OMB Control No.  2070-0057
                                Expires 11/89
                  GUIDANCE FOR THE

        REREGISTRATION OF WOOD PRESERVATIVE

                 PESTICIDE PRODUCTS

                     CONTAINING

ARSENIC, CHROMIUM, AND CHROMATED ARSENICAL COMPOUNDS

              AS THE ACTIVE INGREDIENT



                  CASE NUMBER 0647
                     June 1988
          ENVIRONMENTAL PROTECTION AGENCY

            OFFICE OF PESTICIDE PROGRAMS

              WASHINGTON, D.C.  20460

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                        TABLE OF CONTENTS.
I.    Introduction 	    1

II.   Chemical(s) Covered by this Standard 	    3
        A.  Description of Chemical
        B.  Use Profile

III.  Agency Assessment 	    7
        A.  Summary
        B.  Preliminary Risk Assessment
        C.  Other Science Findings
        D.  Tolerance Reassessment

IV.   Regulatory Position and Rationale	    27
        A.  Regulatory Positions
        B.  Criteria for Registration
        C.  Acceptable Ranges and Limits
        D.  Required Labeling

V.    Products Subject to this Standard	    41

VI.   Requirement for Submission of Generic Data	    4.3
        A.  What are generic data?
        B.  Who must submit generic data?
        C.  What generic data must be submitted?
        D.  How to comply with DCI requirements
        E.  Procedures for requesting a change in protocol
        F.  Procedures for requesting extensions of time
        G.  Existing stocks provisions upon suspension or
            cancellation

VII.  Requirement for Submission of Product-Specific Data  . .    49

VIII. Requirement for Submission of Revised Labeling 	    50

IX.   Instructions for Submission	    50
        A.  Manufacturing use products (sole active)
        B.  Manufacturing use products (multiple active)
        C.  End use products
        D.  Intrastate products
        E.  Addresses

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                           APPENDICES

I.  DATA APPENDICES

    Guide to Tables

    Table A

    Table B

    Table C


II.  LABELING APPENDICES

     Summary of label requirements and table

     40 CFR 162.10 Labeling Requirements

     Physical/Chemical Hazards Labeling Statements

     Storage Instructions

     Pesticide Disposal Instructions

     Container Disposal Instructions


III.  USE INDEX APPENDIX


IV.  BIBLIOGRAPHY APPENDICES

     Guide to Bibliography

     Bibliography


V.  FORMS APPENDICES

EPA Form 8580-1   FIFRA S3(c)(2)(B) Summary Sheet

EPA Form 8580-3   Generic Data Exemption Statement

EPA Form 8580-4   Product Specific Data Report

EPA Form 8580-6   Certification of Attempt to Enter Into an
                  Agreement with Other Registrants for Development
                  of Data
                                  ii

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             GLOSSARY OF TERMS AND ABBREVIATIONS

ADI    Acceptable Daily Intake.  Also known as the Reference
       Dose or RfD.

a.i.   active ingredient

ARC    Anticipated Residue Contribution

CAS    Chemical Abstracts Service

CSF    Confidential Statement of Formula

EEC    Estimated Environmental Concentration.  The estimated
       pesticide concentration in an environment, such as a
       terrestrial ecosystem.

EP     End-Use Product

EPA    U.S. Environmental Protection Agency

FIFRA  Federal Insecticide. Fungicide, and Rodenticide Act

FFDCA  Federal Food. Drug, and Cosmetic Act

LC50   Median lethal concentration - a statistically derived
       concentration of a substance that can be expected to
       cause death in 50% of test animals.   It  is usually
       expressed as the weight of substance per weight or
       volume of water or feed, e.g., mg/1 or ppm.

LD50   Median lethal dose - a  statistically derived single dose
       that can be expected to cause death in 50% of the test
       animals, when administered by the route  indicated
       (oral, dermal, inhalation).  It is expressed as a
       weight of substance per unit weight of animal, e.g.,
       mg/kg.

LEL    Lowest Effect Level

MPI    Maximum Permissible Intake

MRID   Master Record Identification (number).   EPA's system of
       recording and tracking  studies submitted to  the Agency.

MP     Manufacturing-Use Product

NPDES  National Pollutant Discharge Elimination System

NOEL   No  Observed Effect Level
                                 iii

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OPP  Office of Pesticide Programs

OES  Office of Endangered Species. U.S.  Fish and Wildlife
     Service

ppm  parts per million

[X]  an ionic form of copper, pentachlorophenate,
     2,4-dinitrophenol or ammonia.
                                  IV

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                       I.  INTRODUCTION

     EPA has established the Registration Standards program
in order to provide an orderly mechanism by which pesticide
products containing the same active ingredient can be  reviewed
and standards set for compliance with FIFRA.  The standards
are applicable to reregistration and future applications  for
registration of products containing the same active  ingredient.
Each registrant of a product containing an active ingredient
subject to this Standard who wishes to continue to sell or
distribute that product must bring his product and labeling
into compliance with FIFRA, as instructed by this Standard.

     The Registration Standards program involves a thorough
review of the scientific data base underlying a pesticide's
registration.  The purpose of the Agency's 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 "no unreasonable
adverse effects" criteria of FIFRA.  In its.review EPA identifies:

     1.  Studies that are acceptable to support the data
requirements for the currently registered uses of the pesticide.

     2.  Additional studies necessary to support continued
registration.  The additional studies may not have been
required when the product was initially registered or may be
needed to replace studies that are now considered inadequate.

     3.  Labeling revisions needed to ensure that the product
is not raisbranded and that the labeling is adequate to protect
man and the environment.

     The detailed scientific review, which is not contained
in this document, but is available upon request', focuses on
the pesticide active ingredient.  The scientific review
primarily discusses the Agency's evaluation of and conclusions
from available data in  its files pertaining to the pesticide
active ingredient.  However, during the review of these data
the Agency is also looking for potential hazards that may be
associated with the end use products that contain the active
ingredient.  The Agency will apply the provisions of this
Registration Standard to end use products if necessary to
protect man and the environment.
1The scientific reviews may be obtained from the  Information
 Services Section, Program Management and Support Division
 (TS-757C), EPA, 401 M St., SW, Washington, D.C.  20460.

                        1

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     EPA's reassessment results in the development of a
regulatory position, contained in this Registration Standard,
on  the  pesticide and each of its registered uses.  See
Section IV - Regulatory Position and Rationale.  Based on its
regulatory position, tr._• Agency may prescribe a variety of
steps to be taken by registrants to maintain their registrations
in  compliance with FIFRA.  These steps may include:

     1.  Submission of data in support of product registration;

     2.  Modification of product labels;

     3.  Modifications to the manufacturing process of the
pesticide to reduce the levels of impurities or contaminants;

     4.  Restriction of the use of the pesticide to certified
applicators or other specially trained individuals;

     5.  Modification of uses or formulation types; or

     6.  Specification of packaging limitations.

     Failure to comply with these requirements may result in
the  issuance of a Notice of Intent to Cancel or a Notice of
Intent  to Suspend (in the case of failure to submit data).

     In addition, in cases in which hazards to man or the
environment are identified, the Agency may initiate a special
review  of the pesticide in accordance with 40 CFR Part 154
to examine in depth the risks and benefits of use of the
pesticide.  If the Agency determines that the risks of the
pesticide's use outweigh the benefits of use, the Agency
may  propose additional regulatory actions, such as cancellation
of uses of the pesticide which have been determined to cause
unreasonable adverse effects on the environment.

     EPA has authority under the Data Call-in  (DCI) provisions
of FIFRA sec. 3(c)(2)(B) to require that registrants submit
data to answer our questions regarding the chemical, toxicological,
and  environmental characteristics and fate of a pesticide.
This Registration Standard lists the data EPA believes are
necessary to resolve our concerns about this pesticide.
These data are listed in the Tables A, B, and C in Appendix  I.
Failure to comply with the DCI requirements enumerated in
this Registration Standard may result in issuance by EPA of  a
Notice of Intent to Suspend the affected product registrations.

     Registrants are reminded that FIFRA sec. 6(a)(2) requires
them to submit factual information concerning possible unreason-
able adverse effects of a pesticide at any time that they
become aware of such information.  Registrants must notify

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the Agency  of  any  information, including interim or preliminary
results  of  studies,  if that information suggest possible
adverse  effects on man or the environment.  This requirement
is independent of  the specific time requirements imposed by
EPA for  submission of completed studies called in by the
Agency and  continues as long as a product is registered
under FIFRA.

          II.  CHEMICALS COVERED BY THIS STANDARD

A.  Description of chemicals

     This registration standard covers active ingredients con-
taining  arsenic and/or chromium in products intended for use as
wood preservatives.  The six arsenic compounds used in the form-
ulation  of  wood preservatives are arsenic pentoxide, arsenic
trioxide, arsenic  acid, ammonium arsenate, sodium arsenate, and
sodium pyroarsenate.  All but two of these compounds, arsenic
trioxide and ammonium arsenate, are complexed with chromium when
formulated  into end-use wood preservative products.  The four
chromium compounds used in the formulation of wood preservatives
are chromic acid,  sodium chromate, sodium dichromate, and
potassium dichromate.

     For both  arsenic and chromium, multiple valences exist.
The majority of arsenic is present in the pentavalent state
(arsenate,  +5), although some trivalent (arsenite, +3)
arsenic  has been found.  Chromium is usually present in
the hexavalent state (chromate, +6), but is also found in
the trivalent  state  (chromite, +3).

     The general formulations of the products covered by this
standard can be described as [XjCrAs, [X]As, or  [X]Cr.  However,
some wood preservative products may contain a single arsenic
or chromium compound.  The symbol [X] is usually an ionic  form
of copper,  pentachlorophenate, 2,4-dinitrophenol, or ammonia.
Varying  formulations exist within each group.  The major use
group is copper chromated arsenates.  There are  three basic
formulas within this group.  The original formulation is now
referred to as CCA-type A (chromium/arsenic ratio of 2.73),
the use  of  which is limited today.  Updated versions, CCA-B
and CCA-C (chromium/arsenic ratios of .54 and  .96 respectively),
are now  available  and were designed to be even more tightly
retained by the wood that is treated, than  the original
formulation.

     Arsenic and chromium are commodity chemicals with many non-
pesticidal  uses, and the active ingredients incorporated
into the formulated products are not always registered as
manufacturing use  products.

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         CHROMIUM USED IN WOOD PRESERVATIVE FORMULATIONS
Compound
Chromic acid
Sodium chromate
Sodium dichromate
Potassium dichromate
Empirical
Formula
b/
Cr03~
£/
d/
*/
Molecular
Weight
100.01
161 .97
261.96
294.21
CAS
Registry
Number
07738-94-5
07775-11-3
10588-01-9
07778-50-9
Shaugh-
nessy
Number
021101
068303
068304
068302
a/ Values are for the anhydrous form.
F/ Actually, the true chromic acid (H2Cr04) exists in solution.
£/ Most likely would exist as the decahydrate (Na2Cr04.1 OH20) in
solution.
d/ Would probably exist as the dihydrate (Na2Cr04.2H20) in
solution.
ARSENICALS USED
Compound
Arsenic acid
Arsenic pentoxide
Arsenic trioxide
Ammonium arsenate
Sodium arsenate Na
Sodium pyroarsenate
IN WOOD PRESERVATIVE FORMULATIONS
Empirical
Formula
As 2 05
As 2 03
3As04.12H20
Molecular
Weight
141 .94
229.84
197.8
175.92
423.9
353.8
CAS
Registry
Number
7778-39-4
1303-28-2
1327-53-3
53404-17-4
10048-95-0
13464-12-1
Shaugh-
nessy
Number
006801
006802
007001
013601
013505
013401
B.  Use Profile
    Type of Pesticide:  Wood Preservative
    Pests Controlled:  Fungi, Insects, Bacteria, and Marine Borers
    Registered Uses:  Wood Preservative/Commercial Application
    Methods of Application:  Pressure Treatment and Brush on
      Application (Cut Wood Ends/Construction Sites Only)

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    Formulation Types Registered:

      Registered Technicals: 90%, 94%, 95.5%,  99% Arsenic trioxide
                             98% Ammonium arsenate
                             98.88% Sodium arsenate

      Registered Technicals: None for chromium compounds

      End Use:
        Granular (G) 1.5%
        Impregnated Materials (IM) .46% to 13%
        Liquid-Ready-To-Use (L/RTU) 0.2%-34.3%
        Pelleted/tableted (P/T) 19%-85.9%
        Soluble Concentrate/Liquid (SC/L) 3%-75%
        Soluble Concentrate/Solid (SC/S) 4.8%-53%
        Wettable Powder (WP) 20%

     Physical Characteristics: The Agency is requiring
information on the source and description of arsenic, chromium,
and other active ingredients in the formulated end-use products
to determine the characteristics of each product.

C. Regulatory History

     The Environmental Protection Agency issued a Notice of
Rebuttable Presumption Against Registration (hereafter
referred to as Special Review) for the wood preservative
uses of the inorganic arsenicals on October 18, 1978 (43 FR
48267).  That notice was based on a determination that the
use of the inorganic arsenical pesticide products met or
exceeded the risk criteria for oncogenicity, rautagenicity,
and teratogenicity under 40 CFR 162.11, now found at
40 CFR 154.7.

     In January 1981, the Agency issued a preliminary
regulatory determination (46 FR 13020) which proposed changes
to the terms and conditions of registration for inorganic
arsenicals intended for use as wood preservatives.   That
proposal was based on a detailed assessment of the risks
and benefits of continued registration  (PD 2/3); the Agency
concluded that the benefits of use were high and that measures
short of cancellation could be implemented to reduce the
risks to an acceptable level.  The final determination was
published in the FEDERAL REGISTER of July 13, 1984 (49 FR
28666).  The Agency received hearing requests from registrants
contesting the requirements of the July 13, 1984 final
determination.  After considering certain alternative
mechanisms suggested by registrants for accomplishing the
goals set out in the July 13 determination, the Agency published
in the FEDERAL REGISTER of January 10,  1986 (51 FR 1334) an
amended notice.The changes made to the requirements of the
original notice were minor in scope.

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     While the Special Review only addressed the inorganic
arsenic component of arsenical wood preservative products,
this standard addresses chromium in addition to inorganic
arsenic because chromium is often complexed with arsenic
in formulated wood preservative products.

     Both arsenic and chromium have been extensively reviewed
by EPA's Office of Health and Environmental Assessment (OHEA),
Office of Research and Development.  The following final
reports prepared by OHEA are the main source documents for
the science assessment contained in this document:

     Health Assessment Document for Inorganic Arsenic. Final
     Report. EPA-600/8-83-021F. Office of Health and
     Environmental Assessment, U.S.E.P.A., Washington, D.C.
     March 1984.

     Health Assessment Document for Chromium. Final Report.
     EPA-600/8-83-014F. Office of Health and Environmental
     Assessment, U.S.E.P.A., Washington, D.C. August 1984.

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                   III.  AGENCY ASSESSMENT

A.  SUMMARY

     The Agency has conducted a thorough review of the scientific
data base for the inorganic salts of chromium and arsenic.
The results of this review are summarized below and discussed
in greater detail in section III.B. of this document and
in the support documents mentioned above.

     1.  Inorganic arsenic and hexavalent chromium compounds
are classified as Group A carcinogens  (evidence of human
carcinogenicity).  There is currently  sufficient evidence
from epidemiologic studies to support  an association between
exposure to both chemicals and cancer.  No further
oncogenicity studies will be required.

          a.  Inorganic arsenic compounds are both lung
     and skin carcinogens in humans.

                (1).  studies among smelter workers and
          among workers engaged in the production and
          use of arsenical pesticides  have demonstrated
          excess mortality due to lung cancer.

                (2).  A study of a non-occupational
          population within Taiwan exposed to high
          concentrations of arsenic in well water has
          demonstrated excess occurrences of skin cancer.
          The Agency is currently reevaluating the risk model
          for oral and dermal exposure to inorganic arsenicals.

          b.  Hexavalent chromium is a lung carcinogen
     in  humans.  Exposed workers in chromate refining
     plants showed significantly increased levels of
     respiratory carcinomas.

     2.  Both arsenic  and chromium have demonstrated  the potential
to  cause teratogenic/fetotoxic effects thru peritoneal  exposures.

         a.  Studies in which arsenate and chromium
     compounds  were administered intravenously or
     intraperitoneally to hamsters, rats, and mice,
     demonstrated gross malformations  (terata) and
     fetotoxic  effects; however, the  routes of exposure
     were not appropriate for human risk assessment.

         b.  In contrast, oral studies for arsenic  in mice  either
     failed to  produce gross malformations in offspring or  have
     produced only a slightly increased  incidence  of  gross  mal-
     formations and only at dosage  levels that have also caused
     significant maternal mortality.   However, no-observable-
     effect-levels (NOELs) for maternal  toxicity  and  teratogenic/
     fetotoxic  effects could not be determined from the oral
     studies.   The Agency is, therefore,  unable  to fully assess
     the risks  of teratogenicity/fetotoxicity  from pesticide use.

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          c.  Oral studies for chromium are not available.

     In order to better define teratogenic or fetotoxic effects
for arsenic which may occur below maternally toxic, levels,  the
Agency has required two oral teratology studies; one with rabbits,
the other with hamsters or mice, using sodium arsenate or arsenic
pentoxide (See Special Data Call-in Notice on Wood Preservatives
Containing Inorganic Arsenicals, April 7, 1986).  Further,  the
Agency is requiring oral studies to determine teratogenic and
fetotoxic potential of chromium using a formulated chromated
arsenical product.  (See Data Appendix for due dates of these
studies).

     3.   Due to the Agency's concern about teratogenic/fetotoxic
effects of both chromium and arsenic, it is requiring a
reproduction study using a formulated chromated arsenical
product unless a metabolism study demonstrates that blood levels
of chromium and arsenic are not increased above background levels.

     4.  The Agency does not have adequate data to determine the
bioavailability of chromium and arsenic after exposure to a
formulated product.  Metabolism data are required to assess
the bioavailability of these chemicals.

     5.  Short term assays indicate that hexavalent chromium
and trivalent and pentavalent arsenic are mutagenic.  No
mutagenicity data are being required.

     In addition to the studies noted above, the Agency has
identified ecological effects and environmental fate data
which are needed to evaluate the environmental and human risks
associated with the use of chromated and non-chromated
arsenicals.  These data must be developed in order to maintain
registrations of products or register new products containing
chromated and non-chromated arsenicals.  The table in this
section summarizes all the data gaps, in addition to product
chemistry information.  Please note that this is only a
summary and more details can be obtained by referring to
Tables A, B, and C, Section D of Part II.


     Further, the Agency has determined that labeling revisions
or restrictions in the following areas are necessary:

     0  classification of all uses as restricted, except for
        the commercial brush on use.
     0  protective clothing and equipment requirements.
     e  prohibitions against eating, drinking,  or smoking
        during application.
                               8

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requirements for proper care and disposal of
work clothing and equipment
requirements for proper disposal of pesticide waste.
requirements for using respirators in arsenic pressure
treatment plants when arsenic ambient air levels are
unknown or exceed 10ug/m3 over an 8 hour period
(Permissible Exposure Limit Moonitoring Program).
adherence to industry standards to reduce surface
residues of arsenic on treated wood.
using closed systems for mixing and emptying powdered
formulations of inorganic arsenicals.

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 SUMMARY OF DATA GAPS FOR WOOD PRESERVATIVE PESTICIDE PRODUCTS CONTAINING
 ARSENIC, CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
          ([X]As. [X]Cr.  and [X]CrAs)

 DATA REQUIREMENT                           REMARKS *

 ENVIRONMENTAL FATE

   SPECIAL STUDIES - Aqueous,  soil and  air  [Cr] & [As]
                     availability            applied end use products **

   Aerobic Soil                             [As]
   Anaerobic Aquatic                         "
   Aerobic Aquatic                           "
   Volatility                               [As], [Cr]. & [X]

 TOXICOLOGY

   Acute Oral                               All MPs & EPs
   Acute Dermal                              "   "  "  "
   Acute Inhalation                          "   "  "  "
   Eye Irritation                            "   "  "  "
   Dermal Irritation                         "   "  "  "
   Dermal Sensitization                      "   "  "  "

   Teratology                               Sodium arsenate or
                                            arsenic pentoxide and
                                            Formulated chromated arsenical

   Reproduction                             Formulated chromated arsenical

   General Metabolism                       Formulated chromated arsenical

 WILDLIFE AND AQUATIC ORGANISMS ***

   Avian Oral LD50                          Formulated chromated arsenical
   Avian Dietary ICy)                          "           "        "
   Freshwater Fish LC«jo                        "           "        "
   Freshwater Aquatic Invertebrate LCjQ        "           "        "
   Estuarine and Marine Organism ICy)           "           "        "
   Fish Early Life-Cycle  and Invertebrate       "           "        "
      Life-Cycle

 PRODUCT CHEMISTRY

   Product Identity and Composition         Technicals, MPs & EPs
   Analyis and Certification of Product         "        "     "
      Ingredients
   Physical and Chemical                     Technicals
      Characteristics
"*    Indicates  test material
**  Tests must determine  the availability of Cr &  As  from
     treated wood after application of a formulated chromated  arsenical  product,
*** Additional chronic aquatic testing reserved pending review
    of required acute, subchronic and availability studies

                                   10

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B.  PRELIMINARY RISK ASSESSMENT FOR INORGANIC ARSENIC  AND  CHROMIUM

     1.  INORGANIC ARSENIC

          a.  Risks

          There Is an extensive body of information available
     on the salts and oxides of arsenic from literature and
     other sources.  Therefore, although the Agency does not
     have specific studies on the individual inorganic arsenical
     wood preservative chemicals, it is not requiring additional
     data under FIFRA, in many cases.  This risk assessment
     relies primarily on the OHEA document on inorganic
     arsenic referred to previously.  This and other
     documents mentioned are cited  in the Bibliography
     (Appendix IV).

               (1).  Metabolism

               Arsenic exist* primarily in two different
          valence states, pentavalent (arsenate, +5) and
          trivalent (arsenite, +3).  Of the two, the trivalent
          state is more acutely toxic.  Recent analytical
          techniques which permit the chemical speciation of
          arsenic into its various  forms have elucidated the
          metabolism of arsenic in  the animal body.  Two
          processes, oxidation-reduction and methylation,
          have been indicated as the mechanisms involved.
          These two processes may occur sequentially or
          methylation may be the sole mechanism.  These two
          processes are summarized  below:

                    (a).  An in-vivo oxidation-reduction
               interconversion of pentavalent and trivalent
               inorganic arsenic, with the trivalent form
               predominating.

                    (b).  An in-vivo methylation of inorganic
               arsenic resultTng in the formation of monomethyl
               and dimethyl organic arsenic compounds which
               are subsequently excreted.

               Administration of either pentavalent or  trivalent
          arsenic to experimental animals or humans results
          in the formation of methylated  inorganic  trivalent
          arsenic.  The in vivo methylation process has been
          observed in every mammalian system  studied  to date
          (except in the Marmoset monkey) and is believed  to
          be a detoxification mechanism.  In man about  751
          of the total excreted arsenic is  in the form  of
          dimethyl arsenic.


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     Retention of arsenic in skin, hair, and nails
is regarded as an excretory mechanism into a
physiologically inactive compartment.  Generally,
arsenic does not accumulate in physiologically active
compartments of the mammalian body.  Rats, however,
bind arsenic to erythrocytes which results is delayed
distribution to the tissues.  The biological half-life
of arsenic in rats is up to 90 days as compared to
a biological half-life of several days in other
mammalian species.  For this reason, the rat is not
an appropriate test species to determine potential
effects of arsenic in other mammalian species,
especially humans.

     The major excretory route of arsenic in animals,
including humans, is via the urine.  Renal clearance is
very rapid.

     (2). Oncogenicity

     The Agency has performed an assessment of the
weight-of-evidence for carcinogenicity of inorganic
arsenicals.  Based on epidemiological studies in
humans and on other supportive studies and infor-
mation, it was concluded there is sufficient evidence
that inorganic compounds of arsenic are both lung
and skin carcinogens in humans.  According to the
Agency's draft Guidelines for Carcinogen Risk
Assessment (January 7, 1986) inorganic arsenicals
have been classified in Group A (carcinogenic
to humans).

     A large number of toxicological studies are
available on the oncogenicity of arsenic compounds.
The most critical and persuasive evidence linking
human cancer with exposure to inorganic arsenicals
was derived from epidemiology studies.  An excess
mortality due to lung cancer from exposure to
arsenic was demonstrated in several studies of
smelter workers and among workers engaged in the
production of arsenical pesticides.  The  increased
mortality in these studies was related to occupa-
tional inhalation exposure to inorganic arsenicals.

     A final risk model for occupational  inhalation
exposure was based on three studies of copper
smelter workers and on an NCI series of statistical
analyses of some of these same workers.
                  12

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     (a).  Higgins. 
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     Other human epidemiology studies have demonstrated
an association between skin cancer in non-occupational
populations and high levels of arsenic in drinking
water.  Persons exposed to arsenicals in medicines
have also been shown to be at risk.  The Agency has
prepared a risk model for oral exposure to inorganic
arsenicals based on an epidemiology study of skin
cancer in a section of Taiwan with high arsenic
concentrations in well water (Tseng et al., 1968).

     The Agency's Risk Assessment Forum, an Agency-
wide task group charged with assessing risk issues,
has completed its reevaluation of this risk model
for exposure via the dermal and oral routes.  Their
report is expected to be released this summer.   The
availability of it will be published in the Federal
Register.

     In contrast to the clear association between
inorganic arsenicals and cancer in humans, arsenic
carcinogenicity in test animals has not been observed
in most studies.  A few recent reports have noted
positive results.  Studies in species other than
rats have generally shown negative findings.  The
OHEA document (pp. 7-77 to 7-87) summarizes 32
studies using test animals, in which the majority of
studies (25) were either negative or inconclusive.
Given the extensive amount of information on human
exposures, the Agency is not requiring additional
oncogenicity studies.

     (3).  Mutagenicity

     Providing support to the carcinogenic finding
are results from numerous mutagenic and other
gentoxic assays.  The weight of evidence indicates
that arsenate and arsenite can interact with DNA
in mammalian somatic and gonadal cells and there-
fore may have the potential to cause heritable
effects in humans.

     Observed positive effects in various assays
have included chromosome-breaking effects, inter-
ference with DNA repair mechanisms, direct toxicity
to mammalian gonads, and positive effects in selected
microbial test systems for rautagenicity.

     The Agency concludes from the available data,
that inorganic arsenicals, administered  in either
the pentavalent or trivalent form, may  induce
chromosomal aberrations in vitro.  This  effect has
been shown in human fibroFlast cells, Syrian hamster
embryo cells, and human peripheral lymphocytes.
Results for some studies are dose-related,  and
arsenites are more potent than arsenates  in  the


                 14

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 induction of chromosomal aberrations in cultured
 mammalian cells.   In addition, among lymphocytes
 cultured from exposed workers  (or from patients
 undergoing  treatment with medicinal arsenicals)
 there  is suggestive evidence of chromosomal damage
 by  arsenic  iri vivo.  Furthermore, inorganic arsenic
 may potentiate the effects of  chromosome-damaging
 agents  (Sram, 1976; T.C. Lee,  et al., 1986).

     A dominant lethal test conducted by Sram and
 Bencko  (1974), indicated that  inorganic arsenic
 reached the germ cells (gonads) and produced mutagenic
 effects in  mammals.  Further,  studies by Petres et al.
 (1970,  1977) suggest that human exposure to arsenic
 can cause chromosomal aberrations and aneuploidy
 in  humans in vivo.

     (4). Teratogenicity/Fetotoxicity

     The potential of inorganic arsenic to produce
 teratogenic effects through parenteral exposure is
 established.  Parenteral administration of sodium
 arsenate (+5) or sodium arsenite (+3) to experimental
 animals during pregnancy has produced gross malformations
 (terata) in the offspring.  Increased mortality, in-
 creased resorptions, and decreased body weights of
 fetuses have also  been observed in these studies.

     In contrast,  oral (gavage) administration of
 sodium  arsenate or arsenite to experimental animals
 has  either  failed  to produce gross malformations in
 offspring or has produced only a slightly  increased
 incidence and only at dosage levels that have also
 caused  significant maternal mortality.  NOELs could
 not  be  established for these studies.  Oral adminis-
 tration of  sodium  arsenite to  experimental animals
 yielded almost identical results to those  for
 sodium  arsenate although at somewhat lower dosage
 levels.

     Intravenous and intraperitoneal administration
 are  not typical of the exposure likely from pesticide
 use.  The available oral studies do not fulfill
 Agency  requirements, and do not demonstrate conclusively
 that inorganic arsenicals are  teratogenic  or fetotoxic
 by  the  oral route  of exposure  (except at levels also
 showing maternal effects).  Therefore, the Agency
 is currently unable to assess  the risks of
 teratogenicity/fetotoxicity likely from pesticide
use of  chroraated and non-chromated arsenicals.
Additional  studies have been required to assess
 teratogenic risks.  (See Special Data Call-In Notice
on Wood Preservatives Containing inorganic Arsenicals,
April 7, 1986).
                    15

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           (c).  Arsenic can cross the placental
     barrier  and has been incriminated in neonatal
     deaths  (Gosselin et al, 1984).  Human epidem-
     iological studies have implicated arsenic as a
     teratogen.  Increased spontaneous abortions
     and decreased mean birthweights of offspring
     were  reported among female workers employed in
     a smelter in Sweden.  These women were exposed
     not only to arsenic, however, but also to a
     variety  of diverse chemicals in the smelter
     (OHEA,  1984).

     (5).  Reproductive effects

     There are insufficient data to assess the
effects of inorganic arsenicals upon reproductive
functions.   In light of the Agency's concern about
possible teratogenic/fetotoxic effects of
arsenicals,  a reproduction study is required.

     (6).  Acute toxicity

     The acute oral toxicity of inorganic arsenicals
in humans has been well documented over centuries
of use as a  poison in homicides, suicides, and from
accidental ingestion of drugs and pesticides.  The
pentavalent  forms are less toxic than the trivalent
ones; however, both forms are classified as Toxicity
Category I (the Agency's highest acute toxicity
category) and the symptoms of toxicity are the
same.  The reported oral toxicity of arsenic acid
in rats is 48-100 mg/kg, however, the rat is a
poor model for toxicity in man, since it binds
arsenic in the body.  Man appears to be more sensitive
to arsenic poisoning on a dose per weight basis
than the rat.  Acute oral, dermal, and inhalation
toxicity data are required.  In addition, eye and
dermal irritation and dermal sensitization data are
required.  All acute studies must be conducted on
each manufacturing use product and end-use product.

     (7).  Neurotoxicity

     Arsenic  is known to cause neurotoxic effects
in humans.  The expression of severity of effects  is
dependent upon the type and duration of exposure.
Acute and subchronic exposures typically lead to
peripheral neuropathy, distal muscle weakness and
loss of sensation, which may progress to paralysis
and crippling.  Lower exposures and chronic  exposures
generally have a more gradual onset of similar
symptoms.
                      16

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     (8).  Other observed effects  in humans

     Other chronic and subchronic  effects  of
inorganic arsenicals that have been observed in humans
include:

     0  Skin toxicity, resulting in hyperpigmentation
        and disorders such as  eczema,  redness,  keratosis,
        loss of nails, and swelling, which are  reversible
        if exposure ceases.

     0  Toxicity to the blood  system,  resulting in
        blood dyscrasias of various forms, also is
        reversible if exposure ceases.

     0  Liver and kidney toxicity,  with jaundice,
        degeneration of the tissues, and cirrhosis.

     0  Pulmonary system effects,  perforation of the
        nasal septum, and tracheal and bronchial effects.

     (9).  Risks

     The following risk estimates  were extracted from
the OHEA report on inorganic arsenic.

          (a).  The inhalation oncogenic risk of arsenic
     was based on epideraiological  studies  of copper
     smelter workers (Higgins  et al.,  Lee-Feldstein,
     Enterline and Marsh, and  three series of analyses
     by Brown and Chu).  The final risk was  estimated
     to be 4.1  X 10~3 for workers  in pressure treatment
     plants based on an assumed exposure of 10  ug/m^
     inorganic arsenic levels  in the air averaged  over
     an 8 hour workday.

          (b).   The potential  risks of skin cancer from
     dermal and oral (gastro-intestinal) exposure to
     arsenic were estimated using a risk equation based
     on the epidemiological study of skin cancer in
     more than 40,000 people in a section of Taiwan
     with high concentrations  of arsenic in  the well
     water (Tseng et al.).  The Agency Risk Assessment
     Forum is currently reevaluating this  risk  model
     to be used for exposure via the oral  and dermal
     routes.   The report is expected to be released
     this  summer.
                    17

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          However, based on this risk model the dermal risk
          estimates were:

               i.  2.8 X 10"3 for brush on applications
          of arsenic.

               ii.  6.2 X 10-3 for handling freshly
          treated wood and mixing dilute formulations, and

               iii.  7.3 X 10*3 for bag emptying.

          The oral (gastrointestinal) risk from sawing/
          fabricating treated wood was estimated to be:

               i.  3.1 X 10-4 (copper chromated
          arsenate) and

               ii.  7.6 X 10~4 (ammoniacal chromated
          arsenate).

     Regulatory measures (respirators, protective clothing.
closed systems) required as part of the Special Review
will reduce risks to the orders of 10*4 to 10"5.
This level of risk does not outweigh the benefits of
continued registration of these products.
                         18

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2.   CHROMIUM

     a.  Risks

     The toxicity of chromium has been discussed  in
detail in the Health Assessment Document for Chromium.
This document includes a risk assessment for the
carcinogenicity of chromium compounds  and is the  sole
reference for the following discussion of chromium.

          (1).  Essentiality of Chromium and its
                Metabolism

          Chromium exists in several valence states.
     Only the trivalent and hexavalent forms of
     chromium are biologically significant.

          Trivalent chromium is an essential element
     in animals including humans.  It  plays  a role in
     glucose and lipid metabolism.   Chromium supplemen-
     tation improves or normalizes glucose tolerance  in
     diabetics, older people, and malnourished children.
     It has been suggested that chromium deficiency may
     be a basic factor in atherosclerosis.   A deficiency
     of trivalent chromium apparently  increases  the
     toxicity of lead.

          Although the exact level of  chromium needed
     for good health is unknown, it is assumed that an
     average American intake of 0.05 to 0.2  mg/day
     is adequate.

          Trivalent chromium transport in the blood
     is facilitated by specific binding proteins.
     Hexavalent chromium, on entering  the blood  stream,
     diffuses into the blood cells where reduction
     and binding to cellular components occurs.   Absorbed
     trivalent and hexavalent chromium can be transported
     to a limited extent to the fetus  in utero after
     exposures of the dams, although ejclsting" data do
     not allow quantitative estimations of fetal exposure,
     Chromium transported by the blood is distributed  to
     other organs with greatest retention by the spleen,
     liver, and bone marrow.  The major deposition site
     following inhalation exposure is  the lungs,  where
     chromium probably binds to the cellular material
     before absorption can occur.
                          19

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     Absorbed chromium is rapidly cleared  from  the
blood while clearance from tissue is  slower.
Urinary excretion is the primary route of  elimination
accounting for somewhat over 50% of the eliminated
chromium.  Fecal excretion accounts for only  5% of
the elimination from the blood.   The  remaining  chromium
is deposited within the body.  Limited work on
modeling the absorption and deposition of  chromium
indicates that adipose and muscle tissue retains
chromium at a moderate level (approximately two
weeks), while the liver and spleen store chromium
for up to 12 months.  Estimated half-lives for
whole body chromium elimination are 22 days and 92
days for hexavalent chromium and trivalent chromium,
respectively.

     (2).  Oncogenicity

     According to the Agency's draft  Guidelines for
Carcinogen Risk Assessment (49 FR 46294) ,  and based
on combined animal studies and human  epidemiological
data, hexavalent chromium is classified in Group A
(carcinogenic to humans).

           a.  Epidemiological studies of  chromate
     production facilities in the United States, Great
     Britain, West Germany, and Japan have all  found  an
     association between occupational exposure  to
     chromium and lung cancer and are sufficient evidence
     of the carcinogenicity of chromium.   Workers in
     the chromate production industry are  exposed
     to both trivalent chromium (+3)  and hexavalent
     chromium (+6) compounds.  Most of the epidemiologic
     studies did not attempt to determine  which chromium
     compounds were the etiologic agents.

          The strength of the association  of  exposure
     in the chromate production industry with lung
     cancer is evidenced by the high lung  cancer
     mortality ratios found in various studies.
     the consistency of results by different  investi-
     gators in different countries, the dose-response
     found In several studies, and the specificity
     of the tumor site, the lung.  The magnitude
     of the mortality ratios found in several
     studies (studies of three independent cohorts of
     chromate production workers found lung cancer
     mortality ratios of at least 9.5 or greater) lends
     strong support to the association between
     exposure in the chromate production  industry
     with lung cancer.
                   20

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     The best data that can be used for estimating
cancer risks due to exposure to chromium compounds
are found in the study by Mancuso (1975).  In that
study. Mancuso reported age-specific lung cancer
mortality data for chromate production workers in
terms of total chromium exposure, which included
exposure to both trivalenfc and hexavalent
chromium compounds.  Available data, discussed
below, suggest that only hexavalent chromium
compounds are carcinogenic.

     b.   Although increased risk of lung cancer
has been associated with inhalation of chromium by
workers in the chromium industry, as discussed
below, it has proven difficult to demonstrate
a carcinogenic response in the lungs of experimental
animals.

     Trivalent chromium compounds have not produced
lung tumors after inhalation (in mice or rats),
intratracheal implantation (in mice), or intra-
pleural implantation (in mice).  Hexavalent
chromium was not carcinogenic by inhalation
(in mice or rats) or intratracheal instillation
(in mice or rats).  Some hexavalent chromium
compounds did produce tumors following intra-
bronchial or intrapleural implantation (in
rats); however, the number of animals (14)
was small in the study of calcium chromate
(Hueper and Payne, 1962).  Furthermore, the report
of Hueper (1961) , where a number of hexavalent
chromium compounds were reported to be carcinogenic,
lacked detailed information.  The combination of
problems with these two studies make it difficult
to evaluate the potential carcinogenicity of
these compounds to rodent respiratory tissue.

     For these reasons, studies of respiratory
cancer in animals do not provide substantial
confirmation of lung cancer.  However, the
limited data suggest that of the two valences.
hexavalent chromium is more likely to be the
etiologic agent in chromium-induced cancer.

     Hexavalent chromium has produced implant-
ation site tumors in rats following intramuscular
implantation, while trivalent and metallic
chromium compounds have not.  The relevance
of studies using intramuscular implantation
to human risks following inhalation or oral
exposure to chromium compounds is not clear;
however, these animal studies again indicate
that some hexavalent chromium compounds are
likely to be the etiologic agent in human
chromium-related cancer.


              21

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               Trivalent chromium has been tested for
          carcinogenicity by the oral route in rats and
          mice with no significant increase in tumors
          in treated animals as compared with controls.
          These studies have not been reported in detail.

               No additional oncogenicity data are required.


          3.  Mutagenicity

     The valence state of chromium is an important factor  in
producing a mutagenic response in the Ames assay.  Only
hexavalent chromium has consistently demonstrated positive
mutagenic activity in Salmonella typhimurium in the absence
of metabolic activatiorTiAfter metabolic activation, however.
the chromium shows only marginal, if any. mutagenic activity.
This suggests that the mammalian enzymes or cofactors in
the activation system reduced hexavalent chromium to trivalent
chromium.  Although these studies show that hexavalent
chromium compounds produce a positive response, they do not
indicate whether hexavalent or trivalent chromium is the
ultimate mutagen which interacts with the DNA of the cell.

     Both trivalent chromium and hexavalent chromium have
been demonstrated to interact with DNA in bacterial assays,
and hexavalent chromium has inhibited DNA synthesis and
increased unscheduled DNA synthesis in mammalian cells
in culture.

     In in vitro studies, both trivalent and hexavalent
chromium~~h~ave increased the infidelity of DNA replication.
As observed with interaction with DNA, both valences of
chromium have been demonstrated to produce clastogenic
effects (chromosome breaking) in mammalian cells with
hexavalent chromium being more active than trivalent chromium.
The effects observed included a variety of chromosomal
aberrations, sister chromatid exchange, and the appearance
of micronuclei in polychromatic erythrocytes.

     Increased chromosomal damage also has been observed  in
human lymphocytes cultured from subjects occupationally
exposed to chromium.

     For all the observed genotoxic effects, it has been
suggested that trivalent chromium may be the predominant
intracellular species as a result of the reduction of
absorbed hexavalent chromium by cellular components.

     No additional mutagenicity data are required.
                        22

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      4.   Teratogenicity and  Reproductive effects

      Chromium has  adversely  affected fetal development
 and male reproduction in experimental animals.

      Hamsters administered chromium trioxide intravenously
 on day 8 of gestation had an increased  incidence of cleft
 palates  in the young  when examined on day 15 of gestation.
 The malformations  were strain specific  and associated
 with maternal toxicity.

      Studies on the mouse indicated that while some
 skeletal effects were present,  increased incidence of
 cleft palate or fetal death  were not observed.  While
 several  of the studies reported fetal malformations
 only where maternal toxicity was also present, not all
 studies  reported data on maternal effects, so definitive
 conclusions concerning the correlation  between fetal
 and maternal effects  cannot  be made at  this time.

      Reproductive  effects of chromium include testicular
 degeneration in rabbits  receiving 2 mg/kg/day for 6 weeks
 of either trivalent or hexavalent chromium compounds by
 intraperitoneal injection.   The trivalent chromium compound
 produced more severe  effects in this study than did the
 hexavalent chromium compound (Behari et al., 1978).

      The relevance of the observed effects in both the
 teratology and reproduction  studies to  effects observed
 after environmental exposure is questionable since the
 routes of exposure in these  studies were not typical routes
 of exposure in humans.  Therefore oral  teratology and
 reproduction studies  using a formulated chromated arsenical
 product  are being  required.

      5.   Acute toxicity

      a.   Trivalent chromium  compounds have a very low
 order of toxicity  when administered orally.  Oral 1050
 values for the rat have been reported as follows:
 chromic  chloride.  1.87 g/kg;  chromium acetate,  11.26 g/kg;
 chromium nitrate,  3.25 g/kg  (Smyth et al., 1969).
 Kobayashi et al. (1976)  have determined oral LD$Q for
 chromium trioxide  in  mice and rats to be 135 to 177 mg/kg
 and  80 to 114 mg/kg,  respectively, with death occurring
 between  3 to 35 hours.  Symptomatology  included
 diarrhea,  cyanosis, tail necrosis, and  gastric ulcer.
 Surviving animals  showed increases in liver and testes
weight without microscopic changes.

      b.   Hexavalent chromium is more acutely toxic than
 trivalent chromium.   A primary effect of acute exposures is
kidney failure.  Oral administration of high doses results
 in gastric corrosion.  The oral LD50 °f*?illu?0?^hroniate ln
humans has been reported as  50 rag/kg (NIOSH. iy/y;.


                             23

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     c.  Numerous investigators have demonstrated that
sensitization of laboratory animals (guinea pigs) can be
produced by exposure to various chromium compounds,  including
both hexavalent and trivalent chromium.

     Acute oral, dermal and inhalation toxicity data are
required.  In addition, eye and dermal irritation and dermal
sensitization data are required.  All acute studies  must be
conducted on each manufacturing-use product and end-use product

     6.  Other observed effects in humans

     Occupational exposure to chromium compounds, mainly
through inhalation, causes dermatitis, penetrating ulcers
on hands and forearms, perforation of nasal septum,  and
inflammation of the larnyx and liver.  The dermatitis
is probably due to an allergic response; persons sensitive
to hexavalent chromium also respond to trivalent chromium.
The ulcers are believed to be due to chromate ion and not
metalic chromium.  Chromic acid, and to a lesser extent,
chromate, are presumably the causative agents in perforation
of the nasal septum.

     7.  Risks

     A number of epidemiologic studies have found an
association between exposure to chromium compounds and
lung cancer.  The best data that can be used, however,
for estimating cancer risks due to exposure to chormium
compounds are found in the study by Mancuso (1975).
That study reported age-specific lung cancer mortality
data for chroraate production workers in terms of total
chromium exposure (i.e., exposure to both trivalent and
hexavalent chromium combined).

     As noted previously, available data suggest that
only hexavalent chromium compounds are carcinogenic.
Thus, a risk estimate based on total chromium exposure
will underestimate the risk due to hexavalent chromium
alone.  In another study (Bourne and Yee, 1950), the
ratio of trivalent to hexavalent chromium in airborne
dust was determined in the plant's nine major departments.
The ratio ranged from 1 to 3 in seven of the departments;
was 6 for the lime and ash operation, and was as high
as 52 for ore preparation.  Therefore, excluding ore
preparation, the maximum ratio of trivalent to hexavalent
chromium is 6, and thus the underestimation of the risk
would not be more than sevenfold.
                       24

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     The lifetime cancer unit risk calculated  by the
Agency from the Mancuso (1975)  data was determined  to  be
1.2 x 10~2 based on exposure to ambient air levels
containing Iug/m3 of total chromium.

     Assuming that the ratio of trivalent to hexavalent
chromium is 6:1, the Agency's risk estimate may under-
estimate the risk from hexavalent chromium by sevenfold.
However, other factors such as  use of 1949 hygiene  data
to determine worker exposure and implicit assumptions
that the smoking habits of chromate workers are similar
to those of the general white male population may result
in overestimation of the risk by four times.

     On balance, the estimate based on the Mancuso  data
is judged to be the best possible estimate of the risk
from hexavalent chromium.

     It is possible to estimate potential inhalation
exposure of wood treatment workers to chromium, based
on the ratio of chromium to arsenic in formulated
products.  This ratio has been calculated to be .96 or
approximately 1:1.

     If the bioavailability of chromium is similar  to
that of arsenic, the risk from .the use of chromium in
formulated wood preservative products will be the same
order of magnitude as the risk from the use of arsenic
in formulated wood preservative products.  However, the
relative bioavailability of these two constituents,
administered together as formulated wood preservative
products, is not fully known.  The Agency is requiring
data to determine the relative bioavailability.
                         25

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C. OTHER SCIENCE ASSESSMENTS

     1.   Toxlcity to fish and wildlife.

          Data needed to fully assess  the toxicity of
     chromated and non-chromated arsenicals  to birds are
     not available.  Based on avian dietary  studies in
     mallard duck and bobwhite quail,  copper chromated
     arsenicals can be characterized as at least  slightly
     toxic to avian wildlife on a subacute basis.
     LC50S of greater than 4640 ppm (CCA) were reported
     for both bobwhite quail and mallard  duck.

          The toxicity of copper chromated arsenicals
     to freshwater fish varies widely. The  compound
     was reported to be highly toxic to rainbow  trout
     (LC5Q * .84 ppm) but only slightly toxic to
     bluegill sunfish (LC^Q - 90.2ppra).  Chromium
     LC5QS for freshwater fish have been  shown  to
     be in the range of 17 to 118 ppm. Additional
     studies will have to be submitted before the Agency
     can determine whether these values are  reliable.
          No evaluation of the acute toxicity of chromated
     arsenicals to freshwater aquatic invertebrates can
     be made at this time.  Chromium LC5QS for Daphnia
     have been reported to be approximately 0.05 ppm.

     2.   Endangered species

          A hazard assessment to endangered species
     can not be made until the aquatic availability
     studies required under this standard are submitted.
     These studies will indicate whether or not the
     amount of [Cr], [As]  . and additional ions which
     leach out of treated wood into the soil and water
     is high enough to pose a threat to endangered
     species.

     3.   Environmental Fate

          The Agency lacks data to characterize the
     environmental fate of chromium and arsenic formulated
     as chromated arsenicals.  The Agency is requiring
     studies to determine the availability of chromium
     and arsenic from treated wood to both soil and aquatic
     media.  Results of these studies will determine
     whether additional environmental fate data will be
     required.
                          26

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                IV.  REGULATORY DETERMINATIONS

A.  REGULATORY POSITIONS AND RATIONALES

     Based on review and evaluation of all available data
and other relevant information on chromium and arsenic,
the Agency has made the following determinations:

1.   The Agency will not. at this time, initiate a Special
     Review [40 CFR Part 154 (previously 40 CFR 162.11)] on
     the wood preservative uses of inorganic arsenical or
     chromium compounds.

     Rationale:  Inorganic arsenicals were placed in Special
     Review by the Agency in October, 1978 due to suspected
     oncogenic, mutagenic, and teratogenic/fetotoxic effects.
     The Special Review resulted in the Agency's determination
     that inorganic arsenicals are mutagenic.  The Special
     Review also resulted in the classification of inorganic
     arsenicals as Group A oncogens (See Preliminary Risk Assess-
     ment, and the Agency's Draft Guidelines for Carcinogenic
     Risk Assessment, January 7, 1986).  The Agency further
     determined that requirements for protective measures
     and restrictions would reduce exposure and risk to
     levels that are outweighed by the benefits of these
     compounds.  The Special Review also resulted in the
     determination that teratogenicity data for inorganic
     arsenic are inadequate and replacement studies were
     required through a Data Call-in letter dated April 7,
     1986.  Once the appropriate data are received, the
     Agency can reassess the potential for inorganic arsenicals
     to result in  teratogenic effects.

     There is an established association between hexavalent
     chromium and  carcinogenicity in humans.  Chromium has been
     classified as a Group A oncogen and has also been shown
     to be mutagenic in short term assays.  Both the potency
     of, and the exposure to chromium from wood preserving
     uses, are expected to approximate those for inorganic
     arsenicals and the risks from each are of the same order
     of magnitude.  Further, the protective measures imposed
     as a result of the Special Review on workers using
     inorganic arsenical wood preservatives (most of which
     contain chromium) are expected to reduce exposure  from
     chromium as well and result in reductions in risk  of the
     same order of magnitude.  Therefore, the Agency is not,
     at this time, placing chromium into Special Review.
                              27

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2.   The Agency is maintaining the Restricted Use classification
     which was imposed as a result of the Special Review.   The
     Restricted Use classification applies to all wood preser-
     vative uses of arsenic, chromium and chromated arsenical
     compounds except the commercial construction brush-on use.

     Rationale;  Inorganic arsenicals and chromium have been
     demonstrated to cause carcinogenicity in humans by the
     inhalation route of exposure.  The Agency believes that, to
     minimize the risks to users of chromated arsenicals,  use
     should be limited to persons who have been trained in proper
     use procedures and exposure reduction measures.  The  Agency
     decided not to require the commercial brush on uses to be
     restricted to certified applicators in favor of labeling
     which would require use only in commercial applications
     for cut ends of pressure treated wood.  The Special Review
     Final determination, referred to on page 5 of this document,
     provides additional details.

3.   The Agency is maintaining all other measures and restrictions
     resulting from the Special Review as well.

     Rationale; Among the other requirements imposed as a  result
     of the Special Review were protective clothing and
     equipment requirements; the requirement to limit visible
     surface residues on treated wood; the requirement for
     the use of closed systems for emptying and mixing powder
     formulations; and the requirement to use respirators
     unless monitoring shows arsenic air levels to be below
     10ug/m3 (See Section IV D, Required Labeling ).  These
     measures and restrictions are necessary to reduce exposure
     of persons who are treating wood with inorganic arsenicals.

4.   The Agency is not, at this time, placing any regulatory re-
     quirements or restrictions on use of the treated wood itself.

     Rationale: Risk from exposure to treated wood itself is
     expected to be less significant than that resulting from
     exposure to the wood preservative chemicals prior to
     application.  This is due to the fact that the wood
     preservative chemicals are bound to the wood and have only
     limited availability from the wood after treatment.

     Nonetheless, as part of a settlement agreement with the
     Agency, the wood preserving  industry has instituted a
     voluntary consumer awareness program designed to  inform
     users of treated wood of proper uses and handling precautions
     (See Appendix II).  If the Agency determines,  in  the
     future, that risks from use of treated wood are higher
     than believed, regulatory requirements or restrictions
     will be considered.
                              28

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5.   The Agency is requiring an air monitoring study to deter-
     mine the potential exposure to chromium under conditions
     found within wood treating plants.  The study must also
     determine the relative chromium/arsenic ratio found in
     the air samples.

     Rationale:  Due to the oncogenic potential and other
     toxicological concerns of the various component of the
     chromated and non-chromated inorganic arsenicals,  in-plant,
     on-site measurements of the ambient airborne levels of
     arsenic and chromium from treating mixtures is required.
     These data will allow the Agency to determine whether the
     potential exposure to chromium in wood treating plants
     poses more significant concern than that previously described
     in this document due to exposure to arsenic.  These data
     may also allow the Agency to calculate airborne chromium
     levels based on the arsenic levels found from the  ongoing
     monitoring required as a result of the Special Review,
     thus potentially alleviating the need for future chromium
     monitoring.

6.   The Agency is requiring teratology and reproduction studies
     using a representative chromated arsenical formulation
     unless the required metabolism study demonstrates  that
     blood levels of chromium and arsenic, after exposure to
     the formulated product, are not increased above background
     levels.

     Rationale:  Current information regarding the bioavaila-
     bility of chromium and arsenic after exposure to formulated
     chromated arsenical wood preservatives is inadequate.
     The current assumption is that chromium blood levels do
     not increase beyond background levels.  The metabolism
     data will allow the Agency to determine whether this
     assumption is correct.  The metabolism, teratology, and
     reproduction studies must be conducted using a test
     species other than the rat since the rat is known to be
     anomalous to humans with respect to metabolism of arsenic.

7.   The Agency is deferring a decision regarding the need
     for many of the environmental fate studies normally
     required.  The Agency will determine the need for these
     environmental fate studies after special availability
     studies (in aqueous and soil media) for end use products
     are submitted and reviewed.

     Rationale:   There is inadequate information on the
     amount  of the formulated product which actually is
     available to aqueous or soil media from treated wood.
     Therefore,  the Agency is requiring testing to determine
     the quantity, form, and valence of each component  of
     the chromated and non-chroraated arsenicals which is
     available to these media from commercially treated wood.

                             29

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     If these studies indicate that the concentration of
     arsenic, chromium, or the additional ions combined
     together in the formulated product, is high enough
     to cause concern, the Agency may require additional
     environmental fate data for arsenic, chromium,  or the
     additional ions.

 8.  Chronic aquatic testing may be required depending on the
     outcome of (1) acute and subchronic aquatic organism
     testing, (2) aqueous and soil availability studies, and
     (3) the Agency's resultant hazard assessment.

     Rationale;  The uses of treated wood (as pilings and in
     the construction of boat docks and bridges) may allow a
     continuous release of chromium and arsenic into aquatic
     environments.  As a result, aquatic organisms  are likely
     to be exposed to chromium and arsenic ions.  The amount
     of release over time to the aquatic environment from
     these uses is not yet known.  If acute, subchronic, and
     availability data indicate that exposure may be significant
     over extended periods of time, data may be required to
     determine whether there are long term effects  to aquatic
     organisms.

9-   The Agency cannot assess the hazard to endangered species
     from use of treated wood at this time.

     Rationale:  In order to determine potential exposure to
     endangered species, the aquatic organism data and
     special availability studies discussed in regulatory
     positions 7 and 8 in addition to acute avian studies
     must be submitted and reviewed.  A full hazard assessment
     will be conducted when these data are received.

10.  In addition to the product chemistry data traditionally
     required for manufacturing-use and technical products,
     the Agency is requiring that the source and description
     of arsenic, chromium, and other active ingredients in
     the formulated end-use products be submitted to the
     Agency.

     Rationale!  Arsenic and chromium are commodity chemicals
     with many non-pesticidal uses.  Frequently, active
     ingredients incorporated into formulated products are
     not registered for manufacturing-use and the chemical
     characteristics of each product are unknown.  These data
     will allow the Agency to determine these characteristics
     for the individual products.
                              30

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11.  While the data gaps are being filled, currently registered
     manufacturing use products (MPs)  and end-use products (EPs)
     containing as sole actives or multiple actives, the chemicals
     subject to this Registration Standard, may be sold, distri-
     buted, formulated and used, subject-to the terms and con-
     ditions specified in this Standard.   Registrants must pro-
     vide or agree to develop additional  data, as specified in
     the Data Appendices, in order to maintain existing
     registrations.

     Rationale:  Section 6 of the Federal Insecticide, Fungicide,
     and Rodenticide Act (FIFRA) as amended, authorizes the
     Admini-strator to cancel a pesticide  registration if he
     determines that the pesticide will cause unreasonable adverse
     effects on the environmentl.  Based  on available data, the
     Administrator has not made such a determination as to
     chromated and non-chromated arsenical wood preservatives.
     The Administrator has authority under FIFRA sections
     3(c)(2)(B) and 3(c)(7)) to require registrants and
     applicants for registration to provide data needed to
     support new or continuing registrations.

          Issuance of this Standard provides a mechanism for
     identifying data needs.  These data  will be reviewed and
     evaluated and the Agency will determine if the data
     will affect the registration of chromated and non-chromated
     arsenical wood preservatives.
                             31

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B.  CRITERIA FOR REGISTRATION

   To be registered or reregistered under this Standard,  pro-
ducts must contain arsenic and/or chromium,  bear required
labeling, and conform to the product composition, acute toxicity
limits, and use pattern requirements listed  in this section.

C.  ACCEPTABLE RANGES AND LIMITS

     1. Product Composition Standard

     To be registered or reregistered under  this Standard,
manufacturing-use products (MPs) must contain arsenic and/or
chromium.  Each MP formulation proposed for  registration must
be fully described with an appropriate certification of limits,
stating maximum and minimum amounts of the active ingredient
and inert ingredients which are present in products, as well
as impurities found at greater than 0.1%.

     2. Acute Toxicity Limits

     The Agency will consider registration of technical grade  and
manufacturing-use products containing arsenic and/or chromium
provided that the product labeling bears appropriate precaution-
ary statements for the acute toxicity category in which each
product is placed.

     3. Use Patterns

     To be registered under this Standard, manufacturing-use
products may be labeled for formulation into end-use products
only for the commodities listed below.  The EPA Index to
Pesticide Chemicals lists all registered uses, as well as
approved maximum application rates and frequencies.

         -Terrestrial, non-domestic, non-food uses on wood.
                            32

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D.  REQUIRED LABELING

     In order to remain in compliance with FIFRA, manufacturing
use products (and end-use products, if covered by Standard)
must bear appropriate labeling as specified in 40 CFR 162.10.
Appendix II contains information on label requirements.

     No pesticide product registered for use as a wood preser-
vative and containing arsenic, chromium or chromated arsenical
compounds may be released for shipment by the registrant after
June 30, 1989 unless the product bears an amended label which
complies with the requirements of this Standard.

     No pesticide product registered for use as a wood preser-
vative and containing arsenic, chromium or chromated arsenical
compounds may be distributed, sold, offered for sale, held
for sale, shipped, delivered for shipment, or received and
(having been so received) delivered or offered to be delivered
by any person after June 30, 1990 unless the product bears
an amended label which complies with the requirements of
this Standard.

     The following specific information must appear on the
labeling in order for products to remain in compliance with
FIFRA:

     1.  Ingredient Statement

     The ingredient statement for products must list the percent-
age of each component used in the formulation of the arsenic,
chromium or chromated arsenical compound which contributes to
the pesticidal activity of the product in the following manner
(examples) :

     Active Ingredients:
        "Arsenic Pentoxide [As2C>5] 	 XX %";
        "Chromic Acid [CrOaJ       	 XX %";
     Inert Ingredients
     Total                         	 100%

       Total arsenic, all in water soluble form expressed as
       metallic 	.

     2.  Manufacturing Use Products

          a.  Use Pattern Statement

               All manufacturing-use products must state that
they are intended for formulation into end-use products for
wood preservation.

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          b.   Ecological Hazard Statement

               All manufacturing-use products must bear the
following ecological hazard statement:

               "This pesticide is toxic to fish.   Do not
discharge effluent containing this product into lakes, streams,
ponds, estuaries, oceans or public water unless this product
is specifically identified and addressed in an NPDES permit.
Do not discharge effluent to sewer systems without previously
notifying the sewage treatment plant authority.  For guidance,
contact your State Water Board or regional office of EPA."

     3.   All End-Use Products;  The following statements
must appear on the labeling of all end use products subject
to this Registration Standard.

          a.   Ingredient Statement

               The ingredient statement for end-use products
must list the percentage of each component used in the
formulation of the chromated or non-chromated arsenical
which contributes to the pesticidal activity of the product.

          b.   Use Pattern Statement

               All end-use products must be labeled for wood
preservation.  Labeling must specify sites, which are listed
in Use Patterns, Section C.3.  However, no use may be included
on the label where the registrant fails to agree to comply
with the data requirements in the Data Appendices for
that use pattern.

     4.   End Use Products Labeled for Pressure Treatment
of Wood;  In addition to the statement in  (2)above, the
following statements must appear on end use products subject
to this registration standard and which are labeled for
pressure treatment of wood

          a.   Restricted Use Statement

              "RESTRICTED USE PESTICIDE"

              "Due to Oncogenicity"

              "For sale to and use only by certified applicators
or by persons under their direct supervision and only  for
those uses covered by the certified applicators' certification.
                           34

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              "Use of this product may be hazardous to your health.
This product contains arsenic and/or chromium compounds which
have been determined to cause tumors in humans.  Risks can be
reduced by closely following the use directions and precautions,
and by properly using the protective clothing and equipment
listed elsewhere on the label."

              "Applicators must wear gloves impervious to
the wood treatment formulation in all situations where
dermal contact is expected (e.g., handling freshly treated
wood and manually opening cylinder doors). "

          b.   Personal Protective Equipment Statement

               "Individiials who enter pressure treatment
cylinders and other related equipment that is contaminated
with the wood treatment solution (e.g., cylinders that are in
operation or are not free of the treatment solution) must
wear protective clothing, including overalls, jacket, gloves,
and boots, impervious to the wood treatment formulation.  In
addition, individuals who enter pressure-treatment cylinders
must wear properly fitting, well-maintained, high efficiency.
filter respirators (MSHA/NIOSH-approved for inorganic arsenic)
if the level of inorganic arsenic in the plant is unknown or
exeeds 10 micrograras per cubic meter of air (10ug/m3) averaged
over an 8-hour work period."

               "Protective clothing must be changed when it
shows signs of contamination.  Applicators must leave protective
clothing and workshoes or boots and equipment at the plant.
Worn-out protective clothing and workshoes or boots must be
left at the plant and disposed of in a manner approved for
pesticide disposal and in accordance with state and federal
regulations."

               "Individuals in the work area of an arsenical
wood treatment plant must wear properly fitting, well-maintained
high efficiency filter respirators, MSHA/NIOSH-approved for
inorganic arsenic, if the level of inorganic arsenic in the
plant is unknown or exceeds 10 micrograms per cubic meter of
air (10ug/m3) averaged over an 8-hour work period.

          "Note to user - Examples of acceptable materials for
protective clothing (e.g., gloves, overalls, jacket, and
boots) required during application and handling of inorganic
arsenicals are vinyl, polyvinyl chloride  (PVC), neoprene, NBR
(Buna-N), rubber, and polyethylene."

               c.   Monitoring

               "Air monitoring programs,  procedures and record
retention and submission must be conducted in accordance with
the instructions on the attached labeling material."

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               d.   General Work Practice Statements

               "Applicators must not eat, drink,.or use
tobacco products during those parts of the application process
that may expose them to the wood treatment formulation (e.g.,
manually opening/closing cylinder doors, moving trams out of
cylinders, mixing chemicals, and handling freshly treated
wood)."

               "Wash thoroughly after skin contact, and before
eating, drinking, use of tobacco products or using restrooms."

               e.   Disposal

               "Pesticide wastes are acutely hazardous.
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."

               f.   Ecological Hazard Statement

                    "This pesticide is toxic to fish.  Do
not discharge effluent containing this product into lakes,
streams, ponds, estuaries, oceans or public water unless this
product is specifically identified and addressed in an NPDES
permit.  Do not discharge effluent to sewer systems without
previously notifying the sewage treatment plant authority.
For guidance, contact your State Water Board or regional
office of the EPA."

               g.   Visible Residue Statement

               "Processes used to apply inorganic arsenical
formulations shall leave no visible surface deposits on the
wood, as defined by AWPA Standard C-1 and AWPB Standards LP2
and LP22.  (Visible surface deposits means a surface residue
or crystallization on the treated wood. Small isolated or
infrequent spots of chemical on otherwise clean wood shall be
allowed.) "

               h.   Permissible Exposure Limit (PEL) Monitoring
                    Program

                The following must be included as labeling, with
each end-use product labeled for pressure treatement of wood:

   "Implementation of the Permissible Exposure Limit  (PEL)
                      Monitoring Program
                                36

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"Each arsenical wood treatment plant employer shall require
all employees potentially exposed to airborne inorganic
arsenic to wear properly fitting, well maintained, high
efficiency filter respirators, MSHA/NIOSH-approved for
inorganic arsenic for the entire period that the employees
are in the treatment application work area or engaged in any
activity associated with the treatment process.  Alternatively,
to potentially relieve employees from the burden of wearing
respirators, the employer may implement a Permissible Exposure
Limit (PEL) Monitoring Program.  This requirement became
effective on July 10. 1986.  Any plant which begins operations
after April 10, 1986 will have 3 months from the date of
initial operation to implement this program."

"All wood treatment plant employers who elect to implement
the PEL monitoring program must determine the current levels
of airborne arsenic, averaged over an 8-hour period, to
which their employees are exposed.  Monitoring data must
be obtained in the same manner as described below under
'Monitoring and Measurements Procedures'."
"If the initial or subsequent monitoring demonstrates
that airborne inorganic arsenic in a work area is greater
than 10ug/m3, all employees workltig in that area are required
to wear properly fitting, well-maintained, high efficiency
filter respirators. MSHA/NIOSH-approved for inorganic arsenic.
If in subsequent monitoring, at least two consecutive
measurements taken at least 7 days apart, the inorganic
arsenic levels are below 10ug/m3, employees in those areas
may discontinue wearing the respirators except as discussed
in the "PEL checklist" below.  However, if the employee
exposure is below 10ug/m3 but above 5ug/ra3. the employer shall
repeat monitoring at least every 6 months until at least two
consecutive measurement, taken at least 7 days apart, are
below 5ug/m3.  The employer may then discontinue monitoring
except as discussed in the 'PEL Checklist1 below."

"If the monitoring reveals employees are exposed to airborne
arsenic levels below 5ug/m3, monitoring need not be repeated
except as discussed in the 'PEL Checklist1 below."

                       "PEL CHECKLIST"

"In all cases where there has been a change in production,
process, control, or employee handling procedures, or  if any
events in the PEL Checklist occurred, or if, for any other
reasons an employer should suspect new or additional airborne
inorganic arsenic, additional monitoring that complies with
the requirements for initial monitoring shall be completed.
Responses to the Checklist will become part of the monitoring
records.  Monitoring is required within 3 months  if any of
the following events/questions on the checklist can be
answered in the affirmative with respect to any events which
may have occurred since the last monitoring report submitted
to the Agency."

                             37

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      "1.   After  the wood has been treated, have you
changed  from hand stacking to mechanical stacking or from
mechanical stacking to hand stacking?  If yes. when?"

      "2.   Has your production capacity increased
significantly?  If yes. when?"

      "3.   Have you changed from a ready-to-use or dilute
concentrate to a mix-it-yourself formulation?  Has the
proportional amount of arsenic in the solution increased,
e.g., have you shifted from CCA Type A or C to type B?  If
yes,  when?"

      "4.   Has a  significant (i.e., reportable under the
Comprehensive Environmental Response, Compensation, and
Liabililty Act of 1980 (Superfund), 42 U.S.C. 9601 et seq.).
spill occurred?   If yes, when?"

      "5.   Is treated wood being retained on the drip pad
for  less time?  If yes. when?"

      "6.   Have there been any other production, process,
control  or employee handling procedure changes which could
result in new or  additional airborne inorganic arsenic?
Identify change,  and when it occurred."

           "MONITORING AND MEASUREMENT PROCEDURES"

"The  Employer shall collect personal air samples, including at
least one sample which is adequate to represent typical
conditions for a full work shift (at least 7 hours) for each
job classification in each work area.  Sampling should be
done  using a personal sampling pump calibrated at a flow
rate  of  2 liters per minute. Samples should be collected on
0.8 micrometer pore size membrane filters (37mm diameter).
The method of sampling analysis should have an accuracy of
not less than + or - 25 percent (with a confidence limit of
95 percent) for 10 micrograms per cubic meter of air (10ug/m3),
and + or - 35 percent (with a confidence limit of 95 percent)
for concentrations of inorganic arsenic between 5 and lOug/nn."

"Monitoring may be conducted through a request made to
the Occupational Safety and Health Administration (OSHA) for
monitoring assistance, which may be provided free of charge
under the terms of the OSHA consultation program as provided
under section 7(c)(l) of the OSHA Act, or by employees or
contractors of the employer's choosing."

"The Environmental Protection Agency (EPA) may direct that
remonitoring take place at statistically selected establishments
to assure that the Checklist is effective in identifying
events which increase airborne arsenic.  Selected employers
will be notified by EPA/State enforcement representatives.


                              38

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The employer will be responsible for obtaining current air
monitoring data within the time specified in the remonitoring
notification and for submitting these data and reports to the
EPA as described below."

              DATA SUBMISSION AND CERTIFICATION

"The employer shall establish and maintain accurate records
which include responses to the PEL Checklist and all monitoring
reports.  The annual records or copies thereof shall be submitted
to the U.S. Environmental Protection Agency. Office of Pesticides
and Toxic Substances Office of Compliance Monitoring (EN-
342). 401 M St.. SW. Washington. D.C.  20460.  All records
submitted will be certified by the employer as accurate and
in compliance with all calibration, analytical and sampling
requirements outlined in this program.  If the employer
received assistance from an OSHA 7(C)(1) consultant, that
consultant's report to the employer will be an acceptable
record of calibration, analysis, and monitoring requiring no
additional certification."

          5.   All End Use Powder Formulations Labeled For
Pressure Treatment of Wood;In addition to those statements
in D(2) and (3)above,the following statement must appear on all
powder formulations labeled for pressure treatement of wood:

               "A closed emptying and mixing system must be
used for all powder formulations of the inorganic arsenicals.
A closed system is defined as any containment which prevents
the release of subject chemicals into the surrounding external
environment, except that the release of incidental amounts of
chemical during equipment loading and periodic clean-out or
maintenance operations shall not be deemed a breach of
containment."

          6.   End Use Products Labeled for Brush on Treatment!
In addition to the statements in D(2) above, all end use
products labeled for brush on treatment must bear the following
statements:

               "Use of this product may be hazardous to your
health.  This product contains arsenic and/or chromium compounds
which have been determined to cause tumors in humans.  Risks
can be reduced by closely following the use directions and
precautions, and by properly using the protective clothing
and equipment listed elsewhere on the label."

               a.   Protective Clothing

                    "Applicators must wear gloves (e.g. .
rubber, vinyl or neoprene) impervious to  the wood treatment
solution in all situations where dermal contact  is expected
(e.g., during the application process and handling freshly
treated wood). "
                               39

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                    "Applicators must Wear disposable coveralls
 (e.g., vinyl, or polyethylene) or other similar impermeable
 clothing during the application process where dermal contact
 is expected."

                    "Protective clothing must be changed when
 it shows obvious signs of contamination.  Launder non-disposable
 protective clothing separately from other household laundry.
 Dispose of worn-out protective clothing in a manner approved
 for pesticide disposal and in accordance with state and
 federal regulations."

               b.   General Work Practice Statement

                    "Applicators must not eat. drink, or use
 tobacco products during those parts of the application process
 that may expose them to the wood treatment formulation."

                    "Wash thoroughly after skin contact and
before eating, drinking, use of tobacco products, or using
 restrooms."

               c.   Disposal

                    "Pesticide wastes are acutely hazardous.
 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."

               d.   Ecological Hazard Statement

                    "This product is toxic to fish.  Do not
contaminate water by cleaning of equipment or disposal of waste."

               e.   Use Pattern Statement

                    "For application to the cut ends of
pressure-treated wood only.  Do not dilute or mix with other
products."

                    "For commercial construction use only.
Not for household use."
                              40

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            V.  PRODUCTS SUBJECT TO THIS STANDARD

     All products containing one or more of the pesticides
 identified  in Section II.A. are subject t.o certain requirements
 for  data submission or changes in composition, labeling or
 packaging of the product.  The applicable requirements depend
 on whether  the product is a manufacturing or end use product
 and  whether the pesticide is the sole active ingredient or
 one  of multiple active ingredients.

     Products are subject to this Registration Standard as
 follows:

 A.   Manufacturing use products containing arsenic, chromium,
 and  chromated arsenicals as the active ingredients are subject
 to:

     1.  The restrictions (if any) upon use, composition, or
     packaging listed in Section IV, if they pertain to the
     manufacturing use product.

     2.  The data requirements listed in Tables A and B2

     3.  The labeling requirements specified for manufacturing
     use products in Section IV.

     4.  Administrative requirements (application forms, Confiden-
     tial Statement of Formula, data compensation provisions)
     associated with reregistration.
2 Data requirements are listed in the three Tables in
Appendix I of this Registration Standard.  The Guide to
Tables in that Appendix explains how to read the Tables.

  Table A lists generic data requirements applicable to all
products containing the pesticide subject to this Registra-
tion Standard.  Table B lists product-specific data applicable
to manufacturing use products.  The data in Tables A and B
need not be submitted by a producer who is eligible for the
forraulator's exemption for that active ingredient.

  Table C lists product-specific data applicable to end use
products.  The Agency has decided that, in most cases, it
will not require the submission of product-specific data for
end use products at this time.  Therefore most Registration
Standards do not contain a Table C.

                              41

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B«  Manufacturing use products containing this pesticide
as one of multiple active ingredients are subject to:

    1.  The data requirements listed in Table A.

    2.  The labeling requirements specified for manufacturing
    use products in Section IV.

C.  End use products containing arsenic, chromium, and
chromated arsenicals as the sole active ingredient are subject
to:

      1.  The restrictions (if any) upon use, composition,  or
      packaging listed in Section IV if they pertain to the
      end use product.

      2.  If eligible for the formulator's exemption^,  the
      data requirements listed in Table C.

      3.  If not eligible for the forraulator's exemption, the
      data requirements listed in Table A and the data require-
      ments listed in Table C.

      4.  The labeling requirements specified for end use
      products in Section IV-

D.  End use products containing this pesticide as one of
multiple active ingredients are subject to:

      1.  If not eligible for the formulator's exemption,
      the date requirements listed in Tables A and C.
3 If you purchase from another producer and use as the
source of your active ingredient only EPA-registered products,
you are eligible for the forraulator's exemption for generic
data concerning that active ingredient (Table A) and product-
specific data for the registered manufacturing use product
you purchase (Table B).

     Two circumstances nullify this exemption:

     1)  If you change sources of active ingredient to an
unregistered product, formulate your own active ingredient,
or acquire your active ingredient from a firm with ownership
in common with yours, you individually lose the exemption
and become subject to the data requirements in Table A.

     2)  If no producer subject to the generic data requirements
in Table A agrees to submit the required data, all end use
producers lose the exemption, and become subject to those
data requirements.
                             42

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     2.  If eligible for the formulator's exemption, the
     data requirements listed in Table C.

     3.  The labeling requirements specified for end use
     products in Section IV.


       VI.  REQUIREMENT FOR SUBMISSION OF GENERIC DATA

     This portion of the Registration Standard is a notice
issued under the authority of FIFRA sec. 3(c)(2)(B).  It
refers to the data listed in Table A, which are required to
be submitted by registrants to maintain in effect the regis-
tration of products containing this active ingredient.^

A.  What are generic data?

     Generic data pertain to the properties or effects of a
particular active ingredient.  Such data are relevant to an
evaluation of all products containing that active ingredient
regardless of whether the product contains other ingredients
(unless the product bears labeling that would make the data
requirement inapplicable).

     Generic data may also be data on a "typical formulation"
of a product.  "Typical formulation" testing is often required
for ecological effects studies and applies to all products
having that formulation type.  These are classed as generic
data, and are contained in Table A.

B.  Who must submit generic data?

     All current registrants are responsible for submitting
generic data in response to a data request under FIFRA sec.
3(c)(2)(B) (DCI Notice).  EPA has decided, however, not to
require a registrant who qualifies for the formulator's
exemption (FIFRA sec. 3(c)(2)(D) and § 152.85) to submit
generic data in response to a DCI notice if the registrant
who supplies the active ingredient in his product is complying
with the data request.

     If you are granted a generic data exemption, you rely on
the efforts of other persons to provide the Agency with the
required data.  If the registrants who have committed to
generate and submit the required data fail to take appropriate
steps to meet the requirements or are no longer in compliance
with this data requirements notice, the Agency will consider
4 Registrations granted after issuance of this Standard will
be conditioned upon submission or citation of the data listed
in this Registration Standard.

                            43

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 that  both  they  and  you are not in compliance and will normally
 initiate proceedings  to suspend the registrations of both
 your  product(s)  and their product(s) unless you commit to submit
 and submit  the  required data in the specified timeframe.   In
 such  cases,  the Agency generally will not grant a time extension
 for submitting  the  data.

      If you are not now eligible for a formulator's exemption,
 you may qualify for one if you change your source of supply
 to a  registered source that does not share ownership in
 common with your firm.  If you choose to change sources of
 supply, the Confidential Statement of Formula must identify
 the new source(s) and you must submit a Formulator's Exemption
 Statement  form.

      If you apply for a new registration for products containing
 this  active ingredient after the issuance of this Registration
 Standard,  you will  be required to submit or cite generic
 data  relevant to the uses of your product if, at the time
 the application is  submitted, the data have been submitted
 to the Agency by current registrants.  If the required data
 have  not yet been submitted, any new registration will be
 conditioned upon the new registrant's submission or citation
 of the required  data not later than the date upon which
 current registrants  of similar products are required to provide
 such  data.   See  FIFRA sec. 3(c)(7)(A).  If you thereafter fail
 to comply with  the  condition of that registration to provide
 data, the  registration may be cancelled (FIFRA sec. 6(e)).

 C.  What generic data must be submitted?

      You may determine which generic data you must submit by
 consulting  Table A.  That table lists the generic data needed
 to evaluate  current uses of all products containing this
 active ingredient,  the uses for which such data are required,
 and the dates by which the data must be submitted to the
Agency.

 D.  How to  comply with PCI requirements.

      Within  90  days of your receipt of this Registration
 Standard, you must  submit to EPA a completed copy of the form
 entitled "FIFRA  Section 3(c)(2)(B) Summary Sheet" (EPA Form
8580-1 , enclosed) for each of your products.  On that form
you must state which of the following six methods you will
use to comply with  the DCI requirements:

      1.  You will submit the data yourself.

      2.  You have entered into an agreement with one or more
registrants  to jointly develop (or share in the cost of
developing)  the  data, but will not be submitting the data
yourself.   If you use this method, you must state who will
submit the  data  on  which you will rely.  You must also provide

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 EPA with documentary evidence that an agreement has been
 formed which allows you to rely upon the data to be submitted.
 Such  evidence may be:  (1) your letter offering to join in
 an agreement and the other registrant's acceptance of your
 offer, (2) a written statement by the parties that an agreement
 exists, or (3) a written statement by the person who will be
 submitting the data that you may rely upon its submission.
 The Agency will also require adequate assurance that the
 person whom you state will provide the data is taking appropriate
 steps to secure it.  The agreement to produce the data need
 not specify all of the terms of the final arrangement between
 the parties or a mechanism to resolve the terras.

      If you and other registrants together are generating or
 submitting requested data as a task force or consortium, a
 representative of the group should request a Joint Data
 Submitter Number from the Registration Support and Emergency
 Response Branch, Registration Division.  The request must
 include the following information:

      a.  A list of the members of the consortium;
      b.  The name and address of the designated representative
         of the consortium, with whom EPA will correspond
         concerning the data;
      c.  Identity of the Registration Standard containing
         the data requirement;
      d.  A list of the products affected (from all members
         of the consortium); and
      e.  Identification of the specific data that the con-
         sortium will be generating or submitting.

     The Agency will assign a number to the consortium, which
 should be used on all data submissions by the consortium.

      3.  You have attempted to enter into an agreement to
 jointly develop data, but no other registrant has accepted
 your offer.  You request that EPA not suspend your registration
 for non-compliance with the PCI.EPA has determined that,
 as a general policy, it will not suspend the registration of
 a product when the registrant has in good faith sought and
 continues to seek to enter into a data development/cost
 sharing program, but the other registrants developing the
 data have refused to accept its offer.  [If your offer  is
 accepted, you may qualify for Option 2 above by entering
 into an agreement to supply the data.]

     In order to qualify for this method, you must:

     1.  File with EPA a completed "Certification of Attempt
 to Enter into an Agreement with other Registrants for Develop-
ment of Data" (EPA Form 8580-6. enclosed).

     2.  Provide us with a copy of your offer to the other

                              45

-------
 registrant and proof of  the  other  registrant's receipt of your
 offer (such as a certified mail  receipt).  Your offer must,
 at a minimum,  contain the following  language or its equivalent:

      [Your company name]  offers  to share In the burden of
      producing the data  required pursuant to FIFRA sec.
      3(c)(2)(B)  in the [name of  active  ingredient] Registration
      Standard  upon terras  to  be agreed or failing agreement
      to be bound by binding  arbitration as provided by FIFRA
      section 3(c)(2)(B)(iii).

 The remainder  of your offer  may  not  in  any way attempt to
 limit this commitment.  If the other registrant to whom your
 offer is made  does not accept your offer, and if the other
 registrant informs us on  a DCI Summary  Sheet that he will
 develop and submit the data  required under the DCI, then you
 may qualify for  this option. In order  for you to avoid
 suspension under this method, you  may not later withdraw or
 limit your offer to share in the burden of developing the
 data.

      In addition, the other  registrant  must fulfill its
 commitment to  develop and submit the data as required by this
 Notice in a timely manner.   If the other registrant fails to
 develop the data or for some other reason would be subject to
 suspension, your registration as well as that of the other
 registrant will  normally  be  subject  to  initiation of suspension
 proceedings, unless you commit to  submit and submit the required
 data in the specified timeframe.   In such cases, the Agency
 generally will not grant  a time  extension for submitting the data.

      4.   You request a waiver of the data requirement.  If
 you believe that a data requirement  does not (or should not)
 apply  to your  product or  its uses, you  must provide EPA with
 a  statement of the reasons why you believe this is so.  Your
 statement must address the specific  composition or use factors
 that lead you  to believe  that a  requirement does not apply.
 Since  the Agency has carefully considered the composition and
 uses  of  pesticide products in determining that a data require-
 ment  applies,  EPA does not anticipate that many waivers will
 be  granted.  A request for waiver  does  not extend the time-
 frames  for developing required data, and if your waiver
 request  is denied,  your registration may be suspended if you
 fail  to  submit the  data.

     5.   You request that EPA amend  your registration by deleting
 the uses  for which  the data  are  needed.You are not required
 to  submit  data for  uses which are  no longer on your label.

     6.   You request voluntary cancellation of the registration
of your  product(s)  for which the data are needed.
                            46

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E.  Testing Protocols, Standards for Conducting Acceptable
    Tests, Guidance on Evaluating and Reporting Data".

    All studies required under this Notice must be conducted
in accordance with test standards outlined in the Pesticide
Assessment Guidelines, unless other protocol or standards are
approved for use by the Agency in writing.

    As noted herein, these EPA Guidelines, which are referenced
in the Data Tables, are available from the National Technical
Information Service (NTIS), Attn: Order Desk, 5285 Port Royal
Road, Springfield, VA  22161 (tel: 703-487-4650).

    Protocols approved by the Organization for Economic
Cooperation and Development (OECD) are also acceptable if
the OECD-recommended test standards conform to those specified
in the Pesticide Data Requirements regulation (Part 158.70).
Please note, however, that certain OECD standards (such as
test duration, selection of test species, and degradate
identification which are environmental fate requirements) are
less restrictive than those in the EPA Assessment Guidelines
listed above.  When using the OECD protocols, they should be
be modified as appropriate so that the data generated by the
study will satisfy the requirements of Part 158.  Normally,
the Agency will not extend deadlines for complying with data
requirements when the studies were not conducted in accord
with acceptable standards.  The OECD protocols are available
from OECD, 1750 Pennsylvania Avenue, N.W., Washington, D.C.
20006.

F.  Procedures for requesting a change in testing protocol.

     If you will generate the required data and plan to use
test procedures which deviate from EPA's Pesticide Assessment
Guidelines or the Reports of Expert Groups to the Chemicals
Group, Organization for Economic Cooperation and Development
(OECD) Chemicals Testing Programme, you must submit for EPA
approval the protocols you propose to use.

     You should submit your protocols before beginning testing,
because the Agency will not ordinarily accept as sufficient
studies using unapproved protocols.  A request for protocol
approval will not extend the tiraeframe for submission of the
data, nor will extensions generally be given to conduct
studies due to submittal of inappropriate protocols.


G.  Procedures for requesting extensions of time.

     If you think that you will need more time to generate
the data than is allowed by EPA's schedule, you may  submit  a
request for an extension of time.  Any request for a  time


                              47

-------
 extension which is  made  as  an  initial response to a section
 3(c)(2)(B)  request  notice must be submitted in writing to
 the  Product Manager listed  at  the end of this section and
 must be  made by the 90-day  deadline for response.  Once
 dates have  been committed to and EPA has accepted these
 commitments, any subsequent requests for a time extension
 must be  submitted in writing to the Office of Compliance
 Monitoring  at the address given in Section IX.E.

      EPA will view  failure  to  request an extension before
 the  data submission response deadline as a waiver of any
 future claim that there  was insufficient time to submit the
 data. While EPA considers  your request, you must strive to
 meet the deadline for  submitting the data.

      The extension  request  should state the reasons why you
 believe  that an extension is necessary and the steps you
 have taken  to meet  the testing deadline.  Time extensions
 normally will not be granted due to problems with laboratory
 capacity or adequacy of  funding, since the Agency believes
 that with proper planning these can be overcome.

      A request for  an  extension does not extend the timeframe
 for  submission of the  data.  If EPA denies your request for
 a  time extension and you do not submit the data as requested,
 EPA  may  begin proceedings to suspend the registrations of
 your products.

 H.   PR Notice 86-5  and Any  Other Requirements Referenced or
     Included Within this Notice.

     All  data submitted in response to this Notice must comply
 with EPA requirements  regarding the reporting of data, including
 the  manner  of reporting, the completeness of results, and the
 adequacy of  any required supporting (or raw) data, including,
 but  not  limited to,  requirements referenced or included in
 this  Notice  or contained in PR Notice 86-5 (issued July 29,
 1986).

 I.   Existing stocks  provision upon suspension or cancellation.

      The  Agency has  determined that if a registration is
 suspended for  failure  to respond to a DCI request under
 FIFRA sec.  3(c)(2)(B), an existing stocks provision is not
 consistent with the Act.  Accordingly, the Agency does not
 anticipate granting permission to sell or distribute existing
 stocks of suspended product except in rare circumstances.
 If you believe  that  your product will be suspended or cancelled
and  that  an  existing stocks provision should be granted, you
have  the  burden of  clearly  demonstrating to EPA that granting


                            48

-------
such permission would be consistent with the Act*  The following
information must be included in any request for an existing
stocks provision:

     1.  Explanation of why an existing stocks provision is
     necessary, including a statement of the quantity of
     existing stocks and your estimate of the time required
     for their sale or distribution; and

     2.  Demonstration that such a provision would be consis-
     tent with the provisions of FIFRA.


   VII. REQUIREMENT FOR SUBMISSION OF PRODUCT-SPECIFIC DATA

     Under its DCI authority, EPA has determined that certain
product-specific data are required to maintain your registrations
in effect.  Product-specific data are derived from testing
using a specific formulated product, and, unlike generic
data, generally support only the registration of that product.
All such data must be submitted by the dates specified in
this Registration Standard.

     If you have a manufacturing use product, these data are
listed in Table B.  If you have an end use product, the data
are listed in Table C.  As noted earlier, the Agency has
decided that it will not routinely require product-specific
data for end use products at this time.  Therefore, Table C
may not be contained in this Registration Standard; if there
is no Table C. you are not required to submit the data at
this time.

     In order to comply with the product specific data require-
ments, you must follow the same procedures as for generic data.
See Section VI.D. E, F, and G.  You should note, however, that
product chemistry data are required for every product, and the
only acceptable responses are options VI.D.I. (submit data)
or VI.D.6.(cancellation of registration).

     Failure to comply with the product-specific data require-
ments for your products will result in suspension of the
product's registration.
                              49

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    VIII.  REQUIREMENT FOR SUBMISSION OF REVISED LABELING

     FIFRA requires each product to be labeled with accurate,
complete and sufficient instructions and precautions,  reflecting
the Agency's assessment of the data supporting the product
and its uses.  General labeling requirements are set out in
40 CFR 162.10  (see Appendix II - LABELING and SUMMARY).   In
addition, labeling requirements specific to products containing
this pesticide are specified in Section IV.D of this Registra-
tion Standard.  Applications submitted in response to this
notice must include draft labeling for Agency review.

     If you fail to submit revised labeling as required,
which complies with 40 CFR 162.10 and the specific instructions
in Section IV.D., EPA may seek to cancel or suspend the
registration of your product under FIFRA sec. 6.

               IX.  INSTRUCTIONS FOR SUBMISSION

A.  Manufacturing Use Products (MUPs) containing arsenic or
    chromium as the sole active ingredient.

    1.  Within 90 days from receipt of this document,  you
must submit to the Product Manager in the Registration Division
for each product subject to this Registration Standard:

        a.  The "FIFRA Section 3(c)(2)(B) Summary Sheet" (EPA
    Form 8580-1), with appropriate attachments.5

        b.  Confidential Statement of Formula (EPA Form 8570-4).

        c.  Formulator's Exemption Statement (EPA Form 8570-27),
    if applicable.

        d.  Evidence of compliance with data compensation
    requirements of FIFRA sec. 3(c)(1)(D).  Refer to 40 CFR
    152.80-152.99.
5 If on the Summary Sheet, you commit to develop the data,
present arguments that a data requirement is not applicable
or should be waived, or submit protocols or modified protocols
for Agency review, you must submit a copy of the Summary
Sheet (and any supporting information) to the Office of
Compliance Monitoring, which will be monitoring the data
generated in response to this notice.  This submission is in
addition to responding to the Product Manager, and should be
submitted to the Office of Compliance Monitoring at the
address given at the end of this section.   (Actual studies
are not to be submitted to the Office of Compliance Monitoring.)

                               50

-------
    2.  Within 9 months from receipt of this document you
must submit to the Product Manager:
    Form
a.   Application  for  Pesticide Registration (EPA
 8570-1).
        b.  Two copies of any required product-specific data
     (See Table B).

        c.  Three copies of draft labeling, including the
    container label and any associated supplemental labeling.
    Labeling should be either typewritten text on 8-1/2 x 11
    inch paper or a mockup of the labeling suitable for
    storage in 8-1/2 x 11 files.  The draft label must indicate
    the intended colors of the final label, clear indication
    of the front panel of the label, and the intended type
    sizes of the text.

        d.  Product Specific Data Report (EPA Form 8580-4).

     3.  Within the times set forth in Table A, you must
submit to the Registration Division all generic data, unless
you are eligible for the forraulator's exemption.  If for any
reason any test is delayed or aborted so that the schedule
cannot be met, immediately notify the Product Manager and
the Office of Compliance Monitoring of the problem, the
reasons for the problem, and your proposed course of action.

B.  Manufacturing Use Products containing arsenic, chromium,
    or chromated arsenicals in combination with other active
    ingredients.

    1.  Within 90 days from receipt of this document, you
must submit to the Product Manager in the Registration Division:

        a.  F1FRA sec. 3(c)(2)(B) Summary Sheet, with appropriate
    attachments5 (EPA Form 8580-1).

        b.  Confidential Statement of Formula  (EPA Form 8570-4)

        c.  Formulator's Exemption Statement (EPA Form 8570-27),
    if applicable.

    2.  Within 9 months of receipt of this document, you must
submit to the Product Manager:

        Three copies of draft labeling, including the container
    label and any associated supplemental labeling.  Labeling
    should be either typewritten text on 8-1/2 x  11  inch
    paper or a raockup of the labeling suitable for storage
    in 8-1/2 x 11 files.


                            51

-------
     The  draft  label must  indicate the intended colors of the
     final  label, clear  indication of the front panel of the
     label,  and the  intended  type sizes of the text.

     3.   Within the  time frames set forth in Table A, you must
 submit to  the  Registration Division all generic data, unless
 you  are  eligible for  the  formulator's exemption.  If for any
 reason any test is  delayed or aborted so that the schedule
 cannot be  met,  immediately notify the Product Manager and
 the  Office of  Compliance  Monitoring of the problem, the
 reasons  for the problem,  and your proposed course of action.

 C.   End  Use Products  containing arsenic or chromium as sole
     active ingredient.

     1»   Within 90 days  from  receipt of this document, you
 must submit to  the  Product Manager in the Registration Division:

         a.   FIFRA Section 3{c)(2)(B) Summary Sheet, with
     appropriate attachments* (EPA Form 8580-1).

         b.   Confidential  Statement of Formula (EPA Form 8570-4).

         c.   Formulator's  Exemption Statement (EPA Form 8570-27),
     if applicable.

    2.   Within  9 months from receipt of this document you
 must submit to  the  Product Manager:

         a.   Two copies  of any product-specific data, if required
    by Table C.

         b.   Product Specific Data Report (EPA Form 8580-4),
     if Table C  lists  required product-specific data.>

         c.   Three copies  of  draft labeling, including the
    container  label and any  associated supplemental labeling.
    Labeling should be  either typewritten text on 8-1/2 x  11
     inch paper  or a roockup of the labeling suitable for
    storage in  8-1/2  x  11 files.  The draft labeling must
    indicate the intended colors of the final label, clear
     indication  of the front  panel of the label, and the
    intended type sizes of the text.  End use product labeling
    must comply specifically with the instructions  in Section IV
     (Regulatory Position  and Rationale).

 D.  End Use Products  containing arsenic, chromium,  or chromated
    ajrsenicals  as one of  multiple active ingredients.

    Within  9 months from  the receipt of this document, you
must submit  to  the Product Manager:


                             52

-------
        Three copies of draft labeling, including the container
     label and any associated supplemental labeling.  Labeling
     should be either typewritten text on 8-1/2 x 11 inch
     paper or a mockup of the labeling suitable for storage
     in 8-1/2 x 11 files.  The draft labeling must indicate
     the intended colors of the final label, clear indication
     of the front panel of the label, and the intended type
     sizes of the text.  End use product labeling must comply
     specifically with the instructions in Section IV (Regulatory
     Position and Rationale).

E.   Intrastate Products containing arsenic, chromium or chromated
     arsenicals as sole active ingredient or in combination with
     other active ingredients.

     Applications for full Federal registration of intrastate
products are required to be submitted no later than July 13,
1988.

F-   Addresses

     The required information must be submitted to the following
address:

     Lois A.Rossi, PM-21
     Registration Division (TS-767C)
     Office of Pesticide Programs
     Environmental Protection Agency
     401 M St., SW
     Washington, D.C.  20460

     The address for submissions to the Office of Compliance
Monitoring is:

     Laboratory Data Integrity Program
     Office of Compliance Monitoring (EN-342)
     Environmental Protection Agency
     401 M St., SW
     Washington, D.C. 20460.
                              53

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                           TGUIDE-1

                       GUIDE TO TABLES

     Tables A, B, and C contain listings of data requirements
for the pesticides covered by this Registration Standard.

     Table A contains generic data requirements that apply to
     the pesticide in all products, including data requirements
     for which a "typical formulation" is the test substance.

     Table B contains product-specific data requirements that
     apply only to a manufacturing use product.

     Table ~C contains product-specific data requirements that
     apply only to an end use product.

     The data tables are generally organized according to the
fo1lowing format:

1.  Data Requirement (Column 1).  The data requirements are
listed in the order in which they appear in 40 CFR Part 158.
The reference numbers accompanying each test refer to the
test protocols set out in the Pesticide Assessment Guidelines,
which are available from the National Technical Information
Service, 5285 Port Royal Road, Springfield, VA  22161.

2.  Test Substance (Column 2).  This column lists the composition
of the test substance required to be used for the test, as
follows:

     TGAI = Technical grade of the active ingredient
     PAI «  Pure active ingredient
     PAIRA = Pure active ingredient, radio labeled
     TEP *  Typical end use formulation
     MP =   Manufacturing use product
     EP =   End use product

Any other test substances, such as metabolites, will be
specifically named in Column 2 or  in footnotes to the table.

3.  Use pattern (Column 3).  This  column indicates  the  use
patterns to which the data requirement applies.  Use patterns
are the same as those given in 40  CFR Part 158.  The following
letter designations are used for  the given use patterns:

     A » Terrestrial, food
     B » Terrestrial, non-food
     C » Aquatic, food
     D * Aquatic, non-food
     E = Greenhouse, food
     F - Greenhouse, non-food
     G » Forestry
     H = Domestic outdoor
     I » Indoor

Any other designations will be-defined  in  a  footnote to the table.

-------
                           TGUIDE-2

4.  Does EPA have datal (Column 4).  This column indicates  one
of three answers:

     YES - EPA has data in its files that satisfy this data
     requirement.   These data may be cited by other registrants
     in accordance with data compensation requirements of
     Part 152, Subpart E.

     PARTIALLY - EPA has some data in its files, but such data
     do not fully satisfy the data requirement.   In some cases,
     the Agency may possess data on one of two required species,
     or may possess data on one test substance but not all.
     The term may also indicate that the data available to
     EPA are incomplete.  In this case, when the data are
     clarified, or additional details of the testing submitted
     by the original data submitter, the data may be determined
     to be acceptable.  If this is the case, a footnote to
     the table will usually say so.

     NO - EPA either possesses no data which are sufficient
     to fulfill the data requirement, or the data which EPA
     does possess are flawed scientifically in a manner that
     cannot be remedied by clarification or additional infor-
     mation.

5.  Bibliographic citation (Column 5).  If the Agency has
acceptable data in its files, this column lists the identifying
number of each study.  This normally is the Master Record
Identification (MRID) number, but may be a GS number if no
MRID number has been assigned.  Refer to the Bibliography
Appendices for a complete citation of the study.

6.  Must additional data be submitted? (Column 6).  This
column indicates whether the data must be submitted to the
Agency.  If column 3 indicates that the Agency already has
data, this column will usually indicate NO.  If column 3
indicates that the Agency has only partial data or no data,
this column will usually indicate YES.  In some cases, even
though the Agency does not have the data, EPA will not require
its submission because of the unique characteristics of the
chemical; because data on another chemical can be used to
fulfill the data requirement; or because the data requirement
has been waived or reserved.  Any such unusual situations
will be explained in a footnote to the table.

7.  Timeframe for submission (Column 7).  If column 5 requires
that data be submitted, this column indicates when the data
are to be submitted, based on the issuance date of the Regis-
tration Standard.   The tiraefrarnes are those established either
as a result of a previous Data Call-In letter, or standardized
timeframes established by PR Notice 85-5  (August 22,  1985).

8.  Footnotes (at the end of each table).  Self-explanatory.


                           55

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                                                  TABLE A



GENERIC DATA REQUIREMENTS FDR PRODUCTS CONTAINING ARSENIC, CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
Data Requirement Test
Substance
§158.120 Product Chemistry
Product Identity
61-1 - Product Identity and
Disclosure of Ingredients
61-2 - Description of Beginning
Materials and Manufacturing
Process
61-3 - Discussion of Formation of
Impurities
Analysis and Certification of
Product Ingredients
62-1 - Preliminary Analysis
Physical and Chemical
Characteristics
63-2 - Color
63-3 - Physical State
63-4 - Odor
fc3-5 - Melting Point
63-6 - Boiling Point
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
Use
Patterns
All
All
All
All
All
All
All
All
All
Does EPA Bibliographic Must Additional Time Frame
Have Data?1 Citation1 Data be for
Submitted? Submission
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
6 Months
6 Months
6 Months
vO
in
12 Months
6 Months
6 Months
6 Months
6 Months
6 Months

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                                                      TABLE A

     GENERIC DATA REQUIREMENTS FOR PRODUCTS  CONTAINING ARSENIC, CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
IData Requirement
Test Use
Substance Patterns
Does EPA Bibliographic Hist Additional Time Frame
Have Data?1 Citation1 Data be for
Submitted? Submission
§158.120 Product Chemistry (Continued)
[Physical and Chemical Characteristics
(Continued)
63-7
63-8
63-9
63-10

63-11
63-12
63-13
Other
64- 1
- Density, Bulk Density, or
Specific Gravity
- Solubility
- Vapor Pressure
- Dissociation constant

- Octanol/water partition
coefficient
- PH
- Storage Stability
Requirements :
- Submit tal of samples
TGAI
TGAI or PAI
PAI
PAI

PAI
TGAI
TGAI
TGAI. PAI
All
All
All
All

All
All
All
All
No
No
No
No

No
No
No
No
N/A
N/A
N/A
N/A

N/A
N/A
N/A
N/A
Yes
Yes
Yes
Yes

Yes
Yes
Yes
No
6 Months
6 Months
6 Months
6 Months l^»
to
6 Months
6 Months
15 Months

I/ Not applicable.  Although product chemistry data may have been submitted in the past, the Agency has determined that
   these data must be resubmitted for each pesticide.  New requirements have been introduced and previously submitted
   data must be updated.  Therefore bibliographic  citations for the old data are not applicable.

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                                                     TABLE A

GENERIC DATA REQUIREMENTS FOR PRODUCTS CONTAINING ARSENIC,  CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
 Arsenic in arsenic and chromated arsenical compounds ([XJAs & [X]CrAs),
 When [Xjcompound is an ionic form of copper;  pentachlorophenate;  2,4-dinitrophenol;  or ammonia mixed
 with [XJarsenic and [X]arsenic/chromium
Data Requirement
§158.130 Environmental Fate
DEGRADATION STUDIES-LAB:
161-1 - Hydrolysis
Photodegradat ion
161-2 - In water
161-3 - On soil
161-4 - In Air

METABOLISM STUDIES-LAB:

162-1 - Aerobic Soil

162-2 - Anaerobic Soil

162-3 - Anaerobic Aquatic

162-4 - Aerobic Aquatic
MOBILITY STUDIES:
163-1 - Leaching and
Adsorption/Desorption
163-2 - Volatility (Lab)

163-3 - Volatility (Field)
Test
Substance


TCAI or

TGAI or
TGAI or
TGAI or



TGAI or

TGAI or

TGAI or

TGAI or

TGAI or

TEP

TEP


PAIRA

PAIRA
PAIRA
PAIRA


5/
AEP

PAIRA
5/
AEP
5/
AEP

PAIRA




Use Does EPA Bibliographic Must Additional Time Frame
Patterns Have Data? Citation Data be for
Submitted? Submission


H

H
H
H



H

H

H

H

H

H

H


No

No
No
No



No

No

No

No

No

No

No


Reserved

Reserved
Reserved
Reserved



Yes
2/
No-

Yes

Yes

Reserved

Yes
3/
Reserved"







CO
in

27 Months



27 Months

27 Months



12 Months



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                                                   TABLE A
GENERIC DATA REQUIREMENTS FDR PRODUCTS CONTAINING ARSENIC.  CHROMIUM AND CHRCMATED ARSENICAL COMPOUNDS
 Arsenic in arsenic and chromated arsenical compounds ([XJAs & [XJCrAs),
 Vhen [X]compound is an ionic form of copper;  pentachlorophenate;  2,4-dinitrophenol;  or amnonia mixed
 with [XJarsenic and [X]arsenic/chromiiDn
Data Requirement
SI 58. 130 Environmental Fate -
DISSIPATION STUDIES-FIELD:
164-1 - Soil
164-2 - Aquatic (Sediment)
(
164-3 - Forestry
164-4 - Combination and
Tank Mixes

164-5 - Soil, Long-term

ACCUMULATION STUDIES:

165-1 - Rotational Crops
(Confined)

165-2 - Rotational Crops
(Field)
165-3 - Irrigated Crops
165-4 - In Fish
165-5 - In Aquatic Non-Target
Test
Substance
Continued

TEP
TEP

TEP
TEP


TEP



PAIRA


TEP

TEP
TGAI or PAIRA
TEP
Use
Patterns


H
H

H
H


H



H


H

H
H
H
Does EPA Bibliographic
Have Data? Citation


No
No

No
No


No



No


No

No
No
No
Must Additional
Data be
Submitted?


Reserved
Reserved
21
No"
Reserved"

2/
No"


2/
No

2/
No"

Reserved
Reserved
Reserved
Time Frame
for
Submission









ON
in










    Organisms

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                                                     TABLE A

GENERIC DATA REQUIREMENTS FUR PRODUCTS CONTAINING ARSENIC, CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
 Chromium in chromium and chromated arsenical compounds  ([X]Cr &  [X]CrAs),
 When [X]compound is an ionic form of copper; pentachlorophenate; 2,4-dinitrophenol; or ammonia mixed
 with [XJchromium and [X]arsenic/chromium
Data Requirement
S 158. 130 Environmental Fate
DEGRADATION STUDIES-LAB:
161-1 - Hydrolysis
Photodegradation
161-2 - In water
161-3 - On soil
161-4 - In Air
METABOLISM STUDIES-LAB:
162-1 - Aerobic Soil
162-2 - Anaerobic Soil
162-3 - Anaerobic Aquatic
162-4 - Aerobic Aquatic
MOBILITY STUDIES:
163-1 - Leaching and
Adsorption/Desorption
163-2 - Volatility (Lab)
163-3 - Volatility (Field)
Test
Substance
TGAI or

TGAI or
TGAI or
TGAI or
TGAI or
TGAI or
TGAI or
TGAI or
TGAI or
TEP
TEP
PAIRA

PAIRA
PAIRA
PAIRA
PAIRA
PAIRA
PAIRA
PAIRA
PAIRA

Use Does EPA Bibliographic Must Additional Tine Frame
Patterns Have Data? Citation Data be for
Submitted? Submission
H

H
H
H
H
H
H
H
H
H
H
No

No
No
No
No
No
No
No
No
No
No
Reserved

Reserved
Reserved
Reserved
Reserved
2/
No
Reserved
Reserved
Reserved
Yes
I/
Reserved





O
\D



12 Months

-------
                                                        TABLE A
     GKNERIC DATA REQUIREMENTS FOR PRODUCTS CONTAINING ARSENIC, CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
      Chromium in chromium and chromated arsenical compounds ([XJCr & [XjCrAs),
      When [X]compound is an ionic form of copper; pentachlorophenate; 2,4-dinitrophenol; or ammonia mixed
      with [XJchromium and [X]arsenic/chromium
Data Requirement
§158.130 Environmental Fate -
DISSIPATION STUDIES-FIELD:
164-1 - Soil
164-2 - Aquatic (Sediment)
164-3 - Forestry
164-4 - Combination and
Test
Substance
Continued
TEP
TEP
TEP
TEP
Use
Patterns
H
H
H
H
Does EPA Bibliographic
Have Data? Citation
No
No
No
No
Must Additional
Data be
Submitted?
Reserved
Reserved
2/
No
Reserved"
Time Frame
for
Submission



         Tank Mixes

164-5 - Soil, Long-term

ACCUMULATION STUDIES:
TEP
H
No
No"
                                                           2/

165-1


165-2

165-3
165-4
165-5

- Rotational Crops
(Confined)

- Rotational Crops
(Field)
- Irrigated Crops
- In Fish
- In Aquatic Non-Target

PAIRA


TEP

TEP
TGAI or PAIRA
TEP

H


H

H
H
H

No


No

No
No
No
2/
No

2/
No

Reserved
Reserved
Reserved
         Organisms

-------
                                                     TABLE A

GENERIC DATA REQUIREMENTS FDR PRODUCTS CONTAINING ARSENIC, CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
 When [X]compound is an Ionic form of copper;  pentachlorophenate;  2,4-dinitrophenol;  or amnonia mixed
 with [XJarsenic, [XJchromium and [XJarsenic/cnromixm
Data Requirement
SI 58. 130 Environmental Fate
DEGRADATION STUDIES-LAB:
161-1 Hydrolysis
Photodegradat ion
161-2 - In water
161-3 - On soil
161-4 - In Air
METABOLISM STUDIES-LAB:
162-1 - Aerobic Soil
162-2 - Anaexubic Soil
162-3 - Anaerobic Aquatic
162-4 - Aerobic Aquatic
MOBILITY STUDIES:
163-1 - Leaching and
Adsorption/Desorption
163-2 - Volatility (Lab)
163-3 - Volatility (Field)
Test
Substance
TGAI of

TCAI or
TGAI or
TGAI or
IGAI or
TGAI or
TGAI or
TGAI or
TGAI or
TEP
TEP
PAIRA

PAIRA
PAIRA
PAIRA
PAIRA
PAIRA
PAIRA
PAIRA
PAIRA


Use Does EPA Bibliographic Must Additional Time Frame
Patterns Have Data? Citation Data be for
Submitted? Submission
H

H
H
H
H
H
H
H
H
H
H
No

No
No
No
No
No
No
No
No
No
No
Reserved

Reserved
Reserved
Reserved
Reserved
21
No~
Reserved
Reserved
Reserved
Yes
Reserved"




C\J
NO



12 Months


-------
                                                   TABLE A
GENERIC DMA REQUIREMENTS FDR PRODUCTS CONTAINING ARSENIC, CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
 When [X]compound is an ionic form of copper;  pentachlorophenate; 2,4-dinitrophenol; or ammonia nixed
 with [XJarsenic, [X] chromium and [X]arsenic/chromiun
Data Requirement
Test
Substance
Use
Patterns
Does EPA Bibliographic
Have Data? Citation
Must Additional
Data be
Submitted?
Tine Frame
for
Submission
§158.130 Environmental Fate - Continued
DISSIPATION STUDIES-FIELD:
164-1 - Soil
164-2 - Aquatic (Sediment)
164-3 - Forestry
164-4 - Combination and
Tank Mixes
164-5 - Soil, Long-term
ACCUMULATION STUDIES:
165-1 - Rotational Crops
(Confined)
165-2 - Rotational Crops
(Field)
165-3 - Irrigated Crops
165-4 - In Fish
165-5 - In Aquatic Non-Target
TEP
TEP
TEP
TEP
TEP
PAIRA
TEP
TEP
TGAI or PAIRA
TEP
H
H
H
H
H
H
H
H
H
H
No
No
No
No
No
No
No
No
No
No
Reserved
Reserved
2/
No"
Reserved"
2/
No
2/
No"
Reserved
Reserved
Reserved


NO




    Organisms

-------
                                                   TABLE A

GENERIC DATA REQUIREMENTS FDR PRODUCTS CONTAINING ARSENIC.  CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
 When [X]compound is an ionic form of copper;  pentachlorophenate;  2,4-dinitrophenol;  or ammonia mixed
 with [XJarsenic, [Xjchromium and [X]arsenic/chromium
Data Requirement
§158.130 Environmental Fate
SPECIAL STUDIES -IAB:
Availability Studies
Aqueous Availability
Soil Availability
Test Use
Substance Patterns
- Continued
5/
AEP H
5/
AEP H
Does EPA Bibliographic
Have Data? Citation

Partially GS-0647-001
No
Must Additional
Data be
Submitted?

V
Yes"
I/
Yes
Time Frame
for
Submission

12 Months
12 Months
SPECIAL STUDIES - EXPOSURE
Ambient Air Availability
[X]
Total Cr
Speciated Cr
As
Studies
TEP H
TEP H
TEP H
TEP H
No
No
No
No
i/
Reserved
11
Yes"
Reserved"
Yes"'
12 Months



-------
                                                    TABLE A
GENERIC DATA REQUIREMENTS TOR PRODUCTS CONTAINING ARSENIC,  CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
 When [X]compound is an ionic form of copper;  pentachlorophenate;  2,4-dinitrophenol;  or ammonia mixed
 with [XJarsenic, [X]chromium and [X]arsenic/chromium
Data Requirement
Test Use Does EPA Bibliographic Must Additional Time Frame
Substance Patterns Have Data? Citation Data be for
Submitted? Submission
§158.140 Reentry Protection
132-1
132-2
133-3
133-4
- Foliar Dissipation
- Soil Dissipation
- Dermal Exposure
- Inhalation Exposure
TEP
TEP
TEP
TEP
H
H
H
H
No
No
No
No
Reserved
Reserved
Reserved
Reserved
                                                                                                                NO

-------
                                                        TABLE A

GENERIC DATA REQUIREMENTS FOR PRODUCTS CONTAINING ARSENIC. CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
  When [Xjcompound is an ionic form of copper; pentachlorophenate; 2,4-dinitrophenol; or ammonia mixed
  with [XJarsenic, [Xjchromium and [X]arsenic/chromium

§158.130 Environmental Fate

jy For all applied end-use products, tests are to be made after product is applied with normal processing techniques
   and allowed to cure in usual manner.  Products to be tested will be the treated wood or wood products as
   availabe in the marketplace.
2/ No use pattern identified by this Standard which requires this data.
y Field volatility study reserved pending the result of the laboratory volatility study.
4/ Some chromated arsenical wood preservative products may be formulated as tank mixes.  Additional data may be
   required on these mixes at a later date.
5/ AEP = applied end-use product; tests must determine the availability of chromium(Cr) and arsenic(As) to aqueous
   and soil media after application of a formulated end-use product to wood.
6/ Study reserved pending results of volatility and availability studies.
T_l Exposure study required to determine the levels of airborne, total Cr and Cr/As ratio in air of [X]CrAs and
   [X]As treating plants.  An acceptable speciated Cr in air study may be substituted for the total Cr air
   availability study.  Protocols should be submitted for review prior to the initiation of this study and be
   consistent with Subdivision U of the Pesticide Exposure Guidelines.
8/ Study is reserved pending the results of the total chromium in air study.
5/ Monitoring of arsenic in air of treating plants as required under the Federal Register Notice
   (51 FR 1334) January 10, 1986.

-------
                                                   TABLE A



CKNKRIC DATA REQUIREMENTS FOR PRODUCTS CONTAINING ARSENIC, CHROMIUM AND CHRGMATED ARSENICAL CaiPOtlNDS
Date
§158
Requirement
.135 Toxicology
Test
Substance

Use
Patterns

Does EPA Bibliographic
Have Data? Citation

ACUTE TESTING:
81-1
81-2
81-3
81-7
- Acute Oral Toxic ity - Rat
- Acute Dermal Tbxicity
- Rabbit
- Acu^e Inhalation Tbxicity
- Rat
- Delayed
Neurotoxicity - Hen
TGAI
TGAI
TGAI
TGAI
B
B
B
B
N/A
N/A
N/A
N/A
Must Additional
Data be
Submitted
t/
No
I/
No
No"
I/
No
Time Frame
for
Submission


SUBCHRONIC TESTING:
82-1

82-2
82-3
82-4
82-5

- 90-Day Feeding:
- Rodent, and
- Non- rodent (Dog)
- 21 -Day Dermal - Rabbit
- 90-Day Dermal - Rabbit
- 90-Day Inhalation:
- Rat
- 90-Day Neurotoxicity:
- Hen
-Mammal
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
B
B
B
N/A
N/A
B
B
Yes 00159870,
GS-0647-02
Yes 00159870,
GS-0647-02
Yes 00120843


No
Yes 00159870
No
No
No
N/A
N/A
No
No
NO







-------
                                                        TABU-: A
      CKNKRIC  DATA RHQUIRHMKNTS FDR PRODUCTS CONTAINING AKSRNIC, CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
Hit:.-!
§158
Requirement Test
Substance
.135 Toxicology - Continued
Use
Patterns

Does EPA
Have Data?

Bibliographic
Citation

Must Additional
Data be
Submitted?

Time Frame
for
Submission

CHRONIC TESTING:
83-1





83-2






83-3







83-4

- Chronic Toxicity -
2 species:
- Rodent, and TGAI

- Non-rodent (Dog) TGAI

- Oncogen icity -
2 species:
- Rat (preferred), and TGAI


- Mouse (preferred) TGAI

- Teratogenicity -
2 species:
- Rodent other than TGAI
rat

- Rabbit TGAI


- Reproduction - Rat TGAI
2 -generation


B

B



B


B



B


B


B



Yes

Yes



Yes


Yes



No


No


No



00159870,
GS-0647-02
00159870,
CS -0647-02


00159870,
GS-0647-02

00159870,
GS-0647-02












No

No



No


No


21
[As] YesT/
[CrJ Yes
21
[As] Yes7/
[Cr] Yes
4/
[As] Yes4"/
[Cr] Yes"









CO
vO





15 Months


15 Months

39 Months
39 Months
riTTAGENICITY TESTING
84-2
84-2
- Gene Mutation (Ames Test) TGAI
- Structural Chromosomal TGAI
B
B
Yes
Yes
GS-0647-02
GS-0647-02
No
No


        Aberration
84-4 - Other Genotoxic Effects    TGAI
B
Ye*
GS-Ofi47-n?
Mr,

-------
                                                TABLF.A



CWJKRIC DATA REQUIREMENTS FOR PRODUCTS CONTAINING ARSENIC, CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
Data
§158
Requirement
.135 Toxicology - Continued
Test
Substance

Use
Pattern

Does EPA
Have Data?

Bibliographic
Citation

Must Additional
Data be
Submitted?

Time Frame
for
Submission

SPECIAL TESTING
85-1
85-2
86-1
- General Metabolism
- Dermal Penetration
- Domestic Animal
TEP
Choice
Choice
B
B
B
Partially
No
Yes
GS-0647-02

GS-0647-02
5/
Yes
No
No
24 Months


   Safety

-------
                                                        TABUS A

     GKNKRIC DATA REQUIREMENTS FOR PRODUCTS CONTAINING ARSENIC. CHRCMIIM AND CHRfMATED ARSENICAL COMPOUNDS


§158.135 Toxicology - Continued

\_l There is no technical grade active ingredient for chrcmiun and chromated  arsenicals.   The acute toxiclty of
   arsenic and chromium is thoroughly documented in public literature and acute  toxicity tests  on the separate ions
   are not necessary.  However, acute toxicity tests are required on all formulated  products (see tables B and C).
y Teratogenicity study on arsenic to be submitted by July 1988 as per the Special Review Data  Call-in letter dated
   April 7. 1986.
3/ Test material should be a formulated chromated arsenical product.
4/ Test material should be a formulated chromated arsenical product.   This test  will satisfy the reproduction
   study requirement for both [As] and [CrJ.
V The Agency requires a repeated-dose metabolism study on a rodent other than the rat.   The Agency should be
   consulted regarding the test material.  The preferred test material is a  formulated chromated arsenical.   The
   protocol must include determination of blood levels of chrcmiun and arsenic during treatment.

-------
                                                        TABIJi A

     UKNKRIC DATA REQUIREMENTS FOR PRODUCTS CONTAINING ARSENIC,  CHROMIUM AND CHROMATED ARSENICAL COMPOUNDS
Data Requirement Test 1/ Use
Substance Pattern
§158.145 Wildlife and
Aquatic Organisms
AVIAN AND MAMMALIAN TESTING
71-1 - Acute Avian Oral Toxicity TEP B, D, H
71-2 - Avian Subacute Dietary TEP B, D. H
Toxicity
-.Upland Game Bird, and
- Waterfowl
71-3 - Wild Hanmal Toxicity TEP B, D
71-4 - Avian Reproduction TEP B
Does EPA Bibliographic
Have Data? Citation
No
Partially 000104061
000106113
No
No
Must Additional
Data be
Submitted?
Yes
21
Yes
3/
No
4/
No
Time Frame
for
Submission
9 Months
9 Months
r^
        - Upland Game Bird, and

        - Waterfowl

71-5 - Simulated Field Testing     TEP
        - Mammals, and

        - Birds

     - Actual Field Testing        TEP
        - Mammals, and
B
No
           No
                                              4/
No
                                 No
        - Birds

-------
                                                        TABLE A



     (,-KNFRlC IWTA REQUIREMENTS FOR PRODUCTS CONTAINING ARSENIC, CHROMIUM AND CHRCMATED ARSENICAI. COMPOUNDS
Data
§158

Requirement Test Use Does EPA Bibliographic
Substance Pattern Have Data? Citation
.145 Wildlife and
Aquatic Organisms - Continued
AQUATIC ORGANISM TESTING
72-1

72-2
72-3

72-4
- Freshwater Fish Toxicity TEP B, D, H Partial 000099363
- Coldwater Fish Species,
and
- Warmwater Fish Species
- Acute Toxicity to TEP B, D, H No
Freshwater Invertebrates
- Acute Toxicity to TEP D No
Estuarine and Marine
Organisms
- Fish
- Mollusk
- Shrimp
- Fish Early Life Stage, TEP D No
and
- Aquatic Invertebrate
Must Additional Time Frame
Data be for
Submitted? Submission

5/
Yes 9 Months
9 Months
Yes 9 Months
o/ .^
v ^*"
12 Months
12 Months
12 Months
11
Yes 15 Months
15 Months
           life-Cycle



72-5 - Fish - Life-Cycle
TEP
D
Reserved

-------
     (;KNKRIC FWTA REQUIRFMENTS FOR PRODUCTS CONTAINING ARSFNIC. cHRcrnuM AND CHRCMATRD APSFNICAL orripoiiNDS
Ifcta Requirement
Test     \J  Use        Does RPA     Bibliographic
Substance    Pattern    Have Data?   Citation
                                 Must Additional
                                 Data be
                                 Submitted?
                    Time Frame
                       for
                    Submission
§158.145 Wildlife and
         Aquatic Organisms - Continued


72-6 - Aquatic Organism       TEP
         Accumulation

          - Crustacean

          - Fish

          - Insect Nymph

          - Mollusk

72-7 - Simulated Field Testing    TEP
          - Aquatic Organisms

      - Actual Field Testing
          -Aquatic Organisms
             D
                        No
                                         8/
                                 Reserved"
No
        8/
Reserved"

-------
                                                      TABIE A

     CKNKRIC DATA RHQUIRFI1ENTS FOR PRODUCTS CONTAINING ARSENIC,  CHROMIUM AND CHROMATED ARSENICAL COMPOINDS

§158.145 Wildlife and Aquatic Organisms - Continued

I/ There is no actual technical grade of the active ingredient for chromium and chronated arsenicals.  Therefore a
   typical end-use product should be used as the test material.
2j Both studies cited may be upgraded if the percent active ingredient is clarified.   Study assumed 100% active
   ingredient; percent a.i. used must be documented.
3/ Not usually required unless there is a unique exposure situation for feral animals.  Toxicology acute testing
   suffices.
4_/ Not required because exposure to avian and mammal species is  expected to be minimal.
J>/ Study may be upgraded if dissolved oxygen measurements and pH values, as required  by the Pesticide Assessment
   Guidelines; Subdivision E, are submitted.
6/ Required to support use of treated wood in estuarine/marine environments.
7/ Required because of expected  continuous exposure of aquatic  organisms through leaching of chromated arsenicals
   from submersed wood.
   a) A flowr-through system should not be used.  Rather, two tanks, a test tank and a "leaching tank" should be
      set up and the water should circulate between the two.  The first tank, containing the test organisms, should
      be set up as in a normal study but with a provision for recirculation.  The second tank should be large, at
      least 200 gallons, so that waste products may be diluted to maintain good water quality.   Data should be
      submitted showing that materials used to construct the tanks do not absorb or adsorb the ions of interest
      to a significant extent.  In this second tank, the CCA-treated wood should be placed in such a way as to
      maximize surface area, i.e., using 1" boards spaced apart  rather than using 4"  X 4" posts.  The volume of
      wood used should be 1/100th of the volume of the tank.  Three replications of each treatment group should
      be performed.
   b) A control tank system identical to the treatment system should be performed concurrently using, in place of
      the treated wood, an equal volume and surface area of untreated wood of the same species (untreated control).
      Additionally, a negative control, using no wood at all, should be performed.
   c) The concentration of total chromium, and arsenic, and additional ions should be measured biweekly and the
      ions should be speciated as to valence state.
   d) To insure that the water quality at the beginning of the test is the highest possible, the dilution water,
      both fresh and salt, should be reconstituted from deionized water and chemicals of at least reagent-grade
      purity should be used.  Refer to "Methods for Acute Toxicity Tests for Fish, Macroinvertebrates and
      and Amphibians", EPA-660/3-75-009, April 1975.  The dilution water should be assayed for chromium, arsenic,
      and additional ions at test initiation.  All other test standards and data reporting should conform to the
      guidelines for a fish early life-stage test as set forth in EPA's Pesticide Assessment Guidelines;
      Subdivision E.  In this way, both the amount of chromium,  arsenic, and additional ions leaching from the
      wood can be estimated and the subchronic effects of these  ions on fish can be determined.
/ Reserved pending outcome of acute and suhchronic aquatic testing.

-------
                                                     TABLE B
     PRODUCT SPECIFIC DATA REQUIREMENTS FDR MANUFACTURING-USE PRODUCTS CONTAINING ARSENIC. CHROMIUM & CHROMATED
       ARSH4ICAL COMPOUNDS
Data Requirement Test Use Does EPA Bibliographic Must Additional Time Frame
Substance Pattern Have Data?1 Citation' Data be for
Submitted? Submission
SI 58. 120 Product Chemistry
Product Identity:
61-1 - Product Identity and MP All No
Disclosure of
Ingredients
61-2 - Description of Beginning MP All No
Materials and
Manufacturing Process
61-3 - Discussion of Formation MP All No
of Impurities
Analysis and Certification of Product
Ingredients
62-1 - Preliminary Analysis MP All No
62-2 - Certification of Limits MP All No
62-3 - Analytical Methods to Verify MP All No
Certified Limit
N/A Yes
N/A Yes
N/A Yes
N/A Yes
N/A Yes
N/A Yes
6 Months
6 Months
6 Months
to
fx.
12 Months
12 Months
12 Months
I/ Not applicable.  Although product  chemistry data may have been submitted In the past, the Agency has determined that
   these data must be resubmitted for each manufacturing use product.  New requirenients have been introduced and
   previously submitted data must be  updated.  Therefore bibliographic citations for the old data are not applicable.

-------
                                                      TABLE B

PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS CONTAINING ARSENIC, CHROMIUM & CHRCMATED
  ARSENICAL COMPOUNDS
Data
§158.
ACUTE

81-1
81-2


81-3


81-4


81-5


81-6


81-7-

Requirement
135 Toxicology
TESTING

- Acute Oral Toxicity -
- Acute Dermal Toxicity
- Rabbit

- Acute Inhalation Toxicity
-

- Primary Eye
Irritation - Rabbit

- Primary Dermal
Irritation - Rabbit

- Dermal Sensitization -
Guinea Pig

Acute Delayed Neurotoxicity
Hen
Test
Substance



MP
MP


MP


MP


MP


MP


- MP

Use
Pattern



B
B


B


B


B


B


B

Does EPA Bibliographic
Have Data? Citation



No
No


No


No


No


No


No

Must Additional
Data be
Submitted?



Yes
Yes"

M
Yes

V
Yes

V
Yes

I/
Yes
21
No


Time Frame
for
Submission



9 Months
9 Months


9 Months
fv.

9 Months


9 Months


9 Months




I/ The studies are to be performed on a rodent other  than  the  rat.  The Agency may waive certain acute
   studies on specific formulations of copper chromated arsenicals  if adequate data  are already on file
   for a copper chromated arsenical formulation which the  Agency deems applicable, based on
   close similarity of composition.
2J The Agency does not ordinarily require neurotoxicity testing of  pesticides which  are not organophosphates.

-------
                                                      TAULE C
     PRODUCT SPECIFIC DATA REQUIREMENTS FOR END-USE PRODUCTS CONTAINING ARSENIC, CHROMIUM & CHROMATED
       ARSENICAL COMPOUNDS
Data Requirement
Test
Substance
Use
Pattern
Does EPA
Have Data?1
Bibliographic
Citation1
Must Additional
Data be
Submitted?
Time Frame
for
Submission
§158.120 Product Chemistry
Product Identity and Composition
61-2 - Description of Beginning
       Materials and Manufacturing
       Process                      EP
Analysis and Certification of
Product Ingred ients
62-1 - Preliminary Analysis of
       Product Samples
62-2 - Certification of
       Ingredient Limits
EP

EP
All



All

All
No



No

No
N/A



N/A

N/A
Yes"



Yes

Yes
                                                            2/
6 Months



6 Months

6 Months
I/ Not applicable.  Although product chemistry data may have been submitted in the past, the Agency has determined that
   these data must be resubmitted for each end-use product.  New requirements have been introduced and
   previously submitted data must be updated.  Therefore bibliographic citations for the old data are not applicable,  j

2J Only the source and a description of As, Cu, Cr, and any other active ingredients must be provided.  This is
   to include company name and address, product name, percent by weight, and technical data sheets, and
   EPA Registration Number, if a registered product.

-------
                                             TABLE C

 PRODUCT SPECIFIC DATA REQUIREMENTS  FDR END-USE PRODUCTS CONTAINING ARSENIC,  CHROMIUM & CHROMATED
   ARSENICAL COMPOUNDS
Data
§158
Requirenent Test
Substance
.135 Toxicology

Use Does EPA Bibliographic Must Additional Time Frame
Pattern Have Data? Citation Data be for
Submitted? Submission




ACUTE TESTING

81-1

81-2


81-3

81-4

81-5


81-6


81-7-


- Acute Oral Toxicity -

- Acute Dermal Toxicity
- .Rabbit

- Acute Inhalation Toxicity

- Primary Eye
Irritation - Rabbit
- Primary Dermal
Irritation - Rabbit

- Dermal Sensitization -
Guinea Pig

Acute Delayed Neurotoxicity -
Hen

EP

EP


EP

EP

EP


EP


EP


B

B


B

B

B


B


B


No

No


No

No

No


No


No

I/
Yes
I/
Yes"

V
Yes
I/
Yes

I/
Yes

I/
Yes"
21
No



9 Months

9 Months


9 Months

9 Months

GC
9 Months^


9 Months




I/ The studies are to be performed on a rodent other than the rat.  The Agency may waive certain acute
   studies on specific formulations of copper chromated arsenicals if adequate data are already on file
   for a copper chromated arsenical formulation which the Agency deems applicable, based on
   close similarity of composition.
2/ The Agency does not ordinarily require neurotoxicity testing of pesticides which are not organophosphates.

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                          SUMMARY-1

                        LABEL CONTENTS

     40 CFR 162.10 requires that certain specific labeling
statements appear at certain locations on. the label.   This
is referred to as format labeling.  Specific label items  listed
below are keyed to the table at the end of this  Appendix.

     Item 1.  PRODUCT NAME - The name, brand or  trademark is
required to be located on the front panel, preferably centered
in the upper part of the panel.  The name of a product will
not be accepted if it is false or misleading.

     Item 2.  COMPANY NAME AND ADDRESS - The name and address
of the registrant or distributor is required on  the label.
The name and address should preferably be located at the
bottom of the front panel or at the end of the label text.

     Item 3.  NET CONTENTS - A net contents statement is
required on all labels or on the container of the pesticide.
The preferred location is the bottom of the front panel
immediately above the company name and address,  or at the end
of the label text.  The net contents must be expressed in the
largest suitable unit, e.g., "1 pound 10 ounces" rather than
"26 ounces." In addition to English units, net contents may
be expressed in metric units.  [40 CFR 162.10(d)]

     Item 4.  EPA REGISTRATION NUMBER - The registration
number assigned to the pesticide product must appear on the
label, preceded by the phrase "EPA Registration  No.," or  "EPA
Reg. No."  The registration number must be set in type of a
size and style similar to other print on that part of the
label on which it appears and must run parallel  to it.  The
registration number and the required identifying phrase must
not appear in such a manner as to suggest or imply recommendation
or endorsement of the product by the Agency.
[40 CFR 162.10(e)]

    Item 5.  EPA ESTABLISHMENT NUMBER - The EPA  establishment
number, preceded by the phrase "EPA Est." is the final estab-
lishment at which the product was produced, and  may appear
in any suitable location on the label or immediate container.
It must also appear on the wrapper or outside container of
the package if the EPA establishment number on the immediate
container cannot be clearly read through such wrapper or container.
[40 CFR 162.10(f)J

    Item 6A. INGREDIENTS STATEMENT - An  ingredients statement
is required on the front panel.  The ingredients statement must
contain the name and percentage by weight of each active ingredient
and the total percentage by weight of all inert  ingredients.
The preferred location is immediately below  the  product name.
The ingredients statement must run parallel with, and be clearly
distinguished from, other text on the panel.  It must not be
placed in the body of other text.  [40 CFR  162.10(g)]

                            79

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                            SUMMARY-2

    Item 6B.  POUNDS PER GALLON STATEMENT - For liquid  agricul-
tural formulations, the pounds per gallon of active ingredient
must be indicated on the label.

    Item 7.  FRONT LABEL PRECAUTIONARY STATEMENTS  - Front  panel
precautionary statements must be grouped together,  preferably
within a block outline.  The table below shows the  minimum type
size requirements for various size labels.

    Size of Label        Signal Word          "Keep Out of Reach
    on Front Panel       Minimum Type Size      of Children"
    in Square Inches     All Capitals          Minimum  Type Size

    5 and under                6 point              6 point
    above 5 to 10             10 point              6 point
    above 10 to 15            12 point              8 point
    above 15 to 30            14 point             10 point
    over 30                   18 point             12 point

    Item 7A.  CHILD HAZARD WARNING STATEMENT - The statement
"Keep Out of Reach of Children" must be located on the  front
panel above the signal word except where contact with children
during distribution or use is unlikely.   [40 CFR 162.10(h)(1)(ii)]

    Item 7B.  SIGNAL WORD - The signal word (DANGER, WARNING.
or CAUTION) is required on the front panel immediately  below
the child hazard warning statement.  [40 CFR 162.10 (h)(l)(i)J

    Item 7C.  SKULL & CROSSBONES AND WORD "POISON" - On products
assigned a  toxicity Category I on the basis of oral, dermal,
or inhalation toxicity, the word "Poison" shall appear  on the
label in red on a background of distinctly contrasting  color and
the skull and crossbones shall appear in  immediate proximity to
the word POISON.   [40 CFR 162.10(h)(1)(i)]

    Item 7D.  STATEMENT OF PRACTICAL TREATMENT - A statement
of practical treatment (first aid or other) shall  appear on
the label of pesticide products in  toxicity Categories I,
II, and III.  [40 CFR 162.10(h)(1)(ill)]

    Item 7E.  REFERRAL STATEMENT -  The  statement "See  Side
(or Back) Panel for Additional Precautionary  Statements"  is
required on the front panel for all  products,  unless all
required precautionary statements appear  on  the front  panel.
[40 CFR 162.10(h)(l)(iii)]

    Item 8.  SIDE/BACK PANEL PRECAUTIONARY LABELING -  The
precautionary statements listed below must appear  together
on the label under  the heading  "PRECAUTIONARY STATEMENTS."
The preferred location is at the  top of the  side or back
panel preceding the directions  for  use, and  it is  preferred
that these  statements be surrounded by  a block outline.   Each
of the three hazard warning statements  must  be headed  by  the
appropriate hazard  title.   [40 CFR  162.10(h)(2)].

                         80

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                          SUMMARY-3

    Item 8A.  HAZARD TO HUMANS AND DOMESTIC ANIMALS - Where a
hazard exists to humans or domestic animals, precautionary
statements are required indicating the particular hazard, the
route(s) of exposure and the precautions to be taken to avoid
accident, injury or damage.  [40 CFR 162.10(h)(2)(i)J

    Item 8B.  ENVIRONMENTAL HAZARD - Where a hazard exists to
non-target organisms excluding humans and domestic animals,
precautionary statements are required stating the nature of
the hazard and the appropriate precautions to avoid potential
accident, injury, or damage.  [40 CFR 162.10 (h) (2) (ii) ]

    Item 8C.  PHYSICAL OR CHEMICAL HAZARD - FLAMMABILITY
Precautionary statements relating to flammability of a product
are required to appear on the label if it meets  the criteria
in the PHYS/CHEM Labeling Appendix. The requirement is
based on the results of the flashpoint determinations and
flame extension tests required to be submitted for all products.
These statements are to be located in the side/back panel
precautionary statements section, preceded by the heading
"Physical/Chemical Hazards."  Note that no signal word is
used in conjunction with the flammability statements.

    Item 9A.  RESTRICTED USE CLASSIFICATION - FIFRA sec. 3(d)
requires that all pesticide formulations/uses be classified
for either general or restricted use.  Products  classified
for restricted use may be limited to use by certified applicators
or persons under their direct supervision (or may be subject
to other restrictions that may be imposed by regulation).

    In the Registration Standard, the Agency has (1) indicated
certain formulations/uses are to be restricted (Section IV
indicates why the product has been classified for restricted
use);  or (2) reserved any classification decision until
appropriate data are submitted.

    The Regulatory Position and Rationale states whether
products containing this active ingredient are classified
for restricted use.  If they are restricted the draft label(s)
submitted to the Agency as part of your application must
reflect this determination (see below).

     If you do not believe that your product should be classified
for restricted use, you must submit any information  and
rationale with your application for reregistration.  During
the Agency's review of your application, your proposed classi-
fication determination will be evaluated in accordance with
the provisions of 40 CFR 162.11(c).  You will be notified  of
the Agency's classification decision.
                           81

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                          SUMMARY-4

     Classification Labeling Requirements

     If your product has been classified for restricted use.
the following label requirements apply:

     1.  All uses restricted.

         a.  The statement "Restricted Use Pesticide" must
     appear at the top of the front panel of the label.  The
     statement must be set in type of the same minimum size
     as required for human hazard signal word (see table in 40
     CFR 162.10(h)(1)(iv)

         b.  Directly below this statement on the front panel,
     a summary statement of the terms of restriction must
     appear (including the reasons for restriction if specified
     in Section I).  If use is restricted to certified applicators,
     the following statement is required:  "For retail sale
     to and use only by Certified Applicators or persons
     under their direct supervision and only for those uses
     covered by the Certified Applicator's Certification."

     2.  Some but not all uses restricted.  If the Regulatory
Position and Rationale states that some uses are classified
for restricted use, and some are unclassified, several courses
of action are available:

          a.  You may label the product for Restricted use.
     If you do so, you may include on the label uses that
     are unrestricted, but you may not distinguish them
     on the label as being unrestricted.

          b.  You may delete all restricted uses from your
     label and submit draft labeling bearing only unrestricted
     uses.

          c.  You may "split" your registration, i.e., register
     two separate products with identical formulations, one
     bearing only unrestricted uses, and the other bearing
     restricted uses.  To do so, submit two applications for
     reregistration, each containing all forms and necessary
     labels.  Both applications should be submitted  simul-
     taneously.  Note that the products will be assigned
     separate registration numbers.

    Item 9B.  MISUSE STATEMENT - All products must bear  the
misuse statement, "It is a violation of Federal law  to use
this product in a manner inconsistent with  its labeling."
This statement appears at the beginning of  the directions
for use, directly beneath the heading of that section.

-------
                          SUMMARY-5

    Item 10A.  REENTRY STATEMENT - If a reentry interval
has been established by the Agency, it must be included on
the label.  Additional worker protection statements may be
required in accordance with PR Notice 83-2, March 29, 1983.

    Item 10B.  STORAGE AND DISPOSAL BLOCK -  All labels are
required to bear storage and disposal statements.  These
statements are developed for specific containers, sizes, and
chemical content.  These instructions must be grouped and
appear under the heading "Storage and Disposal" in the directions
for use.  This heading must be set in the same type sizes as
required for the child hazard warning.  Refer to Appendix II,
STOR, PEST/DIS, and CONT/DIS to determine the storage and
disposal instructions appropriate for your products.

    Item IOC.  DIRECTIONS FOR USE - Directions for use must
be stated in terms which can be easily read and understood by
the average person likely to use or to supervise the use of
the pesticide.  When followed, directions must be adequate to
protect the public from fraud and from personal injury and to
prevent unreasonable adverse effects on the environment.
[40 CFR 162.10]


                     COLLATERAL LABELING

    Bulletins, leaflets, circulars, brochures, data sheets,
flyers, or other written or graphic printed matter which is
referred to on the label or which is to accompany the product
are termed collateral labeling.  Such labeling may not bear
claims or representations that differ in substance from those
accepted in connection with registration of the product.  It
should be made part of the response to this notice and submitted
for review.
                            83

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                  SIM1ARY-6



LABELING REQUIREMENTS OK WE FIFRA, AS AMENDED
ITEM
1
"2
3
4
5
6A
6B
7
7A
7B
LABEL ELEMENT
Product name
Company name
and address
Net contents
EPA Reg. No.
EPA Est. No.
Ingredients
statement
Pounds/gallon
statement
Front panel
pr ecaut ionary
statements
Keep Out of Reach
of Children
(Child hazard
warning)
Signal word
APPLICABILITY
OF REQUIREMENT
All products
All products
All products
All products
All products
All products
Liquid products
where dosage
given as Ibs.
ai/unit area
AlT products
All products
products
PLACEMENT ON LABEL
REQUIRED
Front panel
None
None
None
None
Front panel
Front panel
Front panel
Front panel
Front panel
PREFERRED
Center front
panel
Bottom front
panel or end
of label text
Bottom front
panel or end
of label text
Front panel
Front panel,
immediately
before or
following
Reg. No.
Immediately
following
product name
Directly below
the main
ingredients
statement

Above signal
word
Immediately
below child
hazard
warning
COMMENTS

If registrant is not the producer, must
be qualified by "Packed for . . .,"
"Distributed by. . . ." etc.
May be in metric units in addition to
U.S. units
Must be in similar type size and run
parallel to other type.
May appear on die container instead of
the label.
Text must run parallel with other text
on the panel.
^T
ow
All front panel precautionary statements
must be grouped together, preferably
blocked.
Note type size requirements.
Note type size requirements.

-------
SUMMARY-7
1TKM
7C
7D
7E
8
8A
8B
LABEL ELEMENT
Skull & cross-
bones and word
POISON (in red)
Statement of
Practical
Treatment or
First Aid
Referral
statement
Side/back panel
precautionary
statements
Hazards to
humans and
domestic
animals
Environmental
hazards
APPLICABILITY
OF REQUIREMENT
All products
which are Cat-
egory I based
on oral, der-
mal, or inhala-
tion toxicity
All products
in Categories
I, II, and III
All products
where pre-
cautionary
labeling
appears on
other than
front panel.
All products
All products
in Categories
I, II, and III
All products
PLACEMENT ON LABEL
REQUIRED
Front panel
Category I:
Front panel
unless refer-
ral statement
is used.
Others :
Grouped with
side panel
precautionary
statements.
Front panel
None
None
None
PREFERRED
Both in close
proximity to
signal word
Front panel
for all.

Top or side
of back panel
preceding
directions
for use
Same as above
Same as above
COMMENTS


in
CO
Must be grouped under the headings in
8A, 8B, and 8C; preferably blocked.
Mist be preceded by appropriate signal
word.
Environmental hazards include bee
caution where applicable.

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SIM1ARY-8
ITEM
8C
9A
9B
10A
10B
IOC
LABEL ELEMENT
Physical or
chemical
hazards
Restricted
block
Misuse
statement
Reentry
statenent
Storage and
disposal block
Directions
for use
APPLICABILITY
OF REQUIREMENT
All pressurized
products, others
with flash
points under
150°F
All restricted
products
All products
PR Notice 83-2
or as determined
by the Agency
All products
All products
PLACEMENT ON LABEL
REQUIRED
None
Top center
of front
panel
Immediately
following
heading of
directions
for use
In the
directions
for use
In the
directions
for use
None
PREFERRED
Same as above
Preferably
blocked

Lined lately
after misuse
statement
Immediately
before
specific
directions
for use or
at the end of
directions
for use
None
COMMENTS
Refer to Appendix II guide
PHYS/CHEM
Includes a statement of the terms otJ
restriction. The words "RESTRICTED USE
PESTICIDE" must be same type size as
signal word.
Required statement is:
"It is a violation of Federal lav
to use this product in a manner
inconsistent with its labeling."

Must be set apart and clearly distin-
guishable from from other directions
for use. ^3
Refer to Appendix II guides STOR, 03
OONT/DIS. and PEST/DIS for further
information and required statements.
May be in metric as well as U.S. units

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§ 162.10 Labeling requirement*.
  (a)  General—(1)  Content*  of the
label  Every pesticide products  shall
bear a label containing the Informa-
tion specified by the Act and the regu-
lations In this Part. The contents of a
label must show  clearly and  promi-
nently the following:
  4t> The name, brand, or trademark
under which the product Is sold as pre-
scribed in paragraph 
-------
 Environmental Protection Agency

   (v)  The  producing  establishment
 number as prescribed In paragraph (f)
 of this section;
   (vi) An ingredient statement as pre-
 scribed in  paragraph (g) of this sec-
 tion;
   (vii) Warning or precautionary state-
 ments as prescribed in paragraph (h)
 of this section;
   (viii) The directions for use  as pre-
 scribed In paragraph (1) of this section;
 and
   (ix) The  use classification^)  as pre-
 scribed In paragraph (j) of this section.
   (2) Prominence and legibility. (1) All
 words, statements, graphic representa-
 tions, designs or other information re-
 quired on the laBelmg  by the  Act or
 the regulations  in this part must  be
 clearly legible  to a person with normal
 vision, and must be  placed with such
 consplcuousness  (as  compared  with
 other words, statements, designs,  or
 graphic matter on  the labeling) and
 expressed in such terms as to render it
 likely to be read and understood by
 the ordinary individual  under custom-
 ary conditions of purchase and use.
   (11) All required label text must:
   (A) Be set In 6-point or larger type;
   (B)  Appear  on a clear contrasting
 background; and
   (C) Not be obscured or crowded.
   (3) Language to be used. All required
 label or labeling text shall appear in
 the English language.  However, the
 Agency may require or the  applicant
 may propose additional text in other
 languages as is considered necessary to
 protect the public. When additional
 text in another language is necessary.
 all labeling -requirements will  be ap-
 plied equally to both the Fngitah and
 other-language versions of the label*
 ing.
  (4) Placement of Label—(I) General.
 The label shall appear on or be secure-
 ly attached to the Immediate contain-
 er of the pesticide product For pur-
 poses  of this  Section,  and  the  mis-
 branding provisions of  the  Act,  "se-
 curely attached"  shall  mean that a
 label can reasonably  be expected to
 remain affixed during the foreseeable
conditions and period of use. If the im-
mediate container is enclosed within a
wrapper or outside container through
which the label cannot be clearly read.
the label must also be securely  at-
                            § 162.10

 tached to such outside wrapper or con-
 tainer, if it Is a part of the package as
 customarily distributed or sold.
  (ii) Tank can  and other bulk con-
 tainers—(A)  Transportation. While  a
 pesticide product is in transit, the ap-
 propriate provisions of 49 CFR Parts
 170-189. concerning the transportation
 of hazardous materials, and specifical-
 ly those provisions concerning the la-
 beling, marking and placarding of haz-
 ardous materials  and the vehicles car-
 rying them, define the basic Federal
 requirements. In addition, when any
 registered  pesticide  product is trans-
 ported In  a tank car. tank truck or
 other mobile or portable bulk contain-
 er, a copy of the accepted label must
 be attached  to the shipping papers.
 and left with the consignee at the tune
 of delivery.
  (B) Storage. When  pesticide  prod-
 ucts are stored  in bulk  containers,
 whether mobile or stationary, which
 remain In  the custody of the user,  a
 copy of the label of labeling, including
 all appropriate directions for use, shall
 be securely attached to the container
 in the immediate vicinity  of the dis-
 charge control valve.
  (5) False or misleading ttatementt.
 Pursuant to section 2(qXlXA) of the
 Act,  a pesticide or a device declared
 subject  to  the  Act   pursuant to
 1162.15, is misbranded if its labeling Is
 false or  misleading in any particular
 including both pestiddal and non-pea-
 tiddal claims. Examples of statements
 or  representations  in  the labeling
 which  constitute  mlsbranding include:
  (1) A false or misleading statement
 concerning the  composition of the
 product;
  (ii) A false or misleading statement
concerning the effectiveness of the
 product as a pesticide or device;
  (ill) A false or misleading statement
about  the value of the product for
purposes other than as a pesticide or
device;
  (Iv) A false or misleading comparison
with other pesticides or devices;
  (v) Any  statement directly or  indi-
rectly  Implying that the pesticide or
device  Is recommended or endorsed by
any  agency of the Federal  Govern-
 ment;
  (vi) The name  of a pesticide which
contains two or more principal active
                                    88

-------
 § 162.10

 ingredients  if the name suggests one
 or  more  but not all  such principal
 active ingredients even though the
 names of the other ingredients are
 stated elsewhere in the labeling;
   (vii) A true statement used in such a
 way as to give a false or misleading im-
 pression to the purchaser.
   (viii) Label disclaimers which negate
 or detract from labeling statements re-
 quired under the Act and these regula-
 tions;
   (ix) Claims as to the safety of the
 pesticide or Its ingredients, including
 statements such as "safe," "nonpoison-
 ous,"  "nonlnjurious,"  "harmless" or
 "nontoxic to humans and pets" with
 or without such ^qualifying phrase as
 "when used as directed"; and
   (x) Non-numerical  and/or compara-
 tive statements on the  safety of the
 product, Including but not limited to:
   (A)  "Contains all  natural ingredi-
 ents";
   (B)  "Among the least  toxic chemi-
 cals known"
   "Pollution approved"
  (6) Final printed labeling, (i) Except
 as provided  in paragraph (aXGXii) of
 this  section,  final  printed  labeling
 must be submitted and accepted prior
 to registration. However, final printed
 labeling need not be submitted until
 draft label texts have been provision-
 ally accepted by the Agency.
  (11) Clearly legible reproductions or
 photo reductions will be accepted for
 unusual labels such  as thoee  silk-
 screened directly onto glass or metal
 containers  or large bag or drum labels.
 Such reproductions must be of micro-
 film reproduction quality.
  (b) Name,  brand, or trademark. (1)
 The name, brand, or trademark under
 which the pesticide  product Is  sold
 shall appear  on the front panel of the
 label.
  (2) No name, brand, or trademark
 may appear on the label which:
  (i) Is false or mM+sAir)g or
  (ii) Has not been approved by  the
 Administrator through registration or
 supplemental registration as an addi-
 tional name pursuant to 1162.6
-------
 Environmental Protection Agency

 or endorsement of the product by the
 Agency.
   (f)  Producing establishments  regis-
 tration number.  The producing estab-
 lishment registration number preced-
 ed by the  phrase "EPA Est.". of the
 final establishment at which the prod-
 uct was produced may appear in any
 suitable location on the label or imme-
 diate  container. It must appear on the
 wrapper  or outside container of the
 package if the EPA establishment reg-
 istration  number on the  immediate
 container  cannot  be  clearly  read
 through such wrapper or container.
   (g) Ingredient statement—<1) Gener-
 al. The label of each pesticide product
 must bear a statement which contains
 the name and percentage by weight of
 each active Ingredient, the total per-
 centage by weight of all inert ingredi-
 ents: and if the pesticide contains ar-
 senic in any form, a statement of the
 percentages of total and water-soluble
 arsenic calculated as  elemental ar-
 senic.  The active ingredients must be
 designated by the term "active ingredi-
 ents" and the inert ingredients by the
 term "inert ingredients," or the singu-
 lar forms of these terms when appro-
 priate. Both terms shall  be  In the
 same type size, be aligned to the same
 margin and be equally prominent. The
 statement "Inert Ingredients, none" is
 not required for pesticides which con-
 tain 100  percent active Ingredients.
 Unless the  ingredient statement Is a
 complete analysis of the pesticide, the
 term "analysis" shall not be used as a
 heading for the Ingredient statement.
  (2) Position of ingredient statement
 «) The Ingredient  statement  Is nor-
 mally  required on the front panel of
 the label. If there Is an outside con-
 tainer  or wrapper through which the
 Ingredient statement cannot be clearly
 read,  the ingredient  statement must
 also appear on such outside container
 or wrapper. If the size or form of the
 package makes  it Impracticable to
 place the Ingredient statement on the
 front  panel of the label,  permission
 may be granted for  the  Ingredient
statement to appear elsewhere.
 (ii) The text of the Ingredient state-
ment  must run  parallel with other
text on the panel oh which It appears.
and must  be clearly  distinguishable
                             § 162.10

  from and must not be placed  in the
  body of other text.
   (3) Names  to be used in ingredient
  statement. The name used for each in-
  gredient  shall  be   the  accepted
  common name, if  there  is one, fol-
  lowed  by  the chemical  name. The
  common name may be used alone only
  if it is well known. If no common name
  has been  established,  the chemical
  name alone shall be used. In no case
  will the use of a trademark or proprie-
  tary name be permitted  unless such
  name has been accepted as a common
  name by the  Administrator under the
  authority of Section 2S(c)(6).
   (4) Statements  of percentages. The
  percentages of  ingredients shall  be
  stated  in terms  of weight-to-weight.
  The sum of percentages of the active
  and the inert ingredients shall be 100.
  Percentages shall not be expressed by
  a range of values such as "22-25%." If
  the uses of the pesticide  product are
  expressed as  weight of active ingredi-
  ent per unit area, a statement of the
  weight of active  ingredient per unit
  volume of  the pesticide  formulation
  shall also  appear in  the ingredient
  statement.
   (5) Accuracy of stated percentages.
  The percentages given shall be as pre-
  cise as possible reflecting  good manu-
  facturing practice. If there may be un-
  avoidable variation  between manufac-
  turing  batches, the value stated for
  each active ingredient shall be the
  lowest   percentage  which  may  be
  present.
   (6) Deterioration. Pesticides  which
  change In  chemical composition sig-
  nificantly must meet the following la-
  beling requirements:
   (1) In cases where It is  determined
  that a pesticide formulation changes
  chemical  composition  significantly,
  the product must bear the following
 statement in  a prominent position on
  the label: "Not for sale or use alter
  [date]."
   (II) The product must meet all label
  claims  up to the expiration time Indi-
 cated on the UbeL
   (7) Inert  ingredient*. The Adminis-
  trator  may require the name of any
  Inert IngredlenUs) to be listed in the
  Ingredient statement If he determines
  that such  ingredientts) may  pose a
  hazard to man or the environment.
90

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  § 162.10
                                   40 CFR Ch. I
   (h)  Warnings  and  precautionary
  statements.  Required  warnings  and
  precautionary  statements concerning
  the general  areas  of  lexicological
  hazard including  hazard to children.
  environmental  hazard, and physical or
  chemical hazard fall into two groups:
  those  required on the front panel of
  the labeling and  those which  may
  appear elsewhere.  Specific require-
  ments concerning  content, placement.
                           type size, and prominence are given
                           below.
                            (1) Required front panel statements.
                           With  the  exception  of  the child
                           hazard warning statement, the text re-
                           quired on the front panel of the label
                           is determined by the Toxicity Catego-
                           ry of the pesticide. The category is as-
                           signed on the basis of  the highest
                           hazard shown by any of the indicators
                           In the table below:
 Hazard nScrtora
                                      Toddty ecttgorkM
                    1
                                                                   IV
    LO..
      LD._
Up to *fid indudng 50
 mg/kg.
UfTVin* inducing .2
 mo/Mar.
Up to and Inducing 200
 mg/kg.
From SO ttvu SOO mg/kg

Frem J tvu 2 mg/ltar_

From 200 ttvu 2000—
              opacity not f«»nMt
                GomMf opftoHy
                 f«v«nb<« w«Nn 7
                 pmMng tor 7 day*.
                S*vw« MUtton « 72
                 hours.
From SCO tn 6000 mg/

From 2. ttvu 20 mg/lur_

From 2400 flwu 20^00-

No com** <*>**£

 «*hh7diya.
GrMkv ttwn 9000 m0/
                                            Mo
                                             hour*.
                                                  T«*tkxiat72
                               MU or HgW Iritatfon «
   (1) Human hazard signal word—(.A.)
 Toxicity Category I. All pesticide prod-
 ucts meeting the criteria of Toxicity
 Category I shall bear  on the front
 panel the signal word "Danger." In ad-
 dition if the product was assigned to
 Toxicity Category I on the basis of its
 oral, inhalation or dermal toxicity (as
 distinct from skin  and  eye local ef-
 fects) the word "Poison" shall appear
 in red on  a background of  distinctly
 contrasting color and the skull  and
 crossbones shall appear in immediate
 proximity to the word "poison."
  (B) Toxicity Category IL  AD pesti-
 cide products meeting the criteria of
 Toxicity Category n shall bear on the
 front panel the signal  word  "Warn-
 ing."
  (C) Toxicitv Category  III  AH pesti-
 cide products meeting the criteria of
 Toxicity Category in shall  bear on
 the front panel  the  signal word "Cau-
 tion."
  (D) Toxicitv Category IV.  AH pesti-
 cide products meeting the criteria of
 Toxicity Category IV shall bear on the
 front panel the signal word "Caution."
  (E) Use of signal words. Use of any
signal word(s) associated with a higher
Toxicity Category  Is not permitted
except when the Agency determines
                          that such labeling Is necessary to pre-
                          vent unreasonable adverse effects  on
                          man or the environment. In  no case
                          shall more  than one  human  hazard
                          signal word appear on  the front panel
                          of a label.
                            (li) Child hazard warning. Every pes-
                          ticide product label shall bear on the
                          front panel the statement "keep out of
                          reach  of children."   Only  In cases
                          where  the likelihood of contact with
                          children during distribution,  market-
                          ing, storage or use Is demonstrated  by
                          the applicant to be extremely remote,
                          or if the nature of the pesticide Is such
                          that it Is approved for use on Infanta
                          or small children, may the Administra-
                          tor waive this requirement.
                            (ill)  Statement  of practical  treat*
                          numi—(A)  ToxicUv  Category  L  A
                          statement of practical treatment (first
                          aid or other) shall appear on the front
                          panel of the label of all pesticides fall-
                          ing Into Toxldty Category I on the
                          basis of oral, inhnTntlffn or dermal tox-
                          icity.  Tne  Agency  may,  however,
                          permit  reasonable variations  In the
                          placement of the statement of practi-
                          cal treatment Is some reference such
                          as "See statement of  practical treat-
                          ment on back panel"  appears on  the
                                       91

-------
  Environmental Protection Agency
                                                            § 162.10
  front panel near the word "Poison"
  and the skull and crossbones.
   (B) Other  toxicity categories. The
  statement of practical treatment is not
  required on the front panel except as
  described in paragraph (hXIXiiiXA) of
  this section. The applicant may. how-
  ever, include such a front panel state-
  ment at  his  option.  Statements  of
  practical treatment are. however, re-
  quired  elsewhere  on  the  label  in
  accord with paragraph (hX2)  of this
  section if  they do not appear  on the
  front paneL
   (iv) Placement and prominence. All
  the require front panel warning state-
  ments shall Ire  grouped together on
  the label, and  shall appear with suffi-
 cient  prominence  relative to  other
 front panel text and graphic material
 to make them unlikely to be over-
 looked under customary conditions of
 purchase and use. The following table
 shows the  minimum type size require-
 ments for  the front panel warning
 statements on various sizes of labels:
Siza of labal front panal in square
tehaa

Arwvt 5 to 10 	
AtXTiV 10 10 15
ATXM 15 to 90 , . ....
O"*rM

Points
ftoqured
signal
wonlal
capitals
6
10
12
14
ta
-KMpOUl
of reach*
nj- y j — ••
cfworwi
6
e
a
10
12
                                 (2) Other required learnings and pre-
                               cautionary statements. The warnings
                               and  precautionary statements  as re-
                               quired below shall appear together on
                               the label under  the general heading
                               "Precautionary    Statements"    and
                               under   appropriate  subheadings  of
                               "Hazard to Humans and Domestic Ani-
                               mals," "Environmental  Hazard"  and
                               "Physical or Chemical Hazard."
                                 (i)  Hazard  to humans and domestic
                               animals. (A)  Where a hazard exists to
                               humans or domestic animals, precau-
                               tionary statements are required indi-
                               cating   the  particular  hazard,  the
                               routes) of exposure and the precau-
                               tions to be taken  to avoid accident.
                               injury  or damage. The precautionary
                               paragraph  shall  be immediately  pre-
                               ceded by the appropriate hazard signal
                               word.
                                 (B) The following table depicts typi-
                               cal  precautionary  statements.  These
                               statements must be  modified or ex-
                               panded to reflect specific hazards.
  catagory
                              Precautionary ftaiamants by todcity category
                Oral inhafrtton. or darrnaJ todotty
                                           Skin and aya fecal •ftactt
IV.
Fatal (pofeonoua) * twaiowad Onhatad or abaorbad
  trough atdn]. Do not braatfia vapor (duat or apray
  m*0. Do not gat In ayaa. on attn. or on ctoHng

  qulradj.
MaW kv  taM af M*ilo*j*>d fWMtod or     ,~^
  through tw attnj. Do not braatha vapors (duat or
  apray a*O. Do not gat In ayaa. 'en atdn, or on
                                             Correafc*, camaa aya and aUn damaga tor atdn
                                              Mtaton). Do not gat in ayaa. on atdn.  or on
                                              cfcMNng. Waar goggtaa s* IK* ("Md and  Mbbar
                                              gtovaa »ftan handBng. Him** or tatat •
                                              (A^firoprMa ftrat aW atatamant raqulrad.)
                                             Cauaaa aya (and atdn] Mattoa Oo not gat to oyw,
                                              —^ ^U^	^_ ^^.^CB^UB ^^^H^Arf
                                              on anv or on tAMiiy. narnwA
                                              prophata irat aid ataUmant laqulradj
 •UnJ. AwoW
 A»od cor*ac<
                       nW^aa^Mt? ^ -• ---- * --- *
                       laTWWQ Of mMCVvVO
                         wapon Iduat or apray mMI.
                          Cayaa or dothingj. (Aepn>
               ^^^M 4^
               ay*a or
 contact ImniJlrtatj iuah ayaa or attn w*i ptanty of
      Oat
(No p
(No |
  (11) Environmental hazard*. Where a
hazard exists to non target organisms
excluding  humans  and domestic ani-
mals, precautionary statements are re-
quired  stating  the  nature  of the
                              hazard and the appropriate  precau-
                              tions  to  avoid  potential  accident.
                              Injury  or damage.  Examples of  the
                              hazard statements  and  the  drcum-
                                         92

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 § 162.10
              40 CFR Ch. I
 stances under which they are required
 follow:
   (A)  If a  pesticide intended for out-
 door use contains an active ingredient
 with a mammalian acute oral LDM of
 100  or less, the statement "This Pesti-
 cide is Toxic to Wildlife" is required.
   (B)  If a  pesticide intended for out-
 door use contains an active Ingredient
 with a fish acute LCM of 1 ppm or less.
 the statement "This Pesticide is Toxic
 to Pish" is required.
   (C) If a pesticide intended for out-
 door use contains an active ingredient
 with an avian acute  oral LDM  of  100
 mg/kg or  less, or a subacute dietary
 LCM of 500 ppm or less, the statement
 "This  Pesticide_is Toxic to Wildlife" is
 required.     "*"" ~
   (D) If either accident history or field
 studies demonstrate  that  use of  the
     pesticide  may  result  in fatality  to
     birds, fish or mammals, the  statement
     "This pesticide is  extremely toxic  to
     wildlife (fish)" is required.
      (E) For uses involving foliar applica-
     tion to agricultural crops, forests,  or
     shade trees, or  for mosquito  abate-
     ment  treatments,  pesticides toxic  to
     pollinating insects must bear appropri-
     ate label cautions.
      (F) For all outdoor uses other than
     aquatic  applications the label  must
     bear the caution "Keep  out of lakes.
     ponds or streams. Do not contaminate
     water by cleaning of equipment or dis-
     posal of wastes."
      (Ill)  Physical  or chemical hazards.
     Warning statements on the flammabfl-
     ity or explosive characteristics of the
     pesticide are required as follows:
               Flashpoint
                 Raquiradtaxt
                               (A) PnCMUKZCO CONTAMGM
 Flash port at or Mow 20* F; t thara m a flashback at
  any vaVa oparwig.
 Flash port ate** 20T f and not ovar 80* F or » **
  flama axtantton Is mora than 18 in long at a dfetanca
   other prassurtrad containars
ExtramaJy flammabla. Contants undar prasaura. Kaap away from
  lira, apart*, and haalad surfacas. Do not punctura or
  containar. Exposure to tamparatura* •b°v* 13°*
  bursting.
FUnwnaMa. Contanta undar prassura.  Kaap away from
  sparks, and opan flama. Do not punctura or Incinarata oortiainar.
  EjpcNira to tamparaluraa abova 130* F may cauaa bursting.
Contants undar praasura. Oo not usa or stora naar haat or opan
  flama. Oo not punctura or  Incinarsta oontainar.  Exposure to
  tamparatura* abova 130* F may cau*a bursting.
                             (B) r40NPfl£MUMZCO CONTAMCM
 At or batow 20* F.
Abova 20* F and not ovar 80* F_
Abova ao* F and not ovw ISO* F.
Extamaly flammabla. Kaap away from lira, sparks, and naatad
 •urtacaa.
Paivivniiotc. K«Mp cwAy vront r)*Mt sVio op^n ntVTtst.
Do not uaa or stora naar haat or opan Kama.
  (i)  Directions for  Utf—(.l)  General
requiTcmer.ls—sr, Adequacy and clar-
ity of directions.  Directions  for use
must be stated in terms which can be
easily read and understood by the av-
erage person likely to use or to  super-
vise the use of the pesticide. When fol-
lowed, directions must be adequate to
protect  the  public  from  fraud  and
from personal injury and to  prevent
unreasonable  adverse  effects on the
environment.
  
-------
 Environmental Protection Agency

 for use only by manufacturers of prod-
 ucts other than pesticide products in
 their regular manufacturing processes,
 provided that:
   U> The label clearly shows that the
 product  is intended  for use  only In
 manufacturing processes and specifies
 the type
-------
  §162.11

    (E) For restricted use pesticides, a
  statement that  the  pesticide may be
  applied under the direct supervision of
  a certified applicator who is not phys-
  ically present at the site of application
  but  nonetheless  available  to  the
  person  applying the pesticide,  unless
  the Agency has determined that the
  pesticide may only be applied under
  the direct supervision of a certified ap-
  plicator who is physically present.
       Other  pertinent  information
  which  the Administrator determines
  to be necessary  for the protection of
  man and the environment.
    (j)  Statement of Use Classification.
  By October 22.1976. all pesticide prod-
  ucts must beat on their labels a state-
  ment of use classification as described
  in paragraphs (j) (1) and (2) of this
  section. Any  pesticide  product for
  which some uses are classified for gen-
  eral use and others for restricted use
  shall be separately labeled according
  to the labeling standards set forth in
  this subsection, and shall be marketed
  as  separate  products with  differen-
  registration numbers, one bearing di-
 rections only for general use(s)  and
 the other bearing directions for re-
 stricted use(s) except that, if a product
 has both restricted use(s) and general
 use
-------
                           PHYS/CHEM-1
Criteria
PHYSICAL/CHEMICAL HAZARDS

                  Required Label Statement
I.  Pressurized Containers

    A.  Flashpoint at or below
        20°F; or if there is a
        flashback at any valve
        opening.
    B.  Flashpoint above 20°F
        and not over 80°F; or
        if the flame extension
        is more than 18 inches
        long at a distance of
        6 inches from the
        valve opening.

    C.  All Other Pressurized
        Containers
II.  Non-Pressurized Containers

    A.  Flashpoint at or below
        20°F.
    B.  Flashpoint above 20°F
        and not over 80°F.

    C.  Flashpoint over 80°F
        and not over 150*F.

    D.  Flashpoint above
        150°F.
                  Extremely flammable.
                  Contents  under pressure.
                  Keep away from fire,  sparks,
                  and heated surfaces.   Do  not
                  puncture  or incinerate
                  container.  Exposure  to
                  temperatures above 130°F
                  may cause bursting.

                  Flammable.  Contents  under
                  pressure.  Keep away  from
                  heat, sparks, and flame.   Do
                  not puncture or incinerate
                  container.  Exposure  to
                  temperatures above 130°F
                  may cause bursting.

                  Contents  under pressure.
                  Do not use or store near
                  heat or open flame.   Do not
                  puncture  or incinerate
                  container.  Exposure to
                  temperatures above 130°F
                  may cause bursting.
                  Extremely flammable.  Keep
                  away from fire, sparks, and
                  heated surfaces.

                  Flammable.  Keep away from
                  heat and open flame.

                  Do not use or store near
                  heat and open flame.

                  None required.
                              96

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                            STOR-1

             STORAGE INSTRUCTIONS FOR PESTICIDES

Heading;

All products are required to bear specific label instructions
about storage and disposal.   Storage and disposal instructions
must be grouped together in the directions for use portion of
the label under the heading STORAGE AND DISPOSAL.  Products
intended solely for domestic use need not include the heading
"STORAGE AND DISPOSAL."

Storage Instructions;

All product labels are required to have appropriate storage
instructions.  Specific storage instructions are not prescribed.
Each registrant must develop his own storage instructions,
considering, when applicable, the following factors:

1.  Conditions of storage that might alter the composition or
    usefulness of the pesticide.  Examples could be temperature
    extremes, excessive moisture or humidity, heat, sunlight,
    friction, or contaminating substances or media.

2.  Physical requirements of storage which might adversely
    affect the container of the product and its ability to
    continue to function properly.  Requirements might include
    positioning of the container in storage, storage or damage
    due to stacking, penetration of moisture, and ability to
    withstand shock or friction.

3.  Specifications for handling the pesticide container,
    including movement of container within the storage area,
    proper opening and closing procedures (particularly for
    opened containers), and measures to minimize exposure
    while opening or closing container.

4.  Instructions on what to do if the container is damaged in
    any way, or if the pesticide is leaking or has been
    spilled, and precautions to minimize exposure if damage occurs

5.  General precautions concerning locked storage, storage in
    original container only, and separation of pesticides
    during storage to prevent cross-contamination of other
    pesticides, fertilizer, food, and feed.

6.  General storage instructions for household products should
    emphasize storage in original container and placement  in
    locked storage areas.

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                                PEST/DIS-1

                     PESTICIDE DISPOSAL INSTRUCTIONS

The label of all products, except those intended solely for domestic
use, must bear explicit instructions about pesticide disposal.   The
statements listed below contain the exact wording that must appear on
the label of these products:

1.  The labels of all products, except domestic use, must contain the
statement, "Do not contaminate water, food, or feed by storage  or disposal."

2.  Except those products intended solely for domestic use, the labels
of all products that contain active ingredients that are Acute  Hazardous
Wastes or are assigned to Toxicity Category I on the basis of oral or
dermal toxicity, or Toxicity Category I or II on the basis of acute
inhalation toxicity must bear the following pesticide disposal  statement:

    "Pesticide wastes are acutely hazardous.  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."

3.  The labels of all products, except those intended for domestic use,
containing active or inert ingredients that are Toxic Hazardous Wastes
or meet any of the criteria in 40 CFR 261, Subpart C for a hazardous
waste must bear the following pesticide disposal statement:

    "Pesticide wastes are toxic.  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."

4.  Labels for all other products, except those intended for domestic
use, must bear the following pesticide disposal statement:

    "Wastes resulting from the use of this product may be disposed of on
    site or at an approved waste disposal facility."

5.  Products intended for domestic use only must bear the  following
disposal statement:  "Securely wrap original container in  several layers
of newspaper and discard in trash."

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                          CONT/DIS-1
               CONTAINER DISPOSAL INSTRUCTIONS

    The Label of each product must bear container  disposal
instructions appropriate to the type of container.

    1.  Domestic use products must bear one  of  the following
container disposal statements:
Container Type
Statement
Non-aerosol products
(bottles, cans, jars)
Non-aerosol products
(bags)
Aerosol products
Do not reuse container (bottle, can, jar).
Rinse thoroughly before discarding in trash.
Do not reuse bag. Discard bag in trash.
Replace cap and discard containers in
trash. Do not incinerate or puncture.
    2.  All other products  must  bear  container disposal  instructions,
based on container type,  listed  below:
 Container Type
 Statement
Metal
containers
(non-aerosol)
Plastic containers
Glass containers
Fiber drums
with liners
Paper and
plastic bags
Compressed gas
cylinders
Triple rinse (or equivalent). Then offer
for recycling or reconditioning, or puncture
and dispose of in a sanitary landfill, or by
other procedures approved by state and local
authorities.
Triple rinse (or equivalent). Then offer
for recycling or reconditioning, or puncture
and dispose of in a sanitary landfill, or
incineration, or, if allowed by state and
local authorities, by burning. If burned,
stay out of smoke.
Triple rinse (or equivalent). Then dispose
of in a sanitary landfill or by other
approved state and local procedures.
Completely empty liner by shaking and
tapping sides and bottom to loosen clinging
particles. Empty residue into application
equipment. Then dispose of liner in a
sanitary landfill or by incineration if
allowed by state and local authorities.
If drum is contaminated and cannot be
reused^ f dispose of in the same manner.
Completely empty bag into application
equipment. Then dispose of empty bag in
a sanitary landfill or by incineration,
or, if allowed by State and local
authorities, by burning. If burned, stay
out of smoke.
Return empty cylinder for reuse (or
similar wording)
  J_/ Manufacturer may replace this phrase with one indicating
     whether and how fiber drum may be reused.
                         99

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Consumer Information Sheet
INORGANIC ARSENICAL
PRESSURE-TREATED  WOOD
(Including  CCA. ACA. and ACZA)
CONSUMER INFORMATION
     This wood has been preserved by pressure-treatment
   with an ERVregistcred pesticide containing inorganic
   arsenic to protect it from insect attack and decay. Wood
   treated with inorganic arsenic should be used only where
   such protection is important.
     Inorganic arsenic penetrates deeply into and remains
   in the pressure-treated wood for a long time. Exposure to
   inorganic arsenic may present certain hazards There-
   fore, the following precautions  should be taken both
   when handling the treated wood and in determining
   where to use or dispose of the treated wood.
 JSE SITE PRECAUTIONS
     Wood pressure-treated with waterborne arsenical pre-
   servatives may be used inside residences as long as all
   sawdust and construction debris are cleaned up and
   disposed of after construction.
     Do not use treated wood under circumstances where
   the preservative may become a component of food or
   animal feed. Examples of such sites would be structures
   or containers for storing silage or food.
     Do not use treated wood for cutting-boards or counter-
   tops.
     Only treated wood that is visibly clean and free of
   surface residue should be used for patios, decks and
   walkways.
     Do not use treated wood  for construction of those
   portions of beehives which may come into contact with
   the honev.
     Treated wood should not be used where it may conic
   into direct or indirect contact with public drinking water.
   except for uses involving incidental contact such as
   docks and bridges.
HANDLING PRECAUTIONS
     Dispose of treated wood by ordinary trash collection
   or burial. Treated wood should not be burned in open
   fires or in stoves, fireplaces, or residential boilers because
   toxic chemicals may be produced as part of the smoke
   and ashes. Treated wood from commercial or industrial
   use (e.g., construction  sites) may be burned only in
   commercial or industrial incinerators or boilers in accor-
   dance with state and Federal regulations.
     Avoid frequent or prolonged inhalation of sawdust
   from treated wood. When sawing and machining treated
   wood, wear a dust mask. Whenever possible, these opera-
   tions should be performed outdoors to avoid indoor
   accumulations of airborne sawdust from treated wcxxi
     When power-sawing and machining, wear goggles to
   protect eyes from flying particles.
     After working with the wood, and before eating, drink-
   ing, and use of tobacco products, wash exposed areas
   thoroughly.
     If preservatives or sawdust accumulate on clothes.
   launder before reuse. Wash work clothes separately from
   other household clothing
                                    100
 45-997343

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c006801                                    ARSENIC ACID*

            TYPE PESTICIDE;   Fungicide  (Refer also to Deslccant entry)

            FORMULATIONS!
            FI   (75Z)
            SC/L (3%,  21Z)

            GENERAL WARNINGS  AND  LIMITATIONS;  RESTRICTED USE PESTICIDE.  Individual*
            who enter  pressure  treatment cylinders and other related equipment that
            are contaminated  with the wood  treatment solution (e.g., cylinders that
            are in  operation  or are not free of the treatment solution) must wear pro-
            tective clothing, including overalls, jacket, gloves, and boots, impervi-
            ous to  the wood treatment formulation.  In addition, individuals vho enter
            pressure-treatment  cylinders must wear properly fitting, veil-maintained,
            high efficiency filter respirators, MSHA/NIOSH-approved for Inorganic ar-
            senic,  if the level of Inorganic arsenic In the plant is unknown or ex-
            ceeds 10 mlcrograms per cubic meter of air (10ug/m3) averaged over an 8-
            hour work period.   Protective clothing must be changed when it shows signs
            of  contamination.   Applicators must leave protective clothing and work-
            shoes or boots and  equipment at the plant.  Worn-out protective clothing
            and workshoes or boots must be left at the plant and disposed of in a man-
            ner  approved for pesticide disposal and in accordance with state and fed-
            eral regulations.  Alternatively, to potentially relieve employees frosi
            the burden of wearing  respirators,  the employer may Implement a Permissi-
            ble Exposure Limit  (PEL) Monitoring Program.  Refer to appropriate label-
            ing for  details of the PEL Monitoring Program.  Examples of acceptable
           materials for protective clothing (e.g.,  gloves, overalls, jacket, and
            boots) required during application and handling of inorganic arsenlcals
           are vinyl,  polyvinyl chloride (PVC), neoprene, NBR (Buna-N), rubber, and
           polyethylene.
           Definition  of Terms;
           w/w - weight to weight
           *orthoarsenic  acid

           Issued:   5-27-86                11-006801-1
           Provisional Update:   8-22-86
                                               101

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                             EPA Compendium of Acceptable Uses

                                        ARSENIC ACID

         Site  and  Peit           Dosages and   Tolerance, Use, Limitation!
                                Fornulation(g)

         DTOOOR

           (Wood or Wood Structure Protection Treatment!)

01 00 A     Wood Protection Treatment to Foreit
            Product! by Pressure

EQBB         Wood  rot /decay      [MAIJ         Vacuum-pressure impregnation.   Di-
                                0.0002-0.0024 iute with water to concentration!
                                 Ib a. I./     of 0.5 percent (w/w) to 0.8 percent
                                 application  (w/w) depending on retention deslr-
                                (3% SC/L)     ed.  Kiln dry after treatment  or
                                              allow 1 week between Impregnation
                                              and Installation for fixation  of
                                              preservative.
                                              Formulated with copper sulfate and
                                              sodium dichr ornate.
                                              Vacuum-pressure impregnation.  Di-
                                0.0011-0.0168 iute with water to concentration*
                                 Ib a.i./     of 0.5 percent (w/w) to 8 percent
                                 application  (w/w) depending on retention desir-
                                (21Z SC/L)    ed.  Kiln dry after treatment or
                                              allow 1 week between Impregnation
                                              and installation for fixation of
                                              preservative.
                                              Formulated with chromic acid and
                                              cupric oxide.
        l!!ued:  5-27-86                 IZ-006801-2

                                            102

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                                           ARSENIC ACID

            Listing of Registered Pesticide Product*  by  Formulation

  /75.0002   75? formulation Intermediate
              arsenic acid (006801)
                000061-00171   003098-00016

&203.0015   31 soluble concentrate/liquid
              arsenic acid (006801),  copper sulfate (024401) plus sodiua dichromate
               (068304)
                045968-00004

&221.0015   211 soluble concentrate/liquid
              arsenic acid (006801),  chromic acid (021101) plus cuprlc oxide (042401)
                045968-00005
           Issued:  5-27-86                11-006801-3

                                           103

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                      EPA Compendium of  Acceptable  Uses

                                ARSENIC ACID

                               Appendix A-l

Listing  of Active  Ingredient(s) Found in Combination With the Report Chemical

Chemical     Common Name              EPA Acceptable
   Code          (source)             Common/Chemical Name

021101        —                    chromic acid

024401        —                    copper aulfate

042401        —                    cuprlc oxide

068304        —                    sodium dichrooate


— Use EPA Acceptable Common/Chemical Naae
Issued:  5-27-86                 11-006801-4

                             104

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 c006802                                  ARSENIC PEMTOXIDE

            TYPE PESTICIDE;  Insecticide,  Fungicide,  Molluscicide

            FORMULATIONS;
            SC/S (10%, 26.9%, 30.52)
            SC/L (7.3%, 8.2%, 9.84%, 9.9%, 16.6%,  16.88%,  17%,  17.6%, 18%, 18.04%,
                 18.2%, 19%, 20.25%, 23.8%,  24.48%,  24.5%,  32.5%,  34%)
            RTU  (4.08%)

            GENERAL WARNINGS AM) LIMITATIONS:  None.
            Site and Pest
            INDOOR
                      Dosages  and   Tolerance, Use, Limitations
                      Formulatton(s)
              (Wood or Wood Structure Protection Treatment)
/640030A
Wood Protection Treatment  of
 Pressure Treated Wood that has
 been Exposed through Fabrication
 or Damage
IMGAAAA
FYAEQB3
  Termites
  Wood rot/decay
4.08% solu-
 tion
(4.08% RTU)
Applicators must wear gloves (e.g.,
rubber, vinyl or neoprene) impervi-
ous to the wood treatment solution
in all situations where dermal con-
tact is expected (e.g., during the
application process and handling
freshly treated wood).
Applicators must wear disposable
coveralls (e.g., vinyl or polyethyl-
ene) or other similar impermeable
clothing during the application
process where dermal contact is ex-
pected.

Commercial or industrial use only.
Wood protection treatment to pres-
sure treated wood.  Brush into all
cut or machined surfaces and allow
to soak into the wood.
Formulated with chromic acid, cupric
oxide.
            Issued:   3-08-85
            Provisional  Update:   8-25-86
                             III-006802-1
                                           105

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      Site and Pest
EPA Compendium of  Acceptable  Uses

        ARSENIC PENTOXIDE

   Dosages and  Tolerance, Use,  Limitations
   Formulatton(s)
DA      Wood Protection Treatment by
         Pressure (forest products)
                RESTRICTED  USE  PESTICIDE.
                For sale  to and use only by certi-
                fied applicators or by persons under
                their direct supervision and only
                for those uses  covered by the certi-
                fied applicators' certification.
                Applicators must wear gloves imper-
                vious to  the wood treatment formula-
                tion in all situations where dermal
                contact is  expected (e.g., handling
                freshly treated wood and manually
                opening cylinder doors).
                Individuals who enter pressure
                treatment cylinders and other relat-
                ed  equipment that is contaminated
                with the  wood treatment solution
                (e.g.,  cylinders that are in opera-
                tion or are not free of the treat-
                ment solution)  must wear protective
                clothing, including overalls, jack-
                et, gloves, and boots, impervious
                to  the wood treatment formulation.
                In  addition, individuals who enter
                pressure-treatment cylinders must
                wear properly fitting, well-main-
                tained, high efficiency filter res-
                pirators, MSHA/NIOSH-approved for
                inorganic arsenic, if the level of
                inorganic arsenic in the plant is
                unknown or  exceeds 10 micrograms per
                cubic meter of  air (10ug/m3) averag-
                ed  over an  8-hour work period.
                Protective  clothing must be changed
                when it shows signs of contamina-
                tion.  Applicators must leave pro-
                tective clothing and workshoes or
                boots and equipment at the plant.
                Worn-out  protective clothing and
                workshoes or boots must be left at
                the plant and disposed of in a man-
                ner approved for pesticide disposal
                and in accordance with state and
                federal regulations.
                Individuals In  the work area of an
                arsenical wood  treatment  plant must
                wear properly fitting, well-main-
                tained high efficiency filter  res-
                pirators, MSHA/NIOSH-approved  for
                inorganic arsenic,  if  the level  of
                inorganic arsenic  In  the  plant  is
     Issued:  3-08-85
          III-006802-2
                                   106

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                                         ARSENIC PENTOXIDE
             Site and Pest
                    Dosages and   Tolerance, Use, Limitations
                    Formulation(s)
              Wood  Protection Treatment by Pressure (forest products)  (continued)

                                                  unknown or exceeds 10 micrograms  per
                                                  cubic meter of air (10ug/m3)  averag-
                                                  ed over an 8-hour work period.
                                                  Alternatively, to potentially re-
                                                  lieve employees from the burden of
                                                  wearing respirators,  the employer
                                                  may implement  a Permissible Exposure
                                                  Limit (PEL) Monitoring Program.
                                                  Note to user - Examples of accepta-
                                                  ble materials  for protective  cloth-
                                                  ing (e.g., gloves, overalls,  Jacket,
                                                  and boots) required  during applica-
                                                  tion and handling of inorganic ar-
                                                  senicals are vinyl,  polyvinyl chlo-
                                                  ride (PVC), neoprene, NBR (Buna-N),
                                                  rubber, and polya«-.hylene.
 IMGAAAA
 FYAEQBB
Termites
Wood  rot/decay
IMGAAAA
FYAEQBB
Termites
Wood rot/decay
0.045-1.9Z
 solution
(10*. 26.9Z,
 30.57. SC/S)
(8.2-34Z
 SC/L)
Wood protection treatment by pres-
sure.
Formulated with one or a combination
of:  chromic acid, copper sulfate,
cupric oxide, potassium dichromate,
sodium dichromate, and sodium pyro-
arsenate.
No dose giv-  y00
-------
       Site and  Pest
EPA Compendium of  Acceptable  Uses

        ARSENIC PENTOXIDE

   Dosages and  Tolerance, Use, Limitations
   Fonnulation(s)
190A      Wood Protection Treatment to Wood
           Intended for Use in the
           Construction of Boats, Ships, and
          Marine Structures
                 RESTRICTED USE  PESTICIDE.
                 For sale  to  and use only by certi-
                 fied applicators or by persons under
                 their direct supervision and only
                 for those uses  covered by the certi-
                 fied applicators'  certification.
                 Applicators  must wear gloves imper-
                 vious to  the wood treatment formula-
                 tion in all  situations where dermal
                 contact is expected (e.g., handling
                 freshly treated wood and manually
                 opening cylinder doors).
                 Individuals  who enter pressure
                 treatment cylinders and other relat-
                 ed equipment that is contaminated
                 with the  wood treatment solution
                 (e.g., cylinders that are in opera-
                 tion or are  not free of the treat-
                 ment solution)  must wear protective
                 clothing, including overalls, jack-
                 et, gloves,  and boots, impervious
                 to the wood  treatment formulation.
                 In addition, individuals who enter
                 pressure-treatment cylinders must
                 wear properly fitting, well-main-
                 tained, high efficiency filter res-
                 pirators, MSHA/NIOSH-approved for
                 inorganic arsenic, If the level of
                 inorganic arsenic In  the plant is
                 unknown or  exceeds 10 micrograms per
                 cubic meter  of air (10ug/m3) averag-
                 ed over an  8-hour work period.
                 Protective  clothing must be changed
                 when it shows signs of contamina-
                 tion.  Applicators must  leave pro-
                 tective clothing and  workshoes or
                 boots and equipment  at  the  plant.
                 Worn-out  protective  clothing  and
                 workshoes or boots must  be left  at
                 the plant and disposed of  In a  man-
                 ner approved for pesticide disposal
                 and in accordance with state and
                 federal regulations.
                 Individuals in  the work area of an
                 arsenical wood  treatment plant must
                 wear properly  fitting,  well-main-
                 tained high efficiency filter res-
                 pirators, MSHA/NIOSH-approved for
                 inorganic arsenic, if the level of
                 inorganic arsenic in the plant Is
       Issued:  3-08-85
          III-006802-4
                                   108

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                                EPA Compendium of Acceptable Uses

                                        ARSENIC PENTOXIDE

            Site  and Peat           Dosages and   Tolerance,  Use, Limitations
                                   Formulatton(s)

             Wood  Protection Treatment to Wood Intended for  Use  in  the  Construction
               of Boats, Ships, and Marine Structures  (continued)

                                                 unknown or  exceeds 10  mlcrograms per
                                                 cubic  meter of air (10ug/m3) averag-
                                                 ed over an  8-hour  work period.
                                                 Alternatively, to  potentially re-
                                                 lieve  employees from the burden of
                                                 wearing respirators, the employer
                                                 may  implement a Permissible Exposure
                                                 Limit  (PEL)  Monitoring Program.
                                                 Note to user - Examples of accepta-
                                                 ble  materials for  protective cloth-
                                                 ing  (e.g.,  gloves,  overalls, jacket,
                                                 and  boots)  required during applica-
                                                 tion and handling  of inorganic ar-
                                                 senicals are vinyl, polyvinyl chlo-
                                                 ride (PVC),  neoprene, NBR (Buna-N),
                                                 rubber,  and  polyethylene.

IIFAAHA         Limnoria            0.073-0.585Z   Wood protection treatment by pres-
1GEAAGA         Teredos              solution     sure.
                                   (7.3X  SC/L)    Formulated with chromic acid, and
                                                 cupric oxide.
           Issued:   3-08-85               III-006802-5

                                       109
                             BEST AVAILABLE COPY

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                              EPA Compendium of Acceptable Uses

                                      ARSENIC PENTOXIDE

         Listing of Registered Pesticide Products by Formulation

.0.0015   10% soluble concentrate/solid
           arsenic pentoxide (006802), copper sulfate (024401)  plus  potassium  dl-
            chloride (068302)
             000061-00127

16.9015   26.92 soluble concentrate/solid
           arsenic pentoxide (006802), copper sulfate (024401)  plus  sodium dlchro-
            mate (068304)
             000061-00140

50.5015   30.5% soluble concentrate/solid
           arsenic pentoxide (006802), sodium pyroarsenate (013401), copper sulfate
            (024401) plus sodium dichromate (068304)
             000061-00139

J7.3015   7.3% soluble concentrate/liquid
           arsenic pentoxide (006802), chromic acid (021101)  plus cuprlc oxide
            (042401)
             003008-00042

38.2015   8.2% soluble concentrate/liquid
           arsenic pentoxide (006802), chromic acid (021101)  plus cupric oxide
            (042401)
             047097-00001

 ..8415   9.84Z soluble concentrate/liquid
           arsenic pentoxide (006802), chromic acid (021101)  plus cupric oxide
            (042401)
             047097-00002

D9.9015   9.92 soluble concentrate/liquid
           arsenic pentoxide (006802), chromic acid (021101)  plus cupric oxide
            (042401)
             010465-00011

L6.6015   16. 6Z soluble concentrate/liquid
           arsenic pentoxide (006802), chromic acid (021101)  plus cupric oxide
            (042401)
             035896-00002

16.8815   16.88* soluble concentrate/liquid
           arsenic pentoxide (006802), chromic acid (021101)  plus cupric oxide
            (042401)
             047097-00003

17.0015   172  soluble concentrate/liquid
           arsenic pentoxide (006802), chromic acid (021101)  plus cupric oxide
            (042401)
             000061-00128   003008-00036   010356-00006   048706-00001
         Issued:   3-08-85               III-006802-6
                                  1  10

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                                          ARSENIC  PENTOXIDE

             Listing of Registered Pesticide Products by Formulation (continued)

  ^,7.6015   17. f>7. soluble concentrate /liquid
               arsenic pentoxide (006802),  chromic acid (021101) plus cupric oxide
                (042401)
                 010465-00012

 &218.0015   18% soluble concentrate/liquid
               arsenic pentoxide (006802),  chromic acid (021101) plus cupric oxide
                (042401)
                 003008-00035

 S218.0415   18.041 soluble concentrate/liquid
               arsenic pentoxide (006802),  chromic acid (021101) plus cupric oxide
                (042401)
                 000061-00170

 &218.2015   18.2Z soluble concentrate/liquid
               arsenic pentoxide (006802),  chromic acid (021101) plus cupric oxide
                (042401)
                 008333-00002

 &219.0015   192 soluble concentrate/liquid
               arsenic pentoxide (006802),  chromic acid (021101) plus cupric oxide
                (042401)
                 010465-00010

 &f    2515   20.25% soluble concentrate/liquid
               arsenic pentoxide (006802),  chromic acid (021101) plus cupric oxide
                (042401)
                 047097-00004

 &223.8015   23.87, soluble concentrate/liquid
               arsenic pentoxide (006802),  chromic acid (021101) plus cupric oxide
                (042401)
                 000061-00141*
                   *Jacket currently unavailable for review

&224.4815    24.487!  soluble concentrate/liquid
               arsenic pentoxide (006802),  chromic acid (021101) plus cupric oxide
                (042401)
                 000061-00173

&224.5015    24. 57.  soluble concentrate/liquid
               arsenic  pentoxide (006802),  chromic acid (021101) plus cupric oxide
                (042401)
                003008-00017

&232.5015    32.SZ soluble  concentrate/liquid
              arsenic  pentoxide (006802),  chromic acid (021101) plus cupric oxide
               (042401)
                003008-00034*
                  *Jacket  cu-rently unavailable for review

            Issued:   3-08-85               III-006802-7

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                             EPA Compendium of Acceptable Uses

                                    ARSENIC  PENTOXIDE

        Listing of Registered Pesticide  Products by Formulation (continued)

.0015   347 soluble concent rate/liquid
          arsenic pentoxide  (006802), chromic acid (021101) plus cupric oxide
           (042401)
            003008-00016   008333-00001

,.0816   4.08Z liquid-ready  to use
          arsenic pentoxide  (006802), chromic acid (021101) plus cupric oxide
           (042401)
            003008-00021
1999     State  Label  Registration

          HI Reg.  No.
            035053-05242   036019-03490
       Issued:   3-08-85                III-006802-8
                                  112

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                                EPA Compendium of Acceptable Uses

 D070CO.                                  ARSENIC TRIOXIDE*

           TYPE  PESTICIDE;  Antifoulant, Herbicide, Insecticide,  Rodenticide

           FORMULATIONS;
           Tech  (907., 94Z, 99Z, 99.5%)
           FI    (37Z, 997.)
           WP    (.207,)

           GENERAL WARNINGS AND LIMITATIONS:  None.
640020A

MGAAAA
           Site, Dosage
           and Formulation

           DOMESTIC OUTDOOR
                      Tolerance,  Use,  Limitations
(Wood or Wood Structure Protection Treatment)

Wood Poles
  Termites

  2 Ib a.i./gal
  (20Z WP)
                                   Impregnation treatment.   Mix product  with water
                                   to form a smooth paste.   Vertical  punctures should
                                   be made at 4 inch intervals.  Inject  all the paste
                                   contained in the piston  sheath into the punctures.
                                   Formulated with 2,4-dinitrophenol  and sodium fluo-
                                   ride.
           *arsenous  oxide

           Issued:   3-08-85
           Provisional Update:
                              1-007001-1
                   8-25-86
                              113

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                            EPA Compendium of Acceptable Uses

                                     ARSENIC TRIOXIDE

       Listing  of  Registered Pesticide Products by Formulation

. 0001   90S  technical  chemical
          arsenic trioxide  (007001)
            009777-00001

.0001   94Z  technical  chemical
          arsenic trioxide  (007001)
            003840-00005    004581-00259

. 0001   99Z  technical  chemical
          arsenic trioxide  (007001)
            001439-00189

.5001   99.51 technical chemical
          arsenic trioxide  (007001)
            007401-00202

.0002   377  formulation intermediate
          arsenic trioxide  (007001) plus copper (metallic) (022501)
            003098-00015

1.0002   99Z  formulation intermediate
          arsenic trioxide  (007001)
            000255-00025

1 0006   20%  vettable powder
          arsenic trioxide  (007001),  2,4-dlnitrophenol (037509) plus sodium fluo-
          ride  (075202)
            003231-00001
       Issued:  3-08-85                 1-007001-2
                                    114

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                                 EPA Compendium of Acceptable Uses

 : 013 6 01                                  AMMONIUM ARSENATE

            TYPE PESTICIDE;  Insecticide, Fungicide

            FORMULATIONS;  RTU (7.7Z)

            GENERAL WARNINGS AND LIMITATIONS:  None.
            Site and Pest           Dosages and   Tolerance, Use, Limitations
                                    Formulation(s)

            INDOOR
              (Wood or Wood Structure Protection Treatments)

 /6A0030A      Wood Protection Treatment
               (exposed surfaces of pressure      Applicators must wear gloves  (e.g.,
               treated lumber)                    rubber, vinyl or neoprene) impervi-
                                                  ous  to the wood treatment solution
                                                  in all situations where dermal con-
                                                  tact is expected (e.g., during the
                                                  application process and handling
                                                  freshly treated wood).
                                                  Applicators must wear disposable
                                                  coveralls (e.g., vinyl or polyethyl-
                                                  ene) or other similar impermeable
                                                  clothing during the application
                                                  process where dermal contact  is ex-
                                                  pected.

IMGAAAA         Termites     .       7.77.  solution Commercial or industrial use  only.
FYAEQBB         Wood  rot/decay      (7.7Z RTU)     Wood protection treatment to  exposed
                                                  surfaces of pressure treated  lumber.
                                                  Stir contents and use full strength.
                                                  Apply several coats with brush or
                                                  rag  mop to all surfaces of pressure
                                                  treated lumber that have been ex-
                                                  posed by cutting, notching or dap-
                                                  ping.
                                                  Formulated with copper (in the form
                                                  of an ammonia complex).
            Issued:   3-08-85                III-013601-1
            Provisional Update:   8-25-86   * .  r

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                              EPA Compendium of Acceptable Uses

                                      AMMONIUM ARSENATE

         Listing of Registered Pesticide Products by Formulation

07.7016   _7. 72 liquid-ready to use
           ammonium arsenate (013601) plus copper (in the form of an ammonia
            complex) (022702)
             003098-00003   011351-00001*
               *currently unavailable for review
        Issued:   3-08-85            „  TII-013601-2

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                                EPA Compendium of Acceptable Uses

c01350..                                  SODIUM ARSENATE*

            TYPE PESTICIDE:   Insecticide, Fungicide

            FORMULATIONS!
            Tech (98Z,  98.88Z)
            SC/S (23.8Z, 23.9*)
            RTU  (1.4Z)

            GENERAL WARNINGS AND LIMITATIONS;
            Agricultural Tolerances!
            Grapes  -  3.5 ppm
            Site  and  Pest
            INDOOR
Dosages and   Tolerance,  Use,  Limitations
Formulatlon(g)
              (Wood or Wood Structure Protection Treatment)
/640100A     Wood  Protection Treatment by Pres*
               sure  (forest products)
           *dlsodlum arsenate

           Issued:  3-08-85
           Provisional Update:  8-25-86
              RESTRICTED  USE  PESTICIDE.
             •For sale  to and use  only by  certl-
             -fled applicators or  by  persons under
             rtheir direct supervision and only
             •for those uses  covered  by  the certi-
              fied applicators'  certification.
             (Applicators must wear gloves imper-
             vious to  the wood treatment  formula-
             tion in all situations  where dermal
              contact is  expected  (e.g., handling
              freshly treated wood and manually
              opening cylinder doors).
              Individuals who enter pressure
              treatment cylinders  and other relat-
              ed equipment that is contaminated
              with the  wood treatment solution
              (e.g., cylinders that are  in opera-
              tion or are not free of the  treat-
              ment solution)  must  wear protective
              clothing, including  overalls, jack-
              et, gloves, and boots,  impervious
              to the wood treatment  formulation.
              In addition, individuals who enter
              pressure-treatment cylinders must
              wear properly fitting,  well-main-
              tained, high efficiency filter  res-
              pirators, MSHA/NIOSH-approved for
              inorganic arsenic, If  the  level  of
              Inorganic arsenic in the  plant  it
              unknown or  exceeds 10 micrograms per
       111-013505-1
            117

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                     EPA Compendium of Acceptable Uses

                              SODIUM ARSENATE

Site and Pest           Dosages and   Tolerance,  Use,  Limitations
                        Formulations)

  Wood  Protection Treatment by Pressure (forest products)  (continued)

                                      cubic meter of air (I0ug/m3)  averag-
                                      ed over an 8-hour work period.
                                      Protective clothing  must  be changed
                                      when It shows signs  of contamina-
                                      tion.  Applicators must leave pro-
                                      tective clothing and workshoes or
                                      boots and equipment  at the plant.
                                      Worn-out protective  clothing  and
                                      workshoes or boots must be left at
                                      the plant and disposed of in  a man-
                                      ner approved for pesticide disposal
                                      and in accordance with state  and
                                      federal regulations.
                                      Individuals la the work area  of an
                                      arsenical wood treatment  plant must
                                      wear properly fitting, well-main-
                                      tained high efficiency filter res-
                                      pirators, MSHA/NIOSH-approved for
                                      inorganic arsenic, If  the level of
                                      inorganic arsenic in the  plant is
                                      unknown or exceeds 10  micrograms per
                                      cubic meter of air (10ug/m3)  averag-
                                      ed over an 8-hour work period.
                                      Alternatively, to potentially re-
                                      lieve employees from the  burden of
                                      wearing respirators, the  employer
                                      may implement a Permissible Exposure
                                      Limit (PEL) Monitoring Program.
                                      Note to user - Examples of accepta-
                                      ble materials for protective  cloth-
                                      ing (e.g., gloves, overalls,  jacket,
                                      and boots) required during applica-
                                      tion and handling of inorganic ar-
                                      senlcals are vinyl,  polyvlnyl chlo-
                                      ride (PVC), neoprene,  NBR (Buna-N),
                                      rubber, and polyethylene.
                                      A closed emptying and  mixing system
                                      must be used for all powder  formula-
                                      tions of the inorganic arsenlcals.
                                      A closed systems is defined  as  any
                                      containment which prevents the  re-
                                      lease of subject chemicals into the
                                      surrounding external environment,
                                      except that the release of Incident-
                                      al amounts of chemical during equip-
                                      ment loading and periodic clean-out
                                      or maintenance operations shall not
                                      be deemed a breach  of containment.

Issued:  3-08-85               111-013505-2
                               118

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                                         SODIUM ARSENATE
            Site and Pest
                      Dosages and   Tolerance,  Use,  Limitations
                      Formulation(s)
              Wood Protection Treatment by Pressure (forest products) (continued)
IMGAAAA
FYAEQBB
  Termites
  Wood rot/decay
0.119-1.19%   Wood protection treatment  by  pres-
 solutlon     sure.  Use only in vacuum  pressure
(23.8Z SC/S)  impregnation of forest  products.
              Formulated with sodium  pentachloro-
              phenate,  sodium chromate and  sodium
              fluoride.

0.239-1.195Z  Wood protection treatment  by  pres-
 solution     sure.
(23.9Z SC/S)  Formulated with 2,4-dlnltrophenol,
              sodium chromate and sodium fluo-
              ride.
/640020A
Wood Protection Treatment  of  Sea-
 soned Forest Products
!MGAAAA
7YAEQBB
  Termites
  Wood rot/decay
(1.4X RTU)
Applicators must wear gloves (e.g.,
rubber, vinyl or neoprene) impervi-
ous to f.he wood treatment- solution
in all -r.tuations where dermal con-
tact is j^nected (e.g., during the
applies. . >u process and handling
freshl" c.-^ated wood).
Applic •: •*.•  must wear disposable
covera*.   -^e.g., vinyl or polyethyl-
ene) o  '  :iter similar Impermeable
cloth!,,   \ ring the application
process  -ire dermal contact is ex-
pected.

Commercial or industrial use only.
Wood protection treatment of season-
ed forest products.  Use only for
application to exposed surfaces when
cutting, notching or dapping pres-
sure treated lumber.  Apply several
coats undiluted with brush or rag
mop to all surfaces of lumber that
have been exposed by cutting, notch-
Ing or dapping.
Formulated with 2,4-dinitrophenol,
sodium chromate, pyridine and
sodium fluoride.
           Issued:   3-08-85
                             III-013505-3

                              119
                    BEST AVAILABLE COPY

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                              EPA Compendium of Acceptable Uses

                                       SODIUM ARSENATE

         Site and Pest           Dosages and   Tolerance,  Use,  Limitations
                                 Fonnulation(s)

40010A      Wood Protection Treatment of Unsea-
            soned Forest Products

GAAAA         Termites            ~            Wood  protection  treatment of unsea-
AEQBB         Wood rot/decay      (23.9* SC/S)  soned forest products.  Use as a
                                               diffusion treatment  in water solu-
                                               tions having hydrometer readings
                                               from  1.13 to 1.37.
                                               Formulated  with  2,4-dinitrophenol,
                                               sodium chromate  and  sodium fluo-
                                               ride.
         Issued:   3-08-85               III-013505-4
                                      120

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                                 EPA Compendium of  Accepcable  Uses

                                          SODIUM ARSENATE

            Listing of Registered Pesticide  Products  by  Formulation

            98% technical chemical
              sodium arsenate (013505)
                015135-00001

S098.8801   98.88Z technical chemical
              sodium arsenate (013505)
                003008-00029

S023.8015   23.8% soluble concentrate/solid
              sodium arsenate (013505),  sodium  pentachlorophenate (063003), sodium
               chromate (068303)  plus sodium fluoride (075202)
                000061-00124

i023.9015   23.9Z soluble concentrate/solid
              sodium arsenate (013505),  2,4-dinitrophenol  (037509), sodium chromate
               (068303) plus sodium fluoride (075202)
                000061-00110   000061-00134

1201.4016   1.4!? liquid-ready to  use
              sodium arsenate (013505),  2,4-dinitrophenol  (037509), sodium chromate
               (068303),  pyridine (069202) plus sodium fluoride (075202)
                000061-00111
,999999      State Label Registration

              HI Reg.  No.
                035053-05213
           Issued:   3-08-85                III-013505-5
                                         1
121

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                                EPA Compendium of Acceptable Uses

C013401                                SODIUM  PYROARSENATE

           TYPE PESTICIDE!   Insecticide, Fungicide

           FORMULATIONS:  SC/S  (6.2Z)

           GENERAL WARNINGS  AND LIMITATIONS;   For Industrial use only.
           Site  and  Pest
           INDOOR
Dosages and   Tolerance,  Use,  Limitations
Formulatlon(s)
             (Wood  or Wood Structure Protection Treatments)
J/640100A     Wood  Protection Treatment by
              Pressure  (forest products)
              RESTRICTED USE  PESTICIDE.
              For sale to and use  only by certi-
              fied applicators or  by persons under
              their direct supervision and only
              for those uses  covered by the certi-
              fied applicators'  certification.
              Applicators must wear gloves imper-
              vious to the wood treatment formula-
              tion in all situations where dermal
              contact is expected  (e.g., handling
              freshly treated wood and manually
              opening cylinder doors).
              Individuals who enter pressure
              treatment cylinders  and other relat-
              ed equipment that is contaminated
              with the wood treatment solution
              (e.g., cylinders that are  in opera-
              tion or are not free of the treat-
              ment solution)  must  wear protective
              clothing, including  overalls, jack-
              et, gloves, and boots,  impervious
              to the wood treatment formulation.
              In addition, individuals who enter
              pressure-treatment cylinders must
              wear properly fitting,  well-main-
              tained, high efficiency filter  res-
              pirators, MSHA/NIOSH-approved for
              inorganic arsenic, if the  level of
              inorganic arsenic in the  plant  it
              unknown or exceeds 10 micrograms per
              cubic meter of air (10ug/m3)  averag-
              ed over an 8-hour work period.
              Protective clothing  must  be changed
              when it shows signs  of contamina-
              tion.  Applicators must leave  pro-
              tective clothing and workshoes  or
          Issued:  3-08-85
          Provisional Update:  8-25-86
       III-013401-1
                                           122

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                                EPA Compendium of Acceptable Uses

                                       SODIUM PYROARSENATE

            Site and Pest           Dosages and   Tolerance, Use,  Limitations
                                   Fonnulation(s)

              Wood Protection  Treatment by Pressure (forest products) (continued)

                                                 boots and equipment at the plant.
                                                 Worn-out protective clothing and
                                                 workshoes or boots must be left  at
                                                 the plant and disposed of in a man-
                                                 ner approved for pesticide disposal
                                                 and in accordance with state and
                                                 federal regulations.
                                                 Individuals in the work area of  an
                                                 arsenical wood treatment plant must
                                                 wear properly fitting, well-main-
                                                 tained high efficiency filter res-
                                                 pirators, MSHA/NIOSH-approved for
                                                 inorganic arsenic, If the level  of
                                                 inorganic arsenic in the plant is
                                                 unknown or exceeds 10 mlcrograms per
                                                 cubic meter of air (10ug/m3) averag-
                                                 ed over an 8-hour work period.
                                                 Alternatively, to potentially re-
                                                 lieve employees from the burden  of
                                                 wearing respirators,  the employer
                                                 may implement a Permissible Exposure
                                                 Limit (PEL) Monitoring Program.
                                                 Note to user - Examples of accepta-
                                                 ble materials for protective cloth-
                                                 ing (e.g., gloves, overalls, jacket,
                                                 and boots) required during applica-
                                                 tion and handling of Inorganic ar-
                                                 senicals are vinyl, polyvinyl chlo-
                                                 ride (PVC), neoprene, NBR (Buna-N),
                                                 rubber, and polyethylene.
                                                 A closed emptying and mixing system
                                                 must be used for all powder formula-
                                                 tions of the inorganic arsenicals.
                                                 A closed systems is defined as any
                                                 containment which prevents the re-
                                                 lease of subject chemicals into  the
                                                 surrounding external environment,
                                                 except that the release of incident-
                                                 al amounts of chemical during equip-
                                                 ment loading and periodic clean-out
                                                 or maintenance operations shall not
                                                 be deemed a breach of containment.

IVGAAAA         Termites            0.062-0.31Z   Wood protection treatment by pres-
TfAEQBB         Wood  rot/decay       solution     sure.
                                   (6.22 SC/S)   Formulated with arsenic pentoxide,
                                                 copper sulfate, and sodium
                                                 dichromate.

           Issued:   3-08-85               III-013401-2

                                        123

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                               EPA Compendium of Acceptable Uses

                                      SODIUM PYROARSENATE

          Listing of Registered Pesticide Products by Formulation

4006.2015   6.2Z  soluble concentrate/solid
            sodium pyroarsenate (013401), arsenic pentoxide (006802), copper  sulfate
             (024401) plus sodium dichromate (068304)
              000061-00139
         Issued:   3-08-85               III-013401-3
                                     124

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              EPft Index to Pesticide Chemicals

                        CHROMIC flCID

                      TQBLE OF CONTENTS

 Site Name	Paoe
 DOMESTIC OUTDOOR                                            1
   (Wood or Wood Structure Protection Treatments)             1

   Seasoned Forest  Products                                  1
   Wood Protection  Treatments of Existing  Buildings
    or Parts of Building                                      2
   Wood Protection  Treatment  of Finished Wood  Products        2
   Wood Protection  Treatments Mad* to Wooden Containers
    and Other Items Used  for  Growing  Plants                   3
   Wood Protection  Treatment  of Forest Products
    by Pressure Treatment                                     3
                           125
Issuvds  3-26-87       III-021101-i

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                       EPA Index to Pesticide Chemicals

C0£11O1                             CHROMIC ACID

          TYPE  PESTICIDEi   Fungicide,  Insecticide

          FORMULATIONS*
          SC/L  (14. 1*,. 14. 12* IS. 1%,  20*, £3.6*, £3.75*, 23.8*, 24.2*, £5. A'/.,
               26.5*,  28.5*,  29.9*,  33. 17*, 32.2*, 22.75*, 32.25*, 34.2*,
               39.3*)
          RTU   (0.2*.  3.18*)

          GENERPL  WARNINGS AND LIMITATIONS:  None.
         Site and  Pest        Dosages and   Tolerance. Use. Limitations
                              Formulat ion(s)

         DOMESTIC  OUTDOOR

            (Wood or  Wood Structure Pr-otection Treatments)

/640020A    Seasoned  Forest  Products
                                            For application to the cut ends
                                            of pressure-treated  lumbar.

FYftEQBB       Wood  rot/decay  CMAI3         Wood protection treatment.   For
                              -—            cornrnerical construction  use  on-
             Termites         (3.18* RTU)   ly.  Stir contents anc use undi-
                               003008-00021 luted.  Liberally brush  into all
                                            cut or machined areas and allow
                                            to soak into  wood.   Meets the
                                            American Wood  Preservers Assoca-
                                            tion Standard  M4.1 for use on
                                            cuts, holes,  or other exposed sur-
                                            faces resulting from fabrication
                                            of framing after  treatment.
                                            Formulated with arsenic  pentoxide
                                            and cupric oxide.
                                      126
         Issued!   3-26-87      III-OaiiOl-1

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                        EPA Index to Pesticide Chemicals

                                  CHROMIC ACID
           Site and Pest
                               Dosages and
                               formal at ion (
                                 Tolerance.  Use   Llrnitat ions
                                             )
 /640OONA
 /64000.NB
 Uood  Protection  Treatments  of
  Existing  Buildings  or  Parts
  of Buildings  (including  porch
  flooring,  steps,  roof  cor-
  nices,  and greenhouses)
                                             May be applied by brush, spray,
                                             or dip.  Uood to be treated must
                                             be in its natural state and free
                                             from dirt,  oil,  stain,  or paint.
                                             One drenching coat is sufficient
                                             for indoor use.   Wood already in-
                                             stalled indoors may be treated,
                                             use adequate ventilation during
                                             application.  Two or 3 applica-
                                             tions are necessary if the wood
                                             is to be exposed to weather or se-
                                             vere moisture.  Thoroughly treat
                                             all cracks,  knot holes, wooden
                                             joints, and bolt hole surfaces
                                             since these areas are most vulner-
                                             able to decay.  One coat may fol-
                                             low another within a few min-
                                             utes.   For outdoor use immerse
                                             for a minimum of 12 hours.  Where
                                             ground or water contact is
                                             planned, immersion should be from
                                             24 to 48 hours.
FvrtEQBB


IMAAACP


/64002NB
               Uood rot/decay  CMAI3
               Termites
               Wooa boring
                insects
                                 Soil  contact  nonfumigation treat-
                   —             ment  and/or nonsoil  contact norsfu-
                   (0. £X  RTU)     migation treatment.
                   003006-00049  Forrnulatea with copper sulfate
                                 and sodium dichromate.
FYAEQBB

IMGPAOA
jMftAACft
Wood Protection Treatment of
 Finished Wood Products  (in-
 cluding boats, garden furni-
 ture,  and truck bodies)

  Wood rot/decay  CMAX3
                                             Refer to Wood Protection  Treat-
                                             ments of Existing Buildings  for
                                             site level information.
  Termites
  Wood boring
   insects
                                             Nonsoil contact nonfumigation
                               —            treatment.
                               (0. 2* RTU)    Formulated with copper sulfate
                                O03008-OO049 and sodium dichromate.
                                    127
          Issued!   3-26-87
                    111-021101-2

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                       EPA Index to Pesticide Chemicals

                                 CHROMIC PCID
          Site and Pest
                  Dosages  and   Tolerance.
                  Formulat ion(s)
                         Use.  Limitations
/64004NA
FYAEQF3

IMGAAAA
IMAAACA
/6401OOA
Wood Protection Treatments Made
 to Uooden Containers  and  Other Refer to Wood Protection Treat-
 Iterns Usec f*r Growing  Plants  ments of Existing  Buildings for
 (including flower  boxes and    site level  information.
 trellises)
  Wood rot/decay   CMAI3
  Termites
  Wood boring
   insects
              Soil contact nonfumigation treat-
—            ment.
(O. 2% RTU)    Formulated with copper sulfate
 OO300S-OOO49 and sodium dichrornate..
Wood Protection Treatment  of
 Forest Products  by  Pressure
 Treatment
FYftEOBB

IIFAAHA

IGERPGA
IMGAAAA
  Wood rot/oecay   CMP.I3
  Gribbles  (Lim-
   noria)
  Teredos
  Termites
 finished
 solution
(14. 1%,
 15. 1*,
 23. 6*,
 23.75*,
 24. 2*,
 25. 4*,
 26. 3%,
 28. 5X,
 29. 9%,
 32. 17*,
 32. 2*,
 32.75%,
 33.25*,
 34. 2*,
 39.3*  SC/L)
 OOOO61-OO141
RESTRICTED USE PESTCIDE.
For sale to and use only  by certi-
fied applicators or by persons un-
cer their direct supervision and
only for those uses covered by
the certified applicator's certi-
fication.  Refer to arsenical re-
ports for applicator safety and
air quality monitoring limita-
t ions.
Impregnation procedures must rig-
idly adhere to the current speci-
fications of the American Wood
Preservers Association.

Wood protection treatment.  Formu-
lations can not be used in dry
form.  To be used only in water.
Consult manufacturer concerning
specific dosage and use
informat ion.
Formulated with one or a.combina-
tion ofs  arsenic  pentoxide  and
cupric oxide.
         Issued:   3-26-87
                    128

                     HI-O21101-3

-------
                             Index  to Pesticide Chemicals

                                   CHROMIC ACID

           Listing  of Registered Pesticide  Products  by Formulation

 *O14. 1015 14. IX  soluble  concentrate/1iquid
             chromic  ac_id (021101),  arsenic  pentoxide  (006802) plus cupric
               oxide (04*2401)
               O03OO8-OO035   OOS333-00002

 &014. 1215 14. 15% soluble concentrate/liquid
             chromic  acid (0211O1),  arsenic  pentoxide  (O06802) plus cupric
               oxide (O42401)
               OOOO61-OO170*
                 ••jacket  currently unavailable for review

 4015. 1O15 15.IX soluble  concentrate/liquid
             chromic  acid (021101),  arsenic  pentoxide  (006802) plus cupric
               oxide (O42401)
               010465-00012

 402O.OO15 SO* soluble concentrate/1iquid
             chromic  acid (O211O1),  cupric oxide  (042401) plus phosphoric acid
               (076001)
               O03O08-00024*
                  ••jacket currently  unavailable for  review

 «Oc:3.6O15 £3.6* soluble  concentrate/liquid
             chromic  acid  (0211O1),  arsenic  pentoxide  (006802) plus cupric
              oxide (O42401)
               0487O6-OO001

 &O23. 7515 £3.75% soluble concentrate/liquid
             cnrornic  acid  (021101),  arsenic  pentoxide  (OO6802) plus cuorous
              oxide (O25601)
               OO3OO3-00036   O10356-00006   047097-00003

             chromic  acid  (021101),  arsenic  pentoxide  (006802) plus cupric
              oxide (042401)
               O00061-00128*  010465-00010
                 •••jacket  currently unavailable for review

&O23. 8O15 S3.SX soluble  concentrate/1iouid
             chromic  acid  (021101),  arsenic  acid  (006801) plus cupric oxide
              (0424OI)
               045968-000051-
                 •••cancelled

4024.2O15 24.2% soluble  concentrate/liquid
             chromic  acid (021101),  arsenic  pentoxide  (006802) plus  cupric
              ox id* (042401)
               O35896-OO002

*025. 4O15 £5.4* soluble  concentrate/liquid
             chromic  acid (021101),  arsenic  pentoxide  (006802)  plus  cupric
              oxide (042401)       j 29
               003OO8-00016

           Issued!  3-26-87      III-O21101-4

-------
                       EPA Index to Pesticide Chemicals

                                 CHROMIC flCID

          Listing of Registered Pesticide Products by Formulation  (continuec)

4026. SO 15  ££. 5X soluble concentrate/1 louid
            chromic ac-id (O21101),  arsenic pent oxide (006802)  plus  cupric
             oxide (O42401)
              O08333-OO001

4028. SO 15  £8.5* soluble cortcer.trate/1 jquiq
            chromic acid (021101),  arsenic pentoxide (006802)  plus  cuprous
             oxide (O25601)
              O10465-00020    047097-00004

4029. 9015  £9.9% soluble concentrate/liquid
            chromic acid (021101),  arsenic pentoxide (006802)  plus  cupric
             oxide (O42401)
              OO3008-OO034*
                •jacket currently unavailable for review

4032.1715  32. 17% soluble concentrate/liquid
            chromic acid (021101),  arsenic pentoxide (006802)  plus  cupric
             oxide (O42401)
              01O465-O0019

4032.2015  32.2*  soluble concentrate/liquid
            chromic acid (O211O1),  arsenic oentoxide (006802)  plus  cupric
            oxide (O42401)
              003008-00042

14032. 7515  52. 75* soluble concentrate/1 iquij
            chromic acid (021101),  arsenic pentoxide (006802)  plus  cuprous
            oxide (O25601)
              O47097-OOOO1

[»033.2515 33.25* soluble concentrate/liquid
           chromic acid (021101),  arsenic pentoxide (006802)  plus  cupric
            oxide (042401)
              000061-OO141

11034. £015 34. S*  soluble concentrate/liquid
           chromic acid (021101),  arsenic pentoxide (006802)  plus cupric
            oxide (O42401)
              000061-00173    OO3008-OO017*
                •jacket currently unavailable for review

1*039.3015 39. 3%  soluble concentrate/1 iouid
           chromic acid (021101),  arsenic pentoxide (OO6802)  plum cuprous
            oxide (025601)
             047097-OOOO8

           chromic acid (021101),  arsenic pentoxide (006802)  plus cupric
            oxide  (042401)
             O1O465-OO011
                                  130


         Issueds   3-86-67       III-O21101-5

-------
                        EPA Index to Pesticide Chemicals

                                  CHROMIC ACID

           Listing of Registered  Pesticide Products by Formulation (continue:

&OOO. £O16 O.2* liquid-ready to use
             chromic acid (0211O1),  copper sulfate (024401)  plus sodium
              dichrornate (O68304)
               003O08-OO043   003992-OOO01*
                 •••jacket currently unavailable for review

4003.1816 3.18* liquid-ready to  use
             chromic acid (021101),  arsenic pentoxide (006802)  plus cupric
              oxide (042401)
               0030O8-OO021
999993/9   State Label  Registrations

            FL Reg. No.
              003992-03315

            HI Reg. No.
              035053-05242    036019-03490
                                  131
          Issued I  3-26-87       111-O21101-6

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             EPA Index to Pesticide Chemicals

                       CHROMIC ACID

                       Appendix A-l

Listing of Active Ingredient(») Found in Combination with the
 Report Chenucal

                                                   EPA Acceptable
                                               Common/Chemical Name
Chemical
Code
006802
O42401
O£56O1
068304
Common Nam*
(source)
arsenic pentoxide
cupric oxide
cuprous oxide
sodium dichr ornate
— Use Common Nami
                         132

Is*u«ds  3-26-87       III-OailOl-7

-------
              EPfl Incex tc< Pesticice Cnemicals

                    POTftSSI'Jtt DICK

                      ~QP_£ 0-
      i\err.e _ ; __ _ ____ _ _ Pas 6
      oc or Wooa Structure Protection Treatments)              1

   (Miscellaneous Incoor Jses)
   Sesscnec Forest Procucts (pole framing, pilings, anc
    railroac ties)
                         133

Issuec:  3-£6-S7         II-06630£-i

-------
                       EPO Index to Pesticide Chemicals

C06S3O2                      POTASSIUM DICHROmflTE

          TYPE PESTICIDE;   Fungicide,  ftnt inucrobial
          FI
          P/~  (39.8*,  85.9*)
          Impr  (3%,  1 S\ 6X>
          RTLJ  (3.
                                 ^ ITQTIQNS ;  None.
         Site and  Pest        Dosages and   Tolerance.  Use.  Limitations
                              Formu1 ation(s)

         DOESTIC  OUTDOOR

            (Uood or Uood Structure Protection Treatments)

     Nft    Seasoned Forest  Products  (po1e
            framing,  oil ings,  and railroad Refer to labelling for warnings
            ties)                           and limitations concerning
                                            creosote oil  (OS5003).
                                            For aoplication to end cuts, bolt
                                            holes,  and hardware fabrication.

  4EQBB       Wood  rot/decay  CMAI3         Soil contact nonfumigation treat -
                              —            ment.   Do not dilute or mix witn
                              (3. 1* RTU)    other products.
                               QO3G08-OO050 Formulated witn creosote oil;
                                            £,4-dinitrophenol, and sodium
                                            fluoride.
                               134

         issuec:  3-26-S7         II-0£820c-l

-------
           £lte  ar-g  Pest
             Jr.cex to Pesticipe Chemicals

               PQTflSSIUm DICHROMflTE

                Dosages and,   Tolerance, use. Limitations
                Formulat ion(s)
           INDGOR
             (Miscel 1 arreous  Indoor- Uses)
              ic logical Specimens  (milk
              samples)
SEftDflfifl
rfacteriostat

Det erioration/
 spoilace bac-
 teria
                               (85.3% P/T)
                               OO2355-OOOS1
0.IS g/180    MilK preservative.  Refrigerate
 ml composite milk samples between 33 F  (0.6 C)
 milk sample  ana 40 F (4.4 C).  Do not over—
              heat sample.  Temperature of milk
              sample batri to be 35 to 33 F
              (35.0 to 37.2. C).  Temperature of
              each milk samole and sulfuric
              acid to be 60 to 70 F (15.6 to
              SI.1 C) before adding the sulfu-
              ric acid to the test charge in
              eacn bottle.  Agitate milk sample
              gently, churning is the result of
              violent agitation.  One tablet
              Mill preserve a 160 - milliliter
              composite milk sample up.to 21
              days,  coloring milk sample light
              green.
                              1 tablet/2
                               f 1. 02 mi ll<
                               sample
                              (33, 8« P/T)
                              Milk preservative.  For  use  by
                              experienced personnel  for  preserv-
                              ing milk samples  in the  Dairy
                              •N«rd Improvement  Program only.
                               037723-GOOO1 Skin  contact  with  milk may cause
                                            severe dermatitis.   Treated milk
                                            cannot be  fed to humans or
                                            animals.   Do  not pipette milk
                                            samples  oy mouth.
                               135
          Issued:   3-26-87
                    II-06830£-£
                           BEST AVAILABLE COPY

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              EPa Incex to Pesticide Chemicals

                    PCTflSSIUM DICKROMftTE

 Listing of Registered Pesticide Products by Formula* i on

 45% f or MU 1 at i on i nt er mec late
   potassium dicnromate (068302),  m-cresoi (0221O£)  plus copper
    sulrate (024401)
     OO399£-OOOO6*
       *jacket  currently unavailable for review

 33. ay. pel letec'/tableted
   potassium oicnrornate (06330£)
     0377c;2-0000l

 85. 9'/. Jel letee/tableted
   Dot ass i urn d ichrornate < 068305)
     002955-OO021

 3%  impregnated  materials
   potassium dicnromate (0&&30£)^  coal  tar creosote  (025004),
    pentachlorophenol** (0630O1),  petroleum distillate  (0635O3)
    = 1 us sod i urn  fluoride (075£O£)
     OOO453-OO190+  006732-^0003-t-
       +cancelled
       **includes  l.^'A percent other cnlorophenols

 l£. S%  impregnated  materials
  potassium dicnrornate <066302),  coal  tar creosote  (0250O4),
   pentachlorophenol  X0630O1) plus sodium fluoride  (075£0£)
    010771-OOOO2*
       •jacket currently unavailable for r«vi«w

3. 1%  liquiG-reacv  to  use
  potassium cicnromate (068302),  coal  tar creosote  (025004),
   2, 4-dinitrophenol  (O37509) plus sodium fluoride  (075£0£)
    003OOS-00004*
       *jacket currently unavailable for review
  potassium dichromate  (06830£),  creosote oil (0£5003), coal tar
   creosote  (025004), 2, 4-dinitrophenol (037509), pentacnlorophenol
   (0&3001) plus sodium fluoride (075£0£)
    003008-00048

  potassium dicnromat*  (068302),  creosote oil (0£5003), £,4-dirn-
   trophenol  (037509) plus sodium fluoride (075£02)
    003008-00050
                     136
Issues:  3-26-87         II-O68302-3

-------
                  Incex to Pesticioe Chemicals

                    POTASSIUM DICHROttATE

                        Appendix A-l
 Listing of Active Ingres lent (s) Founa "in Corn oinat ion witn  tni
 Resort  Chemical
Chemical
  Code

Oc'210£
O25003

Ot5004

O37509

063001

OE.3503

075£03

075£0£
            -Common Name
              (source)

             rn-cresol

             copoer sulfate

             cresote oil

             coal  tar cresote

             £, A-dinitroohenol

             pentachlorophenol

             petroleum distillate

             potassium bifluoride

             sod i urn f 1 uor i de
    EPA Acceptaole
Common/Chemical Nam
— Use Common  Name
Issuea:  3-£6-87
                     137
                         II-0£830c:-4

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             EPA Index to   :sticide Chemicals

                     SODIUM DICHROMftTE

                     TQBLE OF CONTENTS

Site Name	.	Pane

DOMESTIC OUTDOOR                                             1
  (Wood or Wood Structure Protection Treatment)               1
INDOOR                                                       5
  (Commercial and Industrial Uses)                           5

  Brewery Pasteurizer Water                                  5
  Seasoned Forest Products                                   2
  Seasoned Forest Products  (bridge timber,  construction
   timber, gates, pit props, poles supporting farm
   buildings, and railroad ties)                             1
  Seasoned Forest Products  (gate posts,  poles supporting
   farm buildings,  and utility poles)                        £
  Wood Protection Treatment of Finished Wood Product*
   (including boats,  garden furniture,  and truck bodies)     4
  Wood Protection Treatment of Forest Products of
   Pressure Treatment                                        4
  Wood Protection Treatments Made to Wooden Containers
   and Other Items Used for Growing Plants (including
   flower boxes and trellises)                               *
  Wood Protection Treatments of Existing Buildings or
   Parts of Buildings (including porch flooring, steps,
   roof cornices, and greenhouses)                           2
                      138
Issuedi  3-36-87         II-068304-i

-------
                        EPft  Index  to Pesticide  Chemicals

-"68304                         SODIUM DICHROMflTE

           TYPE  PESTICIDE;   Fungicide,  Insecticide

           FORMULflTIONSl
           P/T   (19%)  .
           Impr  (A.9%,  13X)
           SC/S  (14. £*,  18. 5S,  31. 5X,  42. 6X,  53%)
           RTU   
-------
                       EPfl Index to Pesticide Chem-'

                               SODIUM DICHROMflTE

          Site and Pest       Dosages and   Tolerance. Use.  Limitation^
                              Formulation
-------
                        EPP Index  to Pesticide Chemicals

                                SODIUM DICHROMftTE
           Site and Pest
                  Dosages and   Tolerance. Use.
                  Formulat ion(s>
                              Limitat ions
 /640020ft
Seasoned Forest Products
                                             Use only for  application to  ex-
                                             posed  surfaces  when  cutting  or
                                             notching cnromated zinc  chloride
                                             pressure-treated  lumber.
 FYftEQBB

 IMGAfififi
  Wood rot/decay  CMAID
  Termites
              Wood protection treatment.   Stir
              contents and  use undiluted.   ftp-
(3.72% RTU)    ply several coats with brush or
 OO309S-OOO12 rag mop to all  surfaces of
              pressure-treated lumber that has
              been exposed  by cutting,  notch-
              ing, or dapping.
              Formulated with zinc chloride.
/64OOONA
/640OONB
Wood Protection Treatments of
 Existing Buildings or Parts
 of Buildings (including porch
 flooring, steps, roof cor-
 nices,  and greenhouses)
              May be applied by brush,  spray,
              or dip.   Wood to be treated must
              be in its natural state and free
              from dirt,  oil,  stain,  or paint.
              One drenching coat is sufficient
              for indoor us*.   Wood already in-
              stalled indoors may be treated;
              use adequate ventilation during
              application.   Two or 3 applica-
              tions are necessary if the wood
              is to be exposed to weather or se-
              vere moisture.  Thoroughly treat
              all cracks, knot holes, wooden
              joints,  and bolt hole surfaces
              since these areas are most vulner-
              able to decay.  One coat may fol-
              low another within a few min-
              utes.  Dipping for outdoor use
              should be for a minimum of 12
              hours.  Where ground or water con-
              tact is planned,  immersion should
              be from 24 to 48 hours.
              Formulated with chromic acid and
              copper sulfate.
FYfiEQBB

XMGAAAA
JMAAACP
  Wood rot/decay  CMOZ3
  Termites
  Wood boring
   insects
              Soil contact nonfumigation  treat-
—            ment.
(5.01* RTU)
 003006-00049 Nonsoil contact nonfumigation
              treatment.
                               141
           Issued!   3-26-87
                       II-068304-3

-------
         Sit i
    ind  Pest
                       EPA Index to Pesticide Chemicals

                               SODIUM DICHROMATE

                              Dosage? and   Tolerance.  Use.  Limitation^
                              Formal at ion(s)
/64003NB





FYfiEQBB

IMGAAAA
           Uood Protection Treatment  of
            Finished Wood Products  (in-
            cluding boats, garden furni-
            ture, and truck  bodies)

             Uood rot/decay   CMP.13
                                 Refer to Wood  Protection  Treat-
                                 ments of Existing  Buildings  for
                                 site level  information.
             Termites
             Uood boring
              insects
                   (S.01* RTU)
                    OO3008-OO049
              Nonsoil contact
              treatment.
              Formulated  with
              copper sulfate.
nonfumigat ion

chromic acid and
/64004NA
Wood Protection  Treatments Made
 to Uooden Containers  and Other
 Items Used  for  Growing Plants
            (including
            trellises)
             flower  boxes and
                                            Refer to Uood Protection Treat-
                                            ments of Existing Buildings for
                                            site level information.
FYAEQBB

IMGAAAA
1MPAACA
/6401C3A
  Wood rot/decay   CMAID
  Termites
  Uood boring
   insects
                                            Soil contact nonfurnigat ion treat-
                              -—            ment.
                              (5. CIS RTU)   Formulated with chromic acid and
                               003008-00049 copper sulfate.
Uood Protection  Treatment of
 Forest Products by Pressure
 Treatment
 YAEQ6B

 NGftflfift
  Wood rot/decay
  Termit(
                                            RESTRICTED USE PESTICIDE.
                                            For sale to and use only by certi-
                                            fied applicators or by persons un-
                                            der their direct supervision anc
                                            only for those uses covered by
                                            the certified applicator's certi-
                                            fication.  Refer to arsenical re-
                                            ports for applicator safety and
                                            air quality monitoring limita-
                                            tions.
                                            Impregnation procedures must rig-
                                            idly adhere to the current speci-
                                            fications of the American  Uood
                                            Preservers Association.
                                            Uood protection  treatment.   Formu-
                                            lations  cannot  be used in dry
                                            form.  To  be  used only in water.
                                            Consult  manufacturer concerning
                                            specific dosage and us* informa-
                                            tion.
                                            Formulated with one or * combina-
                               OOO061-00133 tion ofi  arsenic pentoxide, sodi-
                                            um pyroarsenate, and copper  sul-
                                            fate.
                                142
CMAZ3
l*-3*
 finished
 solution
(31.3*,
 42.6*, 53*
 SC/S)
         Issuedt  3-26-87
                       II-068304-4

-------
          Site and Pest
             EPA Index to Pesticide Chemicals

                     SODIUM DICHROMATE

                    Dosages and   Tolerance.  Use.  Limitations
                    Formulat ion(s)
/65005MA

FYAFQBB
INDOOR

  (Commercial  and Industrial  Uses)

  Brewery Pasteurizer Water
    SIime-forming
     fungi
CMftID
1  Ib 18.SX
 SC/S/125-
 250 gal
 water
(IB.5X SC/L)
             Water treatment.   Predissolve for-
             mulation prior to adding to pas-
             teurizer by adding a full charge
             to a small amount of hot water in
             a mixing bucket.   Add more hot wa-
             ter and stir well.  Pour this sc—
OO1020-OOOO7 lution into the preheating tank
             and follow the same procedure for
             supet—heating tank, pasteurizing
             tank,  first-cooling tank, and sec-
             ond—cooling tank.  Consult manu-
             facturer for specific recommend*-
             tions regarding dosage and use
             specifications.
             Formulated with 2-benzyl-4-
             chlorophenol and alkyl*dimethyl
             benzyl ammonium chloride *alkyl
             (60X C14, 30X C16, SX CIS, S'/.
             CIS).
                              143
          Issued:   3-26-87
                        11-068304-3

-------
                       EPA  Index  to Pesticide  Chemicals

                               SODIUM  DICHROMBTE

          Listing  of  Registered Pesticide Products  by Formulation

4019. OOOS  19*  pel leted/tableted
           sodium dichromate  (O68304),  2,4-dinitrophenoi  (0375O9), sodium
            fluoride (O75202)  plus potassium  bifluoride  (0752O3)
              007969-00051»
               •jacket  currently unavailable  for review

(004. 9010 4.9* impregnated  materials
           sodium dichromate  (068304),  copper sulfate (024401) plus acetic
            acid  (044001)
              OO8300-OO007+
               •••cancelled

J013. OO1O 13X  impregnated material
           sodium dichromate  (068304),  2,4-dinitrophenol  (0375O9), sodium
            fluoride (075202)  plus potassium  bifluoride  (075203)
              OO7969-O0037*
               ••jacket  currently unavailable  for review

1014.6015 14. 6X soluble  concentrate/solid
           sodium dichromate  (O68304),  chromic acid  (021101)  plus  zinc
            chloride (087801)
              000352-00015+
               •••cancel led

|l018.5015 16. 5* soluble  concentrate/solid
           sodium dichromate  (068304),  0-benzyl-p-chlorophenol,  potasssium
            salt  (O62201)  plus alkyl*dimethyl ammonium chloride  »alkyl  (60%
            C14,  30% C16,  5* CIS,  5*  CIS)  (069104)
             O01020-OO007

JS031.5015 31.5* soluble  concentrate/solid
           sodium dichromate  (068304),  arsenic pentoxide (0068O2), sodium
            pyroarsenate (013401)  plus  copper sulfate  (024401)
             00006l-OO139

1*042.6015 45. 6X soluble  concentrate/solid
           sodium dichrow*t«  (068304),  arsenic pentoxide (006802) plus
            copper sulfate (024401)
             OOOO61-OO14O

1*053.0015 53* soluble concentrate/solid
           sodium dichromate  (068304),  arsenic pentoxide (006802) plus
            copper sulfate (0244O1)
             OOOO6l-OO187

t&O. 3016 Q.3X liQuid-readv to  use
           sodium dichromate  (O68304),  ammonium sulfate  (005601),  boric
            acid  (011OO1)  plus zinc chloride  (087801)
             O06823-OOOO6+
               ^cancelled

1*03.7216 ?,•*?> liouid-readv to use
           •odium dichromate  (O683O4) plus zinc chloride (0878O1)
              003098-OOO12

-------
                        EPA Index  to Pesticide  Chemicals

                                SODIUM DICHROMPTE

           Listing  of Registered Pesticide  Products  by Formulation  (continued)

&205.O115  5.01*  liquid-ready to use
             sodium diehrornate (068304),  chromic  acid  (0211O1)  plus copper
              sulfate (024401)
               OO3008-00049   OO3992-OOO01*  003992-03315
                 •jacket currently unavailable  for review

4234. 3O16  34.3*  liquid-ready to use
             sodium dichromate (068304),  sodium arsenate  (0135O5),  2,4-
              dinitrophenol (O37S09)  plus sodium  fluoride  (075202)
               OO3008-OOOO7+
                 •••cancel led
9999999   State Label  Registration

            FL Reg. No.
              003992-03315
                           145
          Issued I  3-26-87         11-068304-7

-------
              EPA Index  to Pesticide  Chemicals

                      SODIUM  DICHROMATE

                        Appendix  A-l

 Listing  of Active Ingredient(s)  Found in Combination with thi
 Report Cherni-cal
 Chemical
   Code

 O44001

 O69104
005601

OO6802

062201



O11001

O21101

O24401

O37509

075203

012505

068304

O75202

087801
Common Nam*
 (source)

acetic acid

alkyl«dimethyl benzyl
 ammonium chloride *alkyl
 <60X, C14,  30% C16,  5% Cl£(
 5X CIS)

amonium sulfate

arsenic pentox id*

o-benzyl-p-chlorophenolt
 potassium salt

boric acid

chromic acid

copper sulfate

2,4-dinitrophenol

potassium bifluoride

sodium arsenate

sodium dichromate

sodium fluoride

zinc chloride
    EPA Acceptable
Common/Chemical Narni
— Use Common Name
                  146
Issued:  3-26-87
            II-068304-8

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                            BIBGUIDE-1

              GUIDE TO USE OF THIS BIBLIOGRAPHY


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 Standard.  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 ENTRY.  The unit of entry in this bibliography
    is called a "study."  In the case of published materials.
    this corresponds closely to an article.  In the case of
    unpublished materials submitted to the Agency, the Agency
    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 Agency 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 a further explana-
    tion.   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.
                            147

-------
                        BIBGUIDE-2

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

b.  Document Date.  When the date appears as  four digits
    with no question marks, the Agency took it directly
    from the document.  When a four-digit date is followed
    by a question mark, the bibliographer deduced the
    date from evidence in the document.  When the date
    appears as (19??), the Agency was unable  to  determine
    or estimate the date of the document.

c.  Title.  In some cases, it has been necessary for
    Agency bibliographers to create or enhance a document
    title.  Any such editorial insertions are contained
    between square brackets.

d.  Trailing Parentheses.  For studies submitted to the
    Agency in the past, the trailing parentheses include
    (in addition to any self-explanatory text) the  fol-
    lowing elements describing the earliest known submission:

    (1)  Submission Date.  The date of the  earliest known
         submission appears immediately following the  word
         "received."

    (2)  Administrative Number.  The next element,
         immediately following the word "under," is the
         registration number, experimental  use  permit
         number, petition number, or other  administrative
         number associated with the earliest  known  submission.

    (3)  Submitter.  The third element is the submitter,
         following the phrase "submitted by."  When
         authorship is defaulted  to the submitter,  this
         element is omitted.

    (4)  Volume Identification (Accession Numbers).  The
         final element in the trailing parentheses
         identifies the EPA accession  number of the volume
         in which the original submission of the study
         appears.  The six-digit  accession number  follows
         the symbol "CDL,"  standing  for "Company Data
         Library."  This accession  number  is in turn
         followed by an alphabetic  suffix  which shows the
         relative position  of  the study within  the volume.
         For example, within  accession  number 123456, the
         first  study would  be  123^*56-A; the  second, 123456-
         B; the 26th,  123456-Z;  and  the 27th, 123456-AA.


                      148

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                        OFFICE OF PESTICIDE PROGRAMS
                     REGISTRATION STANDARD BIBLIOGRAPHY
        Citations Considered to be Part of the Data Base Supporting
            Registrations Under the Chromated and Non-Chromated
                   Arsenical Wood Preservatives Standard
    MR ID            CITATION

  00099363 Fink, R.; Reno, F.E. (1973) Final Report: Acute LC50—Bluegill
              Sunfish and Rainbow Trout: Taco CCA, 40% Concentrate: Projects
              No. 829-100 and No. 829-101.  (Unpublished study received Aug
              20, 1973 under 8333-1; prepared by Environmental Sciences Corp.,
              submitted by Rentokil, Inc., Spartanburg, N.C.; CDL:128552-B)

  00104601 Wolven, A.; Levenstein, I. (1970) To Determine If the Test Materi-
              al Produces Any Irritation When Instilled into Rabbits' Eyes:
              Assay No. 10100.  (Unpublished study received Oct 27, 1970
              under 390-43; prepared by Leberco Laboratories, submitted by
              Pettit Paint Co., Inc., Borough of Rockaway, NJ; CDL:003224-B)

  00106113 Fink, R. (1973) Final Report: Eight-day Dietary LC50«Bobwhite
              Quail: Taco CCA: Project No. 829-102.  (Unpublished study
              received Aug 20, 1973 under 8333-1; prepared by Environmental
              Sciences Corp., submitted by Rentokil, Inc., Spartanburg, N.C.;
              CDL:128552-C)

  00120843 Peoples, S. (1979) The Dermal Absorption of Arsenic in Dogs from
              Sawdust from Wood Treated with ACA and CCA-C.  (Unpublished
              study received Aug 27, 1979 under unknown admin, no.; prepared
              by Univ. of California--Davis, Dept. of Physiological Science,
              submitted by Koppers Co., Inc., Pittsburgh, PA; CDL:240889-B)

  00159870 Jacobson-Kram, D.; Mushak, P.; Piscator, M.; et al.  (1984) Health
              Assessment Document for Inorganic Arsenic: Final Report: EPA-
              600/8-83-021F.  Washington, DC: Environmental Protection Agency.
              347 p.

GS0647-001 Woolson, E.; Gjovlk, L. (1981) The Valence State of Arsenic on
              Treated Wood.  American Wood-Preservers' Association [Proceedings
              of 1981 Annual Meeting].  5 p.

GS0647-002 US Environmental Protection Agency (1984) Health Assessment Document
              for Chromium: Final Report: EPA-600/8-83-014F.  180 p.
                                149

-------
                                                                            Form Approved.  OMB No. 2070-0057. Approval expires 11-3C-S9
FIFHA SECTION 3(C)(2)(L;) SUi'vUlAHY SHEET
PRODUCT NAVE
APPLICANT'S NAME
EPA REGISTRATION NO

DATE GUIDANCE DOCUMENT ISSUED
With respect to the requirement to submit "generic" data imposed by the FIFRA section 3(C)(2H8) notice contained in the referenced
Guidance Document, I am responding in the following manner:
C 1. 1 will submit data in a timely manner to atisfy the following requirements. If the ten procedures 1 will use deviate from (or are not
specified in) the Registration Guidelines or the Protocols contained in the Reports of Expert Groups to the Chemicals Group. OECO
Chemicals Testing Programme, 1 enclose the protocols that 1 will ust:
D 2. 1 have entered into an agreement with one or more other registrants under FIFRA section 3(CH2)(BKii) to satisfy the following datt I
requirements. The tests, and any required protocols, will be submitted to EPA by:
NAME OF OTHER REGISTRANT
   L-; 3.  I enclose a completed 'Certification of Attempt to Enter Into an Agreement with Other Registrants for Development ot Oata" with
         respect to the following data requirements:
   LJ 4.  I request that you amend my registration by deleting the following uses (this option a not available to applicants for new products):
     ', 5. I request voluntary cancellation of the registration of this product. (This option is not available to applicants for new products.)
REGISTRANT'S AUTHORIZED REPRESENTATIVE
EPA Font. 8580-1 (10-lW)
   SIGNATURE
150
                                                                                                                  DATE

-------
                                             CMB Approval No. 2070-0057
                                             Expiration Date 11/30/89
                         GENERIC DATA EXEMPTION STATEMENT

EPA Product  Registration Number: 	

Registrant's Name and Address:   	
    As an  authorized representative of the registrant of the product identified
 above, I certify  that:

    (1)  I have read and am familiar with the terras of the Notice from EPA dated
              concerning a requirement for submission of generic data on the
 active  ingredient	named under FIFRA Section 3(c)(2)(B).

     (2)  My  firm requests that EPA not suspend the registration of our product,
 despite our  lack of intent to submit the generic data in question, on the grounds
 that the product contains the active ingredient solely as the result of  the
 incorporation  into the product of another product which contains that active
 ingredient,  which is registered under FIFRA Section 3, and which is purchased by
 us from another producer.

    (3)  An  accurate Confidental Statement of Formula(CSF) for the above-identified
 product is attached to this statement.  That formula statement indicates, by
 company name,  registration number, and product name, the source of the subject
 active ingredient in my firm's product, or
                                        i
 The CSF dated   	on file with EPA is complete, current and accurate and
 contains the information requested on the current CSF Form No. 8570-4.  The
 registered source(s) of the above naned active ingredient in my product(s) is/are
	and their registration number(s) is/are	 .

    (4) My firm will apply for an amendment to the registration prior to changing
 the source of  the active ingredient in our product to one that is not registered
 and purchased.

    (5)  I understand, and agree on behalf of my firm, that if at any time any
 portion of this Statement is no longer true, or if ray firm fails to comply with
 the undertakings made in this Statement, my firm's product's registration may be
 suspended under FIFRA Section 3(c)(2)(B).

    (6)  I further understand that if my firm is granted a generic data exemption
 for the product, my firm relies on the efforts of other persons to provide the
Agency with  the required generic data.  If the registrant(s) who have committed
 to generate  and submit the required data fail to take appropriate steps to meet
requirenents or are no longer in compliance with this Notice's data requirements,
 the Agency will consider that both they and my firm are not in compliance and
will normally  initiate proceedings to suspend the registrations of my firm's
product(s) and their product(s), unless my firm commits to submit and submits
the required data in the specified time frame.  I understand  that, in such cases.
 the Agency generally will not grant a time extension  for submitting the data.
Registrant's authorized representative:
                                               (Signature)

Dated: 	
                                    1 5J        (Typed)

-------
                             PRODUCT SPECIFIC DATA REPORT
 EPA Reg. Nb._
    Date
Registration Standard  for
Registration
Guideline No.
§158.120
PRODUCT
CHEMISTRY
61-1
61-2
61-3
62-1
62-2
62-3
63-2
63-3
63-4
63-5
63-6
63-7
63-8
63-9
63-10
63-11
63-12
Name of Test

Identity of
ingredients
Statement of
composition
Discussion of
formation of
ingredients
Preliminary
analysis
Certification of
limits
Analytical methods
for enforcement
limits
Color
Physical state
Odor
Melting point
Boiling point
Density, bulk-
density, or
specific gravity
Solubility
Vapor pressure
Dissociation
constant
Octanol/ water
partition
coefficient
PH
Test not
required
for my
product
listed
above
(check
below)


















I am complying with
data requirements by
Citing MRID
Number or
EPA Accession
Number


















Submit-
ting
Data
(At-
tached)


















(For EPA Use Only)
MRID Numbers
Assigned


















EPA Form 8580-4
152

-------
Registration
Guideline No.
63-13
63-14
63-15
63-16
63-17
63-18
63-19
63-20
63-21
§158.135
TOXICOLOGY
81-1
81-2
81-3
81-4
81-5
81-6
Name of Test
Stability
Ox id i z ing/ reduc ing
reaction
Flammability
Explodability
Storage stability
Viscosity
Miscibility
Corrosion
characteristics
Dielectric break-
down voltage

Acute oral
toxicity, rat
Acute dermal
toxicity, rabbit
Acute inhalation,
toxicity t rat
Primary eye
irritation, rabbit
Primary dermal
irritation
Dermal sensitiza-
tion
Test not
required
for my
product
listed
above
(check
below)
















I am complying with
data requirements by
Citing MRID
Number or
EPA Accession
Number
















Submit-
ting
Data
(At-
tached)
















(For EPA Use Only)
MRID Numbers
Assigned
















153

-------
                                                                                                  OMB Me WTC-0057. En*»* 11-3M8.
   qualify, certify ALL four items)
                                         CERTIFICATION OF ATTEMPT TO ENTER
                                    INTO AN AGREEMENT WITH OTHER REGISTRANTS
                                              FOR DEVELOPMENT OF DATA
  I am duly authorized to represent the following firm(s) who are subject to the require-
  ments of a Notice under FIFRA Section 3(c)(2)(B) contained in a Guidance Document
  to submit data concerning the active ingredient:
                                                                                    GUIDANCE DOCUMENT DATE
                                                                                    ACTIVE INGREDIENT
                                     NAME OF FIRM
                                                                                             EPA COMPANY NUMBER
(This firm or group of firms is referred to below as "my firm".)
2. My firm is willing to develop and submit the data as required by that Notice, if necessary. However, my firm would prefer to enter
  into an agreement with one or more other registrants to develop jointly, or to share in the cost of developing, the following required
  items or data:
3. My firm has offered in writing to enter into such an agreement Copies of the offers an arttchid. That offer was (rrtvocabli and included an offer to be
   bound by an arbitration decision under FIFRA Section 3(c)(2)(B)(iii) if final agreement on ell terms could not be reached otherwise. This offer was mede
   to the following firm(s) on the following date(s):
                                    NAME OF FIRM
                                                                                                 DATE OF OFFER
 However, none of those firm(s) accepted my offer.
4. My firm requests that EPA not suspend the registration(s) of my firm's product(s), if any of the firms named in paragraph (3) above
   have agreed to submit the data listed in paragraph (2) above in accordance with the Notice. I understand EPA will promptly inform
   me whether my firm must submit data to avoid  suspension of its registration(s) under FIFRA Section 3(c)(2)(B). (This statement
    •*s not apply to applicants for new products.) I give EPA permission to disclose this statement upon request.
 TVPEDNAME
                                                     SIGNATURE
                                                    5-t
                                                                                                        DATE
EPA Form 85804 MM2I

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