United States                 Office of Pesticides and Toxic Substances
                     Environmental Protection          Office of Pesticide Programs (H7508C)
                     Agency                    Washington, DC 20460
*£EPA     Pesticide
                      Fact   Sheet
540/FS-89-067
                     Name of Chemical:   COUMAPHOS

                     Reason  for  Issuance: REGISTRATION STANDARD

                     Date  Issued:  SEP 2T l989

                     Fact Sheet Number:  207
          1. DESCRIPTION OF CHEMICAL
                                           *                        •
              Common Name:  Coumaphos
              Chemical  Family:  Organophosphate
              Pesticide Type:  Insecticide/acaricide
              Chemical  Name:  0,0-diethyl  0-(3-chloro-4-methyl-2-oxo-
                             2H-i-benzopyran-7-yl)  phosphorothioate
              Trade Names:  Bay 21/199,  Asuntol, Muscatox, Resitox,
                           Baymix,  Meldane, Co-Ral  and Negashunt
              Other Chemical
              Nomenclature:  0-3-chloro-4-methylcoumarin-7-yl
                            0,0-diethyl phosphorothioate; 3-chloro-7-
                            diethoxyphosphino-thioyloxy-4-
                            methylcoumarin; 0-(3-chloro-4-methyl-2-
                            oxo-2H-l-benzopyran-7-yl)  0,0-diethyl
                            phosphorothioate (Chemical Abstracts,
                            9th Collective Index);  3,chloro-7-hydroxy-
                            4-methylcoumarin 0-ester with 0,0-diethyl
                            phosphorothioate (8th Collective Index);
                            0,3-chloro-4-methyl-2-oxo-2H-chromen-7-y1
                            0-0-diethyl phosphorothioate;
                            [0-(3-chloro-4-methyl-7-coumarinyl)]
                            0,0-diethyl phosphorothioate; 0,0-diethyl
                            0-(3-chloro-4-methyl-7-courmarinyl)
                            phosphorothioate; phosphorothioic acid 0-
                            (3-chloro-4-methyi-2-oxo-2H-l-benzopyran-
                            7-yl) 0,0-diethyl ester; 3-chloro-4-
                            methylumJhelliferone,  0-ester with 0,0-
                            dietyl  phosphorothioate; 0,0-diethyl
                            0-(3-chloro-4-methylumbelliferone
                            thiophosphate
              Year  of Initial Registration:  1958
              CAS Registry Number:   56-72-4
              EPA Pesticide Chemical Code  (Shaughnessy  Number):   036501
              U.S.  Manufacturer:  Bayvet, a division of Cutter Laboratories

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USE PATTERNS AMD FORMULATIONS

   Coumaphos is applied as a direct animal treatment to control
arthropod pests of beef cattle, dairy cattle, sheep, goats,
horses and swine.  Jt is used to treat swine bedding.  Registered
control claims are for face flies, horn flies, fly larvae, cattle
grubs, ticks (including ear tick), lice, mites, screwworms, sheep
keds and fleeceworms.  Methods of application consist of dusts,
sprays, dips, pour-ons, dust bags and backrubber oilers.  Annual
usage is  264,000 to 525,600 Ibs (1986 estimate).  The
predominate use is on beef cattle (98%).  A relatively small
amount is used on dairy cattle «2%) and swine (
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cattle which have entered a body of water.  Aquatic residue
monitoring is required to assess the potential hazards.  Due to
the potential for avian exposure resulting from birds feeding in
cattle lots and on the backs of cattle, Tier I avian field
testing is required to assess possible effects to birds resulting
from the direct treatment to livestock.

     The environmental fate profile for coumaphos is adequately
delineated for the registered use pattern, except for a
groundwater assessment.  Coumaphos is relatively immobile in aged
sandy loam soil, based on findings in a column leaching study.
There are no immediate concerns for groundwater contamination
from non-point source application of coumaphos.  However, the
potential does exist for localized, point source contamination in
animal treatment areas (particularly where animals are dipped),
and as a result of associated disposal practices.  Due to
increased Agency sensitivity in the area of pesticides and
groundwater contamination, environmental fate studies are
required so that the Agency can assess coumaphos's potential for
point source contamination.

     Most of the residue chemistry conclusions drawn in the 1981
Standard have been reversed in the current Standard.  Residue
chemistry data requirements were not imposed in the 1981
Standard.  Since issuance of that Standard, the Agency has
published residue chemistry guidelines (Pesticide Assessment
Guidelines, Subdivision 0, 1982, EPA-540/9-82-023) and other
Federal Register (FR) Notices which provide a more stringent
interpretation of the existing regulations.  As a result of these
new guidelines, data are now required in the area of animal
metabolism, storage stability and method validation.  No changes
to coumaphos tolerances are indicated at this time.

     The Agency is unable to totally assess the safety of current
tolerances and establish an acceptable daily intake (ADI) value
for coumaphos because of the absence of chronic toxicity studies
(reproduction and dog chronic toxicity), and outstanding residue
chemistry data.   However, a preliminary dietary exposure
analysis has been performed for coumaphos.  Based on the results
of this analysis,  current coumaphos tolerances are considered to
be adequate to protect the public health.  When the remaining
data requirements have been fulfilled, the Agency will perform a
final reassessment of coumaphos tolerances.

Chemical/Physical Characteristics of the Technical Material

     Empirical Formula:   C14H16C105PS
     Molecular Weight:  362.8
     Color:  grey to tan
     Physical state:  powder to granules
     Odor:  characteristic sulfur
     Melting Point: 90 to 95 °C

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     Boiling Point:  20 °C at 10"7 rrunHg
     Solubility:   (at 20 °C) :   g/100  mL at 20  C
                  acetone                   23.82
                  methylene chloride         6.39
                  denatured alchohol         0.90
                  xylenes                    0.90
                  hexanes                    0.07
                  water      insoluble at   0.002
                  octanol                    0.13
                  odorless mineral spirits   0.09
                  diethyl phthalate         21.50
     Vapor Pressure:  1 X 10 7 mmHg
     Density, Bulk Density, or
     Specific Gravity:  granules: 30.06 Ib/cu ft, loose; 30.85
                        Ib/cu ft, packed, mhajranermiiled: 24.35
                        Ib/cu ft, loose; 30.51 Ib/cu ft, packed
     pH:  7.23 at 1 g/100 mL
     Stability:  hydrolyses slowly under alkaline conditions;
                 stable under normal storage conditions and
                 use; incompatible with piperonyl butoxide
     Storage Stability:  Stable  (<6% loss) in glass vials up
                         to 8 weeks at -12 to 50 C, dry and
                         at pH 4-10, at 83% moisture, exposed
                         to aluminum, and stainless steel;
                         stable exposed to sunlight for 4
                         days.

Toxicology Characteristics

Acute Oral:  Toxicity Category I  (LD50 of greater than 240 mg/kg
             in males rats and 17 mg/kg in female rats)
Acute dermal:  Toxicity Category  III (LD50 of greater than 2400
               mg/kg in rabbits
Acute inhalation:  Toxicity Category II (LC50 dose for a 1-hour
                   is 341 mg/m3 in female rats and
                   greater than  1080 mg/m3 in  male rats)
Primary eye irritation:  Toxicity Category III, mild
                         eye irritation reported
Primary dermal irritation:  Toxicity Category IV, very minor
                            dermal irritation reported
Skin sensitization:  No observable evidence of dermal
                     sensitization
Delayed Neurotoxicity:  Did not  induce delayed rieurotoxicity in
                        an acceptable study in hens.
Subchronic non-rodent/
       rodent studies:  None available.  Not required
                        since chronic data supercede
                        need for  subchronic testing.
21-day dermal toxicity:  Required Study
Chronic toxicity:  Dog study is  required.  Rat study NOEL is 0.07
                   mg/kg for decreased cholinesterase activity.
Oncogenicity:  The mouse and rat  chronic toxicity/
               oncogenicity studies did not reveal any evidence
               that coumaphos is  oncogenic.

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Mutagenicity:  Negative in all areas of mutagenicity tested.  A
               structural chromosomal abberation study is
               required.
Teratogenicity:  Rat teratology study NOEL and LEL were 5 and 25
                 mg/kg  (based on the observation of cholinergic
                 effects), respectively.  The developmental NOEL
                 was greater than 25 mg/kg (HDT).   Rabbit
                 teratology study maternal NOEL and LEL were
                 2.0 and 18.0 mg/kg, respectively;
                 developmental NOEL was greater than 18.0 mg/kg
                 (HDT).
Reproduction:  Required study
Metabolism:   In a rat metabolism study, coumaphos was rapidly
              excreted.  No dose-related changes in metabolism or
              evidence of activation/bioaccumulation were noted
              in this study.

Environmental Characteristics
                                    t

     Based on the results of a column leaching study, coumaphos
can be characterized as persistent, but immobile in sandy loam
soils.  There are no immediate concerns for groundwater
contamination from non-point source application of coumaphos.
However, the potential does exist for localized, non-point source
contamination in animal treatment areas (particularly where
animals are dipped), and as a result of associated disposal
practices.  In order to evaluate the potential for point source
contamination, special studies are required:  a photodegradation
study in soil, a photodegradation study in water,  an
adsorption/desorption study, a hydrolysis study  and a
retrospective field dissipation study.

Ecological Characteristics

     Based on the results of acceptable laboratory data,
technical coumaphos is characterized as highly to very highly
toxic to birds, moderately toxic to fish and highly toxic to
aquatic invertebrates:

     - Acute LD50  (mallard): 29.4 mg/kg
     - Acute LD50  (pheasant): 7.94 mg/kg
     - Dietary LC50:
        401 ppm (mallard)
        82 ppm (bobwhite)
      - Freshwater invertebrates toxicity (96-hr LC50) for
        amphipods: 0.15 ppb
     - Fish acute toxicity  (96-hr LC50) for rainbow trout: 5900
        ppb
     - Fish acute toxicity  (96-hr LC50) for bluegill sunfish:
        5000 ppb

     Results of laboratory testing, in conjunction with
theoretical monitoring, indicate that aquatic invertebrates may
be potentially exposed to hazardous levels of coumaphos resulting

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from washing-off of the material from the backs of newly treated
cattle which have entered a body of water, such as a pond or
stream.  To evaluate the potential risk, a residue monitoring
study is required.  There is a potential for avian exposure
resulting from birds feeding in cattle feedlots and on the backs
of cattle.  Tier I avian field testing is required to assess
possible effects to birds resulting from direct treatment to
livestock.

Tolerance Assessment

     U.S. tolerances are established for residues of the
insecticide coumaphos, 0,0-diethyl 0-(3-chloro-4-methyl-2-oxo-2H-
l-benzopyran-7-yl) phosphorothioate, and its oxygen analog, 0,0-
diethyl 0-3-chloro-4,-methyl-2-oxo-2H-l-benzopyran-7-yl-phosphate,
in or on raw agricultural products as follows (40 CFR 180.189):
     o    1 ppm in or on meat, fat, and meat byproducts of
          cattle, goats, hogs, horses, poultry ,  and sheep
     o    0.5 ppm in milk fat (reflecting negligible residues in
          milk)
     o    0.1 ppm in eggs

     Most of the residue chemistry conclusions drawn in the 1981
Standard have been reversed.  No residue chemistry data
requirements were imposed in the 1981 Standard.  Since issuance
of that Standard, the Agency has published residue chemistry
guidelines (Pesticide Assessment Guidelines, Subdivision 0, 1982,
EPA-540/9-82-023) and other FR Notices which provide a more
stringent interpretation of the existing regulations.  As a
result of these new guidelines, data are now needed in the area
of animal metabolism, storage stability and method validation.

     The Provisional Acceptable Daily Intake (PADI) for coumaphos
is 0.0007 mg/kg/day and is based on the 2-year rat
feeding/oncogenicity study NOEL of 0.07 mg/kg/day (based on
plasma cholinesterase inhibition in females) and uncertainty
factor of 100.  The Anticipated Residue Contribution (ARC) for
the United States population is 0.000127 mg/kg/day, occupying
18.2% of the PADI.  The two highest calculated exposures for the
population subgroups are children 1 to 6 years of age [ARC
occupies 33.6% of the PADI] and children 7 to 12 years of age
[ARC occupies 25.6% of the PADI].  Based on these calculations,
coumaphos applied at the currently registered application rates
would not be expected to exceed established tolerances.

     The Agency is unable to totally assess the safety of current
tolerances and establish an acceptable daily intake  (ADI) value
for coumaphos because of the absence of chronic toxicity studies
(reproduction and dog chronic toxicity), and outstanding data in
     1    There  are no  longer any  federally registered  uses  for
poultry/poultry houses.  Therefore, the  Agency  intends to revoke
the tolerances for poultry and eggs.

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the area of animal metabolism, method validation and storage
stability.  When the required data have been submitted and
evaluated, the Agency will perform a final reassessment of
coumaphos tolerances.

4. SUMMARY OF REGULATORY POSITIONS AND RATIONALES

     The Agency is not initiating a Special Review for coumaphos.
No Special Review concerns were identified for this chemical by
the Agency during its review of the current data base.

     The Agency is classifying coumaphos 11.6% EC and 42%
flowable concentrate end-use products as restricted use due to
acute oral hazards.

      The Agency will approve new food/feed tolerances for
coumaphos on a case-by-case basis.

      Environmental fate testing is'required to evaluate the
potential for coumaphos to impact groundwater or surface water
resulting from point source application.

      A special aquatic residue monitoring study is required.

      Special Tier I avian field testing is required.

   -  The Agency will revoke the poultry and egg tolerances,
since coumaphos is no longer federally registered for use on
poultry or in poultry houses.

      Unique labeling statements are required:

     o  Restricted-use classification is required for coumaphos
11.6% EC and 42% flowable concentrate formulations.

     o  Special disposal instructions are required for products
bearing directions for use a livestock dip treatment.

     o  Labels bearing directions for use on goats and sheep must
be amended to specify a preslaughter interval (PSI) of 3 days.

     o   Product labels must bear revised and updated fish and
wildlife statments.

     o  Worker safety and protective clothing statements are
required for products falling in Toxicity Category I or II.

     o  Each end-use product label must be revised to reflect the
appropriate signal word and precautionary statements assigned to
it based on the results of acceptable acute toxicity testing.

     o  Revised labeling must be submitted for those products
which do not contain directions for use specifying a maximum
single application rate expressed in terms of: (1) amount of

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active ingredient per animal; (2) a maximum seasonal application
rate or number of applications permitted per season; and (3) a
minimum interval between applications, revised labeling must be
submitted.
SUMMARY OF OUTSTANDING DATA REQUIREMENTS

Toxicology

21-Day Dermal Toxicity
Dog Chronic Toxicity
Reproduction Study
Chromosome Aberration

Environmental Fate/Exposure

Photodegradation in Water and Soil
Adsorption/Desorption
Special Retrospective Field Dissipation
Study
Hydrolysis Study
Fish and Wildlife

Monitoring for Aquatic Invertebrate
Mortality and Residues in Water
Tier I avian field testing

Residue Chemistry

Metabolism data - Animals
Residue Analytical Methods
Storage Stability Data

Product Chemistry

Remaining Data Gaps

6.  Contact Person at EPA

    George LaRocca.
    Product Manager (15)
    Insecticide-Rodenticide Branch
    Registration Division (H7505C)
    Environmental Protection Agency
    Washington, DC  20460
    Tel. No. (703) 557-24006

DISCLAIMER: The information presented in this Chemical
Information Fact Sheet is for informational purposes only and may
not be used to fulfill data requirements for pesticide
registration and reregistration.
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     Environmental Protection Agency
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