United States
                 Environmental Protection
                 Agency	
                      Prevention, Pesticides
                      And Toxic Substances
                      (7508W)	
EPA-738-F-96-008
January 1997
                  R.E.D.   FACTS
     Pesticide
Reregistration
p-Chloro-m-cresol
     All pesticides sold or distributed in the United States must be
registered by EPA, based on scientific studies showing that they can be
used without posing unreasonable risks to people or the environment.
Because of advances in scientific knowledge, the law requires that
pesticides which were first registered before November 1, 1984, be
reregistered to ensure that they meet today's more stringent standards.
     In evaluating pesticides for reregi strati on, EPA obtains and reviews a
complete set of studies from pesticide producers, describing the human
health and environmental effects of each pesticide. The Agency develops
any mitigation measures or regulatory controls needed to effectively reduce
each pesticide's risks. EPA then reregisters pesticides that can be used
without posing unreasonable risks to human health or the environment.
     When a pesticide is eligible for reregi strati on, EPA explains the basis
for its decision in a Reregi strati on Eligibility Decision (RED) document.
This fact sheet summarizes the information in the RED document for
reregi strati on case 3046, p-chloro-m-cresol.
   Use Profile
   Regulatory
        History
     p-Chloro-m-cresol is a microbicide used to control slime-forming
bacteria and fungi that might develop in industrial adhesives, industrial
coatings, emulsions, leather processing liquors, metal cutting fluids, paints
(in can), specialty industrial products, oil drilling muds/packer fluids, and
wet-end adhesives/industrial processing chemicals.  Products are applied by
open pouring.
     Use practice limitations prohibit discharging effluent containing p-
chloro-m-cresol to bodies of water without an NPDES license and/or into
treatment plants without first notifying the sewage treatment plant authority.

     p-Chloro-m-cresol was first registered as a pesticide in the U.S. in
1968. Currently, three p-chloro-m-cresol products are registered including
two manufacturing-use products and one end-use product. Through the
Antimicrobial Data Call-In (DCI) of 1987 and the Reregi strati on Phase IV
DCI of 1991, EPA required additional data to complete p-chloro-m-cresol's
data base for reregi strati on. The U.S. Food and  Drug Administration has
established tolerances or maximum residue levels for p-chloro-m-cresol in

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                    food grade adhesives and paper coatings which may contact foods.  These
                    tolerances are specified in the 21 CFR.
Human  Health
  Assessment
Toxicity
     In most acute and subchronic toxicology studies using laboratory
animals, p-chloro-m-cresol has been shown to be slightly toxic to
practically non-toxic. It is, however, very highly toxic (Toxicity Category
I) when applied to the skin or the eye. It is not a skin sensitizer, and
inhalation exposure is not expected since p-chloro-m-cresol is a chunky
solid and respirable particles are unlikely. In a developmental toxicology
study using rats decreases of body weight and food efficiency, increased
water intake, decreased urinary protein, and changes in organ weights were
noted at the highest dose level. In a chronic feeding study using rats
decreases in body weight and food efficiency, increased water intake,
decreased urinary protein, and changes in organ weights were noted at the
lowest dose. Carcinogenicity and mutagenicity studies were negative for
effects. The Agency thus classified p-chloro-m-cresol as a Group D
carcinogen, that is, a chemical with insufficient or no information to be
classified.
                    Dietary  Exposure
                         There is no direct application of p-chloro-m-cresol to food; however,
                    indirect exposure may occur from its use in paper coatings and adhesives.
                    Tolerances are established by FDA for these indirect food additive
                    exposures.
                    Occupational and Residential Exposure
                         Based on current use patterns, handlers (mixers, loaders, and
                    applicators) may be exposed to p-chloro-m-cresol during and after use of
                    products containing this active ingredient. Occupational exposures may
                    occur to workers from open-pouring the solid end-use product.
                    Assessments for short- and intermediate-term and chronic exposures are
                    appropriate because of the toxicological endpoints from the developmental
                    toxicology and chronic  feeding studies.
                          EPA's exposure assessment included dermal and inhalation
                    exposures for handlers applying product used in industrial preservatives and
                    metal-working/cutting fluids.  The Agency also considered exposures to
                    other workers in industrial settings and people in residential settings who
                    handle products treated with p-chloro-m-cresol. The Agency believes that,
                    with the exception of workers using metal-working/cutting fluids and
                    paints, these secondary  exposures are not greater than the handler exposures
                    described  above.

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                          Exposures are likely to workers in industrial settings and to people in
                     residential settings where p-chloro-m-cresol-treated products have been
                     applied, for example, exposures from working in a recently-painted room.
                     These post-application exposures are expected to be of short duration and
                     result from products with diluted concentrations (0.02 to 5.0%) of p-chloro-
                     m-cresol.  These exposures are expected to be less than those described for
                     the handler of the concentrated p-chloro-m-cresol end-use product.
                          For estimating short- and intermediate-term risks to workers, EPA
                     compared the no observed effect level from the developmental study to the
                     worker exposure estimates. The margins of exposures (MOEs) for short
                     and intermediate term exposures to workers, except painters, are not of
                     concern to the Agency.  The calculated MOEs are well above 100, a level
                     the Agency generally considers adequate protection.
                          Chronic risk was estimated for the handler applying the end-use
                     product as a general  preservative. This MOE was greater than 300 and
                     therefore is not of concern to the Agency.
                          Risks to commercial painters from short- and intermediate-term and
                     chronic exposures were of concern to the Agency. To minimize these risks,
                     the registrant has agreed to reduce the concentration of p-chloro-m-cresol in
                     finished paints to 0.05%.
                          The Agency has concerns for the metal-working/cutting fluid worker,
                     and has made this document available to OSHA for their use in regulating
                     these workers.

                     Human  Risk Assessment
                          p-Chloro-m-cresol is very highly toxic to the skin and eyes (Toxicity
                     Category I), but otherwise is of low acute toxicity. No dietary exposure is
                     expected  as a result of its pesticide uses. Food additive uses, in paper
                     coatings and adhesives, are regulated by FDA.
                          To minimize risks to commercial painters,  the registrant has agreed to
                     reduce the concentration of p-chloro-m-cresol in finished paints to 0.05%.
                     Personal protective equipment (PPE), including  chemical-resistant gloves
                     and protective eyewear, is required for occupational users.

Environmental   Ecological Effects
   AsSGSSrnGnt        p-Chloro-m-cresol is slightly toxic to avian species in both acute oral
                     and subacute dietary toxicity studies. It is highly toxic to freshwater fish
                     and moderately toxic to freshwater invertebrates in acute studies.

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                        Environmental Fate
                             The currently registered uses of p-chloro-m-cresol are not likely to
                        result in significant environmental exposures. Therefore, the Agency
                        required only limited data to describe dissipation in the environment.
   Risk Mitigation
Ecological Effects Risk Assessment
     Current uses of p-chloro-m-cresol are expected to result in minimal
exposure or risk to the environment, and effluent from these uses is
regulated under the NPDES program.  Therefore, no environmental risk
mitigation measures are imposed at this time.

     EPA is requiring the following risk mitigation measure to lessen the
risks posed by p-chloro-m-cresol:
•    Reduction of maximum application concentration of p-chloro-m-
     cresol in paints to 0.05%.
•    Personal protective equipment (PPE) for handlers as described below.
  Additional  Data        All p-chloro-m-cresol end-use products must comply with EPA's
          Required   current pesticide product labeling requirements and with product-specific
                        data requirements including product chemistry and acute toxicity studies,
                        and revised Confidential Statements of Formula for product reregi strati on.
Product  Labeling
          Changes
          Required
     The Agency is requiring revised labeling for reregi strati on of end-use
products:
•    Registrants must specify on labeling the complete directions for use
     for each use pattern:  site of application, type of application, timing of
     application, equipment used for application, and the rate of
     application.
•    The maximum application concentration of p-chloro-m-cresol in
     paints must be revised to 0.05%.
•    The following statement is required to appear in the Environmental
     Hazards section of the label, in accordance with 40 CFR 156.10:
     "This pesticide is highly toxic to fish."
•    To clarify the intent of the oil recovery drilling mud/packer fluid use
     (as an aquatic or terrestrial site), the following statement must be
     added to the labels for terrestrial oil drilling muds and packer fluids:
     "For use in (terrestrial or aquatic) wells only."
PPE Requirements for Pesticide Handlers
     For sole active-ingredient end-use products that contain p-chloro-m-
cresol, the product labeling must be revised to adopt the handler personal
protective equipment requirements set forth in this section.  Any conflicting
PPE requirements on the current labeling must be removed.

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                      For multiple active-ingredient end-use products that contain p-chloro-
                 m-cresol, the handler PPE requirements set forth in this section must be
                 compared to the requirements on the current labeling and the more
                 protective must be retained. For guidance see PR Notice 93-7. Although
                 this PR Notice addresses products within the scope of the Worker
                 Protection Standard (WPS), that is products that are generally for
                 agricultural use, certain parts of the guidance in this PR Notice are
                 applicable to all pesticide products.

                      The Agency is establishing the following active ingredient-based
                 minimum (baseline) PPE  requirements for p-chloro-m-cresol end-use
                 products that are intended primarily for occupational use:

                 Applicators and other handlers must wear:
                      •   long-sleeved shirt, long pants,
                      •   socks and shoes, and
                      •   chemical-resistant gloves

                      Any necessary PPE for each p-chloro-m-cresol occupational end-use
                 product will be established on the basis of the end-use product's acute
                 toxicity category. The PPE that would be established on the basis of the
                 acute toxicity category of the end-use product must be compared to the
                 active ingredient-based minimum (baseline) PPE specified above, and the
                 more protective PPE must be placed on the product labeling.

                 •    The Agency is requiring the following labeling statements to be
                      located on all end-use products containing p-chloro-m-cresol:

                           "Do not apply this product in a way that will contact workers or
                           other persons."

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

                      The use of currently registered products containing p-chloro-m-cresol,
Conclusion   used m accordance with required labeling, will not pose unreasonable risks
                 or adverse effects to humans or the environment.  Therefore, all uses of
                 these products are eligible for reregi strati on.

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                      p-Chloro-m-cresol products will be reregistered once the required
                 product-specific data, revised Confidential Statements of Formula, and
                 revised labeling are received and accepted by EPA.

   For More        EPA is requesting public comments  on the Reregi strati on Eligibility
Information   Decision (RED) document for p-chloro-m-cresol 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 document or to submit written
                 comments, please contact the Pesticide Docket, Public Response and
                 Program Resources Branch, Field Operations Division (7506C),  Office of
                 Pesticide Programs (OPP), US EPA, Washington, DC 20460, telephone
                 703-305-5805.
                      Electronic copies of the RED and this fact sheet can be downloaded
                 from the Pesticide  Special Review and Reregi strati on Information System
                 at 703-308-7224.  They also are available on the Internet on EPA's gopher
                 server, GOPHER.EPA.GOV, or using ftp on FTP.EPA.GOV, or using
                 WWW (World Wide Web) on WWW.EPA.GOV.
                      Printed copies of the RED and fact sheet can be obtained from EPA's
                 National Center for Environmental Publications and Information
                 (EPA/NCEPI), PO  Box 42419, Cincinnati, OH  45242-0419, telephone
                 513-489-8190, fax 513-489-8695.
                      Following the comment period, the p-chloro-m-cresol RED document
                 also will be available from the National Technical Information Service
                 (NTIS), 5285 Port Royal Road, Springfield, VA 22161, telephone 703-487-
                 4650.
                      For more information about EPA's pesticide reregi strati on program,
                 the p-chloro-m-cresol RED, or reregi strati on of individual products
                 containing  p-chloro-m-cresol, please contact the Special Review and
                 Reregi strati on Division (7508W), OPP, US EPA, Washington, DC 20460,
                 telephone 703-308-8000.
                      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, between 9:30 am and 7:30 pm Eastern Standard
                 Time, Monday through Friday.

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