United States
Environmental Protection
Agency
Prevention, Pesticides
And Toxic Substances
(7508W)
EPA-738-F-96-014
August 1996
R.E.D. FACTS
Pesticide
Reregistration
Coumaphos
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 Reregistration Eligibility Decision (RED) document.
This fact sheet summarizes the information in the RED document for
reregi strati on case 0018, coumaphos.
Use Profile
Regulatory
History
Coumaphos is an insecticide/acaricide used to control anthropod pests
on beef cattle, dairy cows, goats, horses, sheep, and swine. Formulations
include wettable powders, emulsifiable liquids, flowable, ready-to-use, and
dusts. Coumaphos is applied by aerosol can, dust bags, hand-held dusters,
dip vats, high and low pressure hand-held sprayers, backrubber oiler,
mechanical dusters, shaker can, and squeeze applicator. The technical
registrant has stated they intend to voluntarily cancel the pour-on
formulation and prohibit application of dust formulations using mechanical
dusters, which are believed to result in higher applicator exposure.
The U.S. Department of Agriculture (USDA) uses coumaphos in dip
vats, located principally along the U.S./Mexico border, to control ticks that
carry equine and bovine piroplasmosis (Texas Cattle Fever). Livestock,
almost exclusively cattle, are immersed in coumaphos solution by entering
and swimming through these large (4000 gallon) trench shaped vats.
Coumaphos was first registered as a pesticide in the U.S. in 1958.
EPA issued a Registration Standard for Coumaphos in 1989 (PB90-
122243). In 1989 and 1992 Data Call-in's (DCI) were issued requiring
additional residue chemistry, environmental fate, and toxicological data.
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Currently, 26 coumaphos products are registered. Two of these
products are classified for restricted use due to acute oral toxicity, i.e., the
11.6% EC and the 42% flowable concentrate. Coumaphos is used as a
direct animal treatment only; no food, feed, ornamental, or homeowner uses
are registered. The predominant use is on beef and dairy cattle with much
smaller amounts being used on swine, goats, and horses. All uses of
coumaphos are considered to be outside the scope of the Worker Protection
Standard for Agricultural Pesticides (WPS).
The Agency currently is requiring additional handler
(mixer/loader/applicator) exposure data for coumaphos before it can make a
regulatory decision on non-USDA uses of coumaphos. Only the USDA
Animal and Plant Health Inspection Service (APHIS) uses of coumaphos
for control of ticks, where there is significant economic benefit and
employees are in a cholinesterase monitoring program, are considered
eligible for reregi strati on at this time. The Agency is deferring a regulatory
decision on all uses other than the USDA uses until handler (mixer/loader/
applicator) exposure data for coumaphos is submitted and reviewed.
Human Health
Assessment
Toxicity
In studies using laboratory animals, coumaphos generally has been
shown to be of moderate to high acute toxicity. It is highly toxic by the oral
and inhalation routes of exposure (Toxicity Category I and II, respectively)
and moderately acutely toxic by the dermal route of exposure (Toxicity
Category III). Technical coumaphos causes only mild eye and dermal
irritation (Toxicity Category III and IV, respectively), and is nonsensitizing.
Coumaphos does not produce organophosphate-type delayed neurotoxicity,
based on acute neurotoxicity testing in hens.
In vitro microbial studies for gene mutation and DNA damage
coumaphos did not cause a mutagenic response. Coumaphos is classified
as a Group E carcinogen, indicating that it is non-carcinogenic to humans.
Studies utilizing rats and rabbits indicate that coumaphos does not cause
reproductive effects. Cholinesterase inhibition (plasma and erythrocyte) is
the primary target of coumaphos. Metabolism studies in rats indicate that
coumaphos is excreted (76-96%) in the urine and feces within seven days
of exposure.
Dietary Exposure
People may be exposed to residues of coumaphos through the diet.
Tolerances or maximum residue limits have been established for residues of
coumaphos in the meat, fat, and meat by-products of cattle, goats, hogs,
horses, poultry and sheep; and in milk fat and eggs (40 CFR 180.189). The
registrant has voluntarily cancelled use on poultry and therefore poultry
tolerances, including eggs, will be revoked as part of reregi strati on.
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The Anticipated Residue Concentration (ARC) for the overall U.S.
population represents 39% of the Reference Dose (RfD), an amount
believed not to cause adverse effects if consumed daily over a 70-year
lifetime. The most highly exposed subgroup, non-nursing infants - less
than one year old, has an ARC which represents 73% of the RfD. This
fraction of the allowable RfD is considered to be an acceptable dietary
exposure risk.
The Agency also conducted an acute dietary exposure analysis
because coumaphos causes neurotoxic effects, i.e., cholinesterase
inhibition. Margins of exposure (MOEs), which show how closely
estimated exposure comes to a dose of concern, were calculated for the
overall U.S. population and several population subgroups including infants
(<1 year old) and children (1-6 years old). The Agency conducted this
analysis using high end or maximum anticipated residues, i.e., a
conservative approach very protective of human health. Infants (<1 year)
and children (1-6 years old) are the only subgroups whose exposure may be
of concern. However, these risk values represent an unrealistic worst case
situation. The Agency used many conservative assumptions in calculating
these risks, including: 1) the dose required to produce red blood cell
cholinesterase inhibition at three weeks, which would overestimate the dose
that would be expected to produce ChE from a single exposure; 2)
maximum residue levels present on all registered food items, with no
dilution or degradation of residues occurring during preparation or
processing of food; 3) all food items were treated with coumaphos. EPA
believes it is unlikely that infants and children will be exposed to
coumaphos-treated commodities at levels that will result in unacceptable
acute dietary risk.
Occupational and Residential Exposure
The primary route of handler exposure to coumaphos is dermal. The
Agency's primary concern is acute dermal exposure during mixing, loading, and
application of coumaphos, especially in the livestock dip-vat and handheld
sprayer uses where large amounts of coumaphos are handled. Livestock dip-vats
can hold up to 4000-4500 gallons and require the mixing/loading of up to 95 Ibs
of active ingredient (ai) to achieve the proper concentration when filling the dip
vats from empty. During hand-held sprayer treatment of cattle, up to 40.0 Ibs of
active ingredient may be handled, an amount sufficient to treat 1000 cattle at
maximum application rate of 4.0 Ibs ai/100 gallons.
Chemical-specific exposure data for coumaphos were never required to
support coumaphos registration or reregi strati on and are not available. EPA
assessed mixer/loader/applicator exposure and risk to coumaphos using the
toxicological endpoint dermal toxicity and surrogate exposure data in the
Pesticide Handlers Exposure Database (PHED), making assumptions that
coumaphos handlers wear certain personal protective equipment and that they
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treat a certain number of livestock, etc. Exposure estimates were conducted for
the two coumaphos use scenarios believed to result in the greatest exposure: dip-
vat use and handheld sprayers.
MOE estimates for these two scenarios indicate a potential for unacceptable
handler exposure and/or risk from coumaphos as currently registered. The
Agency conducted exposure assessments for the dip vat and handheld sprayer
uses, making assumptions intended to reflect handling "typical" and "maximum"
amounts of coumaphos, i.e., pounds of active ingredient per day. For example,
an exposure assessment must make assumptions concerning the number of
livestock that an individual will typically treat per day as well as a likely
maximum. The Agency assumed a "typical" treatment of 100
cattle/day/individual and a "worst case" of 1,000 cattle/day/individual. MOEs for
the handheld spraying scenario were 82 and 8.2, respectively assuming the lowest
registered application rate, while MOEs are eight times lower (10.1 & 1.1) at the
maximum application rate of 4.0 Ibs ai/100 gallons.
MOEs for the dip-vat use were calculated to range from 9 to 36 assuming a
1000 or 250 gallon "topping off" or recharging of the dip vats after animals
moving through the vats have depleted the liquid level. Lower MOEs result
when the greater amount of active ingredient is handled, in this case sufficient
active ingredient to recharge 1000 gallons of dip vat solution.
Uncertainties in the existing handler exposure databases (PHED) do not
allow the Agency to determine, with confidence, the exact MOEs for these
exposure scenarios. However, the Agency finds that MOEs for large dip vat and
hand-held sprayer treatment of large herds are very low. Therefore, the Agency
is requiring closed systems for the mixing/loading of coumaphos products used in
dip vats and/or hand-held sprayers, i.e., water-soluble bags for the WP
formulation. The registrant must determine an appropriate system to reduce
handler exposure during mixing/loading for the flowable and emulsifiable
concentrate formulations. The registrant may choose to reduce handler exposure
during mixing/loading with water soluble "gel packs", "no glug" containers, or
any other equivalent system approved by the Agency. The registrant must
propose a system within eight months and submit handler exposure studies within
one year to document handler exposure and confirm that improved
packaging/closed systems now results in acceptable MOEs.
The Agency has made a regulatory decision concerning the USDA uses of
coumaphos because of the very significant economic benefits and the fact that
USDA has a program in place to monitor the cholinesterase levels of the handlers
(mixer/loader/applicators) involved. In the USDA program livestock are treated
with coumaphos to control ticks (Boophilus spp., Dermacentor nitems, and exotic
ticks) and prevent outbreaks of Texas Cattle Fever. USDA use of coumaphos
accounts for almost half of the U.S. usage. USDA has estimated the economic
importance of this use to be between $1-5 billion dollars. The Agency has
decided, based on the economic importance of coumaphos to the Texas Cattle
Fever Eradication Program, that all USDA uses are considered eligible for
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reregi strati on, provided the required exposure studies are submitted and
mixer/loader exposure reduction measures discussed above are put into place.
When the chemical-specific exposure data required by this RED are received and
reviewed, the Agency will make a regulatory decision regarding the reregi strati on
eligibility of the non-USD A uses of coumaphos.
The Agency believes that there is minimal potential exposure to persons
entering treated sites after application because most coumaphos is applied
directly to livestock. Post-application exposures do not appear to pose an
unreasonable risk to persons contacting treated animals, as long as contact is not
permitted immediately after application.
Human Risk Assessment
Based on the available toxicity studies, EPA has determined that
coumaphos presents a potential acute health hazard. It is of high acute toxicity
and is a cholinesterase inhibitor. Coumaphos has been classified as non-
carcinogenic to humans. Dietary exposure to coumaphos residues occurs from
meat and milk at very low levels. There are no agricultural uses of coumaphos
registered, and the dietary risk, both chronic and acute, appears to be acceptable.
Of greater concern is the risk posed to coumaphos handlers, particularly
mixers/loaders/applicators, who are exposed during treatment of livestock.
Margins of Exposure (MOEs) are less than 100 (the margin believed to be
sufficiently protective) for applicators for several exposure scenarios. Exposure
and risk to workers will be mitigated by the use of PPE and closed systems, as
required by this RED. Non-USDA uses of coumaphos are not eligible for
reregi strati on until mixer/loader exposure reduction measures are implemented,
and handler exposure studies are submitted and evaluated.
EPA is employing a number of risk mitigation measures to protect
coumaphos handlers. For example, the Agency is requiring "baseline" personal
protective equipment (PPE) and closed systems for the mixing/loading of
products used in dip vats and/or hand-held sprayers, i.e., water soluble bags for
the WP formulation. The registrant must determine an appropriate system to
reduce handler exposure, e.g. water soluble "gel packs", "no glug" containers, or
any other equivalent system approved by EPA. The Agency is requiring
exposure data to be submitted, within one year after the RED was received, using
the proposed closed system.
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Environmental Environmental Fate
AsSGSSITIGnt The various degradation, metabolism, mobility, dissipation and
ground water studies, although found mostly to be supplemental, do
nevertheless support a qualitative characterization of the environmental fate
of coumaphos. Coumaphos is persistent, with the exception that aqueous
photolysis is rapid with a half-life of 33 hours. The half-life is much greater
than 30 days for hydrolysis; much greater than a year for aerobic soil
metabolism; and ca. 118 to 185 days for field dissipation. Coumaphos also
appears to be immobile, with Kd values ranging from 61 to 298 for parent
and from 91 to 161 for the degradate chlorferon.
The major coumaphos degradates identified under aerobic conditions
were chlorferon, which reached a maximum of 6.2% of the organosoluble
radioactivity recovered at six months, and 6-hydroxyl-3-methylbenzofuran,
the oxygen analog, which comprised a maximum of 0.2% of recovered
radioactivity at six months. In column leaching studies, chlorferon and 6-
hydroxyl-3-methylbenzofuran comprised 3.1% and 0.2%, respectively, in
the top six inches of the sandy loam soil column. Similar results were
obtained using sand, silt loam, and silty-clay loam soil columns.
Coumaphos was applied to soil at 300 mg/1 with and without
incorporation to evaluate leaching potential. The soil was not sampled at
sufficient depth to define the extent of leaching; however, samples taken 6
to 12 inches deep contained coumaphos at concentrations of 25 to 375 mg/1
32 weeks after treatment and at 5 to 69 mg/1 52 weeks after treatment. A
special retrospective field dissipation study was conducted to characterize
the depth of leaching in disposal pits and walkways of coumaphos
treatment dip vats. On-site disposal of spent coumaphos in unlined pits was
found to result in leaching of coumaphos, chlorferon and potasan to the
subsurface (72 inches in the study), and could result in ground water
contamination in areas of shallow ground water. These compounds may
reach ground water, although there was insufficient depth of soil sampling
conducted in the study to determine if coumaphos and/or its metabolites
could have reached the deep wells that were tested during the study.
Results of the special field dissipation study support the finding that
coumaphos is persistent; however coumaphos moved to greater depths than
expected based on it's Kd values. The apparently higher mobility in the
special dissipation study could have resulted from the high concentration of
spent coumaphos in soil evaporation pits.
Several hundred thousand head of cattle are dipped every year in one
of the ca. 45 USDA vats mainly located along the U.S.-Mexican border.
The vats contain approximately 15,000 liters of coumaphos solution with
the active ingredient concentration of 0.15-0.31%. Vats are emptied,
cleaned, and recharged every 6 to 12 months, depending on usage,
generating approximately one million liters of coumaphos waste per year.
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Typically the vats are recharged when the sediment level reaches 10% of
the total volume.
Since 1986 the Agricultural Research Service (ARS) of the USD A
has been conducting research concerning the degradation of coumaphos in
cattle-dipping vats. Dip vat solutions of coumaphos can be inactivated
through the metabolic action of bacteria that are naturally present in some
dip vats. The USD A/ARS has been experimenting with microbial
degradation of the spent vat solutions and has now successfully
demonstrated a detoxification procedure. This procedure has been tested in
laboratory scale equipment and most recently in the field in a full scale
(4,000 gallon tank) pilot test conducted in Texas. Two spent vat solutions
were bioremediated to ca. 10 ppm. To date field testing of this
bioremediation method indicates that coumaphos levels in the spent vat
solutions are reduced from ca. 1200-1300 ppm to 10 ppm in a few weeks.
The spent solution would then be put into lined evaporation pits or applied
to non-agricultural land. Currently, the untreated 1200-1300 ppm spent
solution is deposited in unlined evaporation ponds.
The Agency is requiring improvements in the disposal of coumaphos
spent dip-vat solution. The Agency is requiring labeling that requires the
use of this bioremediation procedure and/or the use of lined pits for disposal
of spent solution that has not been bioremediated or ultimate disposal of
bioremediated solution. The Agency is allowing local and/or State
Environmental Control Agencies the option to permit use of lined
evaporation ponds. The Agency believes that the lined evaporation pond
method of disposal is much less desirable than bioremediation and should
be permitted only in those instances when use of the bioremediation method
is not feasible. If permitted by local regulations, the lined evaporation pond
can be eliminated and the bioremediated spent solution (ca. 10 ppm
coumaphos) simply sprayed directly onto non-agricultural land in order for
further in-situ bioremediation to occur. This decision should be made by
the individual states involved who are most familiar with the soil types and
ground water situation in their area. In any case, the Agency endorses this
method of treatment. The Agency has concerns about leakage of spent dip
vat solution from lined evaporation ponds. Reducing the absolute amount
of active ingredient in the spent vat solution deposited in the evaporation
ponds greatly mitigates the Agency's concern with leakage. This procedure
appears to be relatively inexpensive and initial communication with
USD A/APHIS, the dip vat operators, indicates that this treatment of vat
solutions is being pursued.
The Agency considers the aerobic biodegradation of the spent dip vat
solution critical in preventing the downward and or lateral movement of
coumaphos and ultimately in preventing the contamination of groundwater.
Although it will result in increased cost, the use of bioremediation is
certainly much less expensive than any "clean-up" of ground water that
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may be necessary if even one evaporation pond were to leak. Because this
is new a procedure and will require capital upgrades (bioremediation tank
and/or lined pits) the Agency will phase in this disposal method revision
over a two year period from issuance of the RED. The Agency also
understands that technical assistance, e.g., answering questions concerning
construction of bioremediation tanks, will initially be provided by
USDA/ARS. The USDA/ARS will not operate bioremediation sites to treat
non-USDA spent dip vat solutions.
Ecological Effects
Coumaphos is highly to very highly acutely toxic to birds if
consumed, based on terrestrial vertebrate test data. Available
measurements of avian acute oral LD50, for technical grade coumaphos
(TGAI), ranged from 2.4 to 29.8 mg/kg based on bobwhite quail, mallard
duck and pheasant. Available measurements of the avian dietary LC50,
using TGAI coumaphos as the test material, ranged from 82.1 to 401.9
mg/kg based on tests including bobwhite quail, mallard duck, ring-necked
pheasant and Japanese quail. For terrestrial mammals, a wide range of LD50
values have been obtained based on testing using rats that indicate slight to
high toxicity on an acute oral basis: LD50 values were as low as 17 mg/kg
for the TGAI, and as low as 32 mg/kg for one end-use product.
Data for aquatic organisms indicate that coumaphos is moderately to
highly toxic to fish on an acute basis: LC50 measurements for coumaphos
TGAI ranged from 0.34 mg/kg for bluegill sunfish to 5.9 mg/kg for rainbow
trout. Coumaphos can be characterized as very highly toxic to aquatic
invertebrates on an acute basis: LC50 values for coumaphos TGAI ranged
from 0.074 //g/1 for Gammarus lacustris to 0.224 //g/1 for Gammarus
fasciatus.
Chronic toxicity data are available for aquatic animals. Data from a fish
early life stage study with coumaphos showed that for Rainbow trout, based
on the most sensitive parameters, length and weight, the NOEC, LOEC and
MATC are 11.7 //g/1, 24.6 //g/1 and 16.9 //g/1, respectively. Data from a
Daphnia magna life cycle chronic toxicity study with coumaphos showed
that based on the most sensitive parameter, survival, the NOEC, LOEC and
MATC are 33.7 ng/1, 75.8 ng/1 and 50.5 ng/1, respectively. (The
concentrations here represent average measured values.)
Data on marine and estuarine animals indicate that coumaphos is
highly toxic to marine and estuarine fish. The LC50 for sheepshead minnow
is 280 //g/1. Coumaphos is also highly toxic to marine and estuarine
mollusks on an acute basis. The LC50 measurements for marine and
estuarine mollusks ranged from 290 //g/1 to 880 //g/1 based on the oyster
Crassostrea virginica. Coumaphos is very highly toxic to marine
crustaceans on an acute basis. The available LC50 measurement was 2.0
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Ecological Effects Risk Assessment
EPA is concerned with the acute hazard of coumaphos to birds. Birds
could be exposed by ingestion of cattle hair, skin or debris or by secondary
exposure such as ingestion of other birds which consumed coumaphos
tainted materials. There is really no effective way to mitigate this risk short
of cancelling the use. In view of the high economic benefits of this
insecticides use (est. to be $1-5 billion by USD A) EPA believes that the
most appropriate means of dealing with this issue is a label advisory
indicating it's acute toxicity and potential exposure.
Technical coumaphos is moderately toxic to freshwater fish and very
highly toxic to aquatic invertebrates. There is a potential for exposure to
aquatic organisms resulting from washing-off of the material from the backs
of newly treated cattle that have entered a stream or pond.
While the potential for risk to aquatic invertebrates exists, it is
geographically limited to major cattle and dairy areas. EPA believes that
alerting cattlemen via label warnings is the most appropriate method to deal
with this concern. In addition, the EPA does not expect sensitive, relatively
undisturbed aquatic ecosystems to be closely associated with feedlots where
the heaviest use of coumaphos is expected to occur.
Risk Mitigation To lessen concerns with the handler risks, ground water
contamination, and danger to avian species and aquatic organisms posed by
coumaphos use, EPA is requiring the following risk mitigation measures:
o Due to concerns about the high acute toxicity of coumaphos, EPA is
establishing baseline personal protective equipment (PPE)
requirements for handlers of all end-use products.
o To further mitigate risks to handlers, EPA is requiring water soluble
packaging for powders and either water soluble "gel packs" or "no-
glug" containers (or other equivalent system approved by the Agency)
for flowable formulations.
o To minimize post-application exposure, EPA is requiring a label
advisory to avoid contact with treated livestock until they are dry.
o Disposal of spent vat solution in unlined evaporation pits is being
phasing out over a two year period. The new disposal method must
meet Local and/or State Environmental Control Agency requirements
for the geographical area where the dip vat is located. The Agency is
recommending that spent dip-vat solution be bioremediated in
accordance with a method developed by the USDA/ARS. The treated
solution can then be transferred to lined, shallow evaporation ponds
or applied to soil to encourage further degradation. Details can be
found in the coumaphos RED.
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Additional Data
Required
The hazard to aquatic invertebrates and birds cannot be eliminated;
however, it may be mitigated by label warnings.
The generic data base supporting the reregi strati on of coumaphos for the
above eligible uses, i.e. the USDA uses, has been reviewed and determined
to be substantially complete with the exception of occupational
(mixer/loader/applicator) exposure data. The following data are required
before the Agency can make a regulatory decision regarding reregi strati on
eligibility of non-USD A uses of coumaphos:
Worker exposure
Guideline 231:Estimation of Dermal Exposure at Outdoor Sites
o
o
Mixing/loading/application of dipping solutions for both the
liquid and wettable formulations (The Agency will use these
data to represent all mixing/loading operations, e.g., backrubber
and dust bag setup).
Mixing/loading/application of liquid and wettable powder
formulations from high and low-pressure handwand sprayers.
Application of ready-to-use, pour-on solutions.
Application with shaker cans, foam spray cans, and application
with mechanical dusters.
Guideline 232:Estimation of Inhalation Exposure at Outdoor Sites
o Testing is required for the same uses as cited under Guideline
231.
The following data are considered confirmatory:
Environmental Fate
Guideline 162-2: Anaerobic Soil Metabolism
The Agency also is requiring product-specific data including product
chemistry and acute toxicity studies, revised Confidential Statements of
Formula (CSFs), and revised labeling for reregi strati on.
Product Labeling All coumaphos end-use products must comply with EPA's current
Changes Required pesticide product labeling requirements and with the following personal
protective equipment requirements as outlined below. For a comprehensive
list of labeling requirements, please see the coumaphos RED document.
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EPA is establishing active-ingredient-based minimum (baseline)
engineering control requirements for liquid-concentrate and wettable-
powder formulations. EPA is also establishing active-ingredient-based
minimum (baseline) personal protective equipment requirements for all
handlers.
Ready-To-Use Products: EPA is establishing minimum (baseline) PPE for
all ready-to-use formulations of coumaphos as follows:
Applicators and other handlers must wear:
— long-sleeve shirt and long pants,
— chemical-resistant gloves, and
— shoes plus socks.
Wettable Powder Products: EPA is requiring that wettable powder
formulation be contained in water-soluble packets. In addition, EPA is
establishing minimum (baseline) PPE for wettable powder formulations as
follows:
"Handlers exposed to the concentrate, such as during a spill or equipment
break-down, and all handlers participating in dip-vat applications must
wear:
— long-sleeve shirt and long pants,
— chemical-resistant gloves,
— chemical-resistant footwear plus socks,
— chemical-resistant apron, and
— face shield or goggles.
"All other handlers must wear:
— long-sleeve shirt and long pants,
— chemical-resistant gloves, and
— chemical-resistant footwear plus socks."
"Water-soluble packets when used correctly qualify as a closed loading
system. Handlers handling this product while it is enclosed in intact water-
soluble packets are permitted to wear long-sleeved shirt, long pants,
chemical-resistant gloves, shoes plus socks, and a chemical-resistant apron.
However, such handlers must be provided a face shield or goggles and have
such PPE immediately available for use in a emergency, such as a spill or
equipment break-down."
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Emulsifiable Concentrate and Flowable Concentrate Products: EPA is
requiring that all liquid concentrate formulations be contained in "no-glug"
containers, water-soluble gel-packs, or other equivalent methods approved
by the Agency. In addition, EPA is establishing minimum (baseline) PPE
requirements for all liquid-concentrate formulations as follows:
"Mixers, loaders, and others exposed to the concentrate (such as during a
spill or equipment break-down) and all handlers participating in dip-vat
applications must wear:
— long-sleeve shirt and long pants,
— chemical-resistant gloves,
— chemical-resistant footwear plus socks,
— chemical-resistant apron, and
— face shield or goggles.
Regulatory
Conclusion
"All other handlers must wear:
— long-sleeve shirt and long pants,
— chemical-resistant gloves, and
— chemical-resistant footwear plus socks."
The USDA use of coumaphos in accordance with approved labeling
will not pose unreasonable risks or adverse effects to humans or the
environment provided exposure reduction measures during mixing loading
are implemented as discussed above. Therefore, these uses of coumaphos
are eligible for reregi strati on. The EPA is requiring water soluble
packaging for powders and either water soluble "gel packs" or "no-glug"
containers (or other equivalent system approved by the Agency) for
flowable formulations.
EPA does not have enough information at this time to make an
eligibility decision for non-USDA uses of coumaphos. The Agency is
requiring additional handler exposure data in order to develop a more
complete data base regarding these uses of coumaphos.
For More
Information
EPA is requesting public comments on the Reregi strati on Eligibility
Decision (RED) document for coumaphos 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
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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 coumaphos 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 coumaphos RED, or reregi strati on of individual products containing
coumaphos, 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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