-------
THE POST-FQPA REDS
Profile of the Post-FQPA REDs
OPP has completed 30 REDs since FQPA was
enacted in August 1996, 7 at the end of fiscal year
1996 (FY 96) and 23 in FY 97. Of these 30 post-
FQPA REDs, 18 have food uses. About 412
tolerances were reassessed in completing these post-
FQPAREDs.
The 30 Post-FQPA REDs
( * indicates food uses)
Post-FQPAREDs = 30
(7 in late FY 96 -h 23 in FY 97)
Post-FQPA REDs with Food Uses/
Tolerances -18
Tolerances Reassessed for
Post-FQPA REDs = 412
7 FY 96 Post-FQPA REDs
*Bromacil (case 0041)
*Colletotrichum gloesporioides (case 4103)
*Mepiquat Chloride (case 2375)
*Paraquat Dichloride (case 0262)
*PoIyhedraI Inclusion Bodies (NPV) (case 4106)
S-Kinoprene (case 4118)
*Virelure (case 4118)
23 FY 97 REDs
Rodenticlde Cluster:
Brodifacoum (case 2755)
Bromethalin (case 2765)
Bromadiolone (case 2760)
Chlorophacinone (case 2100)
Diphacinone (case 2205)
Pival (case 2810)
Others:
*Bt (Bacillus thuringiensis) (case 0247)
Butralin (case 2075)
*Dichlobenil (case 0263)
*Diflubenzuron (case 0144)
*Diphenylamine (case 2210)
IPBC (case 2725)
Methylene bis-thiocyanate (MBT) (case 2415)
*Metribuzin (case 0181)
Paranitrophenol (PNP) (case 2465)
(Voluntary Cancellation 5/30/02)
*Pendimethalin (case 0187)
*Propoxur (case 2555)
(Tolerance proposed)
*Sulprofos (case 0076)
(Voluntary Cancellation)
*Terbacil (case 0039)
Thiobencarb (case 2665)
Triclopyr (case 2710)
Triethylhexahydro-s-triazine (case 3147)
*Zinc Phosphide (case 0026)
Page 14
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THE FISCAL YEAR 1997 REDS
1;;iii;i^;;;;;;;;;;i:;;;;;;;;;;;;;;;;;;;:;f;;;:fi;;;
::TTT::Zf 15::::"::::::::::::::::::; I::::::::;:;;;:;::
Profile of FY97 REDs
EPA completed 23 REDs during fiscal year
1997, 12-with food uses. In completing these REDs,
about 265 tolerances were reassessed under FQPA.
Risk Reduction
Reducing the risks of older pesticides continues to be a primary focus of the reregistration
program. In completing REDs, EPA works with pesticide registrants to develop needed risk
mitigation measures or, if necessary, regulatory controls. As a result, each of the FY 97 REDs
contains a variety of measures to effectively reduce these pesticides' risks.
Highlights of the FY97 REDs
Rodenticide Cluster RED - During fiscal year 1997, for the first time, EPA developed
a RED encompassing a group of pesticides with similar use patterns. The Rodenticide RED
includes six reregistration cases, all of which are rodenticides used indoors and outdoors in urban,
suburban, and rural areas. Most of these products, sold as pelletized baits to control rats, mice,
and other rodents, are acutely toxic. EPA is concerned about their use in residential settings
because an increasing number of related human incidents have been reported in recent years, most
involving children less than six years old. The Agency also is concerned about exposures to
household pets, especially dogs, and about secondary nontarget poisonings.
Five of the six rodenticides included in this RED are eligible for reregistration, and EPA
believes they can be used without posing unreasonable risks, but only by adding strengthened
product labeling and a number of significant risk mitigation measures. For example, an indicator
dye (to help identify whether a child or pet has actually consumed the pesticide) and a bittering
agent must be included in formulating these products; tracking powders will be classified as
Restricted Use Pesticides; registrants must submit annual poison control center incident data;
and use directions must be added to product labels. A stakeholder group will be assembled to
discuss additional ways to significantly reduce exposure and risk to children and pets.
Bacillus thuringiensis (Bt) RED - Bt is a group of similar bacteria that act as
insecticides, and are used on growing agricultural crops, harvested crops in storage, ornamentals,
bodies of water, and around the home to control various groups of insects, depending on the
toxins produced by the specific isolate. In addition to toxins that are active against insect pests,
however, Bt may produce undesirable toxins. To mitigate risks of potential toxicity to the public
(including the risk of human food poisonings) or to nontarget species from these toxins, EPA
requires the following through the RED:
Page 15
-------
All registrants must analyze each batch of Bt produced for the presence of other microbes.
This will reduce the chance of some undesirable toxins being present.
The manufacturing process for each registered technical grade active ingredient must be
reevaluated and standardized.
Label changes must be made including a revised percent active ingredient, adding a
statement of explanation, and including the specific toxins responsible for the pesticidal
activity.
Bt is OPP's largest biopesticide RED, encompassing over 200 end use products.
Risk Reductions Achieved Through FY 97 REDs
The FY 97 REDs include many changes intended to reduce risks to people and the
environment. Risk reduction measures initiated by these 23 REDs are summarized below.
Risk Reduction Measures in FY 97 REDs
Number of REDs
8
5
10
21
7
16
20
5
4
6
6
6
8
Risk Reduction Measures Required by REDs
Voluntary Cancellation or Some Uses Not Eligible/Not Yet Eligible*
Limit Amount, Frequency of Use
Residential / Children's Risks Addressed
Application Restrictions
Restricted Use Pesticide Classification
Personal Protective Equipment (PPE) / Restricted Entry Intervals (REIs)
User Safety Requirements or Recommendations
Special Packaging or Engineering / Production Controls
Ground Water or Surface Water Safeguards
Spray Drift Labeling
Other Environmental Safeguards
Ecological Safeguards
Other**
Tolerances Reassessed ***
Includes 2 voluntary cancellations (PNP and Sulprofos); 1 not eligible (Pival); and 5 with some
uses not yet eligible (Chlorophacinone, Dichlobenil, Diphacinone, IPBC, and MBT).
Includes: Bt - Efficacy data required for public health uses; and Rodenticide Cluster (6 REDs) and
Zinc Phosphide - Two-phase risk reduction program.
Includes Propoxur for which a tolerance is being proposed.
Page 16
-------
Risk Reduction Measures in Individual FY 97 REDS
RED
Bt
Butralin
Dichlobenil
Diflubenzuron
Diphenylamine
IPBC
MBT
Metribuzin
Pendimethalin
PNP
Propoxur
Rodenticides
(6)
Sulprofos
CD
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z
%
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§
ry Cancel
J3
c
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^"
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^SlS
Frequency, Timing of Use
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^f
ial / Kids' Risks Addressed
*-
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^S
^f
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Application Restrictions
^S
^f
*S
^f
^S
+f
^f
6ģ/
Restricted Use Pesticide
6ģ/
LU
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LU
Q.
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^S
^S
^f
Jirements, Recommendations
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t
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ineering / Production Controls
LU
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Ecological Safeguards
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6
*
6**
Tolerances Reassessed
77
-------
RED
TerbacII
Thlobencarb
Triclopyr
Triethylhexa-
hydro-s-triazine
Zinc Phosphide
TOTAL
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in
3
CD
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Application Restrictions
^J
^^
^f
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21
Restricted Use Pesticide
LE.
7
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16
ments, Recommendations
O"
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20
ering / Production Controls
cu
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rface Water Safeguards
CO
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6
ronmental Safeguards
c
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^S
6
Ecological Safeguards
^S
^f
6
0)
6
***
8
rolerances Reassessed
^S
^S
^S
*S
12
- Some Uses Not Yet Eligible (5)
* One case, Pival, is Not Eligible (1)
= Voluntary Cancellation of All Remaining Uses (2)
~ Efficacy Data Required for Public Health Uses
= 2-Phase Program for Short and Long Term Risk Reduction
2-Phase Program as for Rodenticides
Page 18
-------
FY 97 REDs: Uses, Risks, and Risk Reduction Measures
The reregistration eligibility, pesticide type, uses, risks, risk reduction measures, and EPA contacts
associated with each of the FY 97 REDs are summarized below.
RED (Case #),
Author/CRM*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Bacillus
thuringiensis (Bt)
(Case 0247)
Bill Schneider, BPPD
All uses eligible.
Food uses
5 tolerances to be
reassessed.
Insecticide / biopesticide
used on many food and non-
food crops, and in forests,
parks, nurseries,
greenhouses, and around
residences (outdoors).
Bt poses no toxicological
concerns, but may produce
undesirable toxins. Dry,
anhydrous formulations may
cause eye irritation effects.
To mitigate risks from undesirable toxins:
> Production batch testing is required;
> Manufacturing process for each TGAI
must be reevaluated and standardized.
Percent Active Ingredient - must be
recalculated and included on the label.
Insecticidal Toxins - must be identified on the
label.
Efficacy Data - must be submitted for Bt
products with mosquito, blackfly, or other
public health pest control uses.
PPE:
> All handlers must wear respirator;
> Protective eyewear required for dry,
anhydrous products.
Environmental Hazards statements required to
avoid direct application to water.
Spray Drift Labeling required for all products
that can be applied aerially.
Butralin
(Case 2075)
Tom Luminello
All uses eligible.
No food uses.
Herbicide used only as a
plant growth regulator on
tobacco.
Poses no significant
toxicological concerns and
minimal worker inhalation
and dermal exposure risks.
Early entry PPE required (coveralls, chemical-
resistant gloves, shoes and socks);
12hourREI;
Application Restrictions - to protect workers or
other persons from exposure due to
application or spray drift;
User safety requirements and
recommendations.
Old tolerances (6) to be revoked.
*Chemical Review Manager who wrote the RED document.
Page 19
-------
RED (Case #),
Author/CRM*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Dichlobenil
(Case 0263)
Suzanne Cerrelli /
Dana Lateulere
All uses eligible
except sewer
treatment and
granular backpack
applications (more
data are needed).
Food uses
14 tolerances
reassessed for
dichlobenil and its
metabolite BAM.
Herbicide used on
agricultural, residential,
ornamental and industrial
sites, and to control tree
roots in sewers.
Low acute toxicity, Group C
carcinogen, systemic toxicity
in dog study. No
dietary/residential risk
concerns; worker risks of
some concern. Poses risk to
ground water quality.
Granulars pose potential
risks to birds. At highest
application rate,
unincorporated use of
granular poses risks to most
organisms.
Reduce Application Rate - from 20 Ibs ai/acre
to 10 Ibs ai/acre maximum.
Soil incorporation required for 10% granular
formulation.
Ventilation required for use in inhabited
buildings.
Other application restrictions.
Ground Water Advisory required.
PPE - Applicators/handlers must wear long
sleeved shirt & long pants, shoes & socks;
mixers & loaders also must wear chemical-
resistant gloves and apron; sewer use requires
chemical-resistant gloves. Respirator also
required for products in Toxicity Category I or II
for inhalation toxicity.
REI - 24 hour REI required for
horticultural/nursery uses; 12 hour REI
required for other uses under WPS.
Early Entry PPE - Coveralls, chemical-
resistant gloves, shoes & socks required at
WPS sites.
Engineering Controls - Closed systems
(including water soluble bags) or enclosed
cabs may reduce some PPE requirements.
User safety requirements and
recommendations.
Home Use - Post-application reentry
statement, application restrictions, user safety
recommendations required.
Page 20
-------
REP (Case #),
Author/CRM*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Diflubenzuron
(Case 0144)
Susan Jennings
All uses eligible.
Food uses
32 tolerances
reassessed.
Insecticide/ acaricide (insect
growth regulator) used to
control leaf-eating larvae of
insects feeding on
agricultural, forest and
ornamental plants. (No
home uses.)
Low acute toxicity but affects
hemoglobin. Systemic
toxicity endpoint of concern.
Group E carcinogen, but
metabolite PCA is Group B2
carcinogen. Dietary risk
acceptable (1 x 10-6).
Worker risks acceptable with
PPE. Very highly toxic to
aquatic invertebrates.
PPE - Long sleeved shirt & long pants, shoes
& socks, and chemical-resistant gloves
required. Dust/mist filtering respirator also
required for mixers & loaders of wettable
powder formulations for aerial applications.
Early Entry PPE - Coveralls, chemical-
resistant gloves, shoes & socks required.
REI - 12 hour REI required.
Engineering Controls - Closed systems
(including water soluble bags) or enclosed
cabs may reduce some PPE requirements.
Buffer Zone - 150 ft buffer zone for aerial
applications and 25 ft vegetative buffer strip
required to reduce runoff.
Spray Drift language required for all products
applied aerially.
Application Restrictions required to protect
workers and others from drift.
Statement required warning of toxicity to
aquatic invertebrates.
User safety requirements and
recommendations.
Diphenylamine
(Case 2210)
Ben Chambliss
All uses eligible.
Food uses
3 tolerances
reassessed.
Plant growth regulator used
post-harvest (indoors) to
control storage scald on
apples.
Low acute toxicity and "not
likely" a carcinogen, but
diphenylnitrosamine impurity
is a B2 carcinogen. Dietary
risk acceptable. Worker
risks acceptable with PPE
and engineering controls.
PPE - Applicators must wear single layer body
covering (long sleeved shirt & long pants).
Mixer/loaders must add chemical-resistant
gloves.
Engineering Controls - Closed systems
(enclosed cabs) - If truck driver hauling flatbed
loaded with apple bins remains in cab with
windows & doors closed during drenching
applications, PPE is not required.
Application Restrictions required to protect
workers and others from drift.
Environmental Hazards statement required
warning users of toxicity to fish and aquatic
invertebrates.
User safety requirements and
recommendations.
Page 21
-------
RED (Case #),
Author/CRN!*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
IPBCor3-lodo-2-
propynyl butyl-
carbamate
(Case 2725)
Richard Gebken
All uses eligible
except industrial wood
protection treatments
to milled forest
products; heating,
ventilation & air
conditioning (HVAC)
uses; textile uses; and
non-fndustrial wood
treatments other than
brush, roller, and
airless or compressed
air sprayer use more
exposure data are
needed.
No food uses.
Carbamate fungicide/
antimicrobial used in paint,
adhesives, metal cutting
fluids, plastics, textiles, inks,
paper coatings, wood
products. Also used in
residential settings as a
wood preservative stain &
paint preservative, and in
heating, ventilation and air
conditioning systems to
control mold and fungi.
Severely irritating to the eyes
(Toxicity Category I). "Not
likely" to be carcinogenic.
Risks to workers reduced
with PPE. Some uses not
eligible without additional
exposure data.
PPE - Long sleeved shirt & long pants,
chemical-resistant gloves, shoes & socks. If
end use product in Toxicity Category I or II for
eye irritation potential, protective eyewear is
also required.
Application Restrictions - Do not apply product
in way that will contact workers or other
persons.
Application Restriction - Warning of toxicity to
fish. NPDES statement required.
User safety requirements and
recommendations.
Page 22
-------
RED (Case #),
Author/CRN!*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Methylene bis-
thiocyanate (MBT)
(Case 2415)
Ron Kendall /
Pat Dobak
All uses eligible
except paint uses and
products applied with a
paint brush, roller or
compressed air
sprayer (more data
are needed).
No food uses.
Microbiocide, fungicide,
algicide and disinfectant
used in many types of
industrial water systems,
industrial adhesives and
coatings, sewage systems,
wood protection treatments,
latex paints (in-can), and
others.
Acutely toxic via inhalation,
severe eye and dermal
irritant, skin sensitizer
(Toxicity Category I). Group
D carcinogen. Metabolite
cyanide extremely toxic by all
routes of exposure.
Formaldehyde also a
potential degradate. Risk to
occupational painters is of
concern. Risk to handlers
open-pouring liquids is
reduced using PPE and
engineering controls.
PPE - Handlers must wear long sleeved shirt
& long pants and shoes & socks. In addition:
> If product is in Toxicity Category I or II for
eye irritation potential, handlers must wear
protective eyewear;
> If product is in Toxicity Category I or II for
acute dermal toxicity or skin irritation potential,
handlers must wear chemical-resistant apron
and chemical-resistant gloves;
> If product is in Toxicity Category I or II for
acute inhalation toxicity, handlers must wear
respirator;
> If product may be applied as a hand dip,
handlers must wear chemical-resistant full-
front apron with attached full-sleeve gloves.
Engineering Controls - For liquid formulations
applied to cooling water systems of 4000
gallons per day, open pouring is prohibited and
a metering pump delivery system is required.
Application Restrictions required to protect
workers and others from sprays and other
incidental exposure.
User safety requirements and
recommendations.
Directions for Use must be specified
completely.
Effluent Discharge Statement required.
Page 23
-------
RED (Case #),
Author/CRM*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Metribuzin
(Case 0181)
Jean Holmes
All uses eligible.
Food uses
60 tolerances
reassessed.
Herbicide used on many
vegetable and field crops,
turf grasses (in recreational
areas), and non-crop areas.
Group D carcinogen.
Evidence of systemic toxicity.
Total dietary risks are
minimal. Poses inhalation
risks to handlers.
Ground water contaminant.
Poses risks to birds,
mammals & nontarget
plants.
Reduce Application Rate - on sugarcane from
maximum of 6 Ibs ai/acre to 2 Ibs ai/acre.
Use of low pressure or high volume hand
wand equipment prohibited.
Aerial application on asparagus and tomatoes
prohibited.
For aerial application on sugarcane, apply at
minimum upwind distance of 400 ft from
sensitive plants.
Spray drift labeling required.
PPE - Required based on acute toxicity of end
use product.
Early Entry PPE - Coveralls, chemical-
resistant gloves, shoes & socks required.
REI - 12 hour REI required.
Application Restrictions required to protect
workers and others from drift.
Engineering Controls - Use of closed systems
may reduce handler PPE requirements.
User safety requirements and
recommendations.
Paranitrophenol
(PNP) (Case 2465)
Veronica Dutch
Voluntary cancellation
of all uses will become
effective on 5/30/02.
No food uses.
Fungicide used by military to
treat leather shoes & boots
and cork insulation.
Poses acute worker risks:
Corrosive eye irritant
(Toxicity Category I); data
gaps for inhalation toxicity
and skin irritation.
PPE - Basic plus protective eyewear,
chemical-resistant apron with attached full
sleeved chemical-resistant gloves, and a
respirator.
Restriction for Use Statement: "This product
cannot be used after May 30, 2002."
Application restrictions.
User safety requirements and
recommendations.
Page 24
-------
RED (Case #),
Author/CRM*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Pendimethalin
(Case 0187)
Jane Mitchell
All uses eligible.
Food uses
27 tolerances
reassessed.
Herbicide used on many
agricultural crops and
noncrop areas, residential &
recreational turf, and
ornamentals.
Low acute toxicity. Causes
thyroid tumors in rats; Group
C human carcinogen.
Dietary risk is minimal. Risks
to handlers are reduced with
extra PPE, longer REI, and
lower use rate. Turf risks
reduced with lower use rate.
PPE - Long sleeved shirt & long pants, shoes
& socks, chemical-resistant gloves required.
REI - 24 hour REI required (increased from 12
hours).
Engineering Controls -
> Water-soluble packaging required for all
wettabie powders;
> Use of closed systems may reduce
handler PPE requirements.
Application Restrictions to prevent contact with
people or pets, directly or through drift.
Homeowner Turf Uses -
> Reduce Application Rate - from 3 Ibs
ai/acre to maximum of 2 Ibs ai/acre for
residential lawns and sod farms;
> Entry Restrictions - People & pets should
not touch treated plants until sprays have dried
or enter treated areas until dusts have settled.
Environmental Hazards Statement required to
protect water.
Spray drift labeling advisory/best management
practices required.
User safety requirements and
recommendations.
Propoxur
(Case 2555)
Bonnie Adler
All uses eligible.
Food use (crack &
crevice treatments in
food handling
establishments);
tolerance proposed.
Insecticide used to control
ants, roaches, fleas &
hornets in/around residences
& food handling
establishments.
Moderate acute toxicity.
Group B2 carcinogen.
Dietary cancer risk minimal.
Cancer risk to resident
applicators acceptable.
Combined dietary and
residential risk to kids/others
acceptable. PPE reduces
risks to professional
applicators. Toxic to wildlife
& aquatic invertebrates.
PPE - Long sleeved shirt & long pants, shoes
& socks, and chemical-resistant gloves
required for PCOs.
Application Restriction - People and pets
should not enter treated area until sprays have
dried and dusts have settled.
Application Restrictions - To prevent contact
with people or pets, directly or through drift.
User safety recommendations.
Ecological Risk Statements - Warn users that
propoxur is toxic to wildlife and aquatic
invertebrates, and that birds and small
mammals feeding on treated bait may be
killed.
Page 25
-------
RED (Case #),
Author/CRN!*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Rodenticide Cluster:
Brodifacoum (2755),
Bromethalin (2765),
Bromadiolone (2760),
Chlorophacinone
(2100),
Diphacinone (2205),
Ph/al (2810).
Bill Wooge
All uses of all cases
eligible, except Pival
which is not eligible for
registration
(suspended and may
be canceled); and field
uses of high
concentration
Chlorophacinone and
Diphacinone.
No food uses.
Rddenticides used in urban,
suburban and rural areas to
control rats, mice & other
rodents.
Chlorophacinone &
Diphacinone also used in the
field to control several
vertebrate pests.
High acute toxicity (Toxicity
Category I) by oral, dermal &
inhalation routes of
exposure.
Large number of human
incidents reported each year
indicates children under age
6 are at greatest risk from
use around the home. Pet
risks (dogs) and secondary
nontarget poisonings also of
concern.
2-Phase program to reduce risks of all uses
(including residential uses) to children:
Phase 1 short term measures for all products
include:
> Incorporate indicator dye that stains hands
& mouth;
> Incorporate bittering agent;
> Restricted Use Pesticide classification for
tracking powders;
> Submit annual poison control center data;
> Improve use directions on labels.
Phase 2 longer term measure:
> Establish stakeholder group to discuss
additional ways to reduce exposure to children
and pets.
Pival - Not eligible for reregistration
(suspended and may be canceled).
Chlorophacinone and Diphacinone - Field
use of high concentration products are not
eligible w/o further rationale, to reduce risk of
secondary poisonings.
Sulprofos
(Case 0076)
Voluntary Cancellation
Food uses
27 tolerances
reassessed.
(None)
Page 26
-------
RED (Case #),
Author/CRM*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Terbacil
(Case 0039)
Emily Mitchell
All uses eligible.
Food uses
32 tolerances
reassessed.
Herbicide used on food &
feed crops, ornamentals,
and in forestry.
Group E carcinogen.
Associated with
developmental toxicity.
Poses no dietary or
aggregate exposure/risk
concerns. Poses potential
risks to surface & ground
water quality, nontarget
plants.
Maximum application rates must be reduced to
represent typical use situations.
Surface Water label advisory required.
Ground Water label advisory required.
PPE to be determined by acute toxicity of each
end use product.
REI - 12 hour REI required.
Page 27
-------
RED (Case #),
Author/CRM*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Thiobencarb
(Case 2665)
Dennis Deziel /
Pat Dobak
All uses eligible.
Food uses
25 tolerances
reassessed.
Pre-emergence herbicide
used primarily in rice; also in
lettuce, celery and endive.
Group D carcinogen. Poses
no dietary or aggregate
exposure/risk concerns.
Developmental toxicity risk to
handlers reduced with PPE,
engineering controls.
Poses high risk of acute &
chronic effects to fish &
invertebrates, and potential
risks to ground & surface
water quality.
Engineering Controls - For liquid formulations:
Mixers & loaders must use closed systems;
Applicators & flaggers must use enclosed
cabs/cockpits.
PPE for Liquid Formulations:
> Mixers & loaders must wear long sleeved
shirt & long pants, socks & shoes, chemical-
resistant gloves, chemical-resistant apron;
> Applicators & flaggers must wear long
sleeved shirt & long pants, socks & shoes.
> Other handlers must wear coveralls over
long sleeved shirt & long pants, chemical-
resistant gloves, chemical-resistant footwear,
chemical-resistant apron when cleaning
equipment.
PPE for Granular Formulations: Handlers
must wear long-sleeved shirt & long pants,
shoes & socks, chemical-resistant gloves,
chemical-resistant apron when loading
formulation or cleaning equipment.
REI - 24 hour REI required.
Early Entry PPE - Coveralls, shoes & socks,
chemical-resistant gloves required.
Application Restrictions - Do not apply:
> In a way that will contact people or pets,
directly or through drift;
> In Louisiana, south of the Intercoastal
Waterway;
> In Texas, w/in 2 miles of shorelines of
Matagorda Bay and Galveston Bay;
> To rice fields with catfish/crayfish farming;
> On rice fields adjacent to catfish/crayfish
ponds;
> Within 24 hours of rainfall;
> Do not release permanent flood water
within 14 days of application to rice;
> Do not mix/load/handle within 100 feet of
aquatic habitat.
User safety requirements and
recommendations.
Spray Drift labeling language required.
Page 28
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RED (Case #),
Author/CRM*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Triclopyr
(Case 2710)
Includes:
Triclopyr acid;
Triclopyr
triethylamine salt
(TEA); and
Triclopyr butoxyethyl
ester (BEE).
Dean Monos
All uses eligible.
Food uses
34 tolerances
reassessed.
Herbicides used on rights-of-
way, pasture, forests,
rangeland, residential turf,
and rice.
TEA is corrosive to the eye;
TEA and BEE cause dermal
sensitization. Group D
carcinogen. Reproduction
effects (kidney degeneration)
in rats. Poses no dietary or
residential risks of concern.
PPE & REI will reduce any
risks to handlers.
Triclopyr degradate
trichloropyridinol (TCP) may
leach to ground water.
Poses risks to nontarget
organisms.
Reduced Application Rates - Maximum
application rate for range & pasture use must
be reduced from 12 Ibs acid equivalents (ae)
per acre per year to 1 Ib ae/acre/yr.
Also for range & pasture uses:
> Only one application may be made per
growing season;
> Maintain restriction against grazing
lactating dairy cattle until next growing season;
> Specify 14 day PHI for grass hay;
> Retain existing pre-slaughter interval of 3
days.
Other Reduced Application Rates:
> For BEE and TEA forestry uses, specify
maximum of 6 Ibs ae/acre/year.
> For all other uses, BEE labels must specify
maximum of 8 Ibs ae/acre/year, and TEA
labels must specify maximum of 9 Ibs
ae/acre/year.
Statement to protect ground water required.
PPE - to be established based on acute toxicity
of each end use product.
REI - 48 hour REI required.
Early Entry PPE - Coveralls, chemical-
resistant gloves, shoes & socks, protective
eyewear required.
Non-WPS and Homeowner Uses - Do not
allow people/pets to enter treated area until
sprays have dried and dusts have settled.
Application Restrictions - Avoid contact with
people or pets, directly or through drift.
Engineering Controls - Use of closed systems
may reduce handler PPE requirements.
User safety requirements and
recommendations.
Skin sensitizer statement.
Spray Drift labeling language required.
Ground water advisory statement required.
Page 29
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RED (Case #),
Author/CRM*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
1,3,5-
Triethylhexahydro-s-
triazine
(Case 3147)
Marie Boucher/
Margaret Rice
All uses eligible.
No food uses.
Antimicrobial used as
industrial preservative in
adhesives, fuels, oil storage
tanks, metal working cutting
fluids, paints, rubber
products, and others.
Extremely corrosive; assume
Toxicity Category I for eye &
skin irritation.
Formaldehyde is a
degradate. Handler and
post-application inhalation
exposure is of concern, but
MOEs are acceptable and
PPE & engineering controls
will mitigate any remaining
risk.
PPE - Minimum for handlers is long sleeved
shirt & long pants, shoes & socks.
> If end use product is in Toxicity Category I
or II for eye irritation or if these data were
waived due to corrosivity, add: Protective
eyewear.
> If end use product is in Toxicity Category I
or II for acute dermal toxicity or skin irritation
potential, or if data on these effects were
waived due to corrosivity, add: Chemical-
resistant apron and chemical-resistant gloves.
> If end use product is in Toxicity Category I
or II for inhalation toxicity, add: Respirator.
Engineering Controls -
> Meter pumps/other automatic dispensing
equipment is required (open pouring is
prohibited) for wet-end additive/industrial
processing chemical uses.
> Vats must be closed and equipped with
mechanical vents to the outdoors for uses in
paint, rubber products, industrial adhesives, or
fuel/oil storage tank bottoms.
Application Restrictions - Prohibit use of
products in a way that will contact workers or
other persons, and prohibit application as a
spray.
User safety requirements and
recommendations.
Timing of Applications - Labels must specify
when & how often in manufacturing process
product may be added or applied.
Effluent Discharge Restriction - Is required
noting that product is toxic to fish and that
NPDES permit is required.
Page 30
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RED (Case #),
Author/CRM*,
Eligibility, Food/Non-
Food
Pesticide Type, Use
Pattern, and Risks
Risk Reduction
Measures
Zinc Phosphide
(Case 0026)
Susan Jennings
Ail uses eligible.
Food uses
6 tolerances
reassessed.
Rodenticide used indoors &
outdoors to control gophers,
mice, rats, lagomorphs,
prairie dogs, squirrels. Food
uses include grapes,
rangeland grasses,
sugarcane, regional
artichokes & sugar beets.
Toxicity Category I for acute
oral & inhalation effects.
Dietary exposure & risk
believed to be minimal.
Concern re: acute risks from
residential rodenticide uses,
especially to children,
mitigated by 2-Phase
program. Handler inhalation
risks reduced by PPE. Use
in agricultural fields will likely
kill nontarget birds &
mammals.
2-Phase Program to reduce risks of residential
uses to children - Same as for Rodenticide
Cluster above.
PPE - Formulation-specific PPE required for
all occupational uses.
> All formulation types require at a minimum:
Long sleeved shirt & long pants, shoes &
socks, chemical-resistant gloves.
> Concentrates, tracking powders, and
pellets/baits being loaded into aircraft & other
equipment also require respirator & protective
eyewear.
> Persons retrieving carcasses/unused bait
must wear chemical-resistant gloves.
RUP - Restricted Use Pesticide classification
must be retained for all agricultural uses.
Use Restrictions - For crop uses.
Application Restrictions -
> To prevent contact with workers or other
people, directly or through drift;
> To prevent contamination of water, food,
feedstuffs, food/feed handling equipment, etc..
> To prevent contamination of human or pet
food, preparation items or areas.
Directions for Use -
> Improve and make easy to read and
understand.
> Refer consumers to NPTN for additional
information.
First Aid Statements - Identify as such on
product labels, and make brief, clear, simple
and straightforward.
User safety requirements and
recommendations.
Environmental Hazard Statements -
> To protect water; and dogs/other
predatory/scavenging mammals.
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PRODUCT REREGISTRATION
The Product Reregistration Program
Product reregistration is the concluding phase of the reregistration process, in which
EPA's intentions about risk reduction and safer pesticide use, as expressed in RED documents,
become reality.
In developing a RED, EPA assesses a pesticide's human health and environmental effects,
as well as exposure through its current use patterns, to determine whether it poses any
unacceptable risks. To reduce risk, in issuing the RED document, EPA requires changes in the
pesticide's use, usually brought about by changes in product labeling. Data to evaluate the acute
toxicity and chemical properties of each end use product that contains the pesticide also are
required. Once these studies and amended labeling are submitted to EPA and approved, if all
their active ingredients are eligible, end use pesticide products may be reregistered.
EPA has begun implementing significant process improvements to increase its output of
product reregistration decisions. A Product Reregistration Branch, responsible for tracking and
processing most RED responses and data submissions, has added an in-house technical review
section and a label review team, plus an improved tracking system. These changes are enhancing
the Branch's capability to complete product reregistration reviews more quickly and efficiently,
with greater consistency. As a result, EPA expects to increase the quality, consistency, and
quantity of product reregistration actions completed during FY 98 (from 387 decisions in FY 97
to 900 - 1,200 this fiscal year) and in the future.
As more pesticide products are finally reregistered, the goals of the program -- reducing
pesticide risks and improving the safety of the public and the environment -- are being delivered.
Product Reregistration Status
At the end of FY 97, a total of
about 6,194 pesticide products were
associated with 171 completed REDs:
923 products were reregistered;
1818 products were canceled;
146 products were suspended;
55 product registrations were amended
because some but not all of their active
ingredients are eligible for reregistration;
2,104 products were pending EPA
decisions; and
1,148 products were not yet due for
decisions (REDs were completed but not
yet mailed, or product specific data were
not yet due to be submitted to EPA).
Product Reregistration Status
for 171 Completed REDs
146 Suspended
2104 Pending
923 Reregistered
55 Amendments
1148 Not Yet Due
1818 Canceled
Page 32
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TOLERANCE REASSESSMENT UNDER FQPA
New FQPA Provisions
The Food Quality Protection Act of 1996 introduced a number of significant new
regulatory provisions addressing pesticides and food safety. FQPA established a new safety
standard ~ reasonable certainty of no harm -- for pesticides used on food commodities. EPA
must apply this more stringent, protective standard in establishing new tolerances (maximum
residue limits for foods), and in reassessing all existing tolerances over a 10 year period,
examining the potentially riskiest pesticides first. In reassessing tolerances under FQPA, EPA
must consider, among other things, aggregate exposure to the pesticide from all non-occupational
sources, cumulative effects, special sensitivities of infants and children, and endocrine effects.
Tolerance Reassessment Schedule
FQPA requires that within 10 years, EPA reassess all tolerances and tolerance
exemptions that were in place on August 2, 1996, the day before the new law was enacted.
FQPA also sets the following intermediate deadlines:
Reassess 33 percent of all
tolerances by August 2, 1999;
Reassess 66 percent by August
2002; and
Reassess 100 percent by August
2006.
At the time of FQPA's enactment,
there were about 9,635 tolerances and
exemptions for active and inert ingredients
that are subject to this time table. The bar
graph presents the numbers of tolerances
that EPA must reassess within the time
frames specified by the FQPA schedule.
For additional information, please
see EPA's Schedule for Pesticide
Tolerance Reassessment, published in the
Federal Register on August 4, 1997 (62
FR 42020-42030).
Tolerance Reassessment Schedule
10000-
8000-
6000-
4000-
2000-
T 1 T
August 1999 August 2002 August 2006
FQPA Reassessments
Page 33
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Priorities for Reassessment
EPA will give first priority to reassessment of tolerances associated with the pesticides
that the Agency believes may pose the greatest potential risk to public health. These pesticides
include the organophosphates, carbamates, and probable and possible human carcinogens. Also
included are the organochlorine pesticides, high-hazard inert ingredients, and other pesticide
chemicals for which reregistration is substantially complete.
Progress: Current and Continuing
Reassessing Tolerances for High Priority Pesticides
5000-
4000-
3000-
2000-
1000-
0
Non-OP REDs (1400)
OPREDs(1350)
Revocations (1460)
Post-FQPA REDs (412)
Since August 3, 1996, EPA has
issued 30 post-FQP A REDs, 18 of which
have food uses with approximately 412
associated tolerances. In addition, the
Agency is in the process of proposing or has
proposed for revocation approximately
1,460 tolerances, and these revocations
count as FQPA reassessments. During FY
98-99, EPA also plans to reassess about
1,350 tolerances for the organophosphate
(OP) pesticides and 1,400 tolerances for
non-OP REDs. In this way, EPA may meet
the FQPA requirement to reassess 33
percent of all tolerances (about 3,180) for
pesticides that pose the greatest risk by
August 1999.
Background
Tolerance reassessment has been part of the reregistration process since accelerated
reregistration began under FIFRA '88. EPA reassessed over 1,500 tolerances and tolerance
exemptions in the course of making reregistration eligibility decisions for the 171 pesticides that
now have completed REDs. For pesticides registered after November 1984 (known as the post-
1984 chemicals) and for newly registered pesticides, EPA used the registration process to ensure
that tolerances were safe and posed no dietary risk concerns.
Now, under FQPA, tolerance reassessment will continue to be an output of pesticide
reregistration. For pesticides subject to reregistration, tolerances and tolerance exemptions are
being reassessed as REDs are being developed. The Agency also is reassessing tolerances and
exemptions associated with the 53 food use REDs that were completed pre-FQPA, the post-'84
pesticides (which are not subject to reregistration), and food-use inert ingredients. After the
reregistration program is completed in 2002, tolerance reassessment will continue in the future
under the registration review program.
Page 34
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THE ORGANOPHOSPHATES
The class of pesticides known as the organophosphates are EPA's highest regulatory
priority for both reregistration and tolerance reassessment under FQPA. These chemicals are
among both the riskiest and most widely used pesticides on the market today. The
organophosphates present a unique regulatory challenge because they share a common
mechanism of toxicity, EPA must evaluate the total exposure and risk presented by all of them at
once. The organophosphates will be the first large group of pesticides to be reassessed together
under the new, stricter standard of the FQPA.
What are Organophosphate Insecticides?
The organophosphates are 40 currently registered pesticides used widely in U.S.
agriculture on both major and minor crops, and for public health protection, structural pest
control, and lawn care. Approximately 60 million pounds of organophosphates are applied to 60
million acres of agricultural crops each year including field corn, cotton, other field crops (e.g.,
canola, alfalfa), fruits and nuts, and vegetables. In addition, about 17 million pounds are applied
to non-agricultural sites for termite and mosquito control, livestock and pet pest control, grain
storage, residential and commercial use, and turf and ornamental uses.
Acephate
Azinphos-methyl
Bensulide
Cadusafos
Chlorethoxyfos (Fortress)
Chlorpyrifos
Chlorpyrifos methyl (Reldan)
*Chlorthiophos
Coumaphos
DEF
Diazinon
Dichlorvos (DDVP)
Dicrotophos
Dimethoate
*Dioxathion
Disulfoton
Ethion
Ethoprop
Ethyl parathion
Fenamiphos
Fenitrothion
Fenthion
Fonofos
Isazophos methyl (Triumph)
* Canceled
Organophosphate Pesticides
Isofenphos
Malathion
Methamidophos
Methidathion
Methyl parathion
*Mevinphos
*Monocrotophos
Naled
Oxydemeton methyl
Phorate
*Phosalone
Phpsmet
*Phosphamidon
Phostebupirim (Aztec)
Pirimiphos methyl
Profenofos
Propetamphos
Sulfotepp
*Sulprofos
Temephos
Terbufos
Tetrachlorvinphos
Trichlorfon
Page 35
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What Risks Do the Organophosphates Pose?
Organophosphates, used in World War II as nerve toxins, have the potential to adversely
effect the nervous system. They inhibit cholinesterase, an enzyme that normally deactivates the
chemical acetylcholine in neurons. Acetylcholine acts in transferring nerve impulses from a nerve
cell to a muscle cell or another nerve cell. Reducing the deactivation of acetylcholine lets the
cholinergic neurons remain active longer than they should, which results in overstimulation and
symptoms such as weakness or paralysis of the muscles.
Organophosphates can have a range of effects on the nervous system. Depending on the
amount of exposure, they can cause short-term, reversible effects such as headaches, nausea, and
vomiting, or more serious effects that may require medical treatment, such as muscle weakness
and breathing difficulties. Exposure to high levels may even be fatal. There also is evidence that
they may cause longer lasting, harder-to-observe damage to the nervous system.
Since children eat more food, drink more water, and breathe more air for their body
weight than adults do, they often are more exposed than adults and may be more sensitive to the
effects of pesticides, including the Organophosphates.
What is EPA Doing to Address the Risks Posed by the Organophosphates?
EPA has given top priority to reassessment of the Organophosphates under the new,
stricter safety standard of the FQPA. The reassessment is underway now, and the Agency is
giving particular attention to both the possible short- and long-term effects of these compounds
on infants and children. This reassessment includes several important steps:
For each of the 40 Organophosphates, establishing a level of daily exposure (called a
reference dose) that is safe not only for adults but also for infants, children, and any other
sensitive subpopulations;
Determining total exposure to each of these compounds from use in food production,
around homes, and through drinking water;
Evaluating the total exposure and risk for all 40 Organophosphates as a group, since they
share a common mechanism of action on the nervous system; and
Taking action to reduce all exposures that exceed the safety standard of the new law.
EPA will be releasing its regulatory strategy for the Organophosphates in the next several
months.
Page 36
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SCHEDULE FOR FUTURE REDS
Integrated Schedule for Reregistration and Tolerance Reassessment
EPA's schedule for completing future pesticide Reregistration Eligibility Decisions has
been constructed to reflect the FQPA requirement that the Agency reassess all existing tolerances
over a ten year period, considering pesticides that pose the greatest potential risks first. EPA's
current schedule also reflects the Agency's goal to complete the reregistration program by 2002,
and complete tolerance reassessment by August 2006.
A list of the fiscal year 1998 RED candidate pesticides appears below, followed by a list of
groups or waves of pesticides that are the Agency's highest priority for reregistration and
tolerance reassessment during the next several years.
FY 98 RED Candidates
EPA's goal is to complete 40 REDs during FY 98, from among the following candidate
pesticides.
Organophosphates: *
Acephate
Azinphos-methyl
Bensulide
Chlorpyrifos
DBF
DDVP
Diazinon
Dicrotophos
Dimethoate
Disulfoton
Ethion
Ethoprop
Ethyl Parathion
Fenamiphos
Fenthion
Fonofos
Isofenphos
Malathion
Methamidophos
Methidathion
* Includes only OP's currently in the
Methyl Parathion
Naled
Oxydemeton-methyl
Phorate
Phosmet
Pirimiphos methyl
Profenophos
Propetamphos
Sulfotepp
Temephos
Terbufos
reregistration process, not completed
Non-Organophosphates:
Alachlor
Aluminum &
Mg Phosphide
Amdro
Bendiocarb
Benomyl
Bromoxynil
Captan
Carbofuran
Chlorothalonil
DEET
Dicofol
Folpet
Formetanate HCI
Iprodione
Methomyl
Propachlor
Telone
Thiodicarb
Vinclozolin
REDs or post-'84 pesticides.
Page 37
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Waves
EPA's tentative schedule for reviewing clusters or waves of pesticides for purposes of
both reregistration and tolerance reassessment during the next several years follows.
Priority Group 1 Pesticides Subject to Reregistration Review
and/or Tolerance Reassessment under FQPA, Waves 1-11
Chemical
Chemical Class
or Toxicology Concern
Wave 1
Ethfon
Fenamiphos
Fenthion
Naled
Phorate
Profenophos
Terbufos
Formetanate HCI
Chlorothalonil
Captan
Folpet
Telone
Vinclozolin
Dicofol
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
carbamate
B2 carcinogen
B2 carcinogen
B2 carcinogen
B2 carcinogen
B2 carcinogen
organochlorine
Page 38
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Chemical
Chemical Class
or Toxicology Concern
Wave 2
Azinphos-methyl
Chlorpyrifos
DEF
Dimethoate
Isofenphos
ODM
Propetamphos
Iprodione
Bendiocarb
Carbofuran
Methomyl
Thiodicarb
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
B2 carcinogen
carbamate
carbamate
carbamate
carbamate
Wave3
Bensulide
DDVP
Disulfoton
Malathion
Phosmet
Benomyl
Alachlor
Propachlor
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
carbamate
B2 carcinogen
chloroacetanilide
Page 39
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Chemical
Chemical Class
or Toxicology Concern
Wave 4
Diazinon
Ethyl Parathion
Methyl Parathion
Pirimiphos-methyl
Sulfotepp
Temephos
Al and Mg Phosphide
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
phosphide fumigants
(inhalation hazard)
WaveS
Acephate
Dicrotophos
Ethoprop
Methamidophos
Methidathton
Fonofos
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
organophosphate
Non-RED Organophosphates1
Food-Use Organophosphates:
Cadusafos (post-84)
Coumaphos (pre-FQPA RED)
Chlorpyriphos-rnethyl (post-84)
Fenitrothion (pre-FQPA RED)
Mevinphos (pre-FQPA RED)
Monocrotophos
Phostebuplrim (post-84)
Chlorethoxyfos (post-84)
Tetrachlorvinphos (pre-FQPA RED)
Trichlorfon (pre-FQPA RED)
Non-Food Use Organophosphates:
Isazophos-m ethyl (post-84)
OPs are not in the reregistration queue ~ REDs were completed for them prior to
FQPA, or they are not subject to reregistration. However, for most, tolerances still must be
reassessed under FQPA. The other OPs are scheduled as REDs in Waves 1 through 5.
Page 40
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Pesticide
Chemical Class
Wave 6
Phenmedipham
fhiophanate methyl
Asulam
CIPC
Desmedipham
Propamocarb hydrochloride
(pre-FQPA RED)
Aldicarb
Oxamyl
Aldoxycarb (post-84)
vlolinate
Tri-allate
EPTC
Pebulate
Vernolate
Butylate
Thiobencarb
carbamate
carbamate
carbamate
carbamate
carbamate
carbamate
oxime carbamate
oxime carbamate
oxime carbamate
thiocarbamate
C carcinogen
thiocarbamate
C carcinogen
thiocarbamate
thiocarbamate
thiocarbamate
thiocarbamte
thiocarbamate
Wave?
Lindane
Endosulfan
Methoxychlor
organochlorine
B2
organochlorine
organochlorine
Waved
2-Phenylphenol
Ethylene oxide
Propylene oxide
Mancozeb
Maneb
Metiram
Sodium salt of acifluorfen
Cacodylic Acid
Propargite
TPTH
Oxythioquinox
Terrazole
PCNB
Formaldehyde
Paraformaldehvde
alkylenebis(dithiocarbamate)
B2
alkylenebis(dithiocarbamate)
B2
alkylenebis(dithiocarbamate)
B2
dimethyldithiocarbamate
organo arsenical
organosulfur
organotin
quinoxaline
Thiazole
aromatic hydrocarbon derivative
Page 41
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Pesticide
Chemical Class
Wave 9
Carbaryl
Atrazine
Simazine
Propazine (section 18 use only)
Cyanazine (to be canceled in 1999 &
phased out by 2002)
Oxadiazon
Imazalil
Oxyfluorfen
Permethrin
Thiabendazole
Thiophanate methyl
Lactofen
Sodium salt of fomesafen
Sodium dimethyldithiocarbamate
Diclofop-methyl
Fenoxaprop-ethyl
Quizalofop-ethyl
carbamate
1 ,3,5-triazine
1 ,3,5-triazine
1 ,3,5-triazine
1 ,3,5-triazine
benzimidazole
diphenyl ether
pyrethroid
benzimidazole
benzimidazole
diphenyl ether
diphenyl ether
diphenyl ether
2-(4-aryloxyphenoxy) propionic acid
2-(4-aryioxyphenoxy) propionic acid
2-(4-aryloxyphenoxy) propionic acid
Wave 10
Cypermethrin
Propiconazole
Triadimefon
Fenbuconazole
Myclobutanil
Tebuconazole
Triflumazole
Triadimenol
Difenoconazole
pyrethroid
azole
azole
azole
azole
azole
azole
azole
azole
Page 42
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Pesticide j Chemical Class
Wave 11
Diphenamid
Dipropyl isocinchomeronate
DNOC
TCMB
Tetradifon
Thiram
2,4-D
Cycloate
Chloramben
Chloroxuron
Diethatyl ethyl
Hexythiazox
Benfluralin
Ethalfluralin
Oryzalin
Pendimethalin
Trifluralin
Butralin
Dinocap
aryloxyalkanoic acid
2,6-dinitroaniline
2,6-dinitroaniline
2,6-dinitroaniline
2,6-dinitroaniline
2,6-dinitroaniline
2,6-dinitroaniline
dinitrophenol derivative
Page 43
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SPECIAL REVIEW
The Special Review Process
Special Review is EPA's formal procedure for determining whether the use of a pesticide
poses unreasonable risks to people or the environment. In making this determination, the Agency
must consider both the pesticide's risks and benefits. A Special Review can result in a decision to
cancel, restrict, modify, or continue the pesticide uses in question.
Criteria
The criteria for initiating a Special Review, set forth in 40 CFR Part 154, include:
Acute toxicity to humans or domestic animals;
Potential chronic or delayed toxic effects in humans;
Potential hazards to non-target organisms;
Risk to the continued existence of any threatened or endangered species;
Risk of destruction or other adverse modification of a critical habitat of any threatened or
endangered species; or
Any other adverse effect to humans or the environment which may outweigh the benefits
that justify initial or continued registration.
Current Approach
Until the early 1990's, EPA took a traditional regulatory approach in conducting Special
Reviews, issuing Position Documents at several stages in the formal review process,
supplemented by Notices of Intent to Cancel or Suspend as needed. In recent years, however, the
Agency has pursued and achieved the same regulatory objectives through negotiated settlements
to Special Reviews. Through negotiations, registrants may reach agreements with EPA to modify
the terms and conditions of their pesticide registrations to reduce risks. The range of such
modifications includes canceling uses; changing use patterns, application methods or rates; or
adopting other measures to better protect people or the environment.
Negotiated settlements are advantageous in that they can bring about needed, targeted risk
reduction more quickly using significantly fewer resources than the traditional Special Review
process. In recent years, EPA and registrants have successfully negotiated settlements for several
major pesticides including mevinphos, ethyl parathion, methyl parathion, and others.
In addition to negotiating agreements, EPA also is resolving more Special Reviews
through the process of developing Reregistration Eligibility Decisions. For example, Special
Review issues currently are being resolved through RED negotiations for Telone. By combining
Special Review with the reregistration process, efficiencies are gained that may result in obtaining
needed pesticide risk reduction more quickly and cost effectively.
Page 44
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Pesticides in Special Review
The risks of over 100 pesticides have been managed through the Special Review process
during the past 20 years, as summarized in the EPA document, "Status of Chemicals in Special
Review" (February 1998). The following 11 pesticides are in Special Review at present.
Aldicarb
Atrazine (part of Triazines review)
2,4-D (including 2,4-DB and 2,4-DP)
1,3-Dichloropropene or Telone
Dichlorvos or DDVP
Ethylene Oxide
Oxydemeton-methyl or ODM
Propazine (part of Triazines review)
Simazine (part of Triazines review)
Tributyltins (antifouling use)
Triphenyltin hydroxide or TPTH
Special Review Decisions in FY 97
OPP negotiated with pesticide registrants during fiscal year 1997 to expedite the reduction
of risks associated with several pesticides in Special Review. The following agreements and
decisions will bring about significant reduction in pesticide risk.
Flowable Carbofuran - EPA and FMC Corporation reached an agreement on interim risk
mitigation measures for flowable carbofuran to protect agricultural workers and wildlife. EPA's
concerns were with reports of bird and wildlife kills and incidents of human exposure received
from the company, State agencies, Poison Control Centers, and other sources. In an effort to
reduce the occurrence of such incidents, FMC has agreed to: adopt closed mixing and loading
systems for all flowable carbofuran products within the next three years, with 85% of their
production in closed compatible containers by 1997; reduce the amount of chemical that can be
applied and the number of applications allowed on numerous crops; implement spray drift
management practices; eliminate 48 special local needs registrations; voluntarily cancel the use
of flowable carbofuran on strawberries and grapes; and other measures.
Methyl Parathion - Methyl parathion is an organophosphate insecticide registered on a
variety of agricultural crops for outdoor use only. However, because it is relatively inexpensive,
highly toxic, and persistent indoors, methyl parathion has been applied illegally indoors to control
roaches and other insects. Persons exposed to methyl parathion after such unlawful indoor
applications are at risk of acute poisoning. Discussions with Cheminova Agro A/S, the
manufacturer of methyl parathion, to address the problem began after EPA's Region 5 office
documented numerous examples of indoor misuse in Ohio, Michigan, and Illinois. More recently,
in mid-1996, incidents of widespread indoor misuse were reported in Mississippi, Louisiana, and
Alabama. In response, EPA, in conjunction with the Agency for Toxic Substances and Disease
Page 45
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Registry, issued a nationwide alert to consumers, and worked with Cheminova to achieve a
comprehensive agreement to deter further misuse, which was signed on December 30, 1996.
Provisions of the agreement include a recall of all methyl parathion down to the user level, the
addition of a stenching agent to give the products an offensive odor, packaging of all products in
returnable/refillable containers which each have a unique barcode to be tracked by retailers, and
an education program to inform the public about the dangers of indoor pesticide misuse.
Copper and Zinc Naphthenate - On March 12, 1997, the technical registrants of copper
and zinc naphthenate products submitted amended product labels which reflected several risk
mitigation measures. OPP worked with the California Department of Pesticide Regulation
(CDPR) to develop and negotiate these measures, aimed at reducing end-user exposure to these
products. Copper and zinc naphthenate products are topically applied wood preservatives and
present a hazard to end-users through the malodorous off gassing of their naphthenic base.
Through negotiations, these products will now be labeled for exterior use only, will have a
strengthened precautionary statement against inhalation and dermal exposure, and will bear a 1-
800 number for medical questions and emergencies.
Vinclozolin - On April 29, 1997, the registrant of vinclozolin, BASF, submitted a request
to amend its registrations to delete use on tomatoes, table grapes, plums (including prunes), and
residential turf, as well as turf in schoolyards, parks, and recreational areas. The registrant also
temporarily removed residential garden uses from its labels until the Agency has completed its
RED for vinclozolin. If the uses are eligible for reregistration, they will be reinstated on the label.
If not, they will be voluntarily canceled. These use deletions allowed the registrant to obtain a
new use, succulent beans, while reducing dietary and residential risk. EPA is in the process of
revoking tolerances associated with the deleted food uses.
Methamidophos - On July 7, 1997, EPA published a Federal Register notice announcing
receipt of a request from Bayer Corporation and Valent USA, the methamidophos registrants, to
delete all uses except cotton, potatoes, and tomatoes from all methamidophos labels. The
registrants also agreed to implement closed mixing and loading systems for all methamidophos
products registered in the United States. Bayer and Valent took these voluntary actions in
response to EPA's concerns about methamidophos exposure to agricultural workers. EPA
accepted these measures as interim risk mitigation; the remaining methamidophos uses will be
evaluated at the time of the RED.
Iprodione - In March 1997, EPA negotiated with Rhone Poulenc to reduce dietary risk
from peaches. As a result, the company agreed to reduce the number of applications per use
season from four to three, and to restrict application timing to the stage prior to petal fall, thereby
increasing the pre-harvest interval (PHI) from 7 to 90 days. Although the reduction of risk
resulting from these changes is not precisely quantifiable at this time, field data indicate that 99%
of the residue is the result of the last (7 day PHI) application, and the company is currently doing
new field trials to reflect the new use rates. These label changes, as negotiated, were approved in
April 1997, with relabeling of existing stocks to be completed by December 1997.
Page 46
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RfD Exceeders - OPP completed the RfD exceeders project, an effort that had been in
progress since 1989, which involved screening over 400 chemicals to determine which actually
pose unacceptable dietary risks. Results of refined assessments indicate that out of the original
110 pesticides that appeared to exceed the health standard, only four (formetanate HCL, oxamyl,
fenthion, and methyl parathion) still exceed the RfD. The dietary risks for these four will be
addressed through the RED process. OPP also is in the process of revoking tolerances for RfD
exceeders where some or all food uses have been canceled.
Tolerance Reassessment Schedule - On August 4, 1997, EPA published its schedule for
reassessing tolerances under FQPA. Publication of this schedule met the requirements of section
408(q)(3) of the Federal Food, Drug, and Cosmetic Act.
Page 47
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Risk Reduction through Special Reviews
The following FY 97 Special Review actions, decisions, and agreements will result in risk
reduction through label amendments and other measures.
Risk Reduction through Special Review Activities, FY 97
Risks
Use Reduction
Voluntary
Cancellation/
Uses Deleted
PPE Added;
REIs & PHIs
Adjusted
Special
Packaging/
Engineering
Controls
Use
Restrictions/
Stronger Use
Directions
Spray Drift
Labeling
Environmental
Safeguards
Risks to Kids
Reduced
Other Special
Measures
Carbofuran
Worker and
wildlife risks
Copper
and Zinc
Naphthenate
Malodorous
off-gassing
Iprodione
Dietary risk
from
peaches
Metha-
midophos
Worker risks
Methyl
Parathion
OP; Acute
human
poisonings
Vinclozolin
Dietary,
residential
risks
Other FY97 Special Review decisions/accomplishments include:
Tolerance Reassessment Schedule published 8/4/97; RfD Exceeders project completed.
Page 48
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APPENDIX
Cumulative Summary of Reregistration Eligibility Decisions
This Appendix contains a cumulative list of the 171 Reregistration Eligibility Decisions
(REDs) completed to date, by fiscal year. The information provided for each completed RED
includes its reregistration list, the date signed, number of chemicals/active ingredients included,
number of products included, and number of tolerances covered/reassessed.
RED and Tolerance Totals at a Glance
171
j Total Chemicals/ATs Covered ~ 265
1 Total Products Covered ^6* 194
j Total REDn with ^ood^lses." 70
[ Total^Toleranees Reassessed- 1,569
j ,
| REDs Completed Fast-K>P A = 3$ '
I Post-FQPA REDs Wi& Food Uses ģ 18
j Tolerance^ Reassessed Past-FQPA^ 412
~
Page 49
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FY 91 REDs Summary
RED Case Name
1 . Carbon and Carbon Dioxide
2. Dried Blood
3. Fosetyl-Al (Aliette)
4. Heliothis zea NPV
5. Methoprene
6, Potassium Bromide
7. Propionic Acid
8. Silicon Dioxide/Silica Gel
9. Sodium and Calcium Hypochlorites
10. Sodium and Potassium Nitrates
11, Sodium Diacetate (Acetic Acid,
Sodium Salt)
12. Sulfur
13. Warfarin
Totals
List
D
D
A
A
A
A
D
D
A
D
D
A
A
Date
Signed
9/91
9/91
12/90
12/90
3/91
6/91
9/91
9/91
9/91
9/91
9/91
3/91
6/91
#Chemicals/
AIs Covered
2
1
1
1
1
1
1
2
2
2
1
1
2
18
#Products
Covered*
9
3
2
1
63
2
14
75
770
6
2
332
76
1,355
Total
Tolerances
0
0
24
0
23
0
0
0
0
0
0
0
0
47
FY 92 REDs Summary
RED Case Name
14. Alkyl Amine Hydrochloride
15. Allium Sativum (Garlic)
16. Bone Oil **
17. Capsaicin
18. Chlorinated Isocyanurates
19. Citric Acid
20. Ethylene
21.Heptachlor
22. lndole-3-Butyric Acid (IBA)
23. Nosema Locustae
24. Putrescent Whole Egg Solids
25. Soap Salts
26, Sodium Hydroxide
27. Streptomycin
28. Zinc Salts
List
C
D
C
D
A
D
C
A
B
D
D
D
D
A
D
Date
Signed
8/92
6/92
6/92
6/92
9/92
6/92
9/92
3/92
8/92
9/92
6/92
9/92
9/92
9/92
8/92
^Chemicals/
AIs Covered
1
1
1
1
5
1
1
1
1
1
1
2
1
2
2
#Products
Covered*
3
4
2
8
741
3
8
2
31
6
6
25
9
26
7
Total
Tolerances
0
0
N/A
0
0
0
0
0
0
0
1
0
0
5
0
Totals
22
881
* The number of products listed reflects the number registered at the time the RED was completed. This
number is constantly changing.
** Voluntary cancellation.
Page 50
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FY 93 REDs Summary
RED Case Name
List Date #Chemicals/ ^Products Total
Signed Als Covered Covered* Tolerances
29. Biobor
30. Boric Acid
31 . Butylate
32. Cedarwood Oil
33. Daminozide
34. Eugenol ***
35. Glyphosate
36. Inorganic Halides
37. Iron Salts
38. Menthol ***
39. OBPA
40. Oxalic Acid
41 . Oxytetracycline
42. PEP (phenylethyl propionate) ***
43. Silver
44. Sodium Lauryl Sulfate
45. Sulfuryl Fluoride
46. Thymol
47. Tris(hydroxymethyl)nitromethane
C
A
A
C
A
D
A
D
D
D
A
D
A
C
D
D
A
C
C
6/93
9/93
9/93
9/93
9/93
9/93
9/93
9/93
3/93
9/93
6/93
12/92
3/93
9/93
7/93
9/93
9/93
9/93
9/93
2
7
1
1
1
1
2
2
3
1
1
1
3
1
1
1
1
1
1
12
189
14
5
4
5
56
35
5
1
15
4
7
5
65
2
1
5
9
0
1
4
0
0
1
126
0
0
1
0
0
2
0
0
1
0
0
0
Totals
32
439
136
* The number of products listed reflects the number registered at the time the RED was completed. This
number is constantly changing.
*** Exempted from regulation as a pesticide active ingredient under Section 25(b) of FIFRA.
Page 51
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FY 94 REDs Summary
RED Case Name
List Date #Chemicals/ #Products Total
Signed Als Covered Covered* Tolerances
48. Barium Metaborate
49, Bromine
50. Lithium Hypochlorite
51. Mineral Acids
52. Peroxy Compounds
53. Vegetable and Flower Oils
54. 2-1 (Hydroxymethyl)Amino]
Ethanol or Ethanolamine
55. Hexadecadienol Acetates
56. Methiocarb
57. Periplanone B
58. Pronamide
59. Tebuthiuron
60. Maleic Hydrazide
61 . N6-Benzyladenine
62. Bentazon
63. Chlorine
64. p-Chloro-m-xyienol
65. Cosan 145 or Nuosept 145
66. Cresol
67. DBNPA
68. DCDIC
69. Difenzoquat
70. Fenbutatin-Oxide or Vendex
71 . Hexazinone
72. Limonene
73. Mercaptobenzothiazole
74. Metalaxyl
75, Mevinphos **
76. Muscalure or (z)-9-Tricosene
77.OiIofCitronella***
78, Oryzalin
79. Piperalin
80, Sodium Cyanide
81.Xylenol
A
D
C
D
D
D
C
D
A
B
A
A
A
B
A
D
C
C
D
C
C
A
A
A
C
B
A
A
D
C
A
C
C
D
12/93
12/93
12/93
12/93
12/93
12/93
3/94
3/94
3/94
3/94
3/94
3/94
6/94
6/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
9/94
1
1
1
4
3
6****
2
2
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
3
4
40
212
23
32
3
18
22
1
18
12
26
2
14
72
7
2
1
46
80
2
10
20
15
5
81
0
11
17
38
1
7
1
0
1
0
0
0
0
0
1
9
0
55
15
4
1
45
1
0
0
0
1
1
22
44
11
1
0
95
0
0
0
20
0
0
0
Totals
48
846
327
* The number of products listed reflects the number registered at the time the RED was completed. This
number is constantly changing.
** Voluntary cancellation.
**" Exempted from regulation as a pesticide active ingredient under Section 25(b) of FIFRA.
**** One A.I., "essential oils" will become 24 A.l.s after the RED is issued; many of these will eventually be
declared inert ingredients.
Page 52
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FY 95 REDs Summary
RED Case Name
List
Date #ChemicaIs/ #Products Total
Signed Als Covered Covered* Tolerances
82. Benzocaine ***
83. Bromobydroxyacetophenone
84. Ethalfluralin
85. Ethephon
86. Fosamine Ammonium
87. Linuron
88. Metolachlor
89. Polybutene
90. Terbuthylazine
91 . Aliphatic Alcohols
92. Amitraz
93. 4 CPA & Salts
94. Diquat Dibromide
95. Dowicil 100
96. Fenitrothion
97. Picloram
98. Agrobacterium Radiobacter
99. Alkyl Imidazolines
1 00. Ancymidol
1 01 . Asulam
1 02. Bis(trichloromethyl) sulfone
103. Bronopol
1 04. Chiorhexidine Diacetate
105. Chlopropham
106. Cyanazine**
1 07. Cytokinin
108. DCPA
109. Dimethoxane
110. Methyl Nonyl Ketone
111. Nabam
112. Nurarone
113. O-Benzyl-Chlorophenol
114. Prometryn
D
(BHAP) C
B
A
B
A
A
D
B
D
A
B
A
C
A
A
D
C
C
A
B
B
C
A
A
D
A
C
C
A
D
B
A
115. Propamocarb Hydrochloride C
116. Sodium Fluoroacetate
117. Sodium Omadine
118. Starlicide
119. Tetrachlorvinphos
120. Trichlorfon
121.Trifluralin
C
A
B
A
A
A
12/94
12/94
12/94
12/94
12/94
12/94
12/94
12/94
12/94
3/95
3/95
3/95
3/95
3/95
3/95
3/95
6/95
6/95
6/95
6/95
9/95
9/95
6/95
9/95
9/95
9/95
9/95
6/95
6/95
9/95
9/95
9/95
9/95
9/95
6/95
6/95
6/95
6/95
9/95
9/95
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
7
1
10
1
2
1
1
3
1
1
1
1
1
1
1
1
3
1
2
2
1
1
1
1
1
1
3
6
20
1
27
47
6
4
140
8
2
77
2
8
1
2
2
2
4
14
22
2
27
19
18
80
1
47
11
5
132
15
1
7
5
15
129
27
181
0
0
26
30
0
45
71
0
0
0
28
2
45
0
1
48
0
0
0
1
0
0
0
27
11
1
27
0
0
0
0
0
13
0
0
0
0
17
67
41
Totals
63
1,121
501
* The number of products listed reflects the number registered at the time the RED was completed. This
number is constantly changing.
** Voluntary cancellation.
*** Exempted from regulation as a pesticide active ingredient under Section 25(b) of FIFRA.
Page 53
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FY 96 REDs Summary
RED Case Name
List Date ^Chemicals/ #Products Total
Signed Als Covered Covered* Tolerances
122. Gibberellic Acid
123. Hydroxyethyl Octyl Sulfide
124. Hydroxypropyl methanethiosulfonab
(HPMTS)
125. Desmedipham
126. 4,4 Dimethyloxazolidine
127. Methylisothiazolinone
128. Tanol Derivatives (Furanone)
129. p-Chloro-m-cresol
130. Mitin FF
131. Dibromodicyanobutane
132. Cryolite
133. Norfiurazon
134. Coumaphos
135. Amitrole
136. Strychnine
137. B. Popilliae ***
138. Tridecenyl Acetates
139. Cloprop**
140. Oil of Pennyroyal **
141. Phosphamidon **
r"VM~ģ A Cf\FD A. n 1-, r. r. r-. r-.
-------
FY 97 REDs Summary
RED Case Name
List Date #Chemicals/
Signed Als Covered
#Products
Covered*
Total
Tolerances
149. 3-lodo-2-propynyl butylcarbamate
(IPBC)
1 50. 1 ,3,5-Triethylhexahydro-s-triazine
(Vancide TH)
151. Methylene bis(thiocyanate) (MBT)
152. Metribuzin
153. Sulprofos**
154. Pendimethalin
155. Diflubenzuron
156. Propoxur
157. Paranitrophenol (PNP) **
158. Butralin
159. Terbacil
160. Bacillus thuringiensis (Bt)
161. Dichlobenil
162. Diphenylamine
163. Thiobencarb
164. Triclopyr
165. Zinc Phosphide
166. Brodifacoum
167. Bromethalin
168. Bromadiolone
169. Chlorophacinone
170. Diphacinone
171. Pival***
B
C
B
A
A
A
A
B
B
B
A
A
A
B
B
B
A
B
B
B
B
B
B
3/97
3/97
4/97
4/97
4/97
4/97
5/97
9/97
9/97
9/97
9/97
9/97
9/97
9/97
9/97
9/97
9/97
9/97
9/97
9/97
9/97
9/97
9/97
1
1
1
1
1
1
1
1
1
1
1
13
1
1
1
3
1
1
1
1
1
2
2
59
2
59
71
0
58
32
147
1
2
12
179
32
3
23
37
59
38
18
27
57
104
2
0
0
0
60
27
27
32
0
0
0
32
5
14
3
25
34
6
0
0
0
0
0
0
Totals
39
1,022
265
* The number of products listed reflects the number registered at the time the RED was completed. This
number is constantly changing.
** Voluntary cancellation. (Effective 5/30/02 for PNP.)
*** Not eligible for reregistration.
Page 55
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