xvEPA
United States
Environmental Protection
Agency
Pesticides And
Toxic Substances
(7508W)
738-F-91-100
September 1991
R.E.D. FACTS
Pesticide
Reregistration
Carbon
All pesticides sold or used in the United States must be registered by
EPA, based on scientific studies showing that they can be used without
posing unreasonable risks to people or the environment. Because of
advances in scientific knowledge, the law requires that pesticides which
were first registered years ago be reregistered to ensure that they meet
today's more stringent standards.
In evaluating pesticides for reregistration, EPA obtains and reviews a
complete set of studies from pesticide producers, showing the human health
and environmental effects of each pesticide. The Agency imposes any
regulatory controls that are needed to effectively manage each pesticide's
risks. EPA then reregisters pesticides that can be used without posing
undue hazards to human health or the environment.
When a pesticide is eligible for reregistration, EPA announces this and
explains why in a Reregistration Eligibility Document, or RED. This fact
sheet summarizes the information about carbon presented in the RED for
carbon and carbon dioxide.
Use Profile
Carbon is formulated with several other pesticide active ingredients
(sodium and potassium nitrates and sulfur), and used as a rodenticide,
predacide and insecticide in six pyrotechnic fumigant gas cartridge products.
When the cartridges are ignited and placed in pest burrows, they produce
carbon monoxide and other gases which asphyxiate target pests, including
pocket gophers, moles, ground squirrels, prairie dogs, rats, skunks,
woodchucks, red foxes, coyotes, and ground wasps.
Carbon is naturally-occurring and ubiquitous in the environment. In
addition to the pesticide uses described here, it has many other non-
pesticidal uses.
Carbon is a nonmetallic element found in all organic and many
inorganic compounds. Pure carbon exists in three forms: as a black
powder, as graphite, and as diamond crystals. Carbon is the principal
component in charcoal and coal.
Regulatory
The first pyrotechnic cartridge pesticide product containing the active
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History
Human Health
Assessment
ingredient carbon was registered in 1948. Several reported injuries,
including one fatality attributed to gross misuse, prompted EPA to propose
cancellation of these products in 1982. However, the registrants kept these
products on the market by submitting upgraded labeling and data on the
burning characteristics of cartridges. Since then, four more injuries have
been reported to EPA, all involving misfiring of ignited cartridges.
Through the Data Call-In Notice issued in conjunction with this RED, the
Agency is imposing several data requirements to obtain more information on
quality control and product safety.
Toxicity
The toxicology studies on carbon available in the open literature are
adequate to assess the risk to humans; all of EPA's usual toxicology data
requirements have been waived. Carbon is a natural component of all
organic chemicals and all living organisms. One form of carbon, activated
charcoal, is given orally as an adsorbent for treatment of accidental drug
poisoning.
The real, functional, pesticidally active ingredients of the pyrotechnic
fumigants are the pyrolysis products of the carbon and other components.
The toxic properties of carbon bear no relationship to the toxicity of these
pyrolysis products.
Applicator Exposure
Based upon reported incidents, the primary human hazard posed by
use of the pyrotechnic fumigant products is dermal burns to applicators,
which occur when flares ignite prematurely. Applicators also may be
exposed to the gaseous fumes from these products if they do not cover
burrows properly after inserting lit cartridges, or remain too close to
covered burrows. However, if used properly, these products should pose
very low inhalation and dermal exposure hazards to people.
Human Risk Assessment
The toxicity data usually required for pesticide registration are not
required for this use of carbon. A basic component of all living organisms
and all organic chemicals, carbon is truly ubiquitous. Human exposure to
carbon through use of the pyrotechnic fumigants is expected to be
negligible.
Environmental
Assessment
EPA is not requiring any environmental fate or ecological effects data
on carbon. All the usual data requirements have been waived.
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Environmental Fate
The physical and chemical properties of carbon, a naturally occurring
substance, are well understood. Burning carbon with sodium and potassium
nitrates results in simple organic and inorganic compounds, mostly in the
form of gases, which diffuse through burrow openings or into the soil.
Exposure of the environment is limited and localized, however, so
environmental fate studies are not required.
Ecological Effects
Since the gas cartridges are applied below the surface of the ground,
avian and aquatic species are not exposed. However, any organism in a
properly treated burrow is likely to be killed. Endangered species that
inhabit burrows are at potential risk. As a result of several earlier
consultations with the Fish and Wildlife Service, EPA already requires
endangered species labeling to protect the six species identified as being at
risk. Another ongoing consultation may bring about the need for further
label revisions in 1992.
Additional Data The generic data base supporting reregistration of carbon is
determined to be complete for reregistration. However, submission of
product-specific acute toxicity, efficacy and product chemistry data are
being required by the Data Call-in Notice issued in conjunction with this
RED.
Product Labeling
Changes Required
Regulatory
Conclusion
For More
Information
The labels of end-use products containing carbon must comply with
EPA's current pesticide labeling requirements. In addition, the Agency
soon will issue detailed guidance on labeling for gas cartridge products,
which will address concerns regarding applicator safety and protection of
non-target and endangered organisms.
• All registered pesticide products containing carbon can be used
without causing unreasonable adverse effects in people or the
environment. Therefore, they are eligible for reregistration.
• The six end-use pyrotechnic fumigant products containing
carbon will be reregistered once product-specific data and
revised labeling are received and accepted by EPA, and
once any data and labeling needed for the other two active
ingredients in these products (potassium and sodium nitrate and
sulfur) also are received and accepted.
EPA is requesting public comments on the Reregistration Eligibility
Document for carbon and carbon dioxide during a 60-day time period, as
announced in a Notice of Availability published in the Federal Register. To
obtain a copy of the RED or to submit written comments, please contact the
Public Response and Program Resources Branch, Field Operations Division
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(7506C), Office of Pesticide Programs (OPP), US EPA, Washington, DC
20460, telephone 703-557-2805.
In the future, the RED will be available from the National Technical
Information Service (NTIS), 5285 Port Royal Road, Springfield, VA
22161, telephone 703-487-4650.
For more information about carbon, or about EPA's pesticide
reregistration program, please contact the Special Review and Reregistration
Division (7508W), OPP, US EPA, Washington, D.C. 20460, telephone
703-308-8000. For information about the reregistration of individual
carbon products, please contact the Registration Division (7505C), OPP, US
EPA, Washington, DC 20460, telephone 703-557-5447.
For information about the health effects of pesticides, or for assistance
in recognizing and managing pesticide poisoning symptoms, please contact
the National Pesticides Telecommunications Network (NPTN). Call toll-
free 1-800-858-7378, 24 hours a day, seven days a week, or Fax your
inquiry to 806-743-3094.
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