United States    Office of        September 1991
          Environmental Protection Pesticide Programs
          Agency	
&EPA     Reregistration
          Eligibility Document
          (RED)

          Carbon and  Carbon
          Dioxide

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    Carbon and Carbon Dioxide Reregistration Eligibility Team

Office of Pesticide Programs:

Jean Frane          Policy and Special Projects Staff

Program Management and Support Division
John Carley         Information Services Branch
Evelyn Alston       Information Services Branch
Health Effects Division
Pat McLaughlin
Esther Saito
Judy Smith
Alan Nielsen
Debra Edwards -
Andrew Rathman
Christine Olinger
                    Toxicolgy Branch
                    Science Analysis
                    Occupational and
                    Occupational and
                    Chemistry Branch
                    Chemistry Branch
                    Chemistry Branch
II,
and Coordination Branch
Residential Exposure Branch
Residential Exposure Branch
- Reregistration Support
- Reregistration Support
- Reregistration Support
Biological and Economic Assessment Division
Karen Griffin
E. David Thomas
Alan Schreiber
Gabe Patrick
Phyllis Johnson
Steve Jarboe
                    Economic Assessment Branch
                    Biological Assessment Branch
                    Biological Assessment Branch
                    Biological Assessment Branch
                    Biological Assessment Branch
                    Biological Assessment Branch
Registration Division
Walter C. Francis   Anti-Microbial Program Branch
                    Insecticide Rodenticide Branch
                    Insecticide Rodenticide Branch
                    Insecticide Rodenticide Branch
                    Insecticide Rodenticide Branch
Rob Forrest
Dan Peacock
Dick Mountfort
Bill Jacobs
Environmental Fate and Effects Division
Dan Balluff         Ecological Effects Branch
Bill Schneider      Science Analysis and Coordination Staff
Roy Bingham         Environmental Fate and Groundwater Branch

Special Review and Rereaistration Division
Bruce Sidwell       Accelerated Reregistration Branch
Virginia Dietrich   Accelerated Reregistration Branch
Carol Stangel       Policy, Planning, and Evaluation Staff

Office of Qeneral Council - Eran Gasko

Office of Compliance Monitoring - Beverly Updike

Office of Policy, Planning, and Evaluation - Gary Deutsch

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                        TABLE OF CONTENTS

                                                            PAGE

GLOSSARY OF TERMS AND ABBREVIATIONS                             i

EXECUTIVE SUMMARY                                              ^



I.   INTRODUCTION                                               1


II.  ACTIVE INGREDIENTS COVERED BY THE REREGISTRATION DECISION  2
     DOCUMENT


     A.   IDENTIFICATION OF ACTIVE INGREDIENT          '         2

     B.   USE PROFILE                                           3

     C.   REGULATORY HISTORY                                    3

III. EPA ASSESSMENT OF ACTIVE INGREDIENT                        4


     A.   PRODUCT CHEMISTRY ASSESSMENT                          4

     B.   HUMAN HEALTH ASSESSMENT                               5


                             CARBON

          1.    TOXICOLOGY DATA                                  5


          2.    OCCUPATIONAL AND RESIDENTIAL EXPOSURE            6

          3.    HUMAN RISK ASSESSMENT                            6


                         CARBON DIOXIDE

          4.    TOXICOLOGY DATA                                  6

          5.    DIETARY EXPOSURE                                 9


          6.    OCCUPATIONAL AND RESIDENTIAL EXPOSURE            9

          7.    HUMAN RISK ASSESSMENT                           10



     C.    ENVIRONMENTAL ASSESSMENT                              H


          1.    ENVIRONMENTAL FATE ASSESSMENT                   11

          2.    ECOLOGICAL EFFECTS ASSESSMENT                   11


          3.    ENVIRONMENTAL RISK ASSESSMENT                   12

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IV.  REREGISTRATION DECISION FOR CARBON AND CARBON DIOXIDE      13

     A.   DETERMINATION OF ELIGIBILITY                          *3

     B.   ADDITIONAL GENERIC DATA REQUIREMENTS                  14

     C.   LABELING REQUIREMENTS                                 I4

V.   PRODUCT REREGISTRATION                                     14

     A.   DETERMINATION OF ELIGIBILITY                          14

     B.   PRODUCT-SPECIFIC DATA REQUIREMENTS                    14

     C.   LABELING REQUIREMENTS                                 15

VI.  APPENDICES

     A.   APPENDIX A - USE PATTERNS  SUBJECT TO  REREGISTRATION  19

     B.   APPENDIX B - GENERIC DATA REQUIREMENTS FOR REREGISTRATION
          OF   CARBON   AND  CARBON   DIOXIDE  AND   DATA  CITATIONS
          SUPPORTING REREGISTRATION

          1.   GUIDE TO APPENDIX  B                              25

          2.   ECOLOGICAL EFFECTS (CARBON)                      26

          3.   TOXICOLOGY (CARBON)                              26

          4.   ENVIRONMENTAL FATE (CARBON)                      26

          5.   ECOLOGICAL EFFECTS (CARBON DIOXIDE)             27

          6.   TOXICOLOGY (CARBON DIOXIDE)                      28

          7.   ENVIRONMENTAL FATE (CARBON DIOXIDE)             28


      B.   APPENDIX C  - BIBLIOGRAPHY

           1.    GUIDE  TO APPENDIX C                             30

           2.    BIBLIOGRAPHIC CITATIONS                         32

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               GLOSSARY OF TERMS AND ABBREVIATIONS
CAS
CFR
CSF
EPA
FFDCA
FIFRA
GRAS
LEL
MRID

MS HA
NIOSH
OSHA
PEL
ppm
RED
STEL
Chemical Abstracts Service
Code of Federal Regulations
Confidential Statement of Formula
U.S. Environmental Protection Agency
Federal Food, Drug, and Cosmetic Act
Federal Insecticide, Fungicide, and Rodenticide Act
Generally Recognized As Safe
Lowest Effect Level
Master Record Identification (number).  EPA's system of
recording and tracking studies submitted to the EPA.
Mine Safety and Health Administration
National Institute for Occupational Safety and Health
Occupational Safety and Health Administration
OSHA Permissible Exposure Level
Parts per Million
Reregistration Eligibility Document
OSHA Short-term Exposure Level

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Executive Summary
registered for use as a rodenMr-       acive ingredient are
carbon dioxide as an
   ^iaation to

                                         „,
                   ssns sarsSSara
                    11

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 I.   INTRODUCTION
 * rf  J? ^  '  the Federal Insecticide, Fungicide, and
 Rodenticide Act (FIFRA) was amended to accelerate the
 ^registration of products with active ingredients
 registered prior to November 1, 1984.  The amended Act

 ^i??V-SCh?dUle f°r the registration prlcels to be
 completed in nine years.  There are five phases to the
 ^registration process.  The first four phases of the
 process focus  on identification of data requirements to
 support the reregistration of an active ingredient and the
 generation and submission of data to fulfill the
 requirements.   The fifth phase is a review by the U.S.
 Environmental  Protection Agency (referred to as "the EPA")
 of all dat.a submitted to support reregistration.

 M*<  ?ejtion 4(g)(2)(A) of FIFTtt states that in Phase 5 "the
 ™S    Jf  °?  ^H deteraine Aether pesticides  containing
 such  active ingredient are eligible for reregistration"
 before calling in  data on products,  under section
 4(g)(2)(B),  and either reregistering products or  taking
 5?S w?i ?rf rOP51!m  re^latory action" under FIFRA section
 5(g)(2)(C)  and (D) ,  respectively.   Thus,  reregistration
 involves  a thorough review of the  scientific data base
 underlying a pesticide's registration.   The purpose  of  the
 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
                          effects"  criterion of  FIFRA  section
     This document presents the EPA's decision regarding the
reregistration eligibility of the active ingredients ca?bon
and carbon dioxide.  The document consists of five sections.
Section I is this introduction.  Section II describes carbon
and carbon dioxide, their uses and regulatory history.
section III discusses the human health and environmental
assessment based on the data available to the EPA.  Section
IV discusses the reregistration eligibility decision for
carbon and carbon dioxide and Section V discusses product
reregistration requirements.  Additional details concerning
the review of available data are available on request/
     EPA's reviews of specific reports and information on the
     set of registered uses considered for EPA's analyses may
     be obtained  from:  EPA,  Freedom of Information, 401 M St.
     S.W.,  Washington,  D.C.   20460.

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II.   ACTIVE INGREDIENTS COVERED BY THIS REREGISTRATION
     ELIGIBILITY DECISION DOCUMENT

     A-    IDENTIFICATION OF ACTIVE INGREDIENT?

          1.   Chemical Name: Carbon

          CAS Number:  7440-44-0

          Office of Pesticide Programs Chemical Code Number:
          16001

          Empirical Formula: C

          2.   Chemical Name: Carbon dioxide

          CAS Number:  124-38-9

          Office of Pesticide Programs Chemical Code Number:
          16601

          Empirical Formula: CO2


     B.    USE
          Carboji ;

          Type  of  Pesticide:  Rodenticide/Predacide,  Insecticide
          when  used in combination  with sodium or potassium
          nitrates .

          Pests Controlled:  Pocket  gophers, moles, ground
          squirrels,  rats, skunks,  woodchucks,  red foxes,
          coyotes,  prairie dogs,  and ground wasps.

          Registered Use  Groups:  (See Appendix A for detailed
                                 specific use sites)
          Terrestrial Food Crop
          Terrestrial Feed Crop
          Terrestrial Non-Food Crop
          Forestry
          Residential Outdoor

          Formulation Types Registered:

          Ready to use cartridge-type bomb formulated with
          other active ingredients.  Designed  to be  ignited and
          placed in pest  burrow.  Combustion produces pyrolysis
          compounds which are toxic when inhaled by  the pests
          inhabiting the  burrow.  The smaller  cartridges  (0.75  to

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                 Methods  of Application:

       Use  one  cartridge  per burrow  system;







      Carbon DioxiH?.


      Type 'of Pesticide:  Insecticide.

      Pests Controlled: Insects


      Registered Use Groups: (See Appendix A for detailed
                              specific use sites)

           Indoor Food
                                                 "«""'
           pressurized gas:  99  to  99.9%  active  ingredient-
                                     °t cart   dide for
                                a                1- thL
     Methods of Application:


          Seal area to be fumigated.  Adjust atmosphere in

          fSJ? Sre?^v° J°% Carb°n di°xid* ™* aaintSin for
          four or five days.  Following fumigation

                                                  ' is safe
c-   REGULATORY HTSTnpy
     x»82,  in response  to  concern over safety of these

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        ™,     EPA issued a Notice of Intent to Cancel
      (NOIC)  all  products unless registrants submitted
      upgraded labeling and data on the burning
      characteristics of cartridges.  Subsequent to
      compliance  with the NOIC and labeling improvement
      program,  there have been four reports of injuries,  all
      involving misfiring of ignited cartridges.  The EPA has
      contacted the two registrants of these particular
      products  regarding these incidents.

      Carb9n  dioxide;   EPA first registered a carbon dioxide
      containing  product,  a pressurized gas product in 1981
      Carbon  dioxide was formulated with other active
      ingredients as an aerosol spray.   This spray was used
      to control  insects such as wasps.  The registrant of
      this  product has recently notified EPA of their intent
      not to  support the reregistration of carbon dioxide for
      this  particular use.   The first product containing
      carbon  dioxide for use as a fumigant was registered in
      1982.   The  product is used as an insecticide and
      miticide  in stored grain.   In 1980 EPA exempted carbon
      dioxide from tolerances in or on raw agricultural
      commodities (40  CFR  180.1049).   Carbon dioxide does not
      accumulate  in treated raw agricultural commodities  but
      rather  diffuses  into  the atmosphere  following
      application.   Therefore,  no residues of carbon dioxide
      are found in or  on raw agricultural  commodities.  In
      1981, EPA established a food additive regulation for
      carbon  dioxide in  or  on all processed agricultural
      commodities  when used post-harvest (40 CFR 185.650).

III.  EPA ASSESSMENT OF  ACTIVE INGREDIENT

          The EPA has reviewed  the scientific data  base  for
      carbon  and  carbon  dioxide  consisting of published
      literature  studies cited in the Bibliography  in
     Appendix C.    The findings  are summarized below:

A-    DESCRIPTION  OF ACTIVE  INGREPTENT AND ASSESSMENT  OF
     PRODUCT CHEMISTRY        w.i—•••. • .••> nvn-*vvtw *  vf


                        Carbon

     Carbon is a nonmetallic  element with an atomic weight
     of 12.01.   Pure carbon  is  found in three forms:
     amorphous black powder; black crystals known as
     graphite and the usually colorless diamond crystal.
     Carbon is found  in many  inorganic and all organic
     compounds.  It is the principal component in charcoal,
     coal,  and soot.  The melting point for carbon ranges
     from 3652-3697 C.  The dust may explode when exposed to

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          heat or flame or various chemical components including
          nitrates, oxides, peroxides, and halogens  (9).

          Carbon, in the form of charcoal or sawdust, is used as
          a pesticide in combination with nitrates and sulfur in
          gas cartridges.  These cartridges are used in burrows
          to kill coyotes, woodchucks, ground squirrels, prairie
          dogs, and pocket gophers and ground wasps.  No data are
          required concerning generic product chemistry.

                         Carbon dioxide

          Carbon dioxide is a colorless, odorless, noncombustible
          gas.  Its molecular weight is 44.01.  Solid carbon
          dioxide is known as dry ice and the sublimation
          temperature at atmospheric pressure is -74.5"C.   The
          solubility of CO2 in water is 0.14  g/100 g water;  it is
          less soluble in organic solvents.  The specific gravity
          relative to air at 24'C is 1.53.  When added to
          alkaline solutions carbonates are formed (6).

          Carbon dioxide is a naturally occurring gas found in
          the atmosphere which is required for plant and animal
          life.  It is a product of animal metabolism and is
          essential for plant and animal respiration (6).  It was
          first identified by Joseph Priestley about two hundred
          years ago and has been extensively studied since then.

          Carbon dioxide is used for a wide variety of non-
          pesticide applications.  Probably the best known use is
          for the carbonation of beverages.  It may also be used
          in refrigeration, fire fighting, welding operations,
          rubber tumbling, mining operations, and oil well
          secondary recovery.  Medical applications include use
          as a coma-inducing agent in psychiatric treatment and
          as a constituent of therapeutic oxygen.

          Carbon dioxide is used as a pesticide for insect
          control in stored grain under modified atmospheres
          containing approximately 60% carbon dioxide.

     B.   HUMAN HEALTH ASSESSMENT

                              Carbon

    1.  Toxicology - Data Base

     The toxicological data on carbon available in the open
literature are adequate for assessing risk to humans.  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

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(4).  Carbon, in the form of carbon black, is cleared by the Food
and Drug Administration, for use in resinous and polymeric
coatings as food-contact surfaces (21 CFR 175.300).  It is also
listed for use in paper and paperboard and polymers in contact
with food.

     The functional pesticidal active ingredients in animal
control cartridges are the pyrolysis products of the carbon and
other components of the formulation.  The toxic properties of the
carbon bear no relationship to the toxicity of the active
compounds.


    2.  Occupational and Residential Exposure

     Based upon available use data for carbon end-use products
(016001),  gaseous pyrolysis products are generated by oxidation
of carbonaceous materials within flare-like containers for the
purpose of controlling small mammals and coyotes in burrows and
dens.  When properly used for pest control in animal dens and
burrows, the fuse of the flare is ignited, the flare is placed
within the burrow within seconds after ignition, and the opening
is immediately sealed with nonflammable material such as soil to
prevent dissipation of combustion products.  Based upon reported
incidents, the primary hazard posed is dermal burns following
premature flare ignition.  With respect to inhalation and dermal
exposure,  gas cartridges should pose very low exposure hazards to
humans.

    3.  Risk Assessment

     The toxicity data usually necessary for pesticide
registration are not required for this use of carbon.  There are
some factors unique to this case which indicate that specific
studies to fulfill the usual data requirements are not necessary
to regulate this substance as a pesticide.  Carbon is a basic
component of all organic chemicals and all living organisms, and
is truly ubiquitous.  Human exposure is expected to be negligible
for carbon when it is used as one component in gas-producing
cartridges placed in animal burrows.  Ignited cartridges are to
be quickly placed into burrows which are then covered to entrap
the generated fumes.  Improperly covered burrows could result in
inhalation exposure to the fumes if the applicator remains in
close proximity to the burrow.

                         CARBON DIOXIPp

     l.  Toxicology

     All toxicology data requirements are satisfied.  No further
data are required by EPA.  A number of studies have been
conducted with carbon dioxide, but in most instances the purposes

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of these studies were not to determine the major endpoints of
toxicity by using the protocols recommended in EPA guidelines for
evaluating these effects.  However, there is a substantial volume
of information on carbon dioxide in the literature which covers
major biological considerations.

          a. Acute Toxicity

     EPA has a number of adequate acute toxicological studies on
carbon dioxide.  All the available acute studies use the
inhalation route of administration.  In one study (3) dogs were
given 30 percent carbon dioxide for 2 hours, then 40 percent
carbon dioxide, and then abruptly returned to normal air.  Eleven
dogs died within 10 minutes with ventricular fibrillation.  Four
survived with cardiac arrhythmias, and two had no cardiac
symptoms (3). -

     In a second study rats exposed to an atmosphere containing
50 percent carbon dioxide died within 6 hours.  Rats exposed to
25 percent died within 36 hours.  Deaths were a result of
pulmonary injury.  Atmospheres as low as 20 percent carbon
dioxide caused cerebral depression.  All rats exposed to 10
percent carbon dioxide survived (3).

     In a third experiment, rats were exposed to 20 percent
carbon dioxide for 2 hours followed by increasing concentrations
up to 43 percent.  The animals died in 2.5 to 19.3 hours and
showed severe brain and spinal cord damage in proportion to the
exposure (3).

     The first effect of human inhalation of excessive carbon
dioxide occurs at concentrations of about 2 percent  (20,000 ppm)
when the breathing becomes deeper and the tidal volume is
increased.   At 4 percent the depth of respiration is markedly
increased and at 4.5-5 percent breathing becomes labored and, for
some individuals, distressing (2).  Human inhalation of 8-10
percent concentrations for periods up to 1 hour showed no evident
harmful effects (2).  Other effects of increased carbon dioxide
levels are increased heart rate, headache, sweating, shortness of
breath, dizziness, shaking, convulsions, and unconsciousness (5).
Deaths from accidental exposure to extremely high levels of
carbon dioxide have been reported, but generally analyses of the
atmospheres for carbon dioxide concentration or the possible
presence of other deleterious gases have not been performed (3).

          b. Subchronic Toxicitv

     Subchronic exposure of laboratory animal species to various
concentrations of carbon dioxide have resulted in different
effects.  Guinea pigs exposed to 15 percent carbon dioxide for 7
days lost weight at first but later returned to normal weight.
They also had higher blood corticosteroids, lower adrenal

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 fat?vPaciS«' dnSTSed ad5e?al chol*8t«rol, higher arterial free
 exposure ?!)'.    dec«ased lymphocytes in the first 3 days of


      Rats exposed to 10 percent carbon dioxide for 30
   1ht   S  °f14-27 P^cent; those exposed to 20-25
 H*VC ?!! fffects were seen in male rhesus monkeys that spent 93
 days in an atmosphere with 3 percent carbon dioxide (3) .

           C. Human Chronic
        StUdy ?" brewe?y workers suggests that there are no
        cant physiological effects from chronic intermittent

                                            rt **°»* —
               Other Chronic Toxicologic^  Effects


 CQn^«nHteri°U! effects were found when animals  were given
 n«™??  £   fuS!S,°f carbon dloxid« higher than  the levels
 normally breathed in air.   Deleterious  effects on sperm of
 various animal species have been reported  (3)  following exposure
 to  high carbon dioxide atmospheres.   Also,  when pregnant Sts
 were  exposed  to 6 percent  carbon dioxide for one  full  day  23  4
 percent of the offspring had cardiac abnormalitie^and there 'was
 also  an increased incidence of skeletal  malformations  Uo 9

 SbbT^J3'-^6^"1 C°1Umn »al*>rmations^ere reported in

 carbon         h"nan
for lo^TUISL'S1??* P^3 exposed to 0.48 percent carbon dioxide
for 10 minutes daily for 20 days had a high number of

carrieI1?!e?™d ^tt* ParalVsis of th« hind limbs in the pups
carried to term.  Another group exposed to 0.42 percent carbon
mav     h                   3° days had no ^scarriages  bu
many of the offspring were microsomic and many of these had
neuromuscular defects of the hind limbs (3).
          e. Metabolism
     Carbon dioxide is produced by the body's metabolism and is
always present in the body at about 6 percent concentration   In
average adult human will produce more than 500 g of carbon
                            conditions' and »i" Produce much

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      Additional carbon dioxide has several effects on the body
 and responses are immediate,  it stimulates breathing, which
 ?Sab?ood It-1*011 dioxide carried to the lungs from the cells by
 £imS???i Jh "?'  J" lncrease in carbon dioxide concentration
 stimulates the heart rate, increases the blood pressure

 mulcl-65 ?  *SS-i? fl°W' and relaxes the vascula? smooth
 muscles.  In addition, carbon dioxide reacts with water in th*
          ;™ Carb?nic aCid' Which Associates Jo hydrogen ion and
          and tJS ^"u^ ln Carb°n dio*id* ^ thebod? ?nc?
          and then the kidneys act to restore normal acidity.

      studies on men exposed to 1.5 percent carbon dioxide in
 phase during the rest of the exposure period (3).

      1* — Dietary
      Carbon dioxide is exempt from the requirement of a t
 when used post-harvest in modified atmospheres lor stored

         °n     arU
 IS  19   Carb                                   in 40 CFR
 180.1049.   Carbon dioxide may be used as a food additive cost-
 harvest in modified atmospheres for stored product inslct control
          OCe     Agricultural commodities as described in To CFR
          DCFR 1?4'i240 carbon dioxide is listed as a substance
  «       Recognized As Safe  (GRAS) for use in food.  Carbon
™°Xid?  aS been. consumed in naturally carbonated or "mineral"
water for centuries, and in manufactured carbonated beveraaes
                                                               for
                                          continai  exose  to
  r-,
Sa5b°n^10Xlde Wlthfut any indications of toxic effects from such
ordinary exposures to carbon dioxide.  Furthermore, since carbon
percen? SoS nn^a^^nSt^Uent ?f ^ atmosphere at about ofo3
percent (300 ppm) , there is continuous human exposure by
i
                  ,
 inhalation and on the skin.

     ?,  Occupational and
fn^  ^door use of carbon dioxide end-use products as a fumigant
for postharvest treatment of raw and processed food commodities
and cargo areas poses potential exposure risks for workers
roif?^/?0?""^^"^3 are ass°ciated with worker reentr^ into
confined/enclosed spaces.  Carbon dioxide gas may collect and be
present in significantly higher concentrations in poorly
ventilated depressions in grain bins, shafts, etc. and sites
where recirculation of air is minimal.  Studies of workers

?S?rd  ?„ i9h ^T618 °f Carbon dioxide i« other industries
indicate that confirmatory air monitoring is essential in
confined spaces.  Even with ventilation systems present to purge
areas of excess carbon dioxide, some system design may be
inadequate to reduce levels to the OSHA permissible exposure

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 level  (PEL)  of  10,000  ppm.  Ventilation  systems need to be
 periodically tested  to determine  system  adequacy.

     Product labels  must  recommend  air monitoring while treated
 areas  are being ventilated  to  reduce ambient  levels of carbon
 dioxide.  This  monitoring will permit determination of post-
 application  inhalation exposure levels at  indoor use sites.
 During and following ventilation  activities,  short-term reentry
 of more than 15 minutes into treated areas may not occur prior to
 carbon dioxide  levels  falling  below the  OSHA  short-term exposure
 limit, STEL  = 30,000 ppm, within  the breathing zone for workers.
 Monitoring shall also  be  required for the  lowest work areas
 within enclosed/confined  spaces.
     There are many  factors unique to carbon dioxide which
suggest that specific studies to fulfill the usual data
requirements for pesticide registration are not necessary in
order for EPA to regulate this substance as a pesticide.  As
discussed above there are many natural exposures to carbon
dioxide from normal  respiratory and metabolic processes,
inhalation of normal ambient carbon dioxide, and consumption of
carbonated beverages and other foods.  In moderate increases of
carbon dioxide exposure, the human body has rapid compensatory
mechanisms to restore the normal balances through increased
respiration to exhale it and restoration of normal acidity by the
kidneys (8).  Humans ordinarily consume carbon dioxide in foods
and beverages daily.

     Serious teratological effects from acute exposure to
atmospheres containing more than 10% carbon dioxide have been
reported in toxicological studies.  However, such atmospheres are
not likely to be encountered by applicators using this product in
accordance with the label.

     The only risk from pesticide usage is to workers who enter
fumigated enclosures which have not received sufficient aeration.
However, the EPA believes that this risk is low if proper product
application and area ventilation are made.


C.   ENVIRONMENTAL ASSESSMENT

     EPA has not required and does not intend to require any
generic environmental fate or ecological effects data on the
active ingredient carbon considering the registered product
formulations and uses.  All data requirements for these
disciplines that are specified in 40 CFR section 158 are waived.
The rationale for this decision is presented below in the
"Environmental Risk Assessment."
                                10

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 l'
       Environmental
  Sarfean:   The physical  and chemical  properties  of
  carbon,  a naturally occurring  substance   are w«n
  SS*££00d'  Jhe  Pvr°W of  carbon JS'tSe presence of
  the  other active  ingredients such as sodium and
            nitrates  resu^s in  simple organic and
                             is          "- vhich
pyrolysis products eventually difuse through the
burrow opening or into soil/ Exposure to the
iSSSJJ?? ^n beKcha««=terized as limited and
n™it?   rat**r than widespread or broadcast.   EPA
normally requires many of the environmental fate
studies on  estic
            quires many of the environmental fate
 studies on pesticides in order to assist with its
                       Uving °^««i«-.  Given E?A's
             ~                        .
 ISS^iS   ^eCt! assessment, there is no need for
 such data.  Therefore, all environmental fate data
 requirements have been waived.   ™nenta-L rare data

                  Carbon dioxide is also  a
                                     &SSL
 2'
Jajfeon:   The gas  cartridges are  intended  for control of
woodchucks,  ground  squirrels, prairie dogs  pocket
gophers   moles, red foxes, coyotes, and ground wisps
Carbon is formulated with other  active ingredient '
sodium or potassium nitrates and sulfur,  during
manufacture  of the  gas cartridges.  Pest  speciL are
not exposed  to carbon or to thl  other IctiS!
                        t0 the Products of their
                 Carbon dioxide is used as a gas
nn        iS a" lndoor usa patt«rii,  exposure to
nontarget organisms is not expected.   Therefore, no
                     11

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4,  gnyirotiMiit.1 y^ A»amBtnt



    Martian: Application of the gas cartridaes Is
           Jus ssvnssi a
  incidents involving non-targe organises
                                       „.
                                       to




                  12

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     generic ecological effects data have been required or
     are being required.

IV.  RERE6I8TRATIOM DECISION FOR ACTIVE INGREDIENT

A.   DETERMINATION OF ELIGIBILITY

     Section 4(g)(2)(A) of FIFRA requires EPA to determine,
after submission of relevant data concerning an active
ingredient, whether products containing the active
ingredient are eligible for reregistration.  The EPA has
previously identified and required submission of generic
(i.e., active ingredient specific) data required to support
reregistration of products containing carbon and carbon
dioxide as an active ingredients.  EPA has also consulted
and relied upon published literature as a source for
technical information.  EPA has completed its review of
these generic data, and has determined that the data are
sufficient to support reregistration of products containing
carbon and carbon dioxide.  Appendix 8 identifies generic
data requirements that EPA reviewed as part of its
determination of reregistration eligibility of carbon and
carbon dioxide, and lists the submitted studies that EPA
found acceptable.

     The data identified in Appendix B as well as
information from the open literature are sufficient to allow
the EPA to conduct a risk assessment for the registered uses
of carbon and carbon dioxide.  The data available to the EPA
support the conclusion that the registered uses of carbon
and carbon dioxide will not result in unreasonable adverse
effects to the environment.  The EPA has determined that all
products containing carbon or carbon dioxide as the active
ingredient are eligible for reregistration.  The
reregistration of particular products is addressed in
section V of this document ("Product Reregistration"}.

     The EPA made its reregistration eligibility
determination based upon the target data base required for
reregistration, the current guidelines for conducting
acceptable studies to generate such data, and the data
identified in Appendix B.  Although the EPA has found that
products containing carbon and carbon dioxide are eligible
for reregistration, it should be understood that the EPA may
take appropriate regulatory action, and/or require the
submission of additional data to support reregistration of
products containing carbon or carbon dioxide, if new
information comes to the EPA's attention or if the data
requirements for registration (or the guidelines for
generating such data) change.
                           13

-------
 B.    ADDITIONAL GENERIC DATA REQUIREMENTS

      The generic data bases supporting the reregistration  of
 products containing carbon and fumigation  products
 containing carbon dioxide have been reviewed and  determined
 to  be complete for reregistration.   Carbon dioxide  is
 currently registered as an active  ingredient in two aerosol
 spray products used for the control of insects such as
 wasps.   One product is currently listed for cancellation due
 to  non-payment of 1991 maintenance  fees.   The registrant of
 the remaining product has recently  notified EPA of  their
 intent not to support the reregistration of carbon  dioxide
 for this particular use.   EPA is not considering  this use  of
 carbon dioxide for reregistration.   No further generic data
 are required.


 C.    LABELING REQUIREMENTS FOR MANUFACTURING-USE  PRODUCTS
      CONTAINING CARBON OR CARBON DIOXIDE

      The labels and labeling of all products must comply
 with EPA's current regulations and  requirements.  Follow the
 instructions in the Product Reregistration Handbook with
 respect to labels and labeling.  Any product label  which
 allows  both manufacturing and end use must be amended to
 specify either manufacturing or end use, not both.   No
 product may bear both manufacturing and end use labeling.
 In  this situation,  if a registrant  amends  the label to
 specify manufacturing use only and  wishes  to retain end use
 registration,  he/she must apply for a separate end-use
 product registration.

 V.    PRODUCT REREGISTRATION

 A.    DETERMINATION OF ELIGIBILITY

      Based on  the  reviews of the generic data for the active
 ingredients, carbon and carbon dioxide,  the products
 containing this  active  ingredient are eligible for
 reregistration.  Section  4(g)(2)(B)  of  FIFRA calls  for the
 EPA  to  obtain  any  needed  product-specific  data regarding the
 pesticide  after  a  determination of  eligibility has  been
 made.   The EPA will  review these data when they have been
 submitted  and/or cited  and determine  whether to reregister
 individual  products.

 B.    PRODUCT SPECIFIC DATA REQUIREMENTS

     The product-specific  data requirements  are stated in
Attachment  C.
                           14

-------
LABELING REQUIREMENTS FOR END-USE PRODUCTS CONTAINING
THE ACTIVE INGREDIENT CARBON

     The labels and labeling of all products must
     comply with EPA's current regulations and
     requirements.  Follow the instructions in the
     Product Reregistration Handbook with respect to
     labels and labeling.  Any product label which
     allows both manufacturing and end use must be
     amended to specify only manufacturing or end use.
     In this situation, if a registrant amends the
     label to specify manufacturing use only and wishes
     to retain end use registration, he/she must apply
     for a separate end-use product registration.

    'The EPA is currently developing detailed guidance
     on labeling for gas cartridge products, which will
     further address concerns about applicator safety
     and potential impact to endangered and non-target
     organisms.  This guidance will be sent to
     registrants prior to submission of labeling which
     is required eight months after issuance of this
     document.  Registrants will be required to follow
     this guidance in revising their labels.

D.   LABELING REQUIREMENTS FOR END-USE PRODUCTS
     CONTAINING CARBON DIOXIDE

1.   Any product label which allows both manufacturing
     and end use must be amended to specify only
     manufacturing or. end use. In this situation, if a
     registrant amends his label to specify end-use
     registration and wishes to retain manufacturing
     use registration, he must apply for a separate
     manufacturing use product registration.

2.   Required Human Hazard Precautionary Statements:

     a) "After fumigation, aerate treated areas until
     the level of CO2  as measured by [the registrant
     must identify one or more direct-reading detection
     devices suitable for use with the product and
     provide or reference instructions on its use], is
     below 10,000 ppm."

     b) "Short term entry into the treated area is
     permitted when measured CO2  levels are  between
     10,000 and 15,000 ppm; respiratory protection
     [registrant must specify a self-contained
     breathing apparatus (SCBA) or combination air-
     supplied/SCBA respirator approved by the National
     Institute for Occupational Safety and Health

                      15

-------
             •*"?•*** Mine safet* and
      Administration (MSHA) ]  must be worn if 15 or more
      minutes are spent in the treated area."

      £ir!nn measured C02  levels exceed  15,000  ppm, no
      person shall enter the  treated areas without a
      respiratory protection  device [registrant must
      specify either a NIOSH/MSHA approved seif-
      S£H?  ?? b^fthing apparatus (SCBA)  or
      combination air-supplied SCBA respirator]."

 2.    Spill and Leak Procedure Statement

      ™x?Ua*f laune
-------
     These signs must be posted at eye level and must
     be visible from all visible points of entry to the
     treated area.  They must remain posted during
     application and throughout the restricted-entry
     interval until the concentration of carbon dioxide
     is below 10,000 ppm.  Each separate treated area
     (i.e., boxcar, silo, ship container)  must be
     posted or placarded with this sign.

     The applicator or person responsible for
     monitoring levels of carbon dioxide may remove the
     placard when the concentration of carbon dioxide
     is at or below 10,000 ppm.

5.   Precautionary Statements for End-Use Products
    " Intended for Structural, Transportation, Space or
     Commodity Fumigation.

     In addition to the placarding directions specified
     under Section 4 above, the following statements
     must appear on all end-use products intended f r
     structural, transportation, space or commodity
     fumigation:

          "All persons working with this product should
          be knowledgeable of the hazards of this
          chemical, and trained in the use of required
          respirator equipment and detector devices,
          emergency procedures and use of the product.
          When used for fumigation of enclosed spaces,
          [boxcars, silos, ship containers, and other
          transport vehicles], two persons familiar
          with the use of this product must be present
          during introduction of the fumigant,
          initiation of aeration, and after aeration
          when testing for reentry.  Two persons do not
          need to be present if monitoring is conducted
          remotely  (outside of area being fumigated).11

6.   Required Storage and Handling Statements

     "Store in dry, cool, well-ventilated area under
     lock .and key.  Post as a pesticide storage area.
     Do not contaminate water, food or feed by
     storage."

     "Store cylinders upright, secured to a rack or
     wall to prevent tipping.  Cylinders should not be
     subjected to rough handling or mechanical shock
     such as dropping, bumping, dragging or sliding.
     Do not use rope slings, hooks, tongs or similar
     devices to unload cylinders.  Transport cylinders

                      17

-------
using hand truck or fork truck to which the
cylinder can be firmly secured."

"Do not remove valve protection bonnet and safety
cap until immediately before use.  Replace safety
cap and valve protection bonnet when cylinder is
not in use."

"When cylinder is empty, close valve, screw safety
cap onto valve outlet and replace protection
bonnet before returning to shipper.  Only the
registrant is authorized to refill cylinders.  Do
not use cylinders for any other purpose.  Follow
registrant's instruction for return of empty or
partially empty cylinders."
                 18

-------
              APPENDIX A

USE PATTERNS SUBJECT TO REREGISTRATION
                  FOR
       CARBON AND CARBON DIOXIDE
                 19

-------
APPENDIX A: USE PATTERNS SUBJECT TO REREGISTRATION FOR CASE 4019: CARBON ANDTn? I
SITE
Application Type, Application Timing. Application Equipment
j-
FOOOjFEED USES
AGRICULTURAL CROPS
(UNSPECIFIED)(CROPLAND)
Fumigation, When needed, Hand placed cartridge
RANGELAND (UNSPECIFIED)
Fumigation, When needed. Hand placed cartridge
NONFOOD USES
AGRICULTURAL UNCULTIVATED AREAS
Fumigation, When needed, Hand placed cartridge
F OREST PLANTINGS
(REFORESTATION PROGRAMS)
Fumigation, When needed. Hand placed cartridge
GOLF COURSE TURF
Fumigation. When needed. Hand placed cartridge
NONAGRICULTURAL UNCULTIVATED AREAS
Fumigation. When needed. Hand placed cartridge
ORNAMENTAL LAWNS AND TURF
Fumigation. When needed, Hand placed cartridge
-
Form
±=E====


IMPR

IMPR


IMPR

IMPR

IMPR

IMPR

IMPR
Maximum
Application
Rate
(X)
=!==:==
ac


0.1852 b
al/cartrtdge 1

0.1852 fc
at/cartridge 1


0.1852 fc
at/cartridge 1

0.0325 to
•I/cartridge 1

0.0325 to
al/cartridge 1

0.1B52to
ai/cartrtdge 1

0.0325 Ib
ai/cartridge 1
Max*
Apps.
'
live kigr<
^•^-^^_
not
spec

not
spec

not
spec
not
spec

not
spec

not
spec

not
spec
Max.*
Apps.O
Man. Rate
==^=
xilent - C>
~^~^^W^M^_

not spec

not spec
Mln. Interval
Between Apps.
® Max. fete
(D«ys)
	
Restricted
Entry
Interval
(Days)
Geographic
Limitations
Allowed | Disallowed
Use Limitations.

\RBON


not spec

5

not spec

not spec

not spec

not spec

not spec

not spec

not spec

5

not spec

5

not spec

not spec


not spec

not spec

not spec

not spec

not spec

none

none


none

none

none

none

none

none

none


none

none

none

none

none



endangered species restrictions; do
not use inside buildings


. 	
not use Inside buildings

endangered species restrictions; do
not use kialda htildkin*

endangered species restrictions; do II
not U3e Ins Ida hullrlnn« II

endangered species restrictions;do II
not use inside buildings 11

endangered species restrictions; do
not use inside buildings ||

-------
SITE
Appicwlon Type, Application Timing. Application Equipment
^ -— —
FOOQrFBED USES
CXJMMERCIALTRANSPORTAT1ON FACILfTlES
Fumigation, When needed. Cylinder
FEED/FOOD CONTAINERS^MFTY/FULL
Stored oommodKyKimigallon. Whan needed.
Cyfinder
GRAIN/CEREAL/FLOUR BINS. FEED/FOOD-FULL
Stored commodity fumigation. When needed.
Cylinder
PROCESSED FOOD AND FEED PRODUCTS
Stored commodity fumigation, When needed
Cylinder

^"^— ^^•^^-^^¥^^•1
Fwm
=7===


PROS

PROS

PROS

PROS
•B^aataKKB
Maximum
App*catk>n
Hate
<*)
=^===
active In gr
Mm.*
Apps.
=1=:
edient «
Max*
App*.e
Max. ftate
=
CARBC
M In. Internal
Between Apps.
OMajuFMe
(t>«ys)
	
)N DIOXID
Rtilrfcttd
Entry
Interval
(Oayi|
=
E
Geographic
Umttatkxw
Allowed | CMnallQvwd
^===^ .—
Use Limitations




60% (+10%)
aftreated
volume

60% (+10%)
al/kreated
volume

60% (+10%)
aVtreated
volume

80% (+10%)
at/treated
volume
g^EH=m=

not
spec

not
spec

not
spec

not
spec
aaoc^a

not spec

not spec

not spec

notapec
!^=S^=

not spec

not spec

not spec

notapec
— —

not spec

not spec

not spec

not spec


none

none

none

none


none

none

none

none


do not fumigate If grain temperature Is
toss than ^Ofot&O^f (depending on
product)

do not fumigate If grain temperature Is
less than «
-------
                  APPENDIX B
 Generic Data Requirements for Reregiatration
of Carbon or Carbon Dioxide and Data citations
          Supporting Reregistration
                     24

-------
                       GUIDE Tr>
  Registration Eli,lbi£i   tooentf         °°v*r<>* "* this

                                                      aPPly to
which .                 i'S'ss 2%

          '"
                        'enerally organized according to the
                                                           are
           sss sjr                -« "tffsj?-  -
 are available fro» the Nations? ?L ^"8f°?nt Guid«"n«s. which
 5285 Port  Royal Road,Sprin°tael^Ch2lc»2lJJf°™"°n Service,
 Patterns t                          i'1 in
-------
                                         APPENDIX B

DATA SUPPORTING GUIDELINE REQUIREMENTS FOR  REREGISTRATION OF  CARBON



GUIDELINE           TITLE OP             USE                BIBLIOGRAPHIC
CITATION            STUDY                PATTERNS           CITATION


PRODUCT CHEMISTRY


EPA waived 40 CFR 158 requirements for reasons discussed  in section III.

ECOLOGICAL EFFECTS

EPA waived 40 CFR 158 requirements as discussed  in section III.

TOXICOLOGY

EPA waived 40 CFR 158 requirements for reasons discussed  in section III.

ENVIRONMENTAL FATE

EPA waived 40 CFR 158 requirements for reasons discussed  in section III.



The citations listed in the bibliography  (Appendix C) were used to support these
decisions.
                                            26

-------
                                         APPENDIX B



DATA SUPPORTING GUIDELINE REQUIREMENTS FOR REREGISTRATION
OF CARBON DIOXIDE
GUIDELINE TITLE OF
CITATION STUDY
Product
61-1
63-2

63-3
63-4

63-5
63-6
63-7
63-8
63-9
63-10
63-11
63-12
63-13
Chemistry
Product Identity
Color

Physical State
Odor

Melting Point
Boiling Point
Density
Solubility
Vapor Pressure
Dissociation Constant
Oct. /Water Part. Coef.
PH
Stability

USE
PATTERNS
	 	 — • 	
ABL
•jk TST
ABL
ABL
JL Of
ABL
ABL
ABL
ABL
ABL
ABL
ABL
ABL
ABL
ABL

BIBLIOGRAPHIC
CITATION
— 	 " 	 7 	 	
94049-999*

94049-999
94049-999

94049-999
94049-999
94049-999
94049-999
94049-999
94049-999
94049-999
94049-999
94049-999
94049-999
                                           27

-------
  Information was obtained from correspondence with Phase 3 package for company no.  51877
MRID no. for package is cited.

ECOLOGICAL EFFECTS

EPA waived 40 CFR 158 requirements as discussed in section III.

TOXICOLOGY

EPA waived 40 CFR 158 requirements as discussed in section III.

ENVIRONMENTAL FATE

EPA waived 40 CFR 158 requirements as discussed in section III.


     The citations listed in the bibliography (Appendix C) were used to support these
decisions.
                                            28

-------
               APPENDIX C

 CARBON AND CARBON DIOXIDE  BIBLIOGRAPHY

Citations Considered to be Part of the
  Data Base Supporting Reregistration
                 29

-------
                        GUIDE  TO  APPENDIX  C

 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 Reregistration  Eligibility Document.  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 EKTRY.   The unit of entry in this bibliography is
      called a "study",  m  the case of published  materials, this
      corresponds closely to an article.   In the case of
      unpublished materials  submitted to the EPA the EPA 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
      EPA  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 further explanation.   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.

     a.    Author.  Whenever  the EPA could confidently identify
          one, the  EPA  has chosen to show a personal  author.
          When no individual was identified,  the EPA  has  shown  an
          identifiable  laboratory or testing facility as  author.

                               30

-------
      as auor/680'     EPA haS ShOWn  the "«t submitter
     w"??hmnnt dat^:  When the date  aPPears as four digits
     with no question marks,  the  EPA took it direct! JfrL




          if SS do"""18 "  deteralne «^-«»;: the
               ...       U ha= besn necessary for
                              -
d-
                                     2=2
                                  or other administrative
         submission.        Wlth  th6 earliest *nown

     (3)  Submitter.   The third element is the submitter
         fSSSSW^: 5h"sf/pitted **•"  ^
                                                  this


    (4)  volume Identification  (Accession Numbers)    The
 denti«h    ,
in 2ht5i JK    fP*  accessio» "umber of the volume
in which the original submission of the study
appears   The  six-digit accession number follows
         1      "
         SSr^S1 ™?L'" standin* *or "Company  Daa
         Library."  This accession number is  in turn
         rela?iv  nLf f • alphf !^ic suffix which  shows the
         For eiamnlf ^?H-°f th6 S?Udy within the vol™e
             XaKe' Wlthln accession number 123456, the
            heS26?? T^^%123456-A; the second' i2345
           the 26th, 123456-Z;  and the 27th, 123456-AA.
                        31

-------
                    OFFICE OF PESTICIDE PROGRAMS
                 REREGISTRATION ELIGIBILITY DOCUMENT
                             BIBLIOGRAPHY
                are the S°UrCes °f the ^erences cited  in this


  (1) Carbon  dioxide.   1989.   Federal Register 54 (12) -2650-2651
           January 19 (Thursday), 1989.               -2650-2651

  (2) Clayton, G.  D. ,  and Clayton, F. E., eds., 1982
 (4) Oilman, A.G., Goodman, L.  s.,  and Oilman,  A.  (1980)
                                           piiti   -  6th
 (5)  Jacobs^ ^ E   and Smith  M. S.  (1988).  "Exposures to Carbon
           aioxide in the Poultry Processing  Industry »  Ameriran
           industrial Hygiene Association jSurnal  49?«4.
Th? M?rcK Tndpx-  Eleventh  edition,  (1989),  p.  274.

                       Occupational  Safety and  Health
                       T -  TT *t*n A ii^gx uii vjm^y j. nigs for
           TT   ^-,4.1 .nr..^ -H- » ^T -  TT *t*n A ii^gx uii vjm^y j. nigs  for  Cri^Ttt i cs 1
           National ^r^^f10^ ^  flVlfl.  Cincinnati;  Ohio
           National Institute for Occupational Safety and Health,
 f8> NIOSP  PockPt  Guide to rhPmical »**»^r   1990.
                                s?
 " "'

10) Schmeltz  L .L   and Whitaker,  J.o.,  Jr.  1977.  Use of
          Woodchuck Burrows  by Woodchuck and Other Mammals.
          Trans. Kentucky Acad.  Sci.  38(1-2) :79-82.     is>

11) Vaughan, T.A. 1961.  Vertebrates  Inhabiting Pocket Gopher
          Burrows in Colorado,  j.  Mammal.  42 (2): 171-174?
                                32

-------
 ERA'S  BATCHING  OF CARBON AND CARBON DIOXIDE  END-USE PRODUCTS  FOR MEETING
 ACUTE TOXICITY DATA  REQUIREMENTS  FOR REREGISTRATION

    In an effort to reduce the time, resources and number of animals needed to fulfill the acute toxicity data
 requirements for reregistration of end-use products containing either the active ingredients carbon or carbon
 dioxide, the Agency has batched products which can be considered similar for purposes of acute toxicity
 Factors considered in the  sorting  process include each product's active and inert ingredients  (identity
 percent composition  and biological activity), type of formulation  (e.g., emulsifiable concentrate  aerosol'
 wettable powder, granular,  etc.), and labeling (e.g., signal word, use classification, precautionary labeling
 etc.).   Note  that the  Agency is not describing batched products as  "substantially similar" since some
 products within a batch may  not be considered chemically similar or have identical use patterns.

    Batching has been accomplished using the readily available information described above. Frequently
 acute toxicity data on individual end-use products has been found to be incomplete. Notwithstanding the
 batching process, the Agency reserves the right to require, at any time, acute toxicity data for an individual
 end-use product should the need arise.

     Registrants of end-use products within a batch may choose to cooperatively generate, submit or cite
 a single battery of six acute toxicologicai studies to represent all  the products within that batch, it is the
 registrants' option to participate in the process with all other registrants,  only some of the other registrants,
 or only their own products within a batch, or to generate all the required acute toxicologicai studies for each
 of their own products. If a registrant chooses to generate the data for a batch,  he/she must use one of the
 products within the batch as  the test material.  If a registrant chooses  to rely upon previously submitted
 acute toxicity data, he/she may do so provided  that the data base is  compiete and valid by  today's
 standards (see acceptance  criteria attached), the formulation tested is considered by EPA to be similar for
 acute toxicity, and the formulation has not been significantly altered since submission and acceptance of
 the acute toxicity data.

    In deciding how to meet the product specific data requirements, registrants must follow the directions
 given in the Data Call-In Notice and its  attachments appended to the RED. The DCI Notice contains two
 response forms which are to be completed and submitted to the Agency within 90 days of receipt.  The first
 form, "Data Call-In Response," asks whether the registrant will meet the data requirements for each product.
 The second form, "Requirements Status and Registrant's Response," lists the product specific data required
 for  each product, including  the standard six acute  toxicity tests. A registrant who wishes to  participate in
 a batch must decide  whether he/she wil! provide the data or depend on someone else to do so.  If  a
 registrant supplies the  data to support a batch of products, he/she must select one of the following options:
 Developing Data (Option 1), Submitting an Existing Study (Option 4), Upgrading an Existing Study (Option
5) or Citing an Existing Study (Option 6). If a registrant depends on another's data, he/she  must choose
among: Cost Sharing  (Option  2), Offers  to Cost Share (Option 3) or Citing an Existing  Study (Option 6).  If
a registrant does not  want  to participate in a batch,  the choices are Options 1,  4. 5 or 6. However,  a
registrant should know that choosing not to participate in a batch does not  preclude other registrants in the
batch from citing his/her studies and offering to cost share (Option 3) those studies.

-------
                                          -2-

    Table I lists 1 batch including 4 products containing the active ingredient

Table I.
                                                                            carbon dioxide.
Batch
•MH
1.













:^=sz^=:
===^=^=^=
EPA Reg. No.
•^^^•IMHMH^^M
192-49



358-137


1055M


56228-2



=S^==B^=S^==
^=^=
%Carb
&Othe
••^•i
60Ca
45.0 Si
45.0 PC
2.0 Oe
8.7 Sa
34.8 Su
46.2 Po
8.7 Ch
34.8 Su
46.2 So
17.34 C
3.52 &
10.84 Su
3.25 Re
43.36 &
	 —
                                  % Carbon/Charcoal/Sawdust
                                                               Formulation Type
                                                            Smoke Cartridge)
                                                            Smoke Cartridge
                                                            Smoke Cartridge
                                                            Smok* Cartridge
registrant


Table 111.
        "I!?8 °"! pr0
-------
Page  1 of  2
United States Environmental Protection Agency
Washington, D. C. 20460

REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE






INSTRUCTIONS: Please type or print in Ink. Please read carefully the attached infractions and supply the inforastion requested
Use additional sheet(s) if necessary.
1 . Coapeny nan* and Address 2. Case * and Nam
SAHPLE COHPANY 4019 Carbon and CO2
NO STREET ADDRESS
NO CITY, XX 00000
4. Guideline
•equireMont


61-1
61-2 (a)


62-2
62-3 •••:•:•:•••'•'-.:•, :•-
63-2
63-3
63-4
63-7
63-14
63-16
63-17
63-20
S. Study Title

Prod DM* - teautar Chearical
Product identity t, coaposltion(l)
p«*crip of starting Materials, (1,2,50)
production 1 fonmilation
' proe'. . ....:•;. '
Certification of Units (1,5)
Analytical Method d)
Color
Physical state :
Odor
Density •• • : •.';..;•;:. '.;•:.••• '/. ,-: :.!:/
Oxidizing or reducing action (10)
Explodabiltty ; •• . ; (12)
Storage stability *
Corrosion characteristic*

>















Progress
Reports
1 j 2
1




























3















6. Use
Pattern


ABCDEFGHIJKLHNO
ABCDEFGHIJKLHNO


ABCDEFGHIJKLHNO
ABCDEFGHIJKLHNO
ABCDEFGHIJKLHNO
ABCDEFGHIJKLHNO
ABCDEFGHIJKLHNO
ABCDEFGHIJKLHNO
ABCDEFGHIJKLHNO
ABCDEFGHIJKLHNO
ABCDEFGHIJKLHNO
ABCDEFGHIJKLHNO










on this fora.

3. Date and
Fora Approved

(MB Ho. 207Q-0107

Approval Expires 12-31-92


Tyos of OCI
PRODUCT SPECIFIC


7. Test
Substance


EP
EP


EP
EP
EP
EP
EP
EP ';•":•. !.::-:;-
EP
EP:::V. •;•:;
EP
EP. ••: .-:;•;
10. Certification —
1 certify that the statements amtie on this for* and all attachments are true, accurate, and coaplete.
1 acknowledge that any knowingly false or Misleading statement a*y be punishable by fine, isprisonaent
or both under applicable law.
Signature and litle of Coapeny's Authorized Representative
12. Haw of Company Contact ~~~ - ' —











v ::,::•:. •

:;:<::- "•••

'-'-S '.'••











.:'. :.-:..-': "'

•-.-:- -: • • : • !

^:-:.-.-.;:


S. Tia»
framt


8
8


8
8
8
8
8
8
6
8
8
8


•OS.
•OS.


BOS.
•OS.
•OS.

nos.
•OS.
•OS.
•OS.
•OS.
•OS,
9. Registrant
Response
















11. Date









13* PnOfM llUalwr

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United States Environmental Protection Agency
Washington, D. C. 20460

REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE






INSTRUCTIONS: Please type or print In Ink. Please read carefully the attached Instruction* and supply the Infonsstion requested
Use additional sheet(s) if necessary.
1 . Conveny nsa* end Address 2. case * and HMM
SAMPLE COMPANY 4019
NO STREET ADDRESS
Carbon and CO2


NO CITY, XX 00000
*. Guideline
Requirement
Mueber


61-1
61-2 (a)


62-2
62-3
63-2
63-3
63-4
63-7
63-14
63-16
63-17
63-20
S. Study Title

Prod Choa - Reoutw Otoica^
Product Identity t co»positlon
-------
United States Environnental Protection Agency Fora Approved
Washington, D. C. 20460
OHi Ho. 2070-0107
REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE
Approval Expires 12-31-92
INSTRUCT IONS: Please type or print In Ink. Please read carefully
U>e additional sfteetU) If necessary.
1 . Company noae and Address
SAMPLE COMPANY
NO STREET ADDRESS
NO CITY, XX 00000
*. Guideline
Requirement
Nuaber
81-2
81-3
81-4
81-5
81-6
95-8,9
96-13
96-17
5. Study Title
Acute tonic * Regular Oumluil
; Acute oral toxlcity-rat (1,51)
Acute dermal (1,2,51)
toxtcftyr«bt>lt/r«t
Acute Inhalation toniclty-rtt (3,51,52)
Prlaary eye Irritation-rabbit (2,51)
Prlaary denail irritation (1,2,51)
Dtrm*l tens! tlutfoh (4,51)
£ff tcaev • inWftcbrate Control Aoenta '•
•loaaulto. tlactf Iv. •rtlm Mldae •",','••: •"
Treatments
the attached instruct torn and supply the information requested on this for*.
2. Case * and Name
4019 carbon and CO2



Comparative field tWl (51,53,54)
ETTftttcv *" YM*TC|N 4yWe pontpo^n^wijej
Hole tout cants (1,51,53,55)
Rodent fualgants (1,51,53,56)
Hawaiian predaclde* (1,51,53,57)
1

Progress
Report*
1

2
••
3


3. Data and Type of DCI
PRODUCT SPECIFIC
A. Use
Pattern
ABCDEFGHIJKLMNO
ABCDEFGHIJKLMNO
ABCDEFGHIJKLMNO
ABCDEFGHIJKLMNO
ABCDEFGHIJKLMNO
ABCDEFGHIJKLMNO
C • ' • • A • ' ••: ' -: '••• -. '•••
C JK
C JK M 0
C- • . • ;•' .-...'."•. .• ^f '. • '. '.• '• •.>:•.•
** • '.'''• '. •-. '. ! :
Initial to indicate certification as to Information on this page
(full text of certification Is on page one).
7. Test
substance
EP
EP
EP •">:.--:.'" •-. -'
EP
fip^tggpgsipp:
Et»
EP
EP
a. Tin*
8 nos.
8 mos.
8 mos.
8 MOflv
8 nos.
8 nos.
™*t
8 nos.
':;ri.8 nos.'
9. Registrant
Response
•;'-'.:: ;:-:.::':-'-'-V.- ".:;.

Date

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Page 2 of 2
United States Environmental Protection Agency
Washington, D. C. 20460
REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE
INSTRUCTIONS: Please type or print in ink. Pleas* read carefully
Use additional sheet(s) if necessary.
1 . Ccnpany nene and Address
SAMPLE COMPANY
NO STREET ADDRESS
NO CITY, XX 00000
4. Guideline
Requirement
Mustier
81-1
81-2
81-3
81-4
81-5
81-6
95-8,9
96-8
96-13
96-17
S. Study Tftl*
Acute Toxjc - R^fl^er Chearicfi <:
Acute oral toxlcf ty-Nt; 
Efficacy- fnyef^ebraff- Confffl Aoefftf
m**.-***;-**.**
the attached instructions and supply the inforaetlon raquasted
2. Case f and MSB*
4019 Carbon and CO2


CMptrstly* field test ';; (51,55,54)
Molt toxicants : (1,51,55,55)
Rodent fuiigants (1,51,55.56)
MaaMllan pred*cldes : : (1,51,53,57)
initial to indicate certification as to inforwtton on this page
(full text of certification is on page one).


Progress
Reports
1

2
-•;
3

6. Use
Pattern
ABCDEFGHIJKLMNO
ABCDEFGHIJKLMNO
ABCDEFGHIJKLMNO
ABCDEFGHIJKLMNO
ABCDEFGHIJKLMNO
ABCDEFGHIJKLMNO
C K
C JK
C JK M 0
-;:,C,;:.:;-i . ::' K

7. Test
Substance
form Approved
am to. 2070-0107
Approval Expires 12-31-92
on this fora.
3. Date and Type of DCI
PRODUCT SPECIFIC

EP ••'.-•'
EP
EP
EP - ::.;•": . . -•-::;:
EP
BP 	 '""
8. Tine
8 JBOS.
8 mos.
8 BIOS.
8 nos.
8 DOS.
8 BOS.
9. Registrant
Respona*
'::i:-;:.:;.:-:.-:- ..•
Oat*

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                                 United States Environmental Protection Agency
                                             Washington, D.  C.  20460

                          FOOTNOTES AND KEY DBFIMATIONS FOR GUIDELINE REQUIREMENTS

                                     Case / and Name: 4019   Carbon and CO2
                                                                                                         Page   1 of  3


12

 5061
                                  °f
                                            i
         If product U pot«ntl.lty .«plo.fv».

     2 Because of past incidents involving units exploding, rocketing,  prematurely igniting, and burning
       excessively and in the wrong  places, the Agency wants as detailed a description of^he «nStC?
       tSS8^*? P°SSlblfi:.tIn  ««itionf the Agency wants the registrants of thefe f^^^Sl^
       taken to insure quality control of the units, such as periodic sampling to insure that units meet  the
       burning requirements imposed  in 1982.                                     "wuie tnac units meet  tne
•owU talc - tafulor
                  ral
1  Hot r«qu(r«d If t««t MterUI 1. . gM or highly vol.tll*.
 51Not required for CO2 products

     -3 The test must he conducted on the ignition gases.
        and approved, before initiation of test.
                                                         A test protocol must be submitted to the Agency
                                                                                                 «y«*-y

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                                                                                                                Page   2 of    3
                                   United  States Environmental  Protection  Agency
                                                 Washington,  D. C.  20460
                            FOOTNOTES AND KEY  DEFIHATIOHS  FOR GUIDELINE REQUIREMENTS
                                        Case §  and  Naae:  4019  Carbon and CO2
 Footnote  (oont.):
 Efficacy - liwertabrat* Control Aaenta

   Not required  for CO2 products.

 53For Gas Cartridge products, registrants must resubmit the data on burn times  for fuses and the
   cartridges, originally requested in the Agency's 1982 Label Improvement Program and Data Call-In, so that
   these data can  be assigned an HRID  Number.

 5495-9 Field data are required on ground wasps because  currently registered products appear to be too  wide
        to fit into wasp entrances,  thus creating an unnecessary risk to potential users, some of whom
        could have life-threatening  reactions to stings.  A  protocol must be submitted within 3 months,  and
        approved,  before work is begun.   As part of the  protocol, the registrant must document the entrance sizes
        of major wasp species, and  their geographic distribution, in the United  States.   If actual testing  is
        done, any  reports of units that  malfunction, or  were too big to fit into burrows, must be reported.

Efficacy - Vtrtabrate Contra! «e*nte

 1  The aaency haa waived at I r«*ilr«MnU to cUnlt efficacy data for vertebrate control agent* unlea* the peatlclde product boar* a del* to control vertebrate* (ouch
   ao rodonto, bird*, bat*, conld*. and okunko) that «ay dlractly «r Indirectly trenealt df*ee*e* to hum*.  NOMVM-. ooch real*trent wot emure throutfi teattnf that
   Ma product! ara efflcaelou* *wn uMd In accordance with labal direction* and m	utly accoptod prat control practice*. Tho reentrant auat dtvclop and Maintain
   tha relevant data upon *lch the dcteralnatlon of efficacy la baaad.  The Aatncy reaanm the rialit to retail re. on a caaa-bycaaa baata (e.g.. aipntf leant nan UH«
   or benefit* oata In  caaa* of opoclal review) tubilaalon of efficacy data for any peatlcld* product, reflUtered or prapoaad for registration uhan naeeaaary.
 51Not required  for CO2 products.

 53For Gas Cartridge products, registrants must resubmit the data on burn times  for fuses and the
   cartridges, originally requested in the Agency's 1982 Label Improvement Program and Data Call-in, so that
   these data can  be assigned an MRID  Number.

 5596-8 Field data are required on one species of mole.   A protocol must be submitted within 3 months,  and
        approved,  before work is begun.   Any reports of  units that malfunction,  or were too big to fit
        into burrows,  must be reported.

 5696-13 Field data are required on Norway rat, ground squirrel, and woodchuck.   If none of these species
         is claimed,  field data will be  required for one rodent species, if any  are claimed.  A protocol
         must he submitted within  3  months, and approved, before work is.begun.   Any reports of units
         that malfunction must be  reported.

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                                                                                                  Page  3 of
                              United States Environmental Protection Agency
                                          Washington,  D.  C. 20460

                            TNOTES AND KEY DEPINATIONS FOR GUIDELINE REQUIREMENTS

                              Case i and Nave:  4019  Carbon and CO2
 Footnotes (cont.):

Efficacy - Mrt*r*t« bntral
 5796~17 Field data are required on the coyote,  skunk, and red fox.  A protocol must be submitted within
         3 months, and approved, before work is begun.  Any reports of units that malfunction must be reported.

-------