vEPA
           United Sum
           Environmental Protection
           Agency
            Off ice of
            PwticidM and Toxic SubManow
            Washington DC 20460
                                 540/RS-88-086
           Pwticictos
Guidance for the
Reregistration of
Pesticide Products
Containing SULFOTEPP
as the Active Ingredient

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                                      OMB  Control No.  2070-OOf
                                      Expires  11/89
             GUIDANCE FOR THE
   REREGISTRATION OF PESTICIDE PRODUCTS

                CONTAINING

                SULFOTEPP
         AS THE ACTIVE INGREDIENT
             CASE NUMBER 0338

      CAS Registry Number 3689-24-5

EPA Pesticide Chemical Code  (Shaughnessy)
              Number 079501


             SEPTEMBER, 1988
     ENVIRONMENTAL PROTECTION AGENCY

       OFFICE OF PESTICIDE PROGRAMS

         WASHINGTON,  D.C.   20460

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                         TABLE OF CONTENTS
I.     Introduction	1

II.   Chemical(s) Covered by this Standard 	 4
        A.  Description of Chemical  	 4
        B.  Use Profile	4

III.   Agency Assessment  	 5
        A.  Summary	5
        B.  Preliminary Risk Assessment	11
        C.  Other Science Findings	11
        D.  Tolerance Reassessment	12

IV.   Regulatory Position and Rationale	13
        A.  Regulatory Positions	13
        B.  Criteria for Registration	17
        C.  Acceptable Ranges and Limits	17
        D.  Required Labeling	19

V.     Products Subject to this Standard	23

VI.   Requirement for Submittal of Generic Data	25
        A.  What are generic data?	25
        B.  Who must submit generic data?	25
        C.  What generic data must be submitted?	26
        D.  How to comply with DCI requirements	26
        E.  Registrant Requests Regarding Data Requirements
            and Agency Responses	29
        F.  Testing Protocols, Standards for Conducting
            Acceptable Tests, Guidance on Evaluating and
            Reporting Data	29
        G.  Procedures for requesting a change in protocol .   .30
        H.  Procedures for requesting extensions of time .  .   .30
        I.  Data Format and Reporting Requirements	30
        J.  Existing stocks provisions upon suspension or
            cancellation	31

VII.   Requirement for Submittal of Product-Specific Data .  .   .31

VIII. Requirement for Submittal of Revised Labeling	32

IX.   Instructions for Submittal	32
        A.  Manufacturing use products (sole active)	32
        B.  Manufacturing use products (multiple active) .  .   .33
        C.  End use products  (sole active)	34
        D.  End use products  (multiple active)	34
        E.  Intrastate products	343.

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                             APPENDICES

I.  DATA APPENDICES	35

    Guide to Tables	36

    Table A	38

    Table B	55

II.  LABELING APPENDICES  	 61

     Summary of label requirements and table  	 62

     40 CFR 156.10 Labeling Requirements  	 72

     Physical/Chemical Hazards Labeling Statements  	 77

     Storage Instructions 	 78

     Container Disposal Instructions  	 79

     Pesticide Disposal Instructions  	 80


III.  BIBLIOGRAPHY APPENDICES 	 83

     Guide to Bibliography	84

     Bibliography 	 86


IV.  FORMS APPENDICES 	 87

EPA Form 8580-1   FIFRA §3(c)(2)(B) Summary Sheet 	 88

EPA Form 8580-3   Generic Data Exemption Statement  	 89

EPA Form 8580-4   Product Specific Data Report  	 90

EPA Form 8580-6   Certification of Attempt to Enter Into an
                  Agreement with Other Registrants for
                  Development of Data	91
                                 11

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             GLOSSARY OF TERMS AND ABBREVIATIONS

ADI     Acceptable Daily Intake.  Also known as the Reference
        Dose or RfD.

a.i.    active ingredient

ARC     Anticipated Residue Contribution

CAS     Chemical Abstracts Service

CSF     Confidential Statement of Formula
               . »
EEC     Estimated Environmental Concentration.  The estimated
        pesticide concentration system in an environment,
        such as a terrestrial ecosystem.

EP      End Use Product

EPA     U.S. Environmental Protection Agency

FIFRA   Federal Insecticide, Fungicide, and Rodenticide Act

FFDCA   Federal Food, Drug, and Cosmetic Act

LC50    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 or feed, e.g., mg/1 or ppm.

LDso    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.

LEL     Lowest Effect Level

MPI     Maximum Permissible Intake

MRID    Master Record Identification (number).  EPA's system of
        recording and tracking studies submitted to the Agency.

MP      Manufacturing Use Product

NPDES   National Pollutant Discharge Elimination System

NOEL    No Observed Effect Level

OPP     Office of Pesticide Programs
                                111

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OES     Office of Endangered Species,  U.S.  Fish and Wildlife
        Service

PADI    Provisional Acceptable Daily Intake

ppm     parts per million

RfD     Reference Dose

TMRC    Theoretical Maximal Residue Contribution
                                  IV

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                              -1-
                       I.  INTRODUCTION

     EPA has established the Registration Standards program
in order to provide an orderly mechanism by which pesticide
products containing the same active ingredient can be reviewed
and standards set for compliance with FIFRA.  The standards
are applicable to reregistration and future applications for
registration of products containing the same active ingredient.
Each registrant of a product containing an active ingredient
subject to this Standard who wishes to continue to sell or
distribute that product must bring his product and labeling
into compliance with FIFRA, as instructed by this Standard.
                . »
     The Registration Standards program 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" criteria of FIFRA.  In its review EPA identifies

     1.  Studies that are acceptable to support the data
requirements for the currently registered uses of the pesticide.

     2.  Additional studies necessary to support continued
registration.  The additional studies may not have been
required when the product was initially registered or may be
needed to replace studies that are now considered inadequate.

     3.  Labeling revisions needed to ensure that the product
is not misbranded and that the labeling is adequate to protect
man and the environment.

     The detailed scientific review, which is not contained
in this document,  but is available upon request^, focuses on
the pesticide active ingredient.  The scientific review
primarily discusses the Agency's evaluation of and conclusions
from available data in its files pertaining to the pesticide
active ingredient.  However,  during the review of these data
the Agency is also looking for potential hazards that may be
associated with the end use products that contain the active
ingredient.  The Agency will apply the provisions of this
Registration Standard to end use products if necessary to
protect man and the environment.
     scientific reviews may be obtained after April 1, 1988
 from the National Technical Information Service,
 5285 Port Royal Road, Springfield,  Virginia 22161
 (703-487-4650).

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                              -2-
     EPA's reassessment results in the development of a
regulatory position,  contained in this Registration Standard,
on the pesticide and each of its registered uses.   See
Section IV - Regulatory Position and Rationale.   Based on its
regulatory position,  the Agency may prescribe a variety of
steps to be taken by registrants to maintain their registrations
in compliance with FIFRA.  These steps may include:

     1.  Submission of data in support of product registration;

     2.  Modification of product labels;

     3.  Modifications to the manufacturing process of the
pesticide to reduce the levels of impurities or contaminants;

     4.  Restriction of the use of the pesticide to certified
applicators or other specially trained individuals;

     5.  Modification of uses or formulation types; or

     6.  Specification of packaging limitations.

     Failure to comply with these requirements may result in
the  issuance of a Notice of Intent to Cancel or a Notice of
Intent to Suspend (in the case of failure to submit data).

     In addition, in cases in which hazards to man or the
environment are identified, the Agency may initiate a special
review of the pesticide  in accordance with 40 CFR Part 154
to examine in depth the  risks and benefits of use of the
pesticide.  If the Agency determines that the risks of the
pesticide's use outweigh the benefits of use, the Agency
may  propose additional regulatory actions, such as cancellation
of uses of the pesticide which have been determined to cause
unreasonable adverse effects on the environment.

     EPA has authority under the Data Call-in (DCI) provisions
of FIFRA  sec. 3(c)(2)(B) to require that registrants submit
data to answer our questions regarding the chemical, toxicological,
and  environmental characteristics and fate of a pesticide.
This Registration Standard lists the data EPA believes are
necessary to resolve our concerns about this pesticide.
These  data are listed  in the Tables A, B, and C in Appendix I.
Failure to comply with the DCI  requirements enumerated in
this Registration Standard may  result in issuance by EPA of a
Notice of Intent to Suspend the  affected product  registrations.

     Registrants are reminded  that FIFRA sec. 6(a)(2)  requires
them to submit  factual  information concerning possible unreason-
able adverse effects of  a pesticide at  any time that  they
become aware of  such  information.  Registrants  should  notify

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                              -3-
the Agency of any information,  including interim or preliminary
results of studies,  if those results suggest possible adverse
effects on man or the environment.  This requirement continues
as long as the products are registered by the Agency.

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                               -4-
          II.  CHEMICAL(S) COVERED BY THIS STANDARD

A.  Description of chemical (s)

    The following chemical (s) are covered by this Registration
Standard:

    Common name:  Sulfotepp
    Chemical name:  O,O,O',O'- tetraethyl dithiopyrophosphate
    CAS Number: 3689-24-5

    Sulfotep is the British Standards Institution (BSI) and
International Organization for Standardization (ISO) approved
common name of an acaricide/insecticide registered in the U. S
by Centerchem, Inc., Fuller Systems, Inc., and Plant Products
Corp.  The molecular structure is depicted below.
    OPP (Shaughnessy) Number: 079501

    Empirical Formula: C8H20°5P2S2

    Trade names: Bladafume, Dithio, Dithione, and Thiotepp.

    Description of physical characteristics of chemical:
      Pale yellow liquid with a boiling point of 136-139°C at
      2 mm Hg; specific gravity of 1.196 d25/4 °C; solubility
      of 25 mg/1 water at room temperature; completely misci-
      ble with chloromethane and most organic solvents; a
      vapor pressure of 22.6 mPa at 20 °C.

B.  Use Profile

    Type of Pesticide: Insecticide/Acaricide

    First Registration: 1951

    Pests Controlled: aphids, mealybugs, spider mites, thrips,
      scales, whiteflies

    Registered Uses: commercial greenhouses, non-food
    Predominant Use(s): azaleas, carnations, chrysanthemums,
      geraniums, roses, snapdragons

    Mode of Activity: organophosphate, non-systemic, contact

    Formulation Types Registered: technical material, ready-
      to-use  solution, impregnated materials

    Method(s) of Application: liquid fog,  smoke generating
      impregnated materials

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                               -5-
                     III.  AGENCY ASSESSMENT

     The Agency has reviewed all data in its files as of
March 8, 1988 supporting the registration of sulfotepp.
Data received by the Agency after this date have not been
reviewed for the purposes of this Standard.  This section
discusses the Agency's scientific findings and conclusions
based on these data.

A.  SUMMARY

        The main area of concern is for human exposure to
   airborne residues of sulfotepp when used in greenhouses,
   since this chemical is known to be highly acutely toxic.
   There are major data gaps in the areas of toxicology, en-
   vironmental fate, exposure to humans, ecological effects,
   and product chemistry.

   1. TOXICOLOGY

        No data are available that meet the Agency's
   Guideline requirements for the toxicity of sulfotepp.
   However, data available in the public literature indicate
   that sulfotepp is highly toxic.  In addition, some data
   on human poisonings are available, but there is no conclu-
   sive evidence of a significant poisoning problem due to
   the pesticide.  Studies to fulfill all acute toxicity
   requirements are required, including an acute delayed
   neurotoxicity study in the hen.  Subchronic 21-day dermal
   and 90-day inhalation studies are required.  A 90-day
   neurotoxicity study is reserved depending on the results
   from the acute delayed neurotoxicity study.  A teratology
   study in one species is required and all mutagenicity
   studies are required.

   2. ENVIRONMENTAL FATE

        There are no available environmental fate studies on
   sulfotepp.  Therefore, groundwater contamination potential
   cannot be assessed at this time.  Because of toxicological
   concerns involving acute hazards (see above), an interim
   reentry interval in accordance with the proposed § 170.66
   of 40 CFR as it pertains to application of smokes, mists,
   fogs and aerosols in greenhouses is being imposed for the
   registered uses of sulfotepp.  Once adequate data have been
   submitted and evaluated, the Agency will reconsider this
   issue.  The following list summarizes the environmental
   fate data requirements for sulfotepp.

   Environmental Fate Data Requirements Summary

   DEGRADATION STUDIES - LAB
   Hydrolysis
   Photodegradation - air

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                            -6-
METABOLISM STUDIES - LAB
Aerobic metabolism - soil

MOBILITY STUDIES
Adsorption/desorption studies (batch equilibrium study is
     preferred)
Volatility (lab)
Volatility (field) - [reserved]

REENTRY PROTECTION
Air monitoring of toxicologically significant residues are
required for purposes of calculating human exposure  (no
actual monitoring of human inhalation exposure is to be
conducted) .

3. ECOLOGICAL EFFECTS

   Terrestrial

     No data are available for any terrestrial species.
An avian single-dose acute oral LD5Q study and a subacute
dietary LC5Q study using the bobwhite quail are required.
No. data are required for toxic effects on wild mammals or
on honey bees for the existing indoor use patterns.

   Aquatic

     Freshwater Invertebrates and Fish

     The available data indicate that sulfotepp is highly
toxic to the rainbow trout and bluegill sunfish.  No data
are available on effects on freshwater invertebrates.  The
fish studies only partially fulfill the Agency's data re-
quirements,  but may be acceptable if additional data con-
cerning the studies are submitted.  An acute LCso study
on aquatic invertebrates is required.

Ecological Effects Data Requirement Summary

The following data are required for the present use pat-
terns:
Avian single-dose oral LDso (bobwhite quail)
Avian dietary LCso in one species  (bobwhite quail)
Fish acute LCso
Acute LCso on aquatic invertebrates
4. RESIDUE CHEMISTRY

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                           -7-
     There are no registered uses of sulfotepp on agricul-
tural crops.  Residue chemistry data are not required to
support the registered uses of sulfotepp on greenhouse
non-food crops, except for chemical identity and directions
for use.  These requirements may be met by submission of
the required product chemistry data discussed below.

5. PRODUCT CHEMISTRY

   a. PRODUCT IDENTITY AND COMPOSITION

      61-1.  Product Identity and Disclosure of Ingredients

      Sulfotep is the British Standards Institution (BSI)
      and International Organization for Standardization
      (ISO) approved common name of an acaricide/insecti-
      cide registered in the U. S. by Centerchem, Inc.,
      Fuller Systems, Inc., and Plant Products Corp.  The
      molecular structure is depicted below.
                             S   S
                             II   II
      O,0,0',0'-tetraethyl dithiopyrophosphate is the chemi-
      cal name (International Union for Pure and Applied
      Chemistry).  Other chemical, common, and trade names
      include: tetraethyl thiodiphosphate (9th Collective
      Index),  tetraethyl thiopyrophosphate (8th Collective
      Index),  thiodiphosphoric acid tetraethyl ester,
      ASP-47,  Bayer E 393, Bladafume,  Dithio, Dithione,
      sulfotepp (Entomological Society of America approved),
      and Thiotepp.

      Other identifying characteristics and codes are:

           Empirical Formula:                 C8H20°5P2S2
           Molecular Weight:                  322.3
           CAS Registry No.:                  3689-24-5
           Shaughnessy No.:                   079501
           Wiswesser Line-Formula Notation*
             20PS&O2&OPS&O2&02
           U.  S.  Department of Agriculture:   ENT 16 273
* A single-line representation of the structural formula
  for organic chemical molecules.

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                       -8-
  The above  information was obtained  from the  following
  sources: Acceptable Common Names and Chemical Names
  for the Ingredient Statement on Pesticide Labels, 4th
  Ed.,  1979, p.  225; British Crop Protection Council,
  The Pesticide  Manual - A World Compendium, 7th Ed.,
  1980,  p. 498;  Farm Chemicals Handbook  '88, p. C33;
  and Analytical Reference Standards  and Supplemental
  Data;  The  Pesticide and Industrial  Chemicals Reposi-
  tory,  1984, p. 98.

  The sulfotepp  technical products are summarized  in
  Table 1.   Confidential Statements of Formula were not
  available  in the  registration  jackets  for EPA Reg.
  Nos.  8241-5 and 9382-4.

  Table 1. Technical sulfotepp products.
Percent Active
95
95
90
EPA Reg. No.
1327-39
8241-5
9382-4
Registrant
Fuller Systems, Inc.
Plant Products Corp.
Centerchem, Inc.
   61-2.   Description of Beginning Materials and Manu-
          facturing Process

   No description has been submitted for this topic by
   the registrants.  The following manufacturing process
   was obtained from Marshall Sittig's Pesticide Manu-
   facturing and Toxic Materials Control Encyclopedia,
   pp.  689-690.

        Sulfotep is manufactured by reaction of sulfur
        with tetraethylpyrophosphate (TEPP) or O,O-di-
        ethyl phosphorochloridothioate and aqueous sod-
        ium carbonate in the presence of pyridine.

   61-3.   Discussion of the Formation of Impurities

   No discussion was submitted for this topic by the
   registrants.

b. ANALYSIS AND CERTIFICATION OF PRODUCT INGREDIENTS

   62-1.   Preliminary Analysis

   No data were submitted for this topic by the regis-
   trants.

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                            -9-
      62-2.  Certification of Ingredient Limits

      Only ingredient limits of the Fuller System,  Inc.
      95% technical product are known.   No data were sub-
      mitted for this topic by the other registrants.

      62-3.  Analytical Methods to Verify Certified Limits

      No methods were submitted for this topic by the reg-
      istrants .

   c. PHYSICAL AND CHEMICAL CHARACTERISTICS

      No data pertaining to the physical and chemical
      characteristics of any technical product have been
      submitted.  Summarized in Table 2 are physical and
      chemical properties of the PAI obtained from the
      British Crop Protection Council,  The Pesticide Man-
      ual - A World Compendium, 7th Ed., 1980, p. 498.
      This information is provided for reference purposes
      only.


      Table 2.  Physical and chemical properties of pure
                sulfotepp.

      Guidelines Reference
      No., 40 CFR 158, Subpt C
      Name of Property	Description	

      63-2. Color               pale yellow

      63-3. Physical state      liquid

      63-6. Boiling point       136-139°C/2mm Hg

      63-7. Specific gravity    1.196 d25/4°C

      63-8. Solubility          25 mg/1 water at room
                                temperature; completely
                                miscible with chloromethane
                                and most organic solvents

      63-9. Vapor pressure      22.6 mPa at 20°C
Product Chemistry Data Requirements Summary

Product Identity and Composition

Product Identity and Disclosure of Ingredients
Description of Beginning Materials
   and Manufacturing Process

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                          -10-


Discussion of Formation of Impurities

Analysis and Certification of Product Ingredients

Preliminary Analysis of Product Samples
Certification of Ingredient Limits
Analytical Methods to Certify Limits

Physical and Chemical Characteristics

Color
Physical State
Odor
Melting Point .
Boiling Point
Density, Bulk Density or Specific Gravity
Solubility
Vapor Pressure
Dissociation Constant
Octanol/Water Partitioning Coefficient
pH
Stability
Oxidizing or Reducing Action
Flammability
Explodability
Storage Stability
Viscosity
Miscibility
Corrosion Characteristics

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                             -11-
B.  PRELIMINARY RISK ASSESSMENT

     As previously discussed briefly above, there are no data
available on technical sulfotepp satisfying the basic toxi-
cology requirements of the Guidelines.  Therefore, no prelimi-
nary risk assessment is possible at this time.  In the absence
of such an assessment, the toxicology summary is presented
below.

   1. Toxicology Summary

     Sulfotepp is a restricted use pesticide.  It is used on
     greenhouse nonfood crops (ornamental plants and forest
     trees), for ^control of aphids, mealybugs, spider mites,
     scales, thrips and whiteflies.  In the past, sulfotepp
     has been known to be an impurity in the pesticide, Diazi-
     non.  From the toxicity data on Diazinon, the Agency is
     aware that sulfotepp is highly acutely toxic.  However,
     no data are available on the Technical Product.  No toler-
     ances exist for sulfotepp.   No studies are available for
     registered uses.  Dat'a required are listed in Tables A and
     B in Appendices I, the Data Appendices.

   2. ADI Reassessment

     An ADI reassessment is not necessary because there
     are no approved tolerances for sulfotepp.

C.  OTHER SCIENCE FINDINGS

   1. Exposure Assessment;

     The Agency does not have any exposure data on sulfotepp.
     Data are required to do an assessment of exposure under
     40 CFR 158.390 and these data are listed in Table A.

     The only health statistics available for sulfotepp come
     from California.  The ratio of poisonings to applica-
     tions reported in 1981-1984 was somewhat higher than the
     average reported for 54 selected pesticides, but not un-
     usually high.  This ratio is based on a single poisoning
     only (to a chamber fumigator).  There was only one other
     poisoning in California since 1975, which was listed as
     a worker exposed to drift or residue in 1977.  Given
     these data, there is no conclusive evidence of a signifi-
     cant poisoning problem due to sulfotepp.

   2. Ecological Effects

     a. Ecological Effects Profile

     Freshwater fish acute toxicity data indicate that sulfo-
     tepp is highly toxic to the rainbow trout [LCso = 1.0
     (0.8 - 1.3) ppm] and bluegill sunfish [LCso = 0.36 (0.27
     - 0.46 ppm)].

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                               -12-
     b. Ecological Hazard Assessment

     Sulfotepp is registered only for indoor greenhouse use on
     ornamental plants.  Ecological hazard assessments are not
     performed for indoor uses.

D.  TOLERANCE REASSESSMENT

     A tolerance reassessment is not necessary since there are
no registered uses for sulfotepp that require tolerances under
FFDCA.

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                               -13-
              IV.  REGULATORY POSITION AND RATIONALE

A.  REGULATORY POSITIONS AND RATIONALES

     Based on review and evaluation of the limited data avail-
able and other relevant information on sulfotepp the Agency has
made the following determinations:

     1.  Sulfotepp is not a candidate for Special Review at
        this time.

Rationale;   Since available data are quite limited, the Agency
is not yet able to make a determination as to whether any of
the criteria specified in 40 CFR 154.7 have been met or
exceeded.

     2.  Restricted use

        The current position stated in 40 CFR 162.31 that all
        products containing the active ingredient sulfotepp must
        bear labeling for RESTRICTED USE is to be continued,
        based on an acute inhalation hazard to humans.

Rationale;   There is sufficient information of a collateral
nature based on sulfotepp as an impurity in Diazinon for the
Agency to conclude that sulfotepp is highly acutely toxic to
mammals, and by inference to humans.  Data to characterize the
risk are required.

     3.  Groundwater concerns

        The Agency is requiring submission of the minimal studies
        needed for determination of the groundwater contamination
        potential of sulfotepp.  These include laboratory degre-
        dation studies on hydrolysis (161-1) and photodegradation
        in air (161-4); a laboratory metabolism study for aerobic
        soil organisms (162-1);and mobility studies on adsorp-
        tion/desorption (163-1), and volatility in the laboratory
        (163-2) .  The mobility study on volatility in th"efield
        (163-3) is being reserved at the present time, but may be
        required depending on the results of laboratory studies.

Rationale;   Since it is not possible to determine the groundwater
contamination potential without data on the environmental fate
of a pesticide and since the aforementioned studies are required
by the Guidelines for any pesticide used on greenhouse non-food
crops, these studies are necessary in order to fill the data
gaps for the environmental fate of sulfotepp.  The laboratory
study on photodegradation in air is being required due to the
high vapor pressure of sulfotepp [1.7xlO~4 mm Hg or 22.6 mPa at
20°C.] and the possibility that fumes may be sensitive to photo-
degradation.

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                               -14-
     4. Reentry requirements

        The Agency has determined that the present reentry
        requirements of from 1.5 hours to overnight,  and
        ventilation of the greenhouse structure for one or
        two hours, are inadequate to fully protect humans
        exposed to airborne residues of sulfotepp.  An interim
        reentry interval in accordance with proposed Subpart F,
        § 170.66 of 40 CFR, as it pertains to application of
        smokes, mists, fogs or aerosols in greenhouses is being
        imposed for the uses of sulfotepp until adequate data
        have been submitted and evaluated.

Rationale:  Reentry data are required for sulfotepp under
40 CFR § 158.390.  Those data are required by § 158.390 if the
pesticide and its use patterns meet both of certain toxicity and
exposure criteria.  Sulfotepp meets these criteria.

In the case of sulfotepp,  human exposure monitoring data must
not be submitted.  In other cases, human exposure monitoring
data have been accepted when the Registrants chose to submit
those, but the hazard at high levels of airborne sulfotepp resi-
dues could be so great that those data must not be gathered.
Therefore, the Agency is requiring monitoring of toxicologically
significant residues in air over a given time period.

According to the provisions of proposed § 170.66(a),  no worker
shall be allowed or directed to enter or remain in a reentry-
restricted area before the reentry interval specified in para-
graph  (b) has expired, unless: (1) The worker will have no con-
tact with pesticide residues on treated surfaces or in soil,
water, or air; or (2) The following requirements for early re-
entry workers are met: (i) Personal protective equipment spec-
ified on the pesticide labeling for early reentry activities is
worn;  (ii) Duties related to personal protective equipment
specified in § 170.16 are met; (iii) Decontamination provisions
specified in § 170.18 are available; (iv) Training specified in
§ 170.12(b) is given; (v) Any other requirement regarding early
reentry specified on the pesticide labeling is met.

§ 170.66(b) as proposed, states in (2) that for any pesticide
applied in the form of a smoke, mist, fog or aerosol [in the
greenhouse], the reentry-restricted area shall be the entire
nonporous enclosed area within which the pesticide is applied
until the reentry interval specified on the pesticide labeling
has expired.  Since sulfotepp has a vapor pressure such that it
behaves like a fumigant, the Agency is imposing a reentry inter-
val in accordance with § 170.66(b)(1), which states:

     For any pesticide identified on the pesticide labeling as a
     fumigant, the reentry-restricted area shall be the entire
     nonporous enclosed area within which the pesticide is ap-
     plied.  The reentry interval shall extend until all vapors
     have dispersed, as defined by one of the following criteria:

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                               -15-
     (i) Two hours of ventilation using fans or other mechanical
     ventilation systems.

     (ii) Four hours of ventilation using vents, windows or
     other passive ventilation systems.

     (iii) Eleven hours with no ventilation, followed by one
     hour of mechanical ventilation.

     (iv) Eleven hours with no ventilation,  followed by two
     hours of passive ventilation.

     (v) Twenty-four hours with no ventilation.

     (vi) The air concentration of the fumigant is measured to
     be less than or equal to the permissible exposure level
     specified on the product labeling.

Since (vi) is not applicable until the registrants have submit-
ted air monitoring data in accordance with § 158.390 to estab-
lish a permissible exposure level for sulfotepp, and (v) would
not allow the present common practice of overnight treatments
of greenhouses to continue during the data-gathering phase, the
Agency proposes to limit the reentry interval options to (i)
through (iv), as described in Sec. IV.D. below.

     5.  Protective clothing requirements are being imposed as
        labeling amendments for all registered products con-
        taining sulfotepp for end-use application in commercial
        greenhouses, as described in Sec. IV.D. below.

Rationale;  Sulfotepp is highly acutely toxic (approx. 5 mg/kg
acute oral LDso to rat according to Pesticide Index - Fourth
Edition, 1969, p. 356, D. E. H. Frear, editor).  Although we
do not have a complete toxicological data base or enough in-
formation to allow a preliminary risk assessment to be made,
the early history of use recognized the acute hazard involved
and called for the use of protective clothing.   To come into
compliance with FIFRA, uniform wording will be required in
order to standardize the text on current labels.

     6.  Labeling requirements

        The requirements specified in Section IV.D.3. below
        and in the Labeling Appendices must be satisfied, as
        appropriate, for all products containing sulfotepp,
        whether the products are used in the formulation or
        manufacture of end-use products containing sulfotepp
        or as end-use products for treating greenhouse flower
        crops (non-food) of azaleas, carnations, chrysanthemums,
        geraniums, roses and snapdragons, applied as liquid fog
        or smoke-generating impregnated materials.

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                               -16-
     7.  Studies that will receive immediate review.

        The Agency has identified certain data that will receive
        immediate review when submitted.

Rationale;   Certain of the data being required by the Agency
are essential to resolve risk concerns, or may trigger the need
for further studies which should be initiated as soon as possi-
ble.  The following studies have been identified to receive
immediate review.

     40 CFR §158.290  Environmental Fate

      161-1  Hydrolysis
      161-4  Photodegradation in Air
      162-1  Aerobic Soil Metabolism
      163-1  Adsorption/Desorption
      163-3  Volatility (Lab)

     §158.340  Toxicology

      81-1    Acute Oral - Rat
      81-2    Acute Dermal
      81-3    Acute Inhalation - Rat
      81-4    Eye Irritation - Rabbit
      81-5    Dermal Irritation - Rabbit
      81-6    Dermal Sensitization - Guinea Pig
      81-7    Acute Delayed Neurotoxicity - Hen

     §158.49'0  Ecological Effects

      71-1    Avian Single-Dose Oral
      71-2    Avian Dietary
      72-1    Fish Acute
      72-2    Acute LCso Aquatic Invertebrates

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                               -17-
     8. Continuation of registration.

     While data gaps are being filled, currently registered
manufacturing use products (MPs) and end use products  (EPs)
containing sulfotepp may be sold, distributed, formulated
and used.  Registrants must provide or agree to develop
additional data, as specified in the Data Appendices,  in
order to maintain existing registrations.

Rationale; Under FIFRA, the Agency does not normally cancel
or withhold registration simply because data are missing or
are inadequate  (see FIFRA sec. 3(c)(2)(B) and 3(c)(7)).

Issuance of this Standard provides a mechanism for identifying
data needs and labeling changes arising from available data.
Required data will be reviewed and evaluated, after which
the Agency will determine if additional regulatory changes
are necessary.

B.  CRITERIA FOR REGISTRATION

     To be registered or reregistered under this Standard,
products must contain sulfotepp, bear required labeling, and
conform to the product composition, acute toxicity limits,
and use pattern requirements listed in this section.

C.  ACCEPTABLE RANGES AND LIMITS

     1.  Product Composition Standard

     To be registered or reregistered under this Standard,
manufacturing-use products (MPs) must contain sulfotepp.
Each MP formulation proposed for registration must be  fully
described with an appropriate certification of limits, stating
maximum and minimum amounts of the active ingredient and
inert ingredients which are present in products, as well as
impurities found at greater than 0.1%.

     2.  Acute Toxicity Limits

     In order to remain in compliance with FIFRA,  the Agency
will require that product labeling of technical grade  and
manufacturing-use products containing sulfotepp bear approp-
riate precautionary statements for the acute toxicity  category
in which each product is placed.

     3.  Use Patterns

     To remain in compliance with FIFRA,  manufacturing-use
products may be labeled for formulation into end-use products

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                               -18-
only for the commodities listed below.  The EPA Compendium
of Acceptable Uses1 lists all registered uses,  as well as
approved maximum application rates and frequencies.

           -Greenhouse non-food use on:

            Azaleas
            Carnations
            Chrysanthemums
            Geraniums
            Roses
            Snapdragons
 1  The Compendium may be obtained from the National Technical
   Information Service,  5285  Port Royal Road,  Springfield,
   Virginia 22161 (703-487-4650).

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                                -19-
D.  REQUIRED LABELING

     In order to remain  in  compliance with FIFRA, manufacturing
use products (and end-use products,  if covered by Standard)
must bear appropriate  labeling as specified in 40 C?"R i.'3;S,LO,
Appendix II contains  information on label requirements.

     :\To pesticide product containing sulfotepp may be released
for shipment by the registrant after September 30, 1989,
unless the product bears an amende."!. 1.aV>ol -.Jhloh o^aplies
with the ee pil-- >iaent:i  of. this  Standard.

     No pesticide product containing sulfotepp may be dis-
tributed, sold, offered  for sale,  held for sale, shipped,
delivered for shipment, or  received and (having been so
received) dell^ere;! o<~ offered to be delivered by any person
a!7tec September 30, 1990, unless the product bears an amended
label which complies with the  requirements of this Standard.

     The following specific information .uast •i.i>oH-i.r  vi the
labelirig in order for  prodaoi-.s to re>nain in compliance with
FIFRA:
     1.   Ingredients Statement

          The ingredient  statement for MPs irus'r. li.sL ;.1i.»  -. .• i '.
     ingredient as:

     O,O,O' ,O '-tetraec'iyl dithiopyrophosph-iLe

     2.   Use Pattern Statements

          All manufacturing-use products must state f-'n.t fie/
     are intended  r^r  Torinnlation Into end-use products !!:>r
     acceptable use patterns.  Labeling must specify sites,
     which are listed  in  Use  Patterns,  Section C.3.  However,
     no use may be iaolu-.\.*.<\ on the label where the cetji-3 trant
     fails to agree to comply with the data requirements Ln
     TABLE A for that use pattern.

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                          -20-


3.  Precautionary Statements

  a.  Statements applicable to all products

     GENERAL WARNINGS AND LIMITATIONS:  Sulfotepp is
     classified as a RESTRICTED USE PESTICIDE by Title 40,
     Code of Federal Regulations, Part 162,  Section 31, on
     the basis of its acute inhalation hazard to humans.

  b.  Statements for Manufacturing-Use Products

     ENVIRONMENTAL HAZARDS:

     This pesticide is toxic to fish.  Do not discharge
     effluent containing this product directly into
     lakes, streams, ponds, estuaries, oceans, wetlands,
     or public waters unless this product is specifically
     identified and addressed in a NPDES permit.  Do not
     discharge effluent containing this product to sewer
     systems without previously notifying the sewage
     treatment plant authority.  For guidance, contact
     your State Water Board or Regional Office of the
     Environmental Protection Agency.

  c.  Statements for End-Use Products

     RESTRICTED USE:


                  RESTRICTED USE PESTICIDE

 Due to very high acute inhalation toxicity to humans.

 For retail sale to and use only by Certified Applicators
 or persons under their direct supervision and only for
 those uses covered by the Certified Applicator's
 certification.


     General Warnings and Limitations:

     Close all greenhouse vents prior to use.  Block or
     barricade entries and post warning signs.  Do not
     place generators on wood or other flammable materi-
     als as fire hazard may result.

     Reentry Statement; Reentry after applying is restric-
     ted until one  of the  following  intervals has elapsed:

     (1) Two hours  of ventilation using fans  or other  me-
         chanical ventilation systems.

     (2) Four hours of ventilation using vents, windows or
         other passive ventilation systems.

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                          -21-


     (3)  Eleven hours with no ventilation,  followed by one
         hour of mechanical ventilation.

     (4)  Eleven hours with no ventilation,  followed by
         two hours of passive ventilation.

     If necessary to reenter the greenhouse for any reason
     during the specified intervals after application,
     protective clothing described in the Worker Protection
     Statement must be worn.  All greenhouses must be posted
     during the exposure period and until safe to reenter.

     Worker Protection Statement;

     WEAR THE FOLLOWING PROTECTIVE CLOTHING DURING LOADING,
     APPLICATION, EQUIPMENT REPAIR, EQUIPMENT CLEANING, EARLY
     REENTRY TO TREATED AREAS, AND DISPOSAL OF THE PESTICIDE.

          Wear a protective suit of one or two pieces that
     covers all parts of the body except the head, hands,  and
     feet.  Wear chemical-resistant gloves and chemical-resis-
     tant shoes, shoe coverings, or boots.   Wear goggles and a
     pesticide respirator approved by the National Institute
     for Occupational Safety and Health (NIOSH) and the Mine
     Safety and Health Administration (MSHA) at all times
     during application and early reentry to treated areas.

          IMPORTANT!  Before removing gloves, wash them with
     soap and water.  Always wash hands,  face, and arms with
     soap and water before smoking, drinking, eating, or use
     of the toilet.

          AFTER WORK, that is, immediately after completing
     work with this pesticide, take off all clothing and
     shoes.  Shower using soap and water.  Do not reclothe
     with contaminated clothing and shoes.   Wash protective
     clothing and protective equipment with soap and water
     after each use.  Respirators must be cleaned and filters
     replaced according to the instructions included with the
     respirators.  Personal clothing worn during use must be
     laundered separately from household articles.  Clothing
     and protective equipment heavily contaminated, so that
     routine maintenance with soap and water cannot remove
     spilled or undiluted sulfotepp from any drenched non-
     chemical-resistant protective suit,  must be destroyed
     according to State and local regulations.  HEAVILY CON-
     TAMINATED CLOTHING CANNOT BE ADEQUATELY DECONTAMINATED.

4. Directions for Use

  a.  Statements for Manufacturing Use Products

     The following identifying phrase must appear directly
     below the product name:

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                        -22-
   "An insecticide for formulating use only."

   The following statement must appear in the Directions
   for Use section of the label:

   "Formulators using this product are responsible for
   obtaining EPA registration of their formulated prod-
   uct. "

   In the Directions for Use, the following statement
   regarding acceptable use patterns must appear:

   "For formulation into end-use insecticide products
   intended only for greenhouse ornamental flowers:
   azaleas, carnations, chrysanthemums, geraniums,
   roses, and snapdragons."

b. Statements for End-Use Products

   The following statement must appear in the Direc-
   tions for Use section of the label for all end-use
   products:

   "Calculate volume in cubic feet of greenhouse space
   to be treated in order to determine amount of prod-
   uct required for application.  Use only this amount."

   The following paragraph or similar wording should
   appear in the Directions for Use section for all
   end-use products:

   "General Application and Use Directions;

   Apply in greenhouses with ornamental plants only.
   Do not use on edible plants.  Turn off all misting
   systems.  Keep generators a minimum of 2 feet away
   from plants.  Temperatures in the greenhouse should
   be between 70°F to 90°F (21.1°C to 32.2°C).  Foli-
   age and blooms should be free of moisture and rela-
   tive humidity should be low.  Soil should be moist
   but do not water on the day of application.  Do not
   apply on rainy or windy days.  Pick open blooms be-
   fore application."

   The following optional wording is recommended for
   smoke generator products:

   "Where the greenhouse being fumigated is large
   enough to require that generators be placed in  more
   than one walk, it is recommended that one person be
   assigned to  light the generators in each walk start-
   ing at the end farthest from the exit, so that  the
   fumigation in each walk may start simultaneously and
   all persons  exit from the house simultaneously."

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                               -23-
              V.  PRODUCTS SUBJECT TO THIS STANDARD

     All products containing one or more of the pesticides
identified in Section II.A. are subject to certain requirements
for data submittal or changes in composition, labeling or
packaging of the product.  The applicable requirements depend
on whether the product is a manufacturing or end use product
and whether the pesticide is the sole active ingredient or
one of multiple active ingredients.

     Products are subject to this Registration Standard as
follows:

A.  Manufacturing use products containing this pesticide as
the sole active ingredient are subject to:

     1.  The restrictions (if any) upon use, composition, or
     packaging listed in Section IV, if they pertain to the
     manufacturing use product.

     2.  The data requirements listed in Tables A and B2

     3.  The labeling requirements specified for manufacturing
     use products in Section IV.

     4.  Administrative requirements (application forms, Confiden-
     tial Statement of Formula, data compensation provisions)
     associated with reregistration.
2 Data requirements are listed in the three Tables in
Appendix I of this Registration Standard.  The Guide to
Tables in that Appendix explains how to read the Tables.

  Table A lists generic data requirements applicable to all
products containing the pesticide subject to this Registra-
tion Standard.  Table B lists product-specific data applicable
to manufacturing use products.  The data in Tables A and B
need not be submitted by an end-use producer who is eligible
for the generic data exemption for that active ingredient.

  Table C lists product-specific data applicable to end use
products.  The Agency has decided that, in most cases,  it
will not require the submittal of product-specific data for
end use products at this time.  Therefore most Registration
Standards do not contain a Table C.

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                               -24-
B.  Manufacturing use products containing this pesticide
as one of multiple active ingredients are subject to:

     1.  The data requirements listed in Table A.

     2.  The labeling requirements specified for manufacturing
     use products in Section IV.

C.  End use products containing this pesticide as the
sole active ingredient are subject to:

     1.  The restrictions (if any) upon use, composition, or
     packaging listed in Section IV if they pertain to the
     end use product.

     2.  If eligible for the generic data exemption^, the
     data requirements listed in Table C.

     3.  If not eligible for the generic data exemption, the
     data requirements listed in Table A and the data require-
     ments listed in Table C.

     4.  The labeling requirements specified for end use
     products in Section IV.

D.  End use products containing this pesticide as one of
multiple active ingredients are subject to:

     1.  If not eligible for the generic data exemption,
     the data requirements listed in Tables A and C.
3 if you purchase from another producer and use as the
source of your active ingredient only EPA-registered products,
you are eligible for the generic data exemption for generic
data concerning that active ingredient (Table A) and product-
specific data for the registered manufacturing use product
you purchase (Table B).

     Two circumstances nullify this exemption:

     1)  If you change sources of active ingredient to an
unregistered product, formulate your own active ingredient,
or acquire your active ingredient from a firm with ownership
in common with yours, you individually lose the exemption
and become subject to the data requirements in Table A.

     2)  If no producer subject to the generic data requirements
in Table A agrees to submit the required data, all end use
producers lose the exemption, and become subject to the data
requirements in Table A.

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                               -25-
     2.  If eligible for the generic data exemption, the
     data requirements listed in Table C.

     3.  The labeling requirements specified for end use
     products in Section IV.
       VI.  REQUIREMENT FOR SUBMISSION OF GENERIC DATA

     This portion of the Registration Standard is a notice
issued under the authority of FIFRA sec. 3(c)(2)(B).  It
refers to the data listed in Table A, which are required to
be submitted by registrants to maintain in effect the regis-
tration of products containing this active ingredient.4

A.  What are generic data?

     Generic data pertain to the properties or effects of a
particular active ingredient.  Such data are relevant to an
evaluation of all products containing that active ingredient
regardless of whether the product contains other ingredients
(unless the product bears labeling that would make the data
requirement inapplicable).

     Generic data may also be data on a "typical formulation"
of a product.  "Typical formulation" testing is often required
for ecological effects studies and applies to all products
having that formulation type.  These are classed as generic
data, and are contained in Table A.

B.  Who must submit generic data?

     All current registrants are responsible for submitting
generic data in response to a data request under FIFRA sec.
3(c)(2)(B) (DCI Notice).  EPA has decided, however, not to
require a registrant who qualifies for the formulator's
exemption (FIFRA sec. 3(c)(2)(D) and § 152.85)  to submit
generic data in response to a DCI notice if the registrant
who supplies the active ingredient in his product is complying
with the data request.

     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 registrants 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 data requirements notice, the Agency will consider
4 Registrations granted after issuance of this Standard will
be conditioned upon submittal or citation of the data listed
in this Registration Standard.

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                               -26-
that both they and you are not in compliance and will normally
initiate proceedings to suspend the registrations of both
your product(s) and their product(s) unless you commit to submit
and submit the required data in the specified timeframe.  In
such cases, the Agency generally will not grant a time extension
for submitting the data.

     If you are not now eligible for a generic data exemption,
you may qualify for one if you change your source of supply
to a registered source that does not share ownership in
common with your firm.  If you choose to change sources of
supply, the Confidential Statement of Formula must identify
the new source(s) and you must submit a Generic Data Exemption
Statement form.

     If you apply for a new registration for products containing
this active ingredient after the issuance of this Registration
Standard, you will be required to submit or cite generic data
relevant to the uses of your product if, at the time the
application is submitted,  the data have been submitted to the
Agency by current registrants.  If the required data have not
yet been submitted,  any new registration will be conditioned
upon the new registrant's submittal or citation of the
required data not later than the date upon which current
registrants of similar products are required to provide such
data.  See FIFRA sec. 3(c)(7)(A).   If you thereafter fail to
comply with the condition of that registration to provide
data, the registration may be cancelled (FIFRA sec.  6(e)).

C.  What generic data must be submitted?

     You may determine which generic data you must submit by
consulting Table A.   That table lists the generic data needed
to evaluate current uses of all products containing this
active ingredient,  the uses for which such data are required,
and the dates by which the data must be submitted to the
Agency.

D.  How to comply with PCI requirements.

     Within 90 days of your receipt of this Registration
Standard, you must submit to EPA a completed copy of the form
entitled "FIFRA Section 3(c)(2)(B) Summary Sheet" (EPA Form
8580-1, enclosed) for each of your products.  On that form
you must state which of the following six methods you will
use to comply with the DCI requirements:

     1.  You will submit the data yourself.

     2.  You have entered into an agreement with one or more
registrants to jointly develop (or share in the cost of
developing) the data,  but will not be submitting the data
yourself.  If you use this method,  you must state who will

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                               -27-
EPA with documentary evidence that an agreement has been
formed which allows you to rely upon the data to be submitted.
Such evidence may be:  (1) your letter offering to join in
an agreement and the other registrant's acceptance of your
offer, (2) a written statement by the parties that an agreement
exists, or (3) a written statement by the person who will be
submitting the data that you may rely upon its submittal.
The Agency will also require adequate assurance that the
person whom you state will provide the data is taking appropriate
steps to secure it.  The agreement to produce the data need
not specify all of the terms of the final arrangement between
the parties or a mechanism to resolve the terms.

     If you and other registrants together are generating or
submitting requested data as a task force or consortium, a
representative of the group should request a Joint Data
Submitter Number, as part of your 90-day response.  The
request must include the following information:

     a.  A list of the members of the consortium;
     b.  The name and address of the designated representative
         of the consortium, with whom EPA will correspond
         concerning the data;
     c.  Identity of the Registration Standard containing
         the data requirement;
     d.  A list of the products affected (from all members
         of the consortium); and
     e.  Identification of the specific data that the con-
         sortium will be generating or submitting.

     The Agency will assign a number to the consortium, which
should be used on all data submissions by the consortium.

     3.  You have attempted to enter into an agreement to
jointly develop data, but no other registrant has accepted
your offer.  You request that EPA not suspend your registration
for non-compliance with the DCT~.  EPA has determined that,
as a general policy, it will not suspend the registration of
a product when the registrant has in good faith sought and
continues to seek to enter into a data development/cost
sharing program, but the other registrants developing the
data have refused to accept its offer.  [If your offer is
accepted, you may qualify for Option 2 above by entering
into an agreement to supply the data.]

     In order to qualify for this method, you must:

     1.  File with EPA a completed "Certification of Attempt
to Enter into an Agreement with other Registrants for Develop-
ment of Data" (EPA Form 8580-6, enclosed).

     2.  Provide us with a copy of your offer to the other

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                               -28-
registrant and proof of the other registrant's receipt of your
offer (such as a certified mail receipt).  Your offer must,
at a minimum,  contain the following language or its equivalent:

     [Your company name] offers to share in the burden of
     producing the data required pursuant to FIFRA sec.
     3(c)(2)(B) in the [name of active ingredient] Registration
     Standard upon terms to be agreed or failing agreement
     to be bound by binding arbitration as provided by FIFRA
     section 3(c)(2)(B)(iii).

The remainder of your offer may not in any way attempt to
limit this commitment.  If the other registrant to whom your
offer is made does not accept your offer, and if the other
registrant informs us on a DCI Summary Sheet that he will
develop and submit the data required under the DCI, then you
may qualify for this option.  In order for you to avoid
suspension under this method,  you may not later withdraw or
limit your offer to share in the burden of developing the
data.

     In addition, the other registrant must fulfill its
commitment to develop and submit the data as required by this
Notice in a timely manner.  If the other registrant fails to
develop the data or for some other reason would be 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 submit the required
data in the specified timeframe.  In such cases, the Agency
generally will not grant a time extension for submitting the data.

     4.  You request a waiver of the data requirement.  If
you believe that a data requirement does not (or should not)
apply to your product or its uses, you must provide EPA with
a statement of the reasons why you believe this is so.  Your
statement must address the specific composition or use factors
that lead you to believe that a requirement does not apply.
Since the Agency has carefully considered the composition and
uses of pesticide products in determining that a data require-
ment applies, EPA does not anticipate that many waivers will
be granted.  A request for waiver does not extend the time-
frames for developing required data, and if your waiver
request is denied, your registration may be suspended if you
fail to submit the data.  The Agency will respond in writing
to your request for a waiver.

     5.  You request that EPA amend your registration by deleting
the uses for which the data are needed.  You are not required
to submit data for uses which are no longer on your label.

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                               -29-
     6.  You request voluntary cancellation of the registration
of your product(s)  for which the data are neededT
E.  Registrant Requests Regarding Data Requirements and Agency
    Responses

     All requests for modification of data requirements
(inapplicability, waiver), approval of protocols or protocol
changes, or time extensions must be submitted in writing.
The original requirement remains in effect unless the Agency
has notified you in writing that it has agreed to a change in
the requirement.  While being considered by the Agency, such
requests for changes in the requirements do not alter the
original requirements or extend the time allowed for meeting
the requirement.


F.  Testing Protocols, Standards for Conducting Acceptable
    Tests, Guidance on Evaluating and Reporting Data.

    All studies required under this Notice must be conducted
in accordance with test standards outlined in the Pesticide
Assessment Guidelines, unless other protocol or standards are
approved for use by the Agency in writing.  All testing must
be conducted in accordance with applicable Good Laboratory
Practices regulations in 40 CFR Part 160.

    The Pesticide Assessment Guidelines, which are referenced
in the Data Tables, 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 (Part 158.70).
Please note, however, that certain OECD standards (such as
test duration, selection of test species, and degradate
identification which are environmental fate requirements) are
less restrictive than those in the EPA Assessment Guidelines
listed above.  When using the OECD protocols, they should be
modified as appropriate so that the data generated by the
study will satisfy the requirements of Part 158.  Normally,
the Agency will not extend deadlines for complying with data
requirements when the studies were not conducted in accord
with acceptable standards.  The OECD protocols are available
from OECD, 1750 Pennsylvania Avenue, N.W., Washington, D.C.
20006.

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                               -30-
G.  Procedures for requesting a change in testing protocol.

     If you will generate the required data and plan to use
test procedures which deviate from EPA's Pesticide Assessment
Guidelines or the Reports of Expert Groups to the Chemicals
Group, Organization for Economic Cooperation and Development
(OECD) Chemicals Testing Programme, you must submit for EPA
approval the protocols you propose to use.

     You should submit your protocols before beginning testing,
because the Agency will not ordinarily accept as sufficient
studies using unapproved protocols.  A request for protocol
approval will not extend the timeframe for submittal of the
data, nor will extensions generally be given to conduct
studies due to submittal of inappropriate protocols.  The
Agency will respond in writing to your request for protocol
approval or change.

H.  Procedures for requesting extensions of time.

     If you think that you will need more time to generate
the data than is allowed by EPA's schedule, you may submit a
request for an extension of time.

     EPA will view failure to request an extension before
the data submittal response deadline as a waiver of any
future claim that there was insufficient time to submit the
data.  While EPA considers your request, you must strive to
meet the deadline for submitting the data.

     The extension request should state the reasons why you
believe that an extension is necessary and the steps you
have taken to meet the testing deadline.  Time extensions
normally will not be granted due to problems with laboratory
capacity or adequacy of funding, since the Agency believes
that with proper planning these can be overcome.  The Agency
will respond in writing to any requests for extension of time.


I.  Data Format and Reporting Requirements

    All data submitted in response to this Notice must comply
with 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 Notice 86-5 (issued
July 29, 1986).  All studies must be submitted in the form of
a final report; a preliminary report will not be considered
to fulfill the submittal requirement.

-------
                               -31-
j.  Existing stocks provision upon suspension or cancellation.

     The Agency has determined that if a registration is
suspended for failure to respond to a DCI request under
FIFRA sec. 3(c)(2)(B), an existing stocks provision for the
registrant is not consistent with the Act.  Accordingly, the
Agency does not anticipate granting permission to sell or
distribute existing stocks of suspended product except in
rare circumstances.  If you believe that your product will be
suspended or cancelled and that an existing stocks provision
should be granted, you have the burden of clearly demonstrating
to EPA that granting such permission would be consistent with
the Act.  The following information must be included in any
request for an existing stocks provision:

     1.  Explanation of 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 or distribution; and

     2.  Demonstration that such a provision would be consis-
     tent with the provisions of FIFRA.


   VII. REQUIREMENT FOR SUBMISSION OF PRODUCT-SPECIFIC DATA

     Under its DCI authority, EPA has determined that certain
product-specific data are required to maintain your registrations
in effect.  Product-specific data are derived from testing
using a specific formulated product, and, unlike generic
data, generally support only the registration of that product.
All such data must be submitted by the dates specified in
this Registration Standard.

     If you have a manufacturing use product, these data are
listed in Table B.  If you have an end use product, the data
are listed in Table C.  As noted earlier, the Agency has
decided that it will not routinely require product-specific
data for end use products at this time.  Therefore, Table C
may not be contained in this Registration Standard; if there
is no Table C, you are not required to submit the data at
this time.

     In order to comply with the product specific data require-
ments, you must follow the same procedures as for generic data.
See Section VI.D through J.  You should note, however, that
product chemistry data are required for every product, and the
only acceptable responses are options VI.D.I. (submit data)
or VI.D.6.(cancellation of registration).

     Failure to comply with the product-specific data require-
ments for your products will result in suspension of the
product's registration.

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                               -32-
     VIII.  REQUIREMENT FOR SUBMITTAL OF REVISED LABELING

     FIFRA requires each product to be labeled with accurate,
complete and sufficient instructions and precautions, reflecting
the Agency's assessment of the data supporting the product
and its uses.  General labeling requirements are set out in
40 CFR 156.10 (see Appendix II - LABELING and SUMMARY).  In
addition, labeling language specific to products containing
this pesticide is specified in Section IV.D of this Registra-
tion Standard.  Responses to this Registration Standard must
include draft labeling for Agency review.

     Labeling must be either typewritten text on 8-1/2 x 11
inch paper or a mockup of the labeling suitable for storage
in 8-1/2 x 11 files.   Draft labeling must indicate the intended
colors of the final label, clear indication of the front panel
of the label, and the intended type sizes of the text.

     If you fail to submit revised labeling as required,
which complies with 40 CFR 156.10 and the specific instructions
in Section IV.D., EPA may seek to cancel or suspend the
registration of your product under FIFRA sec. 6.
               IX.  INSTRUCTIONS FOR SUBMITTAL

     All submittals in response to this Registration Standard
must be sent to the following address:

     Office of Pesticide Programs
     OPP Mailroom (TS-767C)
     Environmental Protection Agency
     401 M St.,  SW
     Washington, D.C.   20460

     Attn:  Sulfotepp Registration Standard

     All submittals in response to this Registration Standard
are non-fee items, including 90-day responses, protocols and
waiver requests, data, and revised labeling.  Submittals must
be clearly identified as being in response to the Registration
Standard.  Under no circumstances may Registration Standard
responses be combined with other types of filings for which
fees are required.

A.  Manufacturing Use Products (MUPs) containing the subject
    pesticide as sole active ingredient.

    1.  Within 90 days from receipt of this document, you
must submit for each product subject to this Registration
Standard:

-------
                               -33-


        a.   Generic Data Exemption Statement (EPA Form 8580-3),
            if applicable,  or the "FIFRA Section 3(c)(2)(B)
            Summary Sheet"  (EPA Form 8580-1),  with appropriate
            attachments.

        b.   Confidential Statement of Formula (EPA Form 8570-4).

        c.   Evidence of compliance with data compensation
            requirements of FIFRA sec. 3(c)(l)(D).  Refer to 40
            CFR 152.80-152.99.

     2.  Within 9 months from receipt of this document you
must submit:

        a.   Application for Pesticide Registration (EPA Form
            8570-1).

        b.   Two copies of any required product-specific data
            (See Table B).

        c.   Three copies of draft labeling, including the
            container label and any associated supplemental
            labeling.

        d.   Product Specific Data Report (EPA Form 8580-4).

     3.  Within the times set forth in Table A, you must
submit all generic data, unless you are eligible for the
generic data exemption.  If for any reason any test is delayed
or aborted so that the schedule cannot be met, immediately
notify the Agency of the problem, the reasons for the problem,
and your proposed course of action.

B.  Manufacturing Use Products containing the subject pesticide
    in combination with other active ingredients.

     1.  Within 90 days from receipt of this document, you
must submit:

        a.   Generic Data Exemption Statement  (EPA Form 8580-3),
            if applicable,  or the FIFRA sec. 3(c)(2)(B)
            Summary Sheet,  with appropriate attachments  (EPA
            Form 8580-1).

        b.   Confidential Statement of Formula (EPA Form 8570-4)

     2.  Within 9 months of receipt of this document, you must
submit:

          Three copies of draft labeling, including the container
     label and any associated supplemental labeling.

-------
                               -34-
     3.   Within the time frames set forth in Table A, you must
submit all generic data,unless you are eligiblefor the
generic data exemption.  If for any reason any test is delayed
or aborted so that the schedule cannot be met, immediately
notify the Agency of the problem, the reasons for the problem,
and your proposed course of action.

C.  End Use Products containing the subject pesticide as sole
    active ingredient.

     1.   Within 90 days from receipt of this document, you
must submit:

        a.  Generic Data Exemption Statement  (EPA Form 8580-3),
            if applicable,  or the FIFRA Section 3(c)(2)(B)
            Summary Sheet,  with appropriate attachments (EPA
            Form 8580-1).

        b.  Confidential Statement of Formula (EPA Form 8570-4).

     2.   Within 9 months from receipt of this document you
must submit:

        a.  Two copies of any product-specific data,  if required
            by Table C.

        b.  Product Specific Data Report (EPA Form 8580-4),
            if Table C  lists required product-specific data.

        c.  Three copies of draft labeling, including the
            container  label and any associated supplemental
            labeling.

     3.   Within the times set forth in Table A, you must submit
all generic data, unless you are eligible  for the generic data
exemption.  If for any  reason any test is delayed or  aborted  so
that the schedule cannot be met, immediately  notify the Agency
of the problem, the reasons for the problem,  and your proposed
course of action.

D.  End Use Products containing the subject active ingredient
    as one of multiple  active ingredients

     1.  Within 90 days from receipt of this  document, you
must submit:

        a.  Generic Data Exemption Statement  (EPA Form 8580-3),
            if applicable, or the FIFRA Section 3(c)(2)(B)
            Summary Sheet, with appropriate attachments'  (EPA
            Form 8580-1).

        b.  Confidential Statement of Formula  (EPA Form 8570-4).

-------
                               -34a-
     2.  Within 9 months from the receipt of this document, you
must submit:

     Three copies of draft labeling, including the container
label and any associated supplemental labeling.

     3.  Within the times set forth in Table A, you must submit
all generic data, unless you are eligible for the generic data
exemption.  If for any reason any test is delayed or aborted so
that the schedule cannot be met, immediately notify the Agency
of the problem, the reasons for the problem, and your proposed
course of action.

E.   Intrastate Products.

     Applications for full Federal registration of intrastate
products were required to be submitted no later than July 31,
1988.  Unless an application for registration was submitted
by that date, no product may be released for shipment by the
producer after July 31, 1988.

-------

-------
                   -35-
I.  DATA APPENDICES

-------
                             -36-

                           TGUIDE-1

                       GUIDE TO TABLES

     Tables A,  B,  and C contain listings of data requirements
for the pesticides covered by this Registration Standard.

     Table A contains generic data requirements that apply to
     the pesticide in all products, including data requirements
     for which a "typical formulation" is the test substance.

     Table B contains product-specific data requirements that
     apply only to a manufacturing use product.

     Table C contains product-specific data requirements that
     apply only to an end use product.

     The data tables are generally organized according to the
following format:

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

2.  Test Substance (Column 2).  This column lists the composition
of the test substance required to be used for the test, as
follows:

     TGAI = Technical grade of the active ingredient
     PAI =  Pure active ingredient
     PAIRA = Pure active ingredient, radio labeled
     TEP =  Typical end use formulation
     MP =   Manufacturing use product
     EP =   End use product

Any other test substances, such as metabolites, will be
specifically named in Column 2 or  in footnotes to the table.

3.  Use pattern (Column 3).  This  column indicates the use
patterns to which the data requirement applies.  Use patterns
are the same as those given in 40  CFR Part 158.  The following
letter designations are used for the given use patterns:

     A = Terrestrial, food
     B = Terrestrial, non-food
     C = Aquatic, food
     D = Aquatic, non-food
     E = Greenhouse, food
     F = Greenhouse, non-food
     G = Forestry
     H = Domestic outdoor
     I = Indoor

Any other designations will be defined in  a  footnote to  the  table

-------
                             -37-

                           TGUIDE-2

4.  Does EPA have data? (Column 4).  This column indicates one
of three answers:

     YES - EPA has data in its files that satisfy this data
     requirement.  These data may be cited by other registrants
     in accordance with data compensation requirements of
     Part 152, Subpart E.

     PARTIALLY - EPA has some data in its files, but such data
     do not fully satisfy the data requirement.  In some cases,
     the Agency may possess data on one of two required species,
     or may possess data on one test substance but not all.
     The term may also indicate that the data available to
     EPA are incomplete.  In this case, when the data are
     clarified, or additional details of the testing submitted
     by the original data submitter, the data may be determined
     to be acceptable.  If this is the case, a footnote to
     the table will usually say so.

     NO - EPA either possesses no data which are sufficient
     to fulfill the data requirement, or the data which EPA
     does possess are flawed scientifically in a manner that
     cannot be remedied by clarification or additional infor-
     mation.

5.  Bibliographic citation (Column 5).  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
Appendices for a complete citation of the study.

6.  Must additional data be submitted? (Column 6).  This
column indicates whether the data must be submitted to the
Agency.  If column 3 indicates that the Agency already has
data, this column will usually indicate NO.  If column 3
indicates that the Agency has only partial data or no data,
this column will usually indicate YES.  In some cases, even
though the Agency does not have the data, EPA will not require
its submission because of the unique characteristics of the
chemical; because data on another chemical can be used to
fulfill the data requirement; or because the data requirement
has been waived or reserved.   Any such unusual situations
will be explained in a footnote to the table.

7.  Timeframe for submission (Column 7).   If column 5 requires
that data be submitted,  this column indicates when the data
are to be submitted,  based on the issuance date of the Regis-
tration Standard.  The timeframes are those established either
as a result of a previous Data Call-in letter,  or standardized
timeframes established by PR Notice 85-5 (August 22, 1985).

8.  Footnotes (at the end of each table).  Self-explanatory.

-------
                                                         -38-


TABLE A.   GENERIC DATA REQUIREMENTS FOR THE TECHNICAL GRADE OF THE ACTIVE INGREDIENT Sulfotepp.  (Continued).
Data Requirement
  Test
Substance
Does EPA
have data to
satisfy this    Bibliographic
requirement?!./  Citation!/
Must additional
data be submitted
under FIFRA Sec.
3(c)(2)(B)?
Time Frame
For Data
Submission
§158, Subpart C, Product Chemistry

Product Identity and Composition;

61-2 - Description of Beginning      TGAI
         Materials and Manufac-
         turing Process

61-3 - Discussion of Formation       TGAI
         of Impurities

Analysis and Certification of
Product Ingredients;

62-1 - Preliminary Analysis of       TGAI
         Product Samples
                      No
                      No
                      No
                    N/A
                    N/A
                    N/A
     Yes2/
     Yes3/
     YesV
  6 Months
  6 Months
 12 Months
(Continued).

-------
TAHI iK A.   
-------
                                                         -40-

TABLE A.  GENERIC DATA REQUIREMENTS FOR THE TECHNICAL GRADE OF THE ACTIVE INGREDIENT Sulfotepp (Continued).


                                                  Does EPA                          Must additional
                                                  have data to                      data be submitted    Time Frame
                                   Test           satisfy this    Bibliographic     under FIFRA Sec.     For Data
Data Requirement                 Substance        requirement?!./  Citation!/        3(c)(2)(B)?          Submission


§ 158, Subpart C, Product Chemistry (continued).

Other Requirements;

64-1 - Submittal of Samples           N/A              N/A            N/A                No


FOOTNOTES:

1.  Not applicable.  Although product chemistry data may have been submitted in the past, the Agency has determined
  that these data must be resubmitted for each pesticide.  New requirements have been introduced and previously
  submitted data must be updated.  Therefore,  bibliographic citations for the old data are not applicable.

2.  Complete information must be provided regarding the nature of the process (batch or continuous), the relative
  amounts of beginning materials and the order in which they are added,  the chemical equations for each intended
  reaction, equipment used to produce each intermediate and the final product, reaction conditions, the duration of
  each step of the process, purification procedures, and quality control measures.  In addition,  the name and address
  of the manufacturer, producer, or supplier of each beginning material used in the manufacture of each product must
  be provided, along with information regarding the properties' of those materials.

3.  A detailed discussion of all impurities that are or may be present at _>0.1%, based on knowledge of the beginning
  materials, chemical reactions  (intended and side) in the manufacturing process, and any contamination during and
  after production must be submitted.


(Continued).~~~

-------
                                                          -MI-
TABLE A.  GENERIC DATA REQUIREMENTS FOR THE TECHNICAL GRADE OF THE ACTIVE INGREDIENT Sulfotepp (Continued).


§ 158, Subpart C, Product Chemistry (continued).

FOOTNOTES (Continued):

4.  Five or more representative samples must be analyzed for the amount of active ingredient and each impurity for
  Which certified limits are required.  Complete validation data (accuracy and precision) must be submitted for each
  analytical method used.

5.  Physicochemical characteristics (color, physical state,  odor, melting point, boiling point, specific gravity,
  solubility, vapor pressure, dissociation constant, partition coefficient, pH, and stability) as required in 40 CFR
  158.190 and more fully described in the Pesticide Assessment Guidelines, Subdivision D, must be submitted.

6.  Data needed if the technical chemical is a solid at room temperature.

7.  Data required if the technical product is a liquid at room temperature.

8.  Data required if the technical product is organic and nonpolar.

9.  Data required if the test substance is dispersible in water.

-------
                                                          -42-
TABLE A.   GENERIC DATA REQUIREMENTS FOR SULPOTEPP.
Data Requirement
                                    Test
                                  substance
                                  Must addi-
Does EPA        Bibliographic     tional data
have data?      Citation          be submitted?
                                   Time frame
                                       for
                                   submission
§158, Subpart D

§158.240 Residue Chemistry

171-2    Chemical Identity!/

         Directions for use
171-3

171-4



171-4



171-4


171-4

171-4


171-4
         Nature of the residue
         (Metabolism)
         - Plants

         Nature of the residue
         (Metabolism)
         - Livestock

         Residue analytical
         methods

         Storage stability

         Magnitude of the residue
         in plants

         Magnitude of residue in
         Meat/Milk/Poultry/Eggs
(See Index)

     No



     No




     No


     No

     No


     No
N/A




N/A




N/A



N/A

N/A



N/A
Nq2/
Nq2/
No2/

No!/
1.  The same chemical identity data are required as under §158,  Subpart C,  with emphasis on impurities that could
constitute residue problems.  Refer to Product Chemistry Data Requirements  tables.

-------
                                                         -43-

                                                        TAELE  A
                                       GENERIC DATA REQUIREMENTS EXDR Sulfotepp
Does EPA have Must additional Time frame
Test Use data to satisfy Bibliographic data be submitted for
Data Requirement Substance Pattern this requirement? citation!/ under FIFRA submission
(Yes, No, Partially) § 3(c)(2)(B)?
§158, Subpart D (Continued)
§158.290 Environmental Fate
DEGRADATION STUDIES-LAB:
161-1 - Hydrolysis TGAI or PAIRA F No
Photodegradation
161-2 - In Water TGAI or PAIRA
161-3 - On Soil TGAI or PAIRA
161-4 - In Air TGAI or PAIRA F No
METABOLISM STUDIES-LAB:
162-1 - Aerobic Soil TGAI or PAIRA F No
162-2 - Anaerobic Soil TGAI or PAIRA
162-3 - Anaerobic Aquatic TGAI or PAIRA
162-4 - Aerobic Aquatic TGAI or PAIRA

Yes 9 Months



Yes!/ 9 Months
Yes 27 Months
27 Months
27 Months
27 Months
(12 Months - Progress
Report)
(Continued).

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                                                         -44-

                                                        TABLE A
                                        GENERIC DATA REQUIREMENTS FOR Sulfotepp
                                                      Does EPA have                    Must additional    Time frame
                              Test           Use      data to satisfy   Bibliographic  data be submitted     for
                            Substance      Pattern    this requirement?  citationV    under FIFRA        submission
                                •	(Yes,  No,  Partially)	§ 3(c)(2)(B)?	
Data Requirement
§158, Subpart D (Continued)

§158.290 Environmental Fate (continued)

MOBILITY STUDIES;

163-1 - Adsorption/Desorption   TGAI
          and Leaching          or PAIRA
                                                              No
Yes3/
12 Months
163-2 - Volatility (Lab)
163-3 - Volatility (Field)
TEP
TEP
F
F
No
No
Yes!/
Reserved^/
12 Months
To be Determined
FOOTNOTES:

1. EPA Accession Number.

2. Sulfotepp has a high vapor pressure; sulfotepp fumes may be sensitive to photodegradation.

3. The adsorption/desorption (batch equilibrium) study is preferred.   This study should also be conducted
   with major metabolites found in the aerobic soil metabolism study.

4. The reported vapor pressure of sulfotepp is 1.7x10-4 mm Hg or 22.6 mPa (20°C); sulfotepp is considered
   highly toxic.
5. The field studies may be required depending on the results of the laboratory studies.

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                                                        -45-

                                                       TABLE A
                                       GENERIC DATA REQUIREMENTS EDR Sulfotepp
Data
Requirement Test Use Does EPA Bibliographic Must Additional Timeframe.
Substance Patterns Have Data? Citation Data be for
Submitted? Submission
§158, Subpart D (Continued)
§158.
,340 Toxicology

ACUTE TESTING: " '
81-1
81-2
81-3

81-4
81-5
81-6

81-7
- Acute Oral Toxicity - Rat TGAI F No
- Acute Dermal Toxicity - TGAI F No -
Rabbit
- Acute Inhalation Toxicity - TGAI F No -
Rat
- Eye Irritation - Rabbit TGAI F No -
- Dermal Irritation - Rabbit TGAI F No -
- Dermal Sensitization - TGAI F No -
Guinea Pig
- Acute Delayed TGAI F No -
Neurotoxicity - Hen
Yes 9 months
Yes 9 months
Yes 9 months

Yes 9 months
Yes 9 months
Yes 9 months

Yes 12 months
(Continued).

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                                                        -46-
                                                       TABLE A
                                       GENERIC DATA REQUIREMENTS FOR Sulfotepp
Data
§158,
§158.
Requirement
Subpart D (Continued)
340 Toxicology (continued)
Test
Substance

Use
Patterns

Does EPA
Have Data?

Bibliographic Must Additional
Citation Data be
Submitted?

Timefrarne
for
Submission

SUBCHRONIC TESTING:
82-1

82-2
82-3
82-4
82-5
- 90-Day Feeding -
Rodent
Non-rodent
- 21-Day Dental - Rabbit
- 90-Day Dermal - Rat
- 90-Day Inhalation - Rat
- 90-Day Neurotoxicity

TGAI
TGAI
TGAI
TGAI
TGAI
TGAI

F
F
F
F
F
F

No
No
NO
No
No
No .
*
NbV
Nql/
Yes
Nb2/
Yes
[ Reserved ]3_/


12 months

15 months

(Continued).

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                                                         -47-

                                                        TART.F. A
                                        GENERIC DATA REQUIREMENTS FOR Sulfotepp
Data
§158,
§158.
Requirement
Subpart D (Continued)
340 Toxicology (continued)
Test Use Does EPA Bibliographic Must Additional
Substance Patterns Have Data? Citation Data be
Submitted?

Timeframe
for
Submission

CHRONIC TESTING:
83-1


83-2


83-3
83-3
83-4
- Chronic Toxicity -
Rodent
Non-Rodent
- Oncogenicity Study -
Rat
Mouse
- Teratogenicity - Rat
- Teratogenicity - Rabbit
- Reproduction - Rat

TGAI F No No2/
TGAI F No - No2/

TGAI F No - No2/
TGAI F No - No2/
TGAI F NO - Yes!/
TGAI F No Yes!/
TGAI F No No2/






15 months
15 months

(Continued, footnotes follow).

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                                                         -48-

                                                       TABLE A
                                       GENERIC DATA REQUIREMENTS FOR Sulfotepp
Data Requirement Test Use
Substance Patterns
§158, Subpart D (Continued)
§158.340 Toxicology (continued)
MUTAGENICITY TESTING:
84-2 - Gene Mutation (Ames Test) TGAI F
84-2 - Chromosomal Aberration TGAI F
84-4 - Other Mechanisms of TGAI F
Mutagenicity
SPECIAL TESTING:
85-1 - General Metabolism PAI or PAIRA F
86-1 - Domestic Animal Choice F
Safety
Does EPA Bibliographic Must Additional
Have Data? Citation Data be
Submitted?
" «
No - Yes
No - Yes
No - Yes

No - Nq2/
No - No2/

Timeframe
for
Submission
9 months
12 months
12 months




(Continued,  footnotes follow).

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                                                         -49-
                                                       TABLE A
                                        GENERIC DATA REQUIREMENTS FDR Sulfotepp
§158, Subpart D (Continued)

§158.340 Toxicology (continued)

FOOTNOTES:

 1.  This study is not required because there is no oral exposure and because of requirements for subchronic
     dermal and inhalation studies.

 2.  This study is not required under the existing use patterns.

 3.  This study is reserved until the results of the acute delayed neurotoxicity study become available.   If the
     results of the acute study are positive in the hen,  then this study is required.

 4.  A teratology study in one species is required.

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                                                          -50-

                                                         TABLE A
                                         GENERIC DATA REQUIREMENTS FOR Sulfotepp
Data Requirement
  Test
Substance
  Use
Patterns
Does EPA
Have Data?
Bibliographic
Citation
Must Additional Timeframe
Data be            for
Submitted?      Submission
§158, Subpart D (Continued)

§158.390  Reentry Protection

132-1 - Foliar Dissipation

132-1 - Soil Dissipation

133-3 - Dermal Exposure

133-4 - Inhalation Exposure

§158.440  Spray Drift

201-1 - Droplet Size Spectrum

202-1 - Drift Field Evaluation
   TEP

   TEP

   TEP

   TEP



   TEP

   TEP
    F

    F
     No



     No

     No
                   Yes!/



                Reserved^/

                Reserved^/
                                                        27 months
1. The registrant is required to propose an acceptable reentry label statement based upon airborne residue
   levels measured after observing the proposed label conditions,  on estimated human exposure to those residues,
   and on toxicity (No Observed Effect Level) of Sulfotepp.   Human exposure should be estimated from the levels
   of the airborne residues assuming a respiration rate of 60 liters/minute.  Data from monitoring of actual human
   inhalation exposure must not be gathered.
2. Reserved until all the toxicity data requirements are fulfilled.

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                                                        -51-

                                                       TABLE A
                                       GENERIC DATA REQUIREMENTS FOR Sulfotepp
Data
§158,
§158.
Requirement Test
Substance
Subpart D (Continued)
490 Wildlife and Aquatic Organisms
Use Does EPA Bibliographic Must Additional
Patterns Have Data? Citation Data be
Submitted?

Timeframe
for
Submission!/.

AVIAN AND MAMMALIAN TESTING:
71-1
71-2

71-3
71-4
71-5


- Acute Avian Oral Toxicity TGAI
- Avian Subacute Dietary
- Upland Game Bird TGAI
- Wild Mammal Toxicity TGAI
- Avian Reproduction TGAI
- Simulated and Actual TEP
Field Testing for
Mammals & Birds
F No - Yes!/

F No - Yes!/
F No - No!/
F No No!/
F No - No!/


9 months

9 months





(Continued,  footnotes follow).

-------
                                                         -52-
                                                        TABLE A
                                        GENERIC DATA REQUIREMENTS FOR Sulfotepp
Data Requirement
                                     Test         Use      Does EPA     Bibliographic   Must Additional Timeframe
                                   Substance    Patterns   Have Data?   Citation        Data be            for
               	 Submitted?	Submission!/.

§158, Subpart D (Continued)

§158.490 Wildlife and Aquatic Organisms (Continued)

AQUATIC ORGANISM TESTING;                                                         ,  ;

72-1 - Freshwater Fish Toxicity

       - Coldwater Species
72-2   Acute Toxicity
         to Freshwater
         Invertebrates

72-3 - Acute Toxicity to
          Estuarine and Marine
          Organisms
TGAI

TGAI



TGAI
PartiallyV   00104043

   No



   No
Yes!/

Yes



Nbl/
                                                                                                          9 months

                                                                                                          9 months
72-4
72-4
72-5
72-6
72-7

- Fish Early Life Stage
- Aquatic Invertebrate
Cycle
- Fish Full Life-Cycle
- Aquatic Organism
Accumulation
- Simulated or Actual
Field Testing for
Aquatic Organisms
TGAI
Life TGAI
TGAI
TGAI,PAI or
Degradation Product

TEP
F
F
F
F

F
No
No
No
No

No
Nq2/
No!/
No!/
Nb2/

No2/
 (Continued, footnotes follow).

-------
                                                          -53-

                                                         TART.F, A
                                         GENERIC DATA REQUIREMENTS FOR Sulfotepp
§158, Subpart D (Continued)

§158.490 Wildlife and Aquatic Organisms (continued)

FOOTNOTES:

1.  Data must be submitted no later than [9 months from receipt of Guidance Package],  unless
    otherwise indicated.                                                          .  ;

2.  As per 40 CFR 158.490, data are not required for this indoor, greenhouse use pattern.

3.  Only testing with one species (bobwhite quail) is required for this use pattern.

4.  Only testing with one species (rainbow trout) is required for this use pattern.

5.  Certain information, such as the amount of solvent used; whether control contained solvent and, if so, how much;
    photoperiod; time and location of water quality measurements; fish behavior, including signs of toxicity other
    than mortality; were not reported.  If this information was recorded and can be reported to the Agency, it is
    possible that these studies nay be upgraded.

-------
                                                           -54-

                                                          TABLE A
                                          GENERIC DATA REQUIREMENTS FOR Sulfotepp
 Data Requirement
  Test
Substance
  Use
Patterns
Does EPA
Have Data?
Bibliographic
Citation
 §158, Subpart D (Continued)

 §158.590 Nontarget Insects

 NONTARGET INSECT TESTING - POLLINATORS;

 141-1 - Honey Bee Acute Contact        TGAI
           Toxicity

 141-2 - Honey Bee - Toxicity of        TEP
           Residues on Foliage

 141-4 - Honey Bee Subacute
           Feeding Study

 141-5 - Field Testing for              TEP
           Pollinators
                          No
                          No
                          No
Must Additional Timeframe
Data be            for
Submitted?!/    Submission
                                              No
                                              No
                                              No
1.  Ecological Effects Branch, Hazard Evaluation Division, has determined that no data are required on sulfotepp and
    honey bees, as sulfotepp is registered only for indoor use.

-------
                                                           -55-




TABLE B.  PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS CONTAINING Sulfotepp.
Does EPA
have data to
Test satisfy this Bibliographic
Data Requirement Substance requirement?!/ Citation!/
§ 158, Subpart C, Product Chemistry
Product Identity and Composition
61-1 - Product Identity and Disclosure MP
of Ingredients
61-2 - Description of Beginning Mater- MP
ials and Manufacturing Process
61-3 - Discussion of Formation of MP
Impurities
Analysis and Certification of Product
Ingredients
62-1 - Preliminary Analysis of Product MP
Samples
62-2 - Certification of Ingredient MP
Limits
62-3 - Analytical Method to Verify MP
Certified Limits

•
No N/A

No N/A

No N/A



No N/A
No N/A

No N/A

Must additional
data be submitted
under FIFRA Sec.
3(c)(2)(B)?

•
Yes!/

Yes!/

Yes!/



YesV
Yes!/
•t /
YesZ/

Time Frame
For Data
Submission


6 months

6 months

6 months



12 months
12 months

12 months

 (Continued).

-------
                                                          -56-
TABLE B.  PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS CONTAINING Sulfotepp.
Does EPA
have data to
Test satisfy this Bibliographic
Data Requirement Substance requirement?!/ Citation!/
§ 158,
Must additional
data be submitted
under FIFRA Sec.
3(c)(2)(B)?
Time Frame
For Data
Submission
Subpart C, Product Chemistry (Continued)
Physical and Chemical Characteristics
63-2 -
63-3 -
63-4 -
63-7 -
63-12
63-14
63-15
63-16
63-17
Color
Physical State
Odor
Density, Bulk Density or
Specific Gravity
- pH
- Oxidizing or Reducing Action
- Flaimability
- Explodability
- Storage Stability
MP
MP
MP
MP
MP
MP
MP
MP
MP
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
• : Yes8/
Yes8/
Yes8/
Yes8/
Yes8,!/
Y«&10/
Yes8'!!/
Yes8,!2/
Yes8'!!/
6 months
6 months
6 months
6 months
6 months
6 months
6 months
6 months
15 months
(Continued).

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                                                           -57-

TABLE B.  PRODUCT SPECIFIC DATA REQUIREMENTS FDR MANUFACTURING-USE PRODUCTS CONTAINING Sulfotepp (continued).
Data Requirement
  Test
Substance
Does EPA
have data to
satisfy this    Bibliographic
requirement?!/  Citationi/
Must additional
data be submitted
under FIFRA Sec.
3(c)(2)(B)?
Time Frame
For Data
Submission
§158, Subpart C, Product Chemistry (Continued)

Physical and Chemical Characteristics (continued)

63-18 - Viscosity                        MP

63-19 - Miscibility                      MP

63-20 - Corrosion Characteristics        MP

Other Requirements;

64-1  - Submittal of Samples             N/A
                        No

                        No

                        No



                        N/A
                      N/A

                      N/A

                      N/A



                      N/A
       Yes8,14/
       Yes§/
   6 months

   6 months

  15 months
       No
FOOTNOTES:

1. Not applicable.  Although product chemistry data may have been submitted in the past, the Agency has determined
 that these data must be resubmitted for each pesticide.  New requirements have been introduced and previously
 submitted data must be updated.  Therefore, bibliographic citations for the old data are not applicable.

2. The chemical name, nominal concentration, Chemical Abstracts (CAS) Registry Number, and purpose of the active
 ingredient and each intentionally added inert must be provided.  For the active ingredients, the following must
 also be provided: the product, common and trade names; the molecular, structural and empirical formulas; the
 molecular weight or weight range; and any experimental or internally assigned company code numbers.

3. Complete information must be provided regarding the nature of the process (batch or continuous), the relative
 amounts of beginning materials and the order in which they are added, the chemical equations for each intended
 reaction, equipment used to produce each intermediate and the final product, reaction conditions, the duration of
 each step of the process, purification procedures, and quality control measures.  In addition, the name and address
 of the manufacturer, producer, or supplier of each beginning material used in the manufacture of each product must
 be provided, along with information regarding the properties of those materials.

 (Continued).

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                                                           -58-


 TABLE B.  PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS CONTAINING Sulfotepp (continued).


 §158, Subpart C, Product Chemistry (Continued)

 FOOTNOTES, continued:

4. A detailed discussion of all impurities that are or nay be present at _>0.1%, based on knowledge of the beginning
 materials, chemical reactions (intended and side) in the manufacturing process, and any contamination during and
 after production must be submitted.

5. Five or more representative samples must be analyzed' for the amount of active ingredient and each impurity for
 which certified limits are required.  Complete validation data (accuracy and precision) must be submitted for each
 analytical method used.

 6. Upper and lower limits for the active ingredient and each intentionally added inert, and upper limits for each
  impurity present at ^0.1% (w/w) and each "toxicologically significant" impurity present at <0.1% (w/w) must be
  provided and certified.  Also,  an explanation of how each certified limit was established must be provided (e.g.,
  sample analysis using validated analytical procedures, quantitative estimate based on amounts of ingredients used,
  etc.).  Limits for impurities not associated with the active ingredient need be provided only if they are
  considered to be of toxicological significance,  regardless of the concentration at which they are present.
  Certifications must be submitted on EPA Form 8570     Rev.  2-85.

  7. Analytical methods must be provided to determine the active ingredient, and each toxicologically significant
   impurity and intentionally added inert for which certified limits are required.  Each method must be accompanied by
   validation studies indicating its accuracy and precision.   These methods must be suitable for enforcement of certi-
   fied limits.

  8. Physicochemical characteristics (color,  physical state,  odor, melting point,  boiling point, specific gravity,
   solubility, vapor pressure, dissociation constant, partition coefficient, pH, and stability) as required in 40 CFR
   158.190 and more fully described in the Pesticide Assessment Guidelines, Subdivision D, must be submitted.

  9. Data required if the test substance is dispersible in water.

  10. Data required if the product contains any oxidizing or reducing agents.



 (Continued).

-------
                                                          -59-
TABLE B.  PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS CONTAINING Sulfotepp (continued)






§158, Subpart C, Product Chemistry (Continued)



FOOTNOTES, continued:



 11. Data required if the product contains combustible liquids.



 12. Data required if the product is potentially explosive.




 13. This test for long term storage stability must be under warehouse conditions.



 14. Data required if the product is a liquid.



 15. Data required if the product is a liquid and is to be diluted with petroleum solvents.

-------
                                                        -60-
                                                      TABLE B
                PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS CONTAINING Sulfotepp
Data Requirement Test
Substance
§ 158, Section D
§ 158.340 Toxicology
ACUTE TESTING:
81-1 - Acute Oral Toxicity - Rat MP
81-2 - Acute Dermal Toxicity MP
- Rabbit
81-3 - Acute Inhalation Toxicity MP
- Rat
81-4 - Primary Eye Irritation MP
- Rabbit
81-5 - Primary Dermal Irritation MP
Use
Patterns
F
F
F
F
F
Does EPA
Have Data?
No
No
No
No
No
Bibliographic Must Additional
Citation Data be
Submitted?
Yes
Yes
Yes
Yes
Yes
Timeframe
for
Submission
9 months
9 months
9 months
9 months
9 months
         - Rabbit

81-6 - Dermal Sensitization
         - Guinea Pig
MP
No
Yes
                                                                   9 months

-------
                   -61-
II.  LABELING APPENDICES

-------
                             -62-

                          SUMMARY-1

                        LABEL CONTENTS

     40 CFR 156.10 requires that certain specific labeling
statements appear at certain locations on the label.  This
is referred to as format labeling.  Specific label items listed
below are keyed to the table at the end of this Appendix.

     Item 1.  PRODUCT NAME - The name, brand or trademark is
required to be located on the front panel, preferably centered
in the upper part of the panel.  The name of a product will
not be accepted if it is false or misleading.

     Item 2.  COMPANY NAME AND ADDRESS - The name and address
of the registrant-or distributor is required on the label.
The name and address should preferably be located at the
bottom of the front panel or at the end of the label text.

     Item 3.  NET CONTENTS - A net contents statement is
required on all labels or on the container of the pesticide.
The preferred location is the bottom of the front panel
immediately above the company name and address, or at the end
of the label text.  The net contents must be expressed in the
largest suitable unit, e.g., "1 pound 10 ounces" rather than
"26 ounces." In addition to English units, net contents may
be expressed in metric units.  [40 CFR 156.10(d)J

     Item 4.  EPA REGISTRATION NUMBER - The registration
number assigned to the pesticide product must appear on the
label, preceded by the phrase "EPA Registration No.," or "EPA
Reg. No."  The registration number must be set in type of a
size and style similar to other print on that part of the
label on which it appears and must run parallel to it.  The
registration number and the required identifying phrase must
not appear in such a manner as to suggest or imply recommendation
or endorsement of the product by the Agency.
£40 CFR 156.10(e)]

    Item 5.  EPA ESTABLISHMENT NUMBER - The EPA establishment
number, preceded by the phrase "EPA Est." is the final estab-
lishment at which the product was produced, and may appear
in any suitable location on the label or immediate container.
It must also appear on the wrapper or outside container of
the package if the EPA establishment number on the immediate
container cannot be clearly read through such wrapper or container.
[40 CFR 156.10(f)J

    Item 6A. INGREDIENTS STATEMENT - An ingredients statement
is required on the front panel.  The ingredients statement must
contain the name and percentage by weight of each active ingredient
and the total percentage by weight of all inert ingredients.
The preferred location is immediately below the product name.
The ingredients statement must run parallel with, and be clearly
distinguished from, other text on the panel.  It must not be
placed in the body of other text.  [40 CFR 156.10(g)J

-------
                               -63-

                            SUMMARY-2

    Item 6B.  POUNDS PER GALLON STATEMENT - For liquid agricul-
tural formulations, the pounds per gallon of active ingredient
must be indicated on the label.

    Item 7.  FRONT LABEL PRECAUTIONARY STATEMENTS - Front panel
precautionary statements must be grouped together, preferably
within a block outline.  The table below shows the minimum type
size requirements for various size labels.

    Size of Label        Signal Word          "Keep Out of Reach
    on Front Panel       Minimum Type Size       of Children"
    in Square Inches     All Capitals          Minimum Type Size
                 • »
    5 and under  .             6 point              6 point
    above 5 to 10             10 point              6 point
    above 10 to 15            12 point              8 point
    above 15 to 30            14 point             10 point
    over 30                   18 point             12 point

    Item 7A.  CHILD HAZARD WARNING STATEMENT - The statement
"Keep Out- of Reach of Children" must be located on the front
panel above the signal word except where contact with children
during distribution or use is unlikely.  [40 CFR 156.10(h)(1)(ii)]

    Item 7B.  SIGNAL WORD - The signal word (DANGER,  WARNING,
or CAUTION) is required on the front panel immediately below
the child hazard warning statement.  [40 CFR 156.10 (h)(l)(i)]

    Item 7C.  SKULL & CROSSBONES AND WORD "POISON" - On products
assigned a toxicity Category I on thie basis of oral,  dermal,
or inhalation toxicity, the word "Poison" shall appear on the
label in red on a background of distinctly contrasting color and
the skull and crossbones shall appear in immediate proximity to
the word POISON.  [40 CFR 156.10(h)(1)(i)J

    Item 7D.  STATEMENT OF PRACTICAL TREATMENT - A statement
of practical treatment (first aid or other) shall appear on
the label of pesticide products in toxicity Categories I,
II, and III.  [40 CFR 156.10(h)(1)(iii)]

    Item 7E.  REFERRAL STATEMENT - The statement "See Side
(or Back) Panel for Additional Precautionary Statements" is
required on the front panel for all products, unless all
required precautionary statements appear on the front panel.
[40 CFR I56.10(h)(l)(iii)]

    Item 8.  SIDE/BACK PANEL PRECAUTIONARY LABELING - The
precautionary statements listed below must appear together
on the label under the heading "PRECAUTIONARY STATEMENTS."
The preferred location is at the top of the side or back
panel preceding the directions for use, and it is preferred
that these statements be surrounded by a block outline.  Each
of the three hazard warning statements must be headed by the
appropriate hazard title.  [40 CFR 156.10(h)(2)].

-------
                             -64-

                          SUMMARY-3

    Item 8A.  HAZARD TO HUMANS AND DOMESTIC ANIMALS - Where a
hazard exists to humans or domestic animals, precautionary
statements are required indicating the particular hazard, the
route(s) of exposure and the precautions to be taken to avoid
accident, injury or damage.  [40 CFR 156.10(h)(2)(i)J

    Item 8B.  ENVIRONMENTAL HAZARD - Where a hazard exists to
non-target organisms excluding humans and domestic animals,
precautionary statements are required stating the nature of
the hazard and the appropriate precautions to avoid potential
accident, injury, or damage.  [40 CFR 156.10(h)(2)(ii)]

    Item 8C.  PHYSICAL OR CHEMICAL HAZARD - FLAMMABILITY
Precautionary statements relating to flammability of a product
are required to appear on the label if it meets the criteria
in the PHYS/CHEM Labeling Appendix. The requirement is
based on the results of the flashpoint determinations and
flame extension tests required to be submitted for all products.
These statements are to be located in the side/back panel
precautionary statements section, preceded by the heading
"Physical/Chemical Hazards."  Note that no signal word is
used in conjunction with the flammability statements.

    Item 9A.  RESTRICTED USE CLASSIFICATION - FIFRA sec. 3(d)
requires that all pesticide formulations/uses be classified
for either general or restricted use.  Products classified
for restricted use may be  limited to use by certified applicators
or persons under their direct supervision (or may be subject
to other restrictions that may be imposed by regulation).

    In the Registration Standard, the Agency has  (1) indicated
certain formulations/uses  are to be restricted (Section  IV
indicates why the product has been classified for restricted
use); or  (2) reserved any  classification decision until
appropriate data are submitted.

    The Regulatory Position and Rationale states whether
products containing this active ingredient are classified
for restricted use.  If they are restricted the draft label(s)
submitted to the Agency as part of your application must
reflect this determination (see below).

     If you do not believe that your product should be classified
for restricted use, you must submit any information and
rationale with your application for reregistration.  During
the Agency's review of your application, your proposed classi-
fication determination will be evaluated in accordance with
the provisions of 40 CFR 156.11(c).  You will be  notified  of
the Agency's classification decision.

-------
                             -65-

                          SUMMARY-4

     Classification Labeling Requirements

     If your product has been classified for restricted use,
the following label requirements apply:

     1.  All uses restricted.

         a.  The statement "Restricted Use Pesticide" must
     appear at the top of the front panel of the label.  The
     statement must be set in type of the same minimum size
     as required for human hazard signal word (see table in 40
     CFR 156.10(h)(l)(iv)
                 . *

         b.  Directly below this statement on the front panel,
     a summary statement of the terms of restriction must
     appear (including the reasons for restriction if specified
     in Section I).  If use is restricted to certified applicators,
     the following statement is required:  "For retail sale
     to and use only by Certified Applicators or persons
     under their direct supervision and only for those uses
     covered by the Certified Applicator's Certification."

     2.  Some but not all uses restricted.  If the Regulatory
Position and Rationale states that some uses are classified
for restricted use, and some are unclassified, several courses
of action are available:

          a.  You may label the product for Restricted use.
     If you do so, you may include on the label uses that
     are unrestricted,  but you may not distinguish them
     on the label as being unrestricted.

          b.  You may delete all restricted uses from your
     label and submit draft labeling bearing only unrestricted
     uses.

          c.  You may "split" your registration, i.e., register
     two separate products with identical formulations, one
     bearing only unrestricted uses,  and the other bearing
     restricted uses.  To do so, submit two applications for
     reregistration, each containing all forms and necessary
     labels.  Both applications should be submitted simul-
     taneously.   Note that the products will be assigned
     separate registration numbers.

    Item 9B.  MISUSE STATEMENT - All products must bear the
misuse statement, "It is a violation of Federal law to use
this product in a manner inconsistent with its labeling."
This statement appears at the beginning of the directions
for use,  directly beneath the heading of that section.

-------
                             -66-

                          SUMMARY-5

    Item 10A.  REENTRY STATEMENT - If a reentry interval
has been established by the Agency, it must be included on
the label.  Additional worker protection statements may be
required in accordance with PR Notice 83-2, March 29, 1983.

    Item 10B.  STORAGE AND DISPOSAL BLOCK -  All labels are
required to bear storage and disposal statements.  These
statements are developed for specific containers, sizes, and
chemical content.  These instructions must be grouped and
appear under the heading "Storage and Disposal" in the directions
for use.  This heading must be set in the same type sizes as
required for the child hazard warning.  Refer to Appendix II,
STOR, PEST/DIS, and CONT/DIS to determine the storage and
disposal instructions appropriate for your products.

    Item IOC.  DIRECTIONS FOR USE - Directions for use must
be stated in terms which can be easily read and understood by
the average person likely to use or to supervise the use of
the pesticide.  When followed, directions must be adequate to
protect the public from fraud and from personal injury and to
prevent unreasonable adverse effects on the environment.
[40 CFR 156.10]
                     COLLATERAL LABELING

    Bulletins, leaflets, circulars, brochures, data sheets,
flyers, or other written or graphic printed matter which is
referred to on the label or which is to accompany the product
are termed collateral labeling.  Such labeling may not bear
claims or representations that differ in substance from those
accepted in connection with registration of the product.  It
should be made part of the response to this notice and submitted
for review.

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                     -67-






                  SUMMARY-6






LABELING REQUIREMENTS OF THE FIFFA, AS AMENDED
ITEM
1
2
3
4
5
6A
6B
7
7A
7B
LABEL ELEMENT
Product name
Company name
and address
Net contents
EPA Reg. No.
EPA Est. No.
Ingredients
statement
Pounds /gallon
statement
Front panel
precautionary
statements
Keep Out of Reach
of Children
(Child hazard
warning)
Signal word
APPLICABILITY
OF REQUIREMENT
All products
All products
All products
All products
All products
All products
Liquid products
where dosage
given as Ibs.
ai/unit area
All products
All products
All products
PLACEMENT ON LABEL
REQUIRED
Front panel
None
None
None
None
Front panel
Front panel
Front panel
Front panel
Front panel
PREFERRED
Center front
panel
Bottom front
panel or end
of label text
Bottom front
panel or end
of label text
Front panel
Front panel,
imnediately
before or
following
Reg. No.
Inmediately
following
product name
Directly below
the main
ingredients
statement

Above signal
word
Imnediately
below child
hazard
warning
COMMENTS

If. registrant is not the producer, must
be qualified by "Packed for . • . . , "
"Distributed by. . .,"etc.
May be in metric units in addition to
U.S. units
Must be in similar type size and run
parallel to other type.
May appear on the container instead of
the label.
Text must run parallel with other text
on the panel.

All front panel precautionary statements
must be grouped together, preferably
blocked.
Note type size requirements.
Note type size requirements.

-------
   -68-
SUMMARY-7
ITEM
7C
7D
7E
8
8A
8B
LABEL ELEMENT
Skull & cross-
bones and word
POISON (in red)
Statement of
Practical
Treatment or
First Aid
Referral
statement
Side/back panel
precautionary
statements
Hazards to
humans and
domestic
animals
Environmental
hazards
APPLICABILITY
OF REQUIREMENT
All products
which are Cat-
egory I based
on oral, der-
mal, or inhala-
tion toxicity
All products
in Categories
I, II, and III
All products
where pre-
cautionary
labeling
appears on
other than
front panel.
All products
All products
in Categories
I, II, and III
All products
PLACEMENT ON LABEL
REQUIRED
Front panel
Category I:
Front panel
unless refer-
ral statement
is used.
Others:
Grouped with
side panel
precautionary
statements .
Front panel
None
None
None
PREFERRED
Both in close
proximity to
signal word
Front panel
for all.

Top or side
of back panel
preceding
directions
for use
Same as above
Same as above
COMMENTS



Must be grouped under the headings in
8A, SB, and 8C; preferably blocked.
Must be preceded by appropriate signal
word.
Environmental hazards include bee
caution where applicable.

-------
   -69-
suiWARY-8
ITEM
8C
9A
9B
10A
10B
IOC
LABEL ELEMENT
Physical or
chemical
hazards
Restricted
block
Misuse
statement
Reentry
statement
Storage and
disposal block
Directions
for use
APPLICABILITY
OF REQUIREMENT
All pressurized
products, others
with flash
points under
150°F
All restricted
products
All products
PR Notice 83-2
or as determined
by the Agency
All products
All products
PLACEMENT ON LABEL
REQUIRED
None
Top center
of front
panel
Inmediately
following
heading of
directions
for use
In the
directions
for use
In the
directions
for use
None
PREFERRED
Same as above
Preferably
blocked

Inmediately
after misuse
statement
Intnediately
before
specific
directions
for use or
at the end of
directions
for use
None
COMMENTS
Refer to Appendix II guide
PHYS/CHEM
Includes a statement of the terms of
restriction. The words "RESTRICTED USE
PESTICIDE" must be same type size as
signal word.
Required statement is:
"It is a violation of Federal law
to use this product in a manner
inconsistent with its labeling."

Must be set apart and clearly distin-
guishable from from other directions
for use.
Refer to Appendix II guides STOR,
CONT/DIS, and PEST/DIS for further
information and required statements.
May be in metric as well as U.S. units

-------
PRECAUTIONARY STATEMENTS


  HAZARDS TO HUMANS

  |t DOMESTIC ANNALS)

      DANGER
  ENVMONMENTAL HAZARDS
   PHYSICAL ON CHEMCAl

      HAZARDS
   OMfCTONS POR USE
B *
      k •
   RE-ENTRY fTATfMENT

      * Apple**)
   STORAGE AND

   '  DISPOSAL

  STORAGE-
  D0POSAL
CROP:
                                                                   CROP:
                                RESTRICTED USE


                                    PESTICIDE   %
                                (reason for clasnifytnr)
                         ICM WtUL Wui TO MtD CBt OrtJf BY CBRIPICO APPUCKKM OR
                         RRSGNS UWCX THEIR DIRECT WRXVUION AW) ONLY KM THQ6B
                         uses owtno IT THB coaineo APPUCAJDR-I cotrxriorioN
                                                                   CROP:
                               PRODUCT

                                   NAME
                            ACTIVE MOREDCNT:

                            MERT NQREDCNT8:



                            TOTAL:
                                                  100.00%
                                                                   CROP:
                             THIS PRODUCT CONTAMS   IBS OP  PER GALLON
                            KEEP OUT OF REACH OF CHILDREN

                               DANGER -POISON
                                                                                         •o
                                                                                          I
                                STATEMENT OF PRACTICAL TREATMENT
                                                                  CROP:
                        r SWALLOWED:

                        * WHALED=
                         SEE SCC PAWL POR ADDITIONAL PRECAUTIONARY STATEMENTS
                                                                     WARRANTY STATEMENT
                         MFOSY =

                         TOWN. STATE ==

                         ESTABLISHMENT NO. =

                         EPA REOflTRATXTN NO.
                                    NIT CONTENTS:

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 fMCAUnONAftV tTATEMCNTS
  NAZAAMTOHUUAN*
  ftDOMEfnCANMAU
      CAUTION
 DMRONUENTAL HAZAKtt
 fMYWALOHCHEUCAL
    HA2AMM
 MtfCTOMt FM UM
h • *MM d
     h a
  M-iMTKY KTATCMCHT
   PRODUCT
       NAME
ACTWt MOMEOCNT: ,
MfRT MQIUOCNTt:,
TOTAL:
                    100.00%
THtt PftOOUCT CONTAftt  LM OT   KHQAUON
                         KEEP OUT OF REACH OF CHILDREN
                               CAUTION
                             •TATEUKNT Of PRACTICAL mCATUCNT
                      rtWAUOWfO:
                      «««0« 'AN*L KM AOOmONAL PfttCAUTKMAItY STATEUCNTS
                      UFO IV
                      TOWN. ITATl
                      ISTAMJ3HMCNT NO.
                      IPA RtOOTRATION NO.
                                NIT CONTENT*:
                                      STORAGE AND
                                        DISPOSAL
                                     •KMAOC:
                                      WARRANTY STATEMENT

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                                     -72-
                I—fnvtrwiiiienfeil Protection Agency
                                                         § 16X10
          at obtained the data from anothq
            (Identify); applicant copied
            a publication; applicant
            py of the data from EPA).
            The applicant shall submit
                      a  statement that
            Devaluation of the proc
            Land  safety of  the formV
product, may not <
 supporting the  appl
 ,e following data:
  data the applicant,
 l EPA under:
end-
data
except
  (1)
mitted
thissectii
  (2)
safety of
ents, rathe
end-use
  (3)
regulations,
clearances
Food. Drug.
  (e) If the ap
Item of data b
section was
pense of) anoth
ly submitted the
predecessor. USD.
ary 1. 1970. to
for  registration.
permit, or
use to an e:
rereglstration  (
and the on
reached  writ
                                       sub»
                                     (b) of
 data
i product's
than to the
    and
 tolerances.
 ixemptio;
   ed  unde:
    O
       it
                                    to the
                                 tre ingredl-
                                iety of the
                               food additive
                                and  other
                               the Federal
                               Act.
                                  that any
                             ted under.this
                             iy (or at the ex-
                               who original-
                             to EPA  (or Its
                           on or after Janu-
                           irt an application
                           ptperimental   use
                            t adding  a new
                              tratlon. or for
                              the  applicant
                        data \submltter have
                                 it on  the
        amount and th*e terms W payment of
        any compensation  that \rnay be  pay-
        able    under     FIFRA    section
        3  156.10  in Volume 53,  page
         15991 of the Federal Register,  dated May 4,  1988,  and  is

         referred to  by  its  new  designation  throughout  this  docu-
         ment.

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  (Iv)   The    proouc*   !«••.-.-~-.
number a* prescribed In paragraph (e)
of this secMon.            a a a.^^.^^^^.*
  (v)  The producing  eitabmhrneni
number a* prescribed  In paragraph (I)
of thta section;
  (vl) An Ingredient statement•* pre-
scribed  In paragraph (g) of Mil* *ec-
Unn*
  (vil) Warning or precaullonary state-
ment* as  prescribed In paragraph tn>
of this section;
  (vlll) The direction* for use as pre-
scribed In paragraph (I) of Ihto section:

"ax) The use  clas*lflc»llon(s) a* pre-  (
scribed In paragraph (J) of Ihto *ertlon.
  (2) Prominence and legibility. (I) All
words, statements, graphic representa-
llons. designs or olher Informallon re-
quired on Ihe  labeling by Ihe Act or
the regulations In thta part must be
clearly legible to a person wllh normal
vision, and must be placed with such
consplcnousnen  (as  compared  wllh
olher words, slalemenls. design*, or
 graphic matter on the labeling) and
 expressed In s»ich term* as to render It
 likely to be read  and understood by
 the ordinary Individual under custom-
 ary conditions of purchase and use.
   (II) All required label text must:
   (A) Be sel In 0 point or larger type:
   (B> Appear  on  a  clear conlrasllng
 background: and
   (C) Nol be obscured or crowded.
   (3) Language to be toed. All required
 label or labeling text shall appear In
  the English language.  However. Ihe
  Agency may require or Ihe applicant
  may propose  additional text In other
  languages as to considered necessary to
  protect  the public. When additional
  text In another language to necessary.
  all  labeling requirement* will be ap-
  plied equally  to both  Ihe English and
  other-language  version* of the label-
     i) Placemen* of Label-it) OtneraL
  The label shall appear on or be secure-
  ly attached to the Immediate contain-
  er of the pesticide product. For pur-
  poses of this  Section, and the mta-
  brandlng provisions of the Act, "se-
  curely attached" shall mean that  a
  label can  reasonably  be  expected to
  remain affixed during the foreseeable
  conditions and period of use. If the Im-
  mediate container Is enclosed within a
whteh the label cannot be clearly read.
Ihe  label must also be securely at-
tached to such outside wrapper or con-
tainer. It It ta a part of the package as
customarily distributed or sold.
  (ID Tan*  cars and other buOc con-
tainers—(A) Transportation. While a
pesticide product to  In transit, the ap-
propriate provisions of  4f CFR Part*
 170-IR9. concerning Ihe transportation
of hazardous materials, and specifical-
 ly those provision* concerning the la-
 beling, marking and placarding of haz-
 ardous materials and the vehicles car-
i rylng them, define  the baste Federal
 requirement*.  In  addition, when any
 registered pesticide product to trans-
 ported In a lank car.  lank Iruck or
 olher mobile or portable bulk contain-
 er,  a copy  of the accepted label mu«t
 be  attached to the shipping papers.
 and left wllh the consignee at the time
 of delivery.                    	
   (B) Storage. When  pesticide  prod-
 ucts are  *tored  In bulk  container*.
 whether mobile or stationary, which
 remain m  the custody of  the user, a
 copy of the label of labeling. Including
 •II appropriate directions for use. shall
 be securely attached to the container
  In  Ihe Immediate vicinity of Ihe dis-
 charge control valve.
   (5) FalM or militating statement*.
  Pursuant to section 2(qXlXA) of Ihe
  Act. a  pesticide  or a  device declared
  •ubjed  to   Ihe   Art  P«rsu»nt  to
  1162.15. ta mtabranded If It* labeling to
  false or misleading In any particular
  Including  bolh pesllcldal and non-pes-
  tlcldal claims. Example* of statement*
  or  representations In the  labeling
  which conslllule mtobrandlng Include:
    (DA false  or  misleading statement
  concerning the composition  of  the
  product:
    (II) A false or misleading statement
   concerning the  effectiveness of  the
   product aa a pesticide or device;
    (III) A false or misleading statement
   about the value  of  the  product for
   purposes  other than  as • pesticide or
   device:
     (Iv) A false or misleading comparison
   with other pesticides or devices:
     (v) Any statement  directly or Indi-
   rectly Implying lhat the pesticide or
   device ta  recommended or endorsed by
               	
ment;
  (vl> The name of a pesticide which
eontalrw two or more principal active
Ingredient* If the name suggests one
or more but not  all  such principal
active  Ingredient* even  though the
names of the  other Ingredients are
stated elsewhere In the labeling;
  (vll) A true statement lined In such a
way as to give a false or misleading Im-
pression to the purchaser;
  fvlll) Label disclaimers which negate
or detract from labeling statement* re-
quired under the Act and thrwe regula-
tions;
  It*) Claims as to the safety of the
pesticide or Ha Ingredlenti. Including
statements such as "safe." "nonpolson-
ous." "nontnjtirlous."  "harmless" or
"nontoxlc to humans and  pet*" with
or without such a qualifying phrase as
"when used as directed"; and
  (x) Non-numerical  and/or compara-
tive  statements on the safety of the
product. Including but not limited to:
  (A) "Contains all  natural  Ingredl-
enU";
  (B) "Among the least toxic chemi-
cals known"
   name ana address  of producer.
registrant, or  person for whom pro-
duced. An unqualified name and ad-
dress given on the label shall be con-
sidered as the name and address of the
producer. If the registrant's name ap-
pears on the label and the registrant Is
not the producer, or If the name of the
person  for whom the  pesticide  was
produced appears on the label. It mint
be  qualified by appropriate wording
such as "Packed for • • V ••Dblrlbul-
ed by • • V or "Sold by	to show
that the name Is not that of the pro-
ducer,
  (d) Hft weight or memturr of ron-
tentt. (I) The net weight or measure
of content shall be exclusive of wrap-
pers or other materials  and shall be
the average content unless explicitly
stated as a minimum quantity.
  (2)  If the pesticide Is  a liquid, the
net  content statement  shall  he  In
terms of HquM measure at 6ft' P (TOT)
and shall be expressed In conventional
American units of fluid ounces, pints.
quarts, and gallons.
  (.1) If the pesticide Is solid or semlso-
lid. viscous or  pressurized, or Is  a mix-
ture of liquid and solid, the nrl con-
tent statement  shall be In  trrms  of
weight   expressed   as   avolrdiipnl*  I
pounds and ounces.                  [j
  (4)  In all cases, net content shall be  (
stated In terms of the largest suitable
units. I.e., "I pound 10 ounces"  rather
than "20 ounces."
  (5) In addition to the required units
specified, net  content  may be ex-
pressed In metric units.
  (0) Variation  above minimum con-
tent or  around an average Is prrmlssl-
ble only to the extent that It rrprr-
sents deviation unavoidable In good
manufacturing   practice.   Variation
below a stated minimum Is not permit-
ted. In no case shall the average con-
tent of the packages  In a shipment fall
below the stated average content.
  (e) Product  registration  number.
The registration number assigned  to
the pesticide  product at the lime  of
registration shall appear on the Ishrl.
preceded by the phrase "EPA  flcgls-
tratlon No.." or the phrase "EPA flrg.
No." The registration number shall or
set In type of a sire and style similar to
other print  on that  part of  the labrl
on which It appears and shall run par-
                                      28

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I U2.M

allel to It The registration  number
and  the  required  Identifying  phrase
•hall not appear m such a manner •»
to suggest or  Imply ictommendatlen
or endorsement of the product by the
Agency.
  (f) Producing estoMlshmenc* regit-
tration number. The producing estab-
lishment registration number  preced-
ed by the  phrase "EPA Est". of the
final establishment at which the prod-
uct was produced may appear In any
suitable location on the label or Imme-
diate container. It must appear on the
wrapper  or outside  container of the
package If the EPA establishment reg-
totratlon  number  on the  Immediate
container  cannot  be  clearly   read
through such wrapper or container.
  (f) Ingrfdlmt «tof*ment-O) Gener-
al. The label of each pesticide product
mwt bear a statement which contain*
the name and percentage by weight of
each active Ingredient,  the total per-
centage by weight of all Inert Ingredi-
ent*: and If the pesticide contains ar-
nenk In any form, a statement of the
 percentage* of total and water-soluble
 arsenic  calculated  as  elemental ar-
 senic. The active Ingredient*  must be
 designated by the term "active Ingredi-
 ents" and the Inert Ingredient* by the
 term "Inert Ingredient*." or the singu-
 lar  forms of these terms when appro-
 priate. Both  term* shall be In the
 same type size, be aligned to the same
 margin and be equally prominent The
 statement "Inert Ingredient*, none" to
 not required  for pesticide* which con-
 tain 100  percent active  Ingredient*.
 Unless the Ingredient statement to a
 complete analysis of the pesticide, the
 term "analysis" shall not be used as a
 heading lor the Ingredient statement
   (2) Position of ingredient itatemtnL
  (I)  The  Ingredient statement to nor-
  mally required on the front panel  of
  the label. If  there  to an outside con-
  tainer or wrapper through which the
  Ingredient statement cannot be clearly
  read, the Ingredient statement must
  atoo appear on such outside container
  or  wrapper. If the she or form of the
  package  makes  It  Impracticable  to
  place the Ingredient statement on the
  front  panel  of the label, permission
  may be  granted for  the  Ingredient
  statement to appear etoewhere.
  mi*

  (ID The teat of the mgredVnl state-
ment must  run parallel wHh other
text on the panel on which H appears.
and  must be clearly distinguishable
from  and must not be placed In the
body of other tent.
  (3)  Name*  to be tuerf t« ingredient
statement The name used lor each In-
gredient  shall   be   the   accepted
common name. If there to  one. fol-
lownl by  the chemical name.  The
common name may be used atone only
If It to well known. If no common name
has  been  established,  the  chemical
name alone shall be used. In now**
will the  use of a trademark or propri-
etary name be permitted unleas *uch
name has been accepted as a common
name by the Administrator under the
authority of Section 2S(eX«>.
  <«) Statement*  of percentages. The
percentages  of  Ingredient* •hall be
•Uted In terms  of wetghHo-welght
The sum of percentages of the active
and the Inert Ingredients shall be 100.
 percentages shall not be expressed by
 a range of values such as "22-2S%." If
 the uses of  the pesticide produetare
 expressed as weight of active Ingredi-
 ent per unit area, a statement of the
 weight  ol active  Ingredient per unit
 volume  of  the pesticide formulation
 shall also  appear m the  Ingredient
 statement
   (5) *cc«r«c» of state*1 percent****
 The percentages given shall be as pre-
 cise  as possible reflecting good manu-
 facturing practice. If there may be un-
 avoidable variation between manufac-
 turing  batches,  the  value  slated for
 each active Ingredient shall be the
 lowest percentage which may be pres-

   (0) Deterioration.  Pesticides  which
 change In chemical composition sig-
  nificantly must meet the following la-
  beling requirements:
   (I) In cases where It to determined
  that a  pesticide formulation changes
  chemical  composition significantly.
  the product must bear the following
  statement m a prominent position on
  the label:  "Hot  for sale or use after
  I date)."                     .. ...
   (II) The product must meet all label
  claims  up to the expiration time Indi-
  cated on the label.
    (7) Inert ingredient*. The Adminis-
  trator  may require the name  of any
                        I frotsctUm Aasaicy
                            5 16? 10
Inert IngredlenUs) to be listed In the
Ingredient statement If he determine*
that  such  IngredtenUs)  may  pose a
hazard to man or the environment
  (h)  Wanting*  end precautionary
statement*.  Required  warnings  and
precautionary statements concerning
the  general  areas  of  lexicological
hazard  Including hazard to children.
environmental hazard, and physical or
chemical hazard fall Into two  group*;
those required on the front panel of
the  labeling and thane which may
appear  elsewhere.  Specific  rrquiv-i:
ments concerning content placement.
type state, and prominence are  given
  (I) Rewind, front panel statements.
With  the  exception  of  the  cl>li,;
hazard warning statement the text re -
qulred on the front panel of the label
t» determined by the Toxlrlly  Cnlcico
ry of the pesticide. The category h a*
signed on the  barfs  of the  hliclie*l
hazard shown by any of the Indicator*
m the table below.
  (I) Human hazard lipnoJ toor*1— ToxMtf Cateponr IV. All pesti-
cide products meeting  the criteria of
Toxlclty Category IV shall  bear on the
front panel the signal word "Caution."
  (E) Vie  of liffnol word*.  Use of any
signal wonMs) associated with a higher
Toxlclty Category  to  not permitted
except when the Agency determine*
that such labeling to necessary to pre-
vent unreasonable adverse effect* on
man or the environment In no  ca*e
shall more  than one  human hazard
signal word appear on the front panel
of a label.
  (II) Child hazard warning. Every pes-
ticide product label shall bear on the
front panel the statement "keep out of
reach  oJ children."  Or.iy  In rsisjf.
where the likelihood of contact with
children during  distribution, market
Ing. storage or use to demonstrated liy
the applicant to be extremely remote.
or If the nature of the pesticide I* such
that It to approved for use on Infant*
or small children, may the Administra-
tor  waive thb requirement
  (III)  Statement o/ practical  treat
menf—
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M "See statement  of  practical treat-
ment on back panel"  appears  on the
front panel near the  word  "Poison"
and the skull and crossbones.
  (B) Other  (oxJctt* cofepoHet. The
statement of practical treatment Is not
required on the front  panel except as
described In paragraph (hXlXlllXA) of
this  section. The applicant may. how-
ever. Include such a front panel state-
ment at  his option.  Statements of
practical treatment are. however, re-
quired  elsewhere  on  the  label In
accord  with  paragraph  If a pesticide Intended  for out-
  door use contains an active Ingredient
  with a mammalian acute oral LD- of
  (B) If a pesticide. Intended  lor out-
door use contains an active Innrcdlent
with a fish acute LG» of I ppm or Ims,
the statement "This Pesticide Is Toxic
to Fish" Is required.
  (C) If a pesticide Intended  for out-
door use contains an active Ingredient
with an avlan acute oral LD. of KM)
mg/kg or less, or a subacule  dietary
LCM of 500 ppm or less, the statement
"This Pesticide Is Toxic to Wildlife" Is
required.
  
                                          to to>n|Mrcta^v* ibvM I.W F
                                   Cni<«m» uratar pmw« OB not w* o» Mom now hmi w
                                    Aw* Do ml pixclno 01 >«J»«n
                                          M «ho»« IW F may OHM* l»i>««no
                                                                                 Mxn* IW r ontf ml o*M IW r .
                                                                                no CotmuMnw

                                                                            *! cvwwn^f •MivmMii ItcNp twvf wntn %•, npuHni. •nn
                                                                             I  mrtao*
                                                                             1 rinnmiWi KM* fwff ftvii rxol *n« opm •••»•
                                                                             I OB no! IKO «r Mm C>M> two) or opm ••«•
          (I)  rXrrcHon* for t/»e-(l) Oenerof
         rr4«irement>—  Detailed direc-
                                      tions for use may be omitted from la-
                                      beling of pesticides which are Intended
                                      for use only by manufacturers of prod
                                      uct* other than pesticide produrU In
                                      their regular manufacturing  processes.
                                      provided that:
                                                                                      —3
                                                                                      Ul
                                                                                       I

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{ 147.10

  (1) The label clearly shows thai the
product  to Intended  for  use  only In
manufacturing processes and specifies
the type<«) of producU Involved.
  (2)  Adequate Information such as
technical data sheeU or bulletins,  to
available to  the trade specifying the
type  of  product  Involved and  Its
proper use In manufacturing process-

  13) The product will not come Into
the hands of the general public except
after Incorporation Into finished prod-
ucU: and
  («)  The Administrator determines
that such directions are not necessary
to  prevent unreasonable adverse ef-
fect* on man or the environment.
   Detailed directions for use may
be omitted from the labellnc o(, !*•«•
clde producU for which sale to limited
to physicians, veterinarians, or drug-
gist*, provided that:
   U> The label clearly state* thai the
 product to for use only by physicians
 or veterinarians;
   («  The  Administrator  determines
 that such directions are  not necessary
 to prevent  unreasonable adverse  ef-
 fects on man or the environment: and
   13) The product to also a drug and
 regulated under the provisions  of the
 Federal Pood. Drug and Cosmetic Act.
    Detailed directions for  use may
 be omitted from the labeling  of pesti-
 cide products which are Intended  for
 use only by formulators In preparing
 pesticides for sale to the public, pro-
 vided that:
   (J)  There  to  Information readily
 available to the formulators on the
 composition, toxlclty, methods  of use.
 applicable restrictions or limitations.
 and effectiveness of the product for
  pesticide purposes;
   (*) The label clearly states that the
  product Is  Intended  for use only In
  manufacturing, formulating, mixing.
  or repacking for use as a pesticide and
  specifies the typeis) of  pesticide prod-
  ucU Involved;
    (J) The product as finally  manufac-
  tured,  formulated,  mixed, or  repack-
  aged to registered; and
    (¥)  The  Administrator  determines
  that such directions are not  necessary
  >_ .....ii.ni. unreasonable adverse  el-
                                              40
                                                                                                      •itlwl Fr*t«tcM*n Af «my
                                                                                                              5U7.1I
  (1) Content* of Wrectloiu /or Vte.
The directions for use shall Include
the following, under the headings  Di-
rections for Use":
  (I) The statement of use classifica-
tion as prescribed In IM.IWJ) Immedl-
•tely under  the heading  "Directions
for Use."                       .  .
  (M)  Immediately below the  state-
ment of use  classification. the state-
ment "It to a violation of Federal law
to use this product In a manner Incon-
sistent with Its labeling."
  (Ill) The slt« of application ap-
 paratus or equipment required.
   The frequency and timing of ap-
 plications necessary to obtain effective
 result* without causing  unreasonable
 adverse effects on the environment.
   Specific limitations on reentry
 to areas where the pesticide has been
 applied, meeting the  requirement*
 concerning  reentry   provided  by 40
 CFR Part 170.
   (lx> Specific  directions concerning
 the storage and disposal of the pesti-
 cide and Its container, meeting the re-
 quirements of 40 CFR Part 165. These
 Instructions  shall  be  grouped  and
 appear under the heading "Storage
 and Disposal." This heading must be
 set In type of the same minimum  S!MS
  as required for the child hazard warn-
  ing  For restricted use pesticides, a
  statement  that  the  pesticide  may  be
  applied under the direct supervision of
  * certified  applicator who to not phys-
  -   •-    ---- « -• •»-- -i»» nt •nnllratlon
but   nonetheless   available  to  the
person applying the  pesticide, unless
the Agency has determined that the
pesticide may only be applied  under
the direct supervision of a certified ap-
plicator who to physically present.
  (F)   Other  pertinent  Information
which the  Administrator  determines
to be necessary for the protection of
man and the environment.
   Statement of  Vie Classification.
By October 22. 197*. all oestlrlde prod
nets must bear on their labels a state-
ment  of use classification as described
In paragraphs (JX I) and (2) of this sec-
tion. Any pesticide product for which
some uses are classified for general IMC
and others  for restricted use shall be
separately  labeled according to the la-
beling standards set forth In this sub-
section, and shall be marketed us sepa-
rate products with different registra-
tion numbers, one bearing directions
only for general use(s) and the other
bearing directions for restricted usrts)
except that. If a product has both re-
stricted uscXs) and general usets). both
of these uses may appear on a product
labeled  for  restricted use. Such prod-
ucU shall be subject to the provisions
of 1l«2 KXJX2).
  (I) Oenrrol Ute Classification. Pesti-
cide producU bearing  directions for
usc(s) classified general shall be  la-
beled  with the exact words "General
Clarification" Immediately below the
heading "Directions for Use." And ref-
erence to  the general  classification
that suggrsU or Implies that the gen-
eral utility of the pesticide extends
beyond  those purposes and uses con-
tained In the Directions for Usq will be
considered  a false or misleading state-
ment  under the statutory definitions
of mlsbrandlng.
  (2)  Restricted  Uif Classification.
Pesticide  producU bearing direction
for use  classified  restricted  shall
bear statements of  restricted use clas-
sification  on the  front panel  as de-
scribed below:
  (I) Front  panel if a foment of restrict-
ed use classification.  At the top of
the front panel of the label, set In type
of I he same minimum slr.es as required
for human  hazard signal  words (see
table In I 16J IO(hXlMlv)). and appear-
ing with sufficient prominence relative
to other text and graphic material on
 the front panel to make It unlikely to
 be overlooked under customary rondl-
 lions of purchase and use. the  state-
 ment "Restricted Use Peitllrlile" shall
 appear.
   (B) Directly below this statement on
 the front panel, a summary statement
 of the terms of restriction Imposed as
 a  precondition to reglsl ration  shall
 appear. If use Is restricted to ecrHMed
 applicators,  the following statement Is
 required: "For retail sale  to and use
 only by Certified Applicators or per-
 sons under thrlr direct supervision nnd
 only for those uses covered by the Or-
 lifted  Applicator's certlflratlon."  If.
, however, other regulatory  reslrlel.lons
 are Imposed,  the Administrator will
 define the appropriate wording for the
 terms of restriction by regulal Inn.
   (k) Advertising, f Reserved I
140 FR MISS. July 3. I»7B; 40 FR
AII*. I. i«»; 40 rn SSMI. AW*, it. ir?». «
amriMfeil at 43 PR 97SS. Frb ». IW7S)

• If Z.11  CriUrla for rfrtrrmlni
         •M« aawror »ff«H-U.

  (a)V7rtf«-Ha /or f**N«inc«> of Nnti/r of
lnte.n\.to  Deny  Registration,  (jdncrl
Registration, or  to HoM a HeitriiiQ •
(I) rre.s\mptton. (I) A rebutta/ile pre
sumpllorKshall arise thai a/ntlrc  of
Intent to oeny regtolrallon nnrsnanl to
section 3(c\9> of Ihe Acl.yh notice  of
Intent to cancel registration pursuant
to section WtoXl) of Otc  Art.  or a
notice of  Intent to hohf a hearing  to
determine  whether  Vnc registration
should be  canceled
proprlate. shall
 termination by lhe
 the pesticide mee
 the criteria for
 graph (aX3) of )hls
 determination
 shall Issue
    r denied, as  up-
    urd, upon a  de-
   dmlnlstralor Iliat
     exceeds any of
    t forth In para
     ion. Upon such
the   Admlnlstrator
 by ceVlflcd  mall to
 the applicant or registrant, as the rase
 may  be. stating thai the  itopllcant or
 registrant/has  the  opportunity  to
 submit evidence  In rrbiiUnV of such
 presumption In accordance wVh para-
 graph ifcX4) of this section. Th\ appli-
 cant  or registrant shall have forty five
 (46) inays from the dale such noftlrr Is
 senlr  to submll evidence In rebullaJ of
 In/ presumption;  provided.  howeVr,
 tWmt  for good cause shown the Ailin)
 Hrator may grant an additional slxf)
                                          en
                                           I

-------
Criteria
                       -77-

                   PHYS/CHEM-1

            PHYSICAL/CHEMICAL HAZARDS

                              Required Label Statement
I.  Pressurized Containers
    A.
Flashpoint at or below
20°F; or if there is a
flashback at any valve
opening.
    B.
Flashpoint above 20°F
and not over 80°F; or
if the flame extension
is more than 18 inches
long at a distance of
6 inches from the
valve opening.

All Other Pressurized
Containers
II.   Non-Pressurized Containers

    A.   Flashpoint at or below
        20°F.
    B.   Flashpoint above 20°F
        and not over 808F.

    C.   Flashpoint over 80°F
        and not over 150°F.

    D.   Flashpoint above
        150°F.
Extremely flammable.
Contents under pressure.
Keep away from fire, sparks,
and heated surfaces.  Do not
puncture or incinerate
container.  Exposure to
temperatures above 130°F
may cause bursting.

Flammable.  Contents under
pressure.  Keep away from
heat, sparks, and flame.  Do
not puncture or incinerate
container.  Exposure to
temperatures above 130°F
may cause bursting.

Contents under pressure.
Do not use or store near
heat or open flame.  Do not
puncture or incinerate
container.  Exposure to
temperatures above 130°F
may cause bursting.
                              Extremely flammable.  Keep
                              away from fire, sparks, and
                              heated surfaces.

                              Flammable.  Keep away from
                              heat and open flame.

                              Do not use or store near
                              heat and open flame.

                              None required.

-------
                             -78-

                            STOR-1

             STORAGE INSTRUCTIONS FOR PESTICIDES

Heading;

All products are required to bear specific label instructions
about storage and disposal.  Storage and disposal instructions
must be grouped together in the directions for use portion of
the label under the heading STORAGE AND DISPOSAL.  Products
intended solely for domestic use need not include the heading
"STORAGE AND DISPOSAL."

Storage Instructions;

All product labels* are required to have appropriate storage
instructions.  Specific storage instructions are not prescribed.
Each registrant must develop his own storage instructions,
considering, when applicable, the following factors:

1.  Conditions of storage that might alter the composition or
    usefulness of the pesticide.  Examples could be temperature
    extremes, excessive moisture or humidity, heat, sunlight,
    friction, or contaminating substances or media.

2.  Physical requirements of storage which might adversely
    affect the container of the product and its ability to
    continue to function properly.  Requirements might include
    positioning of the container in storage, storage or damage
    due to stacking, penetration of moisture, and ability to
    withstand shock or friction.

3.  Specifications for handling the pesticide container,
    including movement of container within the storage area,
    proper opening and closing procedures (particularly for
    opened containers), and measures to minimize exposure
    while opening or closing container.

4.  Instructions on what to do if the container is damaged in
    any way, or if the pesticide is leaking or has been
    spilled, and precautions to minimize exposure  if damage  occurs

5.  General precautions concerning locked storage, storage in
    original container only, and separation of pesticides
    during storage to prevent cross-contamination  of other
    pesticides, fertilizer,  food, and feed.

6.  General storage instructions for household products should
    emphasize storage in original container and placement in
    locked storage areas.

-------
                             -79-

                          CONT/DIS-1
               CONTAINER DISPOSAL INSTRUCTIONS

    The label of each product must bear container disposal
instructions appropriate to the type of container.

    1.  Domestic use products must bear one of the following
container disposal statements:
Container Type
                Statement
Non-aerosol products
(bottles, cans, iars)
Non-aerosol products
(bags)
Aerosol products "
Do not reuse container (bottle, can, jar).
Rinse thoroughly before discarding in trash.
Do not reuse bag. Discard bag in trash.
Replace cap and discard containers in
trash. Do not incinerate or puncture.
    2.  All other products must bear container disposal instructions,
based on container type, listed below:
 Container Type
                 Statement
 Metal
 containers
 (non-aerosol)
Triple rinse (or equivalent).  Then offer
for recycling or reconditioning, or puncture
and dispose of in a sanitary landfill, or by
other procedures approved by state and local
authorities.
 Plastic containers
Triple rinse (or equivalent).   Then offer
for recycling or reconditioning, or puncture
and dispose of in a sanitary landfill, or
incineration, or, if allowed by state and
local authorities, by burning.  If burned,
stay out of smoke.	_____
 Glass containers
Triple rinse (or equivalent).  Then dispose
of in a sanitary landfill or by other
approved state and local procedures.	
 Fiber drums
 with liners
Completely empty liner by shaking and
tapping sides and bottom to loosen clinging
particles.  Empty residue into application  |
equipment.  Then dispose of liner in a
sanitary landfill or by incineration if
allowed by state and local authorities.
If drum is contaminated and cannot be
reused.!, dispose of in the same manner.	
 Paper and
 plastic bags
Completely empty bag into application
equipment.  Then dispose of empty bag in
a sanitary landfill or by incineration,
or,  if allowed by State and local
authorities, by burning.  If burned, stay
out of smoke.
 Compressed gas
 cylinders 	
Return empty cylinder for reuse (or
similar wording)	
  i/ Manufacturer may replace this phrase with one indicating
     whether and how fiber drum may be reused.

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                                     -80-

                                  PEST/DIS-1

                       PESTICIDE DISPOSAL INSTRUCTIONS

The label of all products,  except those intended solely for domestic
use, must bear explicit instructions about pesticide disposal.   The
statements listed below contain the exact wording that must appear on
the label of these products:

1.  The labels of all products,  except domestic use, must contain the
    statement, "Do not contaminate water, food, or feed by storage or disp

2.  Except those products intended solely for domestic use, the labels
    of all products that contain active ingredients that are Acute Hazardo
    Wastes or are assigned to Toxicity Category I on the basis  of oral or
    dermal toxicity, or,Toxicity Category I or II on the basis  of acute
    inhalation toxicity must bear the following pesticide disposal stateme

    "Pesticide wastes are acutely hazardous.  Improper disposal of
     excess pesticide, spray mixture, or rinsate is a violation of Federal
     Law.  If these wastes cannot be disposed of by use according to
     label instructions, contact your State Pesticide or Environmental
     Control Agency, or the Hazardous Waste representative at the nearest
     EPA Regional Office for guidance."

3.  The labels of all products,  except those intended for domestic use,
    containing active or inert ingredients that are Toxic Hazardous Wastes
    or meet any of the criteria in 40 CFR 261, Subpart C for a hazardous
    waste must bear the following pesticide disposal statement:

    "Pesticide wastes are toxic.  Improper disposal of excess pesticide,
     spray mixture, or rinsate is a violation of Federal Law.  If these
     wastes cannot be disposed of by use according to label instructions,
     contact your State Pesticide or Environmental Control Agency, or the
     Hazardous Waste representative at the nearest EPA Regional Office
     for guidance."

4.  Labels for all other products, except those intended for domestic
    use, must bear the following pesticide disposal statement:

    "Wastes resulting from the use of this product may be disposed of on
     site or at an approved waste disposal facility."

5.  Products intended for domestic use only must bear the following
    disposal statement:  "Securely wrap original container in several lay«
    of newspaper and discard in trash."

-------
    -81-
PEST/DIS-2
          POOS
          P070
          POU4
          POOS
          P006
          POOS
          P010
          P011
          P012
          P021
          P022
          P024
          P030

          P031
          P037
          P039

          P040
107-13-1
116-06-3
309-00-2
107-18-6
1302-45-0
504-24-5
7778-39-4
1303-28-2
1327-53-3
592-01-8
75-15-0
106-47-8
506-77-4
60-57-1
298-04-4

297-97-2
     PESTICIDE ACTIVE INGREDIENTS THAT ARE ACUTE HAZARDOUS WASTES

 I.   PESTICIDES ON  THE "E"  LIST  (with*RCRA I  and CAS »
         140  CFR 261.33(e)J

 Acrolein
 Aldicarb
 Aldrin
 Allyl alcohol
 Aluminum  phosphide        \
 4-Aminopyridine  (Avitrol)
 Arsenic acid  *
 Arsenic pentoxide
 Arsenic trioxide
 Calcium cyanide
 Carbon disulfide
 p-Chloroaniline
 Cyanides  (soluble  cyanide salts
    not otherwise specified)
 Cyanogen  chloride
 Dieldrin
 O,0-Diethyl  S-[2-ethylthio)ethyl]
    phosphorodithioate (disulfoton)
 O,O-Diethyl  0-pyrazinyl
    phosphorothioate    (Zinophos*)
 Dimethoate     .
 O,0-Dimethyl O^p-nitrophenyl
    phosphorothioate  (methyl parathion)
 4,6-Dinitro-o-cresol  and salts
 4,6-Dinitro-o-cyclohexylphenol
 Dinoseb
 Endosulfan
 Endothall
 Endrin
 Famphur
 Fluoroacetamide
 Heptachlor
 Hexachlorohexahydro-exo,exo-
    dimethanonaphthalene (Isodrin)
 Hydrocyanic  acid
 Methorny1
 alpha-Naphthylthiourea (ANTU)
 Nicotine and  salts
 OctamethyIpy rophosphoramide
    (OMPA, schradan)
 Parathion
 Phenylmercuric acetate (PMA)
 Phorate
 Potassium cyanide
 Propargyl alcohol
 Sodium azide
Sodium cyanide
 Sodium fluoroacetate
P044
P071
P047
P034
P020
P050
P088
P051
P097
P057
P059
P069
P063
P066
P072
P075
P085
P089
P092
P094
P098
P102
P105
P106
P058
60-51-5
298-00-0
534-52-1
131-89-5
88-85-7
115-29-7
129-67-9
72-20-8
52-85-7
640-19-7
76-48-8
465-73-6
74-90-8
16752-77-5
86-88-41
54-11-5
152-16-9
56-38-2
62-38-4
298-02-2
151-50-8
107-19-7
26628-22-8
143-33-9
62-74-8

-------
                                -82-
                             PEST/DIS-3
Strychnine and salts       <- «          P108     57-24-9
                             4 ~                 60-41-3
0,0,0,0-Tetraethyl                     P109     3689-24-5
   dithiopyrophosphate (sulfotepp)
Tetraethyl pyrophosphate               Pill     107-49-3
Thallium sulfate                       P115     7446-18-6
Thiofanox                              P045     39196-18-4
Toxaphene                              P123     8001-35-2
Warfarin'(>0.3%)   \                   P001     81-81-2
Zinc phosphide (>10%)                  P122     1314-84-7
50 ACTIVES

-------
                   -83-
III.  BIBLIOGRAPHY APPENDICES

-------
                               -84-

                            BIBGUIDE-1


                GUIDE TO USE OF THIS BIBLIOGRAPHY
1.   CONTENT OF BIBLIOGRAPHY.   This bibliography contains
    citations of all studies  considered relevant by EPA in
    arriving at the positions and conclusions stated elsewhere
    in the Standard.  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, will be  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 attempted also 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 at any time 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 a further explana-
    tion.  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 identifier 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
    standards of the American National Standards Institute
    (ANSI), expanded to provide for certain special needs.

-------
                           -85-

                        BIBGUIDE-2

a.  Author.  Whenever the Agency could confidently identify
    one, 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 author.   As a last resort, the Agency has shown
    the first submitter as author.

b.  Document Date.  When the date appears as four digits
    with no question marks, the Agency took it directly
    from the document.  When a four-digit date is followed
    by a question mark, the bibliographer deduced the
    date from evidence in the document.  When the date
    appears as (19??), the Agency was unable to determine
    or estimate the date of the document.

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

d.  Trailing Parentheses.  For studies submitted to the
    Agency in the past, the trailing parentheses include
    (in addition to any self-explanatory text) the fol-
    lowing 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,
         following the phrase "submitted by."  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," standing for "Company Data
         Library."  This accession number is in turn
         followed by an alphabetic suffix which shows the
         relative position of the study within the volume.
         For example,  within accession number 123456, the
         first study would be 123456-A; the second, 123456-
         B; the 26th,  123456-Z; and the 27th, 123456-AA.

-------
                               -86-
                   OFFICE OF PESTICIDE PROGRAMS
                REGISTRATION STANDARD BIBLIOGRAPHY
   Citations Considered to be Part of the Data Base Supporting
            Registrations Under the Sulfotepp Standard
MRID        CITATION

00104043    Allen, R. (1975) Toxicity of Dieldrin to Bluegill
               Sunfish and Rainbow Trout.  (Unpublished study
               received July 16, 1975 under 9386-10; submitted
               by Vinings Chemical Company, Atlanta, Georgia;
               CDL: 223094-B)

-------
                     -87-
IV. FORMS APPENDICES

-------
                                                                -88-         OMB  Approval   No.  2070-0057
                                                                	Expires   11/30/89
                   FIFHA SECTION 3(C)(2)(B) SUMMARY SHEET
E
                                                                                            •A REGISTRATION NO.
  PRODUCT NAME
  APPLICANT'S NAME
                                                                                          DATE GUIDANCE DOCUMENT ISSUED
   With respect to the requirement to submit "generic" data imposed by the FIFHA section 3(C)(2)(B) notice contained in th- referenced
   Guidance Document. I am responding in the following manner



      D 1.  I will submit data fa a timely manner to satisfy the following requirements. If the test procedures I will use deviate from (or are not
            specified in) the Registration Guidelines or the Protocols contained in the Reports of Expert Groups to the Chemicals Group. OECO
            Chemicals Testing Programme. I enclose the protocols that I will use:
      D2.  I have entered into an agreement with one or more other registrants under FIFRA section 3(C)(2)(B)
-------
                                              OMB Approval No. 2070-0057
                                       -89-   Expiration Date 11/30/89
                         GENERIC DATA EXEMPTION STATEMENT

EPA Product Registration Number: 	

Registrant's Name and Address:   	
    As an authorized representative of the registrant of the product identified
above, I certify that:

     (1)  I have read and am familiar with the terms of the Notice from EPA dated
              concerning a requirement for submission of generic data on the
active ingredient 	named under FIFRA Section 3(c)(2)(B).

     (2)  My firm requests that EPA not suspend the registration of our product,
despite our lack of intent to submit the generic data in question, on the grounds
that the product contains the active ingredient solely as the result of the
incorporation into the product of another product which contains that active
ingredient, which is registered under FIFRA Section 3, and which is purchased by
us  from another producer.

     (3)  An accurate Confidental Statement of Formula(CSF) for the above-identified
product is attached to this statement.  That formula statement indicates, by
company name, registration number, and product name, the source of the subject
active ingredient in my firm's product, or

The CSF dated	on file with EPA is complete, current and accurate and
contains the information requested on the current CSF Form No. 8570-4.  The
registered source(s) of the above named active ingredient in my product(s) is/are
	 and their registration number(s) is/are 	  .

     (4) My firm will apply for an amendment to the registration prior to changing
the source of the active ingredient in our product to one that is not registered
and purchased.

     (5)  I understand, and agree on behalf of my firm, that if at any time any
portion of this Statement is no longer true, or if my firm fails to comply with
the undertakings made in this Statement, my firm's product's registration may be
suspended under FIFRA Section 3(c)(2)(B).

     (6)  I further understand that if my firm is granted a generic data exemption
for the product, my firm relies on the efforts of other persons to provide the
Agency with the required generic data.  If the registrant(s) who have committed
to  generate and submit the required data fail to take appropriate steps to meet
requirements or are no longer in compliance with this Notice's data requirements,
the Agency will consider that both they and my firm are not in compliance and
will normally initiate proceedings to suspend the registrations of my firm's
product(s) and their product(s), unless my firm commits to submit and submits
the required data in the specified time frame.  I understand that, in such cases,
the Agency generally will not grant a time extension for submitting the data.

Registrant's authorized representative: ^	
                                              (Signature)

Dated:
                                                (Typed)


EPA Form 8580-3

-------
US Environmental Protection Agency Registration Standard for
Washington. DC 20460
AFPA Product Specific
^ DataReoort
Registration
Guideline No.
Sec. 158. Sub
Product
Chemistry
61-1
61-2
61-3
62-1
62-2
62-3
63-2
63-3
63-4
63-5
63-6
63-7
63-8
63-9
63-10
63-11
63-12
63-13
63-14
63-15
63-16
63-17
63-18
63-19
63-20
63-21
Sec. 158. 340
Toxicology
81-1
81-2
81-3
81-4
81-5
81-6
Name of Test
>art C

Identity of Ingredients
Statement of .composition
Discussion of formation of ingredients
Preliminary analysis
Certification of limits
Analytical methods for enforcement limits
Color
Physical state
Odor
Melting point
Boiling point
Density, bulk-density, or specific gravity
Solubility
Vapor pressure
Dissociation constant
Octanol/water partition coefficient
PH
Stability
Oxidizing/reducing reaction
Flammability
Explodability
Storage stability
Viscosity
Miscibility
Corrosion Characteristics
Dielectric breakdown voltage
of Subpart D
Acute oral toxicity, rat
Acute dermal toxicity, rabbit
Acute inhalation toxicity, rat
Primary eye irritation, rabbit
Primary dermal irritation
Dermal sensitization
Testing not
required for my
product listed
above
(Check below)


































EPA Registration Number
1 am complying with
Data Requirements by -
Citing MR ID No.


































Submitting Data
(Attached)
(Check below)





»




























Form Approved
OMB #2070-0057
Expires 11-30-89
(For EPA Use
Only)
Accession
numbers
assigned















-


















Certification
I certify that the statements I have made on this form and all attachments thereto 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.
Typed Name and Title
Signature
Date
EPA Form 8580-4 (Rev. 5-88) Previous edition is obsolete.

-------
                                                               -91-
                                                                                  OMB   Approval  No.
                                                                                  Expires  11/30/89
                        2070-0057
    fTo qufltfy. certify ALL four /tarns)
                                             CERTIFICATION Of ATTEMPT TO ENTER
                                        INTO AN AGREEMENT WITH OTHER REGISTRANTS
                                                  FOR DEVELOPMENT OF DATA
    1. I am duly authorized to represent the following firm(s) who are subject to the require-
      ments of a Notice under FIFRA Section 3(c)(2)(8) contained in a Guidance Document
      to submit data concerning the active ingredient:
                                                                                        GUIDANCE DOCUMENT OATC
ACTIVE INGREDIENT
                                        NAMC OF FIRM
                                                                                                 EPA COMPANY NUMBER
   (This firm or group of firms is referred to below as "my firm".)
   2. My firm H willing to develop and submit the data as required by that Notice, if necessary. However, my firm would prefer to enter
     into an agreement with one or more other registrants to develop jointly, or to share in the cost of developing, the following required
     items or data:
  3.  My firm has offered in writing to enter into such an agreement. Copies of the off«rs ut attached. That offer was irrevocable and included in offer to b«
     bound by an arbitration decision under FIFRA Section 3(c)(2)(8)(iii) if final agreement on all terms could not be reached otherwise. This offer wis m*d«
     to tne following firmd) on the following date(s):
                                      NAME OF FIRM
                                                                                                   DATE OF OFFER
 However, none of those firm(tl accepted my offer.
 4. My firm requests that EPA not suspend the registration(sj of my firm's product(s). if any of the firms named in paragraph (3) above
   have agreed to submit the data listed in paragraph (2) above in accordance with the Notice. I understand EPA will promptly inform
   me whether my firm must submit data to avoid suspension of its registration^) under FIFRA Section 3(c)(2)(B). (This statement
   does not apply to applicant* for new products.)  I give EPA permission to disclose this statement upon request.
 TVPCO NAME
EPA Form 8SOO-8
                                                      SIGNATURE
                                                                                                         OATE

-------