r/EPA
                 United States
                 Environmental Protection
                 Agency
                 Office of
                 Public Affairs (A-107)
                 Washington DC 20460
A-107/86-003
June 1986
Pesticides  Fact Book

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Contents	
Overview of Pesticide Regulation 	1
  Products Regulated-	1
  The Regulated Community  	1
  Statutory Authority for Pesticide
  Regulation1	1
How EPA Regulates New Pesticides 	1
Tolerances 	2
How EPA Regulates Existing Pesticides	2
  Registration Standards	 3
  Data Call-in  	3
  Special Review 	3
State Enforcement Role	4
Product Packaging 	4
Farmworker Safety	5
Ground Water Contamination	5
Data Quality	5
Microbial Pesticides	6
Tables
History of Federal Pesticide Legislation — 6
Summary of Tolerance Provisions: Federal
Food, Drug and Cosmetic Act (FFDCA) — 6
Summary of the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA),
as amended	7
Pesticide Registration Process	7


Appendices
A. Glossary	8
B. Basic Data Requirements for a New Major
Food or Food Crop Pesticide	9
C. Map of EPA Regions	9
D. EPA Pesticide Contacts 	9
E. State Agencies	10

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Overview of

        Kcide

        lation


Products Regulated

Pesticides include
insecticides, herbicides,
fungicides, rodenticides,
fumigants, disinfectants,
plant growth regulators and
other substances intended to
control pests. Approximately
45,000 pesticide products are
currently marketed in the
United States.  The
Environmental Protection
Agency (EPA)  regulates these
products primarily on the
basis of their pesticidal active
ingredients. There are
roughly 1,400  "active
ingredients" in the 45,000
products now  on the market.
By combining  these active
ingredients (such as salts and
esters) EPA has defined about
600 distinct  active  ingredient
groups that must be regulated
separately.
        ximately 1.2 billion
       of pesticides costing
           are sold each
year. About 70 percent of all
pesticides used in this
country are applied in
agricultural production, 7
percent in home and garden
settings, and the remaining
23 percent in forestry,
industry and government
programs.

The Regulated
Community

About 30 major pesticide
producers, another 100
companies that market active
ingredients, 3,300 product
formulators, and 29,000,
distributors are subject to
EPA health and safety
regulations. Pesticide users,
including private citizens, are
also subject to EPA
regulation. It is a violation of
the law for any person to use
a pesticide in a manner
inconsistent with its label. In
order to use  certain
          that EPA has
         for "restricted use,"
           commercial
apprators must complete an
approved training program in
the proper handling of toxic
chemicals.
Statutory Authority for
Pesticide Regulation

EPA's regulation of pesticides
is mandated by Congress.
Through its Office of
Pesticide Programs (OPP),
EPA administers two statutes:

• The Federal Insecticide,
Fungicide and Rodenticide
Act (FIFRA), last amended by
Congress in 1980, which
governs the licensing, or
"registration," of pesticide
products.
• The Federal Food, Drug
and Cosmetic Act (FFDCA)
which, among other things,
governs pesticide residue
levels in food or feed crops.

  FIFRA was originally
enacted in 1947, when it
replaced the Federal
Insecticide Act of 1910, but
Congress has amended FIFRA
several times since then. The
most important FIFRA
amendment was  the Federal
Environmental Pesticide
Control Act (FEPCA) of 1972,
which shifted the emphasis
from safeguarding the
consumer against fraudulent
pesticide products to public
health and environmental
protection. EPA assumed
responsibility for
administering FIFRA when
the Agency was established
in 1970. Before that,
pesticides were regulated by
the U.S. Department of
Agriculture (USDA).
How EPA

Regulates New

Pesticides

EPA is responsible under
FIFRA for registering new
pesticides to ensure that,
when used according to label
directions, they will not
Eresent unreasonable risks to
 uman health or
environment. The law
requires the Agency to take
into account economic,
social, and environmental
costs and benefits in making
decisions.
  Pesticide registration is a
pre-market review and
licensing program for all
pesticides marketed in the
U.S., whether of domestic or
foreign orgin. EPA annually
reviews approximately
15,000 registration
submissions of various  kinds.
Only about 15 brand-new
chemicals (new active
ingredients) are registered
each year. Most registration
decisions are for new
formulations containing
active ingredients which are
already registered with EPA,
or new uses of existing
products.
  The Agency bases
registration decisions for new
pesticides on its evaluation
of test data provided by
applicants. Required studies
include testing to  show
whether a pesticide has the
potential to cause adverse
effects in humans, fish,
wildlife, and endangered
species. Potential  human
risks include acute reactions
such as toxic poisoning and
skin and eye irritation,  as
well as possible long-term
effects like cancer, birth
defects, or reproductive
system disorders.  Data on
"environmental fate," or how
a pesticide behaves in the
environment, are also
required so that EPA can
determine, among other
things, whether a pesticide
poses a threat to ground or
surface water.
  EPA may classify a product
for restricted use if its
toxicity warrants special
handling. Restricted
pesticides may be used only
by or under the supervision
of certified applicators
trained to handle toxic
chemicals, and this
classification must be shown
on labels. During registration
review, the Agency may also
require changes in proposed
labeling and use patterns.
Moreover, if a pesticide is
being considered for use on a
food or feed crop, the
applicant must petition EPA
for a tolerance (see
subsequent section on
Tolerances) and submit
appropriate data so that the
Agency can define a safe and
realistic tolerance level.
  A brand-new active
ingredient may need six to
nine years to move from the
laboratory, through full
completion of EPA
registration requirements, to
retail shelves. This
time-frame includes two or
three years to obtain
registration from EPA. The
registration process  generally
begins with an experimental
use permit (EUP) issued by
EPA to permit pre-market
field testing. Subsequently,
manufacturers typically
submit an application for
federal registration to EPA for
review. This application
must include appropriate
health and safety data, and
EPA may require further
testing to clarify specific
health or environmental
Questions that may arise
during registration review.
  The estimated average cost
for a pesticide producer to
comply with EPA's
registration data requirements
is between $2.4 million and
$4.0 million per major new
active ingredient. This is
about four to seven percent
of typical total development
costs of $50 million to $70
million.

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  Registration of a new
formulation containing an
active ingredient already
registered with EPA requires
far less time and expense.
Such new product
registrations may be
completed within six to nine
months.
  Pending full development
of data  required for the
registration  of products
which contain existing active
ingredients, FIFRA allows
conditional  registration if
EPA finds that the use of the
product will not significantly
increase the level of risk
posed by similar products
already on the market.
Conditional registrations  are
subject to immediate
cancellation if the
outstanding data are  not
submitted by the time
specified. Under special
circumstances prescribed by
FIFRA, the Agency may also
grant conditional
registrations for products
containing active ingredients
not previously registered
with EPA. These special
circumstances include a
rinding by EPA that the
conditional  use of the new
pesticide will  be in the
public interest, that a
reasonable time for
conducting the required
studies has not elapsed, and
that use of the pesticide for
the period of conditional
registration  will not present
an unreasonable risk.
  EPA also evaluates several
types of special registration
submissions mandated by
FIFRA.  Experimental use
permits under section 5
allow large-scale
experimentation in order to
develop data for new
products or  new uses of
existing ones. Through
emergency exemptions under
section  18, EPA may
temporarily  authorize state or
federal agencies to combat
emergencies with pesticide
uses not permitted by
existing federal registrations.
Under section  24(c), "special
local need" registrations by
the states become effective
immediately, but may be
disallowed by  EPA within 90
days.
Tolerances

Under the FFDCA, EPA sets
tolerances, or maximum legal
limits, for pesticide residues
on food commodities
marketed in the U.S.
Tolerances apply to imported
commodities as well as
domestically produced food
and animal feed. The
purpose of the tolerance
program is to ensure that
U.S. consumers are not
exposed to unsafe
food-pesticide residue levels.
  Before a pesticide can be
registered under FIFRA for
use on a food or feed crop,
EPA must either establish a
tolerance or, if appropriate,
grant an exemption from the
tolerance requirement.
Tolerances for raw
agricultural  commodities are
established under section 408
of the FFDCA. Certain
pesticide uses also require
separate tolerances under
section 409vfor processed
commodities, if residues are
expected to  concentrate
during food  processing.
  The Agency establishes a
tolerance only if residue
chemistry and toxicological
data indicate no
unreasonable risk to lifelong
consumers. Tolerances are set
at levels no higher than
necessary to permit
marketing of treated
commodities. The Food and
Drug Administration and the
U.S. Department of
Agriculture are  responsible
for enforcing tolerances for
food and feed commodities
in commerce. Any
commodities with residues in
excess of tolerance levels are
subject to seizure.
  Residue chemistry and
toxicology are far more
advanced now than 30 years
ago, but until recently the
basic scientific  assumptions
behind our regulations had
not been re-examined. In the
last few years, EPA has
consulted with  numerous
outside experts in an effort to
upgrade its traditional
tolerance system. A number
of changes have been
initiated, including
refinement of dietary
consumption estimates, a
new scheme that allows for
more extensive  use of group
tolerances for related crops,
and a data call-in program to
bring the data-base up to
contemporary standards.
  Individual tolerances for
existing pesticides are being
reassessed as part of the
reregistration process. (See
subsequent section on
Existing Pesticides.) EPA is
also revoking tolerances for
cancelled pesticides.
Following tolerance
revocation EPA can
recommend "action levels,"
where appropriate, for
enforcement by FDA and
USDA. EPA typically
recommends  an action level
if, following cancellation,
unavoidable low-level
residues are expected to
occur in food commodities as
a result of environmental
persistence of the cancelled
product.
How EPA
Regulates
Existing
Pesticides
In addition to regulating new
pesticides, EPA is charged
with protecting human health
and environment from any
unreasonable adverse effects
associated with pesticides
already registered and in use.
To ensure that previously
registered pesticides meet
current scientific and
regulatory standards, FIFRA
requires the "reregistration"
of all existing pesticides.
This is a massive
undertaking. The "old
chemicals" problem has
drawn  criticism because EPA
has not been able to review
and reregister existing
pesticides as quickly as
Congress originally
envisioned.  However, EPA
has underway an aggressive
reregistration effort through
its "Registration Standf
and "Data Call-In" pr
Also, whenever data ot
registered pesticide indicate
that it may be presenting
unreasonable risks, EPA
initiates a public "Special
Review" to determine
whether regulatory action is
warranted.

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Registration Standards

For reregistration. a pesticide
initially registered prior to
      Jit regulatory
      ements must meet the
      'no unreasonable
      ie effects" criteria that
apply to new pesticides.
Through its Registration
Standards program, EPA is
reexamining, by current
scientific standards, the
health and environmental
safety of the approximately
600 active ingredients
contained in some 45,000
currently registered products.
On the basis of these reviews,
the Agency establishes the
various conditions registrants
must meet in order to
reregister pesticide products
containing these active
ingredients.
  These conditions are
spelled out in a document
known as a Registration
Standard. Such conditions
typically include
requirements for submission
of needed scientific data;
compliance with product
composition, labeling and
    aging requirements; and
    "^jgation to compensate
      egistrants for use of
applfcable safety data.
Certain changes in
application methods and
label directions may also be
required, and some uses may
be restricted to certified
applicators as a condition of
reregistration.
  Depending on how the
existing data measure up to
current registration
requirements, the
manufacturer of a major
active ingredient may incur
costs approaching first-time
registration costs (ranging
from $2.4 million to $4.0
million) to comply with EPA
data requirements for
registration. If existing data
largely satisfy registration
requirements, the costs of
complying with a
Registration Standard will be
considerably less.
  Once a Registration
Standard is developed for a
given active ingredient, new
pesticide products will also
be registered according to the
terms and conditions of the
Standard. The Standards
approach eliminates the need
for complete data review  for
individual products and
improves the efficiency and
consistency  of registration
decisions.
  EPA is proceeding with
Registration Standard reviews
on the basis of clusters of
similar-use pesticides, such
as termiticides, grain
fumigants, and fungicides.
High-volume and food-use
pesticides are being assessed
first. At the  currently
planned rate, Registration
Standards will be developed
for all active ingredients by
the late 1990s. At the end of
fiscal year 1985 EPA had
issued 117 Registration  ,
Standards. The table below
shows the Agency's progress
in completing Registration
Standards during the last six
fiscal years.
FY-80                  6
FY-81                 18
FY-82                 18
FY-83                 23
FY-84                 25
FY-85                 27
FY-86 (projected)       25
Data Call-In

One of the key questions in
doing a Registration Standard
is whether a chemical has an
appropriate data-base by
today's criteria. In many
cases the answer is "no."
This is not to impugn
pesticide registrants. The fact
is that data requirements
have been tightened over
time and many products
were registered in earlier
years when fewer
requirements were in place.
EPA has discovered, not
surprisingly, that the early
Registration Standards have
resulted in many
requirements for additional
data. In order to obtain
important data before the
Agency completes or even
begins a Registration
Standard on a chemical, EPA
initiated a  Data Call-In
program in 1981. Letters are
sent to registrants  identifying
long-term chronic testing
needs (cancer, chronic
feeding, reproduction,  and
teratogenicity testing) and
requiring the initiation, of
such studies. At the end of
fiscal year  1985, EPA
completed "calling in"
chronic toxicity data for all
pesticides applied to food
crops.
  In addition to its regular
data call-in program, EPA has
initiated several "special"
data call-ins.  One was  a
groundwater data call-in,
completed  in fiscal year
1984, concerning 141 existing
pesticides known to
contaminate or suspected of
contaminating aquifers.
Special Review

If a registered pesticide
shows evidence of posing a
potential safety problem, the
Agency can conduct a
Special  Review of risks and
benefits in which all
interested parties
(environmentalists,
manufacturers,  users,
scientists, and the general
public) can participate. A
notice initiating a Special
Review is not a notice  of
intent to cancel the
registration of a pesticide; a
Special Review may or may
not lead to cancellation.
  Depending on EPA's
findings during the Special
Review process, the Agency
may implement various
regulatory options available
under FIFRA. Often, rather
than initiating cancellation or
suspension proceedings to
reduce risks associated with
pesticide use, EPA exercises
less drastic options such as
restricting pesticide use to
certified applicators,
requiring protective clothing,
and prohibiting certain
application methods or use
in certain areas. EPA may
also decide simply to
continue the pesticide's
registrations if risk-reduction
measures are found
unnecessary.
  If the pesticide is found to
cause unreasonable adverse
effects on human health or
the environment, EPA  may
issue a notice of intent to
cancel registration. The
registrants and  others who
would be adversely affected
are given  30 days to request a
hearing. If there is no such
appeal, all pertinent
registrations are
automatically cancelled. If a
hearing is requested,
cancellation proceedings may
take two years or more, and
during that interval
marketing may  continue.
  However, if the EPA
Administrator finds that
continued registration of the

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 pesticide for a given use
 presents an imminent hazard
 to human health, he may
 suspend it. Such action
 requires evidence that the
 risks of continued use
 outweigh benefits during the
 two or more years necessary
 to complete a cancellation
 hearing.
  There are two kinds of
 suspensions under FIFRA.
 Under an ordinary
 suspension, a registrant has a
 right to request a hearing
 before the suspension goes
 into effect. Unlike the
 cancellation hearing process,
 which can consume several
 years, an ordinary suspension
 hearing may take about six  .
 months. But an emergency
 suspension order is handed
 down if EPA determines that
 the risks of continued use
 outweigh benefits during the
 six months it would take to
 hold an ordinary suspension
 hearing. An emergency
 suspension order is
 immediate and absolute; it is
 the most drastic step EPA
 can take under FIFRA.
  EPA began conducting
 Special Reviews, originally
 known as RPARs (Rebuttable
 Presumptions Against
 Registration), in 1975. Most
 of the approximately 70
 chemicals initially identified
 as needing special review
 have been reviewed since
 then, resulting in removal of
 some from the market or
 changes in the way they are
 used, in order to reduce risks
 to exposed populations.
 Other suspect chemicals have
 been identified through the
 Registration Standards
 Program described above and
 placed in the Special Review
 process. Since the program
 began in 1975, the time
 required from start to
 conclusion of a Special
 Review has generally been
 from two to  six years.
 However, EPA has recently
 issued  new Special Review
procedures designed to
expedite decision-making.
State

Enforcement

Role

Since the 1972 amendments,
FIFRA has included
provisions for monitoring the
distribution and use of
pesticides, and issuing civil
as well as criminal penalties
for violations. For example, it
is unlawful under FIFRA to
use a registered pesticide
product in a manner
inconsistent with its label, to
alter the approved label or to
distribute in commerce any
adulterated or misbranded
product. The 1972
amendments  also authorized
"cooperative  enforcement
agreements" between EPA
and the states, and a
certification and training
program for applicators that
qualifies them to use
chemicals classified for
restricted use.
  In the 1978 amendments
the states were given primary
enforcement responsibility
for pesticide  use violations,
subject to oversight by EPA.
Through cooperative
enforcement agreements  all
states but two, Nebraska and
Wyoming, have now assumed
primary enforcement
responsibility. EPA sets
FIFRA enforcement policy
and conducts compliance
monitoring and enforcement
programs in  these two states.
Pesticide applicator and
certification  programs are
also conducted by the states,
except in Colorado (where
the state has a program only
for commercial applicators)
and Nebraska, where EPA
performs this role
  Cases of pesticide misuse
or accidents  should be
reported to the state agency
with lead responsibility for
pesticides, generally the  state
department of agriculture. A
list of these agencies is
provided in Appendix E.
Such cases may also be
reported to an EPA regional
office. See Appendix C for a
map of the 10 EPA regions
and Appendix D for a list of
EPA headquarters and
regional pesticide contacts.
 Product

 Packaging

 Pesticides are toxic chemicals
 that must be stored and
 handled with care. For this
 reason, EPA has set
 requirements to help prevent
 incidents of pesticide
 poisoning in residential as
 well as agricultural settings.
 In 1979, EPA published
 regulations aimed at reducing
 potentially hazardous
 exposure to pesticides, such
 as common insect and weed
 killers and rat poisons
 routinely used in and around
 the home. These regulations
 require that, if pesticides
 registered for residential use
 meet certain criteria, they
 must be marketed in
 packages with special
 closures or other safety
 features commonly known as
 child-resistant packaging.
 These standards have a dual
 purpose: to prevent children
 from gaining access to the
 contents and to increase
 adult awareness that the
 contents may be hazardous.
 These requirements are
 similar to child-resistant
 packaging requirements first
 introduced by the Consumer
 Product Safety Commission
 in 1972,
  In agriculture, EPA-
 approved labels restrict the
 use of certain pesticides  to
 trained, certified applicators.
 In the past, EPA has
 classified pesticides for
 restricted use mainly because
 of acute toxic risks to
 applicators. However, the
 Agency has begun using the
 restricted use classification
 more broadly, and pesticides
 may be  restricted for other
reasons such as long-term
health risks or potential
ground-water contamination.
  The Agency is convinced
that the use of "closed
systems" for transferring
pesticides from containers to
mixing tanks or application
machinery will further
reduce the likelihood oil
accidental poisoning. EF
has published  voluntary
standards, initially proposed
by the pesticide industry, to
encourage the  development
and widespread use of closed
systems. The Agency is
encouraging advanced
technology in closed systems,
as well as more widespread
use of the limited technology
now available. EPA is
monitoring the results to
determine whether a
mandatory approach is
necessary.
\)

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Farmworker
   ifety
    «'
     is making a concerted
    •t to safeguard
farmworkers' health through
its regulatory, educational,
and research programs.
Regulations in effect since
1974 have provided basic
protection for those engaged
in field and hand-labor tasks.
They prohibit direct spraying
of workers and require
protective clothing,
post-application field re-entry
intervals, and toxic-effect
warnings.
  EPA is upgrading and
expanding the 1974
regulations through a
"negotiated rulemaking"
process in cooperation with a
committee of 25 federal,
state, farmworker, grower,
and industry representatives.
This committee is addressing
a spectrum of farmworker
issues ranging from
specialized protective
equipment for pesticide
   ers, loaders, and
    licators,  to enforcement  of
     ations via federal
   el ing and state programs.
EPA expects the proposed
regulations to be ready for
publication in the late spring
or early summer of 1986.
  EPA has prepared two
versions of  a slide and tape
program, one in English and
one in Spanish, for
presentation to farmworkers
and laborers who work with
pesticides. Many states are
now using these teaching
aids. EPA works with other
federal agencies, through
programs such as migrant
clinics, to provide
information on pesticide
hazards and safe-use
practices.
  EPA is also studying field
exposures, health effects, and
the benefits  of protective
clothing to  agricultural
workers.
Ground  Water

Contamination

Depending on their
properties and patterns of
use, pesticides may leach
through the soil and
contaminate ground water;
especially where the water
table is close to the surface
and soils are highly
permeable. EPA is
developing a comprehensive
approach to pesticides in
ground water focused on
existing problems and
prevention of future
contamination as well—all in
the context of a general
Ground-Water Protection
Strategy.
  For pesticides not yet on
the market, EPA is using
sophisticated environmental
chemistry and mathematical
models to predict whether a
new pesticide has the
potential to reach ground
water. All prospective
registrants of pesticides
intended for use outdoors
must submit a range of test
data so EPA staff scientists
can assess the fate of a  new
pesticide when used as
proposed.
  For example, the most
important properties
determining whether a
pesticide represents a threat
to ground water are its
persistence and mobility. In
addition, EPA considers the
site itself, since local water
and soil conditions are
important variables in ground
water contamination. The
Agency has recently
published final guidelines
providing registrants with
detailed technical guidance
for developing
environmental-fate data.
  Existing ground water
problems are generally
caused by pesticides that
entered the marketplace
before the current scientific
and regulatory standards
were put in place. To detect
and correct these conditions,
EPA is engaged in monitoring
ground water in cooperation
with the U.S. Geological
Survey and various state
agencies. EPA is also
planning a nationwide survey
of public and private water
supplies. The results of these
studies will be published in
annual reports and scientific
journals.
  EPA is also taking action to
bring all previously
registered pesticides up to
current ground-water safety
standards. On a priority
basis, registrants of existing
pesticides are required to
submit studies to meet the
same rigorous requirements
that apply to new pesticides.
The Agency has recently
required updated information
on 141 existing pesticides
identified as having some
potential to contaminate
ground water. In some
instances, EPA may also
require the registrant to
conduct monitoring as a
condition of continued
registration.
  Where ground-water
contamination is identified,
EPA may take regulatory
action ranging from selective
restrictions to outright bans
against the manufacture and
use of a pesticide. Where
regional restrictions are
needed, EPA is working
together with state agencies
to develop appropriate
product labeling. The Agency
has also begun to issue
Health Advisories to state
and local health officials
regarding levels of pesticides
in drinking water that may
pose significant risks.
Data Quality

Beginning in 1976, a series of
audits by the FDA and EPA
revealed serious deficiencies
in tests conducted by
Industrial Bio-Test
Laboratories (IBT) to support
the registrations, in both the
United States and Canada, of
numerous pesticides and
some drugs. The IBT case
raised concerns about the
integrity of data submissions
to EPA. Since then, EPA has
taken steps not only to
address the IBT case
specifically, but generally to
assure the quality of data
submitted to support
pesticide registrations.
  The Agency has issued
data requirements and new
guidelines for conducting
studies required for pesticide
registration, and has
promulgated Good Laboratory
Practices (GLP) regulations
under both FIFRA and the
Toxic Substances Control Act
(TSCA). A reorganized
laboratory inspection and
data-audit program supports
EPA's concern for data
quality.
  In December 1983, the
Office of Pesticides and
Toxic Substances (OPTS)
established a single
management unit in the
Office of Compliance
Monitoring for the data audit
and laboratory inspection
programs under FIFRA and
TSCA. Through these
programs, audits are
conducted to verify that final
reports accurately reflect
existing records, and
laboratory inspections are
conducted to check that
laboratories conducting
studies on pesticides and
toxic substances routinely
follow proper scientific
procedures. A computerized
system tracks study quality
from beginning to end. EPA's
inspection and audit
programs are coordinated
with FDA and the National
Toxicology Program through
interagency agreements.

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  In 1986, the OPTS plans to
develop both Data Audit and
GLP Inspection manuals for
use by EPA inspectors and
scientific staff. The Agency is
also developing a
comprehensive set of
Standard Evaluation
Procedures governing how
studies submitted by
registrants are evaluated by
EPA staff scientists. These
procedures, covering studies
in ecological effects,
exposure assessment, residue
chemistry, and toxicology,
will  ensure consistent
treatment of major scientific
topics in EPA's science
reviews and permit greater
public understanding of our
internal review process.
  The IBT problem has been
largely resolved; invalid
studies either have been or
are being replaced. At the
end of 1985, the status of 724
IBT studies on long-term
health effects such as cancer
or reproductive disorders was
as follows:

• 461 do not require
replacement for one of
several  reasons: the study is
valid, non-IBT data are
available, the pesticide is
cancelled or not  registered,  or
the type of study is not
required for registration.
• 107 studies have been
replaced; the new studies
have been reviewed by EPA
scientists and found
acceptable.

• 72 studies have been
replaced and are under
review by EPA scientists.
• By the end of fiscal year
1988, the remaining 84 studies
will have been replaced,
according to an established
schedule.
Microbial

Pesticides

Naturally occurring
microorganisms were first
registered as pesticides in the
late 1940s. Today there are
14 naturally occurring
microbial agents, such as
bacteria, fungi, viruses and
protozoa, registered in about
100 products used in
agriculture, forestry,
mosquito control, and home
and garden applications.
These products are known to
be pest-specific and of low
toxicity to man.
  Biotechnology has
advanced to the point where
genetically altered
micoorganisms have been
developed for use as
pesticides. In October 1984,
EPA published an  Interim
Policy on Small-Scale Field
Testing of Certain Microbial
Pesticides, requiring
developers of biotechnologi-
cal  products intended as
pesticides to notify the
Agency before initiating
small-scale field tests. They
must also submit adequate
information for EPA to assess
whether an Experimental Use
Permit (EUP) will be required
before testing. If an EUP is
required, additional scientific
data must be submitted to
support the safety of the
proposed study, and testing
may be  carried out only
under conditions approved
by the Agency.
  EPA imposes these
requirements to help ensure
that the experimental release
of genetically altered or other
exogenous  microbes  will  not
result in unforeseen risks to
the environment. The Office
of Science and Technology
Policy, an arm of the
Executive Office of the
President, has published a
comprehensive proposed
framework for all federal
agencies regulating
biotechnological products,
including EPA. Its  purpose is
to ensure safety without
stifling innovation in a
discipline with enormous
potential benefits.
History of Federal Pesticide Legislation

1910 - Federal Insecticide Act protects consumers agaj
      fraudulent goods.
1947 - Federal Insecticide, Fungicide and Rodenticide^
      (FIFRA) requires federal registration of .pesticides
      prior to marketing in interstate commerce.
1954 - Miller amendment to Federal Food, Drug, and
      Cosmetic Act requires establishment of 'tolerances'
      for residues of pesticides on food, feed, and fiber
      crops.
1959 - Amendments broaden scope of products  covered by
      FIFRA.
1964 - Amendments tighten provisions regulating
      marketing of pesticides.
1972 - Federal Environmental Pesticide Control Act
      (FEPCA) shifts emphasis from consumer  to public
      health and environmental protection.

1975 - Amendments require review by USDA of major
      pesticide decisions and regulations, and
      establish a Scientific Advisory Panel (SAP) for
      review of major pesticide decisions and
      regulations.
1978 - Amendments authorize a generic system  of
      pesticide registration, based on active
      ingredients common to numerous pesticide
      products, and introduce "conditional"
      registration. Other 1978 provisions include
      more flexible procedures for "restricted use"
      classification outside the registration process,
      delegation of primary use enforcement to the
      states, and public access to basic health and
      safety data underlying pesticide registrations
      so long as "trade secret" information is
      protected.
1980 - Wampler amendment requires peer review of
      major scientific studies funded by EPA and
      used in making regulatory decisions.


Summary Of Tolerance Provisions:
Federal Food, Drug And Cosmetic Act (FFDCA)

Section 406   Authorizes "action levels" (maximum safe
              residue levels) for inadvertent residues of
              pesticides in food or feed commodities.
Section 408   Requires tolerances (maximum legal residue
              levels) for residues in raw agricultural
              commodities. EPA sets tolerances, to be
              enforced by FDA and USDA, at maximum
              safe residue levels expected when approved
              pesticide label directions are followed.
Section 409   Requires tolerances for food additives. A
              "food additive" tolerance is required for a
              pesticide when processing of raw
              agricultural commodities concentrates
              residues in excess of Section 408 tolerances.
              Under the "Delaney Clause," a section 409
              food additive tolerance cannot be
              established for any substance shown to
              induce cancer when  ingested by animj
              human beings.

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Summary Of The Federal Insecticide, Fungicide And Rodenticide Act (FIFRA), As Amended
Section 2 -

Sect^A

 §3(c^f
             Definitions

             Basic Registration Requirements

             A pesticide can be registered if, when used
             in accordance with widespread and
             commonly recognized practice, it will not
             cause unreasonable adverse effects on the
             environment.
  §3(c)(l)(D)  Payment of compensation to original  data
             submitters by subsequent registrants.
  §3(c)(2)     Publication of guidelines specifying data
             required for registration.
  §3(c)(2)(B)  Additional  data to support existing
             registrations.
  §3(c)(7)     Registration under special circumstances
             (i.e., conditional registration).
  §3(d)(l)     Classification of pesticides for restricted use
             (i.e., for application only by trained,
             certified applicators or those under their
             direct supervision).
Section 4 -    Use of restricted pesticides by certified
             applicators.

Section 5 -    Premarket testing of pesticides under
             experimental use permits.

Section 6 -    Procedures for removal of pesticide uses via
               A. suspension (immediate halt of use
             while cancellation hearing is conducted)
             and
               B. cancellation (permanent ban).
                                                          Sections       Registration of pesticide-producing
                                                          7, 8, 9 -       establishments, maintenance of records and
                                                                         right of inspection.

                                                          Section 10 -   Trade secret protection for certain data
                                                                         submitted.

                                                          Section 12 -   Unlawful acts (civil and criminal)

                                                             §12(a)(2)(g)  "it shall be unlawful to use any registered
                                                                         pesticide  in a manner inconsistent with its
                                                                         labeling."
                                                          Section 15 -   Compensation for economic losses due to
                                                                         EPA regulations.

                                                          Section 16 -   Judicial review of cancellation decisions.

                                                          Section 17 -   Notification of foreign governments of
                                                                         suspension  and cancellation actions and the
                                                                         export of  pesticides not registered in the
                                                                         U.S.

                                                          Section 18 -   EPA Administrator may temporarily exempt
                                                                         a Federal  or State agency from provisions of
                                                                         FIFRA if warranted  by emergency
                                                                         conditions.

                                                          Section 19 -   Procedures for the transportation  and
                                                                         disposal of pesticides.

                                                          Sections       State authority in registering pesticides and
                                                          24. 26,,27 -   enforcing regulations.
'esticide Registration  Process
  EPA Data Requirements
  and
  Test Protocols
                                 Pesticide Producer Develops
                                 Data Through Lab And Field
                                 Testing
            Pesticide Producer Submits
            Application to Register
            Pesticide with Data:
            • Product Chemistry
            • Environmental Fate
            • Toxicology
            • Fish And Wildlife
                                           Pesticide Producer Submits
                                           Tolerance Petition for Food
                                           Use Pesticide with Data:
                                           • Residue Chemistry
                                           • Special Toxicology
                           \          /
                      EPA Enters Application or
                      Petition into Tracking System
                      •nd Checks Completeness
                      • Forms  • Label  • Data

                      EPA Sends Data to Its
                      Scientists for Review
                       Producer Responds
                                                                I
• Are Data Valid?
• What Effects Do They Show?
• What is the Significance of
These Effects for Man and
Environment?


If Acceptable, EPA
• Establishes Tolerances
                                                       If Unacceptable. Pesticide
                                                       Producer Must:
                                                       • Modify Label and/or
                                                       • Modify Uses and/or
                                                       • Replace Data and/or
                                                       • Submit More Data
                                                                                                   Pesticide Producer Sells
                                                                                                   Product
                                                                                                   Consumer Uses Per Label
                                                                                                   Directions

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Appendix A
Glossary

Action Levels: Whenever
unavoidable pesticide
residues occur in food or
feed commodities for reasons
other than the direct
application of a pesticide,
EPA can recommend "action
levels" (residue levels
warranting regulatory action)
for enforcement by FDA and
USDA. While tolerances are
established for residues
occurring as a direct result of
proper usage, action levels
are set for inadvertent
residues resulting from
previous legal use or
accidental contamination.

Active Ingredient: In any
pesticide product, the
component which kills, or
otherwise controls, target
pests. Pesticides are regulated
primarily  on the basis of
active ingredients.
Cancellation: The Federal
Insecticide, Fungicide and
Rodenticide Act (FIFRA)
section 6(b) authorizes
cancellation of registration if
unreasonable adverse effects
in the environment and
public health develop when a
product is used according to
widespread and commonly
recognized practice, or if its
labeling or other material
required to be submitted does
not comply with FIFRA
provisions.
Conditional Registration:
Under special circumstances,
FIFRA permits registration
(see definition below) that is
"conditional" upon the
submission of additional
data. These special
circumstances include a
finding by the EPA
Administrator that a new
product or use of an existing
pesticide will not
significantly increase the risk
of unreasonable adverse
effects. A product containing
a new (previously
unregistered) active
ingredient may be
conditionally registered only
if the Administrator finds
that such conditional
registration is in the public
interest, that a reasonable
time for conducting the
additional studies has not
elapsed, and the use of the
pesticide for the period  of
conditional registration will
not present an unreasonable
risk.
Data Call-In: Through its
Data Call-in program, EPA's
Office of Pesticide Programs
(OPP) requires the
development of key test data,
especially on long-term
chronic effects, for existing
pesticides in advance of
scheduled Registration
Standard reviews. Data
Call-In is an adjunct of the
Registration Standards
program intended to expedite
registration (see definition
below).
Inert Ingredient: In addition
to active components,
pesticides contain inert
solvents, carriers, surfactants,
etc., that are not active
against target pests. However,
not all inert ingredients are
innocuous.
Registrant: Any manufacturer
or formulator who obtains
registration for a pesticide
active ingredient or product.
Registration: Before any new
pesticide can be sold or
distributed in intra-or
interstate commerce, it must
be registered  under FIFRA.
EPA is responsible under
section 3 of FIFRA for
registration (premarket
licensing) of pesticides on
the basis of data
demonstrating that when
used according to approved
label directions, they will not
cause unreasonable adverse
effects on the environment.
Reregistration: Under section
3(g) of FIFRA, EPA is
responsible for the
reevaluation and
reregistration of existing
pesticides originally
registered prior to current
scientific and regulatory
standards. EPA reregisters
pesticides through its
Registration Standards
program.
Restricted Use: When a
pesticide is registered, some
or all of its uses may be
classified under FIFRA
section 3(d) for restricted use,
if the pesticide warrants
special handling because of
its toxicity. Restricted use
pesticides may be applied
only by trained, certified
applicators or those under
their direct supervision.
Special Review (formerly
known as Rebuttable
Presumption Against
Registration, or RPAR):
Existing pesticides suspected
of posing unreasonable risks
to human health, non-target
organisms or the
environment are referred for
Special Review to EPA's
Office of Pesticide Programs.
Special Review requires an
intensive risk/benefit
analysis, with opportunity for
public comment. If the risk of
any use of a pesticide is
found to outweigh social and
economic benefits, regulatory
action may be initiated.
FIFRA mandates a range of
regulatory options, from label
revisions and  use-restriction
to cancelled or suspended
registration.
Suspension: Under FIFRA
section 6(c), the EPA    $
Administrator may suspend
(halt) the use of
necessary to pre\
imminent hazard.^
emergency suspension take,-
effect immediately, but und
an ordinary suspension a
registrant can request a
hearing before the suspensii
goes into effect to determine
whether registrations of the
pesticide should be
suspended. An ordinary
suspension hearing may tak
six months.
Tolerances: Under the
FFDCA, EPA is responsible
for establishing tolerances
(maximum permissible
residue levels) for pesticide
in raw agricultural products
and processed foods.
Whenever a pesticide is
registered for use on a food
or feed crop, a tolerance (or
exemption from the tolerani
requirement) must be
established. Tolerances for
agricultural commodities ar
enforced by the FDA.
Tolerances for
poultry products
by the USDA.

-------
Appendix B
                                           Appendix D
Basic Data Requirements For A New Major
Food Or Feed Crop Pesticide
Overview:  Data from the following tests
           must be submitted to EPA by a
           manufacturer prior to
           registration
Chemistry:  list of ingredients (active, inert,
             impurities]
           description of manufacturing
             process
           discussion of formation of
             impurities
           physico-chemical properties
             (e.g., melting point, solubility,
             stability, flammability, PH,
             etc.)
           residue studies (original and
             confirmatory tests for each
             commodity or commodity
             group)
           metabolic studies
           analytical methods (used in
             setting tolerances for raw
             agricultural commodities and
             to detect residues for
             tolerance enforcement)
           results of analytical procedures
Environ-   hydrolysis
mental     leaching
Fate:       terrestrial dissipation
           photodegradation
           metabolism (aerobic and
             anaerobic soil degradation)
           rotational crop study
Toxicology: acute oral
         .  acute dermal
           acute respiratory
           ocular irritation
           chronic toxicity (two-year testing
              of rats)*
           subchronic oral toxicity
              (six-month testing of dogs)**
           reproduction and fertility
              (two-generation study)
           metabolism (testing of rats)
           mutagenicity
           teratogenicity (two species
              tested)
           oncogenicity (two species tested)

Ecological  toxicity (acute) (freshwater
Effects:        aquatic invertebrates)
           fish (acute) (two species tested;
              LC50 = lethal dose for 50
              percent of test animals)
           bird (dietary) (two species; LC50)
           bird (single dose) (LC50)

Note:
Many other studies may also be
conditionally required depending upon
chemical class, site, physico-chemical
properties, biological activity and results of
basic test requirements.
'Chronic toxicity studies on rats can  fulfill one
of two species requirements for oncogenicity.
* * New guidelines could replace this test with
a one-year canine study.
Appendix C
Map Of EPA Regions
EPA Pesticide Contacts

Head-      Policy and Special Projects Staff
quarters    Office of Pesticide Programs
           401 M Street, S.W.
           Washington, D.C. 20460
           (703) 557-7102
Region 1   Director, Air Management
           Division
           JFK Federal Building
           Room 2311-AAA
           Boston, MA 02224
           (617) 223-2226
Region 2   Chief, Pesticides and Toxic
           Substances Branch
           Woodbridge Avenue
           Building 209
           Edison, NJ 08837
           (212) 264-2525
Region 3   Chief, TSCA/FIFRA Enforcement
           Section
           841 Chestnut Street
           (3HW13)
           Philadelphia, PA 19107
           (215) 597-8598
Region 4   Chief, Pesticides and Toxic
           Substances Branch
           345 Courtland Street, N.E.
           Atlanta, GA 30365
           (404) 881-4727
Region 5   Chief, Pesticides and Toxic
           Substances Branch
           536 South Clark Street
           Chicago, IL 60605
           (312) 353-2291
Region 6   Director, Air and Waste
           Management Division
           1201 Elm Street
           Dallas, TX 75270
           (214) 767-2600
Region 7   Chief, Case Preparation and
           Technical Assistance Section
           726 Minnesota Avenue
           Kansas City, KS 66101
           (913) 236-2800
Region 8   EPA
           One Denver Place
           999 18th Street
           Suite 1300
           Denver, CO 80202
           (303) 293-1603
Region 9   Chief, Pesticides and Toxics
           Branch
           215 Fremont Street
           San Francisco, CA 94105
           (415) 974-8071
Region 10  Chief, Pesticides and Toxic
           Substances Branch
           Mail Stop 524
           1200 6th Street
           Seattle, WA 98101
           (206) 442-5810

-------
Appendix  E
 State Agencies
            Region 1
           Region 2
           Region 3
 Connecticut Director
            Dept. of Environmental
            Protection
            Hazardous Materials
            Management Unit
            State Office Building
            165 Capitol Avenue
            Hartford, CT 06115
            (203) 566-5148

 Maine     Director
            Pesticides Control Board
            State Office Building - Station 28
            Augusta, ME 04333
            (207) 289-2731
 Massachu- Chief
 setts       Pesticides Bureau
            Dept. of Food and Agriculture
            100 Cambridge Street, 21st Floor
            Boston, MA 02202
            (617) 727-7712
 New       Supervisor
 Hampshire Pesticides Control Division
            Dept. of Agriculture
            85 Manchester Street
            Concord, NH 03301
            (603) 271-3550

 Rhode     Chief
 Island     Division of Agriculture and
            Marketing
            Dept. of Environmental
            Management
            22 Hayes Street
            Providence, RI 02903
            (401) 277-2782
 Vermont   Director
            Plant Industry Division
            Dept. of Agriculture
            116 State St., State Office Bldg.
            Montpelier. VT 05602
            (802) 828-2431
New Jersey Chief
           Bureau of Pesticide Control
           N] Dept. of Environmental
           Protection
           380 Scotch Road
           West Trenton, NJ 08265
           (609) 292-8393
New York  Director
           Bureau of Pesticides
           Dept. of Environmental
           Conservation
           Rm. 404, 50 Wolf Road
           Albany, NY 12233
           (518) 457-7482
Puerto     Director
Rico       Analysis and Registration of
           Agricultural Materials
           Puerto Rico Dept. of Agriculture
           POB 10163
           Santurce, PR 00908
           (809) 796-1710, 1715
Virgin     Director
Islands     Pesticide Programs
           Division of Natural  Resources
           Management
           Dept. of Conservation and
           Cultural Affairs
           111 Watergut Homes
           Christiansted, St. Croix
           U.S. Virgin Islands 00820
           (809) 773-0565
Delaware   Delaware Dept. of A
           POB Drawer D
           Dover, DE 19901
           (302) 736-4815
District of  Division of Pesticides and
Columbia   Hazardous Materials
           Dept. of Environmental Services
           District of Columbia
           5010 Overlook Avenue, S.W.
           Washington, DC 20032
           (202) 767-8422
Maryland  Chief, Pesticide Applicator's Lav
           Section
           Maryland Dept. of Agriculture
           50 Harry S.  Truman Parkway
           Annapolis, MD 21401
           (301) 841-5710
Pennsylva- Chief, Agronomic Services
nia        Bureau of Plant Industry
           PA Dept.  of Agriculture
           2301 N. Cameron Street
           Harrisburg,  PA 17110
           (717) 787-4843

Virginia    Supervisor
           VA Dept. of Agriculture and
           Consumer Service
           POB 1163
           Richmond,  VA 23209
           (804) 786-3798
West      Director, Plant Pest Control
Virginia    Division
           W VA Dept. of Agricjj
           Capitol Building
           Charleston,  WV 253
-------
   [abama
 Florida
 Georgia
 Kentucky
           Region 4	

           Director
           Ag Chemistry/Plant Industry
           Division
           Alabama Dept. of Agriculture &
           Commerce
           FOB 3336
           Montgomery, AL 36193
           (205) 832-3753
           Administrator
           Dept. of Agriculture and
           Consumer Services
           Mayo Building, Room 213
           Tallahassee, FL 32301
           (904) 487-2130
           Chief
           Pesticides Division
           Dept. of Agriculture
           19 M.L. King, Jr. Drive, S.W.
           Atlanta, GA 30334
           (404) 656-4958
           Director
           Division  of Pesticides
           Kentucky Dept. of Agriculture
           Capitol Plaza Tower
           Frankfort, KY 40601
           (502) 564-7274
Mississippi Director
           Division  of Plant Industry
           Dept. of Agriculture and
           Commerce
           FOB 5207
           Mississippi State, MS 39762
           (601) 325-3390
           Pesticide Administrator
           Pest Control Division
           Dept. of Agriculture
           State Agriculture Building
           Raleigh, NC 27611
           (919) 733-3556
South      Pesticide Supervisor
Carolina   Plant Pest Regulatory Service
           210 Barre Hall
           Clemson  University
           Clemson, SC 29631
           (803) 656-3005
Tennessee  Director
           Plant Industries Division
           Dept. of Agriculture
           FOB 40627, Melrose Station
           Nashville, TN 37204
           (615) 360-0117
"TWrth
 Carolina
	Regions          	

Illinois    Chief
           Bureau of Plant and Apiary
           Protection
           Dept. of Agriculture
           Emmerson Building
           Springfield, IL 62706
           (217) 785-2427

           Office of Health Protection
           Dept. of Public Health
           535 West Jefferson
           Springfield, IL 62761
           (217) 782-4674
Indiana    Pesticide Administrator
           Office of the State Chemist
           Dept. of Biochemistry
           Purdue University
           West Lafayette, IN 47907
           (317) 494-1587
Michigan  Plant Industry Division
           Dept. of Agriculture
           Lewis Cass Building
           Lansing,  MI 48909
           (517) 373-1087
Minnesota Director
           Division  of Agronomy Services
           Dept. of Agriculture
           90 West Plato Blvd.
           St. Paul.  MN 55107
           (612) 297-1161 or 296-1161
Ohio      Specialist in Charge of Pesticides
           Dept. of Agriculture
           8995 East Main Street
           Reynoldsburg, OH 43068
           (614) 866-6361
Wisconsin Executive Assistant
           Dept. of Agriculture,  Trade and
           Consumer Protection
           FOB 8911
           Madison, WI 53708
           (608) 267-9423
                                                                                                    Region 6
Arkansas  Director
           Division of Feed, Fertilizer and
           Pesticides
           Arkansas State Plant Board
           1 Natural Resources Rd.
           Little Rock, AR 72205
           (501) 225-1598
Louisiana  Office of Agricultural and
           Environmental Sciences
           Louisiana Dept. of Agriculture
           FOB 11453
           Baton Rouge, LA 70804
           (504) 925-3763
New       Chief
Mexico    Division of Agricultural and
           Environmental Services
           N. M. State Dept. of Agriculture
           FOB 3150
           New Mexico State University
           Las Cruces, NM 88003
           (505) 646-2133
Oklahoma  Supervisor
           Pest Management Section
           Plant Industry  Division
           Oklahoma State Dept. of
           Agriculture
           310 N.E. 28th Street
           Oklahoma City, OK 73105
           (405) 521-3863 or 3871
Texas      Director
           Division of Agricultural and
           Environmental Sciences
           Texas Dept. of  Agriculture
           FOB 12847
           Austin, TX 78711
           (512) 463-7524

-------
           Region 7

 Iowa      Supervisor
           Pesticide Control Section
           Iowa Department of Agriculture
           Henry A. Wallace Building
           East 7th Street and Court
           Avenue
           Des Moines, IA 50319
           (515) 281-8590
 Kansas    Director
           Plant Health Division
           Kansas State Board of
           Agriculture
           109 S.W. Ninth Street
           Topeka, KS 66612
           (913) 296-2263
 Missouri   Supervisor
           Bureau of Pesticide Confrol
           Dept. of Agriculture
           FOB 630
           Jefferson City, MO 65102
           (314) 751-2462
 Nebraska  Director
           Bureau of Plant Industry
           Nebraska Dept. of Agriculture
           301 Centennial Mall
           Lincoln. NE 68509
           (402) 471-2341
           Region 8

Colorado   Supervisor
           Pesticide Section
           Division of Plant Industry
           Colorado Dept. of Agriculture
           4th Floor, 1525 Sherman Street
           Denver, CO 80203
           (303) 892-2838
Montana   Administrator
           Environmental Management
           Division
           Agriculture-Livestock Building
           Rm317
           Capitol Station
           6th and Roberts
           Helena. MT 59601
           (406) 444-2944
North      Director
Dakota    Plant Industries Division
           Dept. of Agriculture
           State Capitol
           Bismarck, ND 58505
           (701) 224-2232
South      Director
Dakota    Division of Regulatory Services
           SD Dept.  of Agriculture
           Anderson Bldg.
           445 East Capitol
           Pierre. SD 57501
           (605) 773-3375
Utah       Director
           Division of Plant  Industries
           Dept. of Agriculture
           350 North Redwood Road
           Salt Lake City, UT 84103
           (801) 533-4107
Wyoming   Manager
           Plant Industry
           Wyoming Dept. of Agriculture
           2219 Carey Avenue
           Cheyenne, WY 82002
           (307) 777-9321
	Region 9     	

Arizona    Administrator    :
            Board of Pesticide Control
            1624 West Adams - Suite 103
            Phoenix, AZ 85007
            (602) 271-3578

            State Chemist
            Agriculture Experiment Station
            POB 1586
            Mesa, AZ 85201
            (602) 833-5442

            Executive Secretary
            Structural Pest Control Board
            2207 South 48th - Suite M
            Tempe, AZ 85282
            (602) 271-3664
California   Assistant Director
            Division of Pest Management,
            Environmental Protection, and
            Worker Safety
            California Dept. of Food &
            Agriculture
            Sacramento, CA 95814
            (916) 322-6315
Hawaii     Head
            Division of Plant  Industry
            Hawaii Dept. of Agriculture
            POB 22159
            Honolulu, HI 96822
            (808) 548-7124
Nevada     Administrator
            Division of Plant  Indust
            Nevada Dept. of Agricul
            POB 11100
            Reno, NV 89510
            (702) 789-0180
Guam      Director
            Air and Land Programs Division
            Guam Environmental Protection
            Agency
            POB 2999
            Agana. GU 96910
American   Director
Samoa      Dept. of Agriculture
            POB 366
            Pago Pago, American Samoa
            96799
Trust       Executive Officer
Territory of Trust Territory Environmental
the Pacific   Protection Board
Islands     Office of the High Commissioner
            Trust Territory of the Pacific
            Islands
            Saipan. Mariana Islands !)(i950
Common-   Environmental Engineer
wealth      Division of Environmental
of the      Quality
Northern    Commonwealth of the Northern
Mariana    Mariana Islands (CNMI)
Islands     Dr. Torres Hospital
            Saipan, Mariana Island 96950
12

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(
 REMARKS
                                  rruA>6axM
DO NOT use this form as a RECORD of approvals, concurrences, disposals,
                   clearances, and similar actions
FROM: (Name, org. symbol. Agency /Post)
            Room No.—Bldg.
                                              Phone No.
6041-102


• U.S. GPO: 1988 - 201-759
OPTIONAL FORM 41 (Rev.-7-76)
PrMcritMd by GSA
FPMR (41 CHO 101-11^06

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                    MERCURY IN PAINT PRODUCTS

                   Statement  of  Linda J.  Fisher
   Assistant Administrator for Pesticides and Toxic Substances
               U.S.  Environmental  Protection  Agency

                          June 29, 1990


     Good morning.  I am here today to announce a series of

actions by EPA to protect public health, especially that of

children, resulting from exposure to mercury in paint.  Mercury

compounds are used as preservatives in about 30 percent of the

water-based latex paint products currently on the market;  oil

based paints do not contain mercury.



     Before I begin, I would like to introduce Dr. William Roper,

Director of the Federal Centers for Disease Control in Atlanta,

Georgia.  The CDC have assisted EPA in evaluating the toxicity of

mercury and the potential risks associated with exposure to

mercury-containing paints.  I appreciate the support CDC has

provided EPA in this matter.   At the conclusion of my statement,

Dr. Roper will make a few remarks.



     To help prevent risks to the public, EPA is taking the

following specific actions regarding mercury in paint products.

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     1).   EPA a#d the registrants of mercury paint preservatives



     have agreed to eliminate the use of mercury in interior



     paints effective August 20, 1990.  After that date, no



     interior paint will be formulated with mercury.







     2).   All new exterior paints formulated with mercury after



     August 20 will include new warning labels: the labels will



     state that the paint contains mercury, stress the limitation



     to outdoor use, warn of potential health hazards, and



     caution against exposure to children.







     3).   Effective August 20, no new mercury-containing paints



     will be labeled for both interior and exterior use,    as



     some now are.







     EPA's current concern about the risks of mercury in paint



products stems from a reported case of acrodynia, a rare form of



mercury poisoning, which affected a four-year old child in



Michigan whose home was painted with a mercury-containing paint



in 1989.   Although the case was severe, after months of medical



treatment the child is almost entirely recovered.  Exposure to



mercury may also cause other adverse effects to the nervous



system and kidneys. In view of the fact that less risky

-------
alternatives to mercury are available to the paint industry,  we



conclude that it is appropriate to take action to eliminate the



indoor uses which are most likely to pose significant risks.







     EPA's concern about mercury in paint does not end with the



specific actions I have just cited.  Our review of the potential



risks posed by mercury in paint products is on-going, and



includes these additional steps:







     4.) Requiring the manufacturers of mercury preservatives to



     submit a substantial amount of new testing data in order to



     clarify the potential risks which may be posed by outdoor



     uses of paints containing mercury.  EPA will decide whether



     additional actions are needed based on the results of those



     studies on other available information.







     5). EPA is also discussing with the registrant appropriate



     regulatory measures concerning the use of mercury in certain



     products used in construction work, including acoustical



     plaster, adhesives, and spackling and jointing compounds.







     EPA believes that it is preferable that consumers use paints



which do not contain mercury when painting indoor surfaces.



Effective on August 20, all further production of paints



containing mercury must be labeled exclusively for exterior use.



To deal with existing stocks of paint containing mercury, the

-------
National Paints and Coatings Association is working with paint



manufacturers tp relabel all paints with higher mercury levels



(over 200 ppm) for exterior use only.  EPA believes that



consumers may continue to use interior paint with lower mercury



levels (200 ppm or less) without unreasonable risk if they follow



all label directions, ventilate thoroughly during and after use,



and minimize exposure of children.







     If mercury-containing paints have already been used, or are



currently being used we advise that exposure be minimized,



especially for children or pregnant women, and that painted rooms



be thoroughly and frequently ventilated.  We also strongly



caution consumers not to apply any mercury-containing paint



indoors which is labeled for exterior use or labeled as a dual



purpose interior/exterior paint.  These products may contain high



levels of mercury.







       If consumers wish to dispose of mercury-containing paint



products,  we recommend disposal through a community hazardous



waste program, if one is available.  Alternatively, if none



exists, consumers should consult their local governments for



proper means of disposal.  Under no circumstances should mercury-



containing paints ever be poured down a drain, into a ditch or



into any body of water.  Mercury is toxic to many species when



released into water.

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     Again, it should be noted that about 30 percent of water-



based latex paints for interior use contain mercury; between 20



and 35 percent of exterior latex paints contain mercury.  Based



on  information from some paint manufacturers, we believe this



percentage may be dropping in anticipation of this announcement.



Oil-based paints do not contain mercury.  To help consumers



identify mercury-containing paints, EPA will provide information



on which paint products contain mercury through EPA's National



Pesticide Telecommunication Network.  The toll-free phone number



is noted in our press release.  This information will also be



available through EPA Regional offices and State Departments of



Health.  Consumers may also contact paint manufacturers for



information about specific products.







     This concludes my statement.  Let me introduce Dr. Roper and



then we will both be happy to take questions.

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                     United Stoies            Communications And
                     Environmental Protection      Public Affairs
                     Agency               (A-107)
   &EPA      Environmental  News
  FOR RELEASE:  FRIDAY,  JUNE 29, 1990
  USE OF MERCURY COMPOUNDS  IN INDOOR LATEX PAINT TO BE ELIMINATED
                            1

                                      Al Heier (202) 382-4374
      To avoid possible health risks, the U.S. Environmental  Protection

  Agency announced today that the use of mercury compounds in  indoor latex

  paint will be eliminated.  In addition,  warning labels will  be required on

  all  outdoor paint containing mercury stating that the paint  is for outdoor

  use  only.
  con
*
     Effective on August 20,  all further production of paints containing
mercury must be labeled exclusively for exterior use.  EPA prefers that
consumers use paints which do not contain mercury when painting indoor
   faces.  To deal with existing stocks of paint containing mercury, the
   ional Paint and Coatings Assn. is working with paint manufacturers to
 elabel all paints with higher mercury levels (over 200 parts per million)
for exterior use only.  EPA believes that consumers may continue to use
interior paint with lower mercury levels (200 parts per million or less)
without unreasonable risk if  they follow all label directions,  which
include ventilating thoroughly during and after use and minimizing exposure
to children.

     The manufacturers (registrants) of mercury products registered as
pesticides for use in latex paint voluntarily agreed to the announced
actions following discussions with EPA.  Mercury is used as an in-can
preservative to prevent bacterial and fungal growth and to control mildew
on exterior surfaces.  It is  used in 25 to 30 percent of all interior latex
paint (it is not used in oil  based paint),  and in 20 to 35 percent of
outdoor latex paint.

     The Agency has contacted the approximately 1500 paint manufacturers in
the United States in an effort to identify the specific paints containing
mercury. Information on specific paints will be available to the public
through a toll free number for the National Pesticide Telecommunication
Network, 1-800-858-7378, as well as State Health Departments, State
Departments responsible for regulating pesticides  (usually the State
Department of Agriculture)  and EPA Regional offices.  Information on
specific paints may also be available through the paint manufacturer.

                            (more)

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     After August 20, manufacturing interior paint containing mercury will
be unlawful.  By July 23, the mercury registrants have agreed to label
their own- products with specific directions and to  deliver similar sticker
labels to the paint manufacturers.   The labels will prohibit use of
mercury products to make interior paint.  Warning statements, and maximum
allowable use rates will also be required on all newly formulated mercury-
containing exterior paint.
                             i
     EPA's review of the use of mercury compounds in paints began after a
report of acrodynia  (a rare form of childhood mercury poisoning) and
following an investigation by the Centers for Disease Control and the State
of Michigan.  This severe case involved a four year old child whose
Michigan home was painted in 1989 with paint containing mercury.  The
child's condition is much improved following medical treatment..  In this
case, the paint contained three times the amount of mercury normally used
to preserve interior paint (930 vs. 300 parts per million).

     Exterior use paints and paints labeled for both interior and exterior
use may contain high levels of mercury.   EPA recommends that these
products not be used indoors if they contain mercury.  The Agency is
cautioning businesses, schools, homeowners and others,  against the
practice of using exterior paints containing mercury on interior surfaces
because the higher mercury levels increase the chances of possible health
effects.

     •"While available evidence suggests that mercury poisoning is rare, EPA
   concerned about the potential risks to public health and the environment
that may be associated with the use of mercury in paint," said Linda J.
Fisher, EPA's Assistant Administrator for Pesticides and Toxic "Substances.
"EPA wants to prevent the potential risks that mercury in indoor paint can
pose.  We applaud the responsibility of the registrants of mercury for
agreeing to delete this use from their registrations and to accelerate the
development of data so EPA can make prompt decisions on the remaining
uses."

     Most pesticidal uses of mercury were banned in 1976.  The use of
mercury in paint was allowed to continue because it was determined that
effective alternatives were not available. Alternative preservatives are
available today and are already used by many paint companies.  At this
point, EPA does not believe that any of these alternatives present an
unreasonable risk.  Since paints contain many chemicals, however, it is
always prudent to minimize exposure by ventilating the area being painted
as well as possible.

     Acrodynia is characterized by weakness and severe pain in the
extremities; pinkness and peeling of the hands, feet, and nose;
irritability; sweating; and a rapid heart beat.  Other effects of mercury
poisoning include decreased motor functions and muscle reflexes, slight
tremors, short term memory loss, headaches and abnormal EEGs' (a graphic
record of the electrical activity in the brain).   In both adults and
  j.ldren, the major targets of mercury poisoning are the nervous system and
    kidneys.
  itSO
*
R-lll                            (more)

-------
     People who believe that they or a family member may be experiencing
   ns or symptoms of mercury poisoning should contact their family
physician.  People who recently painted indoors with a mercury containing
paint ar» urged to ventilate the area throughly by opening windows for as
long as possible and practical.  If possible, place a fan in or near an
open window to enhance circulation and draw the paint fumes -outside.

     EPA is conducting studies to determine the rate at which mercury
vapors are released after paint is applied, the actual concentrations in
the air, and the amount of time it takes mercury to dissipate.  EPA
believes that mercury concentrations in the air decrease within a number of
days after painting.  Lower concentrations may be present in the air for
months after application, however.

     As a result of discussions with .the mercury registrants, .only phehyl
mercuric acetate will remain registered for use in paint.  Use will be
limited to exterior paint and coatings and miscellaneous interior uses
(spackling and patching compounds, for example).

     Registrants of mercury will be required to develop and submit
substantial additional data concerning the remaining uses in exterior
paint.  The Agency will be assessing whether further action is warranted
based on the results from these studies and other available data.

      Mercury compounds are also used in other products for interior use
   luding spackling and patching compounds, joint compounds, adhesives and
   ustical plasters.  EPA is continuing to evaluate these products and will
 etermine whether action is necessary to address risks from these uses of
mercury.
                                                               i
     Homeowners and consumers who wish to dispose of mercury-containing
paint should take the paint to a household hazardous waste collection point
in their community.  If no community program exists, the consumer should
consult their local government for proper methods of disposal.  For further
information, contact the State environmental agency, State health
department, solid waste management agency, or Regional EPA office to
determine an acceptable means of disposal.  EPA cautions that_paint
containing mercury should never be poured down the sink, drain or toilet.
Mercury which enters aquatic systems can form methyl mercury which is very
toxic to humans and animals.

     Businesses who wish to dispose of mercury-containing paint may be
subject to Subtitle C regulations governing hazardous waste under the
Resource Conservation and Recovery Act.  The method of disposal will depend
on the concentration of mercury in the paint and the quantity of hazardous
waste that the business generates each month.


R-lll                             #  #  #

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                          JUNE 29,  1990
                   MERCURY PESTICIDES IN PAINT

                       Facts  for Consumers

The Environmental Protection Agency (EPA) is concerned that
paints used indoors which contain mercury may present health
risks both to people who apply the paint and to people who occupy
painted rooms, especially children.  The companies that produce
mercury for use as a biocide  in paint have agreed to eliminate
future use of mercury in interior latex paints.  Approximately 25
to 30% of interior use latex paints currently contain mercury.

Mercury will still be used in some paints for outdoor surfaces.
However, all these paints produced in the future will have a
statement on the label that warns painters that the product
contains mercury and should be used only outdoors.  Mercury is
also used in various miscellaneous interior products such as
spackling and patching compounds, joint compounds, adhesives and
acoustical plasters.

EPA will continue to examine the potential risks of mercury and
will take further action, if necessary, to protect the health of
consumers and their families.

EPA believes that it is preferable that consumers use paints
which do not contain mercury when painting indoor surfaces.
Effective on August 20, all further production of paints
containing mercury must be labeled exclusively for exterior use.
To deal with existing stocks of paint containing mercury, the
National Paint and Coatings Association is working with paint
manufacturers to relabel all paints with higher mercury levels
(over 200 ppm) for exterior use only.  EPA believes that
consumers may ^continue to use interior paint with lower mercury
levels (200 ppm or less) without unreasonable risk if they follow
all label directions and use  the following precautions:

     o    Ventilate the area  thoroughly by opening windows for as
          long as possible and practical.  If possible, place a
          fan in or near an open window to enhance circulation
          and draw the paint  fumes outside.

-------
     o    Tightly seal any unused cans of paint  and store  them
          out of the reach of children until they can be disposed
          of properly.

Symptoms of mercury poisoning can intensify and  may become
permanent as exposure time and/or concentration  increases.   These
symptoms, which could be reversed with proper treatment, include:

     o    Slight tremors, particularly affecting the hands  and
          interfering with fine motor control such as
          handwriting; erethism, a syndrome characterized  by
          various levels of insomnia, shyness, and emotional
          instability; decreases in motor function and muscle
          reflexes; short term memory loss; headaches; and
          abnormal EEGs (a graphic record of the electrical
          activity of the brain).

     o    In children, severe pain in the extremities; pinkness
          and peeling of the hands, feet, and nose; irritability;
          sweating; and a rapid heartbeat.  These are symptoms of
          acrodynia, a rare form of childhood mercury poisoning.
          Two separate cases of acrodynia have been diagnosed  in
          two children whose homes had been painted with  interior
          paint containing mercury.

     If your house has recently been painted with mercury-
     containing paint and you believe you are experiencing
     symptoms of mercury exposure, consult a physician.

If you currently have paint that contains mercury and you  wish to
dispose of it:

     o    Do not pour leftover paint down the sink, drain or
          toilet.

     o    Contact the Household Hazardous Waste  collection
          program in your community to see if they will accept
          paint.  To find the location and hours of operation,
          contact your local health department or solid waste
          management agency.  This is the preferred method of
          disposal.

     o    To find out more about the approved methods of paint
          disposal in your area, contact your State environmental
          agency, State Health Department, solid waste management
          agency, or EPA Regional Office.

If you want to know whether the paint you have or plan to
purchase contains mercury:

     o    Call the National Pesticide Telecommunication Network
          (NPTN) toll-free at 1-800-858-7378, 24 hours a day,  7

-------
          days a week, or contact your State Health Department,
          the State Department responsible for pesticide
          regulation (usually the State Department of
          Agriculture),  or an EPA Regional Office.

If you have other questions or want further information:

     o    Call the National Pesticide Telecommunication Network
          (NPTN) toll-free, 24 hours a day, 7 days a week, at 1-
          800-858-7378.

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                         PAINT  LIST  INSTRUCTION  SHEET

   :ached is information EPA has  compiled  to  aid in identification of paints
containing mercury.   There are two lists included in this package.  These lists
are as follows:

 1)   List 1 identifies those paint manufacturer's who DO NOT use mercury.

 2)   List 2 identifies those companies who DO use mercury.

 3)   Supplements to the above lists which are attached to each list.

In order  to determine whether a particular paint contains  mercury,  first
identify the paint manufacturer and determine whether that company is on list
1 or list 2.

If the company  is identified on list 1  (manufacturers who do not use mercury),
the paint is mercury free.*

If the company is identified on list 2 (manufacturers who do use mercury), it
will be necessary to consult Mercury Summary Report  (specific information from
this report  will be available  through a  toll  free number for  the National
Pesticide Telecommunication Network, 1-800-858-7378, as well  as State Health
Departments, State  Departments  responsible for  regulating  pesticides and EPA
Regional  Offices)  to  determine   whether a  specific  product  from.- that
manufacturer, contains mercury.

«     Mercury Summary  Report  is  arranged  alphabetically  by   company  (paint
   ufacturer) followed by an alphabetical  listing of  the  paints manufactured
by that company that contain mercury. The list also identifies if the product
is for interior use (I), exterior use  (E),  or both  (B).

      PLEASE NOTE THAT INCLUSION OF  A MANUFACTURER'S NAME ON LIST 2 DOES
      NOT NECESSARILY MEAN THAT ALL PAINTS MANUFACTURED BY THAT COMPANY
      CONTAIN  MERCURY.   THE  PROJECT  MERCURY  SUMMARY LIST  MUST  BE
      CONSULTED  TO   DETERMINE  WHETHER  A  PARTICULAR  PRODUCT  CONTAINS
      MERCURY.

If the name of a company is not found on either list 1 or 2, that company did
not respond to EPA's request for information.   Consumers should be advised to
contact the manufacturer directly to determine  whether  the paint in question
contains mercury, or  the consumer should assume  that the  paint does contain
mercury.
*     Information presented in  this  package  reflects information provided to
EPA voluntarily, by paint manufacturers.   Responses reflect the situation at
the time  of reporting.   Some  paint manufacturers  who have  reported using
mercury may have already  or may at some time in the future decide to use an
alternative to  mercury.    Consumers  may want  to contact  paint manufactures
directly to determine whether or not their paint contains mercury.   EPA has not
   ified the accuracy of  these  responses and  paint manufacturers were under no
   al obligation to provide accurate information.

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                         LIST  i
Page No.     1
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury

COMPANY                  (d(So See
A. J. DAW PRINTING INK CO.
A. L. HENDRY & CO.
A. P. NONWEILER CO. INC.
A.G.P. SURFACE CONTROL SYSTEMS
AACCO
ABCOM FINISHES INC.
ABSOLUTE COATINGS INC.
AC PRODUCTS INC.
ACADEMY PAINT CO. INC.
ACCURATE COATINGS & DISPERSION
ACE HARDWARE CORP.
ACHESON COLLOIDS CO.
ADAMS MFG. CO. INC.
ADHESIVE COATINGS
ADHESIVE PRODUCTS
ADVANCE PROCESS SUPPLY CO.
ADVANCED PACKAGING & PRODUCTS
ADVANCED PROTECTIVE PRODUCTS
AEROCHEM PAINT CO.
AEROSOL SYSTEMS INC.
AEXCEL CORP.
AGATE LACQUER MFG. CO.
AINSWORTH PAINT & CHEMICAL
AKONA CORP.
AKRON PAINT & VARNISH INC.
AKZO COATINGS
AKZO COATINGS CAR REFINISHES
AKZQ/IOVITE
AKZO/SRP
AL-CHROMA INC.
ALASKAN PAINT MFG. CO. INC.
ALLIED PAINT & COLOR WORKS
ALTAWOOD INC.
AMERICAN ABRASIVE METALS CO.
AMERICAN COATINGS
AMERICAN FINISH & CHEMICAL CO.
AMERICAN FINISHES INC.
AMERICAN INKS & COATINGS CORP.
AMES CHEMICAL CO.
AMITY LAC. PAINT & CHEMICAL
AMSTERDAM COLOR WORKS INC.
ANCHOR PAINT CO.
ANGLO AMERICAN VARNISH CO.
ANT. HYDRO CO. INC.
APPLIED COATINGS INC.
ARGUS COATINGS & CHEMICAL INC.
ARMORGUARD PRODUCTS INC.
ASAHIPEN AMERICA INC.
ATLAS COATINGS CORP.
ATLAS MINERALS & CHEMICALS INC

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Page No.     2
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury

COMPANY
ATLAS PRODUCTS INC.
ATOMIZED MATERIALS CO. INC.
AURACHEM CORP.
AUTOMOTIVE FINISHES INC.
BAKER SEALANTS & COATINGS CO.
BARRETT VARNISH CO.
BARRIER INDUSTRIES INC.
BASF COATINGS & COLORANTS
BASF CORP.
BEAVER PAINT CO.
BECK CHEMICALS INC.
BENJAMIN MOORE & CO.
BENNETTE PAINT MFG. CO. INC.
BERT'S PAINT INC.
BERWOOD IND. INC.
BIDDLE CO.
BIXEL PAINT CORP.
BLATZ PAINT CO, INC.
BONAKEMI USA INC.
BP CHEMICALS
BRADCO PLASTICS INC.
BRINER PAINT MFG. CO. INC.
BRUNING PAINT CO.
BURK-HALL
BY-CHEM CORP.
BYWATER SALES & SERVICE CO.
C. E. BRADLEY LABORATORIES INC
C. F. JAMESON & CO. INC.
C. M. ATHEY PAINT CO.
C. P. INC.
C. P. MAYEN CO. INC.
CACTUS PAINT MFG. CO.- INC.
CADDO PAINT CO. INC.
CALBAR INC.
CALDWELL PAINT MFG. CO. INC.
CAMCO PAINTS INC.
CAMGER CHEMICAL SYSTEMS INC.
CAMIE CAMPBELL INC.
CAPITOL PAINT MFG. CORP.
CARBIT PAINT CO. INC.
CARDINAL INDUSTRIAL FINISHES
CARLISLE MEMORY PRODUCTS GROUP
CAROLINA COATINGS INC.
CAROLINA SOLVENTS INC.
CARPENTER INSULATION  & COATING
CARTER PAINT CO. INC.
CARVIN PAINT & WALLPAPER CO.
CAULKTITE CORP.
CELUCOAT CORP.
CERAMIC INDUSTRIAL COATINGS

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Page No.     3
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury
 «••
COMPANY
CERTIFIED COATINGS PRODUCTS CO
CHAMPION PAINT MFG. CO. INC.
CHAPMAN INDUSTRIAL FINISHES
CHARLES PAINT RESEARCH
CHASE CORP.
CHASE PRODUCTS CO.
CHEM-ELAST COATINGS INC.
CHEM-PAK INC.
CHEMCOAT INC.
CHEMCRAFT SADOLIN
CHEMDESIGN CORP.
CHEMICAL COATINGS & ENGINEERIN
CHEMICAL COATINGS INC.
CHEMICAL-WAYS CORP.
CHEMIFAX
CHEMRAY COATINGS CORP.
CHILDERS PRODUCTS CO.
CHILTON PAINT CO.
CHROMATIC PAINT CORP.
CHUGOKU MARINE PAINTS
CINCINNATI VARNISH CO.
CLEMENT "COVERALL" CO.
CLEVELAND COATINGS CORP.
CLUB KIT INC.
CO-PLAS INC.
CO-POLYMER CHEMICALS INC.
COATERS INC.
COATING SYSTEMS INC.
COATINGS & CHEMICALS CORP.
COATINGS LAB INC.
COATINGS RESOURCE CORP.
COLONIAL PRINTING INK
COLOR CORP. OF AMERICA
COLOR MART PAINT CO. INC.
COLOR TECHNOLOGY INC.
COLOR TILE MANUFACTURING
COLOR TILE SUPERMARTS
COLORAY PAINT CO.
COMMERCIAL COATINGS CORP.
COMMERCIAL MEXICANA DE PINTURA
COMMONWEALTH CUSTOM COATINGS
CONAP INC.
CONKLIN CO. INC.
CONSUMERS PAINTS FACTORY INC.
CONTINENTAL COATINGS INC.
CONTINENTAL PRODUCTS CO.
COOK COMPOSITES & POLYMERS
COOK PAINT & VARNISH CO.
CORBOLINE CO.
CORR-O-BOND PROTECTIVE COATING

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Page No.     4
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury
*»
COMPANY
COVENTRY COATINGS CORP.
CRC INDUSTRIES INC. 1
CRESCENT BRONZE POWDER CO.
CREST INDUSTRIES INC.
CROWE INDUSTRIAL COATINGS
CROWN METRO AEROSPACE COATINGS
CROWN METRO INC.
CROWN ROLL LEAF INC.
CTI INDUSTRIES INC.
CUDNER & O'CONNOR CO.
CUSTOM CHEMICALS CORP.
CUSTOM-PAK PRODUCTS INC.
D & B PAINT MFG. CO.
D & L PAINT CO.
D.C TRANCHE & CO.
D.P.I. QUALITY PAINTS
DAL-WORTH PAINT MFG. CO.
DALY'S INC.
DANACOLORS INC.
DANBERG CHEMICAL CO. INC.
DANIEL BOONE PAINT CO. INC.
DANIEL SMITH INC.
DAP INC.
DARTHWORTH CO.
DAVIES IMPERIAL COATINGS INC.
DEAN & BARRY CO.
DECKER PAINT CO.
DECRATREND PAINTS
DEFT INC.
DELRAC INC.
DELTA INDUSTRIAL COATINGS INC.
DENNIS CHEMICAL CO.
DEVOE & RAYNOLDS CO.
DEVOE COATINGS CO.
DEXTER BROTHERS CO.
DEXTER PACKAGING PRODUCTS
DHAKE INDUSTRIES
DIAMOND PRODUCTS CO.
DIAMOND VOGEL PAINT
DIAMOND VOGEL/KOMAC PAINT
DOLPHIN PAINT & CHEMICAL CO.
DREEBLAN PAINT CO.
DRYVIT SYSTEMS INC.
DUNN-EDWARDS CORP.
DUPLI-COLOR PRODUCTS
DYNAMATCH
DYNAMIC DEVELOPMENT CORP.
DYNAMIC PRODUCTS CORP.

-------
Page No.     5
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury

COMPANY
DYNATRON/BONDO CORP.
E-BOND EPOXIES INC.  ;
EAGLE BRIDGES CO. INC.
EAGLITE CHEMICALS INC.
EARL CAMPBELL MFG. CO.
EASTERN CHEM-LAC CORP.
EASTERN COLOR & CHEMICAL CO.
EGYPTIAN LACQUER MFG. CO.
ELECHROME INC.
ELLICOTT PAINT CO. INC.
ELLIS PAINT CO.
ELPACO COATINGS CORP.
ELSTON PAINT & SUPPLY CO. INC.
EMPIRE STATE VARNISH CO.
ENCAPSULATE INC.
ENGARD COATINGS CORP.
ENGINEERING MATERIALS INC.
ENVIRONMENTAL COATINGS INC.
ESGARD INC.
EVERSEAL INTERNATIONAL SALES
EXCELSIOR VARNISH & CHEMICALS
FAULTLESS STARCH/BON AMI CO.
FEDERATED PAINT
FIELDCO
FINE PAINTS OF FRANCE
FINISHES UNLIMITED INC.
FISCHER INDUSTRIAL COATINGS
FLAME CONTROL COATINGS INC.
FLAMEMASTER CORP.
FLAMORT CHEMICAL CO.
FLECTO CO. INC.
FLEX PROOF INC.
FLEX-BON INC.
FLEXABAR CORP.
FLOOD CO.
FLOORTECH INC.
FMI CORP.
FORREST PAINT CO.
FORREST TECHNICAL COATINGS
FOSROC INC.
FREEDOM COATINGS CO. INC.
FROST PAINT & OIL CORP.
FYN PAINT & LACQUER CO. INC.
G & H COATINGS CO.
G & W ENTERPRISES INC.
G. J. NIKOLAS & CO. INC.
GARDWELL MANUFACTURING CORP.
GARLOCK INC./COLT IND.
GATEWAY PAINT & CHEMICAL CO.
GAVLON INDUSTRIES INC.

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 Page  No.      6
 05/31/90
                           Paint  Manufacturers
                          Who Do  Not Use Mercury

"COMPANY
GC  - THORSEN
GEM GRAVURE CO.  INC;
GEMINI  COATINGS  INC.
GENERAL COATINGS TECHNOLOGIES
GENERAL PAINT &  CHEMICAL  CO.
GILBERT SPRUANCE CO.
GILBRALTER NATIONAL CORP.
GILSONITE CORP.
GLOSS-FLO CORP.
GLYPTAL INC.
GOLD BOND BUILDING PRODUCTS
GOLDEN  AGE FURNITURE  FINISHING
GORDON  BARTELS CO.
GRAHAM  PAINT & VARNISH CO.
GRIGGS  PAINT
GROW BATON ROUGE CORP.
GROW GROUP INC.
GULF COAST PAINT MFG.  INC. .
GULF PAINT & CHEMICAL CO.  INC.
GULF STATES ASPHALT
HARCO CHEMICAL COATING INC.
HARLAN  ASSOCIATES INC.
HARRY MILLER CORP.
HARTIN  PAINT & FILLER
HASKELL CHEMICAL CO.  INC.
HEMPEL  COATINGS  (USA)  INC.
HENTZEN COATINGS INC.
HERESITE PROFECTIVE COATINGS
HEXCEL  CORP.
HILL BROS. CHEMICAL CO.
HISTRAND CHEMICALS INC.
HK  RESEARCH CORP.
HOLRITE INC.
HONEY DO PAINT
HOPPE CO. INC.
HORN SALES CORP.
HOUSE OF KOLOR INC.
HSC INDUSTRIAL COATINGS INC.
HUNTING SPECIALTY PRODUCTS INC
HYDROMER INC.
HYDROSOL INC.
HYDROZO INC.
I.  T. W. PHILADELPHIA RESINS
I.  V. C. INDUSTRIAL COATINGS
IGI ADHESIVES
ILLINOIS BRONZE  PAINT CO.
IMPERVIOUS PAINT INDUSTRIES
INDUROL CHEMICALS INC.
INDUSTRIAL COATING SPEC.  CORP.
INDUSTRIAL FINISHING  PROD.INC.

-------
Page No.     7
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury
«•
COMPANY
INDUSTRIAL POWDER COATINGS INC
INGLIS CO. INC.
INLAND COATINGS
INORGANIC COATINGS INC.
INSI-X PROD. CORP.
INSULATING COATINGS CORP.
INTERNATIONAL PAINT (USA) INC.
INTERNATIONAL PAINT POWDER
IROQUOIS CHEMICALS
ISIS COATINGS INC.
ISOTRON CORP.
ITD INDUSTRIES INC.
J. C. WHITLAM MANUFACTURING
CO.
J. LANDAU & CO. INC.
J. M. RICH PAINT & VARNISH CO.
J. URBAN CO. INC.
JAMES B. DAY & CO.
JAMESTOWN PAINT & VARNISH CO.
JASCO CHEMICAL CORP.
JATUN VALSPAR
JEDCO CHEMICAL CORP.
JELLICO CHEMICAL CO. INC.
JEMA-AMERICAN
JESCO RESOURCES INC.
JOHN C. DOLPH CO.
JOHN C. KAISER CO.
JOHN L. ARMITALE & CO.
JONES BLAIR CO.
JORDAN PAINT
K.A. DUTCHER PAINT & VARNISH
KAUFMAN PRODUCTS INC.
KC COATINGS
KEELER & LONG INC.
KEL-GIO CORP.
KELLER PAINT & LACQUER CO.INC.
KELLY GOODWIN CO.
KEMPEN PAINT CO.
KEN-LAC INC.
KENLAR INDUSTRIES INC.
KENTUCKY PAINT MFG. CO.
KEY POLYMER CORP.
KIMAT PAINT
KIRKER CHEMICAL INC.
KOCH MATERIALS CO.
LAKELAND LABORATORY INC.
LAURENCE - DAVID INC.
LAWRENCE-MCFADDEN CO.
LENMAR INC.
LEXINGTON PAINT & SUPPLY CO.

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Page No.      8
05/31/90
                           Paint Manufacturers
                         Who  Do Not Use Mercury

"COMPANY
LILLY CO.
LILLY INDUSTRIAL COATINGS
LILLY PLASTICS COATINGS
LILLY POWDER COATINGS
LINDSAY  FINISHERS  INC.
LINEAR DYNAMICS INC.
LLOYD LABORATORIES INC.
LOCKHART CHEMICAL  CO.
LONE STAR  PAINT &  LACQUOR MFG.
LONG ISLAND  PAINT
LORD CORP.
LOUTON PAINT
M. A. B. PAINTS INC.
M. A. BRUDER & SONS INC.
M. GRUNBACHER INC.
MAGNET PAINT & SHELLAC CO.INC.
MAN-GILL PAINT GROUP
MANSFIELD  PAINT CO.
MARCHEM  CORP.
MARCHEM  SOUTHEAST  INC.
MARINE INDUSTRIAL  PAINT CO.
MARK-TEX CORP.
MARSH CO.
MARTIN PAINT & CHEMICAL CORP.
MASTER BUILDERS INC.
MATTHEWS PAINT CO.
MCCARTY  PAINT CO.
MCWHORTER  INC.
MEDUSA CEMENT CO.
MERCURY  PAINT CORP.
MERECO DIVISION
MERICHEM CO.
METALCRETE MFG. CO.
MIDWEST  LACQUER MFG.
MILLER PAINT CO.
MINUTEMAN  INC.
MINWAX CO. INC.
MISSION  OFFSHORE  INC.
MOHAWK FINISHING  PRODUCTS INC.
MOLINE PAINT MFG.
MORTELL  CO.
MORTON INTERNATIONAL
MT. MORRIS COATINGS INC.
N. JOSTEN  &  CO. INC.
N.I.G. CO.
N.Y. BELL  PAINT
NA COATINGS
NANKEE ALUMINUM PAINT CO. INC.
NATIONAL AEROSOL  PRODUCTS CO.
NATIONAL BRONZE POWDER CO.INC.

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Page No.     9
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury

COMPANY
NATIONAL CHEMICAL PLASTICS CO.
NATIONAL COATINGS INC.
NATIONAL LACQUER & PAINT CO.
NATIONAL MARINE PAINT CORP.
NAZ-DAR CO.
NAZ-DAR/KC ATLANTA
NCH CORP.
NELSON PAINT CO.
NELSON PAINT CO. OF OREGON
NELSON TECHNICAL COATINGS INC.
NEW YORK BRONZE POWDER CO.INC.
NILES CHEMICAL PAINT CO.
NOR-COTE INTERNATIONAL
NORFOLK CORP.
NORTH AMERICAN PAINT CORP.
NORTHERN COATINGS & CHEMICAL
NORTHERN INDUSTRIES INC.
OCEAN COATINGS INC.
OKON INC.
OLD WESTERN PAINT CO. INC.
OMNI INDUSTRIAL COATINGS INC.
ORELITE CHEMICAL
ORGANIC PRODUCTS CO.
ORLEANS PAINT CO. INC.
P. D. GEORGE CO.
P. F. I. INC.
PAINT ENGINEERING
PAINT PRODUCERS INC.
PAJCO PRODUCTS INC.
PALMER PAINT PRODUCTS INC.
PAN AMERICAN COATING INC.
PAN CHEMICAL CORP.
PARAGON PAINT & VARNISH CORP.
PARIS PAINT & VARNISH CO. INC.
PARKER PAINT MFG. INC.
PATRIOT PAINT CO. INC.
PCA ENGINEERING INC.
PEARL PAINTS NORTH AMERICA INC
PEERLESS COATINGS INC.
PEERLESS INDUSTRIAL PAINT CO.
PENTAGON PLASTICS INC.
PERFECTION & LETZ PAINT MFG.
PERFORMANCE COATINGS UNLIMITED
PERFORMANCE POLYMERS INC.
PERMA INC.
PERMAGILE INDUSTRIES INC.
PERMALUME PLASTICS CORP.
PERMITS CORP.
PETRI PAINT CO. INC.

-------
Page No.     10
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury

"COMPANY
PETTIT PAINT CO.
PIEDMONT PAINT MFG.'CO.
PIEDMONT PAINTS PRIMERS INC.
PIERCE & STEVENS CORP.
PILGRIM PERMOCOAT INC.
PILOT PAINT CO. INC.
PIONEER PAINT & VARNISH CO.
PIONEER PAINT PRODUCTS INC.
PLAS-CHEM COATINGS
PLASTI-KOTE CO. INC.
POLY-CARB INC.
POLY-LUX INC.
POLYCHEM CORP.
POLYMER PLASTICS CORP.
POLYTEX COLOR & CHEMICAL CORP.
POTTER PAINT CO. INC.
POTTER PAINT CO. OF IND. INC.
PRATT & LAMBERT INC.
PRECISION TECHNICAL COATINGS
PREMIER COATINGS INC.
PREMIUM FINISHES INC.
PRESERVO PAINT & COATINGS MFG.
PRESTON PACIFIC CORP.
PRILLAMAN CHEMICAL CORP.
PRIME LEATHER FINISHES CO.
PRODUCTION FINISHES INC.
PRODUCTS/TECHNIQUES INC.
PROFESSIONAL COATINGS INC.
PROSOCO INC.
PROTECTIVE COATING SYSTEMS INC
PRUETT-SCHAFFER CHEMICAL
PURE-COTE CORP.
PYRAMID PAINT PRODS. INC.
PYROLAC CORP.
QUALITY COATINGS INC.
R  &  A SPECIALTY CHEMICAL CO.
R. J. MCGLENNON CO. INC.
RAABE CORP.
RAFFI & SWANSON INC.
RAMPART COATINGS INC.
RANBAR TECHNOLOGY INC.
RANDOLPH PRODUCTS CO.
RAPPAHANNOCK COPPER PAINT CO.
RED  DEVIL COATINGS
RED  SPOT WESTLAND INC.
RELIABLE COATINGS INC.
RELIANCE UNIVERSAL INC.
RESEARCH SALES INC.
REVERE PRODUCTS
RICH ART COLOR

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Page No.    11
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury

COMPANY
RICHARDSON PAINT CO. INC.
RICO CHEMICALS
RIVER VALLEY COATINGS INC.
RIVERSIDE CHEMICAL CO. INC.
RM ENGINEERED PRODUCTS INC.
ROBINSON CHEMICAL COATINGS INC
ROBINSON PAINT PRODUCTS
ROCK-TRED CORP.
ROCKFORD COATINGS CORP.
ROLLIE WILLIAMS PAINT SPOT
ROMAN ADHESIVES INC.
ROWE PAINT MFG.
ROYMAL INC.
RPM INC.
RUDD CO. INC.
RUSTOLEUM CORP.
RUTLAND PRODUCTS
S. L. GILLMAN PAINT
S. P. KISH INDUSTRIES INC.
SADOLIN PAINT PRODUCTS INC.
SAFETY COATINGS INC.
SAGAMORE INDUSTRIAL FINISH COR
SAMUEL SMIDT CHEMICAL CORP.
SASHCO INC.
SAU-SEA SWIMMING POOL PRODUCTS
SAV-KOTE
SAVANNAH PAINT MFG. CO.
SAVOGRAN CO.
SEA MASTER MARINE COATINGS INC
SEIBERT OXIDERMO
SEM PRODUCTS INC.
SENTCO PAINT MFG.
SENTINEL PAINT & VARNISH CO.
SENTRY PAJMT TECHNOLOGIES INC.
SERMATECH INTERNATIONAL INC.
SERVICE COATINGS INC.
SEYMOUR OF SYCAMORE INC.
SHERWIN-WILLIAMS
SHUBERT PAINTS INC.
SIKA CORP.
SIMCO COATINGS INC.
SINCLAIR PAINT CO.
SINNETT-ELPACO COATINGS CORP.
SMITH PAINT PRODUCTS
SNYDER BROTHERS CO.
SOCCO PLASTIC COATING CO.
SOLAR PAINTS & VARNISHES INC.
SOLVENT RECOVERY CORP.
SOPHIE CO.
SOPHIR - MORRIS

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Page No.    12
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury
«v>
COMPANY
SOPHIR CO. INC.
SOUTHEASTERN PAINT MFG. LTD.
SPARTAN LACQUER & PAINT CORP.
SPECIALTY COATING CORP.
SPECIALTY COATINGS & CHEMS INC
SPECIALTY COATINGS CO.
SPECTRUM COATINGS LABORATORIES
SPECTRUM PAINTS INC.
SPENCER-ADAMS PAINT CO.
SPRAYLAT CORP.
SPRUANCE CO. INC.
STAINLESS STEEL COATINGS INC.
STAMPS SALES INC.
STANCHEM INC.
STANDARD COATING CORP.
STANDARD T CHEMICAL CO. INC.
STANDARD TECH. APPLIED RESQURC
STAR BRONZE CO.
STAY NEW PAINT CORP.
STEADFAST INC.
STEBBINS & ROBERTS INC.
STEELCOTE MANUFACTURING CO.
STERLING LACQUER MFG. CO.
STEWART BROS. PAINT CO.
STO CORP.
STONHARD INC.
STRATHMORE PRODUCTS INC.
STRICKER PAINT PRODUCTS INC.
STUART INDUSTRIAL COATINGS  INC
SULLIVAN CHEMICAL COATINGS
SUMMIT INDUSTRIAL COATINGS  INC
SUNBELT COATINGS INC.
SUNNYSIDB CORP.
SUPERIOR COATINGS INC.
SUREGUARD INC.
SURFACE PAINT CO.
SURFACE RESEARCH CORP.
SYNTHETIC SURFACES INC.
TACC  INTERNATIONAL CORP.
TALSOL CORP.
TAPECOAT CO.
TECHNICAL COATINGS CO.
TECHNICAL COATINGS LABORATORY
TEMPO PRODUCTS CO.
TENAX FINISHING PRODUCTS CO.
TESTOR CORP.
TEX ENTERPRISES INC.
THEMEC CO. INC.
THERMAL SCIENCE INC.

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Page No.    13
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury

COMPANY
THERMOCLAD CO.
THOMPSON & FORMBY ING.
THORO SYSTEM PRODUCTS
TI-KROMATIC PAINTS INC.
TIOGA INTERNATIONAL INC.
TITAN FINISHES CORP.
TN. TECHNICAL COATINGS CORP.
TNEMEC CO. INC.
TREMCO INC.
TREMEC CO. INC.
TRI-CHEM INC.
TRIAL CHEMICAL CORP.
TRIPLE G COATINGS INC.
TW GRAPHICS GROUP
U-C COATINGS CORP.
U.S. PAINT CORP.
U.S. YACHT PAINT CO. INC.
UNICHEM COATINGS CO.
UNION INK CO. INC.
UNION TANK CAR CO.
UNITED COATINGS INC.
UNITED GILSONITE LABORATORIES
UNITED PAINT CO. INC.
UNIVERSAL CHEMICALS & COATINGS
UNIVERSAL COOPERATIVES INC.
USG CORP.
V. J. DOLAN & CO. INC.
VALLEY PAINT MFG.
VALSPER CORP.
VANEX COLOR INC.
VANGUARD PAINTS & FINISHES INC
VERSATILE MORAN PAINT PROD. CO
VICKERS INDUSTRIAL COATINGS
VIMASCO CORP.
VOPLEX CORP.
W. C. RICHARDS CO.
W. C. RICHARDS CO. OF CAROLINA
W. J. RUSCOE CO.
W. R. GRACE & CO,-CONN
WABASH PRODUCTS CO.
WAMPLER CHEMICAL CORP.
WASHINGTON PAINT PRODUCTS INC.
WATERLAC INDUSTRIES INC.
WATERSHED SALES CORP.
WATSON STANDARD CO.
WAUKEGAN PAINT & LACQUER CO.
WCC INDUSTRIES'
WELLBORN-DE CORP.
WESLEY LACQUER CORP.

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Page No.     14
05/31/90
                          Paint Manufacturers
                         Who Do Not Use Mercury
*>
«r> ~
COMPANY
WESTFIELD COATINGS CORP.
WESTINGHOUSE ELECTRIC CORP.
WHITFORD CORP.
WHITTAKER COATINGS
WIENERT
WILLAMETTE VALLEY CO.
WILLIAMS-HAYWARD PROTECTIVE
WILSON IMPERIAL CO.
WILSON PAINT CO.
WISCONSIN PROTECTIVE COATINGS
WISE CHEMICAL CO. INC.
WLS COATINGS INC.
WM. ZINSSER & CO. INC.
WOOD FINISHING SUPPLY CO.  INC.
WOOD-KOTE PRODUCTS INC.
XIM PRODUCTS INC.
ZEHRUNG CORP.
ZEHRUNG CORP.
ZENITH PRODUCTS
ZOLATONE

-------
                            SUPPLEMENT

                       Paint Manufacturers
                      Who Do Not  Use Mercury
COMPANY
3M COMPANY
A.F.WOLKE COMPANY, INC.
A.H. THOMPSON COMPANY
ACUSTAR INC.
AJAX FLOOR PRODUCTS CORPORATION
AKZO RESINS & VEHICLES
AKZO-LANCHEM
ALL PURPOSE MARINE PAINTS
AMERICAN TAR COMPANY
APPLIED POLYMERS OF AMERICA
AVONDALE SPECIALTY PRODUCTS
BRINER PAINT MFG. COMPANY, INC.
C.A. REEVE PAINT COMPANY, INC.
CHRYSLER/ACUSTAR CHEMICAL.
CONSOLIDATED COATINGS CORPORATION
CROWN INDUSTRIAL PRODUCTS COMPANY
CUSTOM BUILDING PRODUCTS
D-B INDUSTRIES, INC.
DAY-GLOW COLOR CORPORATION  '•
DEL PAINT MFG.
DELTA TECHNICAL COATINGS
DUNCAN ENTERPRISES
E-DELEPAINT PRODUCTS COMPANY, INC.
E.I. DUPONT DE NEMOURS & COMPANY
EMPIRE INDUSTRIAL COATING
EPOXY COATINGS COMPANY
FARBOIL COMPANY
FASCO UNLIMITED OF HIALEAH, INC.
GEMINI AEROSOLS, INC.
GIBSON" PAINT COMPANY
HAMPTON PAINT MFC COMPANY INC.
HARDIG PAINT
HILLYARD CHEMICAL
INTERSTATE PAINT CORPORATION
JOHNSON PAINTS INC.
KNS COMPANIES, INC.
LACQUER-MAT SYSTEMS INC.
LOES ENTERPRISES INC.
MANTROSE-HAEUSER COMPANY
MASCO PAINT MANUFACTURING
MODEL WALLPAPER & PAINT COMPANY
MORTON PAINT COMPANY
NATIONAL POLYMERS, INC.
NATIONAL VARNISH COMPANY
PAINT AMERICA COMPANY
PARKER COATINGS INC.
PERFORMANCE COATINGS, INC.

-------
                            SUPPLEMENT

                       Paint Manufacturers
                      Who Do Not  Use  Mercury
COMPANY
PRE FINISH METALS
PRODUCTS/TECHNIQUES INC.
REED-UNION CORPORATION
RULE INDUSTRIES INC.
SEABOARD ASPHALT PRODUCTS COMPANY
SOLAR COMPOUNDS CORPORATION
SOUTHERN COATINGS INC.
SOUTHERN STYLE PAINT MFG.
SPECIALTY MARINE COATINGS
STRUCTURAL COATINGS
T.J. RONAN PAINT CORPORATION
THERMOCLAD COMPANY
W.J. LYNCH PAINT & VARNISH
WESTERN STATES LACQUER CORPORATION
ZARCO INDUSTRIAL FINISHES

-------
Page No.     1           I	 I ~>  '
06/04/90
                             Project Mercury
                       Companies Who Use Mercury

Company Name                   <•                *•**•***•
ACRYLUX PAINT MFG. CO.
ALADDIN PAINT MFG. CO. INC.
AMERITONE PAINT CORP.
AMERON ENMAR FINISHES DIV.
AMERON PCD
AMTECO INC.
ANVIL PAINTS & COATINGS INC.
ARMOR PAINTS INC.
ARTCO NATIONAL CORP.
ATECH INC. OF FLORIDA
BEL-MAR PAINT CORP.
BERKLEY PRODUCTS CO.
BEXREL COATINGS CORP.
BLACK & PURYEAR PAINT MFG. CO.
BLUE RIDGE TALC CO. INC.
BOND CHEMICAL MFG.
BRADLEY PAINT CO.
BRIDGES-SMITH & CO. INC.
BROD-DUGAN CO.
BRUNSWICK PAINT CO.
BURKE'S PAINT CO. INC.
CAL WESTERN PAINTS INC.
CALIFORNIA PRODUCTS CORP.
CANSTO PAINT & VARNISH CO.
CAPITOL CITY PAINT CO.
CARBOLINE CO.
CENTERLINE INDUSTRIES INC.
CHEMEX PAINT & COATINGS INC.
CLARK PAINT & VARNISH CO.  INC.
COATINGS DEVELOPMENT CO.
COLORADO PAINT CO.
COLORAMA PAINT CO.
COLUMBIA PAINT CO.
COLUMBIA PAINT CORP.
COLUMBIA PAINT LAB INC.
CON-LUS COATINGS INC.
CONTRACT COATINGS CORP.
COOK & DUNN PAINT CORP.
CORONADO PAINT CO.
COURTAULDS COATINGS
CRAIZIE PAINT CO.
CREATIVE COATINGS INC.
CROSBY COATINGS INC.
CYPRESS PROTECTIVE COATINGS
CZS ENTERPRISES
DAMPNEY CO. INC.
DAN-TEX PAINT & COATING MFG.CO
DAVIS PAINT CO.
DAVIS PAINT MANUFACTURERS
DAVLIN PAINT CO.

-------
Page No.     2
06/04/90
                            Project Mercury
                       Companies Who Use Mercury

Company Name
DEHART PAINT VARNISH CO.
DELAWARE VALLEY PAINT CO.
DELTA LABORATORIES INC.
DESOTO INC.
DEXTER CORP.
DOUGLAS CHEMICAL CO. INC.
DOZIER & GAY PAINT CO.
DUO PAINTS OF ELKHORN INC.
DUPACO PAINT INC.
DURON INC.
DUX PAINTS & CHEMICALS INC.
DYCO PAINTS INC.
EARLY AMERICAN PAINT & VARNISH
EASTERDAY PAINT & CHEMICAL CO.
ELITE COATINGS
ELIXIR INDUSTRIES
EMPIRE PAINT MFG. CO.
ERIE COATINGS & CHEM.
ERIE PAINT & WALLPAPER INC.
EVANS PAINTS INC.
EVR-GARD COATINGS CO.
FARMLAND INDUSTRIES
FARRELL-CALHOUN INC.
FARWEST PAINT MFG. CO.
FINE LINE PAINT
FINNAREN & HALEY INC.
FLORIDA PROTECTIVE COATINGS
FRAZEE INDUSTRIES INC.
FREDERICKS HANSEN PAINT CO.
FUTURA COATINGS INC.
FUTURE SYSTEMS
GACO WESTERN INC.
GATOR PAINT MFG.
GEORGE KIRBY JR. PAINT CO.
GILLESPIE COATINGS INC.
GILMAN/JONES-BIAIR
GLIDDEN CO.
GROCO PAINT MFG. CO.
GUARDSMAN PRODUCTS INC.
H-I-S PAINT MFG. CO. INC.
H. B. FULLER CO.
HANCOCK PAINT & VARNISH CO.
HANLEY PAINT MFG. CO. INC.
HARRISON PAINT CORP.
HENRY CO.
HIRSHFIELD'S PAINT MFG. INC.
HOBOKEN PAINTS INC.
HUMBOLDT PAINT FACTORY
HY-KLAS PAINTS INC.
IMPERIAL PAINT CO.

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Page No.     3
06/04/90
                            Project Mercury
                       Companies Who Use Mercury

Company Name
INDURALL COATINGS INC.
INTERCHEM INC.
IOWA PAINT MFG. CO. INC.
J. S. WILLIAMS & SONS
JAY BEE PAINT CO.
KALCOR COATINGS CO.
KANSAS PAINT & COLOR CO.
KELLEY TECHNICAL COATING INC.
KELLY-MOORE PAINT CO. INC.
RISER PAINT INC.
KLINGER PAINT CO. INC.
KOOL SEAL INC.
KOP-COAT INC.
KURFEES COATINGS
KYANIZE PAINTS
L & L COATINGS CORP.
LANCI INDUSTRIES INC.
LANDZETTEL & SONS
LUNA PAINTS CORP.
LYLE VAN PATTEN CO. INC.
M&R & SONS INC.
MAHONING PAINT CORP.
MAJOR PAINT CO.
MARCUS PAINT CO.
MARTEE IND.
MASON PAINT CO. INC.
MAUTZ PAINT CO.
MCCORMICK PAINT WORKS CO.
MCI QUALITY COATINGS
MICHIGAN INDUSTRIAL FINISHES
MID STATES PAINT & CHEM. CO.
MID-AMERICA PAINT CO.
MISSOURI PAINT & VARNISH CO.
MOBILE PAINT MFG. CO. INC.
MONARCH PAINT CO.
MONSEY PRODUCTS CO.
MURCO WALL PRODUCTS
NORRIS PAINT CO.
NORTH JERSEY PAINT CO.  INC.
NORTON & SON INC.
NUBRITE CHEMICAL CO. INC.
O'BRIEN CORP.
O'LEARY PAINT CO.
OLD QUAKER PAINT CO.
OLIVER PAINT MFG. CO. INC.
OSAGE PAINT & VARNISH CO.
P.H.K. PRODUCTS INC.
PAINT MART
PALM PAINTS
PARAGON PAINT & LACQUER INC.

-------
Page No.     4
06/04/90
                            Project Mercury
                       Companies Who Use Mercury

Company Name
PASSONNO PAINTS
PEN PAINTS INC.
PENN JERSEY PAINT CO.
PERFECTION PAINT & COLOR CO.
PERRY & DERRICK CO.
PERVO PAINT CO.
PIONEER COATINGS INC.
PLASTIC COATINGS CORP.
POLYTECH COATINGS INC.
PONDEROSA PAINT CO.
PORT CITY PAINTS
POVIA PAINTS INC.
PPG ARCHITECTURAL FINISHES INC
PPG INDUSTRIES (DOVER)
PPG INDUSTRIES INC.
PRECISION IND. CTG.
PRECISION PAINT CORP.
PRIDE PAINT CO.
PRIDE PAINTS
PRO-LINE PAINT CO.
PROGRESS PAINT MFG. CO. INC.
PURITAN PAINT & OIL CO.
RASMUSSEN PAINT CO.
RED MILLS PAINT & CHEMICAL CO.
RED SPOT PAINT & VARNISH CO.
REPCOLITE PAINTS
REPUBLIC POWDERED METALS
RICH PAINT MFG. INC.
RICHARD'S PAINT MFG. CO.
RODDA PAINT CO.
ROSE TALBERT PAINT CO.
ROY ANDERSON PAINT CO.
SAMPSON COATINGS INC.
SAMUEL CABOT INC.
SAN JACINTO PAINT MFG. CO.
SAN LUIS PAINTS
SANDSTROM PRODUCTS CO.
SCOTT PAINT CORP.
SHEBOYGAN PAINT CO.
SHERBURN PAINT CORP.
SIERRA CORP.
SIGMA COATINGS
SMILAND PAINT CO.
SOMAY PRODUCTS INC.
SOUTHERN COATINGS INC.
SOUTHWESTERN PAINT & VARNISH
SPECTRATONE PAINT CORP.
SPECTRUM DISPERSIONS INC.
ST. LOUIS PAINT MFG. CO.
STABLER PAINT MFG. CO.

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 Page No.
                          Project  Mercury
                     Companies Who Use Mercury
Company Name
STAHL USA
STANDARD  (DETROIT) PAINT CO.
STERLING CLARK LORTON CORP.
STILES PAINT MFG. INC.
SUN COATINGS INC.
SUNLIFE INC.
SUNTEC PAINT INC.
SUPERIOR SEALANTS
SURFACE PROTECTION INDUSTRIES
TANNER PAINT CO.
TEXTURED COATINGS OF AMERICA INC.
TOLEDO PAINT & CHEMICAL CO.
TOOL WORLD INC.
TOURAINE PAINTS INC.
TOWER PAINT MFG. CO.
TRESCO PAINT CO. INC.
TRIANGLE COATINGS INC.
UCI PAINT FACTORY
UNITED PAINT & CHEMICAL
UNITED PAINT & VARNISH CO.
UNITED PAINT MFG. CO.
UNIVERSAL PAINT PRODUCTS CO.
UP COATINGS INC.
VAN SICKLE PAINT MFG. CO.
VELCO INC.
VERFLEX CO. INC.
VIKING PAINTS INC.
VISTA PAINT CORP.
VOGEL PAINT & WAX CO. INC.
WARLICK PAINT CO. INC.
WARREN PAINT & COLOR CO.
WATERLOX CHEMICAL & COATINGS
WHITTAKER CORP.
WILCO PAINT INC.
WILTECH CORP.
YENKIN-MAJESTIC PAINT CORP.
ZPC INDUSTRIAL COATINGS

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                            SUPPLEMENT

                       Paint Manufacturers
                        Who Do  Use  Mercury
COMPANY
AMERICAN HOME PAINT PRODUCTS INC.
B-B PAINT CORPORATION
BEST BROTHERS PAINT MFG. CO., INC.
BRINK PAINT MFRS INC.
BLUE RIBBON QUALITY PAINTS
BOLCE PAINT COMPANY
CAL-TONE PAINTS, INC.
COMMERCIAL CHEMICAL
CROSSCO AMERICA CORPORATION
CROWN PAINT COMPANY
D.J. SIMPSON COMPANY
DIAMOND PAINT COMPANY
DURANT PAINTS INC.
DURRELL PAINT AND VARNISH COMPANY
FOUR SEASONS PAINT MFG. COMPANY
HALLMAN PAINTS, INC.
HAWTHORNE PAINT COMPANY, INC.
HOFFERS INC.
IOWA PAINT MANUFACTURING COMPANY, INC.
JASPER CHEMICAL COATINGS
KALCOR COATINGS, INC.
LASTING PAINTS, INC.
MAINLINE PAINT MFG. COMPANY
MERRIFIELD PAINT COMPANY, INC.
MORTON INTERNATIONAL
P.H.K. PRODUCTS, INC.
PARKS CORPORATION
PARKS PAINT AND VARNISH COMPANY
PENNSBURY COATINGS CORPORATION
RAINBOW COATINGS CORPORATION
SALEM PAINT COMPANY INC.
SCHULTE PAINT MFG. COMPANY INC.
STANDARD PAINTS, INC.
TALON PAINT PRODUCTS INC.
WELCO MANUFACTURING COMPANY
WIKEL MFG. COMPANY, INC.
WILSHIRE PAINT COMPANY

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                     June 29, 1990

              QUESTIONS AND ANSWERS ABOUT
                    MERCURY  IN PAIMT
What is the Environmental Protection Agency (EPA) doing
about mercury-containing paint?

EPA is concerned about the use of mercury in interior
paints.  As a result of this concern, the manufacturers of
mercury products have voluntarily agreed to eliminate the
use of mercury in indoor latex paint.  In addition, warning
labels will be required on all outdoor paint containing
mercury stating that the product should be used only
outdoors.

EPA believes that it is preferable that consumers use paints
which do not contain mercury when painting indoor surfaces.
Effective on August 20, all further production of paints
containing mercury must be labeled exclusively for exterior
use.  To deal with existing stocks of paint containing
mercury, the National Paint and Coatings Association is
working with paint manufacturers to relabel all paints with
higher mercury levels (over 200 parts per million) for
exterior use only.  EPA believes that consumers may continue
to use interior paint with lower mercury levels  (200 parts
per million or less) without unreasonable risk if they
follow all label directions and use the following
precautions:

o    Ventilate the area thoroughly by opening windows for as
     long as possible and practical.  If possible, place a
     fan in or near an open window to enhance circulation
     and draw the paint fumes outside.

o    Tightly seal any unused cans of paint and store them
     out of the reach of children until they can be disposed
     of properly.

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Q    Why is the EPA concerned about mercury biocides in paint?

A    EPA's concern regarding mercury stems from a recent case of
     acrodynia (a type of mercury poisoning) in a 4-year old
     child whose Michigan home was painted in July 1989 with
     interior paint containing three times the usual level of
     mercury (930 parts per million vs. 300 parts per million).
     Acrodynia is a rare form of mercury poisoning which usually
     occurs in children and is characterized by weakness and
     severe pain in the extremities; pinkness and peeling of the
     hands, feet, and nose; irritability; sweating; and a rapid
     heartbeat.  The effects seen in the Michigan child were
     severe and the pain and weakness in his muscles made him
     unable to walk.  After treatment, the child is much
     improved.   EPA is concerned not only about the possibility
     of other acrodynia cases, but also about other health
     effects which may result from exposure to mercury in paints.
     Children,  painters, and the general population could
     experience these effects.

Q    What are the signs/symptoms of mercury poisoning?

A    Mercury primarily affects the nervous system and the
     kidneys.  Symptoms can intensify and may become permanent as
     exposure duration and/or concentration increases.  Among the
     signs that have been noted are:  l) slight tremors,
     particularly affecting the hands and interfering with fine
     motor control such as handwriting, 2) erethism, a syndrome
     characterized by various levels of insomnia, shyness, and
     emotional instability, 3) decreases in motor function and
     muscle reflexes, 4) short term memory loss, 5) headaches,
     and 6) abnormal EEGs (a graphic record of the electrical
     activity of the brain).

Q    Why are mercury compounds used in paints?

A    Mercury is used in some water-based latex paints to preserve
     the paint while it is in the can by controlling bacterial
     and fungal growth.  It is also used in some exterior paints
     to protect the paint film from mildew attack after it is
     applied.

Q    Do all paints contain mercury?

A    Approximately 25 to 30 percent of interior latex paint  and
     20 to 35 percent of exterior latex paint contains mercury.
     Mercury is not used in oil-based paint.  The use of mercury
     has decreased since 1976, when all but a few of the
     pesticidal uses were cancelled because of concerns about
     release of mercury into the environment.  The pesticidal use
     of mercury in paint was retained  in 1976 because of concerns

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     about the availability of effective alternatives.   More
     alternatives are available and used today.

Q    Can the mercury in paint get into the air inside my house?

A    Yes.  Mercury present in paint can vaporize into the indoor
     air environment, with levels highest during and immediately
     following painting.  EPA is currently conducting studies to
     determine the rate at which mercury vapors  are released
     after the paint is applied, the actual concentrations in the
     air, and the amount of time it takes mercury to dissipate.
     Studies indicate that mercury concentrations decrease a
     number of days after painting.  However, lower
     concentrations may be present in the indoor air for months
     following painting.

Q    How do I determine if the paint I purchased or used in my
     house contains mercury?

A    Until now, paints that contained mercury were not required
     to list it as an ingredient on the product  label.
     Therefore, EPA, the National Paint and Coatings Association,
     and paint manufacturers nationwide have compiled information
     on which paints contain mercury.  Information on whether a
     specific paint contains mercury is available through your
     State Health Department, the State Department responsible
     for pesticide regulation (usually the Department of
     Agriculture), EPA Regional Offices, and the National
     Pesticide Telecommunication Network (NPTN).  The toll free
     telephone number for NPTN is 1-800-858-7378.  Also,
     consumers may wish to contact the paint manufacturer
     directly to obtain this information.  In the future, mercury
     will not be used in interior paints.  Exterior paints
     containing mercury will be clearly labeled to state that the
     product contains mercury.

Q    If my house has been painted with a mercury paint, what can
     I do to minimize exposure to mercury?

A    Consumers whose homes recently have been painted with
     mercury-containing paint can take a number of steps to
     reduce potential risks that may be associated with the use
     of this paint.  Ventilate the area thoroughly by opening
     windows for an extended period of time after painting.  If
     possible, place a fan in the window to enhance circulation
     and draw the fumes outside.  Tightly seal any unused cans of
     paint and store out of the reach of children until they can
     be disposed of properly.

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Q    If my house has been recently painted with a mercury-
     containing paint, should I consult with a physician to
     determine if I should be tested for mercury exposure?

A    No.  At this time, EPA does not believe widespread testing
     is necessary, and testing should only be conducted on  the
     recommendation of a physician.   If you or a family member
     are experiencing symptoms of mercury poisoning,  contact  your
     family physician.  As you may be aware, mercury  is a
     naturally occurring element, thus low background levels  of
     mercury are normally present in the body — and  are not
     cause for concern.

Q    What if someone in my family is showing symptoms of mercury
     poisoning?

A    Consult a physician.  In addition, thoroughly ventilate  the
     painted area for as long as possible.

Q    Should I have the air in my house tested for mercury?

A    No.  EPA does not believe that testing the air in homes  is
     necessary.  Again, if you have recently painted, we strongly
     recommend ventilating the area thoroughly.
Q    Are professional painters at greater risk of mercury
     poisoning than the general population?

A    EPA believes professional painters face a greater potential
     risk depending on the brand(s) of paint used.  EPA has
     required the manufacturers of mercury biocides to conduct a
     painter exposure study so that we may better estimate  the
     risks to painters using exterior paints.

Q    How can I dispose of unused cans of mercury-containing
     paint?

A    Do not pour leftover paint down the sink, drain, or into the
     toilet.  Mercury in aquatic systems could interfere with the
     operation of wastewater treatment systems or could pollute
     waterways, and cause serious injury to animals as well as
     humans.

     If the paint is a household waste (which means any waste
     material derived from households, including single and
     multiple residences, hotels and motels, bunkhouses, ranger
     stations, crew quarters, campgrounds, picnic grounds,  and
     day-use recreation areas) it may be disposed of as follows:

          Contact the Household Hazardous Waste collection
          program in your community to see  if  it will accept your
          paint.  To find the location and hours of operation,
          contact your State Health Department or solid waste

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          management agency.  This is the preferred method  of
          disposal.

          If no community programs exist, consumers should
          consult their local governments for proper means  of
          disposal.

          Empty paint cans should not be reused.

          To find out more about paint disposal requirements  in
          your area, contact your State Health Department,  your
          solid waste management agency, or an EPA Regional
          Office.

     If the paint is a business waste, disposal of mercury-
     containing paint is subject to the Resource Conservation and
     Recovery Act (RCRA) regulations unless the waste is within
     the scope of the household waste exclusion.   If you are  a
     business disposing of mercury-containing paint, you may  be
     subject to RCRA regulations, depending on the concentration
     of mercury in the paint and the quantity of all hazardous
     waste that is generated by your business each month.
     Contact the RCRA/Superfund Hotline (In Washington, D.C.:
     382-3000; Toll-free:  800-424-9346) for further information.

Q    Is the paint manufacturer or retailer responsible for
     refunding my money or replacing my unused can of paint that
     contains mercury?

A    Paint manufacturers and retailers are not required to
     provide refunds for or replace paint containing mercury.
     However, you can ask the store where you purchased the paint
     about its return policy.

Q    Do exterior mercury-containing paints present the same type
     of problem?

A    We expect exposure to mercury while painting outdoors to be
     significantly lower than indoor use because of the rapid
     dilution of paint fumes by the air.  However, exterior
     paints may contain a higher level of mercury than interior
     paints, so it is very important that exterior paint not be
     used indoors.  A warning statement is now required on
     exterior paint cans which tells painters that the paint
     contains mercury and instructs them not to use indoors.
     Pregnant women and children should not apply or assist in
     applying mercury-containing paint.  EPA has required mercury
     manufacturers to develop and submit additional data
     concerning use of mercury in exterior paints.  We will
     examine mercury exposure from exterior paints  further after
     receipt of the data.  Businesses-, schools, homeowners, etc.,
     should never purchase exterior mercury-containing paint to

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     use on interior surfaces even if available at reduced
     prices. "

Q    How long will mercury-containing paint remain on the shelves
     of paint and hardware stores?

A    EPA economists and industry experts believe that paint
     supplies in the marketplace are turned over about every
     three months, although some paint may be found on the
     shelves for longer periods.

Q    How else is mercury used?

A    Other uses of mercury include:  thermometers; instruments
     that are atmospheric-pressure sensitive; mercury vapor and
     fluorescent lamps; fungicides; preservatives; and dry cell
     batteries.
Q    Besides paint, how are people exposed to mercury?

A    Mercury is a naturally occurring element which is present in
     very low concentrations throughout our natural environment.
     It is found in the air we breathe, the food we eat, and the
     water we drink.

Q    Does EPA expect the paint industry to incur significant
     economic costs?

A    Many paint manufacturers do not currently use mercury
     compounds in their paint formulations and, therefore, would
     not be adversely affected by the elimination of interior
     uses.   However, paint manufacturers currently using mercury
     compounds may incur significant short-term economic costs.
     This situation might arise if a manufacturer is unable to
     reformulate its products by August 20th.  In that event, the
     company would have to cease production of affected products.
     Production halts could result in plant closures if a
     significant portion of a company's sales are affected.

     Due to the availability of cost-effective alternatives, EPA
     does not expect there to be substantial long-term economic
     impacts to the industry.

Q    Will the price of paint increase at the consumer level?

A    There may be a short-term increase in the price of interior
     paint, if temporary production halts  (mentioned above) occur
     and less paint is available.  However, EPA expects that
     production of paint that does not contain mercury will
     increase and the prices will stabilize.

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                                7

Q    Are there alternatives to mercury and do they also pose
     health problems?

A    Alternatives do exist.  Based on the data available, EPA
     does not believe that they pose unreasonable risks.
     However, paints contain many chemicals and it is always a
     good idea to ventilate well when using any paint.

Q    Who may I contact for additional information?

A    The EPA operates the National Pesticide Telecommunication
     Network (NPTN).  This is a toll free telephone service
     available 24 hours a day, 7 days a week, to provide a
     variety of information about pesticides to anyone in the
     contiguous United states, Puerto Rico and the Virgin
     Islands.  The toll free telephone number is 1-800-858-7378

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