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                         ENVIRONMENTAL PROTECTION AGENCY

                      LEPTOPHOS ADVISORY COMMITTEE MEETING



                                PUBLIC SESSION
                       ,' •/.   . ROOM .3906
                            WATERSIDE MALL
                        "  401 M STREET, S.W.
                           WASHINGTON, D.C.

                       WEDNESDAY, July 21, 1976
                          2:00 O'CLOCK A.M.
 20

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                                  -ooOoo-

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E. Brenner

EPA 7-21-76

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                    (2:00 p.m.)



          CHAIRMAN  COON:    I would  like  to  convene  the



opening session, ladies and gentlemen.  The  purpose  of this



opening session, if you will  recall  from  yesterday,  was  to



submit to the — to submit any questions   to the Velsicol


                                    •

people the committee may have on  its minds,  as  a result  of



the committee's deliberations in  the last few hours.       !



          And, I should add,  I should  say that  the committe



is really not loaded with questions  at  this  point, but in

      r

answer to the few questions that  we  do  have,  there might be



.other questions generated in.that we can  proceed on  that



basis.                                          -



          Gentlemen.of the  committee,  would you ask any   \



questions that you might have.



        ""  DR. FRIESS:   Gentlemen of Velsicol,  a question



raised in the course of the committee work this morning,
                                                             t


which really bears on  the need for information  relative  to   ;



the toxic effects on humans by whatever routes  or modalities*

                                                             j

Of exposure these humans have experienced, you  did tell  us   |



yesterday that information exists with  respect  to peripheral



neuropathy in the human from certain kinds of exposures  that



have occurred.



          We feel that it would be extremely  important  for



the committee within the next month, which is between now anc

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      the  time that we are going to put  the report out, for us to

      have rough data on these relating  to the following points,

      as much  as you have and in as  crude a form as you have is

      okay with the committee.

                What we would really  like to know is items relat

      ing  to the  airborne concentrations that personnel might be

      exposed to in the course of manufacture, over long periods

      of time,  and rough estimates  of time intervals of contactT;
                                                                  '*
      for  personnel with these airborne   concentrations, and how-«-;

      ever rough you give it to us, indications of peripheral
                                                                 - -^
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      neuropathy in these operational personnel as a function of^','
                                    :"'4-  ---'-  ' •'•   '••-' ': •             ' ""-•••-•"'—. ;-'-: -.-.»:Vv-'.t''^
                     : ."the integrated dosage that they might have gotten.  V J"-"'1;' ^'
                      •;': -  /*, = vl -It is  asking for a lot, and  it  may not be in pol-

                      ished form at this stage, but what we  would really like to  j

                      know in the  earliest possible form for release,  is  the   .,;|!

                      effect in the human,  this peripheral neuropathy  as a functioj
                                                                                    i
                      of dose that the human has been exposed to  by the inhalation]

                      route. That  is a primary need, because the  human is the     j
                                                                                    *
                                                                                    t
                      ultimate target  that we are worried about and the animal    >
                                                9
                      models are great,  but if there is this opidemiological infor-

                      mation on the human,  and if it is reaching   report form in a

                      month, what  we would like to ask is a  preliminary peek at th

                      rough data,  before the  month is out.  This would help us a

                      good bit, especially in terms of  the  timetable  for the pro-

                      duction of the report, in which the committee would benefit


-------


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by having the data at the earliest time to have the longest


consideration time.   So we would very much appreciate that


kind of information if possible, in the earliest part of


August.


          Secondly, it would be of some interest and consi-|


derable interest if data exists relating to single incident]


or group incidents  of accidental skin exposure, percutaneoi
                                                           i
exposure of the human perhaps in the manufacturing  situa-


tion as much as possible relating to time and dose, and net


peripheral  neuropathy/  this would be information of extrem


importance to the committee, in looking at the biological
   •-.   •,•-      _    .-.                            -
situation in man,  vis-a-vis  that  in the. animal,
                                                         j ,-,,»
   : y. •    So, we really are saying that we would very much


appreciate having inhalation and skin contact information


in the human, in however crude a form you wish so t'^at the •'-,.


committee members might have it as the  earliest possible

date.


          And, we would thank you very much for such informa-i
                                                            -
tion.                                                        I
                                                             i
          CHAIRMAN COON:  You are welcome to make any comment


that you wish in connection with those requests.


          MR. CALO:    I think really the only comment that


I could make at this time is I really don't know what infor-


mation is available.   I would  have to ask for exactly what


you asked us for.

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          MR. WHITACRE:  Any 'aspects  having  to  do  with


the manufacturing process.


          DR. FRIESS:  Just in  terms  of  being able to


sequester data, is all manufacturing  done  in one  location --


all manufacturing of Leptophos  done in one location?


          MR. WHITACRE:   Leptophos is manufactured in two :
                                                            I
                                                            i
places, in the world.  It has been manufactured in Japan


since about 1969, and in Texas,  near  Houston since 1971.


          There has been no incident  —  well, maybe I


shouldn't say that, I am not familiar with the  program,  but,


in Japan there has never been   any reports at all  concerninc
 .                                                          • '*'

.that 'due'to. the manufacturing of the  material,, is that true

-. ' r - "--47-'/- :.--".-- " •-'"•<••":--.•  .          "           ""-        • ;
          MR. CALO: That is correct.


          DR. FRIESS:  But, in  this country, there is just


the single plant in Houston?


          MR. WHITACRE:  Right.


          DR. FRIESS:    And, are the populations  relatively


stable of workers so that one might have  expected certain


workers to have prolonged and continuous exposure?


          MR. WHITACRE:  We have asked the manufacturing


people to gather all of those data, and  that is the report


that I am referring to.


          It might seem to you  that we know  a lot  about  that


but in fact, we do not, simply  because it  is their responsi-


bility in the company.   We have asked them  with the  help of

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half or so, data from which should be available.   I  have

not made any report or anything  from that  experience,  and

so when I see it, I am going to see it,  and we will probably

see it about the same time.                                ]
                                                           I
          DR. FRIESS:  Thank you.

          CHAIRMAN COON:  Are there any other questions? Di

McNaniara, did you have another question?
                                                           I
          DR. McNAMARA:  Yes, I  had another  question, one  *

that is definitely in mind.   And, I was wondering,  with-'a

compound that is not registered, why would you  want  a toler'
             f
ance level conducted?                                     ':M
          MR. WHITACRE:  For the  sake of registering  the

compound principally.  It is the first step, or at  least

after certification  of usefulness is made by the agency,

for this compound, the next step is to establish a  tolerance,

whereupon, if everything else is adequate, the registration

can be obtained.  Our intent in originally submitting  the

application for registration in this country, is for that
                                                             !
purpose, to get the registration.  It has just so happened

certain occurrences have not permitted registration be issue<

          Obviously,  if the tolerances will not stand, we

will not have the basis to ask for — the basis upon which

to issue a registration.                                    >;

                                                            ii

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                                                      8







          So, very simply, the reason that we want toleranc




is the first or second step to obtaining   registration.




          DR. McNAMARA:   This is the  general sequence in




getting registered?




          MR. WHITACRE:   I would stand cdrrected by anyone^




from EPA, but that's the sequence for food items.          j




          DR. ROSEN:  I'm finished, I have  no questions.




          CHAIRMAN COON:    I would like to ask one questio




in connection with your plans for a cholincstcrasestudy




in chickens.  I want to be sure — is this a feeding study,




or a single dose per day administration?                .' "




   V:   ;''   MR. WHITACRE":   It'would please us greatly if the




committee would take that proposal, which we have written,




and look through it.  It would answer two questions, and




perhaps it would answer the question that you are asking,




first, but second, you might want to make a suggestion befo




it gets under way.                                          j




          CHAIRMAN COON:    This proposal hasn't been made




available to us, yet.




          MR. WHITACRE:   That  is right. Would you like it,j




that is the question?  I don't think that it has been made




available, although I would be more than pleased to submit




it, for your information and for your comments.




          CHAIRMAN COON:  I think that it would be important




for the committee to have, yes.

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                                                           9;




          MR. Will TAG RE: Incidentally in answer to your ques-


tion, it was going  to  be  —  well,  we haven't decided in facf


absolutely whether  we  should give  --  whether it should be



a feeding study, in which the  material is incorporated intc
                >

the feed, or whether we should  administer the dose by gelaii

                                                       'I

capsules, so that we would  know absolutely what each bird ^

                                                            *
is getting.   Did we decide  finally?


          MR. CALO:  No,  we  have not decided that.


          MR- l'?II ETACRE:   Everything else being equal, I thit

                                                            •?
                                                            4
that we would like  to  go  to  the geletin capsule unless it is
      ,,              "                                    " ,   -3

not necessary.  We  haven't had  to  make that decision, becavts'


we haven't lined up the facilities.         ., ,     /:-.'
  - .'.-.,--'.,  .--.-•-     •  -       .           - _* - '    •  r.--f;
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                                                            " i'*.

doing it with the feed, incorporate it into the feed, and it


is adequate.  Butr  the advantage of administering the capsulj


                                                             1
is that you know exactly  what each bird has ingested, and fo


control purposes,  it   might  be  a  little bit better, I'm not!


sure.


          DR. FRIESS:  Mr. Chairman,  could I address this  i


point?                                                       [


          CHAIRMAN  COON:   Yes,  go  ahead.


          DR. FRIESS:  This  has been the subject of some


discussion with the committee,  and I  think that points can


be made in favor of the feeding experiment,  that this is


more realistic in terms of the  time sequence of ingestion,
                                                                                 iJ

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 as related to man's experience in eating food.



           And,  secondly, the absorption problems with  respec



 to compound tissue, rates of dissolution, carrying  and meta-



 bolism are much better approximated by the feeding  experimer



 than by the gelatin capsule experiment.



           MR.  WHITACRE: Incidentally what we normally do for



 feeding experiments of this type is we use gelatin  capsules



 — well,  what  I do, we try to absorb the material in the



 grain so  that  it shouldn't be a major factor in terms  of —>*



 in other  words,  it is the same material —



  ,V;  J--.   DR.,  ERIES3:  But in a small bolus of relatively



 high concentration, which contrasts with taking in a-larger^



 volume  of food,  with a smaller specific structure,  and one



 wants the model  which is closer to man,  eating food in bulk.



           MR. WHITACRE:   But,  it is your recommendation that



 it  should be a  feeding experiment?                         I



           DR. FRIESS:  Personally yes,  and I  think  that this4



 is  reflected by  the committee.                               i



           CHAIRMAN COON:     This  was  our — practically the

                                                             i

 assumption of the  committee, when it  was discussing this



matter.   It just entered  my  mind  the  possibility  that you



might be  considering  the  capsule  approach  to  the administra-



 tion, so  I thought  that  I would ask questions,  and   that



conventionally in  long term  toxicity  studies   with  food addi-j



 tives and  pesticide residues in food, conventionally they  all

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proceed by incorporating the material in the diet.  And, Dr



Friess gave a fairly succinct reason why this is usually doi



          MR. WHITACRE:  I would like  to do it that way.



          CHAIRMAN COON:    You mentioned the theoretical



advantage of knowing exactly how much of the chemical the



chicken is getting.



          I suppose as time goes on, and the weight of the



chicken changes, so that the amount administered would be



on a pretty low basis to keep that constant.   Well, of coui



as the chicken grows, it eats more too, and so there is



sort of built in an automatic increase in the amount pro-



portionate, to the weight of the chicken.  Of course, .that i



not exact, because sometimes the chicken will not eat, but



what  he eats would be variable, but —  in the chronic    J


                                                           1
mouse and rat studies, they have an estimate of how much   ;;

                                                           ^

the animals eat per day.  In some tests they actually measur



the daily intake of the food, and know the concentration of



the chemical in the food,  and  they can calculate exactly



how much was  consumed.



          I suppose that there are other estimates of the



consumption, the food consumption of the chickens, on a woicjl



basis for the type of food that they are taking.



          MR. WHITACRE:  There is — yes,  it is a matter



of the number of animals being used, if they show any measur



able or significant variation in  intake, then there will be

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                                                                             12
an error there which will not be  easily  defined,  but it


should not be excessive on that basis.


          I am not really concerned  that the study  involvii


the feeding of the compound would be inadequate in any way,


if everything goes according to the   schedule  we would like


to define.


          CHAIRMAN COON:  Well, committee,  is there anythinc


further?


          (No response.)


          CHAIRMAN COON:  Well, I might  invite questions or


comments from the observers, who Jiave arrived today,  if thq


wish to, ask questions or make comments,  I would urge that


if they do, identify themselves,  and indicate whether they


are speaking for themselves, or for  the  agency that they


represent.


          DR. CORODA:    Dr. Rosen brought  up a point


yesterday about accumulation in fish,  and in this regard I .'


would like to ask  Leptophos if they have completed their   (


egg to egg feeding—of the  study  of  brook trout,  and if not, ',

               "   ./                                         i
I think that the data would be very  interesting to the


committee.  I think that it should be  turned over to them.


          MR. CALO:  The study is  completed.   We  have every


intention of turning the information over to the  EPA and the


committee.  I understand that the report will be  completed


within the ne^t three weeks.  As  soon  as it is available,  we

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will pass on the report to appropriate channels.




          DR. CORODA:  This was done by Ken Macy.




          MR. CALO:  It was done by Rionomics,  that  is



correct.




          DR. CORODA:  I have one other comment.  I  heard



that  through the grapevine that  Phosvel  was  banned in




Egypt, do you have any comment?



          MR. CALO:   I guess really I can only give an




unofficial answer.  I have not heard that.  The information



that I  have is that if they had an infestation as they hav




had.in past years, they would probably request  the material



again.1 r know that it is actively being considered by a   ";




number of people in Egypt.




          DR. CORODA:  When you speak of infestations, are  j



you implying that this compound is only used during  periods



of infestation and at other times when there is not  an in-  \



festation it is not used?



          MR. CALO:  Relative to the efficacy of the compound

                                                            i

I really can't comment.  I just am not that familiar with   j


                                                            !

these patterns whether they be here in the U.S. or overseas.



          DR. FRANKLIN:  Dr. Claire Franklin, Health and




Welfare, Canada.




          Could you tell me are there any other pesticides



produced in the plant in Texas other than Phosvel?




          MR. WHITACRE:  I am not certain because again, I am,'

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not really involved with the manufacturing situation, but


my impression is  that Phosvel is the  only  labeled


Methylparathion.


          I think  that there was a Methylparathion con-


verted plant in —                                         *
                                                           5-j

          DR. FRANKLIN:   And, they are  still actively    I

                                                           \
producing it now —


          MR. WHITACRE:  Well, let me finish.  I think that

                                                           *
that was a Methylparathion converted plant that  produced  '*


Phosvel up until early 1976, and it has been converted for *


EPN production, by Velsicol.                  :  .


  . :^V•=:.;;>/.MR^ ROSEN:  Does that mean that you will no longed


be producing it in the States?                         "  .


          MR- WHITACRE:  I really don't know.  I really do


not know what the plans are for that plant,  or far the


compound until we go further.


          DR. FUKUTO:   This is jumping out of the pot and ;_


into the fire, EPN is a neurotoxic agent, and from what


information we have, how seriously has  the company consider^


this?


          MR. WHITACRE:  I am sure that they'have considered


it,  and I really can't answer it from the corporate standpoi^


I'm just not in the position  to do that, because I am not

                                                           • *

involved in their decision making, perhaps it seems so,  and *


it may be so, but I can't really answer the question with an}'

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       25
                     assurity .
                     tion?
                               DR.  ZWEIG:  Are you phasing out  tho Phosvel procluc
                               MR. WHITACRE:   I don't know  if  that  is  the  case.
You've got me in an area in which I know little about it


from the company's standpoint.    Phosvel is not now being


produced in the United States, and it hasn't been for some


months.  That is all that I know.


          DR. ZWEIG:  It is being produced overseas?


          MR. WHITACRE:  As far as I know it is being pro-


duced in Japan, but I really don't know.  It is not one of 1


the considerations thatl'm required to look at or which

     • :.'••-'-. .'                      '                      "• "•"'•':&

Charlie is required to look at.  And, we haven't.


          DR. ZWEIG:  Questions can be answered if they are


cogent and the committee wishes to have them addressed.


          MR. WHITACRE:  Well, I can't answer with any degre


of certainty, because I just  don't know.                   t


          DR. FRIESS:What did come to mind though, is that


the interval in which workers might have been exposed during


manufacture is now limited from 1971 to 1975,  right,  there


is a four year interval?


          MR. WHITACRE:  That was when  the compound was


produced, domestically, that is what I understand, through


1975.
                               DR. FRIESS :  That is  the interval of course, for
                                                                                 -1

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which we would like exposure data.
MR. WHITACRE:
DR. FRIES S:
workers with respect to
under the Occupational
MR. CALO: I
MR. WHITACRE:
Indeed, yes.

Is there any intent to follow up
long-term delayed
Safety and Health
don't know.
neuro toxicity,
type regulations?
. i
I don't know what their long range
plans are. We have not, at least I have
to give ray opinions on that, and I don't
not been asked
*
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know what their lor
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range plans are. 1
CHAIRMAN COON: Does EPN have a registration now?*.'
• > ; MR. WHITACRE: It is a registered product in the"!
United States. . ll
DR.. CORODA:
It is on the presumption against
registration, .it is on the RPAR list for delayed toxicity, .'
so it is going to be examined for that property.
DR. ZWEIG: It is registered though? {
DR. CORODA:
DR. ROSEN:
Do you have any kind of
MR. CALO: I
Yes, it is registered, yes. ,
1
Could you describe the fish study? '\
1
.information?
can describe it in
don't have any of the data. It is an egg
general terms. I
to egg study, whic
encompasses probably 13 months of work, wherein you expose
mature fish to the chemical, during their
during the period of time when they are
*
adult stages, and
reproducing. You

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then  follow through the egg of  the  first  generation until


they reproduce.  In general terms  that  is  the  whole idea of


this study.  It is a laboratory  study,  not a field study.


          CHAIRMAN COON:  The point  of  that is a reproducti'<


study?


         . MR. CALO:  Yes.                                  ;
                                                            i
                                                            *
          CHAIRMAN COON:  You say  that  that is going to be ,
                                                            i

available shortly in about three weeks?                     ^


          MR. CALO:  Yes, I believe   the date  given by Dr. ,

   •                                                         i
Whitacre was the 20th of August, which  is  approximately a


month..


, .,.• ^:%fe?!v, MR.. WHITACRE:  I don't think  that I   mentioned


that, report yesterday, even though it was  in that manuscript:


that I talked about, but that is true,  it  is available, it !j


will be  submitted.


          DR. FRIESS:   We hadn't  heard about  it.


          DR. FUKOTO:   That's the third study that you are }

                                                             i
talking about?                                               .

                                                             i
          MR. WHITACRE:  I don't know what happened.   I don'1:


think that I mentioned it yesterday, because I don't remembei:


it,  but on the other hand it was in  the thing  that I read


from, I think  that when the charges were  restricted on the


environmental  aspect came out,  I  cut it,  and  we got back


into that yesterday,  it broadened again.


          DR. FRIESS:  Because it  is  broadened.

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                                                                        18
          DR. ROSEN:  Are  there  any  other studies that are


going on that might be pertinent to  this?


          MR. WHITACRE:     There are  no other studies goin<


on to my knowledge.


          DR. FRIESS:  The question  that I have is with


respect to the increasing  need to have mutogenic data on  *;


all chemicals in the  food  chain  as  well as the environment


I wondered, does the  company have any  plan to include Velsi-


col in systematic and vitro screening  for nmtogencsis?


          MR. CALO:   The whole area  of mutogencsity is right


now a very difficult  one for us.   We have spent tons of houi


discussing what we should  do.-  Routinely we.have been doing**


at least a dominate lethal study,  and in some cases we have


gone beyond this.  In terms of the in_vitro studies,  we have


not made a decision as to  what we will be doing.   We have


been told by  EPA that some time this   year,  there will be


some guidelines out as to  what tests would be appropriate.  j

Really,  we are waiting for  some  direction in  that area.      '
                                                             4
                                                             i
          DR. FRIESS:  It  hasn't  been  done yet to the best


of your knowledge,and the  in vitro system,  there  is no plan


at the moment?


          HR. CALO:   For  Leptophos?


          DR. FRIESS:  For  Leptophos,  right.    Speaking of


in vitro system.


          MR. CALO:   It has not  been done.   The mutogenisity ,
                                                                                 4

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                                                                             20




                              MR. GEE:   When you say it is available?


                              MR. WI11TACRE:  To the  committee in  the basket.


                              MR. GEE:  It is not part of the basket?


                              MR. WHITACRE:  No, we have it in our files.   It is


                    not part of the petition.                                  '


                              DR» FUKU.TO:  We have some items — there are  some


                    items that came fairly recently like the degradation studies


                    in water, and is that the thing that you are talking about?


                              MR. WHITACRE:  It would have to be from Vclsicol.
          DR. FUKUTO:  It is from Velsicol, and  it  is


called a report, we have those things.


    '-,".."-.--• MR. WHITACRE:  What I am trying  to determine  i


if something was submitted that was  not   part of the peti-


tion, or the amendment to the petition, it was submitted


simply to fill the file, is it available to the  committee's


review, or must we submit it separately to the committee ort


must you submit it separately to the committee?             ']


          MR. GEE:  Let me say the files there contain  all


petition information, the information that you are  talking   '
                                                             $

about recently we received and I know what  you  are talking  {


about, and we've added it to the file.   It is not  part of


our basket.  We have it in our files here  in the main office
                              If the committee wishes to see it, it can be made
                    available.
                              DR. FRIESS:  Mr. Gee, if you do indeed have those

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                                                                               21





                     four studies on mutogenesis,  if you can submit it, and they



                     are in the  file,  the  committee would like those.



                               MR. GEE:If  you  have submitted them -- you have



                     submitted them -to us?


                                                          «

                               MR. WHITACRE:   As  I recall,  they have been sub-



                     mitted in the last  four or  five months.                    I



                               MR. GEE:  We have  them.                           i

                                                                                 *

                               MR. WHITACRE:   The host mediated study is an    »



                     old one.    Right?                                           *



                               DR. FRIESS: Isn't  the dominate lethal the first  '*
one filed?
             .  CALO:     Yes,,  the other  three were submitted^]

             -;: .•;•'•                                    --4
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      • ,                    •                                 1


          MR.  WHITACRE:      So,  the three studies should be



available, all except  the  dominate lethal.



          DR.  FRIESS:    Right,  the dominate lethal infor- '.



mation is available,that is  out, the other three are not.



          MR.  CALO:  That  is correct.



          MR.  BOWEN:    The  three  studies that have been



sent to the  Registration Division  is what the committee



desires to have.



          DR.-FRIESS:  Right.



          MR.  BOWEN:  And, Mr. Frank Gee  will furnish those



to the  Secretariat  when  they are  given  to  the committee.



          CHAIRMAN COON:   I  take it that  these results came

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                                                       22



in too late to be entered in the petition,  is  that  right?


          MR. WHITACRE:   These were studies that were run


in 1975.


          MR. CALO:  Yes, 1975.


          MR. WHITACRE:   Just to update our information on

                                                           <
the compound, we were not required to do them, but  they were


done as part of the accumulation of  information on the


behavior of the compound.


          CHAIRMAN COON:  I don't understand fully  why they


are not in the petition.
      •* „                                                .p

       , ,. MR. WHITACRE:  Because we were not required by


EPA to submit thenv in support of the petition or in the


amendment to the petition.  We conducted them  on our own,


but yet submitted them to the file, to the  EPA file, after


the petition was submitted and amended.  ,


          CHAIRMAN COON:  So, it was a matter  of timing,


it  was too late for the petition.


          MR. WHITACRE:   And, in addition  to  that,  it was


not information which was specifically required by  EP?T~to


support — to support.                               \


          CHAIRMAN COON:  Is there anything further?


          DR. FUKUTO:  I would like to ask  a question, and


Dr. Painter might be the appropriate person. Why are not


chronic feeding studies requested for delayed  neurotoxicity?


          DR. PAINTER:  Why are  they not requested?  I think

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                    the best answer that I can give to that  is  that  this  is  the



                    first compound for an extremely long  time where  we  have  face



                    this kind of a problem.



                              I am going to say something now that I do not  have



                    a direct involvement in.    On some of those  compounds which



                    are currently registered, which show  this effect at extreme!



                    high levels, and I believe Food & Drug did  require  long  term



                    chicken studies.  I say that because  I have been  personally



                    involved with some of those chicken studies.                -



                              So, I guess the answer is when you  come  up agains



                    it, that is what you ask for, and in  fact I have been per-
                             -  ,                                            . .  ,. •' -4"%
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                    sonally involved with some of these gentlemen from  Velsicpl'f



                    in recommending  that chain study.                        ,  «
                              DR.. ZWEIG:
I would like to call to the attentio
                    of the committee, unless  — at  least it wasn't clear to me



                    when the representatives from Velsicol yesterday were men-  *•



                    tioning studies on water buffalo,  there are  two reports in



                    your'possession, one is'47 and the  other is'68.   I don't



                    know  which one is  which, but as I recall the very first



                    study which was carried in 1971,  although the report is not



                    signed by anybody, and I agree that it probably would not —



                    could not be scrutinized as closely as published reports,



                    but at least in that report, from an observer, there were



                    some delayed neurotoxicity symptoms in the water buffalo at



                    the  highest level fed, and  there were, as  I recall, four

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                                                    24

levels, IX, 2X, 3X, and 4X.  When that experiment was re-

peated, apparently under the auspices of the Egyptian Govern

ment, and partially from Velsicol, is that correct?

          MR. WHITACRE:  That  is correct, yes.

          DR. ZWEIG:  These animals were only fed,  1 and 2X

level.  In other words, they did not repeat the experiment
                                                           I
as had been done before, and as I recall,  they did not

observe any neurotoxic effects.   I would just like to call

to your attention that there were two separate water buffalo

studies and neither of them are very well authenticated,
       •—
as  far as  authorship is concerned.                  ,     ;

   "".f,  .-..I. think, that  in your examination you should be  *

made aware that there are two separate studies, one was    ;
                                                           ' j
positive and the other negative.  And, the only difference

that I could see was the positive one was at a higher level

fed than the negative one.                                 ;

          CHAIRMAN COON:  Thank you. Are there any other

questions, or comments?

          (No response.)

          CHAIRMAN COON:  If not,  we then declare the open

session adjourned.  And, I  want to thank the Velsicol

representatives for making themselves available today, and I

 am sorry that we didn't make more use of it to justify it

better, but so be it.

          Thank you very much.

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                                                                   25



                         MR. WHITACRE:  Thank you.


                         (Whereupon,  the open session was  adjourned at
                2:39 p.m.)
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