/water partition coefficient - not available
Physical state - liquid
Density - 0.942 - 0.945
Vapor Pressure - not available
pH - not available
Structural Formula:  CH3(CH2)6 CH CH2CH2
                                          O-
                                    •c=o
Extracted from Food and Cosmetics Toxicology Volume 13, 921,1975.

-------
 dihydro-5-pentyl-2(3H) furanone Properties
 o
 o
 o
 o
 o
              M.W. - 156.25
              Color - colorless to yellow
              Odor - strong odor suggestive of coconut
              Melting point - liquid, not applicable
              Solubility -   50% alcohol in water - 20% soluble
                          60% alcohol in water - 33% soluble
                          Insoluble in water
              Stability - stable under all normal conditions
              Octanol/water partition coefficient - not available
              Physical state - liquid
              Density - 0.958 - 0.966
              Boiling point - 243 °C
             Vapor Pressure - not available
             pH - not available
             Structural Formula:  CH3(CH2)4 CH CH2CH2



Extracted from Food and Cosmetics Toxicology Volume 13, 889,1975.
o
o
o
o
o
o
o
o

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B.
Hunian Health Assessment
       1.     Toxicology Assessment

             The  lexicological  data  base on  furanones  is  adequate  to  support
       reregistration eligibility for dihydro-5-pentyl-2(3H)-furanbne (PC CODE: 122301
       synonymous to gamma-Nonalactone) and dihydro-5-heptyl-2(3H)-furanone (PC
       CODE: 122302 synonymous to gamma-Undecalactone).
             a.     Acute Toxicity

             ACUTE TOXICITY DATA FOR FURANONES
'tfeS? ' " ""
Oral LDSO-rat, Monogram Animal Repellent #100(Limonene) '
Dermal LD50— rabbit, Monogram Animal Repellent
#100(Limonene)J
Inhalation LC50— rat, Monogram Animal Repellent
tflOOCLimonene)1
Eye irritation-rabbit, Monogram Animal Repellent
fllOOCLimonene)1
Dermal irritation—rabbit, Monogram Animal Repellent
#100(Limonene)'
Dermal sensitization— Guinea pig, Monogram Animal Repellent
#100(Limonene)1
&ESTILTS
LD50 > 5 gm/kg
LD50 of dry formulation
> 5 gm/kg
LC50 > 5 mg/1, using
particle size of 297
microns or less.
PIS - Washed = 0.0. PIS -
Unwashed = 0.0
PIS = 0.0
Primary Irritation Score
No sensitization using -
draize technique
"CATEGORY
IV
IV
IV
IV
IV
—
containing furanones also contain limonene.
                   It should be noted that only acute studies On formulations were
             conducted to support the reregistration of gamma-Undecalactone and
             gamma-Nonalactone.  There are no toxicity data available on the technical.
             Toxicity data on the two compounds which comprise the furanones are
             available from the open literature and are discussed below:

                   The following was extracted from two monographs that appeared
             in Food and Cosmetics Toxicology (FD. Cosmet. Toxicol. Vol. 12, pp 889
             and 921, 1975).

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  gamma Nonalactone:

  "The acute oral LD50 in rats and guinea pigs was reported as 9 78
  and 3.44  g/kg, respectively (Jenner, Hagan, Taylor, Cook &
  Fitzhugh,  1964). The acute oral LD50 in rats was reported as 6 6
  g/kg (5.8-7.4 g/kg) (Moreno, 1972a).  The acute dermal LD50 in
  rabbits exceeded 5 g/kg (Moreno, 1972b)."

        Based on this information the toxicity category established in both
  rat studies, for nonalactone, would  be IV for acute oral toxicity   The
  toxicity category based on the guinea pig acute oral LD50 study would be
  III for nonalactone.

  "Nonalactone applied full strength to intact or abraded rabbit skin
  for 24 hr under  occlusion was slightly irritating (Moreno, 1973b)
  Tested at 10% in petrolatum.  It produced no irritation after a 48 hr
  closed-patch test  on human  subjects (Kligman   1972)    A
  maximization test (Kligman, 1966: Kligman & Epstein, 1975) was
  carried out on 25  volunteers.   The material  was  tested  at a
  concentration of 10% in petrolatum and produced no sensitization
  reactions (Kligman,  1972)."

 gamma Undecalactone:

 "The acute oral LD50 in rats  was reported as 18.5 g/kg (Jenner
 Hagan, Taylor, Cook & Fitzhugh. 1964). Fatty infiltration of liver
 parenchymal cells  occurred in rats fed  13-115  mg  gamma-
 undecalactone for 5-9 days (Shillinger, 1950)."

 "Gamma-Undecalactone tested at 2% in petrolatum produced no
 irritation after  a 48-hr closed-patch test on human  subjects
 (Kligman, 1971). A maximization test (Kligman, 1966; Kligman
 & Epstein, 1975) was carried out on 25 volunteers. The material
 was tested at a concentration of 2% in petrolatum and produced no
 sensitization reactions (Kligman, 1971)."

      The acute oral LDSO in rats for  undecalactone would be classified
 as toxicity category IV. The studies  on undecalactone are classified as
 Supplementary  as they are from the open literature.

      However, they offer valuable information for the evaluation of the
toxicity  of the  furanones because these  data  indicate that the two
compounds that make up the furaaones are of low acute toxicity
                      10

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  b.     Subchronic Toxicity

        In an open literature study (Fd Cosmet. Toxicol. Vol. 3, pp. 563-
  569.  Pergamon  Press  1965) gamma-Undecalactone  and  gamma-
  Nonalactone were two of 23 flavoring compounds that were examined in
  subchronic feeding studies.

        Fifteen female FDRL and fifteen male FDRL rats were fed the
  following for 90 days:  females were fed 14.6 mg/kg body weight/day
  gamma-undecalactone  and  62.8  mg/kg  body  weight/day  gamma-
  nonalactone; males were fed. 16.5 and 72.5  mg/kg body  weight/day
  gamma-undecalactone and gamma-nonalactone, respectively.

        Body weight,  food consumption,  haematological  and  blood
  chemical determinations were made on 8 rats of each sex after 6 weeks of
  dosing, and in all rats at 12 weeks. The study was terminated after 90 days
  and tiie rats were necropsied.  Liver and kidney weights were recorded for
  all rats. The following organs from half me animals in each  group were
 taken for histological examinations: liver, kidneys, stomach, small and
 large  intestines, spleen,  pancreas,  heart, lungs, bone marrow, muscle,
 brain, spinal cord, bladder, adrenals/thyroid, pituitary, gonads, salivary
 glands, and lymph nodes.                                   '

       The study authors conclusions are presented below and the Agency
 agrees with their assessment:

       "No significant gross pathological change was observed at
       autopsy in any rats...Several of the animals in  the groups
       receiving the lactones (L,M,N)..:.show various  degrees of
..   ~  . mild thyroid hyperplasia but this observation was also noted
       in the .corresponding control groups and is not uncommon
       finding in these laboratories."

       "90-Day feeding studies in groups  of rats receiving dietary
       doses of any of 23 different flavouring matters at levels
       corresponding to at least  100 times the maximum estimated
       human dietary levels, revealed no evidence of adverse toxic
       effects."
       Since this is an open literature study it  must be core graded
Supplementary.  However, it supplies useful information in evaluating
the potential hazard of the furanones in that compounds making up the
                      11

-------
  furanones did not demonstrate  a hazard following subchronic oral
  administration.

  c.     Chronic toxicity                                         •

        The following was extracted from two monographs that appeared
  in Food and Cosmetics Toxicology (FD. Cosmet. Toxicol Vol  12 DD 889
  and 921, 1975).                                        '  .'.

  Nonalactone:

        "...In another study 0.1-0.5% fed to groups of 20 male and
        female rats in the diet for 2 yr produced no effects (Bar &
        Griepentrog. 1967)."

  Undecalactone:

        "...Groups of 20 male and 20 female rats were fed diets
        containing 0.1 or 0.5% gamma-undecalacone for 2 yr
        without any specific adverse effects (Bar & Griepentroe
        1967)."                                           5'

        These studies are classified as Supplementary as they appear in
 the open literature.  However, they offer valuable information for the
 determination of the toxicity  of the furanones  in that the compounds
 making up the furanones did not demonstrate a hazard following chronic
 oral exposure.

 d.      Carcinogenicity

       No effects were  observed in a 2 year rat study  where rats  were
 administered  0.10% to 0.5% furanones in their diet  (Bar  F  U
 Griepentrog. F. (1967)).
e.
Other Toxic Endpoints
       The Agency has determined that a 90-day dermal toxicity (safety)
study would be required for a product that may result in prolonged human
dermal exposure through repeated skin applications. The Agency has
decided to waive the requirement for the 90-day dermal toxicity for the
furanones based on the following :  a combination of low exposure to
furanones in the product; comparable concentrations of tanols in this
product to those already used in cosmetic products (lotions, detergents
                      12

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       perfumes); naturally occurring compound and absence of toxicity in the
       toxicology studies (notwithstanding limited data).  Also, although not a
       FDA GRAS chemical, furanone is approved by FDA as a food additive
       and exposures to low concentrations are considered safe.
       f.     Reference Dose

             There are no registered food uses for the furanones. The Agency's
       Peer Review Committee has not considered the furanones.  The Joint
       FAO/WHO  Expert Committee  on  Food  Additives  established  an
       unconditional ADI of 0-1.25 mg/kg for undecalactone and nonalactone.
2.    Exposure Assessment

      a.     Occupational and Residential

             For the following reasons the Agency  has no  concerns  for
      occupational or residential exposure to the furanones:  1) the acute battery
      for the furanones indicate toxicity category IV;  and 2) the furanones are
      only  in formulations containing limonene and  the percentage  in
      formulations is less than 1%.

             However,  there is a concern that repeated  high dose dermal
      exposure to limonene may cause dermal sensitization based on a two week
      preliminary  study for a rat 90 day dermal  toxicity study.   The data
      demonstrated that dermally applied technical limonene at 500,  1000, or
      1500 mg/kg/day produced excessive dermal irritation after 1-3 days of
      dermal application. No overt treatment related systemic toxicity or clinical
      signs were observed.

            Since these effects occur after repeated high dose administration
      of limonene, for  purposes of reregistration, the following from the
      Limonene RED, applies to the tanol derivatives:
            "The primary toxicological concerns for humans are dermal
            irritation and/or sensitization from dermal exposure at high
            concentrations. Systemic toxicity is not expected to occur
            from pesticide uses since dermal irritation, which occurs at
            high doses, results in self-discontinuation of product use."
                           13

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                     Thus, since the most noted dermal effect would be self limiting
               dermal irritation resulting from the limonene and not the furanones  the
               Agency does not anticipate occupational or residential risks of concern
               from exposure to the furanones.

        3.      Risk Assessment

               a.     Occupational and Residential

                     For the reasons discussed above, the  Agency does not anticipate
              occupational or residential  risks of  concern from  exposure to the
              furanones. However, as the furanones are only in formulations containing
              hmonene, the following from the limonene RED applies to the furanones:

                     "Human exposure may occur during application of animal
                     repellent granules or insect spray, or use of impregnated
                     tablecloths. The tablecloth product containing limonene to
                     repel insects was exempted from tolerances.  Toxicological
                     concerns for humans from exposure to limonene are dermal
                    irritation and  sensitization.  Systemic toxicity is not
                    anticipated to occur at doses below the threshold for dermal
                    irritation. Exposure to limonene would be discontinued if
                    dermal  irritation  occurred  and  therefore  self-limiting.
                    Ocular irritation may also occur if products are accidently
                    placed in the eye and not washed away."

                    "Additional precautionary statements on label are required
                    to reduce adverse effects."

C.    Environmental Assessment

      1.     Ecological Toxicity Data

             The term "furanones" will be used to refer to the two related chemicals
      covered  by this RED:  dihydro-5-pen1yl-2(3H)-furanone and  5-heptyldihydro-
      2(3H)-furanone. All of the formulated products containing these furanones also
      contain a third active ingredient, limonene. All of the toxicity data for furanones
      are tor one formulated product, Doo-Not Dog & Cat Repellent (Reg No 45987-
      1), containing the three active ingredients in the following concentrations'
                                  14

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PC Code "
122301
122302
079701
...£ - Nam^ % '"
Dihydro-5-pentyl-2(3H)-furanone
5-heptyldihydro-2(3H)-furanone
Limonene
' %Ll
0.024%
0.049%
4.015%
       The other registered formulations containing furanones contain the same
 set of active ingredients  as Doo-Not in identical concentrations,  although
 Rodspray Mosquito Larvicide (Reg. No. 45987-6) also contains 22.94% white
 mineral oil as a fourth active ingredient.

       There are adequate data to assess Hie hazard of the formulated product
 Doo-Not,  as well  as  otiier products that contain  furanones in  identical
 concentrations as Doo-Not and have low-volume minor uses. Only the six basic
 studies are required for these  use patterns because they  are expected to result in
 low exposure to the environment.  The mosquito larvicide use is exceptional in
 that it may result in relatively  large exposures to aquatic habitats. An additional
 chronic aquatic invertebrate study on the technical grade of the active ingredient
is needed to clarify the Agency's understanding and assessment of the potential
nsk posed by the use of furanone as a mosquito larvicide.

       a.     Toxicity to Terrestrial Animals

             (1)     Birds, Acute and Subacute

                    To establish the toxicity of furanones to birds, the following
             tests are required using the technical  grade material:  one avian
             single-dose oral (LD^ study on one species (preferably mallard or
             bobwhite quail); two subacute dietary studies (LC50) on one species
             bf waterfowl (preferably the mallard duck) and one species of
             upland game bird preferably bobwhite quail).  Data that have been
             submitted for these three tests have been with a formulated product,
             not  the technical grade material.  The following tables show the
             results of these tests.
                            15

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.• -*»$
Species
Northern
Bobwhitc
^%k-J ,' -"X;>
V.A.I.-
4.0 15% 079701
0.024% 122301
0.049% 122302
)•,, '^ v "A»*t«AHrti»<^r«(j;j1o^jciry^»dssg$ '''' j.
LDj, mg/kg
>2000
MRIDNo.
Author/Year
109340
Bottoms, J. (1982)
Toxicity Category
The formulated product is
practically nontoxic
Active mgreaients are listed by their Shaughnessey numbers. 	 ' 	 '
Fulfills Guideline
Requirement
Yes, for the formulated
product Doo-Not Dog
Repellent

^ v tJJ^T^J
Species
Northern
Bobwhitc
Mallard
^S?%
%A.I,
4.0 15% 079701
0.024% 122301
0.049% 122302
4.0 15% 079701
0.024% 122301
0.049% 122302
\ %>S, '"" "••"
itCff ppm
>5000
>5000
;«% '" ' ' 	 "'" 	 "";;iN'JNM|....iu mi, M..i....ni,,,,,,,M.u.,m, I.M.I,,., 	 M,,,,,,,,,,..|
MRIDNo.
Author/Year
109342
Bottoms, J. (1982)
109341
Bottoms,!. (1982)
Toxicity Category
The formulated product is
practically nontoxic
The formulated product is
practically nontoxic
Active ingreaicms are listed by their Shaughnessey numbers. 	 ' 	 l
Fulfills Guideline
Requirement
Yes, for the
formulated product
Doo-Not Dog
Repellent
Yes, for the
formulated product
Doo-Not Dog
Repellent

       These results indicate that the formulated product Doo-Not
 Dog Repellent is practically nontoxic to avian species on an acute
 oral and subacute dietary basis (MRID 109340-109341).  However,
 since this  product contains only  a .small  percent  of active
 ingredient, it cannot be inferred from these results that furanones
 are practically nontoxic. If the furanones caused all of the toxicity
 of the formulated product, an estimated acute oral LD50 of the
 furanones for avian species would  be >1.46 mg ai/kg and an
 estimated subacute dietary LC50 would be >3.65 ppm ai.  These
 results tell little about the actual toxicity of the furanones as active
 ingredients.   Furanones  may  fall  into  any  of five toxicity
 classifications.

 (2)   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.
               16

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                           The oral rat LD50 for Dpo-Not Dog & Cat Repellent (Reg.
                     No. 45987-1) is. >5 g/kg (Accession No. 245190).  This result
                     indicates tiiat Ihis formulated product is practically nontoxic, but it
                     tells little about the toxitity of furanones as active ingredients.  If
                     all of the toxicity of the formulated  product was caused by the
                     furanones, an estimated acute oral LD50 of the furanones for avian
                     species would be >3.65 mg ai/kg. Furanones thus may fall into any
                     of five toxicity classifications.

                     Toxicity to Aquatic Animals

                     (1)    Freshwater Fish
                                   .  ' '           '             p            '
                           To establish the toxicity of'a pesticide to freshwater fish, the
                     minimum  data required on the technical grade of Ihe 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).  Data that have been submitted for these two tests have
                     been with a formulated product, not the technical grade material.
                     The following table shows the results of these tests.
>-, ,,,. . -v
Species
Rainbow trout
- Fathead minnow

HA*
4.0 15% 079701
0.024% 122301
0.049% 122302
4.0 15% 079701
0.024% 122301
0.049% 122302
'" \ '" "
LCj, ppm a.i.
569*
1490*
^',L*\0.42 ppm a.i. for the rainbow trout and >1.1 ppm a.i. for the
                    fathead minnow.  These results tell little about the toxicity of the
                    furanones as active ingredients. Furanones could fall into  any
                                   17

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 toxicity classification  except very highly toxic.  (MRID  No.
 109343)                                           *

       Because the tests were conducted with formulated product
 raflier than technical grade active ingredients, they do not fulfill the
 guideline requirements for furanones.  However, these data are
 considered adequate for assessing the risk of the use of the Doo-
 Not product.  They may also be adequate for other low-use
 products that contain furanones in identical concentrations.

 (2)    Freshwater Invertebrates

       The minimum testing  required to assess the hazard  of a
 pesticide to freshwater invertebrates  is a freshwater aquatic
 invertebrate toxicity test, preferably using first instar Daphnia
 magna or early instar amphipods, stoneflies, mayflies, or midges.
 Data that have been submitted for a test with Daphnia magna have
 been with a formulated product, not the technical grade material.
 The table below gives the results of these tests.
*- .^r?;
Species
Daphnia magna
"• s *• O>- >f-
%AX-
4.0 15% 079701
0.024% 122301
0.049% 122302
^^^^^m^^: * *' """V ; ' -- ""' ''
EC,.
(ppm)
If
MRID NO.
Author/Year
109345
Bottoms, J. (1982)
Toricity
Category
The formulated
product is
slightly toxic
Fulfills Guideline
Requirement
Supplemental, for
formulated product Doo-
. Not Dog Repellent
Result is based on the moving average method.
       There  is  sufficient  information to  .characterize  the
formulated product containing furanones as slightly toxic to aquatic
invertebrates (MRID  109345).   However, since this product
contains only a small percent of active ingredient, it cannot be
inferred from these results that furanones are slightly toxic to
freshwater invertebrates. Assuming that all of the toxicity of the
formulated product was; caused by the furanones, the estimated
acute LCso of the furanones is >0.012 ppm a.i. for Daphnia magna.
These results probably overestimate the toxicity of furanone
because much of the toxicity of the formulated product could be the
result  of the other  active ingredient,  limonene, or of inert
ingredients. These results tell little about the actual toxicity of the
furanones as active ingredients. Furanones may fall into any of
five toxicity classifications (MRID 109345).
                18

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                     Because the tests were conducted with formulated product
               rather than technical grade active ingredients, they do not fulfill the
              .guideline requirements for furanones.  However, these data are
               considered adequate for assessing the risk of the use of the Doo-
               Not product.  They may  also  be  adequate for other low-use
               products that contain furanones in identical concentrations.

                     A life-cycle test with a freshwater invertebrate (guideline
               72-4b) is needed for the mosquito larvicide  use of furanones
               because it involves direct application to water and because some of
               the acute risk quotients for freshwater  invertebrates are greater than
               0.01. This guideline requirement is not fulfilled.
 2.     Environmental Fate Assessment
        Environmental fate data are not required to support low-volume outdoor
 residential uses for the furanones.  Environmental fate data generally are required
 to support aquatic nonfood uses. To complete an ecological risk assessment for
 fte mosquito larvicide use, the Agency needs the following data to assess the
 dissipation of the furanones in the environment:

      ,  161-1, Hydrolysis
        161-2, Photodegradation in Water
        162-3, Anaerobic Aquatic Metabolism
        162-4, Aerobic Aquatic Metabolism
        163-1, Leaching/Adsorption-Desorption
        164-2, Aquatic Field Dissipation

       A quantitative environmental fate assessment for the furanones cannot be
 made at this time because no environmental fate data have been submitted for
 rev,ew.  However, the furanones are classified as  lactones, and some open
 literature data are available on physiochemical properties of lactones and their
 possible effect on the environment.
 , u  u LJactones «* ^dic esters *at can be synthesized by acidification  of
alpha-hydroxy acids. Detoxification mechanisms of lactones can be accomplished
through base-catalyzed hydrolysis or microbial-mediated degradation of reactive
groups.  De-esterification may  be catalyzed by metal ions, enzymes, and
nucleophihc attack.  The reported data indicate lactones may  not be stable in
alkaline environments.
                            19

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3.    Exposure and Risk Characterization
      a.     Ecological Exposure and Risk Characterization

             Explanation  of the Risk Quotient (RQ) and the Level o f
      Concern  (LOC):  The Levels of Concern are criteria used to indicate
      potential risk to nontarget organisms. The criteria indicate that a chemical,
      when used as directed, has the potential to cause undesirable effects ori
      nontarget organisms. There are two general categories of LOC (acute and
      chronic) for, each of the four nontarget faunal groups and one category
      (acute) for each of two nontarget floral groups. In order to determine if an
      LOC has been exceeded, a risk quotient must be derived and compared to
      the LOCs.  A risk quotient is  calculated  by dividing an appropriate
      exposure estimate, e.g. the estimated environmental concentration (EEC),
      by an appropriate toxicity test effect level, e.g. the LC50. The acute effect
      levels typically are:

      - EC^ (terrestrial plants),
      - EC50 (aquatic plants and invertebrates),
      - LCSO (fish and birds), and
      - LD50 (birds and mammals)

      The chronic test results are the:

      -NOEL (or NOEC) for avian and mammal reproduction studies, and either
      the NOEL for chronic aquatic  studies, or the Maximum  Allowable
      Toxicant Concentration (MATC), which is  the geometric mean of the
      NOEL and the LOEL (or LOEC)  for chronic aquatic studies.

            When the risk quotient exceeds the LOC for a particular category,
      risk to that particular category  is presumed to exist.  Risk presumptions are
      presented along with the corresponding LOCs.
Levels of Concern (LOC) and associated Risk Presumption
•m-itiM- iiiimirii 	 i, 	 iiii--iL-inifmu • % * % " % Mamftt«Is, Bitds , Y'i
IFTOE
acute RQ>

acute RQ>
1 acute RQ> |
; toe
" 0.5
0.2
0 1
i
s * r Fish.d
I LOC
0.5

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chronic RQ>
''••>• • Mamm»ls,flird<

IFTHE
RQ>

IOC
- 1
1
Plants

nically
PRESUMPTION ' \ 	





4.     Exposure and Risk to Nontarget Terrestrial Animals

       a.     Birds

             Birds may ingest granules of the product Doo-Not.  They may also
       be exposed by other routes, such as dermal exposure when walking on top
       of granules.  The number of lethal doses (LDsos) that are available on one
       square foot immediately after application is normally used to assess the
       risk from such  exposure.   However,  the  available toxicity data are
       inadequate  for this approach  because definitive LD50 values are not
       available.

             The  only acceptable study on  acute effects to birds used the
       formulated product Doo-Not.  This study determined only that Hie LD50 is
       something greater than 2000 mg/kg.  This information is inadequate to
       assess quantitatively the risk of Doo-Not to birds.

            Although the  risk of furanones  to  avian species  cannot be
      quantified, several factors indicate that the risk is small. First, there was
      no mortality or signs of toxicity to birds that received the relatively high
      dose of 2000 mg/kg.  Birds would need to consume more than 2000 mg/kg
      of this product before toxic effects may be expected. This is a relatively
      large quantity of granules for a bird to consume.  Second, Doo-Not is
      labeled for use on lawns and ornamental turf around homes. It is likely to
      be applied only to small isolated areas. Any risk to birds that may result
      would be small in terms of area exposed and number of birds affected
      Third, the formulation repels mammals and insects, and thus is probably
      somewhat repellent to birds as well.  In conclusion, it is reasonable to ,
      assume that normal use of this product would not cause sufficient exposure
    '  to birds to result in any significant ecological damage.

            Birds also could be exposed to furanones if they drink from bodies
      of water treated with Rodspray Mosquito Larvicide (Reg. No. 45987-6).
      The EECs in water immediately following application of the mosquito
      larvicide are not greater than 3.01 ppm (see section 3.a.2). In avian dietary
      toxicity   tests  with  Doo-Not,  a  product  that  contains  the same
      concentrations of furanones as the mosquito larvicide, the dietary LC50 for
                           21

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5.
         both the bobwhite and mallard were greater than 5000 ppm. While there
         is uncertainty associated  with comparing the toxicity  of different
         formulated products and using a dietary toxicity test to assess the risk from
         drinking contaminated water, the huge difference (>1000 fold) between the
         EEC  and the  concentrations that may cause effects is large enough to
         safely presume minimal risk from this type of exposure.

               Other products that contain furanones are expected to result in
        negligible exposure to birds.  The Rodspray Fly, Cockroach, & Ant Killer
        (Reg. No. 45987-2) is sold in a pump-spray bottle and is designed for
        application to very small areas indoors and outdoor premises of domestic
        dwellings. Homeowners would not be likely to use this product on wildlife
        food.  The other products are used as insect repellents and would not result
        in exposure to birds.
        b.
              Mammals
              Mammals may be exposed to furanones by consuming the granular
        product Doo-Not Dog & Cat Repellent  (Reg. No. 45987-1) and  by
        exposure to residues of the liquid product Rodspray Fly, Cockroach & Ant
        Killer (Reg. No. 45987-2).  An acute oral toxicity study with Doo-Not
        showed that no mortality occurred at doses as great as 5000 mg/kg  The
        fly,  cockroach, &  ant killer  product has the  same concentration  of
        furanones as Doo-Not.  Because of this apparent lack of toxicity of the
        formulated products containing furanone, and because these formulations
        repel mammals, it is anticipated lhat mammals will not be exposed to large
        enough quantities to cause any significant ecological damage. The EECs
        of the formulated product Rodspray mosquito larvicide are not expected
       to exceed 3.01  ppm.   This concentration is too small to  cause any
       appreciable risk to mammals that may drink treated water. The use pattern
       of other products should not lead to any appreciable exposure to mammals
       Thus, the currently registered products containing furanones pose minimal
       risk to wild mammals.
       c.
             Insects
       ^     None of the products containing furanones are used in a manner
       that is expected to cause any appreciable exposure to honey bees.

       Exposure and Risk to Nontarget Aquatic Animals

       With the exception of Rodspray Mosquito Larvicide (Reg No 45987-6)
all registered products containing furanones should pose very little exposure to
                            22

-------
 aquatic organisms when used as directed. These products, which are for domestic
 use only, are used to repel dogs and cats, repel insects from human skin, and kill
 household insect pests.  The dog and cat repellent use and insecticide use are for
 spot treatment of very small areas around homes, such as compost piles and
 garbage pails. Considering that me tpxicities of these formulations are at most
 only slightly toxic to aquatic organisms, the risk they pose to aquatic organisms
 is minute.  The potential of exposure to aquatic organisms is much greater with the
 mosquito  larvacide use because it is applied directly to bodies  of water
 Furthermore, it is registered for public use as well as household use, and thus may
 be applied to much  larger areas  than the other products.  The  risk that the
 mosquito larvacide use poses to aquatic organisms is discussed in detail below.

       Expected Aquatic Concentrations: The toxieity of furanones to aquatic
 organisms is not known. However, data on the formulated product Doo-Not (Reg.
 No. 45987-1) indicate that it is practically nontoxic to freshwater fish and slightly
 toxic to freshwater invertebrates.  This formulated product contains the same
 concentration of furanones as the mosquito larvicide (0.024% dihydro-5-penryl-
 2(3H)-furanone and 0.049% 5-heptvldihydro-2(3H)-furanone). Therefore, aquatic
 risk will be assessed by comparing the expected environmental exposure to the
 larvicide formulated product to the toxieity of the Doo-Not formulated product
 This risk assessment approach is less than ideal because the larvicide contains an
 additional active ingredient, mineral oil, as well as different inert ingredients than
 Doo-Not.
The following table summarizes the EECs for the mosquito larvicide
Use Type

Use
Application
Method

Spray
Application Rate
1.64 Ib/A
(2gaI/A)
4.10 Ib/A
(5 gal/A)
Initial EEC (ppm)
6 inches
1.200
3.010
Ifoot
0.603
1.510
6 feet
0.100
0.251
6.     Freshwater Fish

       The  following  table summarizes the risk quotients  (EEC/LC
-------
        None of the acute RQs listed above exceed any of the LOCs.
  Therefore, use of the mosquito larvicide containing furanones is presumed
  to pose low acute risk to freshwater fish and to cause no appreciable acute
  effects to endangered species.

        As stated  previously,  use  of the  other formulated  products
  containing furanones are expected to result in very little exposure to
  aquatic habitats, much less than the mosquito larvacide use described
  above. Since the mosquito larvacide is presumed to pose low acute risk to
  freshwater fish, the other uses are also presumed to pose low acute risk.

  a.     Freshwater Invertebrates
The following table summarizes the risk quotients (EEC/LC,0) for freshwater invertebrates
Crop/application rate
Mosquito Larvicide,
Domestic Use, 1.64 Ib/A
Public Health Use, 4.10 Ib/A
Species
Daphnia magna
Daphnia magna

0.071
0.18
fates , ,
Acute Risk Quotient
0.035
0.089

0.0059
0.015
        None of the acute RQ's listed above exceed the LOG for high
 acute risk. The acute level of concern for which restricted use may be
 appropriate (0.1) are not exceeded for either use of the larvicide when the
 depth of the water is 1  foot or greater.  However, public health use of the
 larvicide at the rate of 4.10 Ibs/A (5 gal/A) exceeds this LOG when applied
 to 6 inches of water.

       The level of concern for endangered species is also exceeded when
 the product is applied at 1.64 Ib/A (2 gal/A) in water 6 inches deep or less
 or when it is applied at 4.10 Ib/A (5 gal/A) in water 1  foot deep or less.'
 These risk quotients are plausible,  since mosquito larvicides are often
 applied to shallow, stagnant water.

       The risk quotients also suggest that some risk could be posed to the
 aquatic stages of amphibians (e.g. tadpoles), although the extrapolation  of
 risk from aquatic invertebrates to amphibian larvae is highly  uncertain.

       It should be recognized that the risk posed to aquatic invertebrates
 would be shared with most, if not all, products for this use.  It is the nature
 of mosquito larvicides  to be harmful to aquatic invertebrates because the
 target species is itself an aquatic invertebrate.   The mosquito larvicide
 containing  furanone  would cause less harm to  aquatic ecosystems than
many other products because its risk is limited to aquatic invertebrates,
whereas others pose a risk to fish and birds as well.   ,'
                      24

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         Persistence of furanones in water or repeated applications of the
  product could cause chronic exposure to furanones.  A chronic freshwater
  invertebrate toxicity  study  is needed to  complete the  aquatic  risk
  assessment.

         As  stated previously, use  of the  other  formulated products
  containing furanones is expected to result in very little exposure to aquatic
  habitats, much less than the mosquito larvicide use described above  A
  high-risk scenario would be if 1% of the formulated product applied to a
  1-acre  lot runs off into a 1-acre pond.  This scenario would result in
  aquatic exposures approximately  100 times smaller than  those  for the
  mosquito larvicide use. Since the mosquito larvicide generally is presumed
  to pose low acute risk (except for the extreme case of application to 6
  niches of water), the other uses are also presumed to pose low acute risk.

  b.     Endangered Species

        When the Endangered Species Protection Program becomes final
 limitations in the use of furanones may be required to protect endangered
 and threatened species.  These limitations have not been defined and may
 be formulation specific.  EPA anticipates that a consultation with the Fish
 and Wildlife Service may be conducted in accordance with the species-
 based priority approach described in the Program.  After completion of
 consultation, registrants would  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.

       Use of the mosquito larvicide  containing furanones (Reg.  No
 45987-6) may have harmful  effects on endangered species of aquatic
 invertebrates. The level of concern for endangered species are exceeded
 when the product is applied  at 1.64 Ib/A (2 gal/A) in water 6 inches deep
 or less, or when it is applied at 4.10 Ib/A (5 gal/A) in water 1 sfoot deep or
 less.  In general, mosquito larvicide of any kind should not be applied to
 stagnant or slow-flowing  bodies of  water that  provide   habitat for
 endangered aquatic invertebrates.  The two primary types of habitats that
 are of concern are vernal pools in California and water that drains into
 caves.  The California state-initiative plan will protect species  in vernal
 pools.  No federal protection is therefore required for these species as long
 as the state-initiative plan continues to be implemented.   Use of this
 mosquito larvicide should be restricted around caves that harbor endemic
populations of endangered crayfish, shrimp, or other aquatic invertebrates
                      25

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                           Other  than the  possible effect  of the  mosquito larvicide  to
                    endangered aquatic invertebrates, the use of products containing furanones
                    should not cause effects to endangered species.

IV.    RISK MANAGEMENT AND REREGISTRAHON 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 data required  to  support registration of products
       containing furanone as active ingredients.  The Agency has completed its review of these
       generic data, and has determined that the data are sufficient to support reregistration of
       all products containing furanone. Appendix B identifies the data requirements that the
       Agency reviewed as part of its determination of reregistration eligibility of furanone 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 furanone and to determine that furanone can be used without resulting
      in unreasonable  adverse effects to  humans and. the environment provided the  the
      production cap is not exceeded.  The Agency therefore finds that all products containing
      ruranone as the active ingredients are eligible for reregistration.  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
      stadies to generate such data, published scientific literature, etc. and the data identified in
      Appendix  B.  Although the Agency has found that all uses of furanone are eligible for
      reregistration, 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
      products containing furanone, if new information comes to the Agency's attention or if the
      data requirements for registration (or the  guidelines for generating such data) change.

      B.    Determination of Eligibility Decision

           1.      Eligibility Decision

                   Based on the  reviews  of the generic data  for  the furanone active
           ingredients, the Agency has sufficient information on the health effects of furanone
           and on its potential  for  causing  adverse  effects  in  fish and wildlife and the
           environment.  The Agency has determined that furanone products  labeled and
           used as specified  in this Reregistration  Eligibility Decision/will not pose
           unreasonable risks or adverse effects to humans or the environment. Therefore,

                                        26

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       the Agency concludes that all uses of products containing furanone are eligible for
       reregistration.

       2.     Eligible and Ineligible Uses

              The Agency  has determined that all uses of furanone  are eligible for
       reregistration.

C.     Regulatory Position

«n.    The following is a summary of the regulatory positions and rationales for furanone
Where labeling revisions are imposed, specific language is set forth in Section V of this
document.

       1.     Mosquito Larvicide Use-Production Limit

             The furanones, when used as mosquito larvicides, are applied directly to
       water (residential and large scale public health use.) The public health larvicidal
       use of furanones applied at 4.10 Ibs/A to 6 inches of water results in exceedances
       of the level of concern for freshwater invertebrates: The LOG  for endangered
       species is exceeded when the product is applied at 1.64 Ib/A in water 6 inches deep
       or less,  or when it is applied at 4.10 Ib/A in water 1 foot deep or less  This
       assessment is based on testing done on a formulated product and tells little about
       the actual toxicity of the furanones as active ingredients.  Chronic invertebrate
       toxicity data (life cycle test with a freshwater invertebrate) and basic environmental
       fate data would improve the Agency's  understanding  and assessment of the
       potential risk posed by the use the of furanones in mosquito larvicides.

             The volume  of furanone products used annually as mosquito larvicides is
      low and the percentage of furanones in the product is also low.  The low volume
      and low percent furanones support the conclusion that widespread adverse impacts
      are not likely to result from the mosquito larvicide use if continued at the amounts
      currently produced and used (volume and  percent furanone in product).  The
      Agency, in this RED document, is imposing a production limit on furanone for use
      ma mosquito larvicide of 150 gallons furanone per year.  Should the volume
      produced and used  and/or the percent of furanone in the  product significantly
      increase, the Agency may impose additional data requirements to understand and
      assess potential risks.

            It should be recognized that  the risk posed to  aquatic invertebrates is
      common to most, if not all, products for this use.  It is the nature of mosquito
      larvicides to be harmful to aquatic invertebrates because the target species is itself
      an aquatic invertebrate.  The mosquito larvicide product containing furanones
      would cause less harm to aquatic ecosystems than many other products because its


        ' •   '  •    ••':'•     27           '    ''     .

-------
              risk is limited to aquatic invertebrates, whereas others pose a risk to fish and birds
              as well.

              2.     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
              restrictions to  protect endangered and threatened species at the  county  level
              Consultations with the Fish and Wildlife Service  may be necessary to assess risks
              to newly listed species or from proposed new uses.

                    In the future, the Agency plans to publish a description of the Endangered
              Species Program in the Federal  Register.  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 OF 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 furanone for the
             above eligible uses has been reviewed and determined to be substantially complete.

                   Environmental fate and chronic invertebrate toxicity data are not available
             and are  needed to complete the assessment of  risks posed by the use of the
             furanones as mosquito larvicides.  However, the Agency is not requiring these data
             as long as the product of furanone for this use does not exceed  150 gallons per
             year. Should the volume produced and used and/or the percent of active ingredient
             in  the product significantly increase, the Agency may impose  additional  data
             requirements to  understand and assess potential risks.
                                         28

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 2.     Labeling Requirements for Manufacturing-Use Products

       To remain in compliance with FIFRA, manufacturing use product (MP)
 labeling must be revised to comply with all current EPA regulations, PR Notices
 and applicable policies.  The MP labeling must bear the following statement under
 Directions for Use:

       "Only for formulation into an [fill blank with Insecticide, Herbicide or the
       applicable term which describes the type of pesticide use(s)] for the
       following use(s)  [fill blank only with those uses that are being supported bv
       MP registrant."

       An MP registrant may, at his/her discretion, add one of the following
 statements to an MP label under

       "Directions for Use" to permit the reformulation of the product for
       a specific use or all additional uses supported by a formulator or
       user group:
(a)
(b)
        "This product may be used to formulate products for specific use(s)
        not listed on the MP label if the formulator, user group, or grower
        has complied with U.S. EPA submission requirements regarding
        support of such use(s)."

        "This product may be used to formulate products for any additional
        use(s) not listed on the  MP label if the formulator, user group, or
        grower has complied with U.S.  EPA  submission  requirements
        regarding support of such use(s)."

              Effluent Discharge Labeling Statements

 "Do not discharge effluent containing this product into  lakes, streams,
 ponds,  estuaries, oceans or  other waters unless in accordance with the
 requirements  of a National Pollutant  Discharge  Elimination System
 (NPDES) permit and the permitting authority  has been notified in writing
.prior to discharge. Do not discharge effluent containing this product to
 sewer systems without previously notifying the local sewage treatment plant
 authority.  For guidance contact your State Water Board or Regional Office
 of the EPA."
                           29

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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.     Labeling Requirements for End-Use Products

       Worker Protection Standard

             Any product whose labeling reasonably permits use in the production of an
      agricultural plant on any farm, forest, nursery, or greenhouse must comply with
      the labeling requirements of PR Notice 93-7, "Labeling Revisions Required by the
      Worker Protection  Standard (WPS),   and  PR  Notice 93-11,  "Supplemental
      Guidance for PR Nptice 93-7, which reflect the requirements of EPA' s labeling
      regulations for worker protection statements ( 4 0 CFR part 156, subpart K).
      These  labeling revisions are necessary to  implement the Worker Protection
      Standard for Agricultural Pesticides (40 CFR part 170)  and must be completed in
      accordance with, and within the deadlines  specified in, PR Notices 93-7 and 93-11.
      Unless otherwise specifically directed in this RED, all statements required by PR
      Notices 93-7 and 93-11 are to be on the product label exactly as instructed in those
      notices.

            After April 21, 1994, except as otherwise provided in PR Notices 93-7 and
      93-11,  all products within the scope  of those notices must bear WPS PR Notice
      complying labeling when they are distributed or sold by the primary registrant or
      any supplementally registered distributor.

            After October 23, 1995, except as otherwise provided in PR Notices 93-7
      and 93-11, all products within the scope of those notices must bear WPS PR Notice
      complying labeling when they are distributed or sold by any person.
                                  30

-------
              The labels and labeling of all products must comply with EPA's current
       regulations and requirements as specified in 40 £FR § 156.10 and other applicable
       notices.                                        ,

       Effluent Discharge Labeling Statements
                            .\  •'        '                •           ,  .        -
              Refer to subsection  A.  above for labeling requirements  for  effluent
       discharge.

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 [add chemical
names here] 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.
                                   31

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32

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VI.  APPENDICES
       33

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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 Furanone covered by this Reregistration Eligibility Decision
 Document. It contains generic data requirements that apply to Furanone in all products, including
 data requirements for which a "typical formulation" is the test substance.

        The data table is organized in the following format:
                                                     -i  . '              i
        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 31 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.
                                         40

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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
  .  ,   •       .atte.nipted 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

            "•49

-------
as (19??), the Agency was unable to determine or estimate the date of the
document.

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.

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 positibn of the study within
       the volume.
                            50

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                                BIBLIOGRAPHY
 MRTO
                      CITATION
 00077001


 40543600


 40543601


 41864500



 41864501


 42380700


 42380701


 42678100


 42678101


 42678102


42678103


42678104
  Monogram Industries, Incorporated (19??) Product Chemistry. (Unpublished
  study received May 5, 1981 under 45987-1; CDL: 245189-A)

  Rod Products Company (1988) Submission of Efficacy Data on Doo-Not (EPA
  Reg. No. 45987-1).  Transmittal of 1 study.

  Rod, R. (1987) Doo-Not Test Procedure TP-109B: Efficacy Tests with Cats.
\ Unpublished study prepared by Connie's Kitty Castle. 13 p.

  Rod Products Co. (1991) Submission of Products Chemistry Data to Support
  the Application for Amended Registration of RodSpray Fly , Cockroach, and
  Ant Killer Spray. Transmittal of 1 Study.

  Rod, R. (1991) Subpart C-Produet Chemistry Data.  Unpublished study
  prepared by Rod Products Co.  58  p.

  Rod Products Comp. (1992) Submission of Product Chemistry Data in Support
  of Registration for Fly, Cockroach, and Ant Killer. Transmittal of 1 study.

  Rod, R. (1991) Subpart C-Product Chemistry Data Requirements: Unpublished
  study prepared by Rod Products Co. 58 p.

 ,Rod Products Co. (1993) Submission of product chemistry, toxicity, and
  efficacy data  to support Rodspray registration.  Transmittal of 4 studies.

  Rod, R. (1993) Subpart C: Product Chemistry: Rodspray Mosquito Larvicide.
  Unpublished  study prepared by Rod Products Co. 15 p.

  Rod, R. (1993) Subpart D: Data Requirements Tables-Rodspray Mosquito
  Larvicide.  Unpublished study prepared by Rod Products Co.  10 p.

  Rod,^R. (1993) Efficacy Study: Rodspray Mosquito Larvicide.  Unpublished
  study prepared by Rod Products Co. 23 p.

  Kuhn, J. (1993) Rodspray: Acute Dermal Toxicity Study in Rabbits: Lab
  Project Number: 9684-92. Unpublished study prepared by Stillmeadow me
  lip.                                      .
                                        51

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                                BIBLIOGRAPHY
 MRID
                    CITATION
 42864100


 42864101


 43013700



 43013701


 43355000



 43355001



 93207000


 93207001


 93207002



93207003



93207004
 Rod Products Co. (1993) Submission of efficacy data in support of registration
 for Bugchaser Insect Repellent Strip. Transmittal of 1 study.

 Rod, R. (1993) Efficacy Studies: Various Rodspray Products. Unpublished
 study prepared by Rod Products Co.  14 p.

 Rod Products Co. (1993) Submission of Efficacy Data in Support of
 Application for Registration of BUGCHASER Insect Repellent Strip.
 Transmittal of 1 Study.

 Vargo, A. (1993) Efficacy Study: Bugchaser Wrist Band Insect Repellent Strip.
 Unpublished study prepared by American Samoa Community College.  5 p.

 Rod Products Co. (1994) Submission of Product Chemistry Data in Support of
 Application for Registration of Rodspray IndoorOutdoor Crawling & Flying
 Insect Killer.  Transmittal of 1 Study.

 Rod, R. (1994) Product Chemistry Data Requirements (Rodspray
 Indoor-Outdoor Crawling & Flying Insect Killer). Unpublished study prepared
 by Rod Products Co. 68 p.

 Rod Products Company (1990) Reregistration Phase 3 Response: Furanone
 dihydro-5-penryl(8CI,9CI).                             .            '

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00077001
 and Related MRIDs  00077002, 00077003. (Product Identity: Doo-Not). 8 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109340
 Acute Avian Oral: Quail: No-Go Dog Repellent: ABSL No. 18766. Prepared
 by Applied Biological Sciences Laboratory, Inc. 11  p.

 Rod, R. (1990) Rod  Products Company Phase 3 Summary of MRID 00109342
 Acute Avian Diet.: Quail: No-Go Dog Repellent: ABSL No. 18866. Prepared
 by Applied Biological Sciences Laboratory, Inc. 12 p.

Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109341
Acute Avian Diet. Duck No-Go Dog Repellent: ABSL No. 18866.  Prepared by
Applied Biological Sciences Laboratory, Inc. 12 p.
                                       . 52

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                                BIBLIOGRAPHY
  MRID
                    CITATION
  93207005
 93207006
 93207007
 93207008
 93207009
 93207010
93207011
93207012
93207013
93207999
 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109344
 Fish Toxicity Fathead Minnows: No-Go Dog Repellent: ABSL No  18766
 Prepared by Applied Biological Sciences Laboratory, Inc. lip.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109343
 Fish Toxicity Rainbow Trout: No-Go Dog Repellent: ABSL No  18766
 Prepared by Applied Biological Sciences Laboratories, Inc. 11 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109345
 Invertebrate Toxicity: No-Go Dog Repellent: ABSL No. 18766.  Prepared by '
 Applied Biological Sciences Laboratories, Inc. 11 p.
                      s      '• '       " '    '       ,'

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109339
 Acute Oral Toxicity Rat: Monogram Animal Repellant No, 100: Test Report
 No. 1-2-27836-2. Prepared by Bio-Technics Laboratories, Inc. 9 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109339
 Acute Dermal Toxicity Rabbit.. .Monogram Animal Repellant No 100 Test
 Report No.  1-2-27836-1. Prepared by Bio-Technics Laboratories, Inc. 9 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109339
 Acute Inhalation Toxicity Rat: Monogram Animal Repellant No  100- Test
 Report No. 1-2-27836-4. Prepared by Bio-Technics Laboratories, Inc. 9 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID  00109339
 Primary Eye Irritation Rabbit: Monogram Animal Repellant No  100- Test
 Report No. 1-2-27836-3. Prepared by Bio-Technics Laboratories, Inc. 9 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID  00109339
 Primary Dermal Irritation: Monogram Animal Repellant No. 100: Test Report
 No.  1-2-27836-5.  Prepared by Bio-Technics Laboratories, Inc. 10 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109339
 Dermal Sensitization: Monogram Animal Repellant No. 100: Test Report No
 1-2-27836-6. Prepared by Bio-Technics Laboratories,  Inc. 9 p.

Rod Products Company (1990) Reregistration Phase 3 Response: Furanone
dihydro-5-pentyl(8CI,9CI).  Correspondence and Supporting Material.    '
                                       53

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                                BIBLIOGRAPHY
 MRBD
                    CITATION
 93208000


 93208001


 93208002



 93208003



 93208004



 93208005



 93208006
 Rod Products Company (1990) Reregistration Phase 3 Response:
 Furanone,5-heptyldihydro-.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00077001
 and Related MRIDs 00077002, 00077003. (Product Identity: Doo-Not). 8 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109340.
 Acute Avian Oral Toxicity: No-Go Dog Repellent: Quail: ABSL No. 18766.
 Prepared by Applied Biological Sciences Laboratory, Inc.. lip.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109342.
 Acute Avian Diet. Toxicity: No-Go Dog Repellent: Quail: ABSL No. 18866.
 Prepared by Applied Biological Sciences Laboratory, Inc. 12 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109341.
 Acute. Avian Diet. Toxicity: No-Go Dog Repellent: Duck: ABSL No. 18866.
 Prepared by Applied Biological Sciences Laboratory, Inc. 12 p.

 Rod,  R. (1990) Rod Products Company Phase 3 Summary of MRID 00109344.
 Fish Toxicity Fathead Minnows: No-Go Dog Repellent: ABSL No. 18766.
 Prepared by Applied Biological Sciences Laboratory, Inc. lip.

 Rpd,  R. (1990) Rod Products Company Phase 3 Summary of MRID 00109343.
 Fish Toxicity Rainbow Trout: No-Go Dog Repellent: ABSL No. 18766.
 Prepared by Applied Biological Sciences Laboratories, Inc. lip.
93208007
93208008
93208009
Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109345.
Invertebrate Toxicity: No-Go Dog Repellent: ABSL No. 18766. Prepared by
Applied Biological Sciences Laboratories, Inc. lip.

Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109339.
Acute Oral Toxicity Rat: Monogram Animal Repellant No. 100: Test Report
No. 1-2-27836-2. Prepared by Bio-Technics Laboratories, Inc. 9 p.

Rod, R. (1990) Rod Products C9mpany Phase 3 Summary of MRID 00109339.
Acute Dermal Toxicity: Rabbit...(Monogram Animal Repellant No. 100): Test
Report No. 1-2-27836-1.  Prepared by Bio-Technics Laboratories, Inc. 9 p.
                                       54

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 MRID
                               BIBLIOGRAPHY
                    CITATION
 93208010
 93208011
93208012
93208013
93208999
 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109339
 Acute Inhalation Toxicity Rat: Monogram Animal Repellant No  100- Test
 Report No. 1-2-27836-4. Prepared by Bio-Technics Laboratories, Inc. 9 p.

 Rod, R, (1990) Rod Products Company Phase 3 Summary of MRID 00109339
 Primary Eye Irritation Rabbit: Monogram Animal Repellant No  100- Test
 Report No. 1-2-27836-3. Prepared by Bio-Technics Laboratories, Inc. 9 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109339
 Primary Dermal Irritation: Monogram Animal Repellant No. 100: Test Report
 No. 1-2-27836-5, Prepared by Bio-Technics Laboratories, Inc. 10 p.

 Rod, R. (1990) Rod Products Company Phase 3 Summary of MRID 00109339
 Dermal Sensitization: Monogram Animal Repellant No. 100: Test Report No
.1-2-27836-6.  Prepared by Bio-Technics Laboratories, Inc. 9 p.

 Rod Products Company (1990) Reregistration Phase 3 Response:
 Furanone,5-heptyldihydro-.  Correspondence and Supporting Material.
                                      55

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                   .UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                     WASHINGTON. D.C. 20460
 GENERIC DATA CALL-IN NOTICE
                                                                          OFFICE OF
                                                                     PREVENTION. PESTICIDES
                                                                     AND TOXIC SUBSTANCES
 CERTIFIED MAIL
 Dear Sir or Madam:
 This Notice requires you and other registrants of pesticide products containing  the active
 ingredient(s) identified in Attachment 1 of this Notice, the Data Call-In Chemical Status Sheet.
 to submit certain 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  produces)
 containing this active ingredients).   Within 90 days after you receive this Notice you must
 respond as set forth in Section HI below.  Your response must state:
 1.
2.
3.
how you will comply with the requirements set forth in this Notice and its Attachments 1
through 4; or,

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-BV
or>

why you believe EPA should not require your submission of data in the manner specified
by this Notice (see section in-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
produces) 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 4).

       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
                                         56

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  nHnnn>7fP?™0* Reducti™ Act by OMB Approval No, 2070-0107
  and 2070-0057 (expiration date 3-31-96).
                      '            '        '        "'"'''•',.'
      This Notice is divided into six sections and five Attachments.  The Notice itself contains
 information and instructions applicable to all Data Call-in Notices.  The Attachments ™
 specific chemical information and instructions. The six sections of the Notice arT
       Section I
       Section II
       Section IE
       Section IV
       Section V

       Section VI
   Why You Are Receiving This Notice
   Data Required By This Notice
   Compliarice With Requirements Of This Notice
   Consequences Of Failure To Comply With This Notice
   Registrants' Obligation To Report Possible  Unreasonable
   Adverse Effects
   Inquiries And Responses To This Notice
    The Attachments to this Notice are:
       Attachment 1  -
       Attachment 2  -
       Attachments  -
       Attachment 4  -
   Data Call-In Chemical Status Sheet
   Data Call-in Response Form
   Requirements Status And Registrant's Response Form
   List Of All Registrants Sent This Data Call-In Notice
SECTION I.  WHY YOU ARE RECEIVING THIS NOTICE
j*. nH        *** reViTd 6Xisting *"* for **• active ™gredient(s) and reevaluated the
data needed to support continued registration of the subject active ingredient(s)  This r
identified additional data necessary to assess the health and safety of the continu J use
conning tins actrve ingredient(s). You have been sent this Notice because you have
containing the subject active ingredient(s).

SECTION II. DATA REQUIRED BY THIS NOTICE

      A.     DATA REQUIRED
         **" Notice are Specified in Attachment 3, Requirements
.S RfP°nse Form- De^ing on the results of the studied reqS
                                                     4^«=u
              «        .                -
            Notice, additional testing may be required.
                                       57

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       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.                                           	

       C.     TESTING PROTOCOL                                           .

              All studies required under this Notice must be conducted in accordance with test
       standards outlined1 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 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)].
       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 e.rxr.rM
      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

      A.     SCHEDULE FOR RESPONDING TO THE AGENCY

             The appropriate responses initially required by this Notice must be submitted to
      the Agency within 90 days after your receipt of this Notice. Failure to adequately respond
                                        58

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 to tins 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.

      ,B.     OPTIONS FOR RESPONDING TO THE AGENCY
    , x :            for ^P011^ to A18 Notice are: 1) voluntary cancellation, 2) delete
 use(s), (3) claim generic data exemption, (4) agree to satisfy the data requirements
 imposed by this Notice or (5) request a data waiver(s).

       A discussion of how to respond if you chose the Voluntary Cancellation option the
 Delete Use(s) option or the  Generic Data Exemption option is presented below   A
 discussion of the various options available for satisfying the 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 m-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 (Attachment 2) and the Requirements Status and Registrant's
 Response Form (Attachment 3). The Data Call-in Response Form must he ..nh^ „
 part of every response to this Notice,   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 Of 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 identified in Attachment 1.

       L     Voluntary Cancellation - You mav avniH th» ^r*™^ nf thi;. Noticc b
      requesting  voluntary  cancellation of  your produces)  containing the  active
      mgredient(s) 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
      *? ™ Data Call-in Response Form. If you choose this option, this is the only form
      that you are required to complete.

       ,.     *f. you  choose  to voluntarily cancel your product,  further sale and
      distribution of your product after the effective date of cancellation must be iii
      accordance with the Existing Stocks provisions of this Notice which are contained
      in Section I V-C.     ,
   „,   '     ' t     '                    ;                     ,

      2     Use  Deletion - You  may avoid the  requirements of this Notice by
      eliminating the uses of your product to which  the requirements apply  If you wish
      to amend your registration to delete uses, you must submit the Requirements Status
      and Registrant's Response Form, a completed application for amendment a copy
                                  59

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 of your proposed amended labeling, and all  other information required  for
 processing the application.  Use deletion is option number 7 on the Requirements
 Status and Registrant's Response Form. You must also complete a Data Call-In
 Response Form by signing the certification, item number 8, Application forms for
 amending registrations may be obtained from the Registration  Support and
 Emergency Response Branch, Registration Division, (703) 308-8358.
                            -1*"1       '          ,  '
       If you choose to delete the use(s) subject to this Notice or uses subject to
 specific data requirements, further sale, distribution, or use of your product after
 one year from the due date of your 90 day response, must bear an amended label.

 3.    Generic Data Exemption - Under section 3(c)(2)(D) of FIFRA, an applicant
 for registration of a product is exempt from the requirement to submit or cite
 generic  data concerning an active ingredient(s) if the active ingredients) in the
 product  is  derived exclusively  from  purchased,  registered pesticide products
 containing the active ingredient(s).  EPA has concluded, as an exercise of its
 discretion, that it normally will not suspend the registration of a product which
 would qualify and continue to qualify for the generic data exemption in section
 3(c)(2)(D) of FIFRA. To qualify, all of the following requirements must be met:

       a.     The active ingredient(s) in your registered product must be present
       soteiy because of incorporation of another registered product which
       contains the subject active ingredient(s) and is purchased from a source not
       connected with you; and,

       b.     every registrant  who  is  the  ultimate  source  of  the  active
       ingredients) in your product subject to this DCI must be in compliance
       with the requirements of this Notice and must remain in compliance; and

       c.    you must  have  provided to  EPA  an  accurate and  current
       "Confidential Statement of Formula" for each of your products to which
       this Notice applies.

       To apply for the Generic Data  Exemption you must submit a completed
Data Call-In Response Form. Attachment 2 and all supporting documentation.  The
Generic Data Exemption is item number 6a on the Data Call-In Response Form.
If you claim a generic data exemption you are not required to complete the
Requirements Status and Registrant's Response Form.  Generic Data Exemption
cannot be selected as an option for product specific data.

       If you are granted a Generic Data Exemption, you rely on the efforts of
other persons to provide the Agency with the required data.  If the registrant(s)
who  have  committed to generate and submit the required data fail to take
appropriate steps to meet the requirements or are no longer in compliance with this
                            60

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c.
  Data Call-in Notice, the Agency will consider that both they and you are not in
  compliance and will normally initiate proceedings to suspend the registrations of
  both your and their product(s), unless you commit to submit and do submit the
  required data within the specified time. In such cases the Agency generally will
  not grant a time extension for submitting the data.

  4' ...  Satisfying the Data Requirements of this Notice - There are various options
  available to satisfy the data  requirements of this Notice.   These options  are
  discussed in Section ffl-C of this Notice and comprise options 1 through 6 on the
  Requirements Status and Registrant's Response Form and option 6b and 7 on the
  Data Call-in Response Form. If you choose option 6b or 7, you must submit both
  forms as well as  any other information/data pertaining to the option chosen to
  address the data requirement.

 5-  • _ Request for Data Waivers.  Data waivers are discussed in Section III-D of
 tiiis  Notice and are covered by options 8 and 9 on the Requirements Status and
 Registrants 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.

 SATISFYING  THE DATA REQUIREMENTS OF THIS NOTICE

       If you acknowledge on the Data Call-in Response Form that you agree to satisfy
                              f ^tion 6b and/or 7), then you must seL one o?£
                              Status ^d Registrant's Response Form related to data
                    n         *  Your 0Pti°n selection should be entered under item
        , Registrant Respond " The six options related to data production are the fim
^options discussed under item 9 in the instructions for completing the Requirements
Status and Registrant's Response Form.  These six options are Led immediately below
                            to guide registrants t
 1.


2.


3.

4.
             I will generate and submit data within the specified time frame (Developing
                                                                          v  B
             Data),
             I have entered into an agreement with one or more registrants to develop
             data jointly (Cost Sharing),                                        p

             I have made offers to cost-share (Offers to Cost Share),

             Tarn submitting an existing study that has not been submitted previously to
             the Agency by anyone (Submitting an Existing Study),
                                  61

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 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.  In addition, certain studies require Agency
 approval of test protocols in advance of study initiation. Those studies for which
 a protocol must be submitted have been identified in the Requirements Status and
 Registrant's Response Form and/or footnotes to the form.  If you wish to use a
 protocol which differs from the options discussed in Section II-C of this Notice,
 you must submit a detailed description of the proposed protocol and your reason
 for wishing to use it.  The Agency may choose to reject a protocol not specified
 in  Section II-C. . If  the Agency rejects  your protocol you will be notified  in
 writing, however, you should be aware that rejection of a proposed protocol will
 not be a basis for extending the deadline for submission of data.

       A progress report must be submitted for each study within 90 days from the
 date you  are required to commit to generate or undertake some other means to
 address that study requirement, such as making an offer to cost-share or agreeing
 to share in the cost of developing that study.  A 90-day progress report must be
 submitted for all studies.  This 90-day progress report must include the date the
 study was or will be initiated and, for studies to be started within 12 months of
 commitment, the name and address of the laboratory(ies) or individuals who are
 or will be conducting  the study.

       In addition, if the time frame for submission of a final report is more than
 1 year, interim reports must be submitted at 12  month intervals from the date you
 are required to commit to generate or otherwise address the requirement for the
 study. In addition to the other information specified in  the preceding paragraph,
 at a minimum, a brief description of current activity on and the status of the study
must be included as well as a full description of any problems encountered since
the last progress report.

      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
                             62

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   completed study reports or protocols.  The noted deadlines ran 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 requirement(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  ~

        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
  kPA 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 bfthe 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 -
             <"        '      *                     •                         '
        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®, 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,
      "     -.'                    ,  _ /    ^  . ,  •      •           ,_

-'  '"   •   .-   -.'" '    '•' '.      63                '''•'•             '  ,

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  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.
  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 pf 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.                                                                6

 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).

       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:
                             64

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 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(7) " 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(7),  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
 Registration 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.
                      65

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               If you submit an existing study, you must certify that the study
        meets all requirements of the criteria outlined above.

               If EPA has previously reviewed a protocol for a  study you are
        submitting, you must identify any action taken by the Agency on the
        protocol and must indicate, as part of your certification, the manner in
        which  all Agency comments, concerns, or issues were addressed in the
        final protocol and study.

               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 a 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.
                            66

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           .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  ecological effects studies, the classification generally would be a rating of
       "core."  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.

D-    REQUESTS FOR DATA WAIVERS

      There are two types of data waiver responses to this Notice. The first is a request
for a low volume/minor use waiver and the second is a waiver request based on your
belief that the data requirement® are inapplicable and do not apply to your product.

      1 •  „ Low Volume/Minor Use Waiver - Option 8 on the Requirements Status
      and Registrant's  Response Form. Section 3(c)(2)(A) of FIFRA requires EPA to
      consider  the appropriateness of requiring  data for low volume,  minor use
      pesticides. In implementing this provision EPA considers as low volume pesticides
      only those active ingredients) whose total production volume for all pesticide
      registrants is  small.  In determining whether to grant a low volume, minor use
      waiver the Agency will consider the extent, pattern and volume of use  the
      economic incentive to conduct the testing, the importance of the pesticide and the
      exposure and risk from use of the pesticide.  If an active ingredient(s) is used for
      both high volume and low volume uses, a low  volume exemption will not be
      approved.  If all uses of an active ingredient(s) are low volume and the combined
      volumes for all uses are also low, then an exemption may be granted, depending
      on review of other information outlined below.  An exemption will not be granted
      if any registrant  of the active ingredients) elects to conduct the testing.  Any
      registrant receiving a low volume minor use waiver must remain within the sales
      figures in their forecast supporting the waiver request in order to remain qualified
                                  67

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for such waiver. If granted a waiver, a registrant will be required, as a condition
of the waiver, to submit annual sales reports. The Agency will respond to requests
for waivers in writing.

       To  apply for a  low volume, minor  use  waiver,  you must submit the
following information, as applicable to your  product(s), as part of your 90-day
response to this Notice:

       a.     Total  company  sales  (pounds  and dollars)  of all  registered
       product(s) containing the active ingredients). If applicable to the active
       ingredients), include foreign sales for those products that are not registered
       in this country but are applied to sugar (cane or beet), coffee, bananas,
       cocoa, and other such crops.  Present  the above information by year for
       each of the past five years.

       b.     Provide an estimate  of the sales (pounds and dollars) of the active
       ingredient(s) for each major use site.  Present the above information by
       year for each of the past five years.

       c.     Total direct  production cost of produces) containing the  active
       ingredients) by year for the past five years. Include information on raw
       material  cost, direct labor cost, advertising, sales and marketing, and any
       other significant costs listed separately.

      d.     Total indirect production cost (e.g. plant overhead, amortized plant
      and equipment) charged to produces) containing the active ingredient(s) by
      year for the past five years.  Exclude all non-recurring costs that were
      directly  related to  the  active  ingredient®, such as costs of initial
      registration and any data development.

      e.     A list of each data  requirement for  which you  seek a waiver.
      Indicate  the type  of Xyaiver sought and the estimated.cost to you (listed
      separately for each data requirement and  associated test) of conducting the
      testing needed to fulfill each of the'se data requirements.

      f.     A list of each data requirement for which you are not seeking any
      waiver and the estimated cost to  you (listed separately  for each data
      requirement and assoqiated test) of conducting the testing needed to fulfill
      each of these data requirements.

      g.     For each of the next ten years, a year-by-year forecast  of company
      sales (pounds and dollars) of the active ingredient(s), direct production
      costs of  produces)  containing the active  ingredients)  (following .the
      parameters in item  c  above),  indirect production  costs  of produces)
                            68

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              containing the active ingredients)' (following the parameters in item d
              above), and costs of data development pertaining to the active ingredient(s).

           „  h.    A description of the importance and unique benefits of the active
              ingredient® to users.  Discuss the use patterns and the effectiveness of the
              active mgredient(s) relative  to registered  alternative chemicals  and
      -       non-chemical control strategies.  Focus on benefits unique to the active
              mgredient(s), providing information that is as quantitative as possible. If
              you do not have quantitative data upon which to base your estimates then
              present the reasoning used to derive your estimates. To assist the Agency
              in determining the degree of importance of the active ingredient(s) in terms
              of its benefits, you should provide information on any of the following
              factors, as applicable to your product(s):

                    (1)    documentation of the usefulness of the active ingredients)
              in Integrated Pest Management,  (b) description of the beneficial impacts on
             -the environment  of use  of the active ingredient(s), as opposed  to its
              registered alternatives, (c)  information on the breakdown of the active
              mgredient(s) after use and on its persistence in the environment, and (d)
              description of its usefulness against a pest(s) of public health significance.

      Failure to submit sufficient information for the Agency to make a determination
regarding a request for a low volume minor use waiver will result in denial of the reauest
for a waiver.                                                               4

      ^  v  Bequest for Waiver of Data -Option 9 on the Requirements Status and
      Registrant s Response Form.  This option may be used if you believe that a
      particular data requirement  should not  apply because the corresponding use is no
      , longer registered or the requirement is inappropriate.  You must submit a rationale
      explaining why you believe the data requirements should not apply.  You must also
      submit the current label(s) of your produces) and, if a  current copy of your
      Confidential Statement of Formula is not already on file you must submit a current
      copy.
         *                        •         .               ,        ''  '
             You will be informed of the Agency's decision in writing. If the Agency
      determines that  the data requirements of this Notice do not apply  to your
      l^S\?™ Wm  n0t * required to "Wfr **  data Pursu*nt to section
      3(c)(2)(B).  If EPA determines that the data are required for your product^ you
      must choose a method of meeting the requirements of this Notice witMnlhetime'
      frame provided by this Notice. Within 30 davs nf y™.r r^0;pt rf the Agency':
      written decision, you must submit a revised Requirements Status and Registrant's
      Response Form indicating the option chosei^:	•

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 1.
IV.    CONSEQUENCES OF FAILURE TO COMPLY WITH THIS NOTICE

       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:

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

                   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.

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

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

                   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).

                   Failure to submit supportable certifications as to the conditions of submitted
                   studies, as required by Section III-C of this Notice.

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

                  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; or,
 4.


 5.
6.


7.

8.
                            70

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by this
                                           t0 devel°P and subm* the data as required
c. 1   otherwise take appropriate steps to meet the requirements stated n
mis Notice unless you commit to submit and do submit the required data
in the specified time frame.
                                                                               in
         L tiJf T       ^ reqUre  °r aPPr°Priate ^ps, not mentioned above  at
         any time following the issuance of this Notice.
  B.
       '          v        determine ** a study (even if submitted within the required
       is unacceptable and constitutes a basis for issuance of a Notice of Ment to
        1.     KFA iemiii»m»nta on~.;*^ h me Dflta ^jj^ Notice ^

                   Dab  R«vwti ^  r""ng' aS applicable' EPAPesticiae Assessment
                 ., Data  Reporting Guidelines, and GeneTox Health  Effects Test
                  regarding the design, conduct, and reporting of required studies  Such
                    include, but are not limited to, those relating to test material, test
                    selection of species, number of animals  sex and diotrihntion nt
        animals  dose and effect levels to be tested or attained', duration of Stand as
        applicable, Good Laboratory Practices.                                  '


        2.     EPA requirements regarding the submission of protocols includine the
        incorporation of any changes required by the Agency folLkg revSw    g


       nf r,  ^A re2uiremeif re£arding U» ^porting of data, including the manner
       of reporting,  the  completeness of results, and the adequacy of anv reouhS
       suonort™ (^ r^ A^ ^^^ but ^ ^^ ^ .ieq^a£ SeSor

                  i final re ! rt- a^mtofai111 ?R 86"5' •M Studies must be submitted in
                 i requirement.                                 1 ere  o fulfill the


C-     EXISTING STOCKS OF SUSPENDED OR CANCELLED PRODUCTS


       EPA has statutory  authority  to permit continued sale, distribution and use of
existing stocks of a pesticide product which has been suspended or caSdSdo^g so
                                  71

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        would be consistent with  the  purposes  of the  Federal Insecticide, Fungicide, and
        Rodenticide 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 produces) 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(s) 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 y°u 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
                                          72

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 whatever spurce, 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.


 SECTION VI.       INQUIRIES AND RESPONSES TO THIS NOTICE
M *•   If y?" ^ ^ questions regarding the .requirements and procedures established by this
Notice, call the contact person 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 (Attachment 2) and a
completed Requirements Status and Registrant's Response Form (Attachment 3) and any other
documents required by this Notice,  and should be submitted to the contact person 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.
          pMff ompliance (°C> of ** Office of Enforcement and Compliance Assurance
       , EPA, will be monitoring the data being generated in response to this Notice.


                                             Sincerely yours,
                                             Lois Rossi, Division Director
                                             Special Review
                                              and Reregistration Division
                                        73

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 FURANONE DATA CALL-IN CHEMICAL STATUS SHEET

 INTRODUCTION

        You have been  sent this Generic Data Call-In Notice because you have produces)
 containing Furanone.
    ..      Generic Data Call-in Chemical Status Sheet, contains an overview nf data r^r**
 by this notice, and point of contact for inquiries pertaining to the reregistration of Furanone  This
 attachment is to be used in conjunction with (1) the Generic Data Call-in Notice, (2) the Generic
 Data Call-in Response Form (Attachment 2), (3) the Requirements Status and Registrant's Form
 (Attachment 2), (4) a list of registrants receiving this  DCI (Attachment 4)  (5) the  EPA
 Acceptance Criteria (Attachment 5), and (6) the Cost Share and Data Compensation Forms in
 replying to this Furanone Generic  Data Call In (Attachment F).  Instructions and guidance
 accompany each form.

 DATA REQUIRED BY THIS NOTICE
       The additional data requirements needed to complete the generic database for Furanone
•are contained in the Requirements Status and Registrant's Response. Attachment C  The Agency
 has concluded that additional product chemistry data on Furanone are needed  These data are
 needed to fully complete the reregistration of all eligible Furanone products.

 INQUIRIES AND RESPONSES  TO THIS NOTICE
 - ur ? /u" 5*Ve  3ny Questions regarding the generic data requirements and procedures
established by this Notice, please contact Emily Mitchell at (703), 308-8583.

       All responses to this Notice for the generic data requirements should be submitted to:

             Emily Mitchell, Chemical Review Manager
       Planning and Reregistration
             Special Review and Registration Division (H7508W)
             Office of Pesticiafde Programs
             U.S. Environmental Protection Agency
             Washington, D.C.  20460
            RE: Furanone            -                            ,
                                       74

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  SPECIFIC INSTRUCTIONS FOR THE GENERIC DATA CALL-IN RESPONSE FORM
                                               1   !            '
       , This Form is designed to be used to respond to call-ins for generic and product specific
  data for the purpose of reregistering pesticides under the Federal Insecticide Fungicide and
  Rodenticide Act. Fill out this form each time you are responding to a data call-in for which EPA
  has sent you the form entitled "Requirements Status and Registrant's Response."
                                      ' '         • '       ,  -                    '"
        Items  1-4 will have been preprinted on the form Items 5 through 7 must be completed by
        the registrant as appropriate Items 8 through 11 must be completed by the registrant before
        submitting a response to the Agency.

        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 informationincluding suggesting for reducing this burden,  to Chief, Information Policy
•522?A^  I  vHrS  Enjironmental Protection Agency, 401 M St, S W , Washington, D C
 20460; and to the Office of Management and Budget, Paperwork Reduction Project 2070-0107
 Washington, D C 20503.                                                              '
 INSTRUCTIONS

       Item 1.

-       Item 2.


       ItemS.

       Item 4.
       Item 5.
 This item identifies your company name, number and address.

 This item identifies the ease number, ease name, EPA chemical number
 and chemical name.

 This item identifies the date and type of data call-in.

 This item identifies the EPA product registrations relevant to the data
 call-in.  Please note that you are also responsible for informing the Agency
 of your response regarding any product that you believe may be covered
 by this data call-in but that is not listed by the Agency in Item 4. You must
 bring any such apparent omission to the,Agency's attention within the
 period required for submission of this response form.

 Cheek  this  item for each  product  registration  you wish to  cancel
 voluntarily. If a registration number is listed for a product for which you
 previously requested voluntary cancellation, indicate in Item 5 the date of
that request. You do not need to complete any item on the Requirements
Status and Registrant's Response Form for any product that is'voluntarily
cancelled.
                                         75

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  Item 6a.
 Item 6b.
 Item 7a.
Item 7b.
Item 8.
Item 9.
  Check this item if this data call-in is for generic data as indicated in Item
  3 and if you are eligible for a Generic Data Exemption for the chemical
  listed in Item 2 and used in the subject product.   By electing this
  exemption,  you agree to the terms and  conditions of a Generic Data
  Exemption as explained in the Data Call-In Notice.

  If you are eligible for or claim a Generic Data Exemption, enter the EPA
  registration Number of each registered source of that active ingredient that
 you use in your product.

 Typically, if you purchase an EPA-registered product from one or more
 other producers (who, with respect to the incorporated product,  are in
 compliance with this and-any other outstanding Data Call-In Notice), and
 incorporate that product into all your products, you may complete this'item
 for all products listed on this form If, however, you produce the active
 ingredient yourself, or use any unregistered product (regardless of the fact
 that some of your sources are registered), you may not claim a Generic
 Data Exemption and you  may not select this item.

 Check this Item if the data calHn is a generic data call-in as indicated in
 Item 3 and if you are agreeing to satisfy the generic data requirements of
 this data call-in.    Attach  the Requirements  Status  and  Registrant's
 Response Form that indicates how you will satisfy those requirements.

 Check this item if this call-in if a data call-in as indicated in Item 3 for a
 manufacturing use product (MUP), and if your product is a manufacturing
 use product for which you agree to supply product-specific data. Attach
 the Requirements Status and Registrants' Response Form that indicates how
 you will satisfy those requirements.

 Check this item if this call-in is a data call-in for an end use product (EUP)
 as indicated in Item 3 and if your product is an end  use product for which
 you agree to supply product-specific data.  Attach the Requirements Status
 and Registrant's Response Form that indicates how you will satisfy those
 requirements.                ,                         •     '.

 This certification statement must be signed by an authorized representative
 of your company and the person signing must  include his/her  title.
 Additional pages used in your response must be initialled and  dated in the
 space provided for the certification.

Enter the date of signature.
                                    76

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Item 10.      Enter the name of the person EPA should contact with questions regarding
             your response.

Item 11.      Enter the phone number of your company contact.
                                 77

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  SPECIFIC INSTRUCTIONS FOR COMPLETING THE REQUIREMENTS STATUS AND
  REGISTRANTS RESPONSE FORM

  Generic Data

  This  form, is  designed  to  be  used for registrants to respond to call-in-  for generic and
  product-specific data as part of EPA's reregistration program under the Federal Insecticide
  Fungicide and Rodenticide Act. Although the form is the same for both product specific and
  generic data, instructions for completing the forms differ slightly.  Specifically, options for
  satisfying product specific data requirements do not include (1) deletion of uses or (2) request for
  a  low volume/minor use waiver.   These instructions are for completion  of generic data
  requirements.                                                             -

  EPA has developed this form individually for each data call-in addressed to each registrant and
  has preprinted this form with a number of items. DO NOT use this form for any other active
  ingredient.

 Items  1 through 8 (inclusive) will have been preprinted on the form. You must complete all other
 items  on this form by typing or printing legibly.

 Public reporting burden for this collection of information is estimated to average 30 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 suggesting for reducing this burden, to Chief, Information Policy Branch  PM-223
 J;«r Z™™01*™^ Protection Agency, 401 M St., S.W., Washington, D.C. 20460; 'and to the
 Office of Management and Budget, Paperwork Reduction  Project 2070-0107, Washington, D.C.
 £\J3\JJ
 INSTRUCTIONS

 Item 1 .       This item identifies your company name, number, and address.
Item 2.


Item 3.

Item 4.



Item 5.
This item identifies the case number,  case name,  EPA chemical number and
chemical name.

This item identifies the date and type of data call-in.

This item identifies the guideline reference numbers of studies required to support
the produces) being reregistered/These guidelines, in addition to requirements
specified in the Data Call-In Notice, govern the conduct of the required studies.
                                                  \
This item identifies the study title associated with the guideline reference number
and whether protocols and 1, 2, or 3-year progress reports are required to be

                            78

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  Item 6.
 submitted in connection with the study. As noted in Section III of the Data Call-in
 Notice, 90-day progress reports are required for all studies.

       If an asterisk appears in Item 5, EPA has attached information relevant to
       this guideline reference number to the Requirements Status and Registrant's
       Response Form.                                         •.".."

 This item identifies the code associated with the use pattern of the pesticide. A
 brief description of each code follows:
                      A.
                      B.
                      C.
                      D.
                      E.
                      F.
                      G.
                      H.
                      I.
                      J.
                      K.
                      L.
                      M.
                      N.
                      O.
                          Terrestrial food
                          Terrestrial feed
                          Terrestrial non-food
                          Aquatic food
                          Aquatic non-food outdoor
                          Aquatic non-food industrial
                          Aquatic non-food residential
                          Greenhouse food
                          Greenhouse non-food crop
                          Forestry
                          Residential
                          Indoor food      \
                          Indoor non-food
                          Indoor medical
                          Indoor residential
- Item 7.
This item identifies the code assigned to the substance that must be used for
testing.  A brief description of each code follows.
                     EP
                     MP
                     MP/TGAI

                     PAI
                     PAI/M
                     PAI/PAIRA

                     PAIRA
                     PAIRA/M
                     PAIRA/PM

                     TEP
                     TEP   *
                          End-Use Product
                          Manufacturing-Use Product
                          Manufacturing-Use Product and Technical Grade
                          Active Ingredient
                          Pure Active Ingredient
                          Pure Active Ingredient and Metabolites
                          Pure Active Ingredient  or Pure Active Ingredient
                          Radiolabelled
                          Pure Active Ingredient Radiolabelled
                          Pure Active Ingredient Radiolabelled and Metabolites
                          Pure Active Ingredient Radiolabelled and  Plant
                          Metabolites
                          Typical End-Use Product
                          Typical End-Use Product, Percent Active Ingredient
                          Specified
                                          79

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                    TEP/MET
                    TEP/PAI/M

                    TGAI/PAIRA

                    TGAI
                    TGAI/TEP

                    TGAI/PAI

                    MET
                    IMP
                    DEGR

       *See: guideline comment
                           Typical End-Use Product and Metabolites
                           Typical End-Use Product or Pure Active Ingredient
                           and Metabolites
                           Technical Grade Active Ingredient or Pure Active
                           Ingredient Radiolabelled
                           Technical Grade Active Ingredient
                           Technical  Grade  Active  Ingredient or  Typical
                           End-Use Product
                           Technical Grade Active Ingredient or Pure Active
                           Ingredient
                           Metabolites
                           Impurities
                           Degradates
Item 8.
Item 9.
This item identifies the time frame allowed for submission of the study or protocol
identified in item 2. The time frame runs from the date of your receipt of the Data
Call-in Notice.

Enter the appropriate Response Code or Codes to show how you intend to comply
with each data requirement. Brief descriptions of each code follow. The Data Call-
in Notice contains a fuller description of each of these options.
                                                L
      (Developing Data) I will conduct a new study and submit it within the time
      frames specified in  item 8 above. 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 and that I will provide the protocol and progress reports required in
      item 5 above.
             1.
             2.
            3.
      (Agreement to Cost Share) I have entered into an agreement with one or
      more registrants to develop data jointly. By indicating that I have chosen
      this option, I certify that I will comply with all the requirements pertaining
      to sharing in the cost of developing data as outlined in the Data Call-in
      Notice.

      (Offer to Cost Share) I have made an offer to enter into an agreement with
      one or more registrants to develop data jointly. I am submitting a copy of
      the form "Certification of Offer to Cost Share in the Development of Data"
      that describes this offer/agreement.  By indicating that I have chosen this
      option, I certify that I will comply with all the requirements pertaining to
      making an offer to share in the cost of developing data  as outlined in the
      Data Call-In Notice.
                                        80

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Item 10.
  4.     (Submitting Existing Data) I am submitting an existing study that has never
         before been submitted to EPA. By indicating that I have chosen this option
         I  certify that this study meets  all the requirements pertaining  to the
         conditions for submittal of existing data outlined in the Data Call-In Notice
         and I  have attached the needed  supporting information  alone with this
 •      -  response.      .  :   '    .    '   -

 5.      (Upgrading a Study) I am submitting or citing data to upgrade a study that
         EPA has classified as partially acceptable and potentially upgradeable  By
         indicating that I have  chosen this option, I certify that I have met all the
         requirements pertaining to the conditions for submitting or citing existing
        data.to upgrade a study described in the Data Call-in Notice   I am
        indicating on attached correspondence the  Master Record Identification
        Number (MRID) that EPA has assigned to the data that I am citing as well
        as the MRID of the study I am attempting to upgrade.

 6.     (Citing a Study) I  am citing an existing study that has been previously
        classified by EPA as acceptable, core, core minimum, or a study that has
        not yet been  reviewed by  the Agency. I  am providing the Agency's
        classification of the study.

        (Deleting Uses)  I  am attaching  an application  for amendment to my
       Registration deleting the uses for which the data are required.

        (Low Volume/Minor Use Waiver Request) I have read  the statements
        concerning low volume-minor use data waivers in the Data  Call-in Notice
        and I request a low-volume minor use waiver of the data requirement  I
        am  attaching  a detailed justification  to support  this waiver  request
        including, among other things, all  information required to  support the
        request. I understand that, unless modified by the Agency in writing the
       data requirement as stated in the Notice governs.

       (Request for Waiver of Data) I have read the statements concerning data
       waivers other than low volume minor-use data waivers in the Data Call-In
       Notice and I request a waiver of the data requirement. I am attaching an
       identification of the basis for this waiver and a detailed justification to
       support this waiver request. The justification includes, among other things
       all information required to support the request. I understand that, unless
       modified by the Agency in writing, the data requirement as stated in the
       Notice governs.

This item must be signed by an authorized representative of your company  The
person signing must include his/her tide, and must initial and date all other pages
or this rorm..                                                   ,
              7.


              8.
              9.
                                          81

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Item 11.

Item 12.
Enter the date of signature.


Enter the name of the person EPA should contact with questions regarding your
response.
Item 13.      Enter the phone number of your company contact.
                                       82

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                  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 produces) containing this active ingredient.  Within 90 days after you receive this Notice
 you must respond as set forth in Section HI 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 IH-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 produces)  subject to this Notice will be subject to suspension.  We have provided a list of
                                        •', 85

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  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).           	'

        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  -
        Section II  -
        Section HI -
        Section IV -
        Section V  -

        Section VI -
       Why You Are Receiving This Notice
       Data Required By This Notice
       Compliance With Requirements Of This Notice
       Consequences Of Failure To Comply With This Notice
       Registrants' Obligation To Report Possible Unreasonable Adverse
       Effects
       Inquiries And Responses To This Notice
 The Attachments to this Notice are:
        1  -
        2  -
        3  -
        4  -

        5  -
        6  -
Data Call-In Chemical Status Sheet
Product-Specific Data Call-in Response Form
Requirements Status and Registrant's Response Form
EPA Batching of End-Use Products for Meeting Acute Toxicology Data
Requirements for Reregistration                              	
List of Registrants Receiving This Notice
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 H. DATA REQUIRED BY THIS NOTICE

H-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, additiorial testing may be required.
                                          86

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 H-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.                        :                          "

 n-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 JO). 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)].

 n-P-  REGISTRANTS RECEIVING PREVIOUS SECTION 3fc)(2)ffi) 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 Dafa"Call-In(s). or any other agreements entered intn with £
 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.

 SECTIONm;  COMPLIANCE WITH REQUIREMENTS OF THIS NOTICE            -

 m-A. SCHEDULE FOR RESPONDING TQ THE AGENCY
                               '           " r *•       '    '
       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.

HI-B.  OPTIONS  FOR RESPONDING TO  THE AGENCY

                                       - 87

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        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
 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 ni-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~valfd
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

                                           88

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  both forms as well as any other information/data pertaining to the option chosen to address the
  data requirement.

  m-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
  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
  m parentheses to guide registrants to additional instructions provided in this Section The
  options are:                                                                  '
        (1)

        (2)

        (3)
        (4)

        (5)

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


       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^),  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
                                          89  ,

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 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
 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)(iji)  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 pommitting to develop and submit the
data required by this Notice.
                                           90

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       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


       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 mus,t 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) reguktion, 40 CFR Part
             160. As stated in 40 CFR  160.3(j) " 'raw data1 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.

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        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.

        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.

      J Option 5, Upgrading a Study - If a study has been classified as partially acceptable and
 upgradable 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
 toe 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 UFA. Your submission must also  specify the MRID nurnber(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
                                         ,92

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        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 jo 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.

 m-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.

 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

    '  •    '   '••"•'   '   ..      ••'."".   93   '        .              '

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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.
       2.
       3.
       4.
      5.
      6.


      7.

      8.
      9.
 Failure to respond as required by this Notice within 90 days of your receipt of
 this Notice.

 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.
                    > '      '   '                 •.         • ~
 Failure to submit on the required schedule an adequate progress report on a
 study as required by this Notice.

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

 Failure to take a required action or submit adequate information pertaining to
 any option chosen to address the data requirements  (e.g., any required actioji 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).

 Failure to submit supportable certifications as to the conditions of submitted
 studies, as required by Section HI-C of this Notice.

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

 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;

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

       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.

Failure to take any required or appropriate steps, not mentioned above, at any
time following the issuance of this Notice.
             b.
             c.
                                          94

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 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.

!V-C EXISTING STOCKS OF SUSPENDED OR CANCELLED 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 produces) 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

                •          ''•"'''<  95        '         ' '     '         '

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 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.

 SECTION VI. INQUIRIES AND RESPONSES TO THIS NOTICE

XT •   If you,_have my  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.                                         .            :	:	
                                         96

-------
       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  -
       2  -
       3  -
       4  -
      \

       5  -
       6  -
Data Call-In Chemical Status Sheet
Product-Specific Data Call-In Response Form
Requirements Status and Registrant's Response Form
EPA Batching of End-Use Products for Meeting Acute Toxicology Data
Requirements for Reregistration                                	
List of Registrants Receiving This Notice
Cost Share and Data Compensation Forms and the Confidential Statement of
Formula Form          "             :           "~          '	~
                                         97

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98

-------
 FURANONE DATA CALL-IN CHEMICAL STATUS SHEET

 INTRODUCTION

       You have been sent this Product Specific Data Call-in Notice because you have produces)
 containing Furanone.                 .                                             w
     .       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
 Furanone 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 arid Registrant's Form (Attachment 3), (4) EPA's  Grouping of End-Use
 Products for Meeting  Acute Toxicology  Data Requirement (Attachment 4),  (5) the  EPA
 Acceptance Criteria (Attachment 5), (6) a list of registrants receiving this DCI (Attachment 6) and
 T?^ « ? Share and Data Compensation Forms in replying to this Furanone Product Specific
 Data Call-In (Attachment 7).  Instructions and guidance accompany each  form.

 DATA REQUIRED BY THIS NOTICE

       The additional data requirements needed to complete  the database for Furanone are
 contained in the Requirements Status and Registrant's Response. Attachment 3. The Agency has
 concluded that additional data on Furanone 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 Furanone products.

 INQUIRIES AND RESPONSES TO THIS NOTICE
 c* ur     u         ?uestions regarding this product specific data requirements and procedures
established by this Notice, please contact Emily Mitchell at (703) 308-8583.

      Afl responses to this Notice for the Product Specific data requirements should be submitted

             Emily Mitchell
             Chemical Review Manager Team 81
             Product Reregistration Branch
             Special Review and Reregistration Branch 7508 W
             Office of Pesticide Programs
             U.S. Environmental Protection Agency
             Washington, D.C. 20460

             RE: Furanone
                                        99

-------
  INSTRUCTIONS FOR COMPLETING THE DATA CALL-IN RESPONSE FORM FOR
                             PRODUCT SPECIFIC DATA
 Item 1-4.

 Item 5.
 Item 6.
Item 7a.
 Already completed by EPA.

 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 win 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).

 Not applicable since this form calls in product specific data only.  However, if
 your prdduct 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.

 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.
                                        100

-------
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      INSTRUCTIONS FOR COMPLETING THE REQUIREMENTS STATUS AND
         REGISTRANT'S RESPONSE FORM FOR PRODUCT SPECIFIC DATA
 Item 1-3
 Item 4.
Item 5.

Item 6.
Item?.
Item 8.
Item 9.
  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.

  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.

  The study tide associated with the guideline reference number is identified.

  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.

 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.

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

 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 hi the Data Call-In Notice.

 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).

 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 is similar enough
to another product to qualify for this option. I certify that another party in the
                                        102

-------
5.
 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).

 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 hi 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).

 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).

 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 IH-C. 1.) apply.  By
the specified due date, I will also submit: (1) a completed "Certification With
                                  103

-------
        6.
       7.
  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).

  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).

 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.
                                         104

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loor L - Indoor f°°<* M - Indoor nonfood
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will be required on a case-by-case basis.
re not required for inert ingredients in products proposed for experim
ibstances are dispersible with water
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grade of Active Ini
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Instructions for Completing the Confidential Statement of Formula

domrf The Con?dential 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.
 d.


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       must be provided.
                                          the telephone number of the responsible party

                                                             ''.••,    '

                                        is on the product specific
                                               be in
            Flashpoint must be in degrees Fahrenheit and flame extension in inches.

            For all active ingredients, the EPA Registration Numbers  for the currently
            registered source products must be reported under column 12.        CUITe™y
      M                       Ce (CAS) Numbers for •" actives
      common names for the trade names must be reported.
                                                                           and all
                 Ve ™8redients' **<* percent purity of the source products must be
      reported under column 10 and must be exactly the same as on the source product's


      ^eTWei8htS " C°^mnS 13'a- "^ 13'b- must  be in Po^ds, kilograms or
      grams. In no case will  volumes  be accepted. Do  not mix Enghsh afd metac
      system units (i.e., pounds and kilograms).

      All the items under column 13.b. must total 100 percent.


                            4'a- -"d  14'b- f°rtheactive ^redients must represent
                                    for ail active and inert ingredients must follow
           aro^-^P    **u       _,  ^ emanation must be provided if the proposed
           are different than standard certified limits.

     When new CSFs are submitted and approved, all  previously submitted CSFs
     become obsolete for that specific formulation.                "omraea c&*s
                                     112

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114

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    &EPA
United Statas  Environmental  Protection  Agency
            Washington,  DC  20460
   CERTIFICATION OF  OFFER  TO COST
 SHARE IN THE DEVELOPMENT OF  DATA
Form Approved

OMB Mo.  2070-01 OS
         2fl7n-nns7
Approval  Expire* 3-31-9A
 PubEc reporting burden for this coSection 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 ol 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.

 Pleasa .fill in blanks below.              .
  Company Nume
                                                 Compny Number
  Product Mune
                                                                          EPA RcE.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 Ad (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):
  Him* of Flrm(»)
                                                  Oil* 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 andaU 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 of  Company'* Authorized  Repreaentatlve
                                                                           Date*
 Name and Title (Please Type or Print)
 EPA Form 8570-32 (»91)   Replaces liFA form 8580, wMch Is obsolete
                                                 115

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116

-------
                        United States Environmental Protection Agency
                                    Washington, DC 20460
                              CERTIFICATION WITH RESPECT TO
                           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, includirig 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 Roderiticide 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(°)(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)
rA rOOTl oo/u-ol (4-yt>;
                                                         117

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  ~on     follpw?.g 5 a K* of av^able documents for Furanone that my further assist you in
                                E%ibi% Decision
 Electronic

 File format:  Portable Document Format (.PDF) Requires Adobe® Acrobat or compatible

              reader. Electronic copies can be downloaded from the Pesticide Special Review
              and ^registration Information System at 703-308-7224. They also are available
              on the Internet on EPA's gopher server, GOPHER.EPA.GOV  or  usine fto on
              FTP.EPA.GOV, or using WWW (World Wide Web) on WWW EPAGOV  or
              contact Emily Mitchell at (703)-308-8583.                 w.cr/v.uuv., or
   . 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 Furanone.
included M
mcluded in
               PAnp      °L** Administrative Record for Furanone and may
              EPA s Office of Pesticide Programs Public Docket. Copies of these documents

                        a' but may be obtained by contacting
    1. Health and Environmental Effects Science Chapters.

    2.Detailed Label Usage Information System (LUIS) Report.
nhto     /Ollowf g .Agencv 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.


    2.
            The Label Review Manual.


            EPA Acceptance Criteria
                                       118

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