CAPTAFOL
           POSITION DOCUMENT 1
   U.S. Environmental Protection Agency




Office of Pesticides and Toxic Substances




       Office of Pesticide Programs




            401 M Street, S.W.




             Washington, D.C.

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                       ACKNOWLEDGEMENTS






Ingrid M. Sunzenauer, Review Manager, Registration Division




William Boodee, Chemist, Hazard Evaluation Division




Harry Day, Chemist, Hazard Evaluation Division




Robert Esworthy, Economist, Benefits and Use Division




Kevin Lee, Attorney, Office of General Counsel




Maureen Lydon, Program Coordination Staff, Registration Division




Neil Pelletier, Plant Pathologist, Benefits and Use Division




Margaret Rostker, Wildlife Biologist, Hazard Evaluation Division




Esther Saito, Science Integration Staff, Hazard Evaluation Division




William Schneider, Toxicologist,  Hazard Evaluation Division




Robert Zendzian, Pharmacologist,  Hazard Evaluation Division

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6560-50




               ENVIRONMENTAL PROTECTION AGENCY




                        [OPP-30000/43]




                           CAPTAFOL




         SPECIAL REVIEW OF CERTAIN PESTICIDE PRODUCTS






AGENCY:  Environmental Protection Agency (EPA).




ACTION:  Notice.




SUMMARY:  This notice announces that EPA is initiating a




Special Review of all pesticide products containing the active




ingredient captafol.  Captafol is a fungicide used to control




the foliar diseases of certain fruits and vegetables.  EPA




has determined that captafol is oncogenic in rats and mice




and is highly toxic to fish.  Captafol meets or exceeds




the risk criteria as described in 40 CFR 162.11.  Accordingly,




a Special Review of products containing captafol is appropriate




to determine whether additional regulatory actions, if any,




are required.  During the Special Review process, EPA will




carefully examine the risks and benefits of using captafol




products.




DATE:  Comments, evidence to rebut the presumptions in this Notice,




and other relevant information must be received 45 days from




the date this notice is received or until (insert




date 45 days after date of publication in the FEDERAL REGISTER)




(whichever is later).






84P-4086

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                            - 2 -




ADDRESS:  Written comments identified as "OPP-30000/43" should




be sent by mail to:




      Information Services Section,




      Program Management and Support Division (TS-757C) ,




      Office of Pesticide Programs,




      Environmental Protection Agency,




      401 M St., SW.,




      Washington, D.C. 20460.




      In person, bring comments to:




      Rm. 236, CM #2,




      1921 Jefferson Davis Highway,




      Arlington, VA.




     Information submitted in any comment concerning this




notice may be claimed confidential by marking any part or all




of that information as "Confidential Business Information"




(CBI).  Information so marked will not be disclosed except in




accordance with procedures set forth in 40 CFR Part 2.  A




copy of the comment not containing material claimed to be




CBI must be submitted for inclusion in the public record.




Information not marked confidential may be disclosed publicly




by EPA without prior notice to the submitter.  All non-CBI




written comments will be available for public inspection  in




Rm. 236 at the Virginia address given above, from 8 a.m.  to




4  p.m., Monday through Friday, excluding legal holidays.

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FOR FURTHER INFORMATION CONTACT:  By mail:




      Ingrid.; M. Sunzenauer,



      Registration Division (TS-767C),



      Office of Pesticide Programs,



      Environmental Protection Agency,



      401 M St.,  SW.,



      Washington, D.C. 20460.



      Office location and telephone number:



      Rm. 717,  CM #2,



      1921 Jefferson Davis Highway,



      Arlington,  VA,



      (703-557-7400).



SUPPLEMENTARY INFORMATION: The term "Special Review" is the



name now being used by EPA for the process previously called



the Rebuttable Presumption Against Registration (RPAR)  process.



Modifications in the process will be proposed in regulations



in the near future.  Until other applicable final regulations



are adopted, the present Special Review will adhere to RPAR



procedures now in effect and set forth  in 40 CFR 162.11.



     EPA has determined that a Special  Review will be conducted



for all pesticide products containing captafol as an active



ingredient.  EPA has also determined that data necessary to



refine the Agency's risk analysis for oncogenicity and ecological



effects must be developed on an accelerated basis, and that



precautionary labeling is required to reduce risk during the



Special Review process.

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     Issuance of this notice means that potential hazards




associated with the use of captafol have been identified.




These hazards will be examined further to determine the




nature and extent of the risk, and considering the benefits




of captafol, whether such risks cause unreasonable adverse




effects on the environment.




     A document entitled "Guidance for the Interim Registration




of Pesticide Products Containing Captafol As The Active




Ingredient" (Guidance Document) has been issued.  (The Guidance




Docume'nt is also referred to as a Registration Standard.)




The Guidance Document is available to the public from the




contact person named above.  The Guidance Document




explains the basis of EPA's decision to start a Special




Review and also contains references, background information,




data requirements, and other information pertinent to the




continued registration of pesticides containing captafol.




              I.  INITIATION OF A SPECIAL REVIEW




                          A. GENERAL




     A pesticide product may be sold or distributed in




the United States only if it is registered or exempt from




registration under the Federal Insecticide, Fungicide, and




Rodenticide Act ( FIFRA)  as amended (7 U.S.C. 136 e_t sejj. ) .




Before a product can be registered, it must be shown that it




can be used without "unreasonable adverse effects on the




environment" (FIFRA section 3(c)(5)), that is, without causing




"any unreasonable risk to man or the environment, taking




into account the economic, social, and environmental costs

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and benefits of the use of the pesticide"  (FIFRA section




2(bb)).  The burden of proving that a pesticide meets this



standard for registration is on the proponent of initial or



continued registration.  If at any time the Agency determines



that a pesticide no longer meets this standard for registration,



then the Administrator may cancel the registration under



section 6 of FIFRA.



     The Agency has created an administrative process for



fully evaluating whether a registered pesticide may not



satisfy the statutory standard for registration.  This Special



Review process provides a procedure through which EPA may



gather and evaluate information about the risks and benefits



of a pesticide's use.  It also provides a means by which



interested members of the public may comment on and participate



in EPA's decision making process.  The regulations governing



this process are set forth at 40 CFR 162.11.



     A Special Review is begun when EPA determines that a



pesticide meets or exceeds one or more of the risk criteria



set out in the regulations (40 CFR 162 .11(a)(3)) .  The Agency



generally announces the beginning of the Special Review by



issuing a Position Document (PD) 1, which is published in the



FEDERAL REGISTER.  In addition, registrants of affected



products will receive the PD 1 by certified mail.  Registrants



and other interested persons are invited to scrutinize the



basis for the Agency's decision to initiate the Special



Review and to submit data and information which rebuts or



supports the Agency's determination of risk.  Commenters

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may also suggest methods to reduce risks of use of. the pesticide.



In addition :to addressing risk issues, conunenters are encouraged



to submit evidence and discussions of the biological, economic,



social, and environmental costs and benefits of use of the pesticide.



The public participation stage is described in more detail



in Unit V.  This notice constitutes PD 1 for pesticide



products containing captafol.



     If risk issues are not satisfactorily resolved, EPA will



proceed to evaluate the risks and benefits of captafol to determine



whether to propose regulatory actions to reduce the risks.  After



providing an opportunity for comment by the Scientific Advisory



Panel, the Secretary of Agriculture, registrants, and the public



on those actions and the reasons for them, EPA will issue an



appropriate final notice.  If EPA determines that the risks of



use exceed the benefits, EPA will issue a notice of intent to



cancel the registration of products intended for such use.  The



notice may state the intention to cancel registrations outright



or it may require certain changes in the composition, packaging,



application methods and/or labeling of the product.  These changes



would be intended to reduce the risks to levels that when considered



against the benefits will not pose unreasonable adverse effects



on the environment.




     A notice initiating a Special Review is not a notice of



intent to cancel the registration of a pesticide, and a



Special Review may or may not lead to cancellation.  This notice



initiating the Special Review for captafol products is an



announcement of EPA's concern about the safety of the

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pesticide's use, and only after carefully considering the



risks and benefits of the pesticide and determining that the




pesticide appears to cause unreasonable adverse effects on



the environment, would EPA issue a notice of intent to cancel.




                       B.  PRESUMPTION



     EPA has determined that the use of pesticide products



containing captafol meets or exceeds the risk criteria for



oncogenicity and hazard to wildlife.  In Un'its I.B.I and 2,



the Agency's concerns over captafol1s oncogenic and wildlife



effects are discussed.



                       1.  ONCOGENICITY



     EPA has determined that captafol meets or exceeds the



risk criterion  in 40 CFR 162.11(a)(3)(ii)(A).  That section



provides that a Special Review shall be conducted if the use



of a pesticide  "induces oncogenic effects in experimental



mammalian species or in man as a result of  oral, inhalation



or dermal exposure...." On the basis of the scientific studies



and information summarized in the Guidance  Document and briefly



discussed below, EPA has concluded that captafol meets or exceeds



this risk criterion.



     A 2-year mouse study showed dose-related oncogenic



lesions in the middle and high dose groups  and dose-related



non-oncogenic lesions in all dose groups.  Oncogenic lesions



included lymphosarcomas, myeloproliferative disease, harderian



gland hyperplasia, benign harderian gland adenomas, and



hemangiosarcomas.



     A 2-year rat feeding study showed a dose-related




increased incidence of fibroadenomas of the mammary gland  and

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an increased incidence of neoplastic nodules in the liver of




females.




     Using the linearized multi-stage quantitative risk




extrapolation model, the Agency calculated a preliminary risk




assessment.  Dietary and non-dietary risks based on the




incidence of neoplastic liver lesions in female rats and




lymphosarcomas in mice were estimated.  The Q* for neoplastic




liver lesions in female rats is 5 x 10~2.  The Q* for lympho-




sarcomas in mice depends upon the sex and number of dose




groups used but ranges from 5 x 10~^ to 5 x 10~2 .




The Agency is using 10~2 as the slope in the preliminary




risk calculations.  The dietary estimate assumes a uniform




distribution of treated crops among the U.S. population and




an average daily consumption of those crops by individuals.




Although an individual's exposure could vary considerably




depending upon eating habits and geographic location, the




dietary exposure values are considered representative for the




total U.S. population over a lifetime.  Because of the lack




of residue data, the dietary exposure estimate was based on




the assumption that residues are at 100 percent tolerance




levels.  Tolerances are the maximum residue levels permitted




on crops by EPA.  This estimate resulted in an upper bound




estimate on the excess lifetime cancer risk of 2 x 10~4




from dietary exposure.  In the Guidance Document, the Agency




estimated non-dietary risk to mixer/loaders and applicators.




Because of the lack of data at the time, the Agency assumed




100 percent dermal penetration and used surrogate data from




many pesticides to estimate worker exposure.  The preliminary

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risk estimates resulted in a risk ranging from 3 x 10~2 to 2



x 10~6.  Based on these risk estimates, the Agency announced in




the Guidance Document that protective clothing, restricted



use classification and a label warning concerning tumors



would be imposed to reduce the risk to workers.  Following



publication of the Guidance Document, the Agency reviewed



recently submitted dermal penetration and worker exposure



studies, which the Agency evaluated and considered in recal-



culating worker risk.  The dermal penetration study was



conducted by applying technical captafol and a formulated



product to the skin of male rats.  The results indicated that



very little was absorbed.  The absorption rate was approximately



0.1 percent per hour.



     Data from the worker exposure study were not used by the



Agency in its exposure calculations because the sample size



in that study was too small to produce reliable results.  The



Agency is confident that its surrogate data, which are based



on many studies involving a large sampling of individuals, is



a reliable basis upon which to estimate worker exposure to



captafol.  It is worth noting, however, that the exposure



values from the study were generally consistent with the



Agency's estimates based on its surrogate data.



     The Agency recalculated the risk assessment using the



dermal absorption rates shown in the dermal penetration



study rather than assuming 100 percent.  However, the same



exposure estimates based on surrogate data and the same




assumptions used in the Guidance document were again used for




the new calculations.  The results of these calculations

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showed an upper limit of excess lifetime cancer risk for




workers ranging from 1 x 10~5 to 1 x 10~7 .   The risk calculated




for the most, common application methods ranged from 1 x 10~5




to 8 x 10~6.



     The requirement for protective clothing reduces this




risk to workers by almost another order of  magnitude.




Specifically, the Guidance Document required workers to wear




impervious gloves and full body clothing during handling and




application.  The Agency is revising this requirement to




replace "impervious gloves" with "mid-forearm to elbow length




chemical resistant gloves." The Agency is also requiring




registrants to submit data concerning the type of glove which




provides the most protection from captafol.   Because inhalation




is still an important route of exposure for mixer/loaders,




the Agency is requiring that workers who mix and load captafol




wear a dust mask.




     In the Guidance Document the Agency also classified




captafol for "restricted use," which means  that only certified




applicators trained for and familiar with pesticide use, or




persons under their direct supervision, may use captafol.




This action was based on the higher cancer  risks previously




estimated in the Guidance Document.  However, the Agency is




lifting this restriction because the new risk estimates show




that hazards to workers applying this pesticide are much




less than originally estimated.

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     The Agency also required registrants to place a statement



on the label of captafol products to warn workers that captafol



causes tumors in laboratory animals.  Based on revised risk



estimates, the Agency believes that risks which may occur during



the period of Special Review do not warrant this label warning.



During the Special Review the Agency will evaluate whether the



long-term risk to applicators justifies the need for any label



warning.




                         2.  WILDLIFE



     The Agency has determined that the use of pesticide



products containing captafol meets or exceeds the risk criteria



in 40 CFR 162.11(a)(3)(i)(B)(_3) and 162.11(a)(3)(ii)(C).  The



first criterion provides that a Special Review shall be



conducted if the use of a pesticide "results in a maximum



calculated concentration following direct application to a



6-inch layer of water more than one-half  the acute LC5Q for



aquatic organisms likely to be exposed...."  The second



criterion requires a Special Review if the use of a pesticide



"can reasonably be anticipated to result  in significant local,



regional, or national population reductions in non-target



organisms, or fatality to members of endangered species."



On the basis of the scientific studies and information summarized



in the Guidance Document,  EPA has concluded that captafol



meets or exceeds these risk criteria.



     The Agency reviewed several valid ecological effects



studies which characterize captafol as very highly toxic to



fish.  Using captafol, the median lethal concentration which

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kills 50 percent of the test organisms  (LC$Q) after 96 hours



ranged from.0.045 to 0.230 parts per million  (ppm) for bluegill



sunfish and 0.027 to 0.190 ppm for rainbow trout.  These data



demonstrate that captafol is very highly toxic to fish.



     As a result of this toxicity, the Agency is concerned



about the effect of captafol on fish as a result of drift



and/or runoff during application to cranberries and citrus



groves.  The Agency is also evaluating potential hazards



of captafol to endangered species.



     Captafol used in cranberry bogs irrigated by sprinkler



systems or by flooding may present a hazard to fish.  Biological



monitoring studies in New Jersey detected fish kills after



the application of captafol.



     Citrus grove applications may present a hazard based on



current use practices.  In groves where captafol treated trees



are irrigated with overhead systems, runoff may result from



dislodgement of residues from foliage.  This is of particular



concern where groves are located near open water.  Captafol



may also enter open water as a result of drift from applications



by way of airblast equipment.




     The Agency used a spray drift model to calculate the potential



amount of captafol to which fish may be exposed from airblast



application to citrus.  The expected residues and effects on



fish in a 1-acre pond and an estuary representing one-half



acre foot of water were estimated.  The expected residues in



both the pond and estuary exceeded the LC5Q for fish.



     A runoff model  using a 6-foot deep 1-acre pond was



used to estimate the expected residues of captafol in water

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from overhead irrigation in captafol-treated citrus groves.



Again for both the pond and estuary, the LC^Q values for fish



were exceeded.




      C.  RISK REDUCTION MEASURES AND REGULATORY STATUS



     Because of the Agency's concerns, the Guidance Document



required registrants to change product labeling.  These changes



include:




       1.  Additional environmental labeling.



       2.  An interim 24 hour reentry interval.



       3.  A prohibition against crops treated with captafol



being rotated with crops not registered for captafol use.



       4.  A prohibition against water from cranberry bogs,



wetland taro fields which are foliarly treated, and rice



fields planted with captafol-treated rice seed being used for



irrigation of crops other than those with registered captatol



uses.



       5.  Specific greenhouse application procedures.



       6.  "Restricted Use" classification.



       7.  A tumor warning statement.



       8.  Protective clothing requirement.



     As discussed in Unit I.B.I, the requirements for "restricted



use" classification and the tumor warning are being lifted.



     The protective clothing requirement is being modified



to require all workers to wear mid-forearm to elbow length



chemical resistant gloves and full body clothing.  Mixer/loaders



are being required to wear dust masks.  Registrants are also

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required to conduct studies to determine what type of gloves



provide the most protection from captafol.



     The Guidance Document requires registrants to submit



studies which will be used to refine the Agency's risk



analysis for oncogenicity-  Included are toxicology and



residue chemistry data.  EPA is requiring that these studies



be conducted on an expedited schedule of 6 months to 1 year,



depending on the test, and will include the results in the



PD 2/3.  Studies needed to refine the analysis for acute and



chronic fish effects are also being expedited.  For acute



effects, EPA is requiring that these studies be conducted



within 1 year.   Depending on the outcome of these studies



EPA will conclude whether acute effects on fish are of



concern; if they are, the Agency will require extensive field



testing.  For chronic effects, EPA is requiring data related



to the environmental fate of captafol.   Depending on the



outcome of the  short-term studies, EPA will determine whether



additional data are needed to assess the chronic risk to



fish.  The following Table 1 describes the pivotal studies



needed for both oncogenic and wildlife concerns.

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         TABLE 1—DATA PIVOTAL TO THE SPECIAL REVIEW
Data Requirements
Submission Date
Studies Pivotal to Oncogenicity

Residue Chemistry

Oncogenicity Study£/

Studies Pivotal to Acute Fish Concerns

Acute Toxicity, Estuarine,
  and Marine Organisms

Aquatic Residue Monitoring/
  Caged Fish Study

Field Testing

Studies Pivotal to Chronic Fish Concerns

Solubility

Vapor Pressure

Octanol/Water Partition Coefficient

Hydrolysis

Photodegradation

Leaching

Adsorption/Desorption

Aerobic and Anaerobic Soil
  Metabolism

Soil Dissipation

Chronic Fish Studies
September 1985

September 1985



March 1985


September 1985


Reserved^/



March 1985

March 1985

March 1985

March 1985

March 1985

March 1985

March 1985

September 1986


September 1986

Reserved^/
I/ The original study was incomplete.  Information concerning
~~  control groups and histopathology are needed.

2/ Contingent on the results of the Aquatic Residue Monitoring/
~~  Caged Fish Study

3/ contingent on the results of the product chemistry and
~~  environmental fate studies.

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                             -16-



     All currently registered products will remain registered




while the Special Review is in progress.  The Agency is




deferring final decisions on the reregistration of any




products containing captafol as a sole active ingredient until




the Agency concludes the Special Review.  The Agency




will not register any new uses of captafol until the Special




Review is completed.  The Agency will also not approve pending




tolerance requests or future requests for new tolerances for




captafol during the Special Review.




                    D.  REBUTTAL CRITERIA




     All registrants, applicants for registration, and other




interested members of the public are invited to submit evidence




either to support or to rebut the presumption that (1) captafol




causes oncogenic effects in rats and mice and may cause such effects




in humans and/or that (2) captafol is very highly toxic to




fish and may result in significant acute and chronic




environmental adverse effects.  Under 40 CFR 162.11(a)(4) (iii) ,




the presumption initiating a Special Review for chronic




oncogenic effects may be rebutted by proving "that the




determination by the Agency that the pesticide meets or




exceeds any of the criteria for risk was in error."




Under 40 CFR 162 .11(a)(4)(i) , the presumption initiating a




Special Review for acute wildlife effects may be rebutted by




proving that "the formulation, packaging, method of use, and




proposed restrictions on and directions for use and widespread




and commonly recognized practices of use, the anticipated




exposure to an applicator or user and to local, regional or




national populations of nontarget organisms is not likely to

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result in any significant acute adverse effects."  Under




40 CFR 162.11(a)(4)(ii) , the presumption initiating a Special



Review for chronic wildlife effects may be rebutted by



proving that "with proposed restrictions on use and widespread



and commonly recognized practices of use, the pesticide will



not concentrate, persist or accrue to levels in man or the



environment likely to result in any significant chronic adverse



effects."




                   E.  BENEFITS INFORMATION



     The Agency will perform a benefits analysis for captafol



during Special Review.  The following information briefly



summarizes the most recent information on the benefits of captafol



     Chevron Chemical Company is the only producer of the



technical product.  Approximately 4.5 to 5 million pounds are



used per year.



     Captafol is a broad spectrum protectant fungicide used



to control foliar diseases of certain fruits and vegetables.



The major sites of use are apples, cherries, tomatoes, and



citrus; more than half of the usage is for the first three



crops.  Minor use sites include the seed of corn, cotton,



peanuts, rice, and sorghum; potato foliage; sweet corn;



plums; watermelon; and cranberries; and use for wood preservation.



     On apples captafol is used to control scab disease



during the primary infection period, which lasts from the



dormant period to the one-fourth green leaf stage of the




apple tree's development.  Captafol is used as a single



application spray as an alternative to multiple applications



of many of the registered alternative fungicides.  The most

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viable alternative fungicides include dichlone, captan,



metiram, fO;lpet, glyodin, thiram, maneb, triforine, mancozeb,



zineb, diammonium EBDC , and a combination of thiophanate-methyl



or benomyl with another fungicide to which resistance has not



been demonstrated.  Up to five applications of any one of the



alternative fungicides may be required to prevent the primary



stage  infections which are often controlled with only one



application of captafol.



     Captafol is one of the most extensively used fungicides



on sour cherries in the northcentral and eastern parts of the



United States.  It is used for control of leaf spot disease,



brown  rot blossom blight, and fruit brown rot.  It is limited



to use on cherries which are mechanically harvested because



hand picking of cherries treated with captafol may result in



allergic skin reactions.  The most viable alternative fungicides



for use on cherries are dichlone, dodine, and ziram, and benomyl



used in combination with a fungicide against which fungal



resistance has not been demonstrated.  For brown rot blossom



blight and fruit brown rot, additional alternative fungicides



include captan,  sulfur, and triforine.  Glyodine, folpet, and



zineb are available alternative fungicides for control of leaf



spot on cherries.



      Captafol is registered for control of anthracnose,



early blight,  late blight, gray leaf spot, nailhead spot,



Septoria leaf  spot, and fruit rot on tomtatoes.  In California



it is also registered for control of black mold.  Because of



the skin sensitization properties of captafol, it is also

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limited to use on mechanically harvested tomatoes.  These




tomatoes are generally produced for processing rather than



for the fresh market.  Captafol is an extensively used fungicide



on tomatoes.  Twenty-six alternative fungicides are registered



for control of one or more of the tomato diseases for which



captafol is registered.  The major ones include metiram,



anilazine, captan, chlorthalonil, diammonium EBDC, folpet,



maneb, nabam, metalaxyl combined with mancozeb, and zineb.



For early blight, late blight, and anthracnose; metiram,



anilazine, captan, chlorothalonil, diammonium EBDC, and maneb



are the most viable.



     In addition to submitting evidence to rebut the presump-



tions of risk in the Special Review, 40 CFR 162 .11(a)(5)(iii)



provides that a registrant or applicant "may submit evidence



as to whether the economic, social and environmental benefits



of the use of the pesticide subject to the presumption outweigh



the risk of use."  The benefits evidence submitted by registrants,



applicants, and other interested persons will be considered



by the Administrator when determining the appropriate regulatory



action.



     Registrants, applicants, or other interested persons who



desire to submit benefits information should consider submitting



information on the following subjects along with any other



relevant information they desire to submit:



     1.  Biological and economic importance of captafol uses,



including market studies and estimated quantities applied for




those uses.

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     2.  Alternative fungicides discussed in this document or




any other which are available.




     3.  Nonchemical methods for all registered uses and




application techniques, including any associated health




effects and potential for water contamination.




     4.  The change in costs to captafol users  for obtaining




equivalent pest control with available substitute products or




management techniques.




     5.  Assessment of the expected changes in  level of




disease control efficacy, crop  yield, crop quality, crop




injury, and environmental impacts associated with the use of




alternative control measures.




     6.  Increased or reduced risks associated  with the




mixing, loading, applying, and  disposing of alternative




chemicals, and of other hazards associated with their potential




increase in use if captafol is  not available.  Describe type




of application equipment, protective clothing,  and mixing/loading




disposing procedures for the alternative chemicals.




     7.  Cultural practices and other factors that impact on




farmworker exposure to captafol and any alternative cultural




or Integrated Pest Management practices which might limit the




use of captafol.




              II.  ADDITIONAL GROUNDS FOR REVIEW




     In the Guidance Document EPA is requiring, pursuant to




section 3(c)(2)(B) of FIFRA, that additional product chemistry,




toxicology, ecological effects, residue chemistry, and

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                            - 21 -

environmental fate studies of captafol be submitted.  The

Agency will review these studies to determine the extent to

which other adverse effects may be associated with the use of

this chemical.

             III. HAZARDOUS WASTE DISPOSAL

     The Agency is also investigating the wastes generated

from manufacturing captafol and may regulate them as hazardous

under the Resource Conservative and Recovery Act.

             IV.  REBUTTAL SUBMISSION PROCEDURES

     All registrants and applicants for registration are

being notified by certified mail of the initiation of the

Special Review on their products containing captafol.

     The registrants and applicants for registration will

have 45 days after the date this notice is received or until

(insert date 45 days after date of publication in the FEDERAL

REGISTER) (whichever is later) to submit evidence in rebuttal

to the Agency's presumption.  Other interested parties may

submit comments during the same period.

       V.  DUTY TO SUBMIT INFORMATION ON ADVERSE EFFECTS

     Registrants are required by section 6(a)(2) of FIFRA to

submit any additional information regarding unreasonable adverse

effects on man or the environment which comes to their attention

at any time.  Registrants of captafol products must immediately
                                        !
submit any published or unpublished information, studies,

reports, analyses, or reanalyses regarding any captafol effects

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                            - 22 -








in animal species or humans, and claimed or verified accidents




to humans, domestic animals, or wildlife which have not been




previously submitted to EPA.  These data should be submitted




with a cover letter specifically identifying the information




as being submitted under section 6(a)(2) of FIFRA.  Registrants




should notify EPA of any studies on captafol currently in




progress, their purpose, the protocol, the approximate completion




date, a summary of all results observed to date, the name




and address of the laboratory performing the studies, and a




statement as to whether these studies are being conducted in




accordance with the Good Laboratory Practices published in




the FEDERAL REGISTER of November 29, 1983 (48 FR 53946).




                V.  PUBLIC COMMENT OPPORTUNITY




     During the time allowed for submission of rebuttal




evidence, specific comments are solicited on the presumptions




set forth in this Notice and in the Guidance Document.  In




particular, any documented episodes of adverse effects on




humans or domestic animals should be submitted to the Agency.




Any information as to any laboratory studies in progress or




completed should be submitted to the Agency with a statement




as to whether those studies are in compliance with the Good




Laboratory Practices specified in 48 FR 53946.  Specifically,




information on any adverse toxicological effects of captafol,




its impurities, metabolites, and degradation products is




solicited.  Similarly, submission of any studies or comments




on the benefits from the use of captafol is requested.  All

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comments and information and analyses, which come to the

attention of EPA, may serve as a basis for final determination

of regulatory action following the Special Review.

     All comments and information should be sent to the

address given above, preferably in triplicate, to facilitate

the work of EPA and others interested in inspecting them.

The comments and information should bear the identifying

notation [OPP-30000/43] .

     During the comment period, interested members of the

public or registrants may request a meeting to discuss the

risk issues and methods of reducing risks.  Any records

pertaining to such meetings, including minutes, agendas, and

comments received will be filed under docket number OPP-30000/43.

Dated :  /
                              Director,
                              Office of  Pesticide Programs

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