United States         Office of Prevention, Pesticides  739-R-05-007
Environmental Protection     and Toxic Substances      September 2005
Agency            (751OC)


    Reregistration


    Eligibility Decision for


    1,2-Benzisothiazolin-3-one


    (BIT)

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           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                              WASHINGTON, D.C. 20460
                                                                    OFFICE OF
                                                           PREVENTION, PESTICIDES
                                                            AND TOXIC SUBSTANCES
CERTIFIED MAIL

Dear Registrant:

       This is to inform you that the Environmental Protection Agency (hereafter referred to as
EPA or the Agency) has completed its review of the available data and public comments
received related to the preliminary risk assessments for the antimicrobial l,2-benzisothiazolin-3-
one (hereafter referred to as BIT). The enclosed Reregistration Eligibility Decision (RED)
document was approved on September 29, 2005.  Public comments and additional data received
were considered in this decision.

       Based on its review, EPA is now publishing its Reregistration Eligibility Decision (RED)
and risk management decision for BIT and its associated human health and environmental risks.
A Notice of Availability will be published in the Federal Register announcing the publication of
the RED.

       The RED and supporting risk assessments for BIT are available to the public in EPA's
Pesticide Docket OPP-2005-0200 at: http://www.epa.gov/edocket.

       The BIT RED was developed through EPA's public participation process, published in
the Federal Register on July 20, 2005,  which provides opportunities for public involvement in
the Agency's pesticide tolerance reassessment and reregistration programs. Developed with
input from EPA's advisory committees and others, the public participation process encourages
robust public involvement starting early and continuing throughout the pesticide risk assessment
and risk mitigation decision making process. The public participation process encompasses full,
modified, and streamlined versions that enable the Agency to tailor the level of review to the
level of refinement of the risk assessments, as well as to the amount of use, risk, public concern,
and complexity associated with each pesticide.  Using the public participation process, EPA is
attaining its strong commitment to both involve the public and meet statutory deadlines.

       Please note that the BIT risk assessment and the attached RED document concern only
this particular pesticide. This RED presents the Agency's conclusions  on the dietary, drinking
water, occupational and ecological risks posed by exposure to BIT alone. This document also
contains both generic and product-specific data that the Agency intends to require in Data Call-
ins (DCIs). Note that DCIs, with all pertinent instructions, will be sent to registrants at a later
date. Additionally, for product-specific DCIs, the first set of required responses will be due 90

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days from the receipt of the DCI letter. The second set of required responses will be due eight
months from the receipt of the DCI letter.

       As part of the RED, the Agency has determined that BIT will be eligible for reregistration
provided that all the conditions identified in this document are satisfied, including
implementation of the risk mitigation measures outlined in Section IV of the document. Sections
IV and V of this RED document describe labeling amendments for end-use products and data
requirements necessary to implement these mitigation measures. Instructions for registrants on
submitting the revised labeling can be found in the set of instructions for product-specific data
that accompanies this document.

       Should a registrant fail to implement any of the risk mitigation measures outlined in this
document, the Agency will continue to have concerns about the risks posed by BIT.  Where the
Agency has identified any unreasonable adverse effect to human health and the environment, the
Agency may at any time initiate appropriate regulatory action to address this concern.  At that
time, any affected person(s) may challenge the Agency's action.

       If you have questions on this document or the label changes necessary for reregistration,
please contact the Chemical Review Manager, Rebecca M. Miller, at (703) 305-0012.
                                         Sincerely,
                                         Frank T. Sanders
                                         Director, Antimicrobials Division

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            REREGISTRATION ELIGIBILITY
                       DECISION
                           for
              l,2-Benzisothiazolin-3-one (BIT)
                          ListC
                       CASE 3026
                                      Approved By:
                                      Frank T. Sanders
                                      Director, Antimicrobials Division
Attachment

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Table of Contents

BIT Reregistration Team	    i D
Glossary of Terms and Abbreviations	    ii D
Executive Summary	   iv D

I. Introduction	    1 D
II. Chemical Overview	      3 D
      A. Regulatory History	      3 D
      B. Chemical Identification  	    4 D
      C. Use Profile	    5 D
III. Summary of BIT Risk Assessments	    6    D
      A. Human Health Risk Assessment	    6 D
             1. Toxicity of BIT	    6 D
             2. FQPA Safety	    9 D
             3. Population Adjusted Dose (PAD)	   10 D
                   a. Acute PAD	   10        D
                   b. Chronic PAD	     10        D
             4. Dietary Exposure Assumptions	   10 D
             5. Dietary (Food) Risk Assessment	   11 D
                   a. Acute and Chronic Dietary Risk	   11 D
                   b. Dietary Exposure for Inert Ingredient Uses	   12 D
                   c. Dietary Risk from Drinking Water	   15 D
             6. Residential Risk for Active Ingredient Uses	   15 D
                   a. Toxicity	   16 D
                   b. Residential Handler Scenarios	   17        D
                         i. Exposure Scenarios, Data and Assumptions	   17 D
                         ii. Residential Handler Risk Estimates	   18 D
                   c. Residential Post-Application Exposure	   19 D
                         i. Exposure Scenarios, Data and Assumptions	   19 D
                         ii. Residential Post-Application Risk Estimates	   19 D
             7. Residential Risk for Inert Ingredient Uses	   20 D
             8. Aggregate Risk	   22        D
                   a. Acute and Chronic Aggregate Risks	   22 D
                   b. Short- and Intermediate- Term Aggregates Exposures   D
                     and Risks	   23 D
             9. Occupational Risk	   26        D
                   a. Occupational Toxicity	   26 D
                   b. Occupational Handler Exposure	   27 D
                   c. Occupational Handler Risk Summary	   28 D
                   d. Occupational Post-Application Exposure	   29 D
      B. Environmental Risk Assessment	   30 D
             1. Environmental Fate and Transport	   30 D
             2. Ecological Risk	   30        D
             3. Listed Species Consideration	   32 D

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IV. Risk Management, Reregistration, and Tolerance Reassessment Decision...   34D
      A. Determination of Reregistration Eligibility	   34 D
      B. Public Comments and Responses	   34 D
      C. Regulatory Position	   35 D
             1. Food Quality Protection Act Findings	  35 D
                   a. "Risk Cup" Determination	  35       D
                   b. Determination of Safety to U.S. Population	  35 D
                   c. Determination of Safety to Infants and Children	   35 D
                   d. Cumulative Risks	  36 D
                   e. Endocrine Disrupter Effects	  36       D
             2. Tolerance Summary	   37       D
                   a. Tolerances Currently or Proposed to be Listed	  37 D
                   b. Codex Harmonization	   37       D
      D. Regulatory Rationale	  38 D
             1. Human Health Risk Management	   38 D
                   a. Dietary (Food) Risk Mitigation	   38 D
                   b. Drinking Water Risk Mitigation	  38 D
                   c. Residential Risk Mitigation	   38       D
                   d. Occupational Risk Mitigation	   39       D
                         i. Handler Exposure	  39 D
                         ii. Post-Application Risk Mitigation	   39       D
             2. Environmental Risk Management	   39 D
             3. Listed Species Considerations	   39 D
                   a. The Endangered Species Program	  39 D
                   b. General Risk Mitigation	   40       D

V. What Registrants Need to Do	   41 D
      A. Manufacturing Use Products	  43 D
             1. Additional Generic Data Requirements	   43 D
             2. Labeling for Technical and Manufacturing Use Products	   43D
      B. End-Use Products	   44 D
             1. Additional Product-Specific Data Requirements	   44 D
             2. Labeling for End-Use Products	  45 D

VI. Appendices	  46 D
      A. Table of Use Patterns for BIT	   47 D
      B. Table of Generic Data Requirements and Studies Used to Make theD
         Reregistration Decision	   62 D
      C. Technical Support Documents	   67 D
      D. Bibliography Citations	   68       D
      E. Generic Data Call-In	   143D
      F. Product Specific Data Call-In	   144D
      G. Batching of End-Use Products	   145D
      H. List of All Registrants Sent the Data Call-In	   150D
      I. List of Available Forms	   151D

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BIT Reregistration Team
Health Effects Risk Assessment
Melba Morrow
Cassi Walls
Tim McMahon
Michelle Centra
Timothy Leighton

Environmental Fate and Ecological Assessment
Najm  Shamim
Kathryn Montague

Use Analysis
Rebecca Miller

Risk Management
Rebecca Miller

Registration Support
Karen Angulo

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GLOSSARY OF TERMS AND ABBREVIATIONS

a.i.             Active Ingredient
aPAD          Acute Population Adjusted Dose
APHIS         Animal and Plant Health Inspection Service
ARTF          Agricultural Re-entry Task Force
BCF           Bioconcentration Factor
CDC           Centers for Disease Control
CDPR          California Department of Pesticide Regulation
CFR           Code of Federal Regulations
ChEI           Cholinesterase Inhibition
CMBS          Carbamate Market Basket  Survey
cPAD          Chronic Population Adjusted Dose
CSFII          USDA Continuing Surveys for Food Intake by Individuals
CWS           Community Water System
DCI           Data Call-In
DEEM         Dietary Exposure Evaluation Model
DL            Double layer clothing {i.e., coveralls over SL}
DWLOC       Drinking Water Level of Comparison
EC            Emulsifiable Concentrate Formulation
EDSP          Endocrine Disrupter Screening Program
ED STAC       Endocrine Disrupter Screening and Testing Advisory Committee
EEC           Estimated Environmental Concentration. The estimated pesticide concentration in an
               environment, such as a terrestrial ecosystem.
EP             End-Use Product
EPA           U.S. Environmental Protection Agency
EXAMS        Tier II Surface Water Computer Model
FDA           Food and Drug Administration
FFDCA        Federal Food, Drug, and Cosmetic Act
FIFRA         Federal Insecticide, Fungicide, and Rodenticide Act
FOB           Functional Observation Battery
FQPA          Food Quality Protection Act
FR            Federal Register
GL            With gloves
GPS           Global Positioning System
HIARC        Hazard Identification Assessment Review Committee
IDFS           Incident Data System
IGR           Insect Growth Regulator
IPM           Integrated Pest Management
RED           Reregistration Eligibility Decision
LADD          Lifetime Average Daily Dose
LC50           Median Lethal Concentration. Statistically derived concentration of a substance expected to cause
               death in 50% of test animals, usually expressed as the weight of substance per weight or volume
               of water, air or feed, e.g., mg/1, mg/kg or ppm. D
LCO           Lawn Care OperatorD
LD50           Median Lethal Dose. Statistically derived single dose causing death in 50% of the test animals D
               when administered by the route indicated (oral, dermal, inhalation), expressed as a weight of
               substance per unit weight of animal, e.g., mg/kg.
LOAEC        Lowest Observed Adverse Effect Concentration
LOAEL        Lowest Observed Adverse Effect Level
LOG           Level of Concern
LOEC          Lowest Observed Effect Concentration
mg/kg/day      Milligram Per Kilogram Per Day
MOE           Margin of Exposure
MP            Manufacturing-Use Product
MRID          Master Record Identification (number). EPA's system of recording and tracking studies
               submitted.
MRL           Maximum Residue Level

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N/A           Not Applicable
NASS          National Agricultural Statistical Service
NAWQA       USGS National Water Quality Assessment
NG            No Gloves
NMFS         National Marine Fisheries Service
NOAEC        No Observed Adverse Effect Concentration
NOAEL        No Observed Adverse Effect Level
NPIC          National Pesticide Information Center
NR            No respirator
OP            Organophosphorus
OPP           EPA Office of Pesticide Programs
ORETF        Outdoor Residential Exposure Task Force
PAD           Population Adjusted Dose
PCA           Percent Crop Area
PDCI          Product Specific Data Call-In
PDF           USDA Pesticide Data Program
PF10           Protections factor 10 respirator
PF5            Protection factor  5 respirator
PHED          Pesticide Handler's Exposure Data
PHI            Pre-harvest Interval
ppb            Parts Per Billion
PPE           Personal Protective Equipment
PRZM         Pesticide Root Zone Model
RBC           Red Blood Cell
RED           Reregistration Eligibility Decision
REI            Restricted Entry Interval
RID           Reference Dose
RPA           Reasonable and Prudent Alternatives
RPM           Reasonable and Prudent Measures
RQ            Risk Quotient
RTU           (Ready-to-use)
RUP           Restricted Use Pesticide
SCI-GROW     Tier I Ground Water Computer Model
SF             Safety Factor
SL             Single layer clothing
SLN           Special Local Need (Registrations Under Section 24C of FIFRA)
STORET       Storage and Retrieval
TEP           Typical End-Use Product
TGAI          Technical Grade Active Ingredient
TRAC         Tolerance Reassessment Advisory Committee
TTRS          Transferable Turf Residues
UF            Uncertainty Factor
USDA         United States Department of Agriculture
USFWS        United States Fish and Wildlife Service
USGS          United States Geological  Survey
WPS           Worker Protection Standard
                                                 ill

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EXECUTIVE SUMMARY

       The Environmental Protection Agency (hereafter referred to as EPA or the Agency) has
completed its review of public comments on the human health and environmental risk
assessments for l,2-benzisothiazolin-3-one (hereafter referred to as BIT) and is issuing its risk
management decision.  The Agency has decided BIT is eligible for reregistration provided all
measures outlined in this document are implemented.  BIT is an antimicrobial that is used as an
industrial preservative for the protection of water-based adhesives, caulks, sealants, grouts,
spackling, ready-mixed cements, ready-mixed wallboard compounds, aqueous compositions
such as emulsion paints, aqueous slurries, home cleaning and car care products,  laundry
detergents, fabric softeners, stain removers,  inks, photographic processing solutions, paints and
stains, titanium dioxide slurries, oil in water emulsions, latices, metalworking fluids, casein/rosin
dispersions,  textile spin-finish solutions, pesticide formulations, tape joint compound, leather
processing solutions, preservation of fresh animal hides and  skins, and for offshore and terrestrial
gas/oil drilling muds and packer fluids preservation.  l,2-Benzisothiazolin-3-one is also used as
an inert ingredient in a variety of products as a materials preservative. Exposures and risks from
the use of products containing l,2-benzisothiazolin-3-one as both the active and inert ingredients
are assessed in this reregistration eligibility  decision (RED).  End-use products are formulated as
either a soluble, ready-to-use, or flowable concentrates (all of which are considered to be
liquids).

Overall Risk Summary

       The Agency's human health risk assessment indicates few risks of concern. Acute and
chronic dietary exposure is below the agency's level of concern for general U.S. populations and
all population subgroups. Likewise, it was concluded that risk from exposure of BIT in drinking
water would also not represent a risk of concern because it is not likely to be in drinking water
sources at substantial concentrations. This is based on the fact that BIT readily biodegrades, is
applied to crops via inert use in small amounts and is only likely to come into contact with
soil/surface water via paint uses in small amounts. The acute and chronic aggregate dietary risk
assessment estimates associated with the use of BIT as an inert or active ingredient are below the
Agency's level of concern.

       Short and intermediate term residential post-application and handler exposures (dermal,
inhalation or incidental oral) from hard surface residues did not exceed the Agency's level of
concern.  For residential exposure and risk, the toddler post-application dermal exposure scenario
from residues remaining on pets from the inert use, the margin of exposure (MOE) is below the
targeted MOE, indicating that this scenario is a risk of concern.

       For aggregate exposure, the risk estimates associated with BIT are below the Agency's
level of concern. In cases where an aggregate risk index (ART) was used to assess risk because
of the different uncertainty factors for oral, dermal and inhalation exposure scenarios, the risk
indices suggested that there is reasonable certainty of no harm from using products containing
BIT.  Based on the information provided, inhalation exposures were not considered to be of
concern with regard to inhalation risk from occupational handler scenarios; however the dermal
MOE indicated that the dermal risk for occupational handlers was below the target MOE for one

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scenario, handlers of BIT-containing paint using an airless sprayer.  While the inhalation risk
may be an underestimation based on extrapolation from an oral study, the dermal risk is based on
a number of conservative assumptions and are not of concern. Dermal and inhalation exposures
to bystanders from the occupational use of BIT are also expected to be minimal.

       The indoor uses of BIT make it unlikely that any appreciable exposure to terrestrial or
aquatic organisms would occur.  Facilities using BIT for indoor industrial applications are
required to have NPDES permits before discharging effluents into receiving waters.

       l,2-Benzisothiazolin-3-one's ready biodegradation in soil and small application amount
greatly reduce the exposure potential for terrestrial and aquatic organisms. Run-off into surface
water from pesticidal uses is likely to be low and it is not likely to be present in water sources at
substantial concentrations. The ecological risks from the use of BIT suggest that because of the
high toxicity of BIT to green algae and invertebrate species, adverse effects to the environment
could result from contamination from BIT-treated oil recovery fluids.

Dietary Risk

       The Agency has conducted a dietary exposure and risk assessment for use of 1,2-
benzisothiazolin-3-one as a pulp and paper mill slimicide, and a preservative in paper coatings
and paper adhesives, all of which may end in indirect food contact scenarios. For both the acute
and chronic dietary exposure, the risk is highest for children (21.8% of the acute and chronic
PAD). For an adult, the acute and chronic dietary exposure is 9.4% of the acute and chronic
PAD.  All dietary exposures calculated are below the Agency's level of concern (100% of aPAD
or cPAD) for non-cancer risk.  Furthermore, given the conservative nature of the assumptions
used in the inert dietary exposure and risk assessment, risks of concern from food are not likely
from the use of l,2-benzisothiazolin-3-one as inert ingredients in pesticide products. A dietary
cancer risk assessment could not be performed as there are no carcinogenicity data for 1,2-
benzisothiazolin-3-one.

Drinking Water Risk

       Based on environmental fate data, l,2-benzisothiazolin-3-one binds moderately with soil
and may potentially move with the soil during rainfall events and reach surface waters.
Although, l,2-benzisothiazolin-3-one has been shown to be hydrolytically stable with a half life
of > 30 days, it breaks down fairly quickly in aerobic soils. Outdoor use  patterns of 1,2-
benzisothiazolin-3-one which may lead to contact with soil and/or surface water include: 1) the
application of agricultural pesticides that contain l,2-benzisothiazolin-3-one as an inert
ingredient, and 2) the application of paints that contain l,2-benzisothiazolin-3-one. Considering
l,2-benzisothiazolin-3-one readily biodegrades and the small amount (0.02 Ibs. per acre) that
may be applied to crops via the inert use and the small amount likely to come into contact with
soils/surface waters via the paint use, l,2-benzisothiazolin-3-one is not likely to be present in
drinking water sources at substantial concentrations.
                                            v

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