United Statea             Office of Pecttekta and Toxic Subftances
             Environmental Protection      Office of Pettidde Program* (TS-766CI                    --.
             Mm                 «-,«.„. °c  20MO              540/FS-88-085
             Pesticide
             Fact Sheet
             Name of Chemical: SULF
             Reason for Issuance:  REGISTRATION STANDARD
             Date Issued:   5tP ^°
             Fact Sheet Number:  IBS
DESCRIPTION OF CHEMICAL

Chemical Name:  0,O,O',O'-tetraethy 1 dithiopyrophosphate (International
               Union for Pure and Applied Chemistry)

ANSI Common Name:  Not applicable

Other Common Names:  Sulfotep (British Standards Institution and Inter-
                    national Organization for Standardization); tetra-
                    ethy 1 thiodiphosphate (9th Collective Index); tet-
                    raethy 1 thiopyrophosphate (8th Collective Index);
                    thiodiphosphoric acid tetraethy1 ester; sulfotepp
                    (Entomological Society of America)

Principal Trade Names:   Bladafume; Dithio; Dithione; Plantfume

EPA Pesticide Chemical  (Shaughnessy) Number:  079501

Chemical Abstracts Service (CAS) Number:   3689-24-5

Year of Initial Registration:  1951

Pesticide Type(s):  Insecticide/acaricide

Chemical Family:  Organophosphate

U.S. Registrants:  Centerchem, Inc.; Fuller Systems, Inc.;
                  Plant Products Corp.

USE PATTERNS AND FORMULATIONS

Registered  uses:  Greenhouse ornamentals (non-food crop)

Predominant uses:  Azaleas, carnations, chrysanthemums,
                  geraniums, roses, snapdragons

Pests controlled:  Aphids, spider mites, whiteflies, mealybugs,
                  scales, thrips

Types of Formulations:   Ready-to-use liquid; impregnated materials

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    Types and Method of Application:  Fogging with liquid spray, smoking
                                      with irtpregnated materials

    Application Rates:  1.75 fl. oz. 4.5%/5,000 ft 3 (liquid fog);
                        1.75 oz. 15%/5,000 ft3 (smoke generator)

3.  SCIENCE FINDINGS

Chemical Characteristics

    Physical state: liquid

    Color: pale yellow

    Odor: Unknown

    Molecular Weight & Formula: 322.3, CsH2cP5P2S2

    Boiling Point: 136-139 °C at 2 mm Hg

    Vapor Pressure: 1.7 x 10-4 mn Hg or 22.6 mPa at 20 °C

    Specific Gravity: 1.196 d25/4°C, where 25°C refers to temperature at
                      which density (d) of sulfotepp measured and 4°C
                      temperature at which density of H2O measured

    Solubility in various solvents: 25 mg/1 water at room temperature;
                                    completely miscible with chloro-
                                    methane and most organic solvents

Toxicology Characteristics

    Acute Oral:  Data gap.  An acute oral LDso study in the rat is re-
                 quired.
    Acute Dermal:  Data gap.  An acute dermal LDso study in the rabbit
                   is required.

    Acute Inhalation:  Data gap.  An acute inhalation 1x150 study in the
                       rat is required.

    Primary Dermal Irritation:  Data gap.  A primary dermal study in
                                the rabbit is required.

    Primary Eye Irritation:  Data gap.  A primary eye study in the
                             rabbit is required.

    Dental Sensitization:  Data gap.  A study in the guinea pig is
                           required.

    Delayed Neurotoxicity:  Data gap.  An acute study in the hen is
                            required.

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Major Routes of Exposure:  Not well understood.  Inhalation of fumes and
                           dermal exposure to treated ornamentals.

    Subchronic Toxicity:  Data gaps.  A 21-day dental study in the
                          rabbit is required.  A 90-day inhalation study
                          is required.
                          Note: The 90-day feeding studies in rodent and
                          non-rodent are not required for the registered
                          use patterns.

    Oncogenicity:  Not required for the registered use patterns.

    Chronic feeding:  Not required for the registered use patterns.

    Metabolism:  Not required for the registered use patterns.

    Reproduction:  Not required for the registered use patterns.

    Teratogenicity:  Data gap.  A study in either a rodent or non-rodent
                     is required.

    Mutagenicity:  Data gaps.  The gene mutation (Ames Test) and the
                   chromosomal aberration studies are required, as is
                   the test for other mechanisms of mutagenicity.

    Physiological and Biochemical Characteristics

        Mechanism of Pesticidal Action:  Neurotoxin

        Metabolism and Persistence in Plants and Animals:  Metabolism
             not understood; short residual period on plant foliage.

    Environmental Characteristics:  There are no available environmental
        fate studies on sulfotepp.  Therefore, groundwater contamination
        potential cannot be assessed at this time.   Because of toxico-
        logical concerns on the acute hazards (see above), an interim
        11-hour minimum reentry interval and 2 hours of ventilation are
        being imposed for the uses of sulfotepp until adequate data have
        been submitted and evaluated.  The following list summarizes the
        environmental fate data requirements for sulfotepp.

        Degradation Studies:  Data gaps.  Laboratory studies on hydroly-
                              sis and photodegradation in air are
                              required.

        Metabolism Studies:  Data gap.  A laboratory study on aerobic
                             soil metabolism is required.

        Mobility Studies:  Data gaps.  Laboratory studies on adsorption/-
                           desorption (batch equilibrium study preferred)
                           and volatility are required.   A field volatil-
                           ity study is reserved until the results of
                           laboratory studies are known.

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        Reentry Protection:  Data gap.   An inhalation exposure study is
             required.  The registrant is required to propose acceptable
             reentry labeling based upon airborne residue levels meas-
             ured after observing the proposed label conditions, on es-
             timated human exposure to those residues,  and on toxicity
             of sulfotepp.  Because of the highly acutely toxic nature
             of sulfotepp, no actual human inhalation exposure monitoring
             data should be gathered.

    Ecological Characteristics:   No data are available for any terrest-
        rial species.  The available data indicate that sulfotepp is
        "highly toxic" to the rainbow trout and bluegill sunfish.  No
        data are available on effects on freshwater invertebrates.  The
        following list summarizes the ecological effects data require-
        ments for sulfotepp.

        Avian acute toxicity:  Data gap.  A single-dose U>50 study in
                               the bobwhite quail is required.
        Avian dietary toxicity:   Data gap..  A subacute dietary
                                 study in the bobwhite quail is required.
        Freshwater fish acute toxicity:   Rainbow trout: LCso =1.0 (0.8-
             1.3) ppm; bluegill sunfish: LC5Q = 0.36 (0.27-0.46) ppm.
             Available fish studies only partially fulfill the require-
             ments, but may be upgraded if additional data concerning
             the studies are available and are submitted.

        Marine fish acute toxicity:  Not required for the registered use
                                     patterns .

        Freshwater invertebrate toxicity:  Data gap.  ton. acute LC5Q
             study on aquatic invertebrates is required.

        Marine invertebrate toxicity:  Not required for the registered
                                       use patterns.

4.  TOLERANCE ASSESSMENT

     There are no approved tolerances for residues of sulfotepp and no
uses on food crops.  Therefore, a tolerance assessment is not required.

5.  SUMMARY OF REGULATOR? POSITIONS

    - Sulfotepp is not a candidate for Special Review at this time.

    - Sulfotepp meets the criteria for restricted use classification
      because of highly acute inhalation toxicity to humans.

    - Groundwater contamination concerns for sulfotepp cannot be as-
      sessed until basic environmental fate data requirements are met.

    - An interim reentry interval based on standards proposed in Title
      40, Code of Federal Regulations, Part 170, Subpart F, Special
      Standards for Workers in Greenhouses, Section 66, is being imposed

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      for the uses of sulfotepp pending submission and evaluation of
      data on exposure to airborne residues.

    - Protective clothing requirements are being imposed as labeling
      amendments for all registered sulfotepp products.

6.  LABELING REQUIREMENTS

    Statements applicable to all products:

       GENERAL WARNINGS AND LIMITATIONS:   Sulfotepp is classified as a
          RESTRICTED USE PESTICIDE by Title 40,  Code of Federal Regula-
          tions, Part 162, Section 31, on the basis of its acute inha-
          lation hazard to humans.

    Statements for Manufacturing-Use Products:

       ENVIRONMENTAL HAZARDS:
       This pesticide is toxic to fish.  Do not  discharge effluent
       containing this product directly into lakes, streams,  ponds,
       estuaries, oceans, wetlands or public waters unless this prod-
       uct is specifically identified and addressed in a NPDES permit.
       Do not discharge effluent containing this product to sewer sys-
       tems without previously notifying the sewage treatment plant
       authority.  For guidance,  contact your State Water Board or
       Regional Office of the Environmental Protection Agency.

    Statements for End-Use Products:

       General Warnings and Limitations;

       Worker Protection Statement:   WEAR THE FOLLOWING PROTECTIVE
          CLOTHING DURING LOADING, APPLICATION,  EQUIPMENT REPAIR,  EQUIP-
          MENT CLEANING,  EARLY REENTRY TO TREATED AREAS,  AND DISPOSAL
          OF THE PESTICIDE.  Wear a protective suit of one or two pieces
          that covers all parts of the body except the head,  hands,  and
          feet.  Wear chemical-resistant  gloves  and chemical-resistant
          shoes,  shoe coverings,  or boots.  Wear goggles and a pesticide
          respirator approved by the National Institute for Occupational
          Safety and Health (NIOSH)  and the Mine Safety and Health Ad-
          ministration (MSHA) at all times during application and early
          reentry to treated areas.

       Reentry Statement:  Reentry after  applying is restricted until
          one of the following intervals  has elapsed:

       (1)  Two hours of ventilation using fans or other mechanical
           ventilation systems.

       (2)  Four hours of ventilation using vents,  windows or  other
           passive ventilation systems.

       (3)  Eleven hours with no ventilation,  followed by one hour  of
           mechanical ventilation.

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       (4) Eleven hours with no ventilation,  followed by two hours
           of passive ventilation.

       If necessary to reenter the greenhouse for any reason during
       the specified intervals after application, protective clothing
       described in the Worker Protection Statement must be worn.  All
       greenhouses must be posted during the exposure period! and until
       safe to reenter.

       Disposal Statement:  Pesticide wastes are acutely ha2;ardous.
          Improper disposal of excess pesticide, spray mixture or
          rinsate is a violation of Federal Law.  If these wastes cannot
          be disposed of by use according to label instructions,  contact
          your State Pesticide or Environmental Control Agency or the
          Hazardous Waste representative at the nearest EPA Regional
          Office for guidance.  In addition,  interested parties may call
          the RCRA/Superfund Hotline toll free (1-800-424-9346) for infor-
          mation on Resource Conservation and Recovery Act requirements.

7.  SUMMARY OF DATA GAPS

    Toxicology   All the acute toxicity studies are required, including
       the acute delayed neurotoxicity study in the hen.  The subchronic
       feeding studies in the rodent and nonrodent are not required due
       to lack of oral exposure in the registered use patterns.  The 21-
       day dermal and 90-day inhalation studies are required.  The 90-day
       neurotoxicity study is reserved depending upon the results from
       the acute delayed neurotoxicity study.  A teratology study in one
       species is required and all the mutagenicity studies are required.

    Environmental Fate/Exposure  The laboratory degradation studies on
       hydrolysis and photodegradation in air are required.  The aerobic
       soil metabolism study is required.  The laboratory mobility stud-
       ies on adsorption/desorption (for which the batch equilibrium
       study is preferred) and volatility are required.  The field vola-
       tility study is reserved pending results from the laboratory
       studies.  The reentry protection study on inhalation exposure is
       required, but there is to be no actual monitoring of human inhala-
       tion exposure.

    Fish and Wildlife  An avian single-dose acute oral 11)50 study and a
       subacute dietary LCso study using the bobwhite quail are required.
       Additional data are required on the freshwater fish toxicity study
       already submitted.  A study on the acute LCso to aquatic inverte-
       brates is required.

    Product Chemistry  All the applicable data on product identity, an-
       alysis and certification of product ingredients, and physical and
       chemical properties are required.

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8.  CONTACT PERSON AT EPA

    William H. Miller
    Product Manager 16
    Insecticide-Rodenticide Branch
    Registration Division (TS-767C)
    Office of Pesticide Programs
    Environmental Protection Agency
    401 M St., SW
    Washington, D.C.  20460

    Office location and phone number:

    Room 211, Crystal Mall #2
    1921 Jefferson Davis Highway
    Arlington, W
    (703) 557-2600

9.  DISCLAIMER;  The information in this Pesticide Fact Sheet is a summary
only and may not be used to satisfy data requirements for pesticide regis-
tration and reregistration.   The complete Registration Standard for the
pesticide may be obtained from the contact person listed above.

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